III. 2004-2005 Programs

As context for our discussion below, we affirm the July 3 ACR that the Commission should continue to pursue EE programs aggressively in order to reduce California's energy consumption and to make EE an essential part of the state's energy program. These objectives are also reflected in the California Energy Action Plan adopted by the Commission, the California Energy Commission (CEC) and the California Consumer Power and Conservation Financing Authority. In order to accomplish them, we set our sights on programs that most effectively use the limited budget available for EE programs.

This decision is one in a series of steps toward assuring the Commission is most effectively promoting EE programs and the benefits that accompany them. To that end, this decision refines the process for awarding funding to various types of entities to implement 2004-05 EE programs funded by the "Public Goods Charge" on customer bills. We intend to review future solicitation criteria, practices and policies in the context of a broader examination of our EE programs.

The July 3 ACR proposed authorizing program funding for a two-year cycle for all entities to promote program stability and continuity while the Commission considers future program administration and other long-term issues.

The parties generally express support for a two-year funding cycle. Some would support program funding for a 3-5 year period. Proctor Engineering supports multi-year funding but observes that some firms who might provide innovative programs may not survive a two year period without any funding should their initial proposals be rejected.

We state our commitment to funding programs for two years for the period 2004-05 in order to ensure program continuity and stability. We intend to consider longer-term funding cycles in the near future as part of a more comprehensive review of EE program policies and practices.

The Commission allocated approximately 20% of PGC funds for EE programs managed by non-utilities during 2002-2003. The July 3 ACR proposed that the Commission consider a ranged of 15-20% of PGC funds for non-utility programs in 2004-2005, assuming the Commission receives adequate proposals for cost-effective programs. In addition, the ACR also proposed that the utilities partner with local governments and non-utilities to develop cost-effective and creative EE programs.

Some parties commented on how the Commission should allocate 2004-2005 PGC funds, raising concerns mainly about the allocation of funding between types of entities. Energy Solutions supports increasing non-utility PGC funding to as much as 35%, observing that the total funds available for EE efforts will increase if the Commission permits the utilities to include EE programs in their procurement portfolios. Energy Solutions observes that including EE program activities as part of the procurement portfolio means the utilities' total funding may not be reduced, even if future funding from the PGC is lower. Proctor Engineering would reduce utility funding to 60% in 2004 and 40% in 2005. SDREO opposes reductions in non-utility funding in favor of government entities "partnering" with utilities. It expresses frustrations with its past efforts to work with the utilities on EE program delivery.

TURN, Local Power, SESCO and WEM object to limiting non-utility funding in any way, suggesting such limits conflict with AB 117, which these parties believe permits third parties to apply for EE program funding without any limits. SESCO observes that single contractors have implemented utility-sponsored statewide programs and should be permitted to apply for funds independently in the future. WEM suggests the Commission conduct a "blind" program proposal review process to avoid any favoritism in the selection process. Local Power raises concerns that Community Choice Aggregators (CCAs) must be recognized as program administrators.2

Schiller & Mahone argue that deciding how to allocate the funds among implementers before determining an overall strategy seems clearly to be putting the cart before the horse. The CEC proposes that the Commission abandon its practice of selecting EE programs and instead permit the utilities to select programs and manage them, whether or not the Commission sets aside specific allocations for third parties. The CEC suggests there may be friction and wasted funds in the current set of arrangements.

Discussion. Our objective in this proceeding is to maximize energy savings with cost-effective programs and consider the other public policy criteria we adopt today. The method by which the Commission considers funding allocation for EE programs is inextricably linked to the Commission's existing rules and objectives when the Commission considers the length of funding, the types of programs to fund and the appropriate administrators. Indeed, the Commission recognized the importance of allowing non-utilities access to PGC funds in D.03-07-034 when it found that, "The Commission's existing policies and procedures for selecting EE programs and administrators generally fulfill those portions of AB 117 that require the Commission to permit non-utilities to apply for program funding and that articulate policy criteria for selecting programs to be funded with revenues collected pursuant to Section 381."3

In their comments, TURN, SESCO, Local Power and WEM object to the limiting of non-utility funding in any way, based in part on the fact that such limitations would conflict with AB 117. In fact, TURN in its comments states that non-utilities should have access to PGC funds without limitation. SESCO and agreed parties agreed with TURN in its reply comments. In essence, these parties propose that the Commission should allow any party to apply for all of the PGC funds the utilities collect pursuant to Pub. Util. Code § 381.

