TELEPHONE BILLING PRACTICES. Citing the filed-rate doctrine, which bars deviation from published tariffs, a federal appeals court affirmed the dismissal of two class action suits against AT&T Corp. that sought damages for alleged fraud. The suite arose from AT&T's failure to disclose to its residential long-distance telecommunications customers its practice of rounding charges up to the higher full minute. (The carrier had disclosed the practice in tariffs filed with the Federal Com-munications Commission, but did not include the information in any of its advertisements or marketing materials.)
While finding some merit in the argument, the court rejected a call to modify the filed-rate doctrine to allow nondisclosure claims in light of increasing competition among long-distance carriers. Strict adherence was required, it said, absent Congressional authorization or direction from the U.S. Supreme Court. Marcus v. AT&T Corp., 138 F.3d 46, Feb. 24, 1998 (2nd Cir.).
ELECTRIC RESTRUCTURING. The Arizona Supreme Court decided on April 23 not to hear an appeal filed by electric utilities that challenged the plan by the Arizona Corporation Commission to open retail electric markets to competition beginning in 1999. The supreme court's action left standing a prior ruling by Maricopa Superior Court Judge Michael Dann, upholding the commission decision. See, www.cc.state.az.us/news/pr04-23.htm.
MASTERCARD INTERNATIONAL introduced a merchant incentive program in the U.S. to get more customers to use its card for recurring payments. MasterCard's new Service Industries Incentive Program targets insurance, utility, telecommunications and cable television industries, which comprise more than 90 percent of the $500 billion recurring payment category, according to the company. MasterCard will offer incentive interchange rates for all merchants in those industries that begin a recurring payment program.
The Gas Research Institute released a study on U.S. oil and gas reserves and a report on the impact of air quality standards on natural gas demand. The study, Assessment and Characterization of Lower-48 Oil and Gas Reserve Growth, found that producers have replaced production with new reserve additions. It also found that most of the growth has come from existing fields rather than from new discoveries, a trend likely to continue. The report, Implications of the New Ozone and Particulate Matter Standards, summarizes new ozone and particulate matter standards, estimates compliance costs, and discusses the potential affect of National Ambient Air Quality Standards on natural gas demand. The report also evaluates the impact of these new standards on other emission sources such as motor vehicles, off-road vehicles and non-utility sources. Copies of the report are available by calling 703-526-7832.
Houston Industries Inc. and Enova Corp. broke ground on El Dorado Energy, a $280 million, 480-megawatt power plant designed to provide energy to customers throughout the western United States. The El Dorado energy project should be finished by the end of 1999, about the same time the electricity market in Nevada is expected to open to competition. The two companies claim the El Dorado Energy plant is the first large-scale merchant power facility to be financed and built in the U.S. The project has no contracts or guaranteed revenue stream; it has been financed strictly on market economics.
PEPCO Services Inc. signed a contract with Ryder Transportation Services for the installation of energy-efficient technologies at locations nationwide. PEPCO Services will conduct a comprehensive, site-specific assessment of all energy systems at each location, including an energy audit and a cost/benefit analysis. PEPCO Services guarantee savings at each site, with the cost for each installation to be paid from a percentage of the savings.
Griffith Energy, a heating oil and propane provider, announced it's becoming part of Energetix Inc., a full-
service energy company. The acquisition, a cash transaction financed as an installment sale, is expected to be completed later this year.
NATURAL GAS CAPACITY RELEASE. The FERC ruled that Texas Eastern Transmission Corp. could refuse to relieve Public Service Electric and Gas Co. of liability for reservation charges under transportation and storage contracts, on the theory that PSE&G had sought to release capacity to an affiliate, Public Service Energy Trading Co., which allegedly was acting as a shell company created solely to absorb and default on the underlying obligations.
Dissenting Commissioner Curt Hebert Jr. faulted the FERC for looking beyond the four corners of the capacity release contract, instead of simply reviewing the language of the agreement. In his initial dissent filed in February, Hebert had described the ruling as "the first step down the road of requiring investigation into [the] parties' goal and motives behind the business decisions they make."
At rehearing, Hebert advised the FERC and Commission staff to "let go." That earned a retort from Commissioner William Massey that current law (Federal Power Act and Natural Gas Act) "make it a little difficult." Chairman James Hoecker asked, "Are we looking behind the contracts or are we ensuring that they will be honored?" Answering his own question, Hoecker concluded, "Here, we are doing the latter." Docket No. RP98-83-001, April 29, 1998.
