Loading...
HomeMy WebLinkAbout1978-01-17; City Council; 5309; Water Deposit Feasibility Study/$ CITY OP CARLSBAD NDA BILL NO.6 E: ' JANUARY &RTMENT :F 17,1978 . ' INANCE Initial Dept.Hd C. Atty C Mrrr- .. • . It -- :1?^ ^TSubject: WATER DEPOSIT FEASIBILITY STUDY. Statement of the Hatter CITY COUNCIL HAS REQUESTED A StUDY OF DEPOSIT FEES FOR WATER ACCOUNTS TO IMPROVE COLLECTION OF FINAL 'AND PAST DUE ACCOUNTS THIS STUDY INCLUDES A SURVEY OF LOCAL WATER DEPARTMENTS AND WATER DISTRICTS. THE AVERAGE WATER COLLECTION LOSSES IN THIS AREA RANGE FROM .003% TO .02%. THESE ARE ESTIMATES IN MOST CASES. LOSSES IN CARLSBAD HAVE BEEN AVERAGING .003%, OR A LOSS"OF $6,900 OVER A TWO YEAR PERIOD. • THE COST-OF IMPLEMENTING AND- MAINTAINING A DEPOSIT. AND "REFUND ' SYSTEM FOR OVER fa, 000 ACCOUNTS WOULD EXCEED THE.ANNUAL LOSS . RATIO. M'ALN REQUIREMENT WOULD BE THE ADDITION OF ONE INTER- MEDIATE ACCOUNT CLERK. •' . EXHIBITS , • • ' • 'WATER "DEPOSIT FEASIBILITY STUDY ••_'-. Recommendation .-"... 1. That the percentage of, nonpayment and dollar amount be monitored by the Finance Department and reported.to the Council'in one year or in January, 1979. 2. That the City be-prepared to implement a .deposit', system if the loss approaches the -1% figure against the totfil dollar amount receivable for water servicre accounts. . • ' ' , In the event the City Council'wishes to adopt 'a new deposit procedure, it is suggested'that-the fee be: . •'• 1. based upon an average bimonthly bill fbi* water service. '2.- uniformly applied "to all new applicants for water service to include homeowners, tenants and commercial accounts alike. 3. refunded upon final payment, or applied to the last monthly bill bor •service upon, closing the account. Co'unci 1 .action • . • • • • \ 1-17-78 Council accepted staff recommendations. CITY OF CARLSBAD DATE : December 7, 1977 TO : City Manager FROM : Administrative Intern, Sean G. Renden SUBJECT : Assignment Study WATER DEPOSIT FEASIBILITY STUDY I. Purpose. The purpose of this study, as suggested by the City Council and City Manager, is to investigate the conditions under which the City may request a deposit fee for water service. The nonpayment of bills has prompted the City to take action to minimize the loss of revenue and facilitate the collection of delinquent accounts by the Finance Department, thereby, lessening the burden of uncollectable accounts which are absorbed by the City. II. Background. The Finance Department reports outstanding past due accounts for the last two fiscal years total $6,900.00. This represents a collection loss of .003, or three tenths of one per cent. Water service is provided and maintained by the City and presently requires a deposit only for construction loan meters at $100.00. Applicants for water service are subject to a meter installation and service charge when a building is con- structed. There is an initial service charge for new accounts at $3.30. No penalty fees are charged for late payment of bills. At one time, there was a 10% penelty fee provided for in Ordinance No. 4001, Section 26, but was amended by Ordinance No. 4005, Section 5. The former City Council felt the fee resulted in poor community relations. Water service may be turned-off without notice following 30 days of nonpayment, and not restored until all delinquent water bills and reconnection charges are paid. Presently, service accounts are not turned-off unless delinquent for 60 days. There is an $8.25 reconnect fee when service is turned-off for nonpayment. The Finance Department estimates 60 accounts per month are turned-off for nonpayment. They estimate this to be the maximum number of meters that can be shut-off by the meter crew, while maintaining their present work load. III. Legal Authority. The application for water service lists both owner and tenant of a residence, and if the tenant becomes delinquent in payment, the owner is ultimately considered liable. Under City Ordinance No.. 4001, Section 42, the owner of the property is liable for water furnished to the premises rented, and so states on the water application. The policy has been to not bring suit against property owners for nonpayment. The City has been cautious in legal action because of possible court precedence which may dissolve the liability of the owner when the tenant is the recipient of water service. Many owners reside outside the corporate limits of the City, and many private water companies have been unsuccessful in collection efforts