Chapter 202

2013 -- H 5803 SUBSTITUTE A

Enacted 07/11/13

 

A N A C T

RELATING TO PUBLIC UTILITIES AND CARRIERS - DISTRIBUTED GENERATION STANDARD CONTRACTS

          

     Introduced By: Representatives Handy, Ruggiero, Gallison, McNamara, and Carnevale

     Date Introduced: February 28, 2013

     

It is enacted by the General Assembly as follows:

 

     SECTION 1. Section 39-26.1-3 of the General Laws in Chapter 39-26.1 entitled "Long-

Term Contracting Standard for Renewable Energy" is hereby amended to read as follows:

 

     39-26.1-3. Long-term contract standard. -- (a) Beginning on or before July 1, 2010,

each electric distribution company shall be required to annually solicit proposals from renewable

energy developers and, provided commercially reasonable proposals have been received, enter

into long-term contracts with terms of up to fifteen (15) years for the purchase of capacity, energy

and attributes from newly developed renewable energy resources. Subject to commission

approval, the electric distribution company may enter into contracts for term lengths longer than

fifteen (15) years. Notwithstanding any other provisions of this chapter, on or before August 15,

2009, the electric distribution company shall solicit proposals for one newly developed renewable

energy resources project as required in section 39-26.1-7. Proposals for the sale of output from an

offshore wind project received under the provisions of this section shall be diligently and fully

considered without prejudice, regardless of the status of any proceedings under sections 39-26.1-7

or 39-26.1-8.

      (b) The timetable and method for solicitation and execution of such contracts shall be

proposed by the electric distribution company, and shall be subject to review and approval by the

commission prior to issuance by the company; provided that the timetable is reasonably designed

to result in the electric distribution company having the minimum long-term contract capacity

under contract within four (4) years of the date of the first solicitation; it is not necessary that the

projects associated with these contracts be operational within these four (4) years, as the

operational dates shall be specified in the contract. The electric distribution company shall,

subject to review and approval of the commission, select a reasonable method of soliciting

proposals from renewable energy developers, which shall include, at a minimum, an annual

public solicitation, but may also include individual negotiations. The solicitation process shall

permit a reasonable amount of negotiating discretion for the parties to engage in commercially

reasonable arms-length negotiations over final contract terms. Each long-term contract entered

into pursuant to this section shall contain a condition that it shall not be effective without

commission review and approval. The electric distribution company shall file such contract, along

with a justification for its decision, within a reasonable time after it has executed the contract

following a solicitation or negotiation. The commission shall hold public hearings to review the

contract within forty-five (45) days of the filing and issue a written order approving or rejecting

the contract within sixty (60) days of the filing; in rejecting a contract the commission may advise

the parties of the reason for the contract being rejected and direct the parties to attempt to address

the reasons for rejection in a revised contract within a specified period not to exceed ninety (90)

days. The commission shall approve the contract if it determines that: (1) the contract is

commercially reasonable; (2) the requirements for the annual solicitation have been met; and (3)

the contract is consistent with the purposes of this chapter. A report on each solicitation shall be

filed with the commission each year within a reasonable time after decisions are made by the

electric distribution company regarding the solicitation results, even if no contracts are executed

following the solicitation.

      (c) (1) No electric distribution company shall be obligated to enter into long-term

contracts for newly developed renewable energy resources on terms which the electric

distribution company reasonably believes to be commercially unreasonable; provided, however, if

there is a dispute about whether these terms are commercially unreasonable, the commission shall

make the final determination after an evidentiary hearing. The electric distribution company shall

not be obligated to enter into long-term contracts pursuant to this section that would, in the

aggregate, exceed the minimum long-term contract capacity, but may do so voluntarily subject to

commission approval. As long as the electric distribution company has entered into long-term

contracts in compliance with this section, the electric distribution company shall not be required

by regulation or order to enter into power purchase contracts with renewable generation projects

for power, renewable energy certificates, or any other attributes with terms of more than three (3)

years in meeting its applicable annual renewable portfolio standard requirements set forth in

section 39-26-4 or pursuant to any other provision of the law.

