GOP Also Concerned About Electricity Consumers

The RGGI states, with New Jersey, which rejoined in June.

by Steve Haner

With an eye on November 5, Virginia’s Republican legislators are expressing their concern for Virginia’s electricity customers and warning that their Democratic competitors will support a new energy carbon tax if they gain the majority. The carbon tax is a key element of the Regional Greenhouse Gas Initiative (RGGI).

In media releases and, of course, Tweets, the simple message is “Higher Taxes on Energy. Democrats Say Yes.  Republicans Say No.” The key evidence provided is State Corporation Commission staff testimony (here), first made generally available on Bacon’s Rebellion, and a recent summary on the issue I wrote for the Thomas Jefferson Institute for Public Policy (here). We took a stand against joining RGGI.

That RGGI white paper has been in process all summer, and it was pure coincidence that it surfaced just as many Democrats were showing their concern for consumers by opposing a higher profit margin for Dominion Energy Virginia. 

I pointed out when that came up that many of those Democrats had voted for some anti-consumer energy legislation in 2015 and 2018. That is an equally fair point for many of these Republicans. One can be cynical and dismiss all this as election posturing, or one can hope that the fog is clearing, and a future General Assembly will show more care about consumer cost and less willingness to enrich utility investors. The damage from 2015 and 2018 can be undone.

Educating and activating readers on these issues has been my goal in scores of stories over the past 16 months, with the hope voters would start raising them. It is not necessary that somebody lose an election over those votes, but a few very uncomfortable minutes in a debate or on a voter’s doorstep would be wonderful.

In the debate over Virginia joining RGGI or not, there are a series of roll call votes for 2018 and 2019 that were purely on party lines, something not true of any of the energy regulatory bills. Those were mixed votes. RGGI also ties into an ongoing national Democratic push to address the so-called “Climate Crisis,” starting at the top with their presidential wannabes.

You can read the white paper or other Thomas Jefferson Institute comments on RGGI for more detail. The bottom-line is that the carbon reduction goals (30% by 2030) are easy and will likely be met with or without RGGI, so there is no reason to impose a carbon tax unless the goal is just to raise money. Nobody is arguing with the stated goal of reducing electricity plant emissions by 30% (certainly not the utilities). Whether that accomplishes anything for the climate is another debate.

Will RGGI compliance cost the billions of marginal dollars over 25 years that the utility and SCC staff believe? Probably not, mainly because coal plants are closing rapidly anyway. But a tax of about $6 per ton on 28 million tons of CO2 emissions, or more, would be paid by customers. That will add up quickly. Nobody knows that the price of carbon allowances in the RGGI market will be in future years, but they could rise. RGGI’s own projections show a rising cost (see page 14.)

As I wrote earlier, “We’ll find out what (RGGI) costs when it starts to cost us and keep learning for decades.”

The Democrats accept SCC estimates as gospel in the argument over Dominion’s profit margin. They cannot turn around and reject the SCC’s estimates of RGGI cost impacts out of hand. And while I think the impact of that Dominion profit margin debate has been exaggerated, the SCC case truly is an important decision going forward. The legislative Democrats were correct that a 10.75% profit margin for Dominion was an outrageous and unjustified request on its part. By going high Dominion invited the attack.

This is all complicated stuff, and when it gets too complicated, it is tempting to just make it simple even if wrong. There is another letter to the editor in the Richmond Times-Dispatch today complaining that Dominion is asking for a rate hike. It is not. I complained back in December that Clean Virginia was being fast and loose with this material, but it was struggling for a way to reach people. Yes, it will cost customers more if the allowed profit margin goes up.

I understand there may be additional efforts by Republicans to make RGGI a campaign issue today. None of this is being coordinated with me. Nevertheless, this effort on RGGI is blurring a line. The same happened with the state’s income tax conformity issue, when my work for Thomas Jefferson Institute translated into several legislative proposals.

Since my work as a “reporter” is not recognized by the self-appointed gatekeeper of journalism (the Virginia Public Access Project filter), and my dabbles in policy do seem to have an impact, it may be time for a change in emphasis.

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34 responses to “GOP Also Concerned About Electricity Consumers

  1. “The carbon reduction goals (30% by 2030) are easy and will likely be met with or without RGGI.”

    Can you elaborate? Why do you say the goals will be easy to meet? Based on Dom’s and Apco’s Integrated Resource Plans?

