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HomeMy WebLinkAbout2007-033 Cascade Natural Gas Merger with MDU Resources Group (Franchise) - ORDINANCE NO 2007 -33 AN ORDINANCE relating to the non - exclusive franchise granted to Cascade Natural Gas Corporation under City of Yakima Ordinance No 2005 -51 to construct, operate, and maintain a natural gas transmission /distribution system /facility(ies) in the City of Yakima, and providing consent under section 2 13 of that Ordinance to a merger transaction whereby MDU Resources Group, Inc. would acquire all of the outstanding stock of Cascade Natural Gas Corporation, and Cascade Natural Gas Corporation would become a wholly owned subsidiary of MDU Resources Group, Inc. WHEREAS, Cascade Natural Gas Corporation ( "CNG ") is duly authorized to construct, operate, and maintain a natural gas transmission /distribution system /facility(ies) in the City of Yakima (the "City "), Washington, for a term of ten years, pursuant to the terms and conditions of a natural gas system franchise (the "franchise ") as granted by the City under City of Yakima Ordinance No 2005 -51, and WHEREAS, CNG has entered into an Agreement and Plan of Merger (the "merger transaction ") with MDU Resources Group, Inc. ( "MDU Resources "), under which upon closing of the merger transaction, MDU Resources would acquire all of the outstanding common stock of Cascade Natural Gas Corporation, and Cascade Natural Gas Corporation would thereafter become a wholly owned subsidiary of MDU Resources which will continue to operate as Cascade Natural Gas Corporation, with its operating headquarters in the State of Washington, and WHEREAS, as provided for in Section 2 13 of Ordinance No 2005 -51, Cascade Natural Gas Corporation must request and be given consent by the City if there is any such change in control, and WHEREAS, in accordance with section 2.13 of Ordinance No 2005 -51, Cascade Natural Gas Corporation has requested written consent by the City to the merger transaction, to the extent that such consent is required under the franchise, in accordance with the terms, conditions, and requirements of the franchise, and a consideration of the draft ordinance was on the agenda at the City Council business meeting on June 19, 2007, and WHEREAS, closing of the merger transaction is subject to regulatory approval by the Washington Utilities and Transportation Commission (WUTC), and the application of the merger transaction was filed by MDU Resources and Cascade Natural Gas Corporation with the WUTC on November 13, 2006, entitled "In the Matter of the Joint Application of MDU Resources Group, Inc. and Cascade Natural Gas Corporation For an Order Authorizing Proposed Transaction ", Docket UG- 061721, and the WUTC approved the proposed merger transaction in Order 06 on June 27, 2007, and WHEREAS, the City has reviewed the franchise consent application letter and accompanying materials and has reviewed the approval of the proposed merger transaction by the Washington Utilities and Transportation Commission that was entered in Order 06 on June 27, 2007, and has concluded that the City's consent to the merger transaction should be given, now, therefore, BE IT ORDAINED BY THE CITY OF YAKIMA. SECTION 1 The City hereby consents to and approves the merger transaction between Cascade Natural Gas Corporation and MDU Resources, to the extent such consent is required by the terms and conditions of the franchise and applicable law, and the continuation by Cascade Natural Gas Corporation of all obligations and liabilities under City of Yakima Ordinance No 2005 -51, known and unknown, subject to applicable law SECTION 2 The franchise, as granted by Ordinance No 2005 -51, shall be amended upon the effective date of this ordinance, as set forth in section 4 of this ordinance Any terms of City of Yakima Ordinance No 2005 -51 not expressly amended by this ordinance shall remain in full force and effect. -2- e SECTION 3 Upon the date this ordinance becomes effective, this ordinance shall have the force of a continuing agreement with Cascade Natural Gas Corporation and shall not be amended, changed or otherwise altered without the consent of the City and Cascade Natural Gas Corporation SECTION 4 This ordinance shall be in full force and effect thirty (30) days after its passage, approval, and publication as provided by law and by the City Charter PASSED BY THE CITY COUNCIL, signed and approved this 3rd day of July, 2007 CITY OF YAKIMA CASC A : NATURAL GAS ____........... CO" ORLTIS ,,, David Edler, Mayo Its - ' , se ∎2 - Ffr SA- ' Attest: K/4;' i t Clerk t • ' 0 E4 r ,i •ma ° *�. z s tiI AJ GI. O Publication Date 7/6/07 -..,--- Effective Date 8/5/07 State of Washington ) ) ss County of K1 n1( ) 1 hereby certify that I know or have satisfactory evidence that 'e l E . MP_wfecc t-rAn is the person who appeared before me, and said person acknowledged that he /she signed this instrument, and on oath stated that he /she was authorized to execute the instrument on behalf of Cascade Natural Gas Corporation, and acknowledged it as the Se 4.1c o r ' t re c tn( of Cascade Natural Gas Corporation, to be the free and voluntary act of such party for the uses and purposes mentioned in this instrument. Dated th 4 day of July, 2007 ,n us,, ham, C, • . Print Name '? rnav C CabroJeS N•••••••• NOTARY PUBLIC in an &4 or the State of ;. Washington, residing at Kt N6, e 014VA My commission expires 0C-7 6, 2010 , L L ‘ � N . -3- [Service Date June 2 2007 • [s 7, 20071 BEFORE THE WASHINGTON STATE UTILITIES AND TRANSPORTATION COMMISSION In the Matter of the Joint Application of ) DOCKET UG- 061721 ) MDU RESOURCES GROUP, INC ) AND CASCADE NATURAL GAS ) ORDER 06 CORPORATION ) ) For an Order Authonzing Proposed ) APPROVING AND ADOPTING Transaction ) STIPULATION, AUTHORIZING ) TRANSACTION ) Synopsis The Washington Utilities and Transportation Commission approves and adopts an unopposed Stipulation that proposes by its terms to resolve all issues in this proceeding The Stipulation includes 36 commitments from the applicants, including ring fencing provisions to maintain Cascade Natural Gas Corporation 's financial independence from its new parent corporation and other corporate affiliates The commitments preserve the Commission's access to information necessary to its regulatory responsibilities, protect service quality, protect consumers from rate impacts and preserve low - income programs Taken together, the commitments address the Commission's concerns in connection with MDU Resources Group, Inc's proposed acquisition of Cascade Natural Gas Corporation. The Commission, by this Order, authorizes the proposed transaction. SUMMARY PROCEEDINGS• Cascade Natural Gas Corporation (Cascade) and MDU Resources Group, Inc (MDU Resources) filed a Joint application on November 13, 2006, for an order authorizing MDU Resources' acquisition of all outstanding common stock of Cascade The Washington Utilities and Transportation Commission (Commission) convened a preheanng conference Olympia, Washington on December 6, 2006, before Administrative Law Judge Dennis J Moss. The Commission, among other things, adopted an agreed schedule upon which to consider the Joint application. • DOCKET UG- 061721 PAGE 2 'V ORDER 06 2 MDU Resources, Cascade, the Commission's regulatory staff (Commission Staff or Staff), the Public Counsel Section of the Washington Office of the Attorney General (Public Counsel), Northwest Industnal Gas Users (NWIGU), the Energy Project, and Boise Cascade LLC (Boise Cascade) filed a Stipulation on May 9, 2007, and requested that the Commission approve and adopt its terms in full resolution of the issues in this proceeding.' 3 PARTY REPRESENTATIVES: James M. Van Nostrand and Laurence Reichman, Perkins Cole LLP, Portland, Oregon, represent MDU Resources and Cascade Melinda J Davison, Matthew Perkins and Sarah Yasutake, Portland, Oregon, represent Weyerhaeuser, Boise Cascade and Longview Fibre John A. Cameron, Davis Wright Tremaine LLP, Portland, Oregon, represents Cost Management Services, Inc Edward A. Finklea, Chad M. Stokes and Lindsay R. Kandra, Cable Huston Benedict Haagensen & Lloyd LLP, Portland, Oregon, represent NWIGU Ron Roseman, attorney, Seattle, Washington, represents the Energy Project. Simon ffitch, Assistant Attorney General, Seattle, Washington, represents Public Counsel. Gregory Trautman, Assistant Attorney General, Olympia, Washington, represents Commission Staff. 4 COMMISSION DETERMINATIONS• The Commission finds its adoption and approval of the parties' Stipulation will establish conditions that ensure the proposed transaction is consistent with the public interest. The Commission concludes it should approve the Revised Application filed by MDU Resources and Cascade on March 23, 2007, and authorize MDU Resources' acquisition of Cascade pursuant to the terms of the Revised Application, subject to the requirements included in the Stipulation. The remaining parties to this proceeding, Cost Management Services, Inc., Weyerhaeuser Company and Longview Fibre, are not signatories to, but do not oppose the Stipulation. 2 In formal proceedings, such as this case, the Commission's regulatory staff functions as an independent party with the same nghts, pnvileges, and responsibilities as any other party to the proceeding. There is an "ex parte wall" separating the Commissioners, the presiding Administrative Law Judge, and the Commissioners' policy and accounting advisors from all parties, including Staff. RCW 34 05 455 DOCKET UG-061721 PAGE 3 ORDER 06 MEMORANDUM I. Background and Procedural History 5 MDU Resources and Cascade (Applicants) initiated Docket UG- 061721 by filing on November 13, 2006, their joint application for an order authonzmg MDU Resources' acquisition of all outstanding common stock of Cascade. The parties held a technical workshop on February 20, 2007, followed by a settlement conference on March 5, 2007 On March 23, 2007, Applicants submitted a Revised Application to incorporate modifications to the structure of the transaction, as agreed during settlement discussions. The parties held additional settlement conferences and reached agreement on the principal terms of a full settlement on Apnl 20, 2007 6 On May 9, 2007, MDU Resources, Cascade, Staff, Public Counsel, NWIGU, the Energy Project, and Boise Cascade, filed their Stipulation. They request that the Commission approve and adopt the Stipulation as a full resolution of all issues pending in this proceeding. By a letter filed on May 21, 2007, Weyerhaeuser stated that it does not intend to sign the Stipulation or become a party to it, but does not oppose its adoption. The remaining intervenors, CMS and Longview Fibre, stated no opposition to the Commission's adoption of the Stipulation. 