RTO Insider reports that FERC has issued a proposed policy statement regarding "hold harmless" commitments made during utility mergers.
The policy is intended to further define merger costs and how they are accounted for, as well as proposed accounting mechanisms to track them.
As if it's about some accounting "confusion," and not about utilities willfully violating the commitments they make as a condition of approval for their merger. But, hey, FERC has to start somewhere, I suppose. Maybe some proactive monitoring of utility financial filings could begin to put a damper on the merger cost recovery free-for-all. But then will the utilities just find more creative ways to improperly recover their merger costs? How about some penalties for utilities found to have improperly recovered merger costs? I think maybe a $30M fine for each occurrence would be appropriate.
On that tape, Dr. Bowring says that the trades did not violate the rules, that he understands why the traders engaged in them, and that the rules need to be changed to remove the incentives that drove the trading. He also says that he would not refer the trading conduct to Enforcement if the traders stopped the trading in question. Powhatan says that accused trader Alan Chen had a similar conversation with Bowring, but did not record it.
The problem here stems from OE's failure to turn over the recording when it was asked to produce exculpatory evidence, i.e. to disclose all evidence that is "favorable to an accused" or "would tend to exculpate him or reduce the penalty."
This seems to be a bit of a double standard, since FERC is relying on the statements of a different trader to make its case to the Commission.
Powhatan also points out that Bowring is obligated to refer trading that he thinks might be market manipulation to FERC's Office of Enforcement. I wonder how many little phone calls he's made to traders over the years, instead of fixing all the flaws in his "markets?"
How is anyone supposed to know what's allowed and what's prohibited? Or do those rules reside only in Bowring's head? So, keep that recorder handy, just in case... unless you've got $30M or so laying around and don't mind parting with it.
Clean Line President Michael Skelly recently told a Tulsa World reporter that his company is going through a federal permitting process for its Plains & Eastern Clean Line because the project wants to cross three states. ( watch the video)
There's no such thing as a "federal permitting process" for high-voltage electric transmission lines!
Skelly calls the U.S. Department of Energy the "permitting agency." However, what he's referring to is Clean Line's application to have the U.S. DOE "participate" in its for-profit transmission venture undertaken outside the normal regional transmission planning process.
Section 1222 of the Energy Policy Act of 2005, Third Party Finance, allows federal power marketing agencies to "participate" in transmission projects that are built within their territories. As noted in the title of the statute, Sec. 1222 projects must be financed by third parties (in this case, Clean Line's private venture capitalists). Section 1222 does not give U.S. DOE authority to PERMIT or site transmission projects. It simply allows "participation." In Clean Line's case, the company is only interested in DOE's "participation" in order to anoint itself with the power marketing agency's federal eminent domain authority to condemn and take right of way from private landowners.
DOE and Southwestern understand and agree that their ability to acquire through condemnation proceedings property necessary for the development, construction and operation of the Project is one of the primary reasons for Clean Line’s interest in developing the Project with DOE and Southwestern and through the use of EPAct 2005 section 1222.
DOE and Southwestern agree that, if the Secretary of Energy ultimately decides upon the conclusion of such evaluation as DOE and Southwestern deem appropriate that (i) the Project complies with section 1222, and (ii) to participate in the Project’s development pursuant to section 1222, then, DOE and Southwestern will use their condemnation authority as may be necessary and appropriate for the timely, cost-effective and commercially reasonable development, construction and operation of the Project. Section 1222 is not purposed to "permit" transmission lines when a state has denied a permit.
d) Relationship to other laws
Nothing in this section affects any requirement of--
(1) any Federal environmental law, including the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.);
(2) any Federal or State law relating to the siting of energy facilities; or
(3) any existing authorizing statutes. It simply allows DOE to "participate" in designing, developing, constructing, operating, maintaining or owning transmission. It permits DOE to assume liability for the actions of a third party in order to utilize federal power marketing authority for benefit of transmission that is not part of or necessary to their systems.