      (2) Except as provided in section 39-26.1-7 and 39-26.1-8, an electric distribution

company shall not be required to enter into long-term contracts for newly developed renewable

energy resources that exceed the following four (4) five (5) year phased schedule:

      By December 30, 2010: Twenty-five percent (25%) of the minimum long-term contract

capacity;

      By December 30, 2011: Fifty percent (50%) of the minimum long-term contract

capacity;

      By December 30, 2012: Seventy-five percent (75%) of the minimum long-term contract

capacity;

      By December 30, 2013 2014: One hundred percent (100%) of the minimum long-term

contract capacity; but may do so earlier voluntarily, subject to commission approval.

      (d) Compliance with the long-term contract standard shall be demonstrated through

procurement pursuant to the provisions of a long-term contract of energy, capacity and attributes

reflected in NE-GIS certificates relating to generating units certified by the commission as using

newly developed renewable energy resources, as evidenced by reports issued by the NE-GIS

administrator and the terms of the contract; provided, however, that the NE-GIS certificates were

procured pursuant to the provisions of a long-term contract. The electric distribution company

also may purchase other attributes from the generator as part of the long-term contract.

      (e) After the adoption of the rules and regulations promulgated by the commission

pursuant to this chapter, an electric distribution company may, at its sole election, immediately

and from time to time, procure additional commercially reasonable long-term contracts for newly

developed renewable energy resources on an earlier timetable or above the minimum long-term

contract capacity, subject to commission approval.

 

     SECTION 2. Sections 39-26.2-3, 39-26.2-4, 39-26.2-6, 39-26.2-7, 39-26.2-8 and 39-

26.2-12 of the General Laws in Chapter 39-26.2 entitled "Distributed Generation Standard

Contracts" are hereby amended to read as follows:

 

     39-26.2-3. Definitions. -- When used in this chapter, the following terms shall have the

following meanings:

      (1) "Annual target" means the target for total renewable energy nameplate capacity of

new distributed generation standard contracts set out in section 39-26.2-3.

      (2) "Commission" means the Rhode Island public utilities commission.

      (3) "Board" shall mean the distributed generation standard contract board established

pursuant to the provisions of chapter 39-26.2-9, or the office of energy resources. Until such time

as the board is duly constituted, the office of energy resources shall serve as the board with the

same powers and duties pursuant to this chapter.

      (4) "Distributed generation contract capacity" means ten percent (10%) of an electric

distribution company's minimum long-term contract capacity under the long-term contracting

standard for renewable energy in section 39-26.1-2, inclusive of solar capacity. The distributed

generation contract capacity shall be reserved for acquisition by the electric distribution company

through standard contracts pursuant to the provisions of this chapter.

      (5) "Distributed generation facility" means an electrical generation facility that is a

newly developed renewable energy resource as defined in section 39-26.1-2, located in the

electric distribution company's load zone with a nameplate capacity no greater than five

megawatts (5 MW), using eligible renewable energy resources as defined by section 39-26-5,

including biogas created as a result of anaerobic digestion, but, specifically excluding all other

listed eligible biomass fuels, and connected to an electrical power system owned, controlled, or

operated by the electric distribution company.

      (6) "Distributed generation project" means a distinct installation of a distributed

generation facility. An installation will be considered distinct if it is installed in a different

geographical location and at a different time, or if it involves a different type of renewable energy

class.

      (7) "Electric distribution company" means a company defined in subdivision 39-1-2(12),

supplying standard offer service, last resort service, or any successor service to end-use

customers, but not including the Block Island Power Company or the Pascoag Utility District.

      (8) "Large distributed generation project" means a distributed generation project that has

a nameplate capacity that exceeds the size of a small distributed generation project in a given

year, but is no greater than five three megawatts (5 MW) (3 MW) nameplate capacity.

     (9) "Office" means the Rhode Island office of energy resources.

      (9)(10) "Program year" means a calendar year beginning January 1 and ending

December 31.

      (10)(11) "Renewable energy classes" means categories for different renewable energy

technologies using eligible renewable energy resources as defined by section 39-26-5. For each

program year, the board shall determine the renewable energy classes as are reasonably feasible

for use in meeting distributed generation objectives from renewable energy resources and are

consistent with the goal of meeting the annual target for the program year. For the program year

ending December 31, 2012, there shall be at least four (4) technology classes and at least two (2)

shall be for solar generation technology, and at least one shall be for wind. The board may add,

eliminate, or adjust renewable energy classes for each program year with public notice given at

least sixty (60) days previous to any renewable energy class change becoming effective. For each

program year, the board shall set renewable energy class targets for each class established. Class

targets are the total program-year target amounts of nameplate capacity reserved for standard

contracts for each renewable energy class. The sum of all the class targets shall equal the annual

target.