We cannot agree with this reading of AB 117. Indeed AB 117 (codified in to Pub. Util. Code § 381) states that the Commission should "establish policies and procedures by which any party, including but not limited to, a local entity that establishes a community choice aggregation program, may apply to become administrators for cost-effective EE and conservation programs established pursuant to Section 381." AB 117 added Section 381.1 to emphasize that EE programs authorized by the Commission should advance the public interest "in maximizing cost-effective electricity savings and related benefits." In addition, Section 381.1 requires the Commission to evaluate each party's proposal in light of public policy goals articulated in Section 381, which addresses cost-effective programs that enhance system reliability. Section 381.1 requires the Commission, in its review of program proposals, to consider "the value of program continuity and planning certainty and the value of competitive opportunities for potentially new administrators."

In order to ensure that California ratepayers benefit from continued operation of EE programs in 2004-2005, and to allow competitive opportunities for all parties, we will continue our funding levels of 80% of PGC funding allocated to statewide utility programs, and 20% of PGC funding allocated to non-utility programs. We do not read Pub. Util. Code § 381.1 to allow absolute access to all PGC funds solely on the phrase "any party." Even if we were to read Section 381.1 to apply to all PGC funding, Section 381.1 mandates that the Commission" establish policies and procedures by which any party...may become administrators...for EE and conservation programs." This was accomplished in D.03.07.034 when the Commission stated that, "the Commission is already implementing that portion of AB 117 that requires a process for parties to apply for EE program funding authorized in Section 381. It [the Commission] selects programs using criteria that are consistent with AB 117 and expressed in Section 381.1(a)."

In addition, we recognize that we are operating on a compressed timeframe to meet the goal of approving EE programs by the end of the year. We therefore find that program continuity and planning certainty would be best served by continuing the current balance between investor owned utility (IOU) and non-utility programs. Below is the adopted allocation of funds between these entities and programs.

Category

SDG&E

SoCalGas

SCE

PG&E

Total

Percent

2004 and 2005 EE PGC Collections

$75,000,000

$53,990,000

$180,000,000

$240,956,000

$549,946,000

100%

Utility Programs

$52,500,000

$37,793,000

$126,000,000

$168,669,000

$384,962,200

70%

Statewide Marketing and Outreach

$4,500,000

$3,239,400

$10,800,000

$14,457,360

$32,996,760

6%

Non-utility Programs (maximum)

$15,000,000

$10,798,000

$36,000,000

$48,191,200

$109,989,200

20%

Evaluation, Measurement and Verification

$3,000,000

$2,159,600

$7,200,000

$9,638,240

$21,997,840

4%

As we learn from the experiences of non-utility programs, we will have data and information available to more accurately assess the value of competitive opportunities for funding. Responding to CEC's suggestion that the Commission permit the utilities to select non-utility EE programs, we intend to address options for EE administrative structures by April 2004. However, consistent with D.03-07-034, and our statutory requirement to balance program continuity with competitive opportunities, we will use the existing processes adopted for solicitation of IOU and non-utility programs.

Consistent with Pub. Util. Code §§ 381 and 381.1, the ultimate allocation of funding for all proposed programs will depend on how well proposals meet adopted evaluation criteria, which we discuss in the following section. D.03-07-034 already addressed the concerns of WEM and Local Power that CCAs should be granted program funding without having to compete for that funding with other entities. In D.03-07-034, we addressed the threshold question of whether CCAs should be treated differently from other parties in the process of allocating EE program funds. We affirm here that CCAs should be permitted to apply for EE program funds as any other party and, for the time being, should not be granted preferences.

We concur with Schiller & Mahone that we should continue to match programs to objectives and administrative structures and to periodically refine our strategic approach to EE program development on the basis of changing circumstances. We believe, however, that this effort requires more time and effort than is available for the 2004-05 funding cycle. We intend to conduct the type of program review Schiller and Mahone suggest, as the July 3 ACR suggests.

For each program cycle, the Commission may adopt a different mix of programs depending on the types of programs proposed, how programs meet adopted criteria, and the potential for energy savings in relevant markets. In the past, the Commission approved funding for activities that fall into the following categories:

1. Statewide programs

2. Local programs

3. Statewide marketing and outreach

4. Market assessment and evaluation activities.

More detailed program descriptions are included in Attachment 1.