7 The parties filed their narrative in support of the Stipulation on May 11, 2007 The narrative describes the proposed transaction in detail. According to the parties, the transaction will be completed in substantially the following manner a. The transaction will be effected pursuant to a reverse triangular merger whereby MDU Resources will acquire all of the outstanding common stock of Cascade for a purchase price of $26 50 per common share or approximately $305 million in cash through Merger Sub, a subsidiary of MDU Resources formed specifically to effectuate the acquisition. At the effective time of the merger, Merger Sub will cease to exist. b The corporate organizational structure that MDU Resources anticipates after closing of the acquisition is set forth in the Post Acquisition Cascade Organizational Chart included as Attachment 1 • DOCKET UG- 061721 PAGE 4 0 ORDER 06 to the transaction commitments. Without regard to the possible use of short term bndge financing (which if used would be repaid at the time permanent financing is put into place), the following steps describe the sequence of events MDU Resources anticipates in establishing Cascade as "nng fenced" in the support of a Non - Consolidation Opinion which Cascade commits to obtain under one of the commitments (i) MDU Resources will either issue new common equity or utilize other available capital resources to fund approximately $220 million for the purchase of the existing Cascade stock. (ii) Debtco, as identified in Attachment 1 and the Stipulation, will obtain approximately $85 million of additional funds through debt financing to complete the funding for the purchase of the Cascade stock. Approximately $165 million of existing debt at Cascade will remain at Cascade and be unaffected by the merger (iii) Approximately $305 million will be transferred to a paying agent who will pay Cascade's existing shareholders MDU Resources will make capital contributions to Debtco Debtco will make capital contributions to Equico, as identified in Attachment 1 to Appendix A of the Stipulation, such that, upon the completion of the transaction, Equico will then own 100% of the stock of Cascade and Debtco will own 100% of the stock of Equico (iv) Equico's stock will be the asset supporting Debtco's loan of approximately $85 million. Equico is expected to be established as a bankruptcy- remote special purpose entity, and is not expected to have debt. (v) At least one director of Equico will be an Independent Director, as described in one of the commitments c In summary, MDU Resources plans to cause all of the common stock of Cascade to be owned by Equico, a new Delaware limited liability company and wholly -owned subsidiary of Debtco, also a Delaware limited liability company whose stock will be owned by MDU 3 The transaction commitments are included as Appendix A to the Stipulation filed with the Commission on May 9, 2007 DOCKET LTG-061721 PAGE 5 ORDER 06 Resources. This structure and transactional flow result in the assets, habihties and equity of Cascade remaining as presently recorded. 8 The Commission conducted a heanng to consider the Stipulation on June 18, 2007 Counsel for MDU Resources and Cascade, and Bruce T Imsdahl, President and CEO of Montana - Dakota Utilities Co (Montana- Dakota), a division of MDU Resources, made opening statements. The parties made available to the Commission for questioning a panel of witnesses including Dave Goodin, who will be Cascade's new president once the transaction is completed, John F Renner, Executive Vice President, Finance and Chief Accounting Officer for Montana - Dakota, Jon T Stoltz, Senior Vice President, Cascade Natural Gas, Ken Elgin for Commission Staff; Steven Johnson and Glenn Watkins for Public Counsel, and Paula Pyron for NWIGU II. Settlement Agreement S 9 The parties recommend under the terms of the Stipulation that the Commission issue an order approving the transaction, imposing as conditions the 36 commitments set forth in Appendix A to the Stipulation. The Stipulation, including Appendix A, is attached to and made a part of this Order by this reference Applicants' commitments include proposed conditions in the following areas • Access to relevant information. • Rate credits and other rate issues. • Cascade's financial stability • Ring - fencing provisions. • Cost allocation and cross - subsidization issues • Low - income programs • Quality of service measures • Commitment implementation issues. 10 The settling parties, arguing that the Commission should find the Stipulation to be in the public interest, focus their joint testimony on the significant financial protections, • particularly the nng- fencing provisions, the financial incentive of a $672,000 per year rate credit commitment for five years, and insulation of customers from transactional DOCKET UG- 061721 PAGE 6 0 ORDER 06 costs and increased operating costs attributable to the merger Public Counsel adds service quality reporting commitments to its focus and the Energy Project emphasizes the several commitments to continue low income assistance and weathenzation programs. 11 The settlement includes a "most favored state" clause to ensure Washington could receive the benefit of any additional commitments the companies make in Oregon where regulatory approval is also required!' III. Discussion and Decisions 12 The standard under Chapter 80 12 RCW and WAC 480 - 143 -170 for approval of transactions such as the one proposed here is that the Commission will deny an application if it determines "the proposed transaction is not consistent with the public interest. i The Commission described this as a "no harm" standard in its Third Supplemental Order in Docket UE- 981627, the 1999 proceeding in which the Commission approved the merger between PacifiCorp and ScottishPower PLC (ScottishPower case) 13 As we observed in the ScottishPower case, two threshold cntena in considering whether a merger of this type meets the no harm test are the acquiring company's financial and managerial fitness to take over the acquired utility's operations, including its ability to run those operations safely and reliably Mr Renner, responding to questions from the Bench, stated that MDU Resources, while acquiring Cascade, is simultaneously involved in other transactions that will result in a cash infusion sufficient to fund the acquisition in a manner that will be perceived by analysts as financially neutral. Thus, from the perspective of the financial markets, the transaction should cause no change in the corporate family's financial condition. MDU Resources' prefiled testimony includes significant evidence of the company's financial fitness and also establishes its managenal fitness to run Cascade's operations safely and reliably 6 4 The Public Utility Commission of Oregon approved a stipulation similar in its terms to the Stipulation pending before us and authorized the transaction on June 5, 2007, in Order 07 -221 WAC 480 -143 -170 6 Exhibit 5 (Imsdahl Direct) at 5 4 — 8 7, 9 — 20 (managerial fitness), Exhibit 7 (Renner Direct) at 5 — 9:3 (financial fitness); 9 — 11.33, 13 8 — 16, 17 16 — 19:22 (managenal fitness). • _ DOCKET UG-061721 PAGE 7 ORDER 06 14 The 36 commitments that are part of the Stipulation ensure that the Commission will have access to information necessary to continue to regulate Cascade. Cascade's financial statements and other financial books and records will be maintained separately from the books and records of MDU Resources Furthermore, Cascade will maintain its own credit rating for the purpose of issuing debt and preferred equity separate from MDU Resources and its affiliates. Commitment 3 addresses the access to be provided to books of account, as well as all documents, data, and records of their affihated interests, which pertain to transactions between Cascade and its affiliated interests or which are otherwise reasonably calculated to lead to discoverable information regarding Cascade. The Stipulation confirms that, as provided under Washington law or regulation, the Commission may audit the accounting records of MDU Resources and its subsidiaries or divisions that are the basis for charges to Cascade Applicants agree to notify the Commission in the event of certain acquisitions by MDU Resources. The Commission will be kept appnsed of 110 written information provided by and to credit rating agencies pertaining to Cascade Commitment 26 provides for access to corporate minutes that provide relevant information regarding Cascade's business and associated nsk analysis. Cascade and MDU Resources agree to provide a copy of any report resulting from an audit or review undertaken by any regulatory body pertaining to cost allocations and affiliated transactions involving Cascade and MDU Resources' regulated operations 15 The commitments provide for the measuring and reporting of certain service quality information to monitor the quality of service provided by Cascade after the transaction. To ensure service quality, the Stipulation includes measunng and reporting requirements in Commitment 22 for calendar years 2008 and 2009 These reports will be provided to the Commission, the parties to this docket and made available to the public within 90 days following the end of the calendar year The reports will include significant detail concerning customer complaints and Cascade's responsiveness to customers in the ordinary course of business. This oversight program will be reviewed after December 31, 2009, and the Commission will receive a report recommending whether to continue the program in its proposed, or another, form. r DOCKET UG- 061721 PAGE 8 O ORDER 06 16 The commitments address cost allocation and cross - subsidization issues to ensure that Cascade's Washington customers will bear only those costs associated with providing retail gas distribution services in Washington. Cascade commits to exclude all costs of the transaction, including acquisition premium and integration costs, from ratemakmg. Further, if there are costs that Cascade incurs for improved efficiencies which are proposed for rate case consideration, Cascade commits to provide to the Commission's satisfaction a demonstration of a net benefit to customers These commitments, in conjunction with other commitments that cap allocated costs and provide direct credits to customers, provide adequate assurance that there is no financial harm to customers from the transaction. 