      (11)(12) "Renewable energy credit" means a New England Generation Information

System renewable energy certificate as defined in subdivision 39-26-2(15);

      (12)(13) "Small distributed generation project" means a distributed generation renewable

energy project that has a nameplate capacity no larger than within the following: Solar: fifty

kilowatts (50 KW) to five hundred kilowatts (500 KW); Wind: fifty kilowatts (50 KW) to one and

one-half megawatts (1.5 MW). For technologies other than solar and wind, the board shall set the

nameplate capacity size limits, but such limits may not exceed one megawatt. The board may

lower the nameplate capacity from year to year for any of these categories, but may not increase

the capacity beyond what is specified in this definition. In no case may a project developer be

allowed to segment a distributed generation project into smaller sized projects in order to fall

under this definition.

      (13)(14) "Standard contract" means a contract with a term of fifteen (15) years at a fixed

rate for the purchase of all capacity, energy, and attributes generated by a distributed generation

facility. A contract may have a different term if it is mutually agreed to by the seller and the

electric distribution company and it is approved by the commission. The terms of the standard

contract for each program year and for each renewable energy class shall be set pursuant to the

provisions of this chapter.

      (14)(15) "Standard contract ceiling price" means the standard contract price for the

output of a distributed generation facility which price is approved annually for each renewable

energy class pursuant to the procedure established in this chapter, for the purchase of energy,

capacity, renewable energy certificates, and all other environmental attributes and market

products that are available or may become available from the distributed generation facility.

 

     39-26.2-4. Standard contracts -- Annual targets. -- (a) To the extent eligible projects

are available and submit conforming applications, an electric distribution company shall enter

into standard contracts for an aggregate nameplate capacity of at least forty megawatts (40 MW)

of distributed generation projects by the end of 2014, unless such schedule is extended by the

board. The contracting shall be spread over four (4) years, based on the annual targets, aggregated

to reflect annual targets from prior program years, contained in the following four (4) year phased

schedule, unless such schedule is adjusted by the board in any given year:

      (1) By December 30, 2011: a minimum of five megawatts (5 MW) nameplate;

      (2) By December 30, 2012: a minimum aggregate of twenty megawatts (20 MW)

nameplate;

      (3) By December 30, 2013: a minimum aggregate of thirty megawatts (30 MW)

nameplate;

      (4) By December 30, 2014: a minimum aggregate of forty megawatts (40 MW)

nameplate.

      (b) By October 15, 2011 and each calendar year following until October 15, 2013, the

board may recommend to the commission that the annual target for the following program year

be adjusted upward to reflect any shortfalls in meeting the previous program year's annual target

or to reflect any standard contracts entered into during prior program years that are voided. The

board may also recommend to the commission that the annual target for the following program

year be adjusted downward by any amounts that the previous program year's annual targets were

exceeded by the standard contracts entered into during that program year.

      (c) The board may, based on market data and other information available to it including

pricing for standard contracts received during previous program years, recommend a reduction of

the annual target for the upcoming program year where the board determines that market

conditions would be likely to produce unfavorably high target pricing for standard contracts

during that upcoming program year. In considering such issues, the board may take into account

the reasonableness of current pricing and its impact on all electric distribution customers who will

be paying for the output for up to twenty (20) years at such prices. The board may also

recommend and the commission shall authorize an extension of time to achieve the forty

megawatt (40 MW) target targets, to allow for contracting to occur after 2014, if necessary.

      (d) The electric distribution company must contract for at least forty megawatts (40

MW) of nameplate capacity distributed generation projects by the end of 2014, unless such

schedule is extended by the board. The electric distribution company may not be required to

contract for more than forty megawatts (40 MW) or the distributed generation contract capacity,

but may do so voluntarily, subject to commission approval.

      (e) Each year, the board shall file its recommendations relating to the schedule, along

with its report and recommendations regarding ceiling prices, for the commission's review and

approval as specified in subsection 39-26.2-5(b).

      (f) Nothing in this chapter shall derogate from the statutory authority of the commission

or the division, including, but not limited to, the authority to protect ratepayers from unreasonable

rates.

