Meralco’s Increasing Rates Due to Outdated “Down and Still Pay” Allowances

David Celestra Tan, MSK
21 February 2016

Meralco recently announced its rate will increase P0.42 per kwh which many consumers and apparently including the ERC and the DOE find inconsistent with the 55% drop in world fuel prices. Of the P0.42 per kwh increase this month, P0.25 or 60% is from generation charges, 0.08 or 19% is from higher transmission charges of NGCP, taxes of 0.05 (12%) , and others of 0.04 per kwh (9%).

Since fuel prices have remained low, the increase could have come only from fixed capacity payments. Meralco had further warned the public to expect more increases because of the coming hot summer months and the scheduled downtimes of more of its contracted power plants. This means Meralco will be paying for capacity fees even during the downtimes for maintenance that the generators are allowed under their power supply agreements. Since there is no output from these plants, the capacity payments will increase the average generation rate passed on to the consumers.

Origins of Guaranteed Capacity Payments during contracted downtime allowances

Guaranteed capacity payments are designed to assure the bankability of power generation projects especially in the aftermath of the power crisis of the 1990s. This is a key provision in the BOT contracts signed by NPC, which is supposed to receive ownership of the plants at the “T” time or transfer. The owners of Meralco followed suit even if their projects with affiliated companies First Gas (1500mw) and QPL (440mw) were BOO, build own and operate and Meralco the off-taker will never gain ownership of the asset. In fact, these two sweetheart contracts were the cause of the mysterious“PPA” charges (Purchased Power Adjustments)that ravaged the consumers in late early 2000’s, when generation charges jumped 50% from the NPC monopoly regime.

It became known as “take or pay” or minimum energy off-take. What most people did not know was that it also included “down and still pay” provisions where the off-taker Meralco or NPC still pay even if there is no service to take. This is in the form of a downtime allowance where the power generator is allowed not to deliver the service during the needed maintenance times whether planned or unplanned. This is normally 30 days for each generating unit and 15 days plant downs. Some plants provide for 45 days for each generating unit.
What are the drawbacks of these that work against the consumers?

1. With the downtime allowance, the off-taker or DU essentially agrees to pay the capacity fees for 12 months even if the service will be available only for 10 months. Power Generators are entitled to assured payments but only for the times that they are providing the service and not even when they are not. If the plant is available but not dispatched by the off-taker, then it may be fair to pay them. But why pay when they are not running and cannot provide the service?

Downtime for maintenance is normal for power plants since they are mechanical equipment that breakdown and need repair and maintenance. However, downtime provisions should only mean the generator is contractually excused from delivering power but not privileged to continue to be paid by the consumers even if their plant is broken down. There should be no reward for non-performance.

2. With such guarantee, the generators do not have the pressure to minimize his downtime and to make the necessary investments for optimum plant reliability. It is a generator flexibility that leaves consumer vulnerable to undeserved capacity charges.

3. In Meralco’s case, the existence of many sweetheart deals between affiliated companies and the coming 1060mw of Meralco PowerGen’s Redondo Power and Mauban expansion, lends to opportunities for lax and sweetheart monitoring of these outages. There is nothing to guarantee that Meralco will not pay its sister generator even if its downtime is in excess of even the contracted downtime limit. In the case of First Gas, there is continuing doubt that they were paid full capacity fees in its first two years when the plants are reported to be actually not yet finished or NPC did not have transmission capacity in the location First Gas chose. They even sued their contractor for the delayed completion of the plant. There is no safeguard against the possibility that, given a choice between putting income in their own pockets or the pockets of the consuming public, that the owners of the distributor-generator would choose the latter.

4. The capacity rate being evaluated and approved by the ERC do not reflect the true annual cost to the consumer of the power rate. Essentially the true monthly cost is the annual capacity rate divided by 10 months, and not 12 months, since the service will not really be available two months of the year. The true cost to consumers would be higher but it’s better than to make them believe the rate is lower when it is not really. This is one compelling reason for a CSP so the generators can sharpen their pencils and not be spoiled by a 2 months free income.