17 The commitments contain extensive ring - fencing provisions that will protect Cascade's customers from any adverse impacts associated with Cascade's ownership by MDU Resources, and include other financial protections such as limitations on Cascade's ability to declare dividends The ring- fencing provisions will protect ratepayers from future financial risk, including the risk of MDU Resources' bankruptcy, upon which subject Cascade expressly commits to obtain a non - consolidation opinion within three months of closing the transaction. Other provisions protect ratepayers from the effects of affiliated interest transactions, require MDU Resources and Cascade to keep separate books, records, and assets, and require that MDU Resources and Cascade provide the Commission and Staff with access to these financial records so the Commission can continue to regulate effectively 18 Apart from protecting against any adverse impacts associated with the transaction, the commitments also provide tangible, quantifiable benefits to Washington customers in the form of rate credits. Under Commitment 11, Cascade will provide $672,000 in annual rate credits that cannot be offset for three years, and which thereafter may be offset in a general rate case only under certain conditions. 19 Having just initiated two new programs with Cascade — the energy efficiency program begun in the fall of 2005 and the energy assistance program established as an outcome 9 In addition to dividend restrictions, Applicants agree in Commitment 29 to provide notice to the Commission when Cascade's dividend payment increases by 10% or more relative to dividends for the previous quarter DOCKET UG-061721 PAGE 9 ORDER 06 of the Company's most recent rate case — and being unfamiliar with the practices and policies of Montana - Dakota Utilities, the Energy Project stated its concerns about the future of the low - income assistance programs. Commitments 33, 34, and 35 address these concerns by ensuring that Cascade will continue to work cooperatively with the Energy Project and the relevant community -based organizations delivering these programs to provide bill assistance, and improve the delivery of energy efficiency measures to gas- heated low- income homes 20 In summary, the commitments undertaken here by MDU Resources and Cascade address comprehensively the range of concerns expressed by the parties to this proceeding, and the Commission's concerns as indicated in previous cases involving transactions of this type We are satisfied on the basis of our review of the record that the proposed transaction, conditioned by the terms of the Stipulation, is consistent with the public interest, thus meeting the applicable statutory and regulatory standards for authorization pursuant to chapter 80 12 RCW and WAC 480 - 143 -170 FINDINGS OF FACT 21 Having discussed above in detail the evidence received in this proceeding concerning all material matters, and having stated findings and conclusions upon issues in dispute among the parties and the reasons therefore, the Commission now makes and enters the following summary of those facts, incorporating by reference pertinent portions of the preceding detailed findings 22 (1) The Washington Utilities and Transportation Commission is an agency of the State of Washington, vested by statute with authority to regulate rates, rules, regulations, practices, and accounts of public service companies, including gas companies. 23 (2) Cascade is a "public service company" and a "gas company" as those terms are defined in RCW 80 04 010 and used in Title 80 RCW Cascade is engaged in Washington State in the business of supplying utility services and commodities to the public for compensation. 110 DOCKET UG- 061721 PAGE 10 ORDER 06 24 (3) MDU Resources' acquisition of Cascade on the terms provided by their Revised Application, as conditioned by the terms of the Stipulation attached to and made a part of this Order by pnor reference, including the 36 commitments set forth in Appendix A to the Stipulation, is consistent with the public interest. CONCLUSIONS OF LAW 25 Having discussed above all matters material to this decision, and having stated detailed findings, conclusions, and the reasons therefore, the Commission now makes the following summary conclusions of law, incorporating by reference pertinent portions of the preceding detailed conclusions 26 (1) The Washington Utilities and Transportation Commission has junsdiction over the subject matter of, and parties to, these proceedings 27 (2) MDU Resources' proposed acquisition of Cascade on the terms provided by their Revised Application, as conditioned by the terms of the Stipulation attached to and made a part of this Order by pnor reference, including the 36 commitments set forth in Appendix A to the Stipulation, meets the standards for approval as set forth in Chapter 80 12 RCW and WAC 480 - 143 -170 The Commission should authorize the proposed transaction. ORDER THE COMMISSION ORDERS 28 (1) The parties' Stipulation, filed in this Docket on May 9, 2007, is approved and adopted in full resolution of the issues pending in this proceeding. 29 (2) MDU Resources' acquisition of Cascade on the terms provided by their Revised Application, as conditioned by the terms of the Stipulation attached to and made a part of this Order by pnor reference, including the 36 commitments set forth in Appendix A to the Stipulation, is authorized. • DOCKET UG- 061721 PAGE 11 ORDER 06 30 (3) Cascade is authonzed and required to make any compliance filing necessary to effectuate the terms of this Order 31 (4) The Commission Secretary is authorized to accept by letter, with copies to all parties to this proceeding, a filing that complies with the requirements of this Order 32 (5) The Commission retains jurisdiction to effectuate the terms of this Order Dated at Olympia, Washington, and effective June 27, 2007 WASHINGTON STATE UTILITIES AND TRANSPORTATION COMMISSION MARK H SIDRAN, Chairman PATRICK J OSHIE, Commissioner PHILIP B JONES, Commissioner NOTICE TO PARTIES This is a Commission Final Order In addition to judicial review, administrative relief may be available through a petition for reconsideration, filed within 10 days of the service of this order pursuant to RCW 34 05 470 and WAC 480 -07 -850, or a petition for rehearing pursuant to 411 RCW 80.04.200 and WAC 480 -07 -870 DOCKET UG061721 PAGE 12 ORDER 06 STIPULATION 0 • • 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 BEFORE THE WASHINGTON STATE 18 UTILITIES AND TRANSPORTATION COMMIS SION 19 20 In the Matter of the Joint Application of 21 Docket No UG- 061721 ® 22 2 MDU RESOURCES GROUP, INC and CASCADE NATURAL GAS STIPULATION 24 25 CORPORATION 26 27 For an Order Authonzing Proposed Transaction 28 30 This Stipulation is entered into for the purpose of resolving all issues in this 31 proceeding by and among the parties as set forth below 32 33 34 I. PARTIES 36 1 The initial parties to this Stipulation (the "Stipulation ") are MDU Resources 38 Group, Inc. ( "MDU Resources "), Cascade Natural Gas Corporation ( "Cascade ") (MDU 40 Resources and Cascade are Jointly referred to as "Applicants "), Staff of the Washington 42 Utilities and Transportation Commission ( "Staff'), the Public Counsel Section of the Office 43 44 45 I In formal proceedings such as this, Staff is an independent party The three- member panel of Commissioners 46 is not a party to this Stipulation. The Commissioners must review, consider, and decide whether this 47 Stipulation should be adopted by the Commission. • STIPULATION— 1 Perkins Coie LLP 62016- 0002/LEGAL13207194 1 1120 N W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax. 503 727.2222 1 of the Attorney General ( "Public Counsel "), Northwest Industrial Gas Users ( "NWIGU "), 2 3 the Energy Project, and Boise Cascade LLC (together "the Parties" and individually 4 5 "Party ") This Stipulation will be made available to other parties to this docket, who may 6 7 participate by and filing a copy of this Stipulation. 8 9 II. RECITALS 10 11 2 On November 13, 2006, Applicants filed a joint application for an order 12 13 authonzing a proposed transaction (the "Transaction ") whereby MDU Resources would 14 15 acquire all of the outstanding common stock of Cascade and Cascade would thereafter 16 17 become a wholly owned subsidiary of MDU Resources. Applicants filed a revised joint 18 19 application on March 23, 2007, reflecting a structural change to the Transaction pursuant to 20 21 which Cascade would become an indirect wholly owned subsidiary of MDU Resources (the 22 23 "Application "). 24 25 3 Administrative Law Judge Dennis J Moss convened a preheanng conference 26 27 on December 6, 2006, and granted interventions for NWIGU, Weyerhaeuser, Boise Cascade 28 29 Corporation, Longview Fibre, and Cost Management Services, Inc. The Energy Project was 30 31 granted late intervention on March 20, 2007 in Order 03 Public Counsel also made an 32 33 appearance in this docket. 34 35 4 In accordance with the procedural schedule adopted at the preheanng 36 37 conference (Order 01), a technical workshop was held in Olympia on February 20, 2007, 38 39 followed by a settlement conference on March 5, 2007 An additional settlement conference 40 41 was held in Olympia on April 5, and telephonic settlement conferences occurred on 42 43 March 16, April 12, and April 20, 2007 44 45 46 47 STIPULATION— 2 Perkins Coie LLP 62016- 0002/LEGAL13207194 1 1120 N.W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax. 503 727.2222 • 1 5 Based on these discussions and related correspondence, the Parties have 2 3 reached agreement on proposed commitments that would provide a basis upon which the 4 5 Parties could recommend approval of the Transaction in Washington. 6 7 6. The Parties wish to present their agreement for the Commission's 8 9 consideration. The Parties therefore adopt the following Stipulation, which is entered into 10 11 by the Parties voluntarily to resolve matters in dispute among them in the interests of 12 13 expediting the orderly disposition of this proceeding. The Stipulation is bemg filed with the 14 15 Commission as a "Multiparty Settlement" pursuant to WAC 480 -07- 730(3). 16 17 III. THE POST- ACQUISITION ORGANIZATIONAL STRUCTURE 18 19 7 The steps by which the Transaction will be completed are described in the list 20 21 of commitments attached hereto as Appendix A. In addition, the corporate organizational . 23 structure that MDU Resources anticipates after closing of the acquisition is set forth in the 24 25 Post - Acquisition Cascade Organizational Chart that is Attachment 1 to Appendix A. In 26 27 summary, following completion of the transaction, all of the common stock of Cascade will 28 29 be owned by the entity identified in Attachment 1 as "Equico," which will be a new 30 31 Delaware limited liability company Equico will be a wholly -owned subsidiary of the entity 32 33 identified in Attachment 1 as "Debtco," which will also be a new Delaware limited liability 34 35 company which will be a wholly owned subsidiary of MDU Resources. 