Consultation Prior to December 2010

Expert Reports

22/12/2010 (9 documents)

Dr Michael Pollitt Review of Proposed Input Methodologies December 2010 PDF (300 KB)
Professor Martin Cave Review of Proposed Input Methodologies 13 December 2010 PDF (49 KB)
Dr John Small Input Methodologies Comments on CEG Memo of 16 November 23 November 2010 PDF (123 KB)
Dr John Small Review of Proposed Input Methodologies 14 December 2010 PDF (239 KB)
Dr Martin Lally Comments on Input Methodologies Draft Reasons 3 September 2010 PDF (82 KB)
Dr Martin Lally Input Methodologies Review of Guthrie Measurement Error 13 September 2010 PDF (57 KB)
Professor George Yarrow Input Methodologies Comments on CEG Memo of 16 November 14 December 2010 PDF (112 KB)
Professor George Yarrow Review of Proposed Input Methodologies 14 December 2010 PDF (208 KB)
Input Methodologies Review of Submissions on Asset Valuation in Workably Competitive Markets November 2010 PDF (185 KB)

Technical Consultation - Correspondence

24/12/2010 (38 documents)

BARNZ Request to alter deadline for Input Methodology Determination 05 October 2010 PDF (20 KB)
Commerce Commission Input Methodologies Letter to Infratil 1 Nov 2010 PDF (97 KB)
Commerce Commission Input Methodologies Mark Berry letter to BARNZ 8 Oct 2010 PDF (160 KB)
Commerce Commission Input Methodologies Mark Berry letter to NZ Airports Association 8 Oct 2010 PDF (180 KB)
Commission Letter to Vector re Input Methodologies Submissions 19 November 2010 PDF (251 KB)
Commission response to Vector re Input Methodologies Release of Final Experts Reports 25 November 2010 PDF (135 KB)
Commission Response to Vectors Input Methodologies letter of 24 November 2010 Chair to Mr Carvell 30 November 2010 PDF (265 KB)
Commissions Letter to Transpower re WACC submission re Input Methodologies 2 December 2010 PDF (191 KB)
Commissions Response to Transpower letter of 3 December on Input Methodologies submissions 9 December 2010 PDF (95 KB)
Commissions Response to Unison letter of 7 December re Input Methodologies Consultation Process 9 December 2010 PDF (134 KB)
Commissions response to Vector letter of 26 November on input methodologies gas transmission 2 Dec 2010 PDF (78 KB)
Commissions response to Vector letter of 26 November on input methodologies rules and processes 2 Dec 2010 PDF (71 KB)
Commissions Response to Vector letter of 3 December on Input Methodologies submissions 9 December 2010 PDF (106 KB)
Letter to Vector re Input Methodologies expert reports 15 December 2010 PDF (183 KB)
NZAA Request for extension on Input Methodologies Update Paper Submissions 05 October 2010 PDF (30 KB)
Orion Input Methodologies Request for clarification 1 8 November 2010 Microsoft Word Document (58 KB)
Orion Input Methodologies Request for clarification 2 8 November 2010 Microsoft Word Document (61 KB)
Powerco Input Methodologies Draft Determination Request for clarification 29 Oct 2010 Microsoft Word Document (57 KB)
Technical Consultation on Input Methodologies Revised Draft Determinations Commission Responses 12 Nov 2010 Microsoft Excel Spreadsheet (38 KB)
Technical consultation on Input Methodologies revised draft determinations Commission responses Microsoft Excel Spreadsheet (27 KB)
Technical consultation on Input Methodologies revised draft determinations Request for clarification Oct 2010 Microsoft Word Document (56 KB)
Technical consultation on revised Input Methodologies draft determinations Commission responses 29 Oct 2010 Microsoft Excel Spreadsheet (20 KB)
Transpowers Response to Commissions letter on Submissions on Input Methodologies Revised Draft Determination and Consultation Update Paper 2 December 2010 PDF (120 KB)
Unisons Letter re Input Methodologies Consultation Process 7 December 2010 PDF (131 KB)
Vector Letter re Input Methodologies Consultation Process 2 November 2010 PDF (940 KB)
Vector letter to Commission Chair re input methodologies gas transmission issues 26 November 2010 PDF (112 KB)
Vector letter to Commission Chair re Input Methodologies Rules and Process for DPP 26 November 2010 PDF (130 KB)
Vector Letter to Dr Mark Berry re Evidence Input Methodologies 25 November 2010 PDF (147 KB)
Vector Letter to Dr Mark Berry re Experts Reports Input Methodologies 23 November 2010 PDF (147 KB)
Vector letter to Dr Mark Berry re release of CCs Input Methodologies final expert reports 9 December 2010 PDF (118 KB)
Commerce Commission Letter to Vector re Input Methodology Consultation Process 12 November 2010 PDF (665 KB)
Vector Request for clarification Input Methodologies 8 November 2010 Microsoft Word Document (58 KB)
Vector Request for Clarification Input Methodologies GPBs asset beta 12 November 2010 Microsoft Word Document (60 KB)
Vectors Letter to Dr Mark Berry re Input Methodologies Expert Reports and Evidence 3 December 2010 PDF (143 KB)
Letter to Vector 23 December 2010 response to letter of 21 December Input Methodologies PDF (73 KB)
Commerce Commission response to Vector letter of 26 November on input methodologies gas transmission 2 December 2010 PDF (81 KB)
Commerce Commission response to Vector letter of 26 November on Input Methodologies Rules and Processes 2 December 2010 PDF (75 KB)
Vector letter to Commission Chair re Input Methodologies Gas Transmission Issues 26 November 2010 PDF (119 KB)