5. Some Other bilateral contract provisions that need to be updated

a) Sell back of undispatched power to the WESM Since Meralco is already paying for the annual capacity fees in its power supply agreement, how do the consumers insure that the sell back of the unused capacity or energy is credited to the Meralco consumers and not provide a double recovery on the part of the generator?

b) Responsibility for replacement power In the November and December 2013 fiasco of the power market, a good number of Meralco bilateral contractors claimed technical shutdowns due to “boiler leaks”. May be those could not have been easy reasons if they are responsible for replacement power in case they are already in excess of their contracted downtime allowance.

c) competitive procurement of fuel There is no current regulatory rule on assuring that the fuel is truly competitive since this is a pass on charge to the consumers. Reports are that the procurement of coal and distillate fuel replacements are done by the affiliated companies of the generators.

4) control of dispatching of the contracted plants by Meralco by a Meralco subsidiary. This is very dangerous for market manipulation and should be looked into by ERC and PEMC to assure it doesn’t happen

5) For brand new greenfield projects essential for the country’s power development especially those in strategic locations may deserve capacity payments including downtime during the first five years to enhance bankability. However, the proponent must be willing to reduce the price in return. Maybe there should also be ladder rate structure where the price is reduced after the original project financing is paid off.

One thing MSK is not able to reconcile is Meralco announcement of the power plants that had downtimes for January 2016 as part of its explanation for the higher generation rate of P0.25 per kwh.

Meralco had announced the Downtime maintenance schedules of its generators for January 2016.
a) Calaca 1 and 2 600mw
b) Masinloc 1 315mw
c) Sta. Rita 10 257.3mw
d) Sta. Rita 40 264mw
e) Sta. Rita 30 265.5mw

An analysis of the Meralco purchases and the dispatch level of each power supplier showed that only SEM Calaca (600mw) had dropped dispatch to 33.8% and 23.7% in December and January. Masinloc still had 98.4% and 91.7% during those months. Sta. Rita had 84.8% and 75.2%. So why imply that these plants shutdowns caused the increase in rate?

The IPP that increased its kwh rate by P5.00 is the Therma Mobile whose dispatch dropped to 5.7% from 10% in December indicating increased supplies from Meralcos base-load suppliers. WESM’S price also dropped significantly in January indicating ample supply to the grid.

Maybe the reserve capacity contracts being entered into by Meralco with Bauang Power and the Panay Power diesel plant as far away as Panay island also needs to be reviewed by the ERC for their usefulness and costs to Meralco consumers.

For August 2016 the following have scheduled maintenance
a) SPPC- Ilijan 190mw
b) Calaca 1 330mw
c) Sta. Rita 20 255.7mw

For September 2016,
a) Sta. Rita 30 and Calaca 600mw

For October and November 2016
SMC Sual 647mw

The ERC instead of waiting until “hell hits the pan” when these downtimes and their capacity payments had already wrecked havoc on the consumers, maybe should conduct a pre-emptive review of the downtime provisions and capacity payments of these bilateral contracts to assure there are no onerous provisions. They must also evaluate how the contracted DU verifies and monitors the downtime allowances to protect the consumers.

Can they ask these generators to schedule their preventive maintenance during the low demand times of the country like maybe in the 3rd quarter? Why are they all bunched up in January?

We are holding our breadth for the next round of Meralco rate increases caused by these outages.

Matuwid na Singil sa Kuryente Consumer Alliance Inc.

Update on CSP Front, Part 2 – Games People Play in “Swiss Challenge” Biddings

Posted on: Feb 17, 2016

David Celestra Tan, MSK
14 February 2016

It is Valentines Day and it is great to read the consumer-heartwarming news about the ERC disagreeing to the requests of many electric cooperatives for exemption from the mandatory bidding or CSP of their pending power supply contracts.

The deadline set by the ERC was November 6, 2015 for filing with their applications with the ERC to be exempted from the new rule as called for in the national policy set by the Department of Energy on June 30, 2015.

Part of sensible governance is the use of an orderly transition period from an old system to a new one. In the case of the CSP rule, where competitive bidding is required, there is a need for a rational transition period to deal with those power supply contracts that have already been signed before November 6, 2015. This is both to be fair to those DU’s and generators whose contracts have been signed and close to implementation and to assure the timely development of power supply to consumers.

We have to hand it to the ERC Commission led by new ERC Chairman Jose Vicente Salazar for deciding on a sensible transition CSP method, one of which is a Swiss Challenge (or price challenge as used by Meralco recently). Happy Valentines to you too, your Honors!

