Date of Hearing: August 18, 2020

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Lorena Gonzalez, Chair

SBPCA Bill Id:SB 1291

Author:(Committee on Transportation) – As Amended Ver:April 3, 2020

Urgency: Yes State Mandated Local Program: No Reimbursable: No

SUMMARY:

This urgency measure eliminates two related transportation reporting requirements for the year 2020 only. Specifically, this bill eliminates the requirements that (1) the Department of Transportation (Caltrans) submit a Federal Statewide Transportation Improvement Program (FSTIP) to the United States Secretary of Transportation for 2020 and (2) a metropolitan planning organization or transportation planning agency submit a Federal Transportation Improvement Program (FTIP) to Caltrans for 2020.

FISCAL EFFECT:

No direct state costs.

Indirectly, elimination of the reporting requirements will allow millions of dollars in planned state and local transportation projects to go forward that otherwise would be delayed.

COMMENTS:

1. Purpose. According to the author:

This bill helps to ensure that transportation projects, and the associated safety benefits and jobs, can proceed despite the uncertainty created by the SAFE Vehicles Rule Part One and Two. Eliminating the state requirement that MPOs submit a [Federal Transportation Improvement Program (FTIP)] in 2020 enables projects consistent with the 2018 FTIP to proceed. MPOs would return to the regular two- year FTIP cycle no later than 2022.

1. Background.
2. FTIPs. Federal Transportation Improvement Programs, or FTIPS, are comprehensive regional spending plans consisting of proposed plans for major transportation projects over multiple years. Federal rules require an FTIP to include all federally funded projects in a region, and they usually include all state-funded and local projects as well.

Metropolitan planning organizations and regional transportation agencies (MPOs and RTPAs, respectively, but both known more generally as “regional agencies”) prepare and manage FTIPS for their respective regions. Federal law requires each regional agency to update its FTIP every four years, and to submit the FTIP for approval by the Federal Highway Administration and the Federal Transit Administration.

1. FSTIP. The Federal Statewide Transportation Improvement Program, or FSTIP, is a statewide intermodal program of transportation projects that is consistent with the statewide transportation plan and planning processes, the metropolitan plans and the FTIPs. The FSTIP is prepared by Caltrans in cooperation with the regional agencies. Federal law requires the state to update its FSTIP every four years and submit it to the U.S. Secretary of Transportation.
2. State requires more frequent update to FTIP and FSTIP than does federal law. Federal law requires the regional agencies and the state update their FTIPs and the FSTIP every four years. State law, however, requires these programming documents be updated and submitted to the federal government every two years, the idea being the more-frequent schedule of updates allows more opportunity to adjust the projects included in the programs.
3. Federal Clean Air Act requires regional agencies to demonstrate conformity. The Federal Clean Air Act protects air quality through regulation of six “criteria” air pollutants: ozone, particulate matter, carbon monoxide, sulfur dioxide, nitrogen dioxide and lead. A regional agency must demonstrate its FTIP conforms to Clean Air Act requirements. To do so, regional agencies use the Air Resources Board (ARB)-created, federally approved emissions factor model to estimate future transmission-related emissions.
4. Trump administration axes California’s authority to set its own standards. Under the Clean Air Act, California has had the authority to set its own passenger car and light-duty truck greenhouse gas emissions standards and set zero-emission vehicle mandates. In November of 2019, the National Highway Safety Administration and the U.S. Environmental Protection Agency (EPA) revoked California’s authority to set its own standards.

In response, ARB adjusted its emissions model to accurately project future transportation emissions. There followed several months of administrative uncertainty as the U.S. EPA reviewed ARB’s model for approval. Though approval did finally come, regional agencies had put development of their FTIPs on hold as they awaited administrative certainty.

1. Change to state law allows projects to move forward. Because of the delay described above, the regional agencies say they do not have time to prepare FTIPs in time for the next biennial state deadline, October 1 of this year. Eliminating the requirement in state law that the FTIPs be updated by that date allows transportation projects consistent with a 2018 FTIP update to proceed.