Submissions on the Regulatory Provisions of the Commerce Act

16/02/2009 (40 documents)

Air New Zealand - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (1.6 MB): Air New Zealand (Air NZ) welcomes this opportunity to submit its views on the New Zealand Commerce Commission's (NZCC) Discussion Paper 'Regulatory Provisions of the Commerce Act 1986' dated 19 December 2008 which sets out the NZCC's views on what the regulatory provisions contained in the recently enacted revised Part 4 of the Commerce Act 1986 mean.
Auckland Airport -Submission on the Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (208 KB): Auckland Airport makes this submission to the Commerce Commission ("Commission") in response to the Regulatory Provisions of the Commerce Act 1986 Discussion Paper ("Discussion Paper") dated 19 December 2008.
Air New Zealand - Cost Allocation Methodologies For Aeronautical Services PDF (153 KB): Air New Zealand (AirNZ) has asked Frontier Economics (Frontier) for its opinion on an issue that will form part of AirNZ's submissions to the Commerce Commission on the appropriate setting of aeronautical charges in New Zealand.

This issue is the appropriate cost allocation methodologies where airports have common costs across both aeronautical and non-aeronautical businesses.
Auckland Energy Consumer Trust - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (88 KB): The Commerce Commission (Commission) has published a Discussion Paper1 setting out its preliminary views on the new regulatory provisions of the Commerce Act 19862 (the Act).

By way of general comment AECT does not consider that key areas in the Discussion Paper properly reflect the intent of the new provisions of the Act. The four key areas, which are discussed in greater detail below, are:
Auckland Chamber of Commerce - Submission on Commerce Commission Release Number 79: Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (114 KB): The Auckland Regional Chamber of Commerce and Industry welcomes the opportunity provided to make a submission on the Regulatory Provisions of the Commerce Act 1986 discussion paper issued by the Commerce Commission late last year.
Aurora Energy Limited - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (497 KB): The Commerce Commission has published a Discussion Paper setting out its preliminary views on the new regulatory control provisions of the Commerce Act 1986. Aurora welcomes the Commission's Discussion Paper, and has prepared this submission in response to the Commission's invitation for interested parties to comment on the Commission's views. In this submission, Aurora outlines the concerns that it has with the Commission's proposed interpre-tation and implementation of the new regulatory control principles.
BARNZ - Submission on Discussion Paper by Commerce Commission on Regulatory Provisions of the Commerce Act 1986 PDF (154 KB): BARNZ therefore believes it is well placed to be able to comment, from its first-hand experience, on issues related to the regulatory control provisions of the Commerce Act.
BARNZ - Do the Airport Authorities (Airport Companies Information Disclosure) Regulations Guard Against the Possibility of Monopoly Pricing? PDF (60 KB): With this purpose in mind, BARNZ members have examined the Airport Authorities (Airport Companies Information Disclosure) Regulations (Disclosure Regulations) with a view to determining whether or not sufficient information is provided to enable airline users and the travelling public to determine whether charges are economically efficient or whether monopoly pricing is occurring.
BARNZ - NZIER Report: Regulatory framework principles - The Commerce Commission's discussion paper 'Regulatory provisions of the Commerce Act 1986' PDF (160 KB): On 19 December 2008, the Commission released the discussion paper Regulatory Provisions of the Commerce Act 1986. This discussion paper sets out the Commission's preliminary views on the new regulatory provisions introduced through the Commerce Amendment Act. The Commission is seeking submissions on this discussion paper from interested parties by 16 February 2009.
Business NZ - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (51 KB): Business New Zealand would like to take the opportunity to briefly comment on the Commerce Commission's publication of the Regulatory Provisions of the Commerce Act 1986 Discussion Paper.
Christchurch City Holdings - Submission on Commerce Commission discussion paper regarding regulatory provisions of Commerce Act as it relates to airports PDF (525 KB): This paper sets out the response of Christchurch City Holdings Limited (CCHL) to the discussion paper issued by the Commerce Commission on 19 December 2008. The submission relates solely to the references to the regulation of the three international airports.
Christchurch International Airport Limited - Response to Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (328 KB): This paper sets out the response of Christchurch International Airport Limited ("CIAL") to the discussion paper released by the Networks Performance Branch of the Commerce Commission on 19 December 2008 entitled Regulatory Provisions of the Commerce Act 1986 (the "Discussion Paper").
Contact Energy Limited - Submission to the Commerce Commission on its Regulatory Provisions of the Commerce Act 1986 Discussion Paper: PDF (87 KB): Contact Energy Limited ("Contact") welcomes the opportunity to provide feedback to the Commerce Commission ("CC") on its discussion paper on Regulatory Provisions of the Commerce Act 1986. Contact's answers to the CC's questions follow.
Counties Power - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (79 KB): This submission is made on behalf of Counties Power Limited ("CP"). CP is a long-established electricity distribution business, owned by the Counties Power Consumer Trust. CP is based in Pukekohe and serves Franklin District and part of Papakura District.
Eastland Network - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (420 KB): This submission is made on the discussion paper 'Regulatory Provisions of the Commerce Act 1986' on behalf of Eastland Network Ltd.
EECA - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (63 KB): We welcome the opportunity to comment on the Commerce Commission's discussion paper on regulatory provisions of the Commerce Act 1986. Our submission is concerned only with section 54Q of the Commerce Amendment Act 2008 which contains provisions on energy efficiency, demand side management and energy losses in relation to lines companies.
ENA - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (113 KB): This submission on the Commerce Commission's Discussion Paper1 is from the Electricity Networks Association (ENA), whose members are the 29 electricity distribution businesses (EDBs) in New Zealand. It covers the following topics:

o Introduction of the ENA Regulatory Working Group (RWG), which prepared
this submission.

o A desire to improve communications in both directions between the EDBs and the Commission in implementing Part 4, some suggestions as to how this might occur, and an offer to convene a workshop on service quality paths and on promoting incentives to invest in energy efficiency initiatives.

o Key success factors from our perspective for the implementation of Part 4.

o Contextual issues relevant to the implementation of Part 4.

o Responses to questions in the Discussion Paper.
GasNet Limited - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (3 MB): A revised regulatory regime for gas pipeline businesses (GPBs), electricity lines businesses (ELBs), and major international airports came into effect on 14 October 2008. The Commerce Commission (Commission) has released the following Discussion Paper setting out its preliminary views on the provisions of the new Part 4 of the Act:

Regulatory Provisions of the Commerce Act 1986, Discussion Paper, 19 December 2008
Grow Wellington - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (825 KB): Thank you for the opportunity to comment on the Commission's discussion paper.

Grow Wellington is the regional economic development agency charged with the delivery of economic aspects of the Wellington Regional Strategy.
International Air Transport Association - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (228 KB): This submission presents the response of International Air Transport Association (IATA). IATA's mission is to represent, lead and serve the airline industry and brings together 230 member airlines whose flights account for 93% of all international scheduled air traffic. IATA welcomes this opportunity to submit its comments to the New Zealand Commerce Commission's Discussion paper as part of its consultation process to develop the new regulatory regimes. IATA's comments are from an international perspective and are based on the requirements of, and practices in, international civil aviation. The views in this submission are applicable and limited to Airport Services only.
Major Electricity Users Group - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (49 KB): This is a submission by the Major Electricity Users' Group (MEUG) on the Commerce Commission discussion paper, "Regulatory Provisions of the Commerce Act 1986," dated 19th December 2008 (the "discussion paper").
Maui Development - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (1 MB): We write in response to the Commission's Regulatory Provisions of the Commerce Ac 1986 - Discussion Paper (the Discussion Paper). We congratulate the Commission on a clear and well written document. Maui Development Limited (MDL) would like to submit on a number of issues raised in the Discussion Part that impact on the operation of the Maui Pipeline.
Mighty River Power - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (354 KB): When forming views on the approach it should take to economic regulation under the revised Commerce Act 1986 provisions, the Commerce Commission should be mindful that it is not starting from a blank canvass. The decisions the Commerce Commission has made to date provide significant precedents which help provide certainty for regulated suppliers and potentially regulated suppliers. The Commerce Commission should be mindful of this given the purpose of the new input methodology requirements is to promote certainty. This does not mean, in setting the input methodologies or making future regulatory decisions, the Commerce Commission should be entirely bound by past decisions. What it does mean though is that the Commerce Commission should be explicitly clear about what any deviations are and the reasons for them.
New Zealand Airports Association - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (51 KB): The report makes the point that speed of delivery and flexibility are becoming as important as the direct costs of production. This places many New Zealand firms at a competitive disadvantage relative to firms that are closer to international markets. The provision of quality international links helps to attract and retain companies, people, and capital. Access to international markets is an important part of the competitive positioning of a country.
Council of The Chartered Institute of Logistics & Transport in NZ - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (26 KB): Submission withdrawn
New Zealand Council for Infrastructure Development - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (45 KB): The New Zealand Council for Infrastructure Development 1 wishes to make the following submission in respect of the Commerce Commission's implementation of the Commerce Amendment Act 2008. While individual member organisations will be responding on issues of specific relevance to them, NZCID wishes to make the following overarching comments in respect of the purpose of regulation as it affects infrastructure investment.
New Zealand Institute of Chartered Accountants - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (720 KB): We welcome the opportunity to comment on the Regulatory Provisions of the Commerce Act 1986 Discussion Paper ('Discussion Paper') and commend the Commerce Commission ('the Commission') for consulting on its high level understanding of the new regime before proceeding to implement if.