“Swiss Challenge” has its basis in the BOT Law in dealing with unsolicited proposals and defined under Section 10.2. Obviously it must not be in the governments “list of priority projects”.

Should it be blindly adopted for purposes of implementing the “Competitive Selection Process” (CSP) policy on power supply contracts?

Swiss Challenge (or price challenge) favors a chosen project proponent with a “right to beat” privilege and hence is only theoretically competitive. It also discourages true competitors from bothering to bid. In fact it is not unusual for potential bidders to back out because they can see that the rules are already designed to favor one preselected bidder. One of its major flaws is the challengers can only challenge the price and not deviate from the technical and commercial aspects even if those are actually faulty and disadvantageous to the off-taker and the consumers.

The key issue is what the original proponent would have done to be entitled to the privilege of “right to beat” the other bidders?

First it must be an Innovative Proposal. This Means an infrastructure proposal submitted by a Private Sector Participant that has innovation in technology that is unique and legally owned or authorized to be used by the Proposal Initiator that could result in increased value addition; it may refer to incremental, emergent or revolutionary changes in products, services, costs, and environmental advantages.

Some private proponents claim that special circumstances dictate the necessity to sole-source some project proposals, such as the following reasons:

• A project developer possesses intellectual property rights to key approaches or technologies;

• A lack of private-sector interest due to the small scale, remote location, or political risk of the project; • Organizing a public tender may not be cost efficient for governments, bidders, or 2 both;

• The speed of project development would be more rapid through negotiations, especially during emergencies or widespread shortages. Intellectual Property Rights Many companies propose unsolicited projects claiming to use new technology. The BOT Law as revised in 2012 deals with “new technology” under Section 10.2


The new technology must possess at least one of the following attributes:

a. A recognized process, design, methodology or engineering concept which has demonstrated its ability to significantly reduce implementation of Construction costs, accelerate project execution, improve safety, enhance project performance, extend economic life, reduce costs of facility maintenance and operation s, or reduce negative environ mental imp act or social/economic disturbances or disruptions either during the project implementation/Construction phase or the operation phase;

b. A process for which the Project Proponent or any member of the proponent consortium possesses exclusive rights, either world -wide or regionally; or

c. A design, methodology or engineering concept for which the proponent or a member of the proponent consortium or association possesses intellectual property rights.

The idea of “intellectual property rights” means having the exclusive or priority rights to offer the service. For power generation, this can include having the water rights to a mini-hydro project, locational rights to a wind-rich area. For the distribution utility it means deciding whether the power supply it needs can be provided from different options.

SECTION 10.3 – PROJECTS INELIGIBLE FOR UNSOLICITED PROPOSALS Projects included in the “List of Priority Projects”.

Most Power generation projects are no longer innovative and involve old and established technologies. Diesel plants, coal, natural gas, solar.

Games People Play in CSP

1. Swiss Knife

One EC had the nerve to invite for challengers without disclosing the price that is being challenged on the claim that it is “not fair” to the original offeror! (That was Swiss alright but not a Challenge!)And the DOE then certified that, for regulatory compliance,” the EC had conducted a CSP” apparently thinking (or not thinking) that it does not matter whether the CSP was manipulated and not truly competitive. This resulted to the government paying more than P100 million a year in additional subsidies or P1.0 billion over its 10 year term. (Did the PDAF scandal only involve P980 million?) It involved the old diesel plant technology.

2. Ropa Dope

In another case, the EC and the favored bidder contrived a scheme where the bid bond was required to be a cash bond of tens of millions of pesos. After the naturally scared potential bidders did not buy the tender documents, the terms of the bid were amended to allow same amount of bid bond but in surety bond not cash. By that time the potential bidders who did not buy the tender documents were no longer required to be notified. Hence competition was eliminated and there were only two bidders, and the second one, as you guessed, was a joker bid. The increase in missionary subsidy was about P20 million a year. This involved diesel technology.

3. Trojan Horse Gambit

In yet another case where there was a battle between an RE biomass project versus a coal project, the EC with the inexplicable blessing of the Arroyo ERC and the DOE’s EPIMB allowed the removal of VAT in the bid comparison thus eliminating the “true cost of generation” disadvantage of the favored Coal proponent. On top of that, the EC and DOE already knew at that time that the people of their island did not want coal to protect the islands main business which was tourism. Thus allowing coal as a bid almost guaranteed a delay in the project because of lengthy battles with the community environmentalists. As you guessed, the coal proponent won the CSP but the coal plant had been rejected by the people in three different towns. That island is now suffering from power shortages.