POWER MARKETING AFFILIATES. The FERC a show cause order after finding Washington Water Power Co. violated comparability rules under Order 888 by agreeing to provide "interruptible firm" transmission service to its affiliated power marketer, Avista Energy, including services beyond those authorized in the pro forma transmission tariff. The FERC was considering having WWP return any profits from the transactions at issue and forfeit market-based rate authority for up to six months.
"This is an important and serious order," said James Hoecker, FERC chairman.
Although violations were rare, the case showed the FERC was willing to test utilities and affiliates. Commissioner Hebert said he supported the order, but said the proposed penalties were "extreme." Docket No. ER09-852, April 29, 1993.
NETWORK TRANSMISSION CREDITS. After approving the utility's open access transmission rates, the FERC set for hearing a new method proposed by Northern States Power to compute a credit for any of its customers owning transmission facilities integrated with the regional power grid.
The FERC will consider separately NSP's contention that the crediting for facilities owned by the network customers is not working as envisioned under section 30.9 of the pro forma open access tariff. NSP does not believe that the crediting provisions should apply in some of the circumstances presented by historical transmission agreements, some dating as far back as the 1960s. NSP asserted that in some instances customer credits could equal or exceed the network rates that otherwise would be billed.
The FERC agreed that section 30.9 was not intended to be the foundation for joint transmission arrangements. But it also noted that NSP "created this untenable situation by negotiating settlements promising something that was not required under the pro forma tariff." Docket Nos. OA97-25-000 et al., April 29, 1998.
GAS PIPELINE NOMINATIONS. The FERC adopted rules to improve the efficiency of the interstate natural pipeline grid. The final rule establishes uniform policies to make it easier for shippers to move gas across multiple pipelines. The rules require uniformity by June 1, 1999.
Pipelines must adopt Version 1.2 of the Gas Industry Standards Board standards and post information on pipeline Web sites. Docket No. RM96-1-007, Order No. 587-G, April 25, 1998.
ELECTRIC RESTRUCTURING. Connecticut Gov. John Rowland (R) signed electric restructuring legislation that guarantees a 10-percent rate cut on Jan. 1, 2000, while allowing for securitization and recoveyr of stranded costs. Choice of electric supplier will being for 35 percent of customers in "distressed cities" as chosen by the Connecticut Department of Public Utility Control. All other customers of both major electric utilities in the state--Northeast Utlities and United Illuminating Co.--will have choice July 1 that year. Municipal utilities aren't affected by the law unless they choose to compete. The law, signed April 29, requires divestiture of electric generation. The utilities, however, will be allowed to bid on their own plants.
PECO ELECTRIC RESTRUCTURING. The Pennsylvania PUC issued a final order approving a settlement of PECO Energy Co.'s restructuring plan. The order also allows the utility to recover $5.26 billion in stranded costs. Lastly, it resolves 15 pending appeals before the Commonwealth Court and one appeal before the U.S. District Court.
The final order guarantees all customers an 8-percent rate cut in electric bills in 1999, and a 6-percent cut in 2000. In addition, PECO customers will receive a "shopping credit" for two years with which to seek out competitive power supplies - 5.09 cents per kilowatt-hour for residential customers, or 4.46 cents per kWh on a system average basis, varying by rate class.
A third of PECO's customers can switch suppliers on Jan. 1, 1999, another third on the same day in 2000, and the rest on Jan. 2, 2000. But on Jan. 1, 2001, 20 percent of all PECO Energy customers will be assigned to a competitive provider of last resort/default. The default supplier will be selected through competitive bidding, and will have to provide 2 percent of its energy from renewable sources. Pennsylvania is the first state to provide for a competitive default supplier, although customers are free to return to PECO.
PECO may collect the $5.26 billion in stranded costs from Jan. 1, 1999 through 2010, but may only securitize $4 billion of that amount. r-00973953, p-00971265, May 14, 1998 (Pa.P.U.C.).
HOURLY ENERGY PRICING. Commonwealth Edison on May 1 asked the Illinois Commerce Commission to approve hourly energy pricing (HEP) for its nonresidential customers. Rate HEP was mandated by the Illinois electric restructuring law to give customers experience with competitive energy.
