Is repair and maintenance work on a telecom company's permanently wired backup generators subject to Utah sales tax?
Apply this to your situation
This page answers the general question as of 2009. Ezel answers yours, under current Utah tax law, with citations.
Plain-English summary
A Competitive Local Exchange Carrier (CLEC) — a telecom company competing with the regulated carrier to provide dial tone and high-speed data service — has 15 sites across Utah (5 main switching/transmission hubs plus 10 remote repeater huts), each with its own permanently wired backup generator to keep the network running during power outages. Its maintenance vendor had recently started charging sales tax on generator repair/maintenance work, having previously treated it as tax-exempt, and the carrier asked the Commission to confirm the correct treatment, pointing to an earlier ruling (PLR 04-019) involving a hospital's backup generator.
Are the generators themselves real property or personal property? The Commission distinguished this case from PLR 04-019. There, a hospital's generator provided complete electrical backup for the entire hospital building and was found to be an integral part of the real property. Here, by contrast, the carrier's generators primarily support its telecommunications equipment — itself tangible personal property — rather than the buildings housing them. PLR 04-019 itself had cautioned that generators serving a specific piece of equipment (rather than an entire structure) generally remain personal property after installation. Applying that distinction, the Commission found the carrier's generators stay personal property, not real property, for purposes of the "converted into realty" test under Rule R865-19S-58.
Is the repair/maintenance labor taxable anyway? No — but through a separate legal test. Utah Code Ann. § 59-12-103(1)(g) taxes labor to repair tangible personal property, but § 59-12-102(88) specifically excludes repairs to property that is "permanently attached to real property" (a defined term under § 59-12-102(68), covering property whose attachment is essential to its use and expected to stay in place over its useful life, or whose detachment would cause substantial damage or require substantial repair). This is a different test from the Rule 58 "converted into realty" question above — a generator can remain personal property under Rule 58 while still being "permanently attached" for purposes of this repair-labor exclusion. Based on the facts and photographs provided, the Commission found the carrier's generators met the "permanently attached" definition, so the repair and maintenance labor is not taxable.
What about replacement parts? Parts are handled separately and remain taxable under § 59-12-103(1)(a) or (l), unless they qualify for Utah's telecommunications equipment exemption in § 59-12-104(62). That exemption covers items purchased by a "telecommunications service provider" (§ 59-12-102(114)(a)) with a useful economic life of one year or more, including a "supplementary power supply" (i.e., a generator itself, per § 59-12-102(110)(b)(iii)) and parts used to maintain or repair such equipment (§ 59-12-102(112)). So parts with at least a one-year useful life are exempt — with a signed Form TC-721 exemption certificate provided to the vendor — while parts expected to last less than a year remain taxable.
Combined invoices need to separate the two. Because labor is nontaxable but some parts may be taxable, the Commission flagged Utah's general bundled-transaction rule (citing prior PLR 04-007): when a single transaction mixes taxable and nontaxable items, the entire charge is taxable unless the vendor separately states or itemizes each. Utah's bundled-transaction statute (§§ 59-12-102(15), 59-12-103(2)(d)), revised effective January 1, 2009, governs how to sort this out if items aren't separately stated.
What this means for you
Telecommunications companies and other utilities with dedicated backup power equipment
Whether your generator is treated as real property or personal property depends on what it primarily serves — a generator backing up an entire building looks different from one dedicated to specific equipment (like telecom switching gear). But even when a generator stays personal property, its repair labor can still be tax-exempt under the separate "permanently attached to real property" test, which turns on the nature of the physical attachment rather than the ownership classification.
Businesses claiming the telecommunications equipment exemption (§ 59-12-104(62))
The exemption for telecom equipment (including power supplies) hinges on a one-year-or-more useful life requirement — track expected part lifespan and provide your vendor a completed Form TC-721 to document the exemption. Parts with shorter expected lifespans stay taxable even if used on otherwise-exempt equipment.
Anyone receiving combined invoices for repair labor plus parts
Insist that your vendor separately state taxable parts from nontaxable labor (or exempt long-life parts) on the invoice. If everything is lumped into one line, the whole charge risks being taxed under the bundled-transaction rules, even if part of it would have been exempt on its own.
Common questions
Q: Why are the generators personal property but their repair labor still exempt from tax?
