The gist: Long considered the goose that laid the golden egg, Lafayette Utilities System, along with its sister entity, LUS Fiber, is now mired in political controversy heading into Saturday’s mayoral runoff between Carlee Alm-LaBar and Josh Guillory. Mayor-President Joel Robideaux has floated accusations of unlawful transactions between the systems, initiated leadership changes and launched an internal investigation, all of which have drawn suspicions of political motives.
The gist: For the first time in its history, Lafayette’s publicly owned utility opened its doors to public involvement in how it plans for the city’s power needs, a process called an integrated resource plan, or IRP. A big decision before LUS and its customer-owners: what to do with its coal-fired power plant.
We own a coal plant? Yes, you do. Well, technically you co-own it with CLECO. The plant, called Rodemacher 2, is located in central Louisiana and accounts for 265 megawatts of the LUS power portfolio. The plant was built in the 1980s and has taken on millions in upgrades to keep pace with regulatory changes.
“I think the unit will be converted to natural gas or retired,” LUS Power Manager Jeff Stewart said at a Tuesday public hearing to a crowd of two dozen attendees, including several renewable energy and environmental advocates who have criticized the system’s lack of public involvement and continued investment in its coal plan.
Consultants estimate $43 million in new upgrades are needed. The investment would update the aging coal plant to comply with federal environmental regulations governing water discharges and emissions. Michael Borgstadt of Burns and McDonnell, the consulting engineer guiding the IRP process, said new revisions to those rules were released in early November, which could affect the price tag. How much, exactly, is unknown, though he said costs shouldn’t vary greatly from those currently anticipated.
LUS still owes $50 million on compliance investments made in 2012. The system issued bonds to pay for upgrades on Rodemacher needed to comply with emission standards issued by the Obama administration. At the time, critics called for the system to be retired or converted to cleaner-burning natural gas. LUS opted to stick with coal, but natural gas prices bottomed out in the fracking boom. The system now faces more costs to keep the unit in compliance while natural gas prices remain historically cheap.
“We have an opportunity to make decisions that have a positive impact,” said Laura McColm, a Lafayette resident and LUS customer, at the Tuesday hearing. McColm, like other attendees, urged LUS and its consultants to consider the costs associated with pollution and be wary of making big, risky investments that cost ratepayers for years. By and large, participants were upbeat about the chance to give feedback and engaged in a lively discussion with Stewart and the consultants on hand.
A 2016 IRP resulted in plans to build new power generation that was later scuttled. LUS then took criticism for a lack of transparency in conducting the power plan — also led by Burns and McDonnell — which ultimately resulted in a $120 million plan to build new power supply powered by natural gas. Rates were raised 9% to pay for a $250 million bond sale that included the new power plants, but the City-Parish Council voted not to go forward with the plan.
With power planning, LUS is shooting at a moving target. Market conditions in the power industry are in turmoil because of constant regulatory changes, new technologies and shifting fuel costs. The Obama- era Clean Power Plan likely would have forced the retirement of the coal plant, Stewart tells me, but current rules have eased the pressure on coal plants broadly. Still, coal is on its way out.
“We’ve known for years that coal would be a target,” Stewart says. “[Rodemacher] could be a good retirement in terms of economics.”
What to watch for: More opportunities for public input. Stewart expects another hearing by spring of next year. LUS has made available other channels to give feedback on the IRP. The plan is set to wrap up by summer of next year. It will be up to LUS and the City Council — which is replacing the Lafayette Public Utilities Authority as LUS’s regulator — to decide what to do with the results. Ratepayers can submit feedback by email to IRPfeedback@lus.org. The deadline for public comment on this phase is December 15, 2019.
The gist: Changes to LUS and LUS Fiber leadership, announced suddenly the night before October’s primary, were said by the Robideaux administration to be tied to an ongoing internal review of transactions between the systems that was requested by the Louisiana Public Service Commission. PSC representatives, however, contradict that assertion — saying no such internal review was asked for, and the leadership change is not related to any request from the commission.