  2. If the GOP spent near as much time on looking at the monopoly behavior of Dominion and neutering the SCC as they play the boogeyman game for RGGI – I might be less of a cynic.

    Truth is the GOP is carrying out the DOminion Playbook… demonizing RGGI as a distraction from the other stuff the GOP has done to further Dominion’s interests – neutering the SCC and letting Dominion run amok on the solar, wind and demand-side technologies.

    It’s a lot like “the Dems are socialists” crappola that the GOP spews out now days… They’re pretty desperate apparently and cannot win on the merits… so they gotta play socialism and RGGI boogeyman games.

  3. The IRP update report from Big D discussed around Labor Day listed 11 coal or oil fired generators closing 2019-2021, no matter what. It listed an additional six more (Clover 1 and 2, Chesterfield 5 and 6, Possum Point 5 and Yorktown 3) which are possible closure candidates, but would likely close to comply with RGGI. Anything Dominion builds for new service would be renewable or the higher efficiency natural gas. It can also buy power from other PJM states (not in RGGI) which is simply the best possible price, with no regard to its CO2 footprint, to meet demand. Can be coal plants from elsewhere.

    http://www.scc.virginia.gov/docketsearch/DOCS/4%24jt01!.PDF (You may have to copy and paste in browser.)

    Dominion also listed a bunch of stuff it says it needs to meet demand, but that depends on whether the demand growth really materializes. The nuke plants run into the 2030s anyway. Because of them, VA has never been as much a carbon-heavy electricity state.

    One aspect of the new RGGI regime which is going into effect are reporting requirements on actual plant operations and emissions in the last year or so. I think DEQ is getting or just got that data. As I noted, it wasn’t very clear what the actual baseline emissions are.

    Larry: So Capitalists can relax, stay later at dinner, and not rush back tonight to see what Bernie, Liz and the rest have in store for them in 2021? I think Warren has just come out with a new tax on investment income….having investment income makes you a capitalist, and thinking the government deserves a share to give to somebody else makes you a (fill in the blank.)

    • re: coal plants – that would close no matter what because they cannot compete against gas… nothing to do with RGGI…

      re: ” Larry: So Capitalists can relax, stay later at dinner, and not rush back tonight to see what Bernie, Liz and the rest have in store for them in 2021? I think Warren has just come out with a new tax on investment income….having investment income makes you a capitalist, and thinking the government deserves a share to give to somebody else makes you a (fill in the blank.)”

      Investment income SHOULD be taxed at a FAIR tax rate just like folks who earn income with their labor – who currently pay a higher rate.

      That’s the dirty secret on taxes…

      there is absolutely NOTHING wrong with being a capitalist nor a entrepreneur – but taxes on income should be fair and not discriminate against those who earn income primarily from their labor rather than inherited wealth.

      ” The cost basis of property transferred at death receives a “step-up” in basis to its fair market value. This eliminates an heir’s capital gains tax liability on appreciation in the property’s value that occurred during the decedent’s lifetime.”

      People who have capital gains – if they hold the property and give it to their heirs – there is no tax on it ….

      these are issues worthy of debate and discussion in my view.

      “socialism” is the favorite GOP boogeyman these days. It’s always been a favorite – they used to call Social Security and Medicare “socialism” before voters let them know how they felt about it!

  4. Larry: JUST APPEARED in my inbox:

    “Our next president is going to be on the debate stage tonight, because I know that we will take back the White House in 2020. But we need your help to pave the way for a Democratic White House. Our General Assembly here in Virginia is the closest to flipping blue this year and chipping away at the Republican stronghold in the South. Flipping Virginia blue in 2019 would send a strong signal across the country that we’re ready to elect Democrats up and down the ballot, and take back the White House and Senate in 2020….”

    So from Sanders and Warren to legislative elections all over VA….For once, nationalizing the election here is a two-edged sword.

    • You’re still having bogey man attacks… 😉 . In each primary – Dem or GOP they track to their bases – then in the general election they track back to the middle.

      As I told you before, I have voted GOP in National and State elections – and will again – once the GOP returns to normalcy..on issues like immigration, health care and education. We have a lot of them in the closet these days -they are called RINOs… I suspect you are one!