Analysis Prepared by: Jay Dickenson / APPR. / (916) 319-2081

Date of Hearing: August 10, 2020

ASSEMBLY COMMITTEE ON TRANSPORTATION

Jim Frazier, Chair

SBPCA Bill Id:SB 1291

Author:(Committee on Transportation) – As Amended Ver:April 3, 2020

SENATE VOTE: 39-0

SUBJECT: Federal Statewide Transportation Improvement Program: submissions

SUMMARY: Waives the 2020 requirement that a Metropolitan Planning Organization (MPO) submit a Federal Transportation Improvement Program (FTIP) to the Department of Transportation (Caltrans). Specifically, this bill:

1. Provides that an MPO or regional transportation planning agency (RTPA) is not required to submit an FTIP to Caltrans for 2020.
2. Provides that Caltrans is not required to submit a Federal Statewide Transportation Improvement Program (FSTIP) to the United States Secretary of Transportation for 2020.
3. Contains an urgency clause and describes the urgency by stating that many MPOs and transportation planning agencies are unable to comply with existing law, which requires those entities to submit Federal Transportation Improvement Programs (FTIP) to Caltrans for 2020.

EXISTING LAW:

Existing state law:

1. Requires MPOs and RTPAs to submit an FTIP to Caltrans for incorporation into the FSTIP no later than October 1 of each even-numbered year.
2. Requires Caltrans to prepare, in coordination with the metropolitan planning agencies, an FSTIP and submit it to the U.S. Secretary of Transportation by December 1 of each even-numbered year.
3. Requires each MPO and transportation planning agency to select and program projects in conformance with federal law.

Existing federal law:

1. Requires, every four years, an MPO to develop an FTIP of upcoming transportation projects covering a period of at least four years.
2. Requires each state to develop an FSTIP and update it at least once every four years.
3. Establishes the Federal Clean Air Act (FCAA), which through its implementing regulations:
4. Establishes National Ambient Air Quality Standards (NAAQS) for six criteria pollutants, and
5. Designates air basins that do not achieve NAAQS as non-attainment.
6. Requires, under FCAA, that in areas experiencing air quality problems, transportation planning, including FTIPs, must be consistent with air quality goals as determined through the transportation conformity process.

FISCAL EFFECT: Unknown

COMMENTS: FTIPs are comprehensive regional spending plans consisting of proposed plans for major transportation projects over multiple years. MPOs and RTPAs prepare and manage FTIPs for their region. Federal law requires regions to adopt a new FTIP every four years, although more stringent state law requires regions to update their FTIP every two years. Federal law also requires the Federal Highway Administration (FHWA) and the Federal Transit Administration to approve the FTIP. FTIPs are required to include all federally funded projects, and regions also include projects funded by state and local revenues in their FTIPs.

Caltrans is responsible for preparing and managing the FSTIP, a four-year statewide intermodal program of transportation projects that is consistent with the statewide transportation plan and planning processes, the metropolitan plans, and the FTIPs. The FSTIP is prepared by Caltrans in cooperation with MPOs and RTPAs. As with the regional program, federal law requires Caltrans to develop an FSTIP and update it at least once every four years, while state law requires Caltrans to prepare and submit the FSTIP to the U.S. Secretary of Transportation every two years. The next federal deadline is December 1, 2022.

The FCAA sets NAAQS for six criteria pollutants: ozone, particulate matter, carbon monoxide, sulfur dioxide, nitrogen dioxide, and lead. Areas that have worse air quality than NAAQS for one or more pollutant are non-attainment areas. Fourteen out of the 18 MPOs in California include non-attainment areas. Because transportation projects may lead to changes in criteria pollutant emissions, these MPOs must perform a conformity determination to demonstrate that their FTIPs conform to FCAA requirements. Conformity determination requires use of California’s emissions factor model (EMFAC) to estimate associated transportation emissions. The EMFAC is maintained by the California Air Resources Board (CARB) but must be approved federally.

On November 26, 2019 the federal Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One went into effect. This rule revokes California’s authority to set its own passenger car and light truck greenhouse gas emissions standards and set zero-emission vehicle mandates. The California Air Resources Board prepared adjustments to EMFAC to accurately estimate future transportation emissions. FHWA required the United States Environmental Protection Agency (U.S. EPA) to approve the use of these adjustments before approving new Regional Transportation Plans and new FTIPs. U.S. EPA approved Part One adjustments on March 12, 2020.