Get caught up, quickly. LUS and its sister company LUS Fiber have been under fire for a pair of potential violations of a state law that prohibits government dollars from propping up the municipal telecom. The most recent of the two, $8 million paid over eight years for a power outage monitoring system, was self-reported by Mayor-President Joel Robideaux in July. In a press release distributed Oct. 11, Robideaux announced he was removing LUS and Fiber’s interim directors, claiming the swap was made to “facilitate an internal review on behalf of the Public Service Commission” and linked the review to the power outage monitoring payments. Robideaux named his chief administrative officer, Lowell Duhon, to oversee LUS, and Kayla Miles, Fiber’s business administrator, as LUS Fiber’s interim director, replacing Jeff Stewart and Teles Fremin, respectively.
“Subsequent to the self-reports, the PSC requested that a more in-depth and internally unbiased review of all LUS Fiber inter-agency transactions be performed, necessitating the staff changes,” Robideaux wrote in his October press release, suggesting that the PSC itself had requested the leadership changes or supported the decision.
There is no written record of such requests from the PSC. Requests for management changes “would absolutely be in writing,” commission spokesman Colby Cook says. “We rarely make those kinds of recommendations. It’s a financial audit.”
PSC Executive Secretary Brandon Frey confirms the commission has not asked for an internal review of inter-agency transactions. “There is nothing pending on anything like that,” he says.
To date, the PSC has investigated only one self-reported violation from 2018. Robideaux’s July letter concerning the power outage monitoring system triggered no new review or request from the PSC, according to PSC staff. The last formal correspondence between the administration and the PSC was a June audit report concerning the 2018 discovery of payments from LUS to Fiber for services to sewer lift stations and some electric system components that were never connected. After a comprehensive review of inter-system transactions, the PSC found that besides the $1.7 million in sewer and electric payments paid out over several years, which Fiber reimbursed, the system was in compliance with state law and PSC rules, according to the report.
The June report raised concerns about having a single director run both Fiber and LUS. Longtime Director Terry Huval ran both LUS and LUS Fiber, an arrangement PSC staff wrote “may have weakened the strength of internal controls.” That concern was moot by the time the audit was concluded, as two different interim directors were already in place by the end of 2018.
Robideaux took widespread criticism for a bid to privatize management of LUS. The deal, first revealed by The Current in the spring of 2018, would have sold management rights to private equity firm Bernhard Capital Partners and at one time potentially included Fiber. Huval retired early from a previously announced decision to step down amid the controversy. The episode pitted Huval against his former boss, as the retired director publicly opposed the Bernhard deal. Later that fall, the City-Parish Council and the mayor-president agreed to divide LUS and Fiber into separate divisions. Robideaux appointed Stewart and Fremin to their interim posts, which they held without incident until October’s shakeup.
The self-reports have figured in political campaign materials. The Lafayette Parish Republican Executive Committee, whose Facebook page is run by Robideaux’s political consultant Joe Castille, used these transactions as a wedge issue against Councilman Bruce Conque, who lost his re-election bid to Andy Naquin, and mayor-president candidate Carlee Alm-LaBar.
(Disclosure: Alm-LaBar gave seed money to The Current in 2018; view our list of donors here.)
The administration has yet to officially respond to the June report from the PSC. Within a month of receiving the June audit, however, Robideaux claimed to have found the second potential violation of the act and said he hand-delivered a letter outlining those findings to the PSC, writing to the PSC that LUS may have made illegal payments totaling $8 million to LUS Fiber over an eight-year period. He actually hand-delivered the letter to Public Service Commissioner Craig Greene, when he visited the commissioner to discuss the June report.
“[Commissioner Greene] hasn’t had any more conversations other than when Mayor Robideaux had given us the letter, and we said we’ll get this to our staff. We gave no formal recommendation as to what they should do with [it],” says David Zito, Greene’s chief of staff. “None of the commissioners have approached us, and we have not approached any of the other commissioners about it.”
The legality of cross-subsidization between LUS and Fiber is regularly tested in annual attest audits, and interagency transactions are run through LCG’s finance department. In his letter, Robideaux, an accountant, took issue with the accounting method used to price the cost of power outage monitoring system, saying the approach likely violated state law. An audit conducted by LUS Fiber’s independent auditors in 2012 and a PSC audit for 2011 and 2012 did not take issue with the payment computations, which were based on the annual estimated savings from power outages. That means numerous oversight mechanisms, including Robideaux’s own administration, would have failed to detect any problems.
Robideaux has not asked the PSC to audit that issue, yet he references it as one of two self-reported findings to justify the leadership changes.