Orion - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (141 KB): Orion New Zealand Limited (Orion) welcomes this opportunity to make a
submission in response to the above discussion paper.
Powerco - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (196 KB): In this submission, Powerco addresses framework issues associated with the discussion document. As we note below, a number of questions posed by the discussion document are too sweeping and lacking in context to be meaningfully answered in the timeframe allowed by the Commission. However, in section F of this submission, we provide detailed comments on some of the Commission's specific questions.
PowerNet Limited - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (59 KB): This paper represents the views of PowerNet Limited (PowerNet) with respect to some of the issues raised in the Discussion Paper from an Electricity Distribution Business (EDB) perspective. It does not deal with issues specifically related to Gas Pipeline Businesses or Major International Airports. We have not attempted to answer all the questions in the Discussion Paper.
PricewaterhouseCoopers - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (505 KB): The Discussion Paper covers a broad range of issues pertaining to the new provision in the Commerce Act for the regulation of ELBs, GPBs and major international airports. It includes a number of questions for submitters. Our submission focuses on issues specific to the electricity lines sector, and most importantly electricity distribution services.
Roading New Zealand - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (853 KB): Thank you for the opportunity to comment on the Commerce Commission's above Discussion Paper. We support the purpose of this Paper which is aimed at safeguarding the long-term interest of consumers in markets where there is little or no competition, by promoting outcomes consistent with competition.
Transpower - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (162 KB): Transpower's submission focuses on the issues discussed in Chapter 8: Electricity Transmission Services. Appended to the submission are Transpower's responses to the questions posed in the Commission's report, focusing on the issues relevant to Transpower.
Unison - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (120 KB): Unison has commissioned CRA to provide a detailed response (the CRA Report) on a number of issues in respect of the Discussion Paper.

Unison has viewed a copy of the submission prepared by Electricity Networks Association (ENA), and supports the recommendations contained within that submission.
Unison Networks Ltd - CRA Report: Regulatory Provisions of the Commerce Act PDF (521 KB): Unison Networks has asked CRA International ("CRA") to prepare a submission in response to the Commerce Commission's Discussion Paper "Regulatory Provisions of the Commerce Act 1986" (the "Discussion Paper"). While Unison's interests obviously primarily lie with the regulation of electricity distribution, there is much to gain from the adoption of common principles across regulated industries.
Vector - Reponse to Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (463 KB): Vector notes that the purpose of the Discussion Paper is to set out preliminary views on the new Part 4 and that this paper is the first in a series. We are conscious that the new provisions of Part 4 require a substantial amount of work to be undertaken in a short period of time. However, Vector considers that early engagement with industry at a higher level of specificity then in the present Discussion Paper is essential to ensure that the process runs as efficiently as possible.
Waipa Networks - Letter Regarding Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (1.4 MB): Letter regarding submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper from Waipa Networks.
WEL Networks - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (42 KB): WEL Networks supports the submission being made by the Electricity Networks
Association in respect of the Regulatory Provisions of the Commerce Act 1986:
Discussion Paper, Commerce Commission, 19 December 2008.
Wellington Electricity - Response to Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (2 MB): Wellington Electricity welcomes the opportunity to engage with the Commerce Commission (Commission) as it sets about implementing the new regulatory provisions of the amended Commerce Act 1986 (Act). The release of the Regulatory Provisions of the Commerce Act 1986 Discussion Paper (Discussion Paper) begins what will be a critical consultation process over the coming months as the new arrangements are bedded in.
Wellington International Airport Ltd - Submission on Regulatory Provisions of the Commerce Act 1986 Discussion Paper PDF (619 KB): The submission is divided into two parts. Part A provides overarching comments on matters relevant to the Commission's need to avoid over-regulation of the three airports. Part B submits on issues contained in the Discussion Paper on a chapter by chapter basis. Responses to the questions contained in the Discussion Paper are provided in Section 6.