A: Because Utah applies two different legal tests for two different purposes. The "converted into real property" test (Rule 58) decides who owes tax on the underlying purchase; the separate "permanently attached to real property" definition (§ 59-12-102(68)) decides whether repair labor is taxable under § 59-12-102(88). An item can fail the first test (stay personal property) while meeting the second (be "permanently attached" for labor-tax purposes).
Q: Are all generator parts exempt if the generator itself qualifies for the telecom equipment exemption?
A: No. Each part is evaluated on its own useful life — only parts expected to last one year or more qualify under § 59-12-104(62). Shorter-lived parts remain taxable regardless of what equipment they go into.
Q: What happens if the vendor doesn't separate labor from parts on the invoice?
A: The transaction may be treated under Utah's bundled-transaction rules, which can result in the entire charge being taxed if taxable and nontaxable items aren't separately stated or itemized.
Q: Can another telecom carrier rely on this ruling?
A: No. It's specific to this taxpayer's generators, sites, and vendor relationship. Different facts — such as a generator that does power an entire structure — could produce PLR 04-019's opposite outcome instead.
Citations and references
Statutes and rules:
- Utah Code Ann. § 59-12-103(1)(a), (g), (l) (tax on retail sales, repair/renovation labor, storage/use/consumption)
- Utah Code Ann. § 59-12-102(88) (repairs/renovations of TPP excludes permanently attached property)
- Utah Code Ann. § 59-12-102(68) (definition of "permanently attached to real property")
- Utah Admin. Rule R865-19S-58 ("Rule 58" — construction materials/integral-to-realty test)
- Utah Code Ann. § 59-12-102(114)(a) (telecommunications service provider definition)
- Utah Code Ann. § 59-12-104(62) (telecom equipment exemption; 1+ year useful life requirement)
- Utah Code Ann. § 59-12-102(110), (112) (telecom enabling/facilitating equipment and maintenance/repair equipment definitions)
- Utah Code Ann. § 59-12-102(15), § 59-12-103(2)(d) (bundled transaction rules, effective Jan. 1, 2009)
Prior Commission rulings cited:
- Utah PLR 04-019 (hospital backup generator — integral to real property)
- Utah PLR 04-007 (bundled transaction — separately state nontaxable items or the whole charge is taxable)
Source
- Landing page: https://tax.utah.gov/commission/rulings/
- Original PDF: https://files.tax.utah.gov/tax/commission/ruling/09-009.pdf
Original ruling text
FINAL PRIVATE LETTER RULING
REQUEST LETTER
09-009
02/24/2009
Utah State Tax Commission
210 North 1950 West
Salt Lake City UT 84134
February 24, 2009
Re: Request for Private Letter Ruling
Dear Commissioners,
I am writing to request an opinion as to how the Utah Sales and Use Tax Act applies to
expenditures related to backup electrical generators. By way of Introduction, my name is
NAME. I am a Field Manager for COMPANY. We are one of several competitive Local
Exchange Carriers (CLEC’s) that serve the state of Utah in the field of telecommunications. We,
like the regulated carrier (REGULATED CARRIER), furnish communications services
throughout the state. Our services range from ordinary dial tone to very high-speed data
transmission. We are licensed to serve small business from ordinary dial tone to very high-speed
data transmission. We are licensed to serve small business and above. We essentially provide
the same services as the regulated carrier to more than 16,000 customers in the state of Utah. In
several areas along the Wasatch front we have both switching and transmission hubs that service
our fiber optic network. Those hubs are completely self sufficient with their own power backup,
HVAC, fire protection and security. These facilities mentioned reside in CITY (1), CITY 2 (1)
and CITY 3 (3). Even though they are housed within other structures, they are completely
separate from the buildings they are housed in as far as power, etc are concerned. We have our
own transformers, metering, etc.
Backup Electrical Generators Required.
At each of these facilities COMPANY has backup generators. In the case of a long-term power
outage, our backup systems will keep us running regardless of the rest of the tenants in the
buildings in which they are housed. We service hospitals, government agencies [DEFENSE
INDUSTRY and large/small business customers. As our customers rely on us for major
telecommunication and data transmission services as well as emergency contact communication
like 911, our network must be online 24 hours a day, 365 days a year.