“We are committed to providing the most complete and unbiased report possible to the PSC, and the need for fresh sets of eyes is what prompted the naming of new interim directors at LUS and LUS Fiber,” LCG spokeswoman Cydra Wingerter writes in an emailed response to questions about the management changes sent this week. “The outcome of this in-depth, internal review will be formally provided to the PSC, and it is expected that a decision will be made as to whether the findings will be included in the initial self-report or taken up separately.”
Robideaux told commissioners in the July letter that Fiber’s annual attest audit began in May 2019 and would be filed with the commission by August. As of Tuesday, the attest audit had not been turned over to the PSC, its records show.
“There’s nothing pending at the commission involving the July letter,” says the PSC’s Frey. “I don’t think there’s been any request from them to open up an audit.”
The gist: Breaking the day before Saturday’s primary, Mayor-President Joel Robideaux removed interim directors for LUS and LUS Fiber, installing his chief administrative officer over the utilities system and elevating a longtime staffer within Fiber.
Get caught up, quickly. LUS and its sister company LUS Fiber have been under fire for a pair of potential violations of a state law that prohibits government dollars from propping up the municipal telecom. The most recent of the two, $8 million paid for a power outage monitoring system, was self-reported by the mayor-president in July. Last year, Robideaux put LUS and LUS Fiber under the authority of separate directors, following the exit of longtime Director Terry Huval, who retired early partially in protest of the mayor-president’s effort to sell management of LUS to Bernhard Capital Partners. Robideaux appointed Huval lieutenants Jeff Stewart (LUS) and Teles Fremin (LUS Fiber) as interim directors of the now independent divisions.
The shakeup was sudden. The directors and the Lafayette Public Utilities Authority, the council sub-agency that oversees LUS, were informed Friday afternoon, shortly before a press release was circulated announcing the decision.
Fremin and Stewart remain with LUS and Fiber. Robideaux temporarily put CAO Lowell Duhon in charge of LUS, and Fiber business administrator Kayla Miles over LUS Fiber, moving LCG Communications Director Cydra Wingerter to fill in for Duhon. Both civil service employees, Fremin and Stewart have returned to the positions held prior to their interim appointments.
Robideaux suggests the move was requested by the Public Service Commission. The PSC is a state agency that has limited regulatory authority over LUS Fiber, primarily for the purposes of enforcing a state fair competition law passed to protect incumbent telecoms when Fiber was created more than a decade ago. A press release sent out Friday claims the PSC requested an “internally unbiased” review of transactions between Fiber and other municipal agencies.
“It is important that we provide the PSC with assurance that this review process removes any internal bias that might be associated with long-term employees,” Robideaux says in the release. “The best way to accomplish that is with fresh sets of eyes.”
The PSC produced an audit in June. It was spurred by the 2018 discovery of $1.6 million in payments to Fiber for services that were never connected. Fiber reimbursed those payments before the PSC audit. The audit report went to an administrative judge in August. The judicial review is ongoing, and the PSC hasn’t taken action since July, when Robideaux self-reported more questionable payments.
Lagniappe. The Advertiser reported what it claims are more suspicious payments totaling $4 million over eight years. The report, published shortly after Robideaux’s press release, centers on charges for a set of communications hubs used by LUS, for which Fiber bills the utilities system $680 a month. It’s unclear whether the payments violate state law — Fiber is audited annually with transactions examined by LCG’s finance department — or if the administration intends to report them. The administration did not respond to requests for comment.
The gist: Flattening energy demand has taken a toll on LUS sales. While electric revenues are growing, they are falling short of budgeted projections each year. For the upcoming fiscal year, LUS cut $10 million from last year’s projected revenue, a belt-tightening figure when compared to historic estimates.
Electrical demand has been sluggish. And that accounts for most of the diminished outlook. In the proposed 2019/2020 budget, LUS projects $101 million in base rate revenue — retail sales, excluding fuel — on $253 million in revenues for the entire utilities system, including wastewater and water services. This year’s adopted budget, reflecting fiscal year 2019, projected $108 million in electric sales on $241 million in total utilities operating revenue.