The July 3 ACR suggested that all parties be able to apply for all types of programs except market assessment and evaluation activities.

No party objected to the Commission's funding any particular type of program. SCE objected to the suggestion that non-utilities may compete for funding for statewide programs, which the Commission has previously prohibited. The CEC suggested increasing funding for evaluation, measurement and verification (EM&V) work.

Consistent with our previous discussion, our primary objective in this proceeding is to promote cost-effective EE savings fairly and sensibly. In pursuit of that objective, we do not wish to limit a party's ability to propose a program. To do so means we eliminate from consideration potentially cost-effective programs and effective entities. To assure the state receives the benefit of the best and most cost-effective package of EE programs, we will permit any party to propose any type of EE program for funding.

We will consider increasing the EM&V funding level, as the CEC suggests, if we determine that additional funds are required for meaningful EM&V reports. We intend to solicit EM&V contracts and manage them for 2004-05 programs in order to assure independent evaluations and protect those entities managing programs from perceived conflicts of interest. Because we intend to contract for and manage EM&V activities, parties who propose EE program funding do not need to include budgets for EM&V in their proposals. They should, however, propose the types of EM&V activities and criteria.

The July 3 assigned Commissioner ruling sought the parties' comments on whether the utilities should be permitted to extend current statewide and local programs for an additional two years through the end of 2005. The ruling suggested any requests for extensions would need to be supported with evidence that the programs are successful and still in demand by customers. It proposed the utilities modify programs to improve cost-effectiveness, administrative efficiency, or fulfill other program criteria.

TURN objects to any automatic extensions on the basis that they would provide preference to the utilities at the expense of non-utility program funding. Proctor Engineering raises similar concerns. The utilities and Schiller & Mahone generally support this change in procedure, observing that it will promote program stability and continuity. SCE proposes that this extension obviates the need for any program solicitation. We concur with the ACR that the utilities should be permitted to propose extensions to their program offerings for an additional two years. On the basis of our review of AB 117, however, these extensions could not be automatic because we must ensure that all programs advance the public interest in maximizing cost-effective electricity and natural gas savings and related benefits and are consistent with the goals of existing programs established pursuant to Sections 381, 381.1, and 890. In their proposed extensions, the utilities should demonstrate that these programs are successful and the programs are still in demand by customers. The utilities may propose modifications designed to improve cost-effectiveness, administrative efficiency, or fulfill other program criteria. We will evaluate utility filings for program extensions based on the information provided to the Commission.

E. Criteria and Policy Rules for 2004-2005 Program Selection

The Commission has evaluated recent program proposals from all parties using the program selection criteria adopted in D.01-11-066. That order articulated the objectives of the Commission's EE programs and adopted criteria for evaluating EE program proposals, as follows:

The July 3 ACR solicited the parties' views on whether and how the Commission should modify these evaluation criteria.

Several parties commented on the relevance of existing criteria. PG&E proposes to remove the criteria that refer to innovation, synergies with other programs, and market failures. It proposes that each program meet at least one of the four remaining criteria and that program portfolios meet all four in a more or less balanced way. PG&E also proposes the Commission eliminate the point system in the Policy Manual as "subjective." SCE would also reduce the list of evaluation criteria.

Sempra would add creditworthiness and program experience to this list. SDREO would add criteria that recognize customer preferences. San Francisco would add "environmental justice" to the list of criteria to recognize that minority and low-income customers living next to power plants are disproportionately affected by pollution. It also suggests the Commission consider the benefits of reducing regional peak demand, which may differ from statewide effects.

SESCO makes several suggestions for changing the criteria by which the Commission evaluates proposals. It advocates that preference be given to cost-effectiveness, not energy savings in isolation, since consideration of energy savings alone creates a bias in favor of large projects that are not necessarily most cost-effective. NAESCO and Sisson also advocate for increased emphasis on program cost-effectiveness. NAESCO proposes the Commission recognize various types of benefits that occur from EE programs and that cost-effectiveness may differ according to geographic area. It also emphasizes the need for those who implement programs to coordinate their efforts in ways that permit customers to see a whole package of EE options, rather than a set of disparate program offerings.

