8. Does the Proposed Merger of the Parent Companies and Change in Control Create Environmental Issues of Concern?

The Applicants state "this transaction is occurring at the parent, holding company level and involves no creation or consolidation of existing physical assets."269 The Applicants state that "The Commission has consistently held that the indirect transfer of ownership of facilities, as is the case with this transaction, does not raise significant environmental concerns."270

No party raised any environmental issues concerning the proposed financial transaction.

Pursuant to state law and Commission precedents we find this application raises no environmental issues of concern.

269 Joint Applicants Opening Brief, p. 55.

270 Joint Applicants Opening Brief, p. 56, footnotes eliminated.

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