LUS revenues missed on budget projections each of the last three years. While electric sales have increased year-over-year, they’ve fallen as much as $10 million short of estimated revenues in each of the last three budgets. To an extent, next year’s diminished projections hew closer to the system’s actual performance but still reflect an expectation of growth, albeit slower:
|Year||Total Projected||Total Actual||Elec. Sales Proj.||Elec. Sales Act.|
|2016||$240 million||$220 million||$92 million||$84 million|
|2017||$244 million||$225 million||$97 million||$87 million|
|2018||$246 million||$232 million||$107 million||$95 million|
|2019*||$253 million||n/a||$108 million||n/a|
|2020*||$241 million||n/a||$101 million||n/a|
*Only projected revenues are available.
Interim LUS Director Jeff Stewart says the trend is concerning, but notes the system is still adding customers. But these new customers, he says, are using less energy per person. That means diminishing returns as LUS grows its customer base through city annexations, franchise agreements with Broussard and Youngsville, and an acquisition deal with Slemco.
“We’re adding customers, but they’re more efficient customers,” Stewart tells me.
LUS raised electric rates in 2016. A 9% total increase was phased in over the last few years to pay for a $240 million bond package that included $120 million for a new natural gas power generator. The plan was scuttled after public pushback, and LUS reduced its bond request to $70 million, throwing out plans for the new generator. The rate increases have remained in place. LUS moved forward with work on new wastewater treatment facilities, sewer line upgrades in the urban core, and has submitted work orders to outfit 18,000 city lights with LEDs, a $7 million project.
Energy efficient appliances and consumer habits have taken a bite out of power company revenues nationwide. The U.S. Energy Information Agency forecasts that trend to continue, projecting flattened electricity demand decades into the foreseeable future
If you can’t sell more of it, what do you do? Stewart tells me LUS is exploring EV charging as a potential revenue stream. Air conditioners, he says, were the 20th century innovation that drove electric revenues. Some 10 million electric vehicles are expected to hit American streets by 2025, offering one consumer sector that could increase electric demand and, in turn, drive sales for power companies.
Why this matters: LUS has major upgrades in the not-so-distant future. Remember that whole business with Jim Bernhard? Paying for those upgrades was a big part of his sales pitch. Most of Lafayette’s power capacity comes from a coal plant, which is routinely on the cusp of regulatory shutdown, depending on who occupies the White House. (Most of the time, LUS buys the power you use in your house from a grid market.) Outside of the looming need for investing in power generation, the system is a capital-intensive enterprise. Historically, the electric system has subsidized water and wastewater operation. A budget crunch on the electric side presents a major challenge for the system’s long-term financial health and could even put its contribution to the city’s budget, roughly $23 million every year, at risk.
LUS Fiber has recently been accused of receiving millions in illegal subsidies from LUS. This is a complex issue with a lot at stake. An explainer is in order.
The gist: The Daily Advertiser broke a story late Monday that Lafayette Mayor-President Joel Robideaux has self-reported a second potential violation of state law regulating LUS Fiber. In his Monday letter to the Louisiana Public Service Commission, Robideaux claims LUS may have made illegal payments totaling $8 million to LUS Fiber over an eight-year period. If the PSC agrees, this could create a significant financial burden for LUS Fiber’s operations moving forward.
The gist: LUS will contract Burns & McDonnell to run its integrated resource plan, the process the utility uses to determine its future energy needs and how it will power them. The choice of consultant met immediate criticism among local green energy advocates. The contract is worth $500,000 and was approved Tuesday by the professional services committee.
Burns & Mac guided LUS on two controversial decisions. In 2011, the company recommended LUS continue burning coal in central Louisiana, instead of switching to natural gas, a decision critics maintain was a costly mistake in hindsight. And in 2016, LUS developed a $100 million plan to build new natural gas generators, at the consultant’s suggestion, even raising electric rates to finance the plan. That decision triggered a backlash that ultimately shelved the plan and in part led to last year’s privatization controversy.
“Half a million dollars is a lot of money,” renewable energy advocate Simon Mahan tells me. Mahan developed a lengthy document criticizing the 2016 plan but has since departed Lafayette. “To use the same firm that got it wrong twice before is eyebrow raising.”
Interim Director Jeff Stewart says this contract is different. The 2011 and 2016 plans did not involve robust public engagement, and Stewart says that engagement is baked into this upcoming process.
“That’s why we shelved [the 2016 plan],” Stewart tells me. “I want as many people who want to get involved to get involved.” He expects to time the public facing process to PlanLafayette activities, with outreach beginning in September.