Regulatory Provisions of the Commerce Act - Discussion Paper

(1 documents)

Commerce Commission - Regulatory Provisions of the Commerce Act 1986 - Discussion Paper PDF (903 KB): This Discussion Paper sets out the Commerce Commission's preliminary views on the new regulatory provisions that have been introduced through the Commerce Amendment Act. It represents the first in a series of consultation documents that will be released by the Commission in order to develop the new regulatory regimes.

Consultation Prior to December 2010

Documents

Expert Reports

Technical Consultation - Correspondence

Transpower Technical Consultation - Submissions

Electricity Distribution Businesses and Gas Pipeline Businesses Technical Consultation - Submissions

Transpower - Technical Consultation Papers

GPBs - Technical Consultation Papers

Airports Technical Consultation - Submissions

EDBs - Technical Consultation Papers

Code of Conduct Compliance

Technical Consultation Input Methodologies- Correspondence

Airports - Technical Consultation Papers

Electricity Distribution Businesses and Gas Pipeline Businesses - Draft Determination and Reasons Paper - Cross Submissions

Individual Price Quality and Draft Reasons Paper for Transpower - Cross Submissions

Marked Up Copy of Draft Determinations - Submissions

Electricity Distribution Businesses and Gas Pipeline Businesses - Customised Price-Quality Path Submissions

Electricity Distribution Businesses and Gas Pipeline Businesses - Asset Valuation Submissions

Submissions on Input Methodologies Draft Determination for Transpower - Cost of Capital

Cost of Capital - Draft Decisions Submissions

Transpower - Cost of Capital Submissions

Transpower - Draft Decisions Submissions

Electricity Distribution Businesses - Draft Decisions Submissions

Gas Pipeline Businesses - Draft Decisions Submissions

Airports Draft Decisions - Cross Submissions

Airports Draft Decisions - Submissions

Transpower Draft Decisions

Gas Pipelines Draft Decisions

Electricity Distribution Draft Decisions

Airports Draft Decisions

Draft Decisions - Correspondence

Emerging Views Post-Workshop Correspondence

Draft Determination Notification

CPP Workshop - Informal Workshop Gas Opex/Capex/Demand Requirements

CPP Workshop - Transcripts

CPP Workshop Notifications and Commission Papers

CPP Workshop Presentations

CPP Workshop - Post-Workshop Submissions

CPP Workshop - Pre-Workshop Submissions

Electricity Distribution and Gas Pipelines Workshop - Transcripts

Electricity Distribution and Gas Pipelines Workshop - Notifications and Commission Papers

Electricity Distribution and Gas Pipelines Workshop - Opening Statements and Presentations

Electricity Distribution and Gas Pipelines Workshop - Post-Workshop Submissions

Electricity Distribution and Gas Pipelines Workshop - Pre-Workshop Submissions and Comments on Workshop Process

Airports Workshop - Transcripts

Airports Workshop - Notifications and Commission Papers

Airports Workshop - Opening Statements and Presentations

Airports Workshop - Post-Workshop Submissions

Airports Workshop - Pre-Workshop Submissions and Comments on Process

Tax Workshop - Transcript

Tax Workshop - Notifications and Commission Papers

Tax Workshop - Post-workshop Submissions

Tax Workshop - Pre-Workshop Submissions and Comments on Workshop Process

Emerging Views Papers - Consultation Documents

Update on Process to Determine Input Methodologies and Airports Information Disclosure Requirements

Input Methodologies Conference - Transcripts

Input Methodologies Discussion Paper - Notifications

Input Methodologies Discussion Paper - Post-Conference Cross Submissions

Input Methodologies Discussion Paper - Cross Submissions

Input Methodologies Discussion Paper - Submissions

Input Methodologies Discussion Paper - Consultation Papers

Submissions on the Regulatory Provisions of the Commerce Act

Regulatory Provisions of the Commerce Act - Discussion Paper

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