The CEC, among others, suggest that reducing peak demand is a more important policy objective than the current ranking suggests, considering that it improves system stability and reduces the need for new capacity. The CEC also suggests the Commission's evaluation criteria recognize the need for programs to be consistent with resource needs identified in the utilities' procurement proceeding.

Discussion. We retain most of the program criteria adopted in D.01-11-066, while making some modifications that reflect changes in markets and build on our recent experience. We adopt the following criteria in order of importance, as follows:

We agree with the parties who raised concerns about characterizing total energy savings as the most important criteria because it suggests we are more concerned with the size of an individual program rather than its effectiveness. Maximizing long-term energy savings remains one of our primary goals, but we agree that overall cost-effectiveness should be elevated in importance. The benefit-cost ratio of a program, defined as the program benefits divided by the program costs, will capture the effectiveness of a program irrespective of the program's size. At the same time the program's net benefits, defined as the program benefits minus the program costs, will capture the magnitude of the program's benefits and long-term energy savings. However, because of discounting, cost-effectiveness alone would tend to favor programs with greater short-term than long-term benefits. In addition, retaining long-term energy savings as a separate criterion helps us balance our portfolio between baseload energy savings and peak demand savings. Removing long-term energy savings as a separate criterion, while leaving cost-effectiveness and peak demand savings, would tend to bias the portfolio in favor of a total short-term, peak demand focus, to the detriment of programs that take longer to realize savings but are ultimately more sustainable and permanent. Thus, we simply reorder these three criteria and weight them differently from the last round.

We agree with CEC and others who suggest that reducing peak demand should be among the most important selection criteria. Reducing peak demand improves system reliability and permits the state to forego expensive capital investments in new power for on-peak demand. We rank the evaluation criteria accordingly. We will give additional weight to proposals that would reduce peak demand in geographic areas that are transmission-constrained or otherwise face reliability problems that have been identified by the California Independent System Operator (ISO) in its most recent system assessment report, generally published in the Spring and Fall.

As CEC suggests, we also intend to provide a preference for programs that would address resource needs the Commission has identified, whether as part of the procurement review or other process. We do not include this as a criteria but intend to select proposals that would address identified resource needs in cases where competing proposals are otherwise comparable from the standpoint of satisfying other criteria, such as cost-effectiveness or equity.

We continue to encourage parties to propose creative and innovative programs. We also agree with parties who suggest that success in delivering EE programs should be added to the list of program selection criteria. In this context, we expect parties to be able to show that their past programs have been cost-effective (for those measured that way) and have reached targeted communities. We agree with San Francisco's proposals, recognizing that environmental quality is among the essential benefits of EE programs. Equity in the distribution of selected EE programs will inherently ensure environmental equity as EE provides environmental benefits to the communities it serves. The Commission will continue to explicitly endorse equity in the distribution of EE funds.

Information and statewide marketing and outreach programs should be evaluated using criteria most relevant to these programs. Accordingly, we do not require an explicit showing of cost-effectiveness or a demonstration that programs will reduce peak demand. To the extent proposals can demonstrate these kinds of benefits, however, we will credit the proposal accordingly.

We also decline to adopt Sempra's proposal to add creditworthiness to the criteria list. In our view, Sempra has failed to establish that an entity's creditworthiness is tied to that entity's ability to provide cost-effective EE programs.

We do not adopt PG&E's suggestion that we reduce the evaluation criteria and judge proposals on the basis of a portfolio of program proposals. Many who propose programs may not present a portfolio of programs and our goal is to choose programs that maximize cost-effective energy savings rather than reduce accountability for individual program elements. PG&E and SCE may propose a reduced list of criteria for their EE programs that are incorporated in their procurement portfolios.

We also decline to eliminate the point system, which PG&E believes is subjective. While the point system may not be precise, no party has proposed an improvement to the existing rating system.

Staff will review proposals and recommend the design of the portfolio as follows: (1) Staff will evaluate each qualifying proposal using the primary and secondary criteria set forth below; (2) The proposals will be ranked in order of their scores on each set of criteria, and (3) Finally, using the proposals that will most effectively accomplish the goals articulated below, a portfolio of programs will be assembled from the pool of proposals. The portfolio must adhere to available funding by utility territory and have a total resources cost (TRC) ratio greater than one, and we ask staff to compile a balanced portfolio of programs that balances the following goals:

· Maximized energy savings

Staff's recommendation for the portfolio design will be provided to the Commission, which will make the final determination regarding which proposals will qualify for funding in the 2004 and 2005 program years.