36 37 IV. TERMS OF THE STIPULATION 38 39 8 Appendix A contains the complete list of commitments that Applicants agree 40 41 to make in exchange for the support of the Parties in this proceeding (hereinafter referred to 42 43 as "Commitments ") By virtue of executing this Stipulation, the Applicants agree to perform 44 45 all of the Commitments set forth in Appendix A according to the provisions of each 46 47 Commitment as set forth therein. • STIPULATION— 3 Perkins Coie LLP 62016- 0002/LEGAL13207194.1 1120.N.W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax. 503 727.2222 1 9 In the process of obtaining approval of the Transaction in other, states, the 2 3 Commitments may be expanded or modified as a result of regulatory decisions or 4 5 settlements. In developing this Stipulation, the Parties considered and agreed upon adoption 6 7 of various commitments from the stipulation entered into by Applicants m the approval 8 9 proceeding in Oregon. The Applicants agree that the Commission shall have an opportunity 10 11 and the authority to consider and adopt in Washington any commitments or conditions to 12 13 which the Applicants agree or with which the Applicants are required to comply in other 14 15 jurisdictions, even if such commitments and conditions are agreed to after the Commission 16 17 enters its order m this docket. To facilitate the Commission's consideration and adoption of 18 19 the commitments and conditions from other junsdictions, the Parties urge the Commission 20 21 to issue an order accepting this Stipulation as soon as practical, but to reserve in such order 22 23 the explicit right to re -open Appendix A to add (without modification of the language 24 25 thereof except such non - substantive changes as are necessary to make the commitment or 26 27 condition applicable to Washington) commitments and conditions accepted or ordered in 28 29 another state jurisdiction. To provide input to the Commission to facilitate a prompt 30 31 decision regarding the desirability or lack of desirability for these out -of -state commitments 32 33 and conditions to be adopted in Washington, the Parties agree to and recommend the 34 35 following process 36 37 • Within five calendar days after a stipulation with new or amended 38 39 commitments is filed by the Applicants with a commission in another state 40 41 junsdiction, Applicants will send a copy of the stipulation and commitments 42 43 to the Parties. 44 45 • Within five calendar days after a commission in another state junsdiction 46 47 issues an order that accepts a stipulation to which Applicants are a party or STIPULATION— 4 Perkins Coie LLP 62016- 0002/LEGAL13207194 1 1120 N W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax: 503 727.2222 • 1 otherwise imposes new or modified commitments or conditions, that order, 2 3 together with all commitments and conditions of any type agreed to by 4 5 Applicants or ordered by the commission in such other state, will be filed 6 7 with the Commission and served on all Parties by the most expeditious means 8 9 practical. 10 11 • Withm ten calendar days after any such order from another state commission 12 13 is filed with this Commission, any Party wishing to do so shall file with the 14 15 Commission its response, including its position as to whether any of the 16 17 covenants, commitments, and conditions from the other junsdiction (without 18 19 modification of the language thereof except such non - substantive changes as 20 21 are.necessary to make the commitment or condition applicable to . 22 23 Washington) should be adopted in Washington. 24 25 • Within five. calendar days after any such response filing, any Party may file a 26 27 reply with the Commission. The Parties agree to support in their filings (or 28 29 by representation of same by MDU Resources) the issuance by the 30 31 Commission of an order regarding the adoption of such commitments and 32 33 conditions as soon as practical thereafter 34 c 35 • If the last day of any calendar time penod referenced above falls on a 36 37 Saturday, Sunday, or a holiday, the next business day will be considered as 38 39 the last day 40 41 10 MDU Resources and Cascade will promptly disclose to the Parties any 42 43 written commitments, conditions, or covenants made in another state junsdiction (between 44 45 the date of the filing ofthe Stipulation and the receipt of the last state order in a transaction 46 47 • STIPULATION— 5 Perkins Coie LLP 62016 - 0002 /LEGAL13207194 1 1120 N W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax. 503 727.2222 1 docket) intended to encourage approval of the Transaction or avoidance of an objection 2 3 thereto 4 5 11 The Parties agree that with the commitments set forth in paragraphs 8 6 7 through 10 above, mcludmg those in Appendix A, the Transaction meets the pubhc interest 8 9 standard under RCW 80 12.020 and WAC 480 - 143 -170 for approval in Washington. The 10 11 Parties therefore agree to support this Stipulation as a settlement of all issues in this 12 13 proceeding and to recommend approval of the Transaction and the Application. The Parties 14 15 encourage the Commission to enter a final Washington approval order by June 5, 2007 The 16 17 Parties understand that this Stipulation is not bindmg on the Commission in ruling on the 18 19 Application. 20 21 12 The Parties agree that this Stipulation represents a compromise in the 22 23 positions of the Parties. As such, conduct, statements, and documents disclosed in the 24 25 negotiation of this Stipulation shall not be admissible as evidence in this or any other 26 27 proceeding. By executing this Stipulation, no Party shall be deemed to have approved, 28 29 admitted, or consented to the facts, principles, methods, or theones employed in arnving at 30 31 the terms of this Stipulation, nor shall any Party be deemed to have agreed that any 32 33 provision of this Stipulation is appropnate for resolving issues in any other proceeding, 34 35 except those proceedings involving the enforcement or implementation of the terms of this 36 37 Stipulation. 38 39 13 Applicants acknowledge that the Commission's approval of the Stipulation, 40 41 the Commitments, or the Joint Application shall not bind the Commission in other 42 43 proceedings with respect to the determination of prudence, just and reasonable character, 44 45 rate or ratemaking treatment, or public interest of services, accounts, costs, investments, any 46 47 particular construction project, expenditures, or actions referenced in these Commitments. STIPULATION— 6 Perkins Coie LLP 62016- 0002/LEGAL13207194 1 1120 N W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax. 503 727.2222 1 14 The Parties shall cooperate in submitting this Stipulation promptly to the 2 3 Commission for acceptance, and shall cooperate in developing a supporting narrative 4 5 statement as required by WAC 480 -07- 740(2). The Parties agree to support the Stipulation 6 7 throughout this proceeding, provide a panel of witnesses to sponsor such Stipulation as well 8 9 as legal representatives to support the Stipulation at a Commission heanng if necessary), 10 11 and recommend that the Commission issue an order adopting the settlements contained 12 13 herein. In the event the Commission rejects this Stipulation or accepts this Stipulation upon 14 15 conditions not contained herein, the provisions of WAC 480 -07- 750(2) shall apply 16 17 15 Subject to Paragraph 16 of this Stipulation, the effective date of this 18 19 Stipulation shall be the date entered below 20 21 16 The obligations of the Applicants under this Stipulation are subject to the 41, 22 23 Commission's approval of the Application in this docket on terms and conditions acceptable 24 25 to the Applicants, in their sole discretion, and the closing of the Transaction. 26 27 This STIPULATION is entered into by each Party as of the date entered below 28 29 DATED May 8, 2007 30 32 MDU Resources Group, Inc. Staff of the Washington Utilities and 33 Transportation Commission 34 35 By By 36 37 38 39 40 Cascade Nat a Gal Corporation Northwest Industrial Gas Users 42 By A dria B Y By 43 Jon 4 1f. z Paula E. Pyron 44 Sr % esident- Gas Supply & Executive Director 45 Re: ory 46 47 • STIPULATION— 7 Perkins Coie LLP 62016 -0002 /LEGAL13207194.1 1120 N W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax. 503 727.2222 1 14 The Parties shall cooperate in submitting this Stipulation promptly to the 2 3 Commission for acceptance, and shall- cooperate in developing a supporting narrative 4 5 statement as required by WAC 480 -07- 740(2). The Parties agree to support the Stipulation 6 7 throughout this proceeding, provide a panel of witnesses to sponsor such Stipulation as well 8 9 as legal representatives to support the Stipulation at a Commission hearing (if necessary), 10 11 and recommend that the Commission issue an order adopting the settlements contained 12 13 herein. In the event the Commission rejects this Stipulation or accepts this Stipulation upon 14 15 conditions not contained herein, the provisions of WAC 480 -07- 750(2) shall apply 16 17 15 Subject to Paragraph 16 of this Stipulation, the effective date of this 18 19 Stipulation shall be the date entered below 20 21 16 The obligations of the Applicants under this Stipulation are subject to the 22 23 Commission's approval of the Application in this docket on terms and conditions acceptable 24 25 to the Applicants, in their sole discretion, and the closing of the Transaction. 26 27 This STIPULATION is entered into by each Party as of the date entered below 28 29 DATED - 30 31 MDU Resources Group, Inc. Staff of the Washington Utilities and 32 33 Transportation Commission 35 By ` By 36 ry D. Hildestad 37 President & Chief Executive 38 Officer 39 40 Cascade Natural Gas Corporation Northwest Industrial Gas Users 41 42 By B 43 Paula E. Pyron 44 Executive Director 45 46 Public Counsel The Energy Project 47 gY J STIPULATION— 7 Perkins Coie ter 62016 0002/LEGAL13207194 1 1120 N W Couch Street, Tenth Floor Portland, OR 97209-4128 Phone: 503 727.2000 Fax: 503 727.2222 III 1 14 The Parties shall cooperate in submitting this Stipulation promptly to the 2 3 Commission for acceptance, and shall cooperate in developing a supporting narrative 4 5 j statement as required by WAC 480 -07- 740(2). The Parties agree to support the Stipulation 6 7 throughout this proceeding, provide a panel of witnesses to sponsor such Stipulation as well 8 9 as legal representatives to support the Stipulation at a Commission hearing (if necessary), 10 11 and recommend that the Commission issue an order adopting the settlements contained 12 13 herein. In the event the Commission rejects this Stipulation or accepts this Stipulation upon 14 15 conditions not contained herein, the provisions of WAC 480-07-750(2) shall apply 16 17 15 Subject to Paragraph 16 of this Stipulation, the effective date of this 18 19 Stipulation shall be the date entered below 20 21 16 The obligations of the Applicants under this Stipulation are subject to the . 