because of PUBLIC UTILITY COMMISSION regulations that provide that the person who signs-up for the water service is responsible- owner or tenant. A water deposit is within the rights of the City under Ordinance No. 4001, Section 3. This gives the Council the power to adopt rules and regulations for the maintenance of the water department and, by resolution, modify the rates and impose charges and penalties. Resolution No. 5127, Section 11, Restoring Service after Discontinuance, states "When an owner or consumer has been delinquent in his water bills in succession or three times in any one calendar year, he shall be required to deposit a sum equal to an average two month's water bill upon such premises...". IV. Study Method. The manner in which this study was made is a comparative analysis of the City of Carlsbad's water policy to that of other cities in the County of San Diego. This survey includes the practices of five cities, whose water service is a municipal function, and three water districts providing service to the remaining cities and adjoing areas. They responded to questions about their particular billing practice and general water policy. These areas include: 1. payment schedule 2. measuring or pricing systems 3. initial service fee for water turn-on 4. percentage of nonpayment 5. deposits and conditions 6. how deposit fee is determined 7. deposit refund and conditions 8. delinquency or penalty charges 9. turn-on fee after shut-off for nonpayment 10. payment liability: owner or renter? 11. employment of collection agencies and success 12. feasibility of a water deposit. The results of the survey (Table 1 & 2) provide an indication — 2 — of how other cities and water districts control water service and the incidence of nonpayment. Aside from variations in the management of the service and size of the agency, this can be used as a reference in assessing whether a similar deposit system is desirable. V. Discussion. During the fiscal years 1975-76 and 1976-77, Finance Department figures show uncollectable bills for water service amount to $6,900.00, an average write-off of $3,450.00 per year. Against the total amount receivable, this results in approximately .003, or three tenths of one percent uncollectable payment for water service. This local comparative survey indicates that the City is below the average in percentage of nonpayment in the County. The cities or companies that estimated their percentage of nonpay- ment to be high said they were compelled to request a deposit due to a transient renter population and low income areas. As most of the percentages are estimates, it is difficult to discern whether a deposit has deterred the incidence of nonpayment in these areas or increased the number of paid accounts. Yearly figures showing differences in percentage of nonpayments over the previous year were, in most cases, not available. Many respondents were unable to give an accurate percentage of nonpayment and considered the incidence of nonpayment to be low. Two-thirds of the water companies and cities surveyed required a deposit as a condition of providing water service. Three- fourths of the respondents felt the water deposit is a workable deterrent against delinquent bills. All of the respondents that require a deposit felt it was effective and provided the city or company with some form of compensation when left with a delinquent account. The amount and type of deposit varies: 1. Flat rate 2. An average monthly or bi-monthly bill 3. Twice the average monthly or bi-monthly bill 4. A multiple base rate of an average monthly bill. Deposits are returned 3 ways according to this survey: 1. Full refund following 12 months with good record of payment; 2. Deposit fee attached to opening account, and auto- matically applied to final closing bill; 3. Full refund when final bill is paid. In the event of a water shut-off for nonpayment, all those1 surveyed attached a service fee for turning the water back on. -3- Carlsbad currently charges $8.25, compared to the mean fee of approximately $7.50, ranging from $3.00 to $10.00. In many instances, a delinquency or penalty fee is added to an over- due bill, and, in some cases, in addition to a turn-on fee. This charge is determined by either a percentage of the bill (Del Mar, Oceanside, HWD) or by a flat rate (VID). Two thirds of the respondents employ outside collection agencies in handling difficult outstanding bills following 90 days of nonpayment. Collection agencies