"Choice for nonresidential customers is just 17 months away," said Arlene Juracek, ComEd vice president. " By participating in rate HEP, they will be able to view the next day's hourly energy rates on a special ComEd Internet site, and adjust their energy consumption accordingly."
Every afternoon ComEd will calculate hourly energy prices for the next day. Those prices will be posted on the dedicated Internet site by 4 p.m.
REGIONAL REGULATION. The Utah Public Service Commis- sion approved a new cost allocation method that will require PacifiCorp to allocate costs evenly across its seven-state service territory, revising a prior method set in 1989 by a task force of state and federal regulators in the wake of the merger between Pacific Power & Light Co. and Utah Power & Light, which had allocated pre-merger costs by company of origin and post-merger costs system wide.
As the PSC explains, the new method will be phased in over five years and will allocate costs evenly over the companies' jurisdictions without regard to whether costs were incurred before or after the merger. The PSC predicts that Utah ratepayers could save about $50 million to $60 million a year once the phase-in is complete, but savings still depend on a rate proceeding expected to end later this year. Docket No. 97-035-04, April 14, 1998 (Utah P.S.C.).
INCENTIVE REGULATION. Describing the idea as tilted against ratepayers, the Missouri Public Service Commission has rejected a move by Missouri Public Service, an operating subsidiary of UtiliCorp United Inc., to replace an experimental performance-based rate plan with a permanent program to share excess earnings with stockholders. It forced the company to cut rates by about $16.89 million (return on equity at 10.75 percent, using the parent company's capital structure) and said that Missouri Public Service should credit ratepayers with 100 percent of off-system sales revenue, instead of 50 percent as proposed. It also rejected real-time and flexible pricing tariffs proposed by the utility to "better conform" to competition. Case Nos. er-97-394 et al., March 18, 1998 (Mo.P.S.C.).
MILLENNIUM BUG. The Nevada PSC has launched an investigation into whether the state's energy and telecommunications companies are prepared for potential computer glitches due to the year 2000 problem.
The PSC unanimously voted to require the electric, gas, water and telephone companies to report on the status of preparedness for changes to computer dates beginning with 2000. Commissioner Timothy Hay requested the investigation to ensure that Nevada utilities and customers are protected from disturbances that might occur due to computer difficulties.
TELEPHONE WHITE PAGES. Finding that a single directory will best promote local telephone competition, the Tennessee Regulatory Authority has ruled that a BellSouth affiliate that publishes telephone "white pages" directories must allow a new local carrier, AT&T Communications of the South Central States Inc., to contract to insert the numbers of its local customers in the directory and add its name and corporate logo on the front cover. Docket No. 96-01692, March 19, 1998 (Tenn.R.A.).
TELEPHONE YELLOW PAGES. Bell Atlantic-New Jersey Inc. (a local telephone carrier) won permission from the New Jersey Board of Public Utilities to spin off its "yellow pages" publishing to an affiliate, but must keep $116 million in directory revenues embedded in its local exchange rates because, according to the board, the spin-off plan included no rate change. The board said it would fix the final amount of compensation to ratepayers in a future proceeding. Docket No. to97100766, March 3, 1998 (N.J.B.P.U.).
STORM DAMAGE RESERVES. The Hawaii Public Utilities
Commission has rejected a proposal by utilities in the state to establish ratepayer-funded, self-insured property damage reserves (through a 1-percent rate surcharge over a 10- to 15-year term) to cover damages from natural disasters. The PUC cited several problems with the plan: (1) the unknown probability and magnitude of disasters and damages; (2) intergenerational inequity among ratepayers; and (3) unclear tax effects. Decision No. 16228, Docket No. 95-0051, March 4, 1998 (Haw.P.U.C.).
NEW RETAIL GAS SERVICE. In two cases that turned on expe- rience and financial capability, the Maine Public Utilities Commission has approved one proposal but denied another that would have electric utilities offering natural gas distribution service to areas not previously served.
First, it authorized Central Maine Power Co., in a joint venture with New York State Electric and Gas Co., to serve some 60 cities and towns that will have access to gas supplies from two new pipelines, the Portland Natural Gas Transmission System and Maritimes and Northeast. To back its decision, the PUC cited Central Maine's electric experience and NYSEG's gas expertise. Docket No. 96-786, March 11, 1998 (Me.P.U.C.).