      • You mentioned socialism, not me. The GOP candidates are always happy when that word appears, so keep it up….but I’d rather talk about energy. Yes, you broke the code, gas and even renewables are driving out coal on market principles, with no regulatory mandate required.

        • Steve, market forces drove out coal. Gas is super, super low about $2 mmbtu. The market is very fluid. I skimmed your tji report. Did you talk with people in
          states part if rggi? If not, why not?

        • re: ” Larry: So Capitalists can relax, stay later at dinner, and not rush back tonight to see what Bernie, Liz and the rest have in store for them in 2021? I think Warren has just come out with a new tax on investment income….having investment income makes you a capitalist, and thinking the government deserves a share to give to somebody else makes you a (fill in the blank.)”

          so no you did not explicitly say “socialism” but geeze Steve….come on guy… you know, I am NO lover of Bernie nor Warren – I think people are idiots to support them but these folks have always been around.. just like the wacadoodles on the far right..

          but when it comes to writ large Capitalism when we have things like crop subsidies, lower tax rates for capital gains, subsidized flood insurance, forcing folks to sell their land to DOminion for a pipeline, and the GOP is bleating “socialism”… LORD!

  5. We have low CO2 in Virginia due to many nukes, electricity imports, and natural gas use. Dems want RGGI to tie our hands and pledge that Virginia will never build another fossil fuel power plant, and will shut down the relatively few fossil fuels plants we have. But that’s probably a prescription for expensive imports and/or expensive nukes and/or expensive off-shore wind. No need to rush into this mandate, let’s let the RGGI states show us the way, if they are so smart.

  6. RGGI is no different than the system set up for acid rain.

    https://www.epa.gov/airmarkets/acid-rain-program

    and it worked. Trout streams in Virginia and other states have come back.

    Used to be – things like this were not about Dem or GOP – but now they are … I strongly suspect that today – the GOP would oppose the Acid Rain program as well as the agreements made to reduce CFCs and the ozone hole.

    Things have changed. the GOP no longer is about the environment.

  7. Larry, you and Peter just agreed with me that market forces are working to retire coal, so there is no need for a cap and trade scheme to reduce power plant CO2. It’s happening. That wasn’t the case with SO2 and NOx, but those will also go down more as the coal plants retire.

    Peter: Here is all you need to know about other states, from May Energy Information Agency data: Average residential power prices in the RGGI states. Compared to VA’s 12.46 cents per kWh, the prices range from a low of 13.45 cents in MD to a high of over 27 cents in Massachusetts and 23.35 in Connecticut. All but MD and Delaware way higher than here, and that VA figure includes the more expensive coops and the municipals. Rhode Island 20.95 cents….NJ 16.80 cents…

    I left it out because it really isn’t relevant to my argument, and of course the carbon tax is hardly the only reason. But happy for a chance to bring it up, thanks.

    • I don’t think RGGI has had much to do with the price of electricity which was already high in California and the North East states prior to the advent of RGGI.

      But the simple truth is that the more expensive electricity is – the more people will adopt and incorporate demand-side conservation which means less burning of fossil fuels all together and more and more use of renewables.

      Gas will never completely go away for a long time as it is needed to cover the times that wind/solar cannot meet total demand unless and until the cost of renewables + storage are less than gas alone.

      I just don’t see RGGI as much a cost driver as the cost of providing power at peak demand which means a lot of gas plants that sit idle at times other than peak demand.

      It’s the cost of building more gas plants that will sit idle most of the time that is an issue – no different than the cost of providing enough airplanes to carry all passengers at peak periods rather than using price to spread out demand.

      If the airlines can use price to discourage peak use and it’s totally a legitimate capitalist idea – why not electricity? Peak hour pricing is a capitalism idea and it also happens to reduce pollution.

  8. Strve. Tells me nothing. Northeast electricity rates have been higher for decades. Youdid not answer my question. Did you you speak anyone in a RGGI state in your analysis or not?

  9. RGGI is really a non-issue except for the folks who use it like “socialism” as a boogeyman… My GAWD – look at how Dominion is ripping off customers – and folks are blathering about RGGI!

    Where is all that fire and fury with regard to Dominion tax rebates, coal ash cleanup, and these bogus renewable projects that are way overpriced from what the market would provide?

    All the “concern” from the GOP and conservatives is RGGI !!!! geeze.

