The following are general comments we have about the preliminary justification form/instructions and the consumer disclosure form: To Whom It May Concern: May 2, 2011 Calculation of rate increases: In response to the proposed rule for rate increase disclosure and review, our work group proposed a revision to the way in which rate increases are determined for Section 154.200. 3 The following is an excerpt from the letter: 4 Page 2 of 11