Public Utility Commission

City of Fa rming ton Wa ter/Wa stewa ter AGENDA ……for the regular meeting of the Public Utility Commission of the City of Farmington, on Wednesday, July 10, 2024 at 3:00 pm in the Executive Conference Room, City Hall, 800 Municipal Dr., Farmington, New Mexico. I. GENERAL A. Roll Call B. Convening of Meeting by Mr. Tory N. Larsen, Chair 1. Approval of Minutes - May 8, 2024 Regular meeting II. BUSINESS 2. ACTION: Open Meetings Resolution - Jennifer Breakell 3. O&M Water/Wastewater Operations Report - Benedikte Webb 4. Water/Wastewater CIP Update - Mark Hathcock 5. Electric Utility Report - Sheree Wilson 6. Discuss AMI Matters/Discontinue Cash Payments in the Field - Hank Adair ACTION: AMI Opt-Out Policy and Remote Connect/Disconnect Fee ACTION: Discontinue accepting cash payments in the field 7. Director’s Report - Hank Adair III. BUSINESS FROM THE FLOOR Citizens who wish to address the committee shall sign in prior to the start of the meeting. Comments are accepted in person and limited to 3 minutes. No formal action will be taken at this meeting that relates to comments or input from the General Public. IV. ADJOURNMENT The next regular meeting will be held August 14, 2024 The City of Farmington will make every effort to provide reasonable accommodations for people with disabilities who wish to attend a public meeting. If you need to request that an accommodation be made, please notify the Electric Administration office (599-1160) at least 24 hours prior to the meeting.  BOARD OF PUBLIC UTILITY COMMISSION The regular meeting of the CITY OF FARMINGTON BOARD OF PUBLIC UTILITY COMMISSIONERS was held Wednesday, May 8, 2024 at 3:00 p.m., in the Executive Conference Room, City Hall, 800 Municipal Dr., Farmington, New Mexico in full conformity with the laws and ordinances of the Municipality. Upon roll call, the following were found to be present, constituting a quorum: Commission members present: Tory N. Larsen Connie Dinning Patricio Sanchez Nathan Thompson Linda Corwin John Buffington Diane Schmidt Stewart Logan Commission members absent: George Sharpe Drew Degner Council Liaison: Janis Jakino constituting all members of said Advisory Commission. Also present were: Electric Utility Director Hank Adair Electric Engineering John Armenta Electric Field Operations Luke Lugenbeel Electric Business Operations Sheree Wilson Customer Service Nicki Parks Community Works Mark Hathcock Community Works Benedikte Webb Administrative Services Nalinee Jose Administrative Services Jim Cox PUC Secretary Amy McKinley The meeting was convened by the Chair. The Chair called for a motion to approve the Minutes of the April 10, 2024 Regular meeting. Commissioner Corwin offered a motion to approve the Minutes and Commissioner Sanchez provided a second. By voice vote the motioned passed. The Chair called for a motion to approve the Minutes of the April 10, 2024 Budget meeting. Commissioner Corwin offered a motion to approve the Minutes and Commissioner Sanchez provided a second. By voice vote the motioned passed. Vice-Chair Dinning arrived at 3:05 pm BUSINESS Customer Service Write-Offs Ms. Nicki Parks, Customer Care Manager, addressed the commission seeking a PUC recommendation to city council to write off inactive utility accounts aged over four years with a balance of $0.01 or more. She noted the amount being requested for the year ending December 31, 2019 is $154,338.90, 0.108092% of 2019 revenue. Industry standard is 1% for write-offs for utilities and the City of Farmington consistently stays well beneath this standard. Responding to a question posed by Commissioner Logan Ms. Parks states she feels the write offs for years 2020 and 2021 may be larger than normal due to the Covid pandemic. She anticipates year 2022 will return to a normal write off scenario. Chair Larsen asked if the parties included within the write off total continue to be in the system. Ms. Parks those delinquent customers do not have active utility service in their name. Even though a customer’s debt has been written off, if that customer wishes to have utility service, the bad debt must be collected prior to connection. The Chair called for a motion to recommend city council approval to write off uncollectible and unsecured utility accounts. Vice-Chair Dinning offered such a motion and the motion was seconded by Commissioner Buffington. Upon a voice vote, the motion passed unanimously. Electric Utility Report Ms. Sheree Wilson provided a PowerPoint presentation to detail FEUS financial information for March and April 2024. Ms. Wilson noted Customer Consumption is 7% under budget for April. Customer Consumption Fiscal Year to Date is 4% under budget. When comparing consumption to FY2023, Customer