22 23 Commission's approval of the Application in this docket on terms and conditions acceptable 24 25 to the Applicants, in their sole discretion, and the closing of the Transaction. 26 27 This STIPULATION is entered into by each Party as of the date entered below 28 29 DATED 30 31 MDU Resources Group, Inc. Staff of t . • Washin: on Utilities and 32 33 Transp , lion rem ,' 'ssi 34 35 B y By 46/.. ,,i% ` G ./ 36 /c'_o `. T 'Iran, .� • 37 Assis • IT 11 ' - y General 38 39 40 41 I Cascade Natural Gas Corporation Northwest Industrial Gas Users 42 43 By B 44 Paula E. Pyron 45 Executive Director 46 47 STIPULATION— 7 Perkins Cole LLP III 62016 -0002 /LEGAL 13207194.1 1120 N.W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax: 503 727.2222 05/08/2007 18 29 FAX 5036360703 PAULA_PYRON 1g 00.8/009 0 1 14 The Parties shall cooperate in submitting this Stipulation promptly to the 2 3 Commission for acceptance, and shall cooperate in developing a supporting narrative 4 5 statement as required by WAC 480 -07- 740(2). The Parties agree to support the Stipulation 6 7 throughout this proceeding, provide a panel of witnesses to sponsor such Stipulation as well 8 9 as legal representatives to support the Stipulation at a Commission hearing (if necessary), 10 1 1 and recommend that the Commission issue an order adopting the settlements contained 12 13 herein. In the event the Commission rejects this Stipulation or accepts this Stipulation upon 14 15 conditions not contained herein, the provisions of WAC 480 - 750(2) shall apply 16 17 I 15 Subject to Paragraph 16 of this Stipulation, the effective date of this l 8 19 Stipulation shall be the date entered below 20 2i 16. The obligations of the Applicants under this Stipulation are subject to the 22 III 23 Commission's approval of the Application in this docket on terms and conditions acceptable 24 25 to the Apphcants, in their sole discretion, and the closing of the Transaction. 26 27 This STIPULATION is entered into by each Party as of the date entered below 28 29 DATED 30 31 MDU Resources Grou Inc. 32 P+ Staff of the Washington Utilities and 33 Transportation Commission 34 35 B y By 36 Gregory J Trautman, 37 Assistant Attorney Genera] 38 39 40 41 Cascade Natural Gas Corporation Northwest Industrial Gas Users 42 43 By By °Pa Jo!' 7"' `' T.--- 44 Paula E. Pyron 45 Executive Director 46 47 STIPULATION— 7 Perkins Coie LuP 62016.0002/LEC3ALI3207194 1 1120 N W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503,727.2000 Fax: 503 727.2222 • 1 2 Public Co nsel The Energy Project 3 4 By / ' By 5 e : - th Krebs Ronald L. Roseman 6 ' ssistant Attorney General Attorney at Law 7 8 9 Boise Cascade LLC 10 11 By 12 13 14 15 16 17 18 19 20 21 22 S 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 STIPULATION— 8 Perkins Coie LLP • 62016 0002/LEGAL13207194 I 1120 N W Couch Street, Tenth Floor Portland, OR 97209 -4128. Phone: 503 727.2000 Fax: 503 727.2222 FEB -16 -2005 06 47 From RON ROSEMAN 206 568 0138 To Fax Server P 2/2 1 3 Public Counsel The E Proje 4 B By 5 Judith Krebs Ronald L. Roseman 6 Assistant Attorney General Attorney at Law 7 8 9 Boise Cascade LLC 10 11 lay 12 13 14 IS 16 17 18 19 20 21 23 24 25 26 27 28 79 30 31 32 33 34 35 36 37 38 39 40 41 42 43 ' 44 45 46 47 STIPULATION— 8 Perkins Cnie 1.1. 62016- 11012/1.F.(iA1.117117194 1 1120 N.W Couch Strcct, Tenth Floor Portland, OR 97209 -41211 Phone: 503 727,2000 Fax. 503 727.2222 • 3 Public Counsel The Energy Project 4 5 By By Judith Krebs Ronald L. Roseman 6 7 Assistant Attorney General Attorney at Law 8 9 Boise Cascade LLC 10 ' 11 By G( 12 M thew W. Per ns 13 Attorney at Law — 14 15 16 17 18 19 20 21 22 • 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 � 41 42 43 44 45 46 47 STIPULATION 8 Perkins Coie LLP • 62016- 0002/LEGAL13207194.1 1120 N.W Couch Street, Tenth Floor Portland, OR 97209 -4128 Phone: 503 727.2000 Fax. 503 727.2222 Appendix A MDU Resources Acquisition of Cascade Natural Gas Corporation MDU Resources Group, Inc. ( "MDU Resources ") and Cascade Natural Gas Corporation ( "Cascade ") have filed a joint application with the Washington Utilities and Transportation Commission for an order authorizing a transaction whereby MDU Resources would acquire all of the outstanding common stock of Cascade and Cascade would thereafter become an indirect wholly -owned subsidiary of MDU Resources (the "Transaction "). The Transaction will be completed in substantially the following manner The Transaction would be effected pursuant to a reverse triangular merger whereby MDU Resources will acquire all of the outstanding common stock of Cascade for a purchase price of $26 50 per common share or approximately $305 million in cash through Merger Sub, a subsidiary of MDU Resources formed specifically to effectuate the acquisition. At the effective time of the merger, Merger Sub will cease to exist. The corporate organizational structure that MDU Resources anticipates after closing of the acquisition is set forth in the attached Post Acquisition Cascade Organizational Chart ( "Attachment 1 "). Without regard to the possible use of short term bridge financing (which if used would be repaid at the time permanent financing is put into place), the following steps describe the sequence • of events MDU Resources anticipates in establishing Cascade as ring fenced in the support of the Non- Consolidation Opinion addressed in commitment 30 1 MDU Resources will either issue new common equity or utilize other available capital resources to fund approximately $220 million for the purchase of the existing Cascade stock. 2 Debtco, as identified in Attachment 1 and the Stipulation, will obtain approximately $85 million of additional funds through debt financing to complete the funding for the purchase of the Cascade stock. Approximately $165 million of existing debt at Cascade will remain at Cascade and be unaffected by the merger 3 Approximately $305 million will be transferred to a paying agent who will pay Cascade's existing shareholders. MDU Resources will make capital contributions to Debtco Debtco will make capital contributions to Equico, as identified in Attachment 1 and the Stipulation, such that, upon the completion of the Transaction, Equico will then own 100% of the stock of Cascade and Debtco will own 100% of the stock of Equico 4 The stock of Equico will be the asset supporting Debtco's loan of approximately $85 million Equico is expected to be established as a bankruptcy - remote special purpose entity, and is not expected to have debt. • 5 At least one director of Equico will be an Independent Director as described in commitment 7 In summary, MDU Resources plans to cause all of the common stock of Cascade to be owned by Equico, a new Delaware limited liability company and wholly -owned subsidiary of Debtco, also a Delaware limited liability company whose stock will be owned by MDU This structure and transactional flow results in the assets, liabilities and equity of Cascade remaining as presently recorded In support of the application, MDU Resources and Cascade make the following commitments. 1 Cascade will maintain its own accounting documentation, and financial data will be accessible in Cascade's Washington office Cascade's financial books and records and state and federal utility regulatory filings and documents will continue to be maintained in Cascade's Washington office consistent with current practice and be available to the Commission, upon request. 2 Financial statements and other financial books and records for Cascade shall be maintained separate from the books and records of MDU Resources. The assets of Cascade and its subsidiaries will be accounted for separately from the assets of MDU Resources and its other subsidiaries, divisions and affiliates in accordance with the Commission's rules governing the System of Accounts. This condition shall not prevent the maintenance of books and records for Cascade, MDU Resources or their affiliates on or through a common computer accounting platform This condition shall also not prevent, for non - Washington regulatory purposes, the consolidated treatment or reporting of financial statements, financial results, and other financial books and records of Cascade, MDU Resources or their subsidiaries and affiliates for financial reporting, tax or other purposes 3 MDU Resources and Cascade will provide the Commission and Commission Staff access to all books of account, as well as. all documents, data, and records of their affiliated interests, which pertain to transactions between Cascade and its affiliated interests or which are otherwise reasonably calculated to lead to discoverable information regarding Cascade Upon request and subject to execution of a confidentiality agreement that incorporates the terms of the Commission's standard protective order, MDU and Cascade will provide copies of relevant documents subject to this commitment to Public Counsel and other consumer parties to this docket. 