Another mystery was the PSA was changed to P12.80 per kwh of bunker c based power after the bidder won with a P9.50 per kwh bid offering coal. This, with the approval of both the DOE and ERC. Some companies can get away with murder.

4. Hot Dog Sandwich

In this one, the DU will call for bids that are specifically suited to the specifications, location, and timetable of the preferred proponent specially a sister company. The “hot dog” is sandwiched between specifications and delivery time that only the preferred proponent can meet. The DU waits until its preferred supplier has had an insurmountable headstart to gain an advantage and offer specifications, permits, and delivery time that other challengers will be impossible to beat. We expect the large distributor-generator groups to try this one.

Outwitting the rules is a national past time in the Philippines. Let us hope the new DOE Secretary and new ERC Chairman will not allow these CSP shenanigans to happen.

If the DOE and ERC check the records, the Swiss challenge biddings in the Spug areas and even Meralco recently, either end up with no challenging bidders, or with joker competitor bids.

Swiss or Price Challenge should not be an acceptable procedure for compliance to the words and spirit of the CSP policy of the DOE. This must be the standard policy. However, for a Transition CSP of say 90 days and in the interest of continuing direly needed power supply projects, Swiss Challenge can be tolerated…..but with well thought off safeguards to assure “true challenges” to the price.

We offer the following safeguards for the consumers:

1. The PSA must be a signed and binding and notarized contract before November 6, 2015. No exceptions. Board approvals and notice of awards are not PSA contracts.

2. It must have been awarded in accordance with the bilateral contract rules in effect at that time before November 6, 2015. If it is for the EC in the off-grid area then it must have undertaken a truly competitive bidding or CSP under the existing rules of the DOE for CSP in missionary areas. (DOE Circular 2004-01-001)

3. The contract cannot be between related DU and Genco.

4. Encourage True Bidders and Level the playing field

Swiss Challenge actually is normally intended to favor a chosen supplier. So a Swiss Challenge term of reference normally contain requirements that favor him and difficult for new bidders to challenge.

a) Sufficient time to submit a challenge bid New bidders are normally allowed about 45 days to submit their bid, hardly enough to prepare a power supply proposal especially bigger projects.

b) Sufficient time to Complete the project Since the proponent has had probably a year’s jumpstart in preparing his offer, there can be a truly competitive challenge if new bidders are given as much time as feasible for project completion.

The EC or DU must be required to prove to the satisfaction of the DOE that the intended power supply is urgently needed and proceeding with the signed contract is its best chance to meet the timetable and that the contracted capacity and technology is appropriate for its service area. If the power supply timetable has room, then the Swiss Challenge bidding must allow for a longer delivery timetable instead of the one provided for under the contract. This is one area of levelling the playing field for new bidders especially when time constraints for project completion are not really necessary.

c) Sanitizing the Terms of Reference The proposed terms of reference for the challenge must be thoroughly reviewed by a specially trained competitive bid team at the DOE that will comb through the proposed bid terms to spot provisions that tend to favor the current proponent and put the new bidders at a disadvantage or outright deterrent for new bidders.

5. DOE must adopt an Eco-Technical Swiss Challenge (of course it is possible!)

To guard against contracted but improperly conceptualized power project, the challenge shall be both economic (price) and technical.

a) A bonafide challenger can match the proponents price or lower, offer superior terms, and also be allowed to improve or revise the specs for the better.

b) An independent technical consultant hired by the DOE and ERC can evaluate whether the technical revision was an improvement over the originally offered technical specifications. Like, brand new vs refurbished engines, or 4mw engine sizes instead of 8mw.

If it is an improvement, the original proponent would be allowed to match or lower both the technical and price of the challenger.

6. This Transition CSP must definitely require the use of independent Third Party bid administrators.

7. Stiff Penalties

For good measure the ERC must specify stiff penalties to those who will be found to be circumventing the November 6, 2015 deadline likely falsifying and anti-dating the PSA.

We can refine international practices to suit Philippine conditions especially when it will benefit the consumers. Maybe we should call this Filipino Challenge.