Consumption is down 5%, every class shows a decrease in consumption. The utility’s Cash Balance continues to improve from last year. Overall, FY2024 began with a Cash Balance of $25 million; currently the Cash Balance is $56 million, an increase of $31 million. Year to Date Revenue is $97.9 million, budget is $127 million. FY2024 Expenses for April were $86 million, 24% under the budgeted amount of $112 million. Major components are purchase power at 23% below budget and gas at 34% below budget. Year to Date Capital Improvement Expenses Budget is 39% under budget. The PCA rates continues to be $01.12/kWh. Through April 2024, FEUS has recouped $1.2 million via the PCA. Total Generation Cost per mWh for March 2024 was $67.76 per mWh. Utility Financial Statements Ms. Nalinee Jose offered a presentation detailing the quarterly financials for the 3rd Quarter ending March 31, 2024. Electric Utility The Net Income for the Electric Utility decreased $3.6 million from FY2023. Operating Revenues decreased $45 million. Electric Sales decreased $45 million largely due to a decrease in PCA sales. Operating expenses decreased by $32 million and fuel costs, natural gas and coal combined, decreased by $23.6 million, with Purchase Power costs down $5 million and Other operating expenses decreased $3.6 million largely due to the decrease in San Juan O&M. Non- operating Revenues increased $10.9 million, due to increases in interest income and revenue from grants; Non-operating Expenses decreased $1.1 million, due to decreases in the revenue transfer. Water Utility Net Income for the Water Utility increased $2 million from FY2023. Operating revenues increased $2.9 million and Operating expenses increased $1 million. Non-operating revenues increased $219 thousand and Non-operating expenses increased $67 thousand. Wastewater Utility The Net income for the Wastewater Utility increased $2.5 million from FY2023. Operating revenues increased $1.7 million and Operating expenses decreased $206 thousand. Non-operating revenues increased $241 thousand. Non-operating expenses decreased $339 thousand. Water and Wastewater Quarterly Financial Report Ms. Lynda Hayes offered a report detailing the financials for the Water and Wastewater utilities for the nine months ending March 31, 2024. Water Utility In Q3 of FY2024, the number of customers and meters remained constant from the prior year. The number of gallons YTD increased by 5.7% from FY2023. The YTD Water Utility Revenue Budget is $16.9 million with Revenue Actuals of $18.5 million; YTD Water Utility Expenditures Budget is $15.4 million with $15.4 million Actual Expenditures. Wastewater Utility The number of customers remained constant from the prior year. The number of Gallons YTD increased 6.9% from FY2023. The YTD Revenue Budget for the Wastewater Utility was $10 million with Revenue Actuals of $11.4 million. YTD Budgeted Expenditures were $7.4 million with Actual Expenditures of $6.8 million. Water/Wastewater O&M Report Utilizing a PowerPoint presentation, Ms. Benedikte Webb, Water/Wastewater Operations Manager/Environment Administrator provided information regarding water/wastewater operations activities for April 2024. The reported data indicated water production for April 2024 was 321 million gallons. Farmington Lake levels are very near capacity at 99.6%. Four new residential meters and two new commercial meters were installed inside city limits in April. There were three service line breaks, all were of black polyethylene, and two main line breaks in April. Regarding Wastewater treatment, effluent flow for April was 4.49 MGD. The report noted the Effluent BOD (Biochemical Oxygen Demand) was 6.13 mg/L; effluent TSS (Total Suspended Solids) was 5.92 mg/L; Effluent TDS Net Increase was 347.85mg/L; Effluent e.Coli saw a slight increase to 5.66 MPN/100ml but continues to remain well below the 100 mL limit. CIP Water/Wastewater Report Mr. Mark Hathcock, Water/Wastewater CIP Administrator, provided an update regarding capital projects planned and under way throughout the city. For Renewal and Replacement projects, work continues on the 2019 Polyline Replacement project. 