Along with those facilities mentioned in the previous paragraph, we also have 10 remote sites on
our Long Haul network. Those sites are in very remote areas of the state and function as repeater
stations for our long haul fiber. They start at the northern part of the state and continue on to the
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very southern end. They are essentially small huts and once again have their own power backup
and HVAC.
In June of 2007 the FCC released an Order on Recommendations of the Independent Panel
Reviewing the Impact of Hurricane Katrina on Communications Networks. In that order the
FCC directed the Public Safety and Homeland Security Bureau (PSHSB) to implement several of
the recommendations. Among those recommendations was that all assets necessary to the
provision of communication services should have backup power regardless of what type of
commercial power they normally use.
The reason this letter is being written arises from the billing of one of our vendors, VENDOR
does all of our generator maintenance throughout the state and even a few places in the southern
portion of Idaho on the Long Haul sites. In times past, the billing from VENDOR has been, as I
have interpreted the tax law, free of sales tax on labor concerning the maintenance on the backup
generators at all 15 sites mentioned previously. Recently Mr. Mark Seeronen of VENDOR has
communicated to us that some of their accounts have been ruled upon by the tax commission as
not eligible for sales tax free status for one reason or another.
Those generators, regardless of the site, are all permanently installed and totally wired into the
electrical circuitry of the site. They are totally dedicated to keep us on the air in case we should
incur a long-term power outage. The Long Haul units actually come on line quite often as those
remote sites do experience frequent power interruptions due to their remote nature. In reading
publication 42 from tax.utah.gov., it is my interpretation that as a utility providing the services
that we do in the way that we do, COMPANY does qualify for the sales tax exemption for
Tangible Personal Property. In Private Letter Ruling 04-019, dated March 29, 2005, the
Commissioners addressed the issue of backup electrical generators for a hospital and concluded
that where the backup generators primary function is to provide power to the entire underling
real property structures, consist of large pieces of equipment not easily moved and are intricately
integrated into the underlying realty, any transaction to purchase, install, repair, renovation and to
install tangible personal property, in connection with them would be non-taxable events. As with
the hospital, COMPANY’S backup generators are both physically and functionally incorporated
into the underlying real property, in this case the switching and transmission hubs. As these
generators are large, permanently installed and provide backup power for our entire electrically
isolated facility, they should fall under that sales tax exemption associated with the labor services
for repairs or installations. I have provided photographs of the generators in support of
COMPANY’S position.
COMPANY is committed to following all of the Utah Law, but with that in mind, would like a
specific direction given so that we can answer the concern that has been raised by our vendor (in
this case, VENDOR. Thank you for your prompt attention to this matter.
Respectfully,
NAME
COMPANY
ADDRESS
PHONE
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RESPONSE LETTER
August 20, 2009
NAME
TITLE
COMPANY
ADDRESS
RE: Private Letter Ruling Request—Sales Tax Treatment of Repair and Maintenance Services
on Backup Generators Owned by Telecommunications Service Provider
Dear NAME:
You have requested a ruling on the sales tax treatment of your company’s purchases of
repair and maintenance services performed on your backup generators that provide backup
power for your telecommunication equipment.
You provided that your company, COMPANY, is one of several Competitive Local
Exchange Carriers serving more than 16,000 customers in the State of Utah. Its services range
from simple dial tone to high-speed data transmissions. Its customers are small businesses and
above. It has both switching and transmission hubs that service its fiber optic network. You
further explained that COMPANY has five main facilities in Utah and smaller facilities at ten
remote sites in the state. At each of these fifteen locations, you have a backup generator. You
explained that these generators are permanently installed and totally wired into the electrical
circuitry of the sites and are dedicated to keeping COMPANY “on the air” in case of a power
outage.
You further explained that your question arises from what COMPANY’S vendor,
VENDOR, said. VENDOR performs repair and maintenance services on all of COMPANY’s
backup generators throughout Utah. You stated that VENDOR told COMPANY that the Utah
State Tax Commission ruled against it on some of its accounts, finding that the accounts are not
tax exempt for one reason or another. You explained that VENDOR is currently charging sales
tax on the maintenance services for the generators, but previously it had not. Therefore, you now
ask the Commission whether the VENDOR’s repair and maintenance services performed on
COMPANY’s backup generators are tax-exempt. You explained that you think that the services
are tax-exempt based on our previous Private Letter Ruling (“PLR”) 04-019.