The federal SAFE Vehicles Rule Part Two was finalized March 31, 2020 and went into effect June 29, 2020. Part Two requires corporate average fuel economy (CAFE) and CO₂ emissions efficiency to increase by 1.5 percent each year, compared with the CO₂ standards issued in 2012, which would have required increases of about 5 percent per year.

While Part Two was anticipated to require additional adjustments, on May 13, 2020 CARB announced that the impacts of Part Two will not affect transportation conformity determinations. However, this guidance comes after months of uncertainty and leaves inadequate time for the FTIP process to be completed by the state’s October 1, 2020 deadline. On average, FTIPs take over half a year to complete, and not all MPOs meet during the summer months. This bill helps to ensure that transportation projects that have already been approved can proceed despite the uncertainty created by the SAFE Vehicles Rules Part One and Two. Eliminating the state requirement that MPOs submit an FTIP in 2020 enables projects consistent with the 2018 FTIP to proceed. The process resumes by 2022, when the next federally required FTIP is due.

According to the author, “SB 1291 (Senate Committee on Transportation) ensures that transportation projects, and their associated safety benefits and jobs, can proceed despite months of uncertainty around Federal Transportation Improvement Program (FTIP) approval. The new federal SAFE Vehicles Rule rolled back fuel economy standards and revoked California’s authority to set more stringent emissions requirements under the federal Clean Air Act. This Rule had the secondary effect of creating uncertainty around how to estimate the emissions potentially resulting from Federal Transportation Improvement Programs (FTIPs), a necessary step before these plans can be approved and projects move forward. Federal guidance out in May provided clarity, but left inadequate time for Metropolitan Planning Organizations to meet a looming FTIP deadline on October 1, 2020. This bill provides MPOs much needed additional time for MPOs to finalize these plans.”

In support of the bill, the California Association of Councils of Governments writes, “The challenge that SB 1291 addresses is timing. It takes as long as eight months to put together the information to develop a list of projects under ideal circumstances. The process involves detailed conversations with all local agencies about all the projects that will occur, outreach, analysis, circulation, and ultimately, approval by the Regional Agency board before it can be submitted to Caltrans. Each regional list is subject to the conformity analysis. If conformity cannot be demonstrated, the projects in the list cannot proceed. State-wide, the total value of projects is over $130 billion (though each region would be subject to its own analysis).”

Accordingly, SB 1291 affords Regional Agencies some flexibility with the unique circumstances surrounding the SAFE Rule and other events this year. We also appreciate that SB 1291 permits the process to be completed prior to 2022 (which would be the deadline under federal law). Most Regional Agencies actually prefer a two-year FSTIP cycle to the four-year federal minimum because it allows more flexibility in delivering projects (if one project unexpectedly stalls, there is a larger shelf of conforming projects in which they can shift resources under a two-year cycle). As a result, we actually expect that our member Regional Agencies will work with Caltrans to adopt the next FSTIP prior to the federal deadline. SB 1291 affords them this flexibility.”

REGISTERED SUPPORT / OPPOSITION:

Support

Association of Monterey Bay Area Governments

California Association of Councils of Governments

Council of Fresno County Governments (COG)

Council of San Benito County Governments

Madera County Transportation Commission

Orange County Transportation Authority

Placer County Transportation Planning Agency

Sacramento Area Council of Governments

San Diego Association of Governments

San Luis Obispo Council of Governments

Santa Barbara County Association of Governments

Santa Cruz County Regional Transportation Commission

Shasta Regional Transportation Agency

Southern California Association of Governments

Stanislaus Council of Governments

Transportation Agency for Monterey County (TAMC)

Transportation California

Ventura County Transportation Commission

Opposition

None on file

Analysis Prepared by: Christine Casey / TRANS. / (916) 319-2093

 CONSENT 

Bill No: SB 1291

Author: Committee on Transportation

Amended: 4/3/20

Vote: 27 - Urgency

SENATE TRANSPORTATION COMMITTEE: 13-0, 5/29/20

AYES: Beall, Allen, Dahle, Dodd, Galgiani, Lena Gonzalez, Grove, McGuire, Melendez, Morrell, Roth, Rubio, Wieckowski

NO VOTE RECORDED: Skinner, Umberg

SENATE APPROPRIATIONS COMMITTEE: Senate Rule 28.8

SUBJECT: Federal Statewide Transportation Improvement Program: submissions

SOURCE: Author

DIGEST:

This bill suspends the 2020 requirement that a Metropolitan Planning Organization (MPO) submit a Federal Transportation Improvement Program (FTIP) to the Department of Transportation (Caltrans).