1,570 polylines have been replaced and as of April 30, the project is approximately 63% complete. Regarding the federally funded Water Treatment Plant #1 project, staff is finalizing details with contractor Oscar Renda and waiting on the tentative schedule. Work is anticipated to begin within the next couple of weeks. Regarding the Feasibility Study for the Farmington Lake Dam Raising, the Biological Study is schedule for May 13. The Randolph Street Upgrade project (between Murray Dr. & S. Miller Street) where approximately 1,600 feet of 6” cast iron water line is being upgraded to 8” PVC, is nearing completion on May 10. The 16” PVC transmission line replacement on 30th Street (Marquette to Hutton) is tentatively scheduled to begin May 5. The Main/30th/Gila Loop project will reduce pressure zones by combining them. This project is set to go out to bid in the next couple of weeks. Director’s Report Mr. Hank Adair offered an update regarding activities within the electric utility. Regarding Customer Service, an update of the accounting software, Central Square, has caused a change to the billing format for net metering customers. Ms. Parks is planning a public meeting for net metering customers to discuss the changes and how to read the new bill format. The LiHEAP program provided 97 payments for $24,430.00. The LiHWAP program provided 11 payments for $2,257.00. The Utility Assistance Program provided help to 96 families for $21,876.00. There were 11,097 customer contacts in the month of March. Regarding Substation/Distribution/Transmission, crews completed the Bluffview Substation X411 bushing replacement. The X13 transformer for the Animas Substation should be delivered any day. Regarding Distribution, an overhead three phase regulator bank was installed on 24-03 circuit related to the Enterprise load. The Single phase OH line extension was completed for Rise Gymnastics. Underground inspections and maintenance on Circuit 51-03 is 80% complete. 145 AMI meters were installed in the system in April. Regarding Transmission, a transmission outage for pole over pole maintenance is taking place from Westloop to Praxair, which is in the Kirtland area. Regarding Generation resources, flows on the San Juan River were increased to 500 CFS making an increase to 11 MW at the Navajo Hydro Plant. At the Bluffview plant, the Steam Generator stator coils are expected to arrive on June 12 with installation completed and the unit back to operation by July 8. The rotor wedges have been removed and have been laser scanned to fabricate. The bolts based on elasticity will remain the same material to be fabricated and re- installed. Regarding new generation RICE, the utility is looking at an October 2025 in service date. The construction bid was awarded to Casey (MasTec). Project costs recently updated by MasTec at $45.5M. The Resources Recap for April 2024 showed 71,215 MwH, a 2.27% increase from April 2023. There were three circuit outages in April: one outage on the Giant Circuit (southeast of Bloomfield)-cause unknown; one outage on the Bisti Circuit southeast of Farmington due to wind that caused a broken arm; one outage on the Turley Circuit East of Bloomfield where a tree limb fell across two phases. FEUS was recognized by the American Public Power Association for Top Quartile Performance. This honor will be recognized by the City Council at the next council meeting. Regarding Solar, eleven customers for 68.3 kW connected in April. Total MW installed to date, including large commercial, is 4.2MW. FEUS is again participating in the Light Up Navajo project for two weeks in July. The utility received an Energy Efficiency and Conservation grant and work is set to proceed for the replacement of 81 streetlights with LED on Main Street. The utility will be participating in the San Juan College School of Energy’s Energy Week, where kids from schools around the region can and learn about all forms of energy. The FEUS Engineering team, led by John Armenta will be manning a booth for Energy Week. The utility will be seeking a new contract for Tree Trimming. Asplundh Tree Service has worked well with the utility for many years but the utility would like to change the scope of the work perhaps making it more performance based. Because members of the commission and city staff are participating in the APPA National Conference and because the dates of the conference conflict with the June 12 PUC meeting, it was the consensus of the commission to cancel the June 12 meeting. Regarding the utility’s participation in the Light Up Navajo project, Commissioner Schmidt said her grandparents did not have electricity until the 1970s/80s and it made such a difference to their lives so FEUS’s participating in this project is a good thing. BUSINESS FROM THE FLOOR ADJOURNMENT There being no further business to come before the Commission the meeting was adjourned at 4:30 p.m. Approved this 10th day of July, 2024. ________________________________ Tory N. Larsen, Chair  INTER-OFFICE MEMORANDUM CITY OF FARMINGTON • CITY ATTORNEY'S OFFICE 800 Municipal Drive · Farmington, NM 87401 · E-mail: debberts@fmtn.org Phone: (505) 599-1127 Date: May 17, 2024 To: Amy McKinley, Administrative Assistant, Electric Utility From: Delana Ebberts, Paralegal RE: Open Meetings Resolution 2024 BOARD OF