4 In accordance with Washington law or regulation, the Commission or its agents may audit the accounting records of MDU Resources and its subsidiaries or divisions that are the basis for charges to Cascade. MDU Resources agrees to cooperate fully with such Commission audits 5 Any diversified holdings and investments (e g , non - utility related business or foreign utilities) of MDU Resources will not be held by Cascade or a subsidiary of 2 62016- 0002 /LEGAL13166275 7 • Cascade This condition will not prohibit MDU Resources or its affiliates other than Cascade from holding diversified businesses 6 Cascade will operate as an indirect wholly owned subsidiary of MDU Resources. Cascade agrees to hold its customers harmless from any business and financial risk exposures of MDU Resources or its other affiliates including Centennial Energy Holdings, Inc. (Centennial) The business and financial risk exposure to Cascade shall be that of a stand -alone regulated utility Cascade will not issue debt for the acquisition of Cascade's stock by MDU Resources. No credit facilities at Cascade will contain cross - default provisions with respect to credit facilities at MDU Resources or Centennial or their respective subsidiaries. No credit facility signed by Cascade will allow any creditor of MDU Resources, Centennial or their subsidiaries (other than Cascade and its subsidiaries) to have recourse against Cascade or its subsidiaries, in the event of bankruptcy of MDU Resources or Centennial or their subsidiaries (other than Cascade and its subsidiaries) No credit facilities at MDU Resources or Centennial or their subsidiaries (other than Cascade and its subsidiaries) will contain cross - default provisions with respect to credit facilities at Cascade No credit facility signed by MDU Resources or Centennial or their respective subsidiaries will allow any creditor of Cascade or its subsidiaries to have recourse against MDU Resources or Centennial or their subsidiaries (other than Cascade and its subsidiaries) • 7 At least one director of Equico will be an Independent Director who is not a member, stockholder, director (except as such Independent Director of Equico), officer, employee, partner, attorney, creditor, supplier, or customer, other than an individual consumer, of MDU Resources or its affiliates. The organizational documents for Equico will not permit Equico, without the unanimous consent of all its directors including the Independent Director, to merge, liquidate or sell substantially all of Equico's assets or to consent to the institution of bankruptcy proceedings or the inclusion of Equico in bankruptcy proceedings 8 Cascade or MDU Resources will notify the Commission subsequent to MDU Resources' board approval and as soon as practicable following any public announcement of (1) any acquisition of a regulated or unregulated business representing 5 percent or more of the capitalization of MDU Resources, or (2) the change in effective control or acquisition of any material part or all of Cascade by any other firm, whether by merger, combination, transfer of stock or assets, or (3) any acquisition of a business with a substantial business presence in Cascade's service area that has a value in excess of $100 million or requires notification of the United States Securities and Exchange Commission 9 MDU Resources and Cascade shall comply with all Commission statutes, rules, and ordering conditions concerning affiliated interests filings This shall include the Inter - company Administrative Services Agreement (IASA). The IASA will include the corporate and affiliate cost allocation methodologies described in 3 62016- 0002 /LEGAL1 3166275 7 condition 12 The IASA will be filed with the Commission as soon as P racticable after the closing of the transaction by which Cascade becomes an indirect subsidiary of MDU Resources (the "Transaction "). Amendments to the IASA will also be filed with the Commission. MDU Resources and Cascade agree not to contest, for ratemaking purposes, the Commission's application of an asymmetrical pricing standard (reflecting the Commission's choice in setting rates between the more advantageous (1) of cost, including a reasonable retum, or (2) of market pricing) for affiliate charges or costs if a readily identifiable market for the goods, services or assets exists, and if the transaction involves a cost of more than $100,000 Filings by Cascade with the Commission regarding transactions with MDU Resources affiliates that involve a cost of more than $100,000 will include an explanation and a rationale for the purchase method used if other than a competitive bid process. 10 Cascade commits for Washington regulatory purposes, that commencing with closing of the Transaction and through December 31, 2012, the allocated shared corporate costs, as well as its allocated and assigned utility division costs, will not exceed the costs the Cascade customers would otherwise have paid absent the acquisition, as adjusted for changes in the Consumer Price Index. Application of the Consumer Price Index is limited to the instant commitment. Compliance with this condition shall be determined as follows. a For purposes of this condition, Cascade's Washington- direct plus allocated A &G costs will be based on the A &G categories, assumptions, and values contained in Attachment 2 titled, "900 Accounts. Stretch — Washington- allocated" using the proforma adjusted 2005 Accounts 901 through 935 labor and non -labor costs, as reflected in Cascade's general rate case Docket UG- 060256, but excluding Account 904 (uncollectible accounts) costs and excluding the $800,000 of low- income assistance that Cascade provides pursuant to the final order in Docket UG- 060256 (the "2006 Benchmark ") The pro forma adjusted 2006 Benchmark will be set at $21,642,845 as of December 31, 2006 The benchmark for each subsequent year shall equal the prior year's benchmark multiplied by the increase in the Consumer Price Index for All Urban Consumers All Items Index 1982 -84 =100 (Series CUUR0000SA) in the previous twelve months Except as provided in Condition 11, Cascade commits that during the period of this condition, Cascade's A &G costs, excluding Account 904 costs and the low- income assistance that Cascade provides pursuant to the final order in Docket UG- 060256, for rate making and regulatory reporting purposes shall be the lesser of its actual 900 Accounts costs, excluding Account 904 costs and the low- income assistance that Cascade provides pursuant to the final order in Docket UG- 060256 and including Commission Basis adjustments as provided in WAC 480 -90 -257, or the benchmark for the applicable year Cascade will not shift A &G costs to operational and maintenance accounts (FERC accounts 700 -894), capital 4 62016- 0002 /LEGALI 3166275.7 • accounts, deferred debit accounts, deferred credit accounts, or other regulatory accounts that are a basis for ratemaking -b Cascade may request that the Commission include in the benchmark A &G costs that are incurred or increased as a direct consequence of a change in a statute rule, or as a result of an o rder or directive of the Commission, effective after the date of this condition. The intent of this condition is to protect Cascade from, unforeseen mandated circumstances that could increase A &G costs 11 MDU Resources and Cascade further commit that beginning November 1, 2008 and continuing through December 31, 2012, Cascade will provide annual rate credits of $672,000 to Washington customers distributed on an equal margin basis unless otherwise ordered by the Commission. The rate credits in this paragraph will not be off - settable for the first three years, and thereafter will be fully off - settable, on a prospective basis, by the amount that Cascade demonstrates to the Commission's satisfaction in any general rate case that the Washington - allocated A &G expenses included in Cascade's rates are lower than the benchmark set in condition 10 and have not been shifted to operational and maintenance accounts (FERC accounts 700 -894), capital accounts, deferred debit accounts, deferred credit accounts, or other regulatory accounts that are a basis for ratemaking The rate credits shall be provided as bill credits for each • month that this condition is in effect, pro -rated based upon estimated volumes and subject to true -up on an annual basis in a manner to be approved by the Commission Rate credits shall be excluded from Cascade's regulatory accounts and shall be paid for out of shareholder funds 12 Any corporate cost allocation used for rate setting, and subsequent changes thereto, will be submitted to the Commission for review Any proposed cost allocation methodology for the allocation of corporate and affiliate investments, expenses, and overheads, required by law or rule to be submitted to the Commission for review or approval, will comply with the following principles a For services rendered to Cascade or each cost category subject to allocation to Cascade by MDU Resources or any of its affiliates, Cascade must be able to demonstrate that such service or cost category is necessary to Cascade for the performance of its regulated operations, is not duplicative of services already being performed within Cascade, and is reasonable and prudent. b Cost allocations to Cascade and its subsidiaries will be based on generally accepted accounting standards, that is, in general, direct costs will be charged to Cascade and its subsidiaries whenever possible and shared or indirect costs will be allocated based upon the primary cost - driving factors • 5 6201 6- 0002/LEGAL l 3166275.7 c. MDU Resources and its divisions will have in place an allocation or 411 reporting system adequate to support the allocation and assignment of costs of executives and other relevant personnel to Cascade d An audit trail will be maintained such that all costs subject to allocation can be specifically identified, particularly with respect to their origin In addition, the audit trail must be adequately supported Failure to adequately support any allocated cost may result in denial of its recovery in rates e Costs which would have been denied recovery in rates had they been incurred by Cascade regulated operations will likewise be denied recovery they are allocated directly or indirectly through MDU Resources Cascade shall include in any rate case filing a determination confirming this provision or a proposed implementing ratemaking adjustment, if necessary 13 Cascade's debt and preferred equity will be maintained separate from the financial securities of MDU Resources and its affiliates. Cascade will maintain its own corporate credit rating separate from that of MDU Resources and its affiliates 14 Cascade will exclude all costs of the Transaction, including the acquisition premium (goodwill) and integration costs, from Cascade's utility accounts for ratemaking purposes (e g , general rate cases, earnings reviews, PGA filings, etc.) Within 90 days following completion of the Transaction, Cascade will provide a preliminary accounting of transaction costs. Further, Cascade will provide the Commission with a final accounting of these costs within 60 days of the close of accounting for the Transaction. For purposes of this. condition, "integration costs" include costs associated with determining how Cascade will operate effectively as an indirect subsidiary of MDU Resources after the Transaction closes Integration costs include but are not limited to senior executive officers costs as a result of employment agreement change of control provisions Integration costs will not include any costs that Cascade would have reasonably incurred absent the Transaction or costs incurred to combine Cascade's operating systems with those of MDU Resources for improved efficiencies or for other beneficial purposes. Transition costs are costs that are neither transaction nor integration costs and are incurred to improve efficiencies For purposes of this condition, transition costs may include by example, but are not limited to, combined platform and joint software licensing for applications such as customer information and work management systems. If Cascade proposes any transition costs for rate case purposes, it must provide to the Commission's satisfaction a demonstration of the net benefit for customers. This condition is without effect as to any future determination of whether these costs 6 62016- 0002/LEGAL13166275.7 • have been prudently incurred Cascade commits that it will not seek to defer any transition costs. 