I. Applicable Law
Utah Code Ann. § 59-12-103(1) imposes a sales and use tax on:
amounts paid or charged for . . .
(a) retail sales of tangible personal property made within the state;
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....
(g) amounts paid or charged for services for repairs or renovations of tangible
personal property, unless Section 59-12-104 provides for an exemption from
sales and use tax for:
(i) the tangible personal property; and
(ii) parts used in the repairs or renovations of the tangible personal property
described in Subsection (1)(g)(i), whether or not any parts are actually
used in the repairs or renovations of that tangible personal property . . .
....
(l) amounts paid or charged for tangible personal property if within this state the
tangible personal property is
(i) stored;
(ii) used; or
(iii) otherwise consumed . . .
For § 59-12-103(1)(g), Utah Code Ann. § 59-12-102(88) states that “repairs or
renovations of tangible personal property” means:
(a) a repair or renovation of tangible personal property that is not permanently
attached to real property; or
(b) attaching tangible personal property or a product that is transferred
electronically to other tangible personal property if the other tangible
personal property to which the tangible personal property or product that is
transferred electronically is attached is not permanently attached to real
property.
Utah Code Ann. § 59-12-102(68) states:
(a) "Permanently attached to real property" means that for tangible personal
property attached to real property:
(i) the attachment of the tangible personal property to the real property:
(A) is essential to the use of the tangible personal property; and
(B) suggests that the tangible personal property will remain attached to
the real property in the same place over the useful life of the tangible
personal property; or
(ii) if the tangible personal property is detached from the real property, the
detachment would:
(A) cause substantial damage to the tangible personal property; or
(B) require substantial alteration or repair of the real property to which
the tangible personal property is attached.
(b) "Permanently attached to real property" includes:
(i) the attachment of an accessory to the tangible personal property if the
accessory is:
(A) essential to the operation of the tangible personal property; and
(B) attached only to facilitate the operation of the tangible personal
property;
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(ii) a temporary detachment of tangible personal property from real property
for a repair or renovation if the repair or renovation is performed where
the tangible personal property and real property are located; or
(iii) property attached to oil, gas, or water pipelines, except for the property
listed in Subsection (68)(c)(iii) or (iv).
(c) "Permanently attached to real property" does not include:
(i) the attachment of portable or movable tangible personal property to real
property if that portable or movable tangible personal property is
attached to real property only for:
(A) convenience;
(B) stability; or
(C) for an obvious temporary purpose;
(ii) the detachment of tangible personal property from real property except
for the detachment described in Subsection (68)(b)(ii);
(iii) an attachment of the following tangible personal property to real
property if the attachment to real property is only through a line that
supplies water, electricity, gas, telecommunications, cable, or supplies a
similar item as determined by the commission by rule made in
accordance with Title 63G, Chapter 3, Utah Administrative Rulemaking
Act:
(A) a computer;
(B) a telephone;
(C) a television; or
(D) tangible personal property similar to Subsections (68)(c)(iii)(A)
through (C) as determined by the commission by rule made in
accordance with Title 63G, Chapter 3, Utah Administrative
Rulemaking Act; or
(iv) an item listed in Subsection (108)(c).
Utah Admin. Code R865-19S-58 (“Rule 58”), titled “Materials and Supplies Sold to
Owners, Contractors and Repairmen of Real Property Pursuant to Utah Code Ann. Sections 59-12-
102 and 59-12-103,” states in pertinent part:
(1) Sales construction materials . . . to . . . repairmen of real property are generally
subject to tax if the . . . repairman converts the materials . . . to real property.
(a) “Construction materials” include items . . . that lose their separate identity as
personal property once incorporated into the real property.
(b) Fixtures or other items of tangible personal property such as furnaces, built-in
air conditioning systems, . . . or other items that are appurtenant to or
incorporated into real property and that become an integral part of a real
property improvement are treated as construction materials for purposes of this
rule.
....
(4) This rule does not apply to contracts where the retailer sells and installs personal
property that does not become part of the real property. Examples of items that
remain tangible personal property even when attached to real property are:
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(a) moveable items that are attached to real property merely for stability or for an
obvious temporary purpose;
(b) manufacturing equipment and machinery and essential accessories appurtenant
to the manufacturing equipment and machinery;
(c) items installed for the benefit of the trade or business conducted on the property
that are affixed in a manner that facilitates removal without substantial damage
to the real property or to the item itself and
(d) [certain telephone or communications equipment and associated wire and lines]
The Utah Code provides specific exemptions that apply to telecommunications service
providers. “Telecommunications service provider” is defined in Utah Code Ann. § 59-12-
102(114)(a) as “a person that: (i) owns, operates, and manages telecommunications service; and
(ii) engages in an activity described in Subsection (114)(a)(i) for the shared use with or resale to
any person of the telecommunications service.”