Primary Criteria

We adopt the following points for each selection criteria according to the type of program as follows:

PGC "Hardware" and Incentive Programs

· Cost-Effectiveness (40 points: 30 points program net benefits, 10 points program benefit-cost ratio);

· Long-term Annual Energy Savings (20 points);

· Peak Demand Reductions (15 points);

· Equity (10 points);

· Ability to overcome market failures (5 points);

· Innovation (5 points);

· Coordination with Other Entities (5 points);

Information-Only and Statewide Marketing and Outreach Programs

· Ability to overcome market failures (25 points);

· Equity (25 points);

· Innovation (25 points);

· Coordination with other Program Implementers (20 points); and,

Secondary Criteria

· Quality and viability of program design (30 points);

· Distribution and reasonableness of budget (20 points);

· Program objectives and tasks clearly identified (20 points);

· Experience with successful delivery of similar programs (20 points);

· Alleviates transmission constraints in an area identified by the California ISO (10 points).

Although not a selection criteria, in order to execute the contract, parties who implement EE programs must demonstrate that they will comply with all local, state, and federal laws, and that they have or will obtain all necessary licenses.

The assigned Commissioner ruling solicited the parties' views on whether the Commission should allocate about $15 million per year to Marketing and Outreach (M&O) programs. It suggested permitting any party to propose statewide M&O programs for 2004-05.

Efficiency Partnership proposes the Commission retain the current level of spending for M&O programs, about $20 million. It also suggests program criteria that promote coordination between those managing programs and those conducting M&O programs to promote the effectiveness of both types of programs and avoid duplication of efforts. In particular, Efficiency Partnership observes that a single website could provide information about or links to all PGC programs.

We concur with Efficiency Partnership that all parties implementing programs should demonstrate that they will coordinate their efforts with parties implementing M&O programs, and will include that requirement as an element of narrative program descriptions.

The July 3 assigned Commissioner ruling solicited suggestions for market assessment and evaluation activities for 2004-2005 programs. It also suggested the Commission consider reestablishing the evaluation, measurement and verification protocols used by the Commission prior to l996.

PG&E proposes consistent evaluation criteria for all parties. Proctor Engineering and Cal-UCONS support the use of previous EM&V protocols as long as they are applied equally to all parties. They also suggest the findings of these investigations should be applied in the first program year. The CEC suggests the Commission contract for EM&V activities, observing that entities with program funding have incentives to influence evaluations of their own programs and may be able to assert that influence if they are managing evaluation contractors.

We will continue to refine the EM&V protocols by way of workshops and through the existing Commission mandated EM&V framework study with TecMRKT Works, overseen by SCE. Until the parties have had an opportunity to work with Commission staff on this issue, we will continue to use the existing EE Policy Manual to provide guidance for 2004-2005 EE program submissions. While we are in the process of revising and updating the EM&V protocols and framework, we will leave the bulk of the evaluation responsibility with the utilities, subject to oversight from this Commission. We will consider the larger issues related to who should evaluate EE program progress in the context of our deliberations later this year and in early 2004 on the overall structure of administration of EE programs.

Some parties raised concerns about program administration and the nature of contracts between the utilities and third parties, which govern non-utility activities and payments. Energy Solutions recommends the contracts apply standard industry terms for time and materials rather than cost-plus terms, suggesting industry standards would promote more cost-effective use of funds. Schiller and Mahone oppose many aspects of the existing policy manual where they concern program administration, and suggest completely revising the manual to clarify and simplify the process. WEM raises several concerns about contract language, the contracting process and schedules for administration.

We will update the Policy Manual to make it consistent with the criteria and other requirements laid out by this Decision. We have taken comments on the standard contract required during the 2002 and 2003 program years. Based on those comments and our experience over the past 2 years, staff have revised the standard contract and will be posting the new contract on our EE website along with the revised Policy Manual. For those items that do not need to be resolved for the current program solicitation, we will conduct workshops to better understand the parties' concerns modify the Policy Manual in a future Commission decision.