  10. Fourteen Democratic candidates, who refused to take any money from Dominion, were able to win 14 seats in the VA legislature in the last statewide election. This remains a campaign issue in this state, as Dominion continues to exercise every financial muscle they have to hold customers captive, force their unneeded projects and demands for funding on all of us, and wield influence over legislators from all sides.
    Dominion has lost the trust of many ratepayers and an increasing number of VA citizens with their bogus data and exaggerated trend numbers and just plain wrong submissions to FERC on the Atlantic Coast Pipeline. The domestic demand for energy trends offered by the U.S. Dept. of Energy and the U.S. Energy Information Administration show a relatively flat trend through 2030. With renewable energy generation providing increasingly lower costs for infrastructure development and a lower cost for the ratepayers, we can see this transition continuing over some time based on both real market developments and the science based need for clean energy to deal with the climate crisis. Battery and storage innovations are required for a more rapid transition to clean energy solutions, but those are areas of strong science development and market investment. Given a choice, many ratepayers are happy to obtain clean energy at a lower cost than fossil fuel generation. It will be up to the voters to determine if our government will support ratepayers, will provide competitive energy provider choices, and support private property owners and the beautiful Virginia environment in the face of corporate profit seeking.

    • Yet, the GOP in Virginia stands firm in support of Dominion and it’s outrageous corporate conduct while distracting to boogeyman RGGI talk.

      If voters perceive RGGI to be about using more renewables, demand-side conservation technology and reducing greenhouse gases (polls show most voters do accept climate change from greenhouse gases but most Conservatives/GOP do not),

      that puts the GOP out of touch with voters. Demonizing RGGI will actually backfire on them. When you add this issue to things like health care, the use of eminent domain for a for-profit pipeline, Draconian immigration, gerrymandering/voter suppression, and things like Charlottesville – they are reduced to accusing Dems of socialism and RGGI boogeymen.

      It WILL work with their rural base, it won’t work for the blue urban areas – will it work for the suburbs? Nope, they are losing the suburbs as well and their response is more boogeyman scares.

      And yet, rather than respond to the actual issues that concern voters, they just continue to use these bogus deionization tactics…. The GOP used to be a forward thinking party anchored by fiscal responsibility and free markets and now they have morphed into an “anti” party with no real solutions to issues that voters want addressed – health care, education, immigration and climate change.

  11. It’s a tax. The RGGI data itself shows the tax going up three or four-fold over the decade. That’s a projection, but their own projection. The Democrats are claiming they will save people money on their bills by fighting big D’s profit margin, and the Republicans are claiming they will save people money on their bills by stopping RGGI. Both positions have merit. The dollars involved are the same. Frankly, the politics involved are the same.

    When you spew a few thousand words of partisan hype like that, it just gives me a warm feeling and anybody reading this deep into the comments can see you dragging red herrings right and left….

    • Among the more extreme environmentalists, it has long seemed to me that their primary goal, whether by RGGI or otherwise, is the drive up the cost of energy as high as possible in order to drive down demand for energy of all sorts and kinds, including demand for electricity. They have long acknowledged this tactic, though not some much lately as they try to argue that green energy will be less costly than fossil and nuclear energy. Of course, they want to ban all sources of energy other than green energy, a sure recipe for economic suicide world wide if they achieve that foolish goal, or come anywhere near to approaching it.

      • correction to above comment.

        Among more extreme environmentalists, it has long seemed to me that their primary goal (whether by RGGI or otherwise) is to drive up the cost of energy to the consumer as high as they possible can in order to drive down the consumers’ demand for energy (and the consumer’s ability to afford energy) of all sorts and kinds, including electricity.

        These tactics were behind the hidden policy objectives of the Obama Administration, including its massive resistance to gas, fracking, and gas pipelines. Many within the environmental movement have long acknowledged this tactic, though not so much lately as they try to argue falsely that green energy will be less costly than fossil and nuclear energy.

        Of course, too, they want to ban all sources of energy beyond green energy, a sure recipe for economic suicide world wide if they achieve that foolish goal, or come anywhere near to approaching it.

    • Exactly so, Steve.

  12. Peter and Larry,

    For someone like me who is a committed environmentalist, but is largely ignorant of the nuances of these energy issues, but who is learning a lot lately, what is your answer to Steve’s simple question: If the market forces are going to result in the closure of coal plants soon anyway, what is the advantage of Virginia joining RGGI?