Utah Code Ann. § 59-12-104(62) provides an exemption from sales and use tax for:
(a) purchases or leases of an item described in Subsection (62)(b) if the item:
(i) is purchased or leased by, or on behalf of, a telecommunications service
provider; and
(ii) has a useful economic life of one or more years; and
(b) the following apply to Subsection (62)(a):
(i) telecommunications enabling or facilitating equipment, machinery, or
software;
(ii) telecommunications equipment, machinery, or software required for 911
service;
(iii) telecommunications maintenance or repair equipment, machinery, or
software;
(iv) telecommunications switching or routing equipment, machinery, or
software; or
(v) telecommunications transmission equipment, machinery, or software
“Telecommunications enabling or facilitating equipment,” which is used in § 59-12-
104(62)(b)(i), is defined in Utah Code Ann. § 59-12-102(110) to include, among other things,
“(b)(iii) a supplementary power supply.” In addition, “telecommunications maintenance or
repair equipment,” which is used in § 59-12-104(62)(b)(iii), is defined in Utah Code Ann. § 59-
12-102(112) to include:
equipment, machinery, or software purchased or leased primarily to maintain or
repair one or more of the following, regardless of whether the equipment,
machinery, or software is purchased or leased as a spare part or as an upgrade or
modification to one or more of the following:
(a) telecommunications enabling or facilitating equipment, machinery, or
software . . .
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II. Analysis
A. COMPANY’s Generators Are Not Integral to Real Property; Rather, They Remain
Personal Property After Installation.
In general, sales and repair transactions involving tangible personal property are taxable
under § 59-12-103(a) and (g). However under Rule 58, if a repairman of real property converts
tangible personal property into real property, the repairman does not charge sales tax. Rather, the
repairman pays sales and use tax on the purchase of the tangible personal property prior to
converting it to real property. R865-19S-58(1)-(1)(a). Furthermore, if a repairman sells and
installs or later repairs certain property that is integral to the real property, he does not charge
sales tax on such sales, either. Property that becomes an integral part of real property may
include furnaces, built-in air conditioning, and other similar items. R865-19S-58(1)-(1)(b).
However, Rule 58 does not apply when the personal property does not become real property.
R865-19S-58(4).
PLR 04-019 addressed whether a hospital generator was so incorporated into the hospital
real property that it became an integral part of the real property. That generator “provided
complete electrical power replacement for the hospital”; it did not “exist only to serve a specific
piece or pieces of equipment.” Furthermore, it was “necessary to serve the utility needs of the
hospital and [was] both functionally and physically incorporated into the underlying real
property improvement; i.e., the hospital.” Under the facts of that situation, the Commission
found that the generator was “considered part of the realty upon installation.” However, the
Commission also cautioned,
[U]nder different circumstances, the Commission has found generators, including
back-up generators, to remain tangible personal property after their installation. A
generator that is installed to provide back-up electrical power to a specific piece
of equipment has generally been considered to remain personal property after
installation because the equipment it serves is itself tangible personal property.
(Emphasis added.)
In this case, COMPANY’S generators are tangible personal property and are not an
integral part of real property. You have argued that COMPANY’S’s generators are like the
hospital generator in PLR 04-019 and, therefore, no sales tax should apply. We reject this
argument because the hospital generator in PLR 04-019 is distinguishable from COMPANY’S.
The hospital generator served the real property, the hospital building and grounds, and did not
primarily support other equipment that was tangible personal property. In contrast,
COMPANY’S generators primarily support its telecommunications equipment, not real property.
Therefore, COMPANY’S generators are similar to the generators discussed in PLR 04-019 that
“generally . . . remain personal property after installation because the equipment it serves is itself
tangible personal property.”
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B. The Repair and Maintenance Services for COMPANY’S Generators Are Not Subject to
Sales Tax Under § 59-12-103(1)(g).