Second, it rejected a proposal by Bangor Hydro Electric Co. to participate with Maritimes & NE in forming a gas distribution company to serve the Bangor area, describing the company's financial condition as "relatively precarious," marked by a bond rating of below investment grade, and finding no identified source of funds for the proposed $2.5-million investment. It also rejected a settlement by which Bangor would trim its investment to $1 million as well, and discounted claims that a recent rate increase of $13.2 million awarded in February would improve matters
sufficiently to justify the investment. Docket No. 97-796, March 26, 1998 (Me.P.U.C.).
TELCO DIVERSIFICATION. The Michigan Public Service Commission ruled that Ameritech Michigan violated state law when, without prior notice, it transferred $1.7 million in assets to Ameritech New Media Inc., an unregulated cable television affiliate, to help the company launch a video dialtone service. The PSC said notice was required because the assets were capable of use in providing regulated local exchange telephone service. It awarded attorney's fees to the Michigan Cable Telecommunications Association, which had filed the complaint. Case No. u-11507, March 24, 1998 (Mich.P.S.C.).
RETAIL GAS CHOICE. The Pennsylvania Public Utility
Commission has approved tariffs allowing Equitable Gas Co. to launch a program for customers to buy gas supplies from competitors, with marketers allowed to aggregate customer loads. The PUC will phase out rules that require customers to buy from marketers to use pipeline capacity assigned to the distribution utility. r-00963858, March 19, 1998 (Pa.P.U.C.).
TORT LIABILITY. Vacating a prior ruling, the Pennsylvania Public Utility Commission has opened a new rulemaking case to consider policy on guidelines in tariffs that purport to limit utility liability for negligence or intentional torts. In a separate statement, Commissioner John Hanger endorsed the idea of protecting ratepayers from unlimited utility liability, but questioned whether such protection should extend to competitive services. He also questioned PUC authority, pointing out that the commission lacked underlying jurisdiction to set legal liability or to award damages in tort cases. m-00960882, March 11, 1998 (Pa.P.U.C.).
TELCO MERGERS. The Virginia State Corporation Commission approved the acquisition of Teleport Communications Group Inc., by AT&T Corp. The new affiliate will offer local exchange and interexchange services principally under the AT&T brand. Case No. 980004, March 30, 1998 (Va.S.C.C.).
Mergers & Acquisitions
TEXAS UTILITIES/ENERGY GROUP. Texas Utilities has emerged as the apparent victor in a tense bidding war for The Energy Group Plc, in the United Kingdom.
PacifiCorp's last bid was $9.7 billion, with Texas Utilities agreeing to pay $10.4 billion. PacifiCorp decided the purchase price was climbing too high after British regulators announced they would require both utilities to make sealed bid offers. But it cost PacifiCorp almost $200 million to attempt the purchase, a cost which will be picked up by stockholders. However, PacifiCorp has accumulated a large amount of cash that would have been used to make the purchase, which now makes PacifiCorp a prime takeover target.
In order for Texas Utilities to complete the deal, it will have to divest The Energy Group's subsidiary, Peabody Coal, the world's largest private coal company. Texas Utilities plans to sell Peabody to Lehman Merchant for $2.3 billion.
NEVADA POWER/SIERRA PACIFIC. Nevada Power Co. and Sierra Pacific Resources on April 30 announced their "merger of equals" to create a company with a total market capitalization of $4 billion.
The companies claim that combining Nevada Power (claimed to be the fastest-growing utility in the nation) with Sierra Pacific will create a company with annual customer and kilowatt-hour sales growth of 5 percent and 7 percent, respectively.
Sierra Pacific Resources would become the holding company for both utilities. Investors owning stock in Nevada Power or Sierra Pacific could trade their shares for cash or stock in the new combined company in ratios reflecting five-percent premiums on 10-day average stock trading prices through April 28.
Michael R. Niggle, Nevada Power's president and CEO, was slated to become chairman and CEO of the new holding company and chairman of its subsidiaries. Malyn K. Malquist, SPR chairman, president and CEO, would become president and COO of the holding company and president and CEO of both companies. The present chairman and CEO of Nevada Power, Charles A. Lenzie, would retire when the merger was complete.