The Secretary, acting through WAPA or SWPA, or both, may design, develop, construct, operate, maintain, or own, or participate with other entities in designing, developing, constructing, operating, maintaining, or owning, a new electric power transmission facility and related facilities (“Project”) located within any State in which WAPA or SWPA operates if the Secretary, in consultation with the applicable Administrator, determines that the proposed Project--
(1)(A) is located in an area designated under section 216(a) of the Federal Power Act [16 U.S.C. 824p(a)] and will reduce congestion of electric transmission in interstate commerce; or
(B) is necessary to accommodate an actual or projected increase in demand for electric transmission capacity;
(2) is consistent with--
(A) transmission needs identified, in a transmission expansion plan or otherwise, by the appropriate Transmission Organization (as defined in the Federal Power Act [16 U.S.C. 791a et seq.]) if any, or approved regional reliability organization; and
(B) efficient and reliable operation of the transmission grid;
(3) will be operated in conformance with prudent utility practice;
(4) will be operated by, or in conformance with the rules of, the appropriate (A) Transmission Organization, if any, or (B) if such an organization does not exist, regional reliability organization; and
(5) will not duplicate the functions of existing transmission facilities or proposed facilities which are the subject of ongoing or approved siting and related permitting proceedings. There's simply nothing in Section 1222 that authorizes DOE to issue a "permit" for new transmission lines that have been denied by a state. If a state created laws requiring merchant transmission projects to receive a permit from the state before beginning construction, Section 1222 is a worthless exercise in federal usurpation of state authority. Transmission siting and permitting is state-jurisdictional. The federal government has no authority to override state laws.
Clean Line is currently trying to get the DOE to agree to accept liability for its actions and "participate" in its project. Before making a decision whether or not to "participate," DOE is undertaking an Environmental Impact Statement, which is required for any federal actions that affect the environment. In the video, Skelly encourages people to "weigh in" during the Draft EIS comment window (ends March 19). Skelly tells people to comment whether or not they like the project and where it should be routed. This is wrong. Comments should be directed around aspects of the draft EIS, which examines the environmental and social factors of the project. There will be a separate 45-day comment period for the public to "weigh in" on the DOE's decision whether or not to "participate" in the project, which will begin AFTER the EIS is completed. Skelly wants you to think that the EIS is your only avenue to comment on Section 1222. It's not, but you should comment on it nonetheless by going to this link.
Skelly also goes on about state and local property taxes, claiming that localities will benefit to the tune of $20K per mile, or half a million bucks a year. How did he do that math, considering each county has a different amount of proposed line mileage? He also forgets to mention that Clean Line has pursued and received tax abatement in a number of states and localities for periods of up to ten years. That will be 10 years of Clean Line using your local roads, infrastructure and services to construct and operate its project before you receive a dime of reimbursement for what it costs you to support it.
Skelly also tells the reporter that "the grid is maxed out" and Clean Line is "a vital piece of the puzzle to get wind online." Not so. The grid is not "maxed out." It is a carefully planned machine that is operated by regional transmission organizations and balancing authorities. These authorities undertake long-term planning that allows for needed expansion of our grid. If wind farms, or other generators, submit requests to interconnect to the grid, they get placed in a queue that allows the authority to consider new generation and how transmission may be needed and planned to move the generation to where it is needed in within the region.
Clean Line has bypassed this process and is proposing its project without any recognized need for the transmission or generation it proposes to bring online. Section 1222 requires that any project in which the DOE "participates" be consistent with, and not duplicative of, any regional plan.
IS CONSISTENT WITH: transmission needs identified, in a transmission expansion plan or otherwise, by the appropriate Transmission Organization (as defined in the Federal Power Act [16 U.S.C. 791a et seq.]) if any, or approved regional reliability organization; and (5) will not duplicate the functions of existing transmission facilities or proposed facilities which are the subject of ongoing or approved siting and related permitting proceedings. Clean Line fails this very important stipulation in Sec. 1222. Needed transmission is already being undertaken by our regional authorities. Clean Line is unnecessary duplication intended to stimulate construction of generation purposed only to export power between regions. It also fails to present any evidence that there are buyers for this power in other regions. It's just not true that new generation cannot be built without Clean Line providing a way to get it to "market," considering there is no identified market. Clean Line is in a chicken/egg scenario, supposing if it builds its project that generation and customers will develop, however, Clean Line cannot build without generators and customers developing FIRST. So, which came first? Clean Line, or generators and customers? We'll probably never find out because I don't think Clean Line is ever going to happen.