LUS’s open approach seems to be working. Mahan tells me he believes that Burns & Mac is capable of delivering. And he gives a lot of credit to Stewart’s leadership style.
“Frankly, I’ve been really impressed with what he’s been saying and the actions he’s taken. There’s a new wind at LUS to listen to the public a little bit more,” Mahan says. “That makes me feel good.”
Fighting climate change takes a global effort — one that we are simply choosing not to participate in.
The gist: LUS is in the early stages of pursuing a pilot program to add electric vehicle charging stations to its portfolio and buy electric forklifts for its warehouse.
If funded, the pilot could put chargers at the Target shopping center on Louisiana Avenue but isn’t limited to that location. Interim LUS Director Jeff Stewart says work is very much preliminary and not related to surveys underway for a Tesla supercharger at the same site. LUS is also researching EV policies and approaches in major regional markets to write a local one.
LUS applied for funding through Louisiana’s allotment of VW’s settlement program, which is paying billions in atonement money for the German automaker’s use of software to cheat emission standards tests on its diesel fleet. As part of its settlement with the EPA, VW established a $2.9 billion trust to pay for programs that reduce diesel emissions. Louisiana received around $20 million from the trust. It’s that pot of money LUS is after for the pilot.
This is the second time LUS applied for the VW money. The utility’s first attempt at funding through the trust wasn’t successful. A second round was opened this year, according to Stewart, and last week LUS turned its application, which asks for more than $150,000 in grants.
LUS is at the beginning stages of a major power planning process called an integrated resource plan. Stewart says LUS has shortlisted four consultants to assist LUS on the IRP and will bring those candidates in for staff presentations in the coming weeks. He’s hoping to have a contract in place by June. A big part of the IRP is projecting the future of power demand, i.e. how much electricity the city will need, and how to meet the demand. Stewart has positioned this iteration of the process to be more public than previous go-rounds, saying in recent interviews that he wants the public to help create a vision for the future of the electric utility.
Meanwhile, automakers are investing billions in EV fleets. Lafayette has been criticized for lagging behind national (and even regional) adoption of EV infrastructure. Industry movement is now difficult to ignore. VW itself plans to spend $80 billion over the next five years developing EVs and outfitting them with batteries, according to The Economist, ultimately producing 20 million electric cars in the next decade.
Why this matters. EVs are only one disruption the utility industry faces. Bernhard Capital Partners criticized LUS’s lack of innovation and flexibility when the private equity firm pursued purchasing the right to manage the utility. LUS has been more proactive in the last couple of years exploring renewable energy and other disruptive technologies, contracting wind power from the midwest last year, but nevertheless has been cautious to dive into a fast-moving space.
The gist: Robideaux has about $43,000 in his war chest, according to The Advocate. At this point during his 2015 bid for office, he had $335,000. He’s widely seen as vulnerable to a challenge, a somewhat rare occurrence for an incumbent mayor in Lafayette.
Robideaux says he’s been working, not campaigning. Side-stepping the implication that he can’t get the taps flowing. Indeed, it is somewhat early to draw anything conclusive from the numbers. We’ll see another report soon, and Robideaux told The Advocate’s Claire Taylor he expects to raise the money he needs in short order.
“To my friends in the media, thanks for the advice. I’ll get right on it,” Robideaux replied in a clapback posted to his Facebook page. (Campaign staffers often post on his behalf; it’s unclear if Robideaux authored the statement himself.) The mayor-president has been in a spat with the media lately, freezing out reporters who have been hard on him. He pushed back at the “criticism” and spun it as proof positive of his efforts as mayor-president. “The simple fact is (and a lot of people don’t get this about me) — I’m not a politician at heart,” the statement reads.
Lack of money doesn’t necessarily indicate a lack of support, a local political operative tells me, rather a lack of campaigning. That backs up Robideaux’s defense. But the operative says it is indeed odd for an incumbent to have spent so little time fundraising. Articles like The Advocate’s, he says, raise reasonable questions of political strength. Put simply, whatever the reason, having no money in the bank shows a weakness that could tantalize opposition.
“He has not had an incident-free tenure,” UL political scientist Pearson Cross told The Advocate. He’s pointing out that Robideaux’s lack of ground game is odd given his recent controversies.