A FIRST CO-OP DEAL. Licking Rural Electrification Inc., an electric cooperative based in Utica, Ohio, has announced it will acquire National Gas & Oil Co. for $93 million in cash by folding a subsidiary into NGO. After the merger, NGO will become a cooperative, and its 27,000 customers will be owners and members of the integrated utility. Total customers post-merger will top 46,000.
By late May, the agreement had been OK'd by the board of each partner, but still required the blessing of the Public Utilities Commission of Ohio, among others. A shareholder vote on the merger was set for August. The expanded company, selling electricity, propane and natural gas, would serve 17 counties in east-central Ohio. LRE believes it will be the first co-op in Ohio to merge with an investor-owned natural gas utility.
RETAIL FRANCHISING. UtiliCorp United and PECO Energy
Co. have ended their marketing alliance, EnergyOne LLC, citing absence of a nationwide regulatory framework for retail choice.
Established a year ago, EnergyOne was formed as a 50-50 partnership. It was envisioned to link branded non-energy products and services (such as long-distance telephone and home security) with traditional energy services from gas and electric utilities.
According to PECO Chairman Corbin A. McNeill Jr., the slow and inconsistent development of a truly national market was forcing the entire industry to rethink competitive strategies. "Frankly, we know of no one in this business who can predict just when our nation might open up to the kind of competition we envisioned, but we feel it makes greater sense for us to attack this market differently now, rather than wait for it to wake up," McNeill said.
INTERNATIONAL POWER SALES. Virginia Electric and Power Co. has asked the U.S. Department of Energy to allow it to sell electricity to Canada, either its own surplus generation or power purchased at wholesale. It would export electricity over international transmission facilities owned by 14 utilities and power cooperatives, including Bonneville Power Administration, Niagara Mohawk Power Corp., Northern States Power, Minnesota Power & Light Co., and Detroit Edison.
POWER PLANT AUCTIONS. The California Public Utilities Commission has OK'd the sale by Southern California Edison Co. of its Long Beach power plant to NRG Energy Inc. and Destec Energy Inc., even though the $28.8 million sales price equaled only about 30 percent of book value (roughly $98 million in September 1997). Edison said it had received no satisfactory bids for its Long Beach or Ormond plants during the first round of bidding, but the PUC approved the Long Beach sale, finding no danger of market power concentration and that Edison had accepted the highest bid. Decision 93-03-077, Application 96-11-046, March 26, 1998 (Cal.P.U.C.).
SUMMER RELIABILITY. Officials from ISO New England and various New England electric utilities have held six news conferences at various locations to explain preparations being made to ensure adequate electric supplies in the region this summer. Officials warned that power shortages are possible if the region experiences an extended heat wave, high demand for electricity or an extraordinarily high amount of unplanned outages. It said parts of the Midwest, Ontario and Alberta also could experience
problems this summer. Transmission constraints will limit how much relief other regions could offer.
ISO New England forecasts peak demand of 22,100 megawatts for electric this summer. That represents a 700-megawatt increase over the projected peak last summer. To ensure maximum resources are available, plant maintenance was rescheduled so that it will not occur in summer, transmission line inspection has been beefed up, and there will be more coordination with neighboring power pools for importing electricity into the region.
MERCHANT PLANTS. The difference between an investment- grade and noninvestment-grade rating for a merchant power plant ultimately derives from the project's ability to hedge its exposure to volatile commodity pricing, not from a particular set of financial indicators. That's the finding of a report from Moody's Investors Service, entitled Power Costs, Market Risk Hedging, Diversifications Key to Investment-Grade Ratings in Merchant Power.
The report explains an investment-grade rating from Moody's hasn't yet gone to "pure" merchant plants, which sell their output on the open market, but only to "hybrids," selling close to 100 percent of their output largely during the plant's financing period, under contracts with creditworthy parties.
Even for what appears to be the most competitive projects, the absence of some form of market price hedge - whether power sales contracts, tolling agreements, linkage of fuel costs to pool prices, or subordination of operating expenses to debt service - is likely to preclude the attainment of an investment-grade rating, said Moody's, or at least at any capital structure that would make economic sense for its owners.