    • Dick- Short answer….the left feels all U.S. fossil use must stop immediately. All coal, gas , and oil use must be stopped. RGGI looks at all CO2 for electric, not just coal., and forces it to zero over the long haul. Many blue states including RGGI are not building power plants.

      Basically in our region we are developing into power importing states (RGGI) and power exporting sates (PA, WV, Canada, OH). And it looks like Virginia Dems want continue Va. as an importing state by stopping any future nat gas power plants. So I am not too optimnistic about our future growth.

    • Dick- Short answer….the left feels all U.S. fossil use must stop immediately. All coal, gas , and oil use must be stopped. RGGI looks at all CO2 for electric, not just coal., and forces it to zero over the long haul. Many blue states including RGGI are not building power plants.

      Basically in our region we are developing into power importing states (RGGI) and power exporting states (PA, WV, Canada, OH). And it looks like Virginia Dems want continue Va. as an importing state by stopping any future nat gas power plants. So I am not too optimistic about our future growth.

      • I think TBill’s answer is a little extreme. RGGI isn’t intended to stop all fossil fuel consumption but to create a medium of exchange, like a carbon tax nationally would have done, to reward those building efficient plants at the expense of those who build (or continue to operate) inefficient ones. The problem is, if the revenue is not plowed back into the reward mechanism but simply pocketed by the State, then it’s no more than a tax, and should be treated as such! Thus far, Virginia’s proposed implementation has been deserving of that scorn.

        • It might be a little extreme in terms of what this specific regulation is able to accomplish, but if you listen to the Dem debates, it is not the least bit extreme in terms of the Blue approach.

  13. Dick,
    Here’s my response to your question. An opinions piece I did on the same topic in The Washington Post, a few months ago. Steve still hasn’t answered my question of whether he spoke with any RGGI states. I did.

    Local Opinions
    Virginia needs to take action on climate change — before it’s too late

    Signs mark the route of the Atlantic Coast Pipeline in Deerfield, Va., in 2018. (Steve Helber/Associated Press)
    By Peter Galuszka May 17
    Peter Galuszka is a freelance writer in Chesterfield, Va.

    After more than a decade of prodding, Virginia was on the verge of making an important decision on climate change. It could join a regional cap and trade plan that could help it dramatically lower carbon dioxide emissions as nine Northeastern states, including Maryland, have.

    Virginia would have been the first Southern state to enter the Regional Greenhouse Gas Initiative, which sets caps for carbon dioxide and breaks the pollutant into allotments, which are then bought and sold on a market. The cap would gradually decrease to specific goals. A similar concept worked brilliantly in the early 1990s to control nitrogen oxides and sulfur dioxide pollution, which caused acid rain.

    But this month, Gov. Ralph Northam (D), battered by an unrelated political scandal, took a dive. He refused to veto a sticky ball of wax of a budget bill that the Republican legislature had set up in part to stymie the initiative. Republicans used the same ploy for years to avoid expanding Medicaid.

    Fearful of a lengthy legal fight, Northam says it is better to wait until the November elections, which could give Democrats majorities in the General Assembly.

    That’s a lame excuse, considering what Maryland and its partners have done with carbon cap and trade for years. It also shows just how backward Virginia’s carbon policy remains under Dominion Energy, the politically powerful utility.

    When RGGI was proposed in the mid-2000s, Maryland was quick to give a thumbs-up. Gov. Bob Ehrlich (R) supported joining, noting that climate change “is a real thing” and had to be addressed. Public polls were favorable, and Maryland joined.

    In Virginia, meanwhile, Dominion dominated the narrative for a decade, claiming that RGGI would be intrusive and too expensive. Just a few months ago, the state still had not sorted out the numbers. The State Corporation Commission said joining the initiative would add up to $12 a month to ratepayer bills as utilities shut down or cleaned up fossil fuel plants. Northam’s office came up with a $1 a month extra cost. Green groups said it would be either a wash or net cost reduction.

    Apparently, no one bothered to ask Maryland. According to Jay Apperson, spokesman for the Maryland Department of the Environment: “The program has not created any discernible increase in consumers’ monthly bills, as the savings from energy efficiency investments have offset any price increases.” In a decade, the group has cut carbon emissions in half, he said.