The ACR proposed that third parties implementing EE programs be able to propose extending those programs through the second quarter of 2004 using currently approved funding levels. Program implementers would be allowed to commit all funds to specific purposes no later than March 31, 2004, and have until June 1, 2004 to complete all program activities, including final installations, evaluation, measurement and verification, and final reports. Final reports and evaluations for extended programs would be due no later than July 1, 2004.

LA does not oppose this change but asks that parties be permitted to submit related proposals no later than November rather than by September. We will not make that change in the schedule, but will provide a process for program implementers that need more time to prepare their request.

Requests for program extensions are due by September 8, 2003. M&O program implementers, in addition to non-utility program implementers, are eligible to request no-cost extensions. Those program implementers who are unable to comply with the September 8th deadline must obtain approval from the Executive Director for an exception prior to the deadline. In seeking approval for an exception to the deadline, implementers should provide an explanation for their anticipated delay. We also delegate authority to the Executive Director to approve these extensions since they do not require authorization of new funds or program elements, but simply extend program offerings for an additional time period.

We will permit non-utilities to seek program extensions for existing programs through the second quarter of 2004. These requests for extensions of time should explain the reasons for program delays and should not seek additional funding. These extensions will not affect funding for or administration of 2004-05 programs. Because these extensions do not require new funding or program elements, the Executive Director will have discretion to approve or deny the extensions on behalf of the Commission.

Separate from program extensions for existing programs, Efficiency Partnership believes it should be directed to file a justification for extension on September 22, 2003 similar to the process proposed for utilities rather than requiring another competitive solicitation process. It reasons that the ACR proposes that the utilities file justifications to extend their current statewide and local programs for two additional years, yet it requires the statewide marketing and outreach programs to competitively bid for funding over the next two years. Efficiency Partnership furthers states that this approach will disrupt the progress that the Efficiency Partnership has made in creating a statewide umbrella for the marketing and outreach efforts related to program diversity. SCE supports this program and contract extension for Efficiency Partnership.

We will grant the request of Efficiency Partnership that it should be permitted to file for an extension of its statewide marketing and outreach programs into the 2004-2005 time period. We intend to extend the funding for its statewide marketing and outreach programs upon a justification that the programs have been successful in light of stated criteria. We grant this exception for Efficiency Partnership because, unlike non-utility local programs, Efficiency Partnership's programs are designed to support the statewide utility programs. Our goal is to avoid disruption in statewide energy efficiency programs that have proven to be successful while at the same time, ensuring cost-effective programs, administrative efficiency and the fulfillment of other program criteria. Indeed, requiring statewide marketing and outreach programs to go through the solicitation process could potentially undermine the momentum and public awareness of statewide programs due to the time-sensitivity and distinct strategies of these programs. As the Efficiency Partnership states, "The Flex Your Power" campaign, for example, is planning a stakeholder workshop this Fall which will be attended by the utilities, municipal utilities, water agencies, manufacturers and retailers and appropriate third party providers to review enhancements to the efforts currently underway and finalize planning for 2004-2005. This type of forum may be vital to planning for the 2004-05 period and would need to be conducted in advance in order for related activities to be most effective. A potential disruption in this statewide program could effect the participation in this forum, as the stakeholders require some level of assurance and consistency in order to provide the resources necessary to ensure this program's effectiveness and statewide participation. Efficiency Partnership must file for an extension by September 8 in order for review of its proposal to be complete prior to filings by other parties.

Information about the process for applying for 2004-2005 EE program funding will be posted at the Commission's website. All parties must submit complete proposals, in accordance with the instructions posted on the Commission's EE web page, no later than September 23, 2003. Parties should assume the total budget for EE programs will be those funds collected pursuant to Section 381 from electric utilities and Section 890 from gas utilities. Utilities' proposals should specify how they would allocate additional procurement funds approved in R.01-10-024.

The parties generally advocate for an order by the end of the year that finalizes funding for programs. The Commission intends to authorize EE programs selected for funding in an order to be issued in December 2003, recognizing the need for program continuity and time for parties to plan their procurement and delivery strategies.

2 CCAs are organizations created by local governments pursuant to AB 117 for the purpose of procuring power and administering EE programs on behalf of local citizens. We recently addressed certain issues relating to AB 117's requirement that CCAs be provided opportunities to apply for EE program funding. (See D.03-07-034.) 3 Finding of Fact #2, D.03.07.034

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