 

     39-26.2-6. Standard contract enrollment program. -- (a) Each electric distribution

company shall conduct at least three (3) standard contract enrollments during each program year;

however, during 2011 the electric distribution company need only conduct one enrollment. Each

enrollment shall be open for a two (2) week period during which the electric distribution

company is required to receive standard short-form applications requesting standard contracts for

distributed generation energy projects. The short-form applications shall require the applicant to

provide the project owner's identity and the project's proposed location, nameplate capacity, and

renewable energy class and allow for additional information relative to the permitting, financial

feasibility, ability to build, and timing for deployment of the proposed projects. For small

distributed generation projects, the applicant must submit an affidavit confirming that the project

is not a segment of a larger project being planned for enlargement over time. For large distributed

generation projects, the short-form application shall also require the applicant to bid a bundled

price for the sale of the energy, capacity, renewable energy certificates, and all other

environmental attributes and market products that are available or may become available from the

distributed generation facility, on a per kilowatt-hour basis for the output of the project. Subject

to the provisions of subsections (b) and (c) below, the electric distribution company shall not be

required to enter into standard contracts in excess of the annual target for the applicable program

year and shall not be required to enter into standard contracts in excess of any limit set by the

board and approved by the commission for a given enrollment. However, the electric distribution

company may voluntarily exceed an enrollment period limit as long as it does not exceed an

annual target for the applicable program year.

      (b) For small distributed generation projects, the electric distribution company on a first-

come, first-served basis, shall enter into standard contracts at the applicable standard contract

ceiling price shall select projects for standard contracts based on the lowest proposal prices

received with any distributed generation project which meets the requirements of all applicable

tariffs and regulations, and meets the criteria of a renewable energy class in effect, until the class

target is met. Enrollment periods will be governed by a solicitation and enrollment process rules

that shall be filed with the commission each October 15 by the electric distribution company, and

approved by the commission within sixty (60) days of such filing.

      (c) For large distributed generation projects, the electric distribution company shall

select projects for standard contracts based on the lowest proposed prices received, but not to

exceed the applicable standard contract ceiling price, provided, that the selected projects meet the

requirements of all applicable tariffs and regulations and meet the criteria of a renewable energy

class in effect until the class target is met. Except for 2011, no enrollment period shall seek to

enroll more than one-third (1/3) of the annual goal for the distribution company for large

distributed generation projects.

      (d) If there are more projects than what is specified for a class target at the same price,

the electric distribution company shall review the applications submitted and select first those

projects that appear to be the furthest along in development and likely to be deployed in

consultation with the office. Those projects that are likely to be deployed on the earliest timelines

shall be selected. To the extent the electric distribution company is unable to make a clear

distinction on this basis, the electric company shall report the results to the board and not enter

into contracts with those projects that are tied on pricing. In such case, the board may take such

action as it deems appropriate for the selection of projects, including seeking more information

from the projects. Alternatively, the board may consider adjustments to the ceiling price and a

rebid, or simply wait until the next enrollment.

     (e) Should an electric distribution company determine that it has entered into sufficient

standard contracts to achieve a program-year class target, it shall immediately report this to the

board, the office of energy resources, and the commission, and cease entering into standard

contracts for that renewable energy class for the remainder of the program year. An electric

distribution company may exceed the renewable energy class target if the last standard contract

entered into may cause the total purchased to exceed the target. The office and the electric

distribution company shall enter into a memorandum of understanding regarding the sharing of

the information and data related to the distributed generation program.

      (f) The electric distribution company is authorized to enter into standard contracts up to

the applicable ceiling price. As long as the terms of the standard contract are materially the same

as the standard contract terms approved by the commission and the pricing is no higher than the

applicable ceiling price, such contracts shall be deemed prudent and approved by the commission

for purposes of recovering the costs in rates.

      (g) A distributed generation project that also is being employed by a customer for net

metering purposes may submit an application to sell the excess output from its distributed

generation project. In such case, however, at the election of the self-generator all of the renewable

energy certificates and environmental attributes pertaining to the energy consumed on site may be

sold to the electric distribution company on a month-to-month basis outside of the terms of the

standard contract. In such case, the portion of the renewable energy certificates that pertain to the

energy consumed on site during the net metering billing period shall be priced at the average

market price of renewable energy certificates, which may be determined by using the price of

renewable energy certificates purchased or sold by the electric distribution company.