PUBLIC UTILITY COMMISSIONERS Attached is the 2024 Open Meetings Resolution for the Board of Public Utility Commissioners (PUC). Please schedule this resolution for consideration on the agenda of the meeting of the Public Utility Commission on July 10, 2024, at 3:00 p.m. This is necessary to satisfy the requirements that the City Council has set in regard to proper notice for meetings of public bodies of the City of Farmington in conformance with the Open Meetings Act. It is necessary that you schedule the Resolution for the agenda of this meeting in particular and that a quorum be present to vote on this Resolution. Please proof read the Resolution and ensure that the correct day, time, place and the office location where agendas can be picked up is shown. If this information is not correct, please notify me immediately and I’ll prepare a revised Resolution and get it to you prior to the above scheduled meeting. Should the PUC during the above scheduled meeting vote to CHANGE the meeting day/time/place, etc., from that information shown on the attached Resolution, please contact me immediately following your meeting, and I will provide you with a replacement Resolution for signature by your commission’s chairperson. The Open Meetings Act requires that the day, time and place of regular meetings be established, and that the commissions, committees and boards of the City not vary from that regular meeting schedule whenever possible. Once adopted any deviation from the adopted schedule will require you to publish a "special notice" to comply with the Open Meetings Act. If for any reason the Public Utility Commission elects to change the day, time or place given in the resolution, please notify this office as soon as possible so that we may alter the notice of regular meetings which is permanently posted and give other appropriate notice to the public. Thank you for your time and patience in helping us to comply with the provisions of the Open Meetings Act. Please return the original Resolution to Legal after it has been signed and keep a copy for your file. Attachment -2-  RESOLUTION A RESOLUTION SETTING AND ESTABLISHING A REGULAR MEETING DAY, TIME AND PLACE FOR THE BOARD OF PUBLIC UTILITY COMMISSIONERS PURSUANT TO CITY COUNCIL RESOLUTION NO. 2013-1466 AS RATIFIED WHEREAS, pursuant to the provisions of Resolution No. 2013-1466 as ratified, each board, commission, committee or other policy making body of the City of Farmington which holds regular meetings shall annually, subject to the ratification and approval of the City Council of the City of Farmington, establish a regular meeting day, time and place; and WHEREAS, the Board of Public Utility Commissioners of the City of Farmington has determined and does recommend to the City Council that the regular meeting day, time and place of the Board of Public Utility Commissioners of the City of Farmington and the location where a copy of the agenda of such meetings may be obtained shall be as set forth in this resolution. NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF PUBLIC UTILITY COMMISSIONERS OF THE CITY OF FARMINGTON: That the regular meeting day, time and place of the Board of Public Utility Commissioners of the City of Farmington shall be held on the second Wednesday of each month at 3:00 p.m., in the Executive Conference Room, Municipal Building, 800 Municipal Drive, Farmington, New Mexico and that the location where a copy of the agenda of the regular meeting may be inspected seventy-two (72) hours prior to such meeting shall be at the Office of the Director of the Farmington Electric Utility System, Municipal Operations Center, 101 North Browning Parkway, Farmington, New Mexico. PASSED, SIGNED, APPROVED and ADOPTED this ______ day of July, 2024. By: Chairperson, Board of Public Utility Commissioners -2.1- PUC ACTION ITEM REQUEST DATE: July 1, 2024 DEPARTMENT: Electric Utility MEETING DATE: July 10, 2024 1. ITEM/TOPIC: AMI Opt-Out Policy and Remote Connect/Disconnect fee for Farmington Electric Utility System 2. ACTION REQUESTED OF PUC: Recommend City Council approval of the AMI Opt-Out Policy and Remote Connect/Disconnect Fee for Farmington Electric Utility System 3. BACKGROUND / RATIONALE: Farmington Electric Utility System (FEUS) is upgrading its existing non-standard meter (a non-communicating digital meter) to an AMI meter (Advanced Metering Infrastructure). The AMI meters will provide an automated wireless communication to FEUS. The purpose of an AMI Opt-Out Policy is to provide Residential customers and account owners the option to opt-out of upgrading to an AMI meter and utilize a non-standard electric meter for a monthly fee. Unless a customer expressly opts out, all existing and new FEUS customers