Skelly says that in order to utilize Clean Line's maximum capacity of 4,000 MW, 3,000 new wind turbines will have to be constructed near the project's Oklahoma converter station. Each turbine requires 1/2 a square mile of land, so we're talking about covering 1,500 square miles of land with wind turbines. That's roughly an area comparable to the entire State of Rhode Island. Skelly also points out that his project will simply waste 5% of the energy it carries through line loss. By comparison, a renewable generator sited near or at the electric load wastes little to none of the energy generated. Taking huge tracts of land out of production to generate energy that is transported long distance to load is simply wasteful.
Skelly shares that he believes "energy is a big deal" and his long journey from idea to reality will be "worth it." Classic words from a guy using someone else's money to dream the impossible dream.
At some point in the near future, Secretary of Energy Ernest Moniz will have to read and make a decision on Clean Line's "updated" application to utilize Sec. 1222 of the Energy Policy Act to forcibly take land from people in Oklahoma and Arkansas to build an unnecessary transmission line.
Last night he practiced his face for that moment.
The solicitation for commitments, expected to last about seven weeks, will be a gauge in determining the interest in using the line. GBE is soliciting customers in accordance with the plan it filed with FERC last year to negotiate rates in a fair and non-discriminatory manner that results in just and reasonable rates.
Despite GBE's media push that FERC has "approved" its project, FERC has no jurisdiction to approve the siting and permitting of the project. What FERC does have an interest in is ensuring that the rates GBE charges to its customers are just and reasonable. FERC simply approved GBE's plan to undertake this process fairly. Once GBE completes the negotiation process and assigns capacity, it must make a compliance filing with FERC demonstrating that it complied with the plan as approved. That may be be the tricky part!
Who wants to make a contractual commitment to purchase capacity on a transmission line that may or may not be permitted, and may or may not be built? It could be generators, that Clean Line admits have not yet been built. It could also be utilities, who commit to purchase the capacity. Or it could be no one at all.
In the case of generators, the generators would need to have customers (utilities) that want to purchase their generation delivered to Indiana (and incur additional transmission costs on other systems to get the power to load). Since these generators have yet to be built, and the transmission to Indiana has yet to be built, committing to a purchase price for delivered power could be risky. Utilities hate risk. A utility seeking to add renewable generation to its portfolio has many options, including existing generators and transmission. Utilities plan their resources many years in advance as part of their obligation to provide a public service. They are obligated to seek the cheapest price. They want to know the resources they commit to purchase will actually be there when needed, not possibly unavailable at some later date, which would leave the utility scrambling to fill some hole in its plan at whatever price they can find. Utilities hate risk. Risk is costly.
In the case of utilities purchasing capacity directly... more risk! Purchase of capacity on a transmission line that may or may not be there when needed, connected to unnamed generators that may or may not be there when needed, is risky. Utilities hate risk.
I read an article long ago regarding Clean Line's business plan. Some panned the plan, saying there is no market for this kind of risk. So, I thought about it. If Clean Line's plan is such a sure thing, why aren't there hundreds of transmission companies building merchant lines outside the regional planning process? Utilities have transmission affiliates, and they like to make money, too. Maybe it's because experienced transmission developers know that there truly is no market for Clean Line's business plan?
Last year, Clean Line opened a different FERC-jurisdictional solicitation process for another of its projects, the Plains and Eastern Clean Line. Regarding that process, Clean Line recently claimed:
It was encouraged by the strong response to a solicitation of customers for another power line it plans to build to deliver wind energy from Oklahoma to Southern states. Encouraged? Strong response? If the response was strong and encouraging, Clean Line should have negotiated contracts with the respondents and made its compliance filing at FERC and announced to the world that it had committed customers for that project, right? What happened?
From May through July of 2014, Clean Line conducted an open solicitation for transmission capacity on the Plains & Eastern Clean Line. 15 potential customers submitted more than 17,000 MW of requests for transmission service.
Clean Line's negotiated rate authority for Plains & Eastern requires the company to: ... make a compliance filing disclosing the results of the capacity allocation process within 30 days after the close of the open solicitation process, as discussed in the body of this order. *crickets*
It's been 6 months. No compliance filing. No contracts. No customers. What happened? Is Clean Line still negotiating? Doesn't sound very strong and encouraging to me. What if the bids Clean Line received were unacceptably conditioned to manage risk, or not satisfactory to economically support the project? Remember, the bidding window has closed. Would Clean Line have to award capacity to the top bidders, no matter the conditions? If so, then perhaps it is busy evaluating the economic reality of its project.