utilize extensive mail and personal tracking techniques and typically retain 50% of the due amount of the bill if successful, and return the remaining amount to the city or company. Of the respondents who employ collection agencies, some feel they are not noticiably successful (Escondido) where as another (Cal American) estimates collection efforts to be 75% successful. It is perceived as obtaining money that had previously been deemed uncollectable. Most respondents consider a water deposit for water service as being feasible and workable. Residental accounts are more frequently delinquent in payments than agricultural and commerical accounts because of transient tenancy. This has also made collection difficult due to the time period of up to three months before shut-off is effected, and the whereabouts of previous tenants are unknown. In such cases, a water deposit applied to the final payment or returned after twelve months is seen as a desirable means of compensation. VI. Analysis. Because the incidence of nonpayment in Carlsbad is currently low, one must consider the necessity and cost of implementing a water service deposit procedure. Managing the deposit will require additional tasks of recording and accounting procedures, combined with present collection efforts in the Finance Depart- ment. The finance clerk will need to be knowledgeable of the conditions, procedures and general handling of the deposit when dealing with customers. Other options that may be utilized or studied in addition to, or instead of, a deposit system may be: 1) a tighter and more aggressive bill collection effort involving procedural and follow-up changes in the Finance Department. 2) to provide for personnel to be specifically in charge of collecting outstanding bills, assuming the duties and respons- ibilities of a comparable collection agency. The first option would conceivably involve a minor reorganization to accomadate a collection effort. The second option needs -4- further explanation. To provide for personnel to act as a comparable collection agent would involve the formulation and organization of a systematic mail and telephone campaign designed to locate the account holder and apply pressure until the balance of the bill is paid. This effort may reduce the number of unpaid accounts and serve as an early warning of impending consequences such as court proceedings against the user. It may be necessary to create a new clerical position in the Finance Department, or assign such duties to the present staff. The additional clerical work and cost of implementing such a program must be weighed against the benefits of recovered revenue. Part of the problem of nonpayment is that there is presently no positive incentive for customers of water service to make timely payments. Of greater concern is the situation of nonpayment by a user who moves from the City, making collection efforts difficult. The attachment of a deposit fee or an arrears charge to a delin- quent account may alter the users bill paying habits, but does not respond to the more important issue of preventing the incidence of nonpayment and reducing the risk of uncollectable accounts. Rather than charge a deposit fee following payment delinquency, it may be more appropriate to extend the provisions of a deposit to require the fee before the service is provided, and refund the deposit after the customer establishes a good record of payment. The basis for requiring a deposit fee should be to both protect the City from nonpayment and encourage timely payment. It is upon this premise that the following options should be considered: 1) That the City adopt a resolution extending the provisions of a deposit fee for water service to include first time recipents who have not yet established a record of prompt payment. This fee should be uniformally applied to owners and tenants alike, depending upon who is listed as the recipient of water service on the application. The procedure of requesting a deposit for new accounts would probably not offend established customers, and provide an incen- tive for new customers to maintain a good record of bill payment. It is important that the deposit procedure, if adopted, be equally and uniformally applied to all first time accounts; other- wise, the City may be accused of an unfair practice. An applicant cannot be refused water service for reasons relating to a bad credit record; however, a deposit fee charged in advance may deter the nonpayment of a bill. 2) That a delinquency notice be sent to users after 10 days following nonpayment of a bill for two months service. The delinquency notice serves as a warning to the user and reminder of the procedure for shut-off. -5- The Finance Department has indicated that the delinquency notice would require additional staff time in the regular processing of such notices. There is some question as to the immediate need for such a procedure, and doubt as to whether the result- ing benefits of more timely payment warrant the additional time and clerical effort necessary to process delinquency notices. 