will receive an AMI meter. FEUS is not offering an opt-out option for water. Opt-Out Fee Schedule Fee Charge Rate * Monthly Charge Per month, per service $50.00 Meter change Trip Charge w/ Labor $50.00 Meter change Admin Fee $15.00 Meter change (analog) One-time fee $65.00 Additional meter reads Per month, per service $80.00 Admin fee for remote connect/disconnect $15.00 4. STAFF RECOMMENDATION: Recommend City Council approval of the AMI Opt-Out Policy and Remote connect/disconnect fee for Farmington Electric Utility System 5. INSTRUCTIONS UPON APPROVAL: Instruct staff to proceed to City Council with recommendation. -6-  AMI Opt-Out Policy for Electric Utility Service 1. Summary Farmington Electric Utility System (FEUS) is upgrading its existing non-standard meter (a non- communicating digital meter) to an AMI meter (Advanced Metering Infrastructure). The AMI meters will provide an automated wireless communication to FEUS. The purpose of an AMI Opt-Out Policy is to provide Residential customers and account owners the option to opt-out of upgrading to an AMI meter and utilize a non-standard electric meter for a monthly fee. Unless a customer expressly opts out, all existing and new FEUS customers will receive an AMI meter. FEUS is not offering an opt-out option for water. 2. Eligibility Customers with the following types of services are eligible to opt-out: 2.1. Residential Service electric customers. Individual residences, dwellings and individually metered apartments that are under Electric Rate No. 1. 2.1.1. Residential Service electric customers with any accompanying additional separately metered, domestic use Residential Service electric account ( e.g. garage or shed) may opt-out of an AMI meter for both accounts as long as the following criteria are met: 2.1.1.1. The primary Residential Service account is on the same premise, with the same parcel zoning, as the accompanying Residential Service account. 2.1.1.2. The primary Residential Service account is the same place of residence as the accompanying Residential Service account. 2.1.1.3. The primary Residential Service account is under the same business partner as the accompanying Residential Service account. 2.2. Opt-out consideration is not available for customers under the following Electric Rates: 2.2.1. Solar/Net-Metering customers 2.2.2. Commercial customers 2.2.3. Industrial customers 2.2.4. Temporary Service customers 2.3. A customer is ineligible to opt-out or the customer’s status can be revoked if he or she has a record of the following: 2.3.1. Equipment tampering or manipulation. 2.3.2. Unauthorized electric connections/use. 2.3.3. Have a past-due balance at the time of the opt-out request 2.3.4. Have been disconnected for non-payment. 2.3.5. Failure to provide and maintain unrestricted access to FEUS for meter installation, maintenance and reading. 2.3.6. Documented threat to utility staff 2.4. Fees related to opt-out policy will be evaluated and updated on a periodic basis. -6.1-  Opt-Out Fee Schedule Fee Charge Rate * Monthly Charge Per month, per service $50.00 Meter change Trip Charge w/ Labor $50.00 Meter change Admin Fee $15.00 Meter change (analog) One-time fee $65.00 Additional meter reads Per month, per service $80.00 Admin fee for remote connect/disconnect $15.00 *Rates for the Opt-out program are subject to change based on the cost to FEUS to service customers in the opt-out program. 3. Steps to Opt-Out Customers requesting an opt-out status related to FEUS’s standard advanced meter (AMI) shall complete the following process: 3.1. Complete and sign an opt-out application acknowledging associated fees, terms, and conditions, and provide relevant service information. Incomplete applications may delay the processing. Applications can be submitted via FEUS website, in person at Customer Service, or by mail. 3.1.1. In tenant-landlord relationships, the FEUS account holder must complete the application. Only the account holder, regardless whether a tenant or landlord, may request and be granted an opt-out status. 3.2. After an application is processed, the customer will receive an approval or denial letter in the mail. FEUS will do it’s best to process applications in a timely manner. However, some cases may need additional information before a decision can be made. This process may take up to one billing cycle (within 30 days). 3.3. Upon move out (or account closing), any opt-out meters will be converted to an AMI meter. 4. Steps to Cancel Opt-Out 4.1. Customers requesting to cancel their opt-out status (to opt to an AMI meter) should contact FEUS by email, calling, or in person at Customer Service. 