Or is Clean Line planning to reject the first round of bidders and open a second solicitation window, hoping for better bids? Would that be fair in FERC's eyes?
Don't forget to get your bids in. ;-)
Utilities hate risk.
This paper evaluates changes in fuel procurement practices by coal and gas-fired power plants in the United States following state-level legislation that ended cost-of-service regulation of electricity generation. I find that deregulated plants substantially reduce the price paid for coal (but not gas) and tend to employ less capital-intensive sulfur abatement techniques relative to matched plants that were not subject to any regulatory change. Deregulation also led to a shift toward more productive coal mines. I show how these results lend support to theories of asymmetric information, capital bias, and regulatory capture as important sources of regulatory distortion. The study looked at fuel deliveries to coal- & gas-fired electric power plants, to compare regulated to deregulated.
He found that the deregulated plants combined save about $1 billion a year compared to those that remained regulated. This is because a lack of transparency, political influence and poorly designed reimbursement rates led the regulated plants to pursue inefficient strategies when purchasing coal.
Deregulated plants paid 12% less for coal... because they have an economic interest in the cost to run the plant. Deregulated plants sell a product, and all their costs to produce that product are included in the cost of their product in a competitive market. In contrast, regulated plants sell a service at their cost, the supply of power. You will pay whatever it costs to produce the power, plus a guaranteed return. The higher the cost, the bigger the return. With ratepayers footing all the bills, these plants have absolutely no incentive to purchase the cheapest fuel available.
This is compounded by the "confidential," opaque nature of coal markets, where regulators may not compare prices to know when plant operators are paying too much for fuel. The same effect was not found in deregulated gas plants, and this was attributed to the transparent nature of natural gas markets.
In addition, the study found that regulated plant owners are more likely to curry favor with state regulators by purchasing more expensive in-state fuel for their plants. With ratepayers picking up the tab, why not? This is how states like West Virginia continue to be ruled by a dying coal industry, and part of the WV PSC's basis for approving the "sale" of an uncompetitive deregulated coal-fired plant into West Virginia's regulated environment in 2013.
The study also found that deregulated plants increase their purchase of low-sulphur coal from out-of-state mines as a cheaper way to meet environmental regulations. Regulated plants will choose installing expensive scrubbers, because ratepayers pick up the tab and the utilities collect a return on their investment.
Although the study only concentrated on fuel costs of regulated v. deregulated generators, its findings can be liberally applied across the board to all aspects of regulated electric utilities, whose cost of service rates are padded with all sorts of uneconomic purchases. When faced with the cost of its own inefficiency, the utility will always find a cheaper way to get things done, but not when ratepayers are picking up the tab.
FERC bad-boy Kevin Gates says he's going to create an animated monkey for his website that explains how to make money in PJM's badly-designed markets.
Gates therefore said he stands by his earlier statement that FERC created a market "where a monkey could have made money that summer" by randomly picking nodes, MWs, congestion caps and hours. "We now have the data and I intend to prove it empirically," Gates added. "Once I'm done with the analysis, I intend to create an animated monkey to put on my website to present the results of my work and help explain the market that FERC created." But what kind of monkey? Will it be a nice monkey?
Or will it be a naughty monkey?
For instance, staff said Chen and Powhatan's investors, including Gates, should have known that it was improper for Chen to submit trades in PJM's up-to congestion, or UTC, market on the funds' behalf just to maximize the rebates PJM gives market participants that use its transmission lines when it collects excess line-loss payments.
Staff further alleged that Gates and Chen suspected as much, citing an email exchange between the two parties suggesting that they "contact a law firm, the FERC, or PJM to try to get more insight into this issue." They never did, however, but instead decided to have Chen ramp up the trading activity, staff asserted.
Gates told SNL Energy that the problem with most of the emails and other information cited by staff to support its case is that they were taken out of context.
For instance, when asked if he indeed suspected that the types of trades in which Chen was engaging might be improper and why he did not seek advice on the issue, Gates recalled that the email exchange regarding the potential need for guidance took place in March 2010 and Chen did not begin trading in an allegedly illegal manner until the following June.
“The timing and the content of the email shows we weren't talking about Alan's trading at all — it was about the rebates themselves. We were concerned that FERC would try to retroactively take them back — not just for us, but for everyone," Gates said. He insisted that he never thought Chen's trading would be considered illegal.