 

     39-26.2-7. Standard contract -- Form and provisions. -- The following process shall be

implemented to establish the non-price terms and conditions of the standard contract:

      (1) A working group ("contract working group") shall be established and supervised by

the board, consisting of the following members: (i) The director of the office of energy resources;

(ii) A designee from the division of public utilities and carriers; (iii) Two (2) designees of the

electric distribution company; (iv) Two (2) individuals designated by the office of energy

resources who are experienced developers of renewable generation projects; (v) One individual

designated by the office of energy resources who represents a customer of the electric distribution

company; and (vi) A lawyer designated by the office of energy resources who has at least three

(3) years of experience in negotiating and/or developing power purchase agreements. With

respect to the lawyer designated in (vi) above, the electric distribution company shall enter into a

cost reimbursement agreement with such lawyer, to compensate the lawyer for the time spent

serving in the contract working group at the reasonable hourly rate negotiated by the office of

energy resources. The costs incurred by the electric distribution company under the

reimbursement agreement shall be recovered in rates by the electric distribution company in the

year incurred or the year following incurrence through an appropriate filing with the commission.

The contract working group shall be an advisory group that is not to be considered to be an

agency for purposes of the administrative procedures act or any other laws pertaining to public

bodies.

      (2) The contract working group shall work in good faith to develop standard contracts

that would be applicable for various technologies for both small and large distributed generation

projects. The standard contracts should balance the need for the project to obtain financing

against the need for the distribution company to protect itself and its distribution customers

against unreasonable risks. The standard contract should be developed from contracting terms

typically utilized in the wholesale power industry, taking into account the size of each project and

the technology. The standard contracts shall provide for the purchase of energy, capacity,

renewable energy certificates, and all other environmental attributes and market products that are

available or may become available from the distributed generation facility. However, the electric

distribution company shall retain the right to separate out pricing for each market product under

the contracts for administrative and accounting purposes to avoid any detrimental accounting

effects or for administrative convenience, provided that such accounting as specified in the

contract does not affect the price and financial benefits to the seller as a seller of a bundled

product. The standard contract also shall:

      (i) Hold the distributed generation facility owner liable for the cost of interconnection

from the distributed generation facility to the interconnect point with the distribution system, and

for any upgrades to the existing distributed generation system that may be required by the electric

distribution company. However, a distributed generation facility owner may appeal to the

commission to reduce any required system upgrade costs to the extent such upgrades can be

shown to benefit other customers of the electric distribution company and the balance of such

costs shall be included in rates by the electric distribution company for recovery in the year

incurred or the year following incurrence;

      (ii) Require the distributed generation facility owner to make a performance guarantee

deposit to the electric distribution company of fifteen dollars ($15.00) for small distributed

generation projects or twenty-five dollars ($25.00) for large distributed generation projects for

every renewable energy certificate estimated to be generated per year under the contract, but at

least five hundred dollars ($500) and not more than seventy-five thousand dollars ($75,000), paid

at the time of contract execution;

      (iii) Require the electric distribution company to refund the performance guarantee

deposit on a pro-rated basis of renewable energy credits actually delivered by the distributed

generation facility over the course of the first year of the project's operation, paid quarterly;

      (iv) Provide that if the distributed generation facility has not generated ninety percent

(90%) of the output proposed in its enrollment application within eighteen (18) months after

execution of the contract, the contract is automatically voided shall be terminated and the

performance guarantee is shall be forfeited. An eligible small-scale hydropower distributed

generation facility that has not generated ninety percent (90%) of the output proposed in its

enrollment application within forty-eight (48) months after execution of the contract shall result

in the contract being terminated and the performance guarantee being forfeited. Any forfeited

performance guarantee deposits shall be credited to all distribution customers in rates and not

retained by the electric distribution company;

     (v) Provide for flexible payment schedules that may be negotiated between the buyer and

seller, but shall be no longer than quarterly if an agreement cannot be reached;

      (vi) Require that an electric meter which conforms with standard industry norms be

installed to measure the electrical energy output of the distributed generation facility, and require

a system or procedure by which the distributed generation facility owner shall demonstrate

creation of renewable energy credits, in a manner recognized and accounted for by the GIS; such

demonstration of renewable energy credit creation to be at the distributed generation facility

owner's expense. The electric distribution company may, at its discretion, offer to provide such a

renewable energy credit measurement and accounting system or procedure to the distributed

generation facility owner, and the distributed generation facility owner may, at its discretion, use

the electric distribution company's program, or use that of an independent third party, approved

by the commission, and the costs of such measurement and accounting are paid for by the

distributed generation facility owner.