Saying his tenure is not “incident-free” is something of an understatement. In the last two years, Robideaux has found a way to alienate voters of all stripes. Progressives are angry about his escalation of the drama around Drag Queen Story Time and then trying to raid the library’s fund balance while accusing its directors of deception. Conservatives remain skeptical of CREATE, an initiative they characterize as a slush fund, and the cynical tactics Robideaux used to pass it. Outrage was community-wide upon discovery of his backchannel pursuit of privatizing management of LUS. Now his administration is mired in questions of ethics and transparency related to a suspect loan obtained by one of his aides.
In short, Robideaux has built a platform for his eventual challenger. And most believe he will draw one.
The gist: For the past year or so, LCG has honed policy for the dawn of 5G networks. Tired of waiting, Councilman Kenneth Boudreaux short-circuited the deliberation, introducing his own policy ahead of the administration’s schedule.
Stop. What’s 5G? A quick oversimplification: 5G is the next (fifth) generation of cellular networks projected to supplant 4G and LTE service in the coming years. 5G networks use dense clusters of small wireless transmitter boxes, attached to existing utility poles or mounted on short towers, to broadcast connections comparable to fiber speeds and reliability. Phones have not yet been developed to use 5G — AT&T’s 5G E is not 5G; it’s LTE plus marketing — but the event horizon is only a couple of years away. Cities are now grappling with policies to deal with fleets of transmitter boxes — i.e. “small wireless facilities” — in public rights of way. It’s progress, but also a nuisance.
Boudreaux compiled a policy to regulate deployment of 5G transmitters in the city and unincorporated areas of the parish. He introduced it as an ordinance, which governs “small wireless facilities,” at Tuesday’s City-Parish Council meeting. It defines things like fees and permitting and defines aesthetic restrictions. Over the past year or so, Boudreaux tells me, he talked with some of the major telecoms developing the technology — like Cox, Verizon and AT&T — but pulled from policies adopted in other Louisiana cities to craft his ordinance. His draft resembles one passed in Baton Rouge in 2017 and shares some of the same exact language. He says the administration should have acted a while ago.
He forced the administration to move. Boudreaux allowed LCG’s legal team to sub in its own draft ordinance as an amendment to his. The legal department and administration worked for the last year or so on the policy with a D.C. law firm specializing in communications. The administration’s draft policy is more detailed and applies stricter guidelines for how the boxes look and where they can be placed. Fees are different too: Boudreaux’s ordinance charges $270 annually per device to add them to city-owned utility poles; while the administration’s policy bills $220. You can view Boudreaux’s original ordinance here. And the administration’s ordinance here.
“My God, Crowley has adopted theirs already,” Boudreaux tells me. His decision to put forth an ordinance ahead of legal was spurred by watching small communities like Carencro adopt policies while Lafayette had yet to do so. (My family is from Crowley, for the record.) In pushing an ordinance, one he admits was not quite ready for prime time, Boudreaux intended to force a public conversation and position himself to lead it. “I gotta govern in a way other people don’t have to,” he explains. One primary concern, he expressed Tuesday night, is that poles could clutter the neighborhoods in his district. He showed the council a picture of a squat, unsightly tower pimpled with grey boxes in McComb-Veazey. It’s not clear where the tower came from. (Maybe it’s a ghost tower.)
Rapidly adopted policies have caused problems in other markets. Baton Rouge rushed an industry-friendly ordinance in July 2017 only to circle back to close loopholes later that year. Still, downtowners there fussed when AT&T began planting 80 5G towers, sometimes in the middle of sidewalks.
5G could pressure LUS Fiber. Some observers say the technology could one day challenge fiber-to-the-home internet service. 5G networks are cheaper to build in neighborhoods that don’t currently have fiber-to-the-home in place (like many of the areas Boudreaux represents) and can be used to add fixed internet service wirelessly. Others say it’s not likely to supplant fiber service altogether, but it could muscle fiber-based internet providers around in the market.
What to watch for: How the council approaches the policy discussion going forward. Boudreaux’s move appears to have pushed the administration into the conversation ahead of schedule, and the draft ordinance swapped in is now subject to council debate at final adoption in a couple of weeks. Other communities have haggled over how much to charge telecoms for the use of public space. Baton Rouge charges $250 per device. Other cities charge thousands. Money will play a big factor in the discussion here.