Gates further explained that he did not contact an energy attorney at that time because he thought the possibility that FERC might punish market participants retroactively for flaws in existing rules was "preposterous when those rules were clearly approved." He also thought that while an attorney could quantify the risk or the likelihood that FERC may do so, contacting one would do nothing to protect him from that risk.
According to Gates, his decision not to seek legal advice at that time was the right one. He noted that after FERC in July 2011 tried to retroactively "claw-back those rebates" by ordering virtual (financial) traders such as Powhatan to return the previously refunded amounts, a federal appeals court in August 2013 remanded that decision, finding that the agency failed to justify its mandate. Moreover, Gates stressed that FERC staff has not alleged that any of Chen's trading activities prior to June 2010 were improper. To be fair, SNL Financial also did an article featuring FERC's perspective, but that one is behind a pay wall, so I guess nobody cares...
Personally, I'm looking forward to the animated monkey! I hope it's an evil monkey! They're ever so much more fun!
Grassroots citizens’ group Block Grain Belt Express Illinois (Block GBE IL) is poised to host outreach and educational meetings in affected counties across the state prior to a second round of open houses by Clean Line Energy Partners (CLEP) in early February. The group is opposed to CLEP’s plan to construct the Grain Belt Express, a 750-mile long high voltage direct current (HVDC) transmission line, which would impact landowners in nine counties across Illinois, along with thousands of others in Kansas, Missouri and Indiana. The organization is quickly gaining momentum after launching earlier this month in response to CLEP’s first round of open house meetings. Greene County will be first to host an educational meeting on January 14th at the Carrollton KC Hall at 7pm. Meetings will follow in other counties to raise awareness about the project and provide landowners with important information. Shelby County - Saturday, January 24th, 9am, Cowden Community Center Clark and Cumberland Counties – Sunday, January 25th, 1pm, Greenup Municipal Building Montgomery and Christian Counties – Thursday, January 29th, 6:30pm, Nokomis St. Louis Parish Center Macoupin County – Tuesday, January 27th, 7pm, Modesto Ashleigh Rockwell, the new Vice President of Block GBE IL, said “I encourage landowners and residents to unite and stand up for private property rights. It’s vital at this stage to get the information out there that GBE is not necessary or beneficial to Illinois, regardless of the final route chosen. We will spread the word and take action. Talk to your neighbors and get them to these meetings. Our support just keeps growing and we’re excited to get to each county to meet landowners and share information.” Block GBE IL recently held a successful launch meeting with an impressive turnout of landowners from across the state, along with assistance from three other BLOCK groups opposing Clean Line projects from Missouri, Iowa, and northern Illinois. A citizens’ board was elected, and two Illinois State Representatives were in attendance, both of whom oppose the GBE. Several county board members were also present. Megan Beeler, a Montgomery County board member, said, “Montgomery County has been offered what feels like “hush money” for awhile now, but as you can see, I’m not hushing!” Jennifer Gatrel from Block Grain Belt Express Missouri stated, " It was very exciting to be part of the launch meeting. I was thrilled that delegations from three other Clean Line opposition groups spanning three states were able to attend to help get this new organization on its feet. A family has been formed in a 6 state region, and we’re thousands strong! Together, we can and will stop the precedent from being set that a private company can seize private land for its own financial gain. I am grateful to be part of such an impressive team and have been amazed at the speed with which Block GBE Illinois has organized." A sub-group to represent landowners in the legal process at the Illinois Commerce Commission is already taking shape as well. Both groups will work in partnership to battle the GBE from all angles. “We have the odds in our favor by learning from what other states have successfully accomplished, and repeating that success. But we have to act now and we have to stick together,” adds Rockwell. For more information about any of the upcoming meetings or to learn more about Block GBE IL, please visit us on Facebook under Block Grain Belt Express Illinois or call 618-203-6909.
Despite Clean Line's song and dance about how it has consulted with all stakeholders about its projects, it somehow missed the Cherokee Nation.
Last week, The Cherokee Nation passed a Resolution “opposing the establishment of an energy line route by the Plains & Eastern Clean Line in Sequoyah County, Oklahoma located within the Cherokee Nation jurisdictional area.”