ANALYSIS:

Existing federal law:

1. Requires, every four years, each MPO to develop an FTIP, which is a list of upcoming transportation projects covering a period of at least four years.
2. Requires, under the Federal Clean Air Act (FCAA), that in areas experiencing air quality problems, transportation planning including FTIPs must be consistent with air quality goals as determined through the transportation conformity process.

Existing state law:

1. Requires every MPO and transportation planning agency to, no later than October 1 of each even-numbered year, submit its FTIP to Caltrans for incorporation into the Federal Statewide Transportation Improvement Program (FSTIP).
2. Requires Caltrans to prepare the FSTIP in accordance with federal law to be submitted to the United States Secretary of Transportation no later than December 1 of each even-numbered year.

This bill:

1. Specifies that an MPO or transportation planning agency shall not be required to submit a FTIP to Caltrans for 2020.
2. Specifies that Caltrans shall not be required to submit a FSTIP to the United States Secretary of Transportation for 2020.
3. Contains an urgency clause and explanation that, due to changes in federal law, many MPOs and transportation planning agencies are unable to comply with existing law, which requires to entities to submit FTIPs to Caltrans for 2020.

Comments

1. Purpose. This bill ensures that transportation projects, and their associated safety benefits and jobs, can proceed despite months of uncertainty around FTIP approval.
2. Emissions modeling is part of transportation planning. Federal law requires each MPO to develop an FTIP, which is a list of upcoming transportation projects covering a period of at least four years. For most MPOs in California, adoption of a new FTIP requires use of California’s emissions model, EMFAC, to accurately estimate future transportation emissions and demonstrate that the FTIP conforms with FCAA criteria pollutant standards.
3. SB 1291 mitigates the impacts of the Federal Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule on transportation planning and project delivery. The new Federal SAFE Vehicles Rule Parts One and Two roll back greenhouse gas emission and fuel economy standards and revoke California’s authority to set more stringent emissions standards. In light of these rules, state and federal agencies determined what adjustments to EMFAC were needed to reflect changes in future emissions, concluding this process in mid-May. However, this process took place during the crucial window MPOs need to prepare FTIPs for the state’s October 1, 2020 deadline. On average, FTIPs take over six months to complete, and not all MPOs meet during the summer months. SB 1291 eliminates the 2020 FTIP requirement. This enables MPOs to continue delivering on projects in their 2018 FTIPs before returning to the regular two-year FTIP cycle by 2022 at the latest.
4. Urgency Clause. This bill includes an urgency measure and shall go into effect immediately upon passage by the Legislature and signed by the Governor.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: No

SUPPORT: (Verified 6/8/20)

Association of Monterey Bay Area Governments

California Association of Council of Governments

Council of Fresno County Governments

Council of San Benito County Governments

Madera County Transportation Commission

Placer County Transportation Planning Agency

Sacramento Area Council of Governments

San Diego Association of Governments

San Luis Obispo Council of Governments

Santa Barbara County Association of Governments

Santa Cruz County Regional Transportation Commission

Shasta Regional Transportation Agency

Southern California Association of Governments

Stanislaus Council of Governments

Transportation Agency for Monterey County

OPPOSITION: (Verified 6/8/20)

None received

Prepared by: Amy Gilson / TRANS. / (916) 651-4121

6/10/20 13:25:14

**** END ****

SENATE COMMITTEE ON TRANSPORTATION

Senator Jim Beall, Chair

2019 - 2020 Regular

Bill No: SB 1291 Hearing Date: 5/29/2020

SUBJECT: Federal Statewide Transportation Improvement Program: submissions

DIGEST: This urgency bill suspends the 2020 requirement that a Metropolitan Planning Organization (MPO) submit a Federal Transportation Improvement Program (FTIP) to the Department of Transportation (Caltrans).

ANALYSIS:

Existing federal law:

1. Requires, every four year, each MPO to develop an FTIP, which is a list of upcoming transportation projects covering a period of at least four years. Requires the FTIP to include all regionally significant projects receiving Federal Highway Administration (FHWA) of Federal Transit Administration (FTA) funds or for which FHWA or FTA approval is required.
   
