Subject: File No. S7-45-10
From: Deborah H White, CPA
Affiliation: Director of Finance, Augusta County Service Authority

February 15, 2011

Please exempt all members serving on a governing body-- whether appointed, elected, or an employee--from the municipal financial advisor definition.

Our rural public service authority that provides water and sewer service to up to 15,000 customers in a 970 square mile area county has a very dedicated and involved Board of Directors appointed by the County Board of Supervisors. This Board is composed of citizen volunteers and politicians whose expertise lies in the operating side of the authority and not the financial. We have a heavy debt load because of a large number of independent systems that must keep in compliance with regulations. Therefore, we employ an independent financial advisor, who has registered with the SEC, when we must make difficult funding decisions or decide to issue municipal bonds. The County might find it very difficult to find citizens willing to participate on our Board should they have to register as "financial advisors" with the SEC.