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HomeMy WebLinkAboutAgenda Bill 3A 04/19/2010w~~z,U~ a '~ r Ig5$ DATE: April 19, 201.0 ~l~~,v~.dc~ Itewv # 3.~1 TO: Honorable Mayor and Members of the City Council through City Manager FROM: John C. Brown, City Manager SUBJECT: Resolution Opposing Proposition 16, the "New Two-Thirds Vote Requirement for Local Public Electricity Providers." RECOMMENDA'T'ION: It is recommended that the City Council adopt the attached resolution opposing Proposition 16. BACKGROiTND: Proposition'16, known as the "New Two-Thirds Requirement for Local Public Electricity Providers" has qualified for the June 2010 California primary election ballot. It is sponsored by PG&E; and if approved by voters, would require .multiple two-thirds votes for any public power utility to expand or upgrade electric service outside of its territory to serve existing customers. Proposition 16 would also impact the ability of cities and counties to engage in Community Choice Aggregation programs by requiring the same two-thirds vote. A copy of the analysis of Proposition 16, prepared by the Legislative Analyst's office, is attached for further background and information. DISCIJSSLON: Proposition 16 requires that any bonded. indebtedness or use of public funds to expand electric delivery service must be approved by two-thirds of the voters within the territory (including newly annexed territory, even where the annexation has been approved by the Local Agency Formation Commission (LAFCO) and the local government has been designated by LAFCO as the electric service provider). The only exception to this is if the local government is the sole provider of such services within its jurisdiction. Because eligible renewable .resources would be exempted from the requirements of Proposition 16, public utilities -after having failed to reach the two-thirds voter threshold to acquire conventional sources of generation -would likely have to purchase electricity generated at a higher cost, presumably from investor-owned utilities such as PG&E in Northern California, which in turn may have an impact on rates for electricity customers. The impact of higher costs Agenda Review: Dept. Director City Attorney Finance Director ,,o~~ City Manager would.be particularly negative for business customers that need reliable and affordable electricity to remain competitive. At its February meeting, the Board of Directors of the League of California Cities voted to oppose Proposition 16. Opposition of the measure is shared in growing numbers by cities locally and statewide. >FINAN:CIAL IMPACTS: There are no costs associated with the City taking a position on Proposition 16. According to the California Legislative Analyst's Office, the fiscal effects of this initiative are unknown. The net impact on state and local government costs and revenues are dependent on future voter decisions, due to the measure's potential effects on electricity rates and publicly owned utility operations. ATTACHMENTS 1. Resolution. 2. Proposition 16 Summary 3. Summary from League of California Cities/Committee on Environmental Quality 4. 'Summary from League of California Cities Board of Directors 5. Legislative Analysis 2 ATTACHMENT 1 RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PETALUMA OPPOSING PROPOSITION 16, KNOWN AS THE "NEW TWO-THIRDS VOTE REQUIREMENT FOR LOCAL PUBLIC ELECTRICITY PROVIDERS" WHEREAS, Proposition 16, known as the "New Two-Thirds Requirement for Local Public Electricity Providers", has qualified for the June 2010 California primary election ballot; and WHEREAS, Proposition 16 is being sponsored by PG&E, and if approved by voters, would require multiple two-thirds votes for any public power utility to expand electric service outside of its territory to serve existing customers; and WHEREAS, Proposition 16 would impact the ability of cities and counties to engage in Community Choice Aggregation (CCA); and WHEREAS, there are no costs associated with the City taking a position on Proposition 16; and WHEREAS, Proposition 16 would have an unknown cost to local government costs and revenues due to its potential effects on electricity rates and electric operations, as well as the costs associated with any special elections that would be required under the initiative; and WHEREAS, some local government agencies .might not start up or expand a publicly owned utility into a new territory or create a CCA as a result ofthe measure's new voter approval requirements, possibly resulting in higher electric rates for its customers... This could affect state and local government costs, since many public agencies are themselves large consumers o~f electricity. NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Petaluma does hereby oppose Proposition 16, the "New Two-Thirds Vote Requirement for Local Public Electricity Providers". ATTAC~IlVIENT 2 PROPOSITION 16 "New Two-Thirds Requirement far Local.Public Electricity Providers" Education Information Back ound o Proposition t6 was entered in'lhe initiative process originaily named ``The Taxpayers Right to Uote Act;" The San Francisco i;ocai Agency Formation Commission {LAFCO). argued -that this title was misleading, and