4.2. No fees are associated with canceling opt-out status (to opt to AMI meter). Advanced Metering Opt-Out Term and Conditions A. Available only for single family residential electric customer. B. Customer must be the account holder (or legal guardian) of the utility account number provided. -6.2- C. Customer must be the legal owner of the premise, a tenant, or the legal guardian of the owner or tenant, as listed on the application. D. By signing the application, I verify that I request to opt-out of FEUS’s standard communicating advanced electric meter. I acknowledge that FEUS will use a non-radio frequency transmitting meter for purposed of opting-out at the premise listed on the application. E. I understand and have read the specific Opt-Out policy details and provisions in the Opt- Out policy, including eligibility, fees, steps to opt-out, moves and cancelling opt-out. F. I understand the FEUS will charge my account a monthly fee according to the fee schedule in the policy. G. I understand that if I move to a new location, this opt-out application does not transfer. A new opt-out application for the new premise must be completed. This will include payment of any related fees. H. I agree that I will maintain clear and direct access to my meter(s), allowing FEUS to manually read the meter(s) during standard business hours throughout the month. I. A completed application form can be submitted to Farmington Electric Utility System (FEUS) at 101 N. Browning Parkway, Farmington, NM 87401, Attention Customer Service Department, or email a copy to customerconnect@fmtn.org, or fax to 505-599- 1477 or drop off the form at our Customer Service Department located at 101 N. Browning Parkway. If you choose to fax or email your application to FEUS, you willingly accept all risks related to the interception, misaddressed, mis-delivered, or otherwise unsecured transmissions. For more information about this program, please contact us at (505)599-1353. -6.3-  Advanced Metering Opt-Out Application The Advanced Metering Infrastructure (AMI) Opt-Out Program is available for Farmington Electric Utility System (FEUS) residential electric customers. The program allows for the removal of radio frequency (RF) emitting equipment used for purposed of collecting a meter read at a premise and replacement with non-automated equipment. Participation in the Program requires the following: • Fees according to the Opt-Out Fee Schedule. • FEUS will manually read the meter(s) each month requiring physical access to the meter(s). Customer self-read and reporting is not available. • In addition to the standard monthly charges for utility service, the customer will incur a $45 read charge each month for manually reading the meter(s). This meter reading charge is applicable regardless of the number of meters at the customer’s premise. To elect participation in the Opt-Out Program, please complete all the fields in the form below. Upon submission of this Agreement, Customer agrees to the Terms and Conditions of the agreement and FEUS’s tariffs and rules and regulations, as amended from time to time. Please complete this form for each residence electing to participate in the Opt-Out Program. Customer and Meter Information * indicates required field Customer Name (Primary Account Owner): * Service Address: * City: State: * Zip * Code: Daytime Phone: Email: * FEUS utility account number: * Are there any meter access issues that we need to be aware of at the service address?  Yes  No If Yes, please describe: (Please indicate if locked gate, dog, etc.) Account Owner Acknowledgement Account Owner: Date: You may submit this completed application form to Farmington Electric Utility System at 101 N. Browning Parkway, Farmington, NM 87401, Attention Customer Service Department, or email a copy to customerconnect@fmtn.org, or fax to 505-599-1477 or drop off the form at our Customer Service Department located at 101 N. Browning Parkway. -6.4- PUC ACTION ITEM REQUEST DATE: July 3, 2024 DEPARTMENT: Electric Utility MEETING DATE: July 10, 2024 1. ITEM/TOPIC: Discontinue cash payments in the field 2. ACTION REQUESTED OF PUC: Staff seeks a PUC recommendation to City Council to approve discontinuing cash payments in the field 3. BACKGROUND / RATIONALE: The safety of personnel who carry cash has been a concern. The installation of AMI meters now allows the ability to remotely disconnect/reconnect customers and reduce the need for personnel in the field. Customers have several options to make a payment to include over the phone, website, auto pay via credit card or bank draft, kiosk, as well as in person. 4. STAFF RECOMMENDATION: PUC recommendation to City Council to approve discontinuing cash payments in the field 5. INSTRUCTIONS UPON APPROVAL: Instruct staff to proceed to City Council with recommendation. -6.5-