A RESOLUTION OPPOSING THE ESTABLISHMENT OF AN ENERGY LINE ROUTE BY THE PLAINS AND EASTERN CLEAN LINE IN SEQUOYAH COUNTY, OKLAHOMA LOCATED WITHIN THE CHEROKEE NATION JURISDICTIONAL AREA
WHEREAS, the Cherokee Nation since time immemorial has exercised the sovereign rights of self-government in behalf of the Cherokee people; and,
WHEREAS, the Cherokee Nation is a federally recognized Indian Nation with a historic and continual government to government relationship with the United States of America; and,
WHEREAS, The Plains and Eastern Clean Line organization is proposing an energy line route to go through Sequoyah County and Sequoyah County land owners do not want it. The towers will be at least 200 feet high and it appears that this energy line will be going across the Stokes Smith Ceremonial Grounds and also along the pathway where the Trail of Tears crossed in Sequoyah County where some historical markers are located; and,
WHEREAS, although the Cherokee Nation does support positive environmental activities, this activity does not appear positive, landowners do not want this and it could impact Cherokee Historical Areas and Ceremonial Grounds; and, the Council of the Cherokee Nation opposes the establishment of this energy line; and, therefore,
BE IT RESOLVED BY THE CHEROKEE NATION, that the Council of the Cherokee Nation, on behalf of its citizens and residents in the Sequoyah County area and due to concerns of the impact on the Tribal Historical and Ceremonial Grounds, hereby opposes the establishment of this energy line by Plains and Eastern Clean Line in Sequoyah County which is within the jurisdictional area of the Cherokee Nation. Doesn't sound like the work of a Nation that's been working hand in glove with Clean Line and the DOE, does it? In fact, it sort of seems like the reaction of a Nation that has been blindsided by a project they knew nothing about.
Janelle Fulbright, deputy speaker of the of the Cherokee Nation Tribal Council, who sponsored the resolution said:
“There is no benefit to us in any way,” Fullbright said of the transmission line. “We’re just seen as the pass through for a monstrosity that will lower our property value. Even if the proposed routes didn’t go right along the Trail of Tears and through our ceremonial ground, I’d be against it because we like to live in the country and not see anything out our back door.”
Three Arkansas County Quorum Courts (the local county government system) have also passed Resolutions opposing Clean Line. More to come.
Secretary Moniz:
I have now written you in August 2013 and September 2014 regarding the Department of
Energy's (DOE's) consideration for a partnership with Clean Line Energy Partners through the Plains & Eastern transmission line project and have yet to receive a satisfactory answer to my questions.
Since the date of my previous inquiry, I understand that the Draft Environmental Impact Statement (EIS) has been released for public comment, at which point, in accordance with your latest response to my office, "DOE will consider questions such as those raised in [my] letter." Unfortunately, merely acknowledging this fact does not, in turn, answer the questions raised.
As you know, the path of the proposed transmission line runs directly through the Third District of Arkansas. Therefore, I am extremely concerned about Clean Line's authorization. Respectfully, I am also very frustrated by one of your Department's disingenuous responses to my letters that identified "public interest" as one of the considerations given to the Clean Line
application. There has been an astounding lack of assurance that my district - and the State of Arkansas- will have any interest in this project at all and no guarantee that Clean Line will supply power to my constituents and my state. I place further emphasis on this concern given the denial of a Certificate of Public Convenience and Necessity from the initial application Clean Line had submitted to the Arkansas Public Service Commission.
Section 1222 of the Energy Policy Act of 2005 has never been invoked for the approval of an
electric power transmission facility. In light of the uncertainty of this process and the Section
1222 application, in addition to a lack of assurance regarding the benefit for the state of Arkansas from such a transmission line, I must again ask the following:
• What guarantee might the citizens of the Third District be afforded when it comes to a
specific energy supply to our state rather than a highway for power to Tennessee?
• How does the Department of Energy determine its authority for partnership with a private entity and the application of supposed rights to eminent domain?
• What factor does the denial of Clean Line as a public utility in the State of Arkansas play
in the final decision by the Department of Energy?
The DOE has been less than forthright in providing answers to the legitimate questions raised regarding Clean Line. Therefore, at this time, I would like to request a formal meeting with you to not only discuss these questions, but also the unacceptable responses that have been sent to both my office and stakeholders within the Third District. I look forward to your prompt reply.
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