In general, § 59-12-103(1)(g) taxes “amounts paid or charged for services for repairs or
renovations of tangible personal property . . .” However, § 59-12-10 2(88) defines “repairs or
renovations of tangible personal property” to exclude repairs to tangible personal property
permanently attached to real property. Also, § 59-12-102(68) defines “permanently attached to real
property.” In this case, after reviewing the information and pictures you provided, we conclude that
your generators are permanently attached to real property. Because they are permanently attached,
the repair or maintenance services would not be subject to tax under § 59-12-103(1)(g).
C. The Parts Used for the Repairs of the COMPANY’s Generators Are Subject to Tax if the
Parts have a Useful Life Less than One Year.
In general, § 59-12-103(1)(a) taxes “ retail sales of tangible personal property made within
the state” and § 59-12-103(1)(l) taxes the storage, use, or consumption of tangible personal property
within the state. Parts are taxable under either § 59-12-103(1)(a) or § 59-12-103(1)(l). However,
§ 59-12-104(62) provides an exemption for certain purchases by a telecommunications service
provider if the items purchased are described in subsection (62)(b) and have a useful life of one
year or greater. These items include a supplementary power supply (i.e. generator), under
§§ 59-12-104(62)(b)(i) and 59-12-102(110), and parts used to repair a generator, under §§ 59-12-
104(62)(b)(iii) and 59-12-102(112). Therefore, in this case, § 59-12-104(62) exempts from tax
COMPANY’S purchases of parts to repair its generators if those parts have a useful life of one
year or greater. To receive the exemption for parts under § 59-12-104(62), COMPANY should
provide its vendor, VENDOR, with a valid, signed Utah sales tax exemption certificate (Form
TC-721) with the box checked for telecommunications equipment, machinery, or software.
Form TC-721 is available online at http://www.tax.utah.gov/forms/current/tc-721.pdf .
D. A Repair Service that Combines Taxable Parts with Nontaxable Repair Services or
Parts Should Separately State the Nontaxable Items.
In general, when a combined transaction consists of both taxable and non-taxable items,
the entire transaction is taxable unless the nontaxable and taxable items are separately invoiced
or itemized.1 Effective January 1, 2009, the Utah Code contains a revised and expanded
definition of “bundled transaction” in § 59-12-102(15) and a modified tax treatment for bundled
transactions in § 59-12-103(2)(d). If a seller does not separately state items on its invoice, one
must refer to §§ 59-12-102(15) and 59-12-103(2)(d) to determine taxability. If a transaction is
bundled according to the current statutes and a seller has its underlying books and records in
order, an otherwise nontaxable service may remain nontaxable even though it is both bundled
1
See Private Letter Ruling 04-007 (“[T]he Commission has long held that if a combined or
‘bundled’ transaction occurs that consists of both taxable and non-taxable transactions, the entire
transaction is taxable unless the different transactions are separately invoiced or itemized. This
concept is specified for exempt transactions under Rule 78(D)(1) [currently at Utah Admin Code
R865-19S-78(1)], which states ‘. . . [i]f the extended warranty agreement covers parts as well as
labor, any parts that are exempt from sales tax pursuant to Section 59-12-104 must be separately
stated on the invoice or the entire charge under the extended warranty agreement is taxable.’”)
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with a taxable item and not separately stated. § 59-12-103(2)(d)(ii)(A)(I). In this case, if repair
and maintenance services include both taxable and nontaxable items, VENDOR should
separately state those items on the invoice. If the items are not separately stated, COMPANY
must refer to §§ 59-12-102(15) and 59-12-103(2)(d) to determine taxability. COMPANY is
welcome to contact the Tax Commission again about how §§ 59-12-102(15) and 59-12-103(2)(d)
apply to COMPANY’S situation.
III. Conclusion
Based on the above analysis, the repair and maintenance services performed on
COMPANY’S backup generators are tax-exempt if they are either separately stated or are not
combined with any taxable item, such as parts having a useful life of less than one year. If the
repair and maintenance services are combined with a taxable item, then our conclusions might
change. Our conclusions are based on the facts as described. Should the facts be different, a
different conclusion may be warranted. If you feel we have misunderstood the facts as you have
presented them, if you have additional facts that may be relevant, or if you have any other
questions, please contact us.
For the Commission,
Marc B. Johnson
Commissioner
MBJ/aln
09-009
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