3) That the Finance Department enforce the present provisions for penalties and deposit fees set forth by Council Resolution No. 5127, Section 11, requiring a deposit fee equal to an average water bill for two months service, when a customer has been delinquent in succession, or three times in any one calendar year. This option requires no action by the Council, and a deposit fee charged by the Finance Department shall be implemented when appropriate. VII. Implementation. In determining whether a water deposit is desirable, the cost and impact of its implementation should be considered. As an advantage, the application form for new customer accounts provides a space listed as "deposit" and can accomadate a provision for a deposit. In addition to the application, the City computer is programmed to accept a deposit in its "cash receipts and adjustments journal" listings. When a new account is opened, a deposit figure can be addid to the account number, date, payments, etc., as such: Acct. Date Payments Deposits Adj. Code Ref. No. Cash Rec. Cash Pep. The read-out will provide the clerk with the date the deposit was paid and indicate the conditions of the refund. Returned deposits will then be recorded and dated. In the event of a change of tenants, the Finance Department should be notified and either accomplish a transfer of deposit or subject the new resident to a deposit under the new name. Deposits should be refunded only to the tenant or owner who signs for the water service. If a deposit has been refunded, and a change in tenants occur, the new user will be subject to a deposit upon moving in, unless the owner of the residence is the account holder, and the deposit is therefore applied to his account and refunded accordingly. The owner should not be eligible for a deposit refund if paid by the tenant, and the tenant leaves without qualifying for the refund. The deposit will then be forfeited to the City, and a new deposit charged to the account for water service. One method of applying a deposit may be to make it commensurate with the average bi-monthly or monthly bill for service, or -6- with a standard fee based upon meter size. A deposit based upon bi-monthly or monthly bill is advantageous as it is equitably determined and can be adjusted with the anticipated fluctuation of water cost and service. An example of this method is shown on Table 3. This deposit fee is determined by calculating the average monthly units of water consumed by meter size, and multiplying this figure by the base rate for water consumption. The monthly minimum stand by charge is then attached, producing an estimate for water service with- out the refuse disposal and sewage fee. The refuse disposal and sewage fee is not included in the deposit schedule on Table 3, because not all recipents for water service are recipents of City Refuse and Sewage Service. See the Supplement for a further description of Table 3. The Finance Department has indicated that there is less need in charging a deposit fee to water accounts with meter sizes larger than 1%" for reasons of their limited number, local permanence and long-term use of the service. VIII. Conclusion. Presently, the situation of nonpayment for water service is not seen as an immediate or serious problem based upon the low figure of uncollected loss for the last two fiscal years. It is the conclusion of this study that a mandatory deposit fee for first time applicants for water service is not necessary at this time. However, it is not likely that the incidence of nonpayment will decrease with the projected rise in the growth rate of the City. It is recommended at this time that the Council take no immediate measures to extend the present provisions for penalties and de- posit fees under Council Resolution No. 5127, Section 11, requiring a deposit fee equal to an average water bill for two months