     (vii) All distributed generation projects that have executed contracts will be required to

submit quarterly reports on the progress of the project to the distribution company and the office

of energy resources. Failure to submit these quarterly progress reports may result in the

termination of the contract.

      (3) If the contract working group reaches agreement on the terms of standard contracts,

the board shall file the contracts with the commission for approval. If there are any

disagreements, they shall be identified to the commission. The commission shall review the

standard contracts for conformance with the standards set forth in subsection (2). Should there be

any disputes, the commission shall issue an order resolving them. To the extent the commission

needs expert assistance to resolve any disagreements noted in the filing, the commission is

authorized to hire a consultant to assist it in the proceedings, the costs of which shall be recovered

from electric distribution customers pursuant to a uniform factor established by the commission

in rates for recovery by the electric distribution company in the year incurred or the year

following incurrence, as requested through a filing by the electric distribution company. The

commission shall issue an order approving standard forms of contract within sixty (60) days of

the filing.

 

     39-26.2-8. Standard contract -- Reporting. -- (a) After each enrollment during a

program year the electric distribution companies shall provide a report to the board, office of

energy resources, and the commission of the aggregate amount of project nameplate capacity that

was the subject of standard contracts entered into during that enrollment and the prices under

each of the standard contracts that were executed.

      (b) Each quarter of a program year, the electric distribution company shall provide an

accounting to office of energy resource, the board, and the commission of the total amount paid to

distributed generation facilities under standard contracts during that quarter, until the forty

megawatt (40 MW) target is met;

      (c) Until the forty megawatt (40 MW) target is met, the electric distribution company

shall submit preliminary reports to office of energy resources, the board, and the commission

indicating the number of standard contracts and total estimated annual generation, price, class,

and any other relevant information for the purposes of better specifying classes, targets, or

standard contract prices so as to achieve the purposes set forth in this chapter. Such reports shall

be submitted no later than sixty (60) days prior to the end of the calendar year.

     (d) The electric distribution company shall in consultation with the office utilize uniform

standard forms for evaluating project proposals and shall rank projects according to uniform

criteria.

     (e) At the end of each enrollment, the electric distribution company shall, upon request by

an applicant, provide said applicant with written feedback on the evaluation of said applicant's

project proposal.

 

     39-26.2-12. Powers and duties. (a) The board shall have the power to:

      (1) Develop and recommend to the public utilities commission for review and approval

ceiling prices for standard contracts under the distributed generation standard contracts;

      (2) Develop and recommend to the commission adjustments up or down to the annual

target for standard contracts for the following program year;

      (3) Monitor and evaluate performance under the distributed generation standard

contracts act, including an assessment of ratepayer impact and the project selection process, to be

submitted annually in a report to the governor and the general assembly as provided in subsection

39-26.2-12(b).

      (4) Participate in proceedings of the public utilities commission that pertain to the

purposes of the board.

      (5) In order to provide funding for the purposes of engaging consultants and professional

services as necessary and appropriate for the board to fulfill its duties and purposes, an allocation

of no less than fifty thousand dollars ($50,000) from unused portions of Regional Greenhouse

Gas Initiative ("RGGI") auction proceeds not dedicated to efficiency measures but to overhead

expenses shall be transmitted from the office of energy resources to the board.

     (b) On January 15 of each year the office of energy resources shall submit to the

governor, the president of the senate, and the speaker of the house of representatives, an annual

jobs, economic impact and environmental impact study on the distributed generation standard

contracts program. The study shall include, but not be limited to, environmental benefits,

including carbon emission reductions from the installations; economic impacts including, but not

limited to, direct and indirect jobs created; system reliability improvements; property and income

tax benefits; and ratepayer impacts including, but not limited to, hedges against general inflation

and fuel price volatility, short term price impacts, and wholesale price suppression.

 

     SECTION 3. This act shall take effect upon passage.

     

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LC01651/SUB A/2

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