Moody's has assigned ratings to over $1 billion of debt associated with four single-asset merchant generating facilities in the U.S., U.K. and Chile. Rated Ba2 is Calpine Pasadena, Texas. Rated Baa3 is Sutton Bridge, U.K.; Guacolda, Chile, and Kincaid, Ill. The lowest rated, Calpine Pasadena, has the most conservative leverage, and debt service coverage similar to Sutton Bridge, rated two notches higher. Sutton Bridge and Kincaid enjoy very different debt service coverage of 2.5 and 6.0 times, respectively, during their merchant period.
LIPA/LILCO TAKEOVER. The New York Public Authority Control
Board on April 22 authorized the Long Island Power Authority to issue $7 billion in tax exempt bonds to finance the takeover of Long Island Lighting Co., including the utility's electric distribution system and transportation system and its ill-fated Shoreham nuclear plant. The first issue was set for May 13, for $3.05 billion.
It's believed that the overall $7-billion issuance is the largest ever offered. Included in the acquisition price is $4.2 billion in debt related to the Shoreham plant. LIPA will serve LILCO's former electric customers and will purchase power from the company created after Brooklyn Union Gas Co. takes over LILCO's non-nuclear generating assets.
Meanwhile, Standard & Poor's has issued a report on the sale, rating the $3.05 billion bonds "A-." According to S&P, the "A-" senior lien rating reflects limited competitive risk, stability associated with a transmission and distribution system that serves a mostly residential and affluent customer base and sound projected debt service coverage. F
News Digest is compiled by Lori A. Burkhart and Phillip S. Cross, contributing legal editors, and by Beth Lewis, editorial assistant.
Restructuring: Out of Control?
Commission Abandons Case, but Says It Was Only "Clearing Dockets."
FINDING THE PACE of change "faster and broader" than it could have imagined, with events driven by "legislative and economic forces beyond [our] control," the Washington Utilities and Transportation Commission decided on April 22 to terminate its generic investigation of electric industry restructuring in Docket No. UE-940932, leaving only a statement of policy it had issued late in 1995.
Does that mean the UTC will just stand back, make way for competition and let 'er rip?
Well, not exactly, explained UTC chair Anne Levinson. When asked whether the UTC would abandon electric regulation entirely, Levinson answered, "I'm afraid you may have less of a story here than you might think.
"It was more of a process improvement than a substantive shift," she explained. "We launched that investigation about four years ago, but the shelf life for this docket turned out to be very short, as the nature of the questions changed.
"The questions that you raise - codes of conduct, reliability, consumer safeguards - virtually none of those items were in the debate when we launched our inquiry. Also, at the end of the last session, our legislature ordered us to examine several components and trends in the electricity system, including aggregation of customer loads, service quality, reliability and investments in public purpose programs. Those studies are due by Dec. 31.
"When I came in six months ago and saw the number of cases going on, I wanted to simplify. Our staff was running in all different directions. Now, however, we felt the need to reprioritize, to address the critical areas of the debate. The forum has changed, in a way."
In fact, a study group convened in 1996 by governors of northwest states had recommended the area move toward electric service competition at the retail level. Recently state lawmakers enacted three electric restructuring bills, requiring utilities to: (1) submit unbundled cost studies and reports on service quality and reliability to the UTC and the state auditor and directing both to report to the legislature; (2) adopt specific basic consumer information and protection policies; and (3) make available "bi-directional" metering equipment for customers who install site-specific renewable generation equipment. Also, the UTC had issued rulings in utility-specific cases involving special rate contracts, market-based pricing tariffs, retail open access pilots, and a merger.
By abandoning its restructuring docket, how would the UTC deal with subjects such as hydroelectric policy, salmon conservation and market power at Bonneville Power Administration?
"BPA, hydro and salmon - these issues are enormously important for the region," Levinson admitted. "BPA controls 80 percent of the transmission and produces more than half the power. We have more public power than any state except for Nebraska, but our commission cannot regulate it. This combination of actors make the debate different for us than other states.
"We have the second-lowest cost of power in the country," she added. "So a significant issue in our debate is whether in fact retail competition will bring any savings for residential customers.
"Cost shifting is a significant issue for us, but so is the loss of decades-old benefits.
"Some in Congress might argue that we are simply beneficiaries of federal largesse. But what many people don't understand is that our region's ratepayers have paid significantly - to the tune of $400 million a year. The impact for our state for losses in the salmon fishing industry is often forgotten as a factor in the debate.
"Rates would have been even lower all these years had we not been mitigating the salmon loss. Everyone agrees that we have obligations to go with our benefits."
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