service when a customer has been delinquent in succession, or three times in any one calendar year. A deposit procedure is feasible, but does have peculiar problems in adapting to the present resolution in requiring the fee for nonpayment "in succession or three times in any one calendar year." First, the Finance Department does not keep a running record of customer delinquency in successive nonpayment. To accomplish this, the Department would have to record and maintain a list of customers known to be delinquent; this would require an additional accounting and record-keeping procedure. The cu-stdmei? may question the present method of billing on the basis of 30-60-90 day increments and what exactly constitutes "successive nonpayment". Two options were presented in the analysis that could be utilized or studied: 1) a tighter and more aggressive bill collection effort by the Finance Department, and 2) to provide for personnel to be specifically in charge of collecting outstanding bills, assuming the -7- duties and responsibilities of a comparable collection agency. First, the Finance Department has, of this year, initiated an extended effort to locate users with past due accounts who have moved from the area. They have indicated that this effort has had notable success in recovering some of the revenue. The present staff has incorporated this effort in addition to their other duties, with little additional cost. Secondly, assuming that added personnel to act as a collection agent would be necessary and desirable in handling difficult delinquent accounts, it is evident by looking at the low percentage figure for nonpayment that additional staff is not warranted at this time. When the projected nonpayment dollar loss is compared to the cost of a position salary directed to recovering that loss, the result would not be cost effective (see Table 4.). However, the percentage or amount of nonpayment may increase given the variables of increased tenant transiency, the cost for water and service, and the rise of consumption following a possible increase in the supply of water. It is therefore recommended that: 1. The percentage of nonpayment and dollar amount be monitored by the Finance Department and reported to the Council in one (1) year, or in January of 1979. 2. The City be prepared to implement a deposit system if the loss approaches the 1% figure against the total dollar amount receivable for water service accounts. In the event the City Council wishes to adopt a new deposit procedure, it is suggested that the fee be: 1. based upon an average bi-monthly bill for water service; 2. uniformally applied to all new applicants for water service to include homeowners, tenants and commercial accounts alike; 3. refunded upon final payment, or applied to the last monthly bill for service upon closing the account. -8- W K Pen rH W CUcuIH TJ QJ•P C•H -rlCO g O Ma <u CU 4->'O cu•o o inSS-H in«« C04J -H •H 4->cn -H O T3a co oQ U 1G SO 4J O C G r4CU 1•W g XI0 >it^13 -Hc*> G.K cu •o •rl )H> cu• i i) cu idw S rH J-i d10 o o•H in i 4J G •H 0) M C CU 3M >H 4J g 4-> M COO >icncn d tT1 •H a SH -HCU 0 4J-HCU HS a <u 4J rH C 3 CU TJG GJ>i ,£rd ut^ cn -M U •rH M 4-1 CO •HC* Oo ^1JH (U EH 4->H 10U 3 rl OMI r* 0 4J -H CU O •O 3 -PX (H G CU 4-> 3* in oC Oo o uZ o id £ CNo * GO •. •' tt•: a o CU -rl CO H (0 CJXI Q, * O , m cutnM 10 XiO >1 X!in i M Tfcu d 4-1 10 CU 4J6 w >1rHx; 4Jcog TJr3XICO rHHiOO IJ O 4J IH £ CUIH V4 COCU 3 >i> O C O -rl 10•a > a•H CU gOHOtU DJ O •a o c s 3 •4-> O >i CU g 0!H f^ (N CU ••rH 3o tr1 0 H G • CU -H in 4J"rH rH IH CUto- iO 'O 10X.•G COCU ^J3cr> O 64 !H * cuc0c inita) 0) 4-><U g ^rHx: 4J G Oe J_j iO J2 rH (U Q >i-a rH CUx: -P 4-> 10d gO-HE -Pi in •rH CU XI • ^ • rH tJIrH > -H O 0 • in fMto- • 4J CO CU rH O • IH IHO IH . -H CU OG mO • C <*>•x • rH CU 10•P tnidM o 0fQ O CU - O rH 14 3. CU T3 M4-1 CU CUCU in -Pg * IHid • £>, rH XI4J GOg1 •rl •° O-d•iH•aco 0tow cu •cn oid g •X tnin > CO nO•a(U CU rH CO 4J rH 10 10 -rl ,0 rl XI • tn id in<y*• CO fMto- • 4Jto CU &0 O rH . CU £j O G M CU4J CUe ^rH XI 4-1GOe cutl•H COGidcu .o0 X!4-> CU G CU O >*H g 0m O ^ •rl . • > 4Jtn H cn > CU 01< CO — 10 4JJH O0 0IH id 4JrHa 10 o oX MCU CU * g1 c0 0G 0 • 4J CO CU rHo. 3CO 1 X)•P tn cO SH rH oU cu id -Hid' G 4-) in rHS -ri G id• o a id a. D1 10. Qj-rH rH (U O X Ocu g cu c G H O 0 -rl O O X! 0 d >Hd MH CM -H Q,* i3</> • tn G 0O •rl fu| 4J (Uid g C in O •H CU 4JX) 4J CO g CU 3o g o0 1 1 •a C >i Id rHx; •H Cx; o•P gG 1 O -rl gX! 0 01 CU-H Q G(0w