This Transition CSP program is only for those DU’s who did not have any PSA’s exempted by the ERC under the normal CSP policy that came into effect on November 6, 2015.

In the case of Meralco and Meralco PowerGen, they should no longer be allowed to avail of this transition CSP because their two contracts the 480MW Mauban expansion and the 600mw Redondo Power project in Subic have already been exempted under this new CSP rule.

These safeguard ideas are by no means complete. The point is yes, Swiss challenges can be adopted as Transition CSP only for a fixed grace period with appropriate safeguards to protect consumers and assure a truly competitive challenge. And only for signed and binding PSA’s and with a 60 day deadline to submit the ERC application. Swiss Challenge should not be adopted as normal policy for CSP purposes.

Happy Valentine’s Day everyone!

Matuwid na Singil sa Kuryente Consumer Alliance

Why Electric Consumers Need A Petilla in the Senate

David Celestra Tan, MSK

There is a lot of work needed to undo the damage to electric consumers of the failures of the implementation of the Epira Law, of the deregulated and privatized power industry, of the compromised regulatory authority and system, of anti-consumer rate setting methodology, and of rules full of loopholes perpetuated by the powerful vested interests.

As consumers, we can bark up as much as we want at the Department of Energy and the Energy Regulatory Commission but there are reforms that need to be done at the source which is the legislature that controls not only the basic law but the oversight committee called the Joint Congressional Power Committee (JCPC).

Despite the broken system and the obvious need and uproar to rectify the Epira law, the Senate is unsympathetic to consumers flight and instead has clearly taken the position to retain the law, warts and all, and “allow it time to work”, ( yes after 15 years?!) which not coincidentally is the same song being sang by the PIPPA which has been dominated by the distributor-generator conglomerates.

There has not even been any deep debate on the law and any protestations on behalf of the consumers at the podium of the Senate by well -meaning but out-matched junior Senators, have been bullied and brushed off by the resident reactionary forces. The same forces who dominated the bicameral committee that finalized the Epira Law in June 2001.

The electric consumers badly need someone in the Senate to argue for them, to change laws to improve safeguards for consumers, to assure true competition in the power industry, to assure the long term of power supply for the country. Someone who can explain to his colleagues in clear and lucid terms the reforms that need to be undertaken. No grandstanding and no smokescreen.

It is not enough for the Peoples Champion to have the patriotism and the sincere desire. The electric consumers need a Senator who has proven intellectual depth, ready knowledge of the intricacies of the energy sector, and the demonstrated moral grounding and courage to stand up to the vested interests. Someone who has the financial and moral wherewithal to resist the tempting offers from the vested interests when they come calling for the reforms to be called off. Someone who will not sell down the people as we have seen many times in those who pretended to speak for the people only to disappear at crunch time.

There has not been any Senatorial candidate who fits such a bill for a long time. In this coming election there is one in the person of Carlos Jericho Petilla, the former DOE Secretary who presided over the Department in a very tumultuous period specially in the system breakdown of December 2013 when the wholesale electricity spot market failed the people and caused a 100% jump in the generation charge in that month.

Fondly called “Icot” in his home province of Leyte where he was a three term Governor, Petilla has demonstrated the kind of intellectual depth needed to deal with the intricacies of the sector and the games players play, the obvious power sector experience, the ready knowledge of what ails the sector, the innovative thinking in search of solutions, and equally important the courage and conviction to stand up for what is right for the people.

Ironically, not enough electric consumers are aware of Petilla’s career defining moment as Energy Secretary when he passed a bold rule requiring the mandatory subjecting of the power supply contracts to competitive bidding or selection process, obviously upsetting the distributor-generator conglomerates who had been negotiating their sweetheart deals with sister generators and passing on the cost to the consumers. This is huge for the consumers because it will open the generation market to more truly independent generators and reap the benefits of “least cost power” through robust competition.

Petilla in the Senate will contribute tremendously to the better understanding by the Senate and its energy committee of the failures of the power sector and the logic of proposed solutions. They will not easily be misled and snowed by the allies of the vested interests. Solutions can be identified and passed into law much faster.

“Luzonites” knock him for “failing to deliver on his promised repair timetable of the typhoon ravaged Leyte”. Petilla can be faulted for underestimating the challenge of repairing the downed power lines. But his willingness to be accountable for the “failure” to finish as he promised is admirable and rare. He offered his resignation to the President. That’s the kind of upright character we need from our public servants. The willingness to be accountable and take responsibility.