2. Establishes the Federal Clean Air Act (FCAA), which through its implementing regulations:
   
3. Establishes National Ambient Air Quality Standards (NAAQS) for six criteria pollutants, and
   
4. Designates air basins that do not achieve NAAQS as non-attainment.
   
5. Requires, under FCAA, that in areas experiencing air quality problems, transportation planning including FTIPs must be consistent with air quality goals as determined through the transportation conformity process.

Existing State Law:

1. Requires every MPO and transportation planning agency to, no later than October 1 of each even-numbered year, submit its FTIP to Caltrans for incorporation into the Federal Statewide Transportation Improvement Program (FSTIP).
   
2. Requires Caltrans to prepare the FSTIP in accordance with federal law to be submitted to the United States Secretary of Transportation no later than December 1 of each even-numbered year.

This bill:

1. Specifies that an MPO or transportation planning agency shall not be required to submit a FTIP to the department for 2020.
   
2. Specifies that Caltrans shall not be required to submit a FSTIP to the United States Secretary of Transportation for 2020.
   
3. Contains an urgency clause and explanation that, due to changes in federal law, many MPOs and transportation planning agencies are unable to comply with existing law, which requires to entities to submit FTIPs to Caltrans for 2020.

COMMENTS:

1. Purpose. This bill ensures that transportation projects, and their associated safety benefits and jobs, can proceed despite months of uncertainty around Federal Transportation Improvement Program (FTIP) approval. For most Metropolitan Planning Organizations (MPOs) in California, adoption of a new FTIP requires use of California’s emissions model, EMFAC, to accurately estimate future transportation emissions and demonstrate that the FTIP conforms with Federal Clean Air Act (FCAA) criteria pollutant standards.

The new Federal SAFE Vehicles Rules Parts One and Two roll back greenhouse gas emission and fuel economy standards and revoke California’s authority to set more stringent emissions standards. In light of these rules, state and federal agencies determined what adjustments to EMFAC were needed to reflect changes in future emissions, concluding this process in mid-May. However, this process took place during the crucial window MPOs need to prepare FTIPs for the state’s October 1, 2020 deadline. On average, FTIPs take over six months to complete, and not all MPOs meet during the summer months. SB 1291 eliminates the 2020 FTIP requirement. This enables MPOs to continue delivering on projects in their 2018 FTIPs before returning to the regular 2-year FTIP cycle by 2022.

1. FTIPs are not federally required this year. Federal law requires each MPO to develop an FTIP, which is a list of upcoming transportation projects covering a period of at least four years. The FTIP must include all regionally significant projects receiving FHWA or FTA funds or for which FHWA or FTA approval is required. Rural non-MPO regions do not prepare an FTIP. However, they report to Caltrans any federally funded or regionally significant projects. Caltrans then prepares the FSTIP for submission to the US Department of Transportation (US DOT), which includes the non-MPO regions’ projects plus the FTIPs from California’s 18 MPOs. State law requires this process to occur ever even-numbered year, but federal law is more flexible, only requiring an MPO to prepare a new FTIP only every four years. Therefore, state-mandated deadlines are pending (an MPO to submit its FTIP to Caltrans by October 1 of this year and Caltrans to submit the FSTIP to US DOT by December 1), but preparation of new FTIPs may be deferred until the next federal deadline in 2022.
2. Most California MPOs must demonstrate that their FTIP conforms with the FCAA. The FCAA sets NAAQS for six criteria pollutants: ozone, particular matter, carbon monoxide, sulfur dioxide, nitrogen dioxide, and lead. Areas that have worse air quality than the NAAQS for one or more pollutant are non-attainment areas. Fourteen out of the 18 MPOs in California include non-attainment areas. Because transportation projects may lead to changes in criteria pollutant emissions, these MPOs must perform a conformity determination to demonstrate that their FTIPs conform with FCAA requirements. Conformity determination requires use of California’s emissions model, EMFAC, to estimate associated transportation emissions. The EMFAC is maintained by the California Air Resources Board but must be approved federally.
3. Federal Safer Affordable Fuel Efficient (SAFE) Vehicles Rule Part One and Two. In the past year, the National Highway Traffic Safety Administration (NHTSA) and the US Environmental Protection Agency (US EPA) issued the federal SAFE Vehicles Rule, Parts One and Two which together have the effect of rolling back greenhouse gas emission and fuel economy standards and revoking California’s authority to set more stringent standards. Part One went into effect November 26, 2019 and revokes California’s authority to set its own passenger car and light truck greenhouse gas emissions standards and set zero-emission vehicle mandates. Part Two will go into effect June 29, 2020 and requires corporate average fuel economy (CAFE) and CO₂ emissions efficiency to increase by 1.5% each year, compared with the CO₂ standards issued in 2012, which would have required increases of about 5% per year.
4. Consequence of SAFE Vehicles Rule Part One and Two on FTIP. To reflect SAFE Vehicles Rule Part One, the California Air Resources Board (CARB) prepared adjustments to the EMFAC (CARB’s EMFAC Off-Model Adjustment Factors to Account for the SAFE Vehicles Rule Part One). Before approving new transportation plans that require a conformity determination (including FTIPs), the FHWA required US EPA to accept the use of these adjustments. US EPA approved Part One adjustments March 12, 2020 – a six month process from rule publication to approval. During that period, approval of new transportation plans and amendments to existing plans that required conformity determinations could not take place.