as a result, the Attorney General renamed the initiative to its cui•rentaitle: o~ Will'be on the June 8~,20f 0 ballot. Existing-Law o .Cities are ailowed fo complete annexations that include: he expansion of electric service by the approval of a simple majority of voteis;in the area to be!annexed. o An election can be held within the city's existing jurisdiction.ifirequested by 25 percent of the city's residents or bythe area's LAFCO: Initiative. Proposed. Changes o Cities must obtain 2/3rds voter approval from both the existing service area and newly annexed area if electric^service. is to be expanded. o Any city or county pursuing Community Choice Aggregation (CCA) or the formation of a newpublicly-owned electric utilitymuse.obtain 2/3Gds voter approval before proceeding. o Votingtequirements only apply if thete will bean expenditure of public funds for construction; acquisition, of ser6ices used to expand delivery'seivice. Exemptions o Voter approval would. not be required foi electricity expansions within the jurisdiction of the local goverriinentarid within;the territory to be served. o A 2/3rds vote wouldroot applyif fdnds:are used.-solely for purchasing, providing, or supplying renewable electricity, or if electric delivery service is frir the local government's own end use: Major lmnacts to Existing Publicly Owned Utilities n .Annexation of uew territories°will:require a 2/3rds vote before cities can serve those areas -with. municipally-ov~med electricity. o 'the intiative language is vat,'ne and it is unclear if a 2/3rds vote would also be required for the development of nqn-renewable generation facilities or transmission lines located outside ofalte city's jurisdiction. o The Legislative Analysts office concluded that the initiative would create an unknown impact to state'-and locat government costs and revenues, duexo thepotential impacts on electricity rates and'pizblicly-owned electric utility operations. ATTACHMENT 3 PROPOSIiIDN IMPOSES NEW TVVO-THIRDS VOTER APPROVAL REQUIREMENT'EDR'LOCAL PUBLIC ELECTRICITY `PROVIDERS. INITIATIVE CONSTITUTIONACAMENDMENT. OFElC191L TtTLF, AND SUMMARY PREPARED BY THE AT1"ORNEY GENERAL IMPOSES. NEW TWO-THIRDS VDTEI? APPROVAL REQUIREMENT FOR LOCAL PUBLIC ELECTRICITY PROVIDERS. INITIATIVE CONSTITUTIONAL;AMENDMENT. • Requires local governments to obtai~i the approval of two-thirds of the voters before. providing electriciry service to new customers or expanding such service to new territories using public funds or bonds. • Requires same two-thirds vote-to .provide electricity service through a community choice program using public Rinds' or bonds; • Requires the vote tc~ be in the jurisdiction of the local governmenc_and arty new territory to be served. • Provides exceptions to the voting;requirements for a,li;nited.number of identified projects. 'Summary of I:egislative Analyst's Estimate of'Net State and Local'Governinentfiscal Impact: • 'Unknown net,impacton.state.and local,governmentcosts~and revenues due to uncertainty as to the measure's effects, on public, electricity providers and.on electricity rates. These effects are unlikely to be significant-intfie-short run. ANALYSIS BY THE LEGISLATIVE ANALYST BACKGROUND Provision of Electricity Service,irt,California California Electricity Providers. Californians generally receive tEteir electriciry service from;one of three types of providers: nvesior-owned utilities '.(IOUs},: oval publicly owned electric utilities, or electric service providers (ESPs).'These provide 68 percent, 24 percent, and 8 percent; respectively, of retail-electricity service in the state. Investor-Owned. Utilities. The IOUs are owned try private investors and provide electriciry service for profit:'The three largest electricity OUs in the state are;L'acific°Gas and .Electric (PG&E), Southern'California Edison, and Ban Diego Gas and Electric. Each IOU has.a unique; defined geographic service area acid is required bylaw to serve=ctistoiners in thacarea..The California Pixblic Utilities Commission (CPUC) :regulates thz rates charged by ICUs and,how they provide electricity service to [lien customers. Publicly Owned `Utilities. Publicly owned electric utilities are publicentities that provide electriciry service to residents and businesses in their local-area. Whilenot regulated by CPUC, publicly owned electric utilities are governed by locally elected boards which set their own terms of service, including the rates charged to their customers: Electricity°service is currently provided by local goverrimerits'through several different governmental structures authorized under state .law, including: • Utility depai•trnents oF¢ities, such: as the Los Angeles Department of Water and Power. • Municipal utility districts, such as the Sacramento Municipal Utility District (SMIJp): • Publicutility districts; such as-the Truckee Donner Public Utiliry.District. • Irrigation districts, such as the Imperial'. Irrigation District. 26 ~ Tit/c and Summary / Arralytis PROP INIPOSES'NEW TWO=THIRDS=VOTER ARPROVAL:REQUIREMENT FDR"LOCAL PUOCIC ELECTRICITY-PROVIDERS. INITIpTIUE CONSTITUTIDNAL AMENDMENT. ANALYSIS BY THEfiEGISLATIVE'ANALYST Electric Servii'e Providers.. The ESPs provide