Petilla is a real deal and someone the electric consumers have been direly needing in the legislature. Someone who can enunciate the deep issues on behalf of the electric consumers and eloquently argue for the urgently needed reforms and solutions.

Let us hope enough electric consumers in the Meralco area recognize this rare opportunity to put someone of his caliber for quality representation in the Senate.

Electric Consumers must vote Carlos Jericho “Icot” Petilla to the Senate.

Matuwid na Singil sa Kuryente Consumer Alliance Inc.

Update on CSP Front!

David Celestra Tan, MSK

Consumers were overjoyed when the DOE and then later the ERC passed the rules requiring the bidding or competitive selection process (CSP) for the contracting of power supply. Meralco decided not to obstruct the pro-consumer policy by threatened challenge of it’slegality. So how has it been in the implementation?

Now six months after the DOE passed this bold policy and 2 months after the ERC finally released their own enabling regulatory rule that was supposed issued in October 2015, both the Meralco and Aboitiz groups have announced competitive biddings for the interim and short term power supply for the summer of 2016 with one year power reserve contracts.

These gesture biddings have been expected and but we remain wary that these are designed to demonstrate that they are following the CSP policy and that requiring that Third Parties administer the CSP would not be really necessary.

It will be in the contracting for the plum power supply, the long term base-load contracts, where we can really see whether these two distributor-generator giants are willing to comply not only with the words but the spirit of the CSP idea that is supposed to open the generation market and cause true competition. Meralco still has 2,000mw to go in their announced goal of 3,000mw for their sister company Meralco PowerGen. The 460mw Mauban coal expansion and the 600mw Redondo Power in Subic appear to have beaten the CSP requirement.

Who will seriously participate in these tenders if it is Meralco and Aboitiz themselves conducting the bidding where their own affiliated generators are going to participate. Who really takes seriously swiss challenge type biddings that everyone in the business knows is just a pseudo bidding designed to favor the original “proponent”. It takes a lot of time and resources to prepare serious bids for a multi billion power project. Who would bother if they know the bid committee is a sister company of the one of the bidders. Who bothers with bidding for swiss challenge type tenders?

It will take time for the truly independent power generation investors to believe in the honest to goodness conduct of the CSP before we can see a robust and true competition that can bring down rates. It is not going to happen with mixed signals from the government agencies, specially DOE and ERC, on their resoluteness to truly open the generation market and create competition.

The DOE seemed serious about the words and spirit of its Resolution 2015-06-0008 that mandated CSP. Secretary Zenaida Monsada announced that they will conduct CSP’s for new renewable energy projects, something MSK had been espousing. With so many investors interested in Solar and Wind, why not auction it off to the lowest offered rates and minimize FIT subsidies? With true CSP, solar should come down to P7.00 to 7.30 per kwh instead of the current FIT of P8.69 per kwh, a likely 20% reduction.

Talking about the CSP, the DOE needs to improve its own implementation of the CSP rule for missionary areas where its Electric Power Industry Management Board had been issuing certifications that an electric coop had conducted a CSP without really caring whether the CSP was truly competitive. This had caused the award of sweetheart deals and clearly blatant CSP trickery that were overpriced and huge losses to the government. One such CSP had the winner bidding P9.38 per kwh only to be awarded the contract for P12.80 per kwh. That’s a loss of P175 million per year to the government who by the way passes the subsidy on to the people as part of the universal charge being assessed by the National Power Corp.

The same thing cannot be said of the ERC with it’s unexplainable position not to require that the CSP be administered by Third Parties, an essential to assure a level playing field, transparent bidding process, and judicious evaluation and award. This anemic posture is actually very disheartening to see in the country’s regulatory agency. Unless there is an enlightened change in ERC’s resolve in assuring a truly competitive bidding, we would be seeing another let down of consumer hopes in the numbing pattern of the Epira Law of 2001, its implementing rules of 2003, and now the supposed mandated CSP.

Implementation continue to bedevil the consumers. Meralco’s and Aboitiz gesture biddings are the equivalent of head-fakes in basketball. What a front for true CSPs.

Matuwid na Singil sa Kuryente Consumer Alliances Inc.