Since Part Two will increase emissions, it seemed possible that additional EMFAC adjustment factors would be necessary, and it was unclear on what timeframe any new guidance would be issued. However, at the May 13, 2020 California Transportation Commission (CTC) meeting, CARB announced that Part 2 would increase upstream emissions, and therefore not impact transportation conformity determinations. FHWA also stated that EMFAC, as adjusted to address Part 1, may continue to be used.

1. Too late. This guidance comes after months of uncertainty and leaves inadequate time for the FTIP process to be completed by the state’s October 1, 2020 deadline. On average, FTIPs take over half a year to complete, and not all MPOs meet during the summer months. This bill helps to ensure that transportation projects that have already been approved can proceed despite the uncertainty created by the SAFE Vehicles Rules Part One and Two. Eliminating the state requirement that MPOs submit a FTIP in 2020 enables projects consistent with the 2018 FTIP to proceed. MPOs would return to the regular two- year FTIP cycle by 2022.

According to the California Association Councils of Governments:

The challenge that SB 1291 addresses is timing. It takes as long as eight months to put together the information to develop a list of projects under ideal circumstances. The process involves detailed conversations with all local agencies about all the projects will occur, outreach, analysis, circulation, and ultimately, approval by the Regional Agency board before it can be submitted to Caltrans. Each regional list is subject to the conformity analysis. If conformity cannot be demonstrated, the projects in the list cannot proceed. State-wide, the total value of projects is over $130 billion (though each region would be subject to its own analysis).

Accordingly, SB 1291 affords Regional Agencies some flexibility with the unique circumstances surrounding the SAFE Rule and other events this year. We also appreciate that SB 1291 permits the process to be completed prior to 2022 (which would be the deadline under federal law). Most Regional Agencies actually prefer a two-year FSTIP cycle to the four-year federal minimum because it allows more flexibility in delivering projects (if one project unexpectedly stalls, there is a larger shelf of conforming projects in which they can shift resources under a two-year cycle). As a result, we actually expect that our member Regional Agencies will work with Caltrans to adopt the next FSTIP prior to the federal deadline. SB 1291 affords them this flexibility.

1. Urgency Clause. This bill includes an urgency measure and shall go into effect immediately upon passage by the Legislature and signed by the Governor.

FISCAL EFFECT: Appropriation: Fiscal Com.: Local:

POSITIONS: (Communicated to the committee before noon on Thursday,

May 21, 2020.)

SUPPORT:

Association of Monterey Bay Area Governments
California Association of Council of Governments
Council of San Benito County Governments
Placer County Transportation Planning Agency
Sacramento Area Council of Governments
San Diego Association of Governments
San Luis Obispo Council of Governments
Santa Barbara County Association of Governments
Santa Cruz County Regional Transportation Commission
Shasta Regional Transportation Agency
Southern California Association of Governments
Stanislaus Council of Governments
Transportation Agency for Monterey County (TAMC)

OPPOSITION:

None received.

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