    Predictions for Virginia promised similar benefits with a carbon dioxide cut of 30 percent in a decade. The Virginia Air Pollution Control Board certainly liked the figures. It voted to join RGGI in April.

    When the issue came to Northam, he shied away. Dominion Energy was pleased. It stated that the initiative cost too much and that since 2005, the utility has achieved a 52 percent reduction in carbon emissions without it.

    Environmentalists were enraged. Mike Tidwell, director of the Chesapeake Climate Action Network, said other states can proceed with positive climate regulations “because they don’t have a toxic anchor around their necks.”

    Another factor, and a big conflict for Dominion, is that joining RGGI would be an existential threat to one of the utility’s plum projects. Dominion is the lead partner of a plan to build a 42-inch pipeline that would take natural gas from West Virginia through Virginia and on to North Carolina.

    Opponents complain that it will destroy plants and wildlife, hurt property values, pose a safety hazard and contribute to climate change. It is also not clear who would use the gas or if the project is necessary.

    Opposition is so stiff that a series of legal challenges has halted its construction at least temporarily. The delays have upped its price tag from about $6 billion to $7.5 billion or more. That apparently is giving Duke Energy, a North Carolina utility and a pipeline partner, cold feet. In March, Bloomberg News reported that Duke chief executive Lynn Good said that her utility might need to find a “Plan B” to ship gas if the Dominion-led project fails.

    RGGI requires any electrical-generation facility of 25 megawatts of power or more to be subject to mandatory carbon cuts. That would include natural gas stations — exactly what Dominion is trying to promote with its pipeline. The initiative is a disincentive to “carbon-emitting fuel like fracked gas,” says Ivy Main, a lawyer who works with the Sierra Club.

    As the dithering continues in Richmond, the threat of sea flooding in coastal Virginia increases. A study last year predicted that a Category 4 hurricane would inundate most of Hampton Roads. Parts of downtown Norfolk and the Norfolk Naval Shipyard, a key defense facility, would be underwater.

  14. Oh and Dick. For more discussion check out ivy main a virginia mercury this morning

  15. Dick – they want to join RGGI anyway because 1) they want the tax dollars, starting at about $150-160 million per year and 2) most of the other RGGI states are retail choice states, RGGI is less compatible with integrated utilities such as Dominion and joining RGGI pressures Dominion to surrender to retail choice. Peter and Ivy Main have swallowed the “climate catastrophe” Kool Aid like the rest of the MSM but happy to admit I believe it less and less all the time. Virginia could take CO2 from power plants to zero and it won’t matter a lick for the climate. Likewise the whole USA, really….

    • Steve, you are spot on target.

      This RGGI and related tactics are bad policy and bad decision making, all driven by ideological group think and hysteria, divorced altogether from science, real problems and solutions.

    • Good explanation — but regardless of whether one drinks (or endorses) the kool aid locally, if the national debate turns back towards CO2 reductions, I still believe RGGI positions VA better to play those games than without it — provided, of course, that it isn’t used simply as a tax, to dump revenue into the General Fund. How the revenue is used is why the State impacts from RGGI vary so greatly.

      • “provided, of course, that it isn’t used simply as a tax, to dump revenue into the General Fund.”

        Good luck with that. And of course it will be used to drive electric costs sky-high to force consumers to ration demand, hitting the middle class and poor the hardest, while the wealthy, individuals and corporations, make out like bandits with their crony capitalism, subsidies, tax credits, and write offs through the roof, while the cost of making most everything and just keeping the heat, cool, and lights on for everyone else all go higher and higher. It’s happening already, look at California and Connecticut.

      • You are correct, Reed, that’s the problem, in a State like Virginia where there is a GA that knows how to talk Green but live Rapacious-Red. RGGI was born in States where the enviro movement is strong enough that the legislature and the electorate understand there’s a quid pro quo: in order to reward the utilities making low-carbon-impact generation choices, i.e, to make RGGI work, the dollars have to go back to those utilities’ consumers. In Virginia the leadership just wants to play the environmentalists for suckers and use RGGI as a hidden consumption tax increase on all electric consumers through their electric bills (at the same time as they effectively de-regulate Dominion’s rates in exchange for cooperating in this theft from electric consumers).

  16. Re: “time for a change in emphasis” — boo! — rather than that, can you tell us how to work more effectively to turn VPAP around?

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