Iili t 6c idx. cud0c •4 0) 4JidM COj_j 4J CU Id 4-> rH CUIH g -^rHx;4Jco•g tnoOl_j nJs didto •o d wBOX! • -a dCT> O O> CO g<o id XI CMcu O rH 4-> •rl rH CO 5 **~J RJE-l XI rH 0o• 0into- • 4Jcn x;cu o> •rl CM XI 0 * ll)GOd * CO Mcu cug ^r-Hx: Goe1 •HXI rH £>1 Id 4-> •H -rl Vl O - 0)G Id O,rH" 10 4-> g -o in M 4-> •rl -rl ^ IS M > 0 Z(U T3 E; id «3 -rt! rH ex; 3 O O rH 43 ^1 Idrd O O CUu * o n ,o • Cn id cu O rH •H rH rS 'H •aC CM M O -PH IH GCU CU•Pin gIH IH >iid o iO1 (X tn" 3 Ga x! oSH CO G n 0o. * cuc0G id CU 4Jid M CO 4-> CU CO 4-1i-H CU IH g £x, i-Hx; Gog •H X! id• in 4J 0)tn a -HQ id t "] W CUcu - >4-> d oi3 O M12 -1-1(3<0'X O C-H O rH rH g CU W 0) X * rl t 1 I Oc . .p COCU So O rHc \ cu - ~coG L9 CU4Jid rl 4J CUid 4-> rH CU ^rHx; gog •rl XI Go •rl 4J fd •rl H 4J H O•Hid M in cn •H -H> Q ' T A B LE w^ D m<EH 0)•-) 'TJ c&Sj --H # -301 3 li•a- M_t m IHa ILJgi.a :& a^ •H -P •H i10 iJtn COto- «-i8 tos, oo rH xt "8 Of I<H10 s a <W O (U -S 04 0) ra oin -r) -HrH .Q -4->4Hj 05 s VJ 4-1 j-Saa +3 CP-U Tj r-S§8rfl 4-> (fl 4J O rH (rt M-4< H! 0 O. O O' I rHr OO rH rH (0 in rH > M8J4-1 <H I01 S£si I §en Bl <0 •4J -W8S oo 1 in -Itn oo oa J! ^ -iH n 3 O tji O S*IH I 8•a o >H4J 0) frt o ,M rH Q,rH rH3 m (1J>, H in rH -rt «» H UJ8, oo Q H <3u, ro ft3 Q)>1<M C "O <u n-i o>B n» n <3 4JS-M rH 0>dj -HW Q § oo -33 in•P - -a a)c ai(8 M-l x: nen CD MH Co• X! -H-P -P 4J •rH C D> COS3 e 3CD tn QJ O> a o O >! °§^ .m -H 4->r~-p 4J C•H C< O IC 6 633 r- • C <1>XCn O OJH> O ~~ D!Q ffi U EH M Ul0a,wQ 0 w,-1 1X 0) siJ= E O -r-l ^>1 *r-lXI g•ac; •fd o to**-* a)Nro -H W J S-lm ai EH 01s VOro CO rH CO rH on • roro in 0 (N rH in 00 ro CO X.in on <M in rH CM rH inro <-' o rH, 5 or- ,_! x: CO in „• 01 CM CA CO o 0 1C. CO inro 10 H en CO r. •a? ro r^ O\ inro 10 VO, ro CO o 0 CO (N rH rH •d t-t O COro co O) O •aC M in •* r~( *xt* rH 0o t—rH iHid•H W *uCM in ^r rH ^* co r>coin oo .in 0 CM O O roH (N ro vo rH t OlCO CM O^ s ro . vo rH in CM en rH ro fMn Kro 10 roVO rH VDin inO)1 0o CNCT> <N 3 •K rH COro - s 20 Industrial509.3^} (tf • f~| ^"^•S* ilfM U) 0) -P* (8 * Vl *O iHO (8 • -H CO ^4 0\ -P tH W 3 CH O 0 ro rH U3 H^ in VD «3in vo 1 I * 0>^t -P •Je i» O O i — | • 2o-rta>ii 0•sH o 0 ovo s •K CO T A B L E Supplement Table 3 Description Table 3 represents one method of calculating a deposit fee for water service. The deposit figures represent the average monthly and bi-monthly bill according to meter size. The monthly minimum standby charge is then added to the average units consumed from January 1 through July 31, 1977- a period of 7 months. A random sample of accounts were chosen and their average units of consumption were then averaged with others of the same meter size. Seasonal variations, occupancy, and nature of the account, along with other variables affecting consumption figures must be taken into consideration. Wider samples were taken from smaller sized meters for the reason of availabilty; there are very few accounts with meter sizes larger than 3 inches. Variations in water consumption of the larger size meters were great, resulting in an unrepresentative sample in applying these to a deposit schedule. The deposit figures are based upon an average monthly and bi-monthly bill for water alone. Refuse disposal and sewage fees, which are included with the charge for water service, were not included in the deposit schedule because many:: accounts do not receive these other services from the City. The fees for refuse collection and sewage also vary depending upon the . nature of the user, whether it be commercial, industrial or residential. A deposit for refuse collection and sewage may be included in the water deposit, or can be charged separately based upon the minmum fee of $3.25 for refuse disposal, and $2.00 monthly for sewage fee. <*.Many of the cities surveyed indicated that the deposit based upon an average bi-monthly bill is advantageous in protecting against non payments for periods of greater than 60 days. It is better able to cover the loss of water payment ordinarily lost between the delinquent bill and the discontinuance of the service. Another type of deposit to be considered is an arbitrary flat-rate fee, and made high or low depending upon the nature and size of the account. This type may typically include previously delinquent accounts or new ones that involve considerable risk. * 1 unit of consumption represents 100 cubic feet each. •*! w <T> Ti t-- t^<7l r-t in-r~o> ooo •M- CM OOO CM ooo oCJ ooo ooo ooo ooo ooo ooo ooo ooo ooo 04