15 MDU Resources and Cascade will provide the Commission and Commission Staff,. upon .request, with unrestricted access to all written information provided by and to credit rating agencies that pertains to Cascade Upon request and subject to execution of a confidentiality agreement that incorporates the terms of the Commission's standard protective order, MDU Resources and Cascade will provide Public Counsel and other consumer parties to this docket with access to written information provided by and to credit rating agencies that pertains to Cascade. 16 MDU Resources and Cascade commit that neither Cascade nor its subsidiaries will, without the approval of the Commission, make loans to MDU Resources or its respective subsidiaries, or assume any obligation or liability as guarantor, endorser, surety or otherwise for MDU Resources or its respective subsidiaries; provided that this condition will not prevent Cascade, to the extent allowed by law, from making loans or transferring funds to a subsidiary of Cascade or assuming any obligation or liability on behalf of a subsidiary of Cascade MDU Resources and Cascade will not pledge any of the assets of the business of Cascade as backing for any securities which MDU Resources or its respective subsidiaries, but excluding Cascade and its subsidiaries, may issue. • 17 Cascade will not advocate for a higher cost of debt ore equity qu ty capital as compared to what Cascade's cost of debt or equity capital would have been, absent MDU Resources' ownership 18 Nothing in these acquisition conditions shall be interpreted as a waiver of Cascade's or MDU Resources' rights to request confidential treatment for information that is the subject of any conditions 19 Nothing in these acquisition conditions shall be interpreted to limit the Commission's authority under its statutes and rules. 20 The parties urge the following process for administering and enforcing the commitments, unless another process is provided by statute, Commission regulations or an approved Cascade tariff The Commission should give Cascade and MDU Resources written notification of any violation by either company of the commitments made in this application. If such failure is corrected within ten (10) business days for failure to file a report, or five (5) business days for other violations, the Commission should take no action The Commission shall have the authority to determine if the corrective action has satisfied or corrected the violation Cascade or MDU Resources may request, for cause, an extension of these time periods If Cascade or MDU Resources fails to correct such violations within the specified time frames, as modified by any 1111 7 62016- 0002 /LEGAL 13166275 7 Commission - approved extensions, the Commission ma. seek to compel Y p compliance with the commitment and assess penalties for violation of a Commission order, against either Cascade or MDU Resources, as allowed under state laws and regulations. The Commission may seek penalties only against MDU Resources for violations by only MDU Resources and only against Cascade for violations by only Cascade, but may seek penalties against both MDU Resources and Cascade when both have violated a commitment or condition 21 MDU Resources and Cascade commit to maintaining Cascade's provision of sales and distribution services to all classes of customers in a safe, reliable and prudent manner in conformity with its tariffs and obligations as a natural gas utility understate laws including but not limited to maintaining sufficient physical plant, gas supply and staffing levels to meet the needs of customers in its service territory in each state in which it operates 22 To ensure service quality,. Cascade commits to measuring and reporting certain information regarding customer service quality for calendar years 2008 and 2009 The reports shall include the following information, which will be provided to the Commission within 90 days following the end of the calendar year, provided to the parties to this docket, and made available for public inspection on Cascade's website The calculations for reporting will be based on calendar year a Cascade will separately report the number of customer complaints (i) received by Cascade and (ii) filed with the Commission b Cascade will report the average time from a customer call to the arrival of field technicians in response to a gas emergency c. Cascade will report the number of missed customer appointments. A customer appointment is defined as a mutually agreed appointment time between a customer and Cascade for service to be provided either when the customer needs to be present or when the customer need not be present. A missed customer appointment occurs when Cascade fails to keep a customer appointment. d Cascade will separately report the percentage of customer disconnects due to non - payment for (i) residential customers (schedule 503) and (ii) commercial customers (schedule 504) e For calendar year 2007, Cascade will report the percentage of calls answered live within sixty (60) seconds by its customer call center For calendar year 2008, Cascade will report the percentage of calls answered live within fifty (50) seconds by its customer call center For calendar year 2009, Cascade will 8 62016- 0002/LEGAL13166275 7 • report the percentage of calls answered live within forty (40) seconds by its customer call center Following December 31, 2009, Cascade will meet with Commission Staff, Public Counsel and .other interested parties in a collaborative process to recommend to the Commission whether Cascade should continue to report this information, whether Cascade should report other information, and whether any further action is required to ensure Cascade's customer service quality 23 Within twelve months of the closing of the Transaction and annually thereafter through December 31, 2012, Cascade will file a report with the Commission and Commission Staff regarding the implementation of the Conditions. The report will, at a minimum, provide a description of the performance of each of the Conditions that have quantifiable results If any Condition is not being met, relative to the specific terms of the Condition, the report shall provide proposed corrective measures and target dates for completion of such measures. From the report filed with the. Commission and Commission Staff, Cascade will make publicly available at the Commission, as well as provide to parties to this proceeding, non - confidential portions of the report. Upon request and subject to execution of a confidentiality agreement that incorporates the terms of the Commission's standard protective order, MDU and Cascade will provide confidential portions of the report to Public Counsel and other consumer parties • to this docket. 24 The premium paid by MDU Resources for Cascade (Goodwill or Acquisition Premium) will be excluded from the utility accounts of Cascade Further, MDU Resources and Cascade commit that they will not propose rate recovery of the Acquisition Premium in Washington rates or include the Acquisition Premium in Cascade's Washington results of operations unless this condition is modified by the Commission to allow for the recovery of the Acquisition Premium for reasons based on proposals by parties other than Cascade or MDU Resources 25 Cascade and /or the MDU Resources Foundation will maintain at least Cascade's current level of charitable contributions in Oregon and Washington Some of those contributions may be made directly by Cascade in support of local organizations In addition, qualified tax - exempt 501(c)(3) entities will be eligible to apply for grants from MDU Resources Foundation 26 MDU Resources and Cascade will provide the Commission and Commission Staff access to those portions of corporate minutes including Board of Directors' minutes, all committee and subcommittee minutes, along with any related reports and source documents that may lead to relevant information regarding Cascade's business and associated risk analysis. Upon request and subject to execution of a confidentiality agreement that incorporates the terms of the Commission's standard protective order, MDU and Cascade will provide copies • 9 62016- 0002/LEGAL13166275 7 of relevant documents subject to this commitment that pertain to Cascade to 410 subject p Public Counsel and other consumer parties to this docket. 27 Cascade will not declare or make any dividend to MDU Resources or any other entity that owns or holds an equity interest in Cascade, unless, on the date of such dividend, either a at the time and as a result of such dividend, Cascade's Interest Coverage Ratio is equal to or greater than 3 1, or b at such time, Cascade's unsecured debt rating is at least investment grade (BBB- or its then equivalent with Standard & Poor's Ratings Group and Baa3 or its then equivalent with Moody's Investors Service, Inc) "Interest Coverage Ratio" means, with respect to Cascade on any Measurement Date, the ratio of (i) the aggregate amount of EBITDA of Cascade for the four fiscal quarters for which financial information in respect thereof is available immediately prior to such Measurement Date to (ii) the aggregate Interest Expense during such four fiscal quarters. 28 a Cascade will not make any dividends that will. reduce Cascade's common equity capital below 38% of Cascade's Total Adjusted Capital without Commission approval, subject to the exception stated herein For the purposes of calculating a common equity capital for this commitment, Cascade's Total Adjusted Capital is defined as common equity, preferred equity, long -term debt, short-term debt and capitalized lease obligations If Cascade's common equity capital is below 38 %, but above 35% of Cascade's Total Adjusted Capital, Cascade may make a dividend upon notice to the Commission Cascade may use this exception only once each calendar year If Cascade uses this exception, it shall make a presentation to the Commission regarding the financial health of Cascade including Cascade's plans to increase the percentage of common equity capital Cascade shall also provide written reports to the Commission regarding the financial health of Cascade and progress on Cascade's plans to increase the percentage of common equity capital for four quarters following Cascade's use of this exception, unless this requirement is waived by the Commission b Cascade will not make any dividends that will reduce Cascade's common equity capital below.35% of Cascade's Total Adjusted Consolidated Capital (using a purchased accounting approach) without Commission approval Cascade's Total Adjusted Consolidated Capital is defined as the common equity, preferred equity, long -term debt, short-term debt and capitalized lease obligations of both Cascade and Cascade's intermediate holding companies viewed on a consolidated basis The use of a consolidated basis of both 10 62016- 0002 /LEGAL13166275 7 • Cascade and Cascade's intermediate holding companies for the determination of Cascade's Total Adjusted Consolidated Capital is for the purposes of this commitment only 29 Through December 31, 2016, Cascade will provide notice to the Commission, and to other parties to this Docket upon request, when the dividend payment increases by 10% or more than Cascade's paid dividends for the previous quarter 30 Within three months of closing of the transaction, Cascade commits to obtain a non - consolidation opinion, subject to customary limitations and qualifications, concluding that if the ring- fencing around Cascade is maintained, a bankruptcy court, on its own or upon proper request of a party in interest, in a case under the United States Bankruptcy Code commenced against MDU Resources, would not order the substantive consolidation of the assets and liabilities of Cascade with those of MDU Resources. Cascade commits to promptly file such opinion with the Commission If the ring- fencing provisions of this agreement are insufficient to obtain a non - consolidation opinion, MDU Resources and Cascade agree to promptly undertake the following actions a Notify the Commission of this inability to obtain a non - consolidation opinion. • b Propose and implement, upon consultation with Commission Staff and parties to this stipulation and Commission approval, such ring- fencing provisions that are sufficient to obtain such a non - consolidation opinion c. Obtain a non - consolidation opinion 31 The. Applicants agree that the Commission shall have an opportunity and the authority to consider and adopt in Washington any commitments or conditions to which the Applicants agree or with which the Applicants are required to comply in other jurisdictions, even if such commitments and conditions are agreed to after the Commission enters its order in this docket provided, however, that any financial commitments, or commitments having a financial impact, shall be proportionate to Cascade's corresponding business function in Washington in relation to its corresponding total company business function To facilitate the Commission's consideration and adoption of the commitments and conditions from other jurisdictions, the Parties urge the Commission to issue an order accepting this Stipulation as soon as practical, but to reserve in such order the explicit right to re -open to add commitments and conditions accepted or ordered in another state jurisdiction • 11 62016- 0002/LEGAL 1 3166275.7 32. Cascade commits that Cascade will continue its current gas procurement practices except to the extent Cascade notifies and justifies to the Commission in writing of any proposed change in gas procurement practices. 33 Cascade will continue to fund the Washington Energy Assistance Fund as per paragraph 14 of the Settlement Agreement approved by the Commission's Final Order 05 in Docket UG- 060256 and will explore with the implementing agencies methods to improve the program effectiveness and funding level as is shown to be justified 34 Cascade will pay the low income agencies for the installation of the approved energy efficiency measures in their low- income conservation program up to the full avoided cost provided that Cascade is authorized to defer the program costs associated with its low- income weatherization program to a sub - account of Account 186 and to amortize the costs through a temporary technical adjustment at the time of the Company's applicable Purchase Gas Adjustment filings Any such measures shall be consistent with any Conservation and Low - Income Weatherization Plan approved by the Commission 35 Cascade will meet annually with the community action agencies implementing the energy efficiency program to review program accomplishments, measure funding levels, and explore ways to improve program effectiveness The meeting(s) will be held so that program adjustments can be filed with the utility's conservation program filing 36 In the event that any regulatory body undertakes an audit or review of cost allocations and affiliated transactions involving Cascade and MDU Resources regulated operations, Cascade or MDU Resources will provide to the Commission and Commission Staff a copy of any report available to MDU Resources or Cascade resulting from such audit or review Upon request and subject to execution of a confidentiality agreement that incorporates the terms of the Commission's standard protective order, MDU and Cascade will provide copies of relevant documents subject to this commitment to Public Counsel and other consumer parties to this docket. 12 6201 6- 0002/LEGAL13166275 7 Attachment 1 • MDU Resources Group, Inc. Post - Acquisition Cascade Organizational Chart MDU Resources Group, Inc. Issue MDUR $2 M Equity \1 Transfer to Debtco Debtco 4 $85 M Third Party Lender Sub of MDUR Issue Debt to Debtco $305 M Transfer Transfer Equico Cash to Debt & Equity Proceeds Paying Agent to Equico Equico Paying Sub of Debtco _ $305 IN` Agent Paying Agent pays Cascade $305 M Shareholders • of record as of Cascade acquisition date Cascade. assets Cascade Natural Shareholders remain at Book Value Gas Corporation as of acquisition date Sub of Equico Note: Merger Sub is only a temporary subsidiary created solely to effect the reverse triangular merger and as such is not reflected on the organizational chart, • Attachment 2 CASCADE NATURAL GAS 900 ACCOUNTS STRETCH Washington - Allocated WASHINGTON A &G EXPENSE BENCHMARK 2006 CALENDAR YEAR Washington 1/ Customer Accounting $ 3,874,200 00 Remove Acct. 904 from Customer Accounting (775,414.00) Customer Service 1,189,336 00 Sales 441,711.00 A &G 17,713,012.00 Total Proforma Results $22,442,845 Less Low - Income Assistance (800,000.00) Baseline @ 12 -31 -06 $21,642,845 Limit Baseline CPI A &G 2007 CPI Est. = $21,642,845 3.50% $22,400,345 2008 CPI Est. = $22,400,345 3.50% $23,184,357 1/ From settlement in Docket No UG- 060256, general rate case, including proforma adjustments • CERTIFICATE OF SERVICE I. hereby certify that I have this day served this STIPULATION, in Docket UG- 061721, by causing a copy to be sent by electronic mail and U.S mail to John Cameron Melinda Davison Davis Wright Tremame LLP Davison Van Cleve, P C. Suite 2300 333 SW Taylor, Suite 400 1300 SW Fifth Avenue Portland, OR 97204 Portland, OR 97201 mid @dvclaw.com johncameron @dwt.com Edward A. Finklea Judy Krebs Chad M. Stokes Public Counsel Section Cable Huston Benedict Office of Attorney General Haagensen & Lloyd LLP Suite 2000 Suite 2000 800 Fifth Avenue 1001 SW Fifth Avenue Seattle, WA 98104 Portland, OR 97204 judyk @atg.wa.gov • efinklea @chbh.com cstokes @chbh.com Greg Trautman Ronald L. Roseman Assistant Attorney General 2011 14th Avenue East 1400 S Evergreen Park Dr SW Seattle, WA 98112 P 0 Box 40128 ronaldroseman@comcast.net Olympia, WA 98504 gtrautma@vvutc.wa.gov • CERTIFICATE OF SERVICE - 1 62016- 0002/LEGAL13110754.1 A Robert B Sheppard 30 Glacier Key Bellevue, WA 98006 Dated this 9th day of May, 2007 PERKINS COTE LLP By James M. Van Nostrand, WSBA #15897 Lawrence H. Reichman, OSB #86083 Attorneys for MDU Resources Group, Inc. and Cascade Natural Gas Corporation CERTIFICATE OF SERVICE - 2 62016 -0002 /LEGAL13110754.1 • BUSINESS OF THE CITY COUNCIL YAKIMA, WASHINGTON AGENDA STATEMENT Item No (1 For Meeting of July 3. 2007 ITEM TITLE Consideration of an Ordinance relating to the non - exclusive franchise granted to Cascade Natural Gas Corporation under City of Yakima Ordinance No 2005 -51 to construct, operate, and maintain a natural gas transmission /distribution system /facility(ies) in the City of Yakima and providing consent under section 2 13 of that Ordinance to a merger transaction whereby MDU Resources Group, Inc would acquire all of the outstanding stock of Cascade Natural Gas Corporation, and Cascade Natural Gas Corporation would become a wholly owned subsidiary of MDU Resources Group, Inc SUBMITTED BY Legal Department O CONTACT PERSON/TELEPHONE Helen A. Harvey, Senior Assistant City Attorney 575 -6030 SUMMARY EXPLANATION On September 20, 2005, the City Council adopted Ordinance No 2005 -51 granting a non - exclusive franchise to Cascade Natural Gas Corporation ( "Cascade ") to construct, operate, and maintain a natural gas transmission /distribution system /facility(ies) in the City of Yakima The voters approved the franchise Ordinance on the November 8, 2005 general ballot. Cascade recently entered into an Agreement and Plan of Merger (the merger transaction ") with MDU Resources Group, Inc ( "MDU Resources "), under which upon closing of the merger transaction, MDU Resources would acquire all of the outstanding common stock of Cascade and Cascade would thereafter become a wholly owned subsidiary of MDU Resources which will continue to operate as Cascade Natural Gas Corporation, with its operating headquarters in the State of Washington The closing of the merger transaction was subject to regulatory approval by the Washington Utilities and Transportation Commission ( "WUTC "), and the WUTC approved the merger transaction on June 27, 2007, iri WUTC Docket UG- 061721 in Order 06 As provided for in Section 2 13 of Ordinance No 2005 -51 Cascade has requested that the City give written consent to the merger transaction If the City provides consent to the merger transaction, then upon. closing of the merger transaction, there will be a continuation by Cascade of all obligations and liabilities under Ordinance No 2005 -51 The attached ordinance provides the City's consent to the merger transaction between Cascade and MDU Resources Resolution Ordinance X Other (specify) 1 Contract Mail to (name & address) Mail Ordinance to Daniel E. Meredith, Sr. Director, Safety & Engineering, Cascade Natural Gas Corporation, 222 Fairview Avenue North, Seattle, WA 98109 Phone (206) 381 -6720 Funding Source APPROVAL FOR SUBMITTAL �Q - City Manager STAFF RECOMMENDATION Pass ordinance BOARD /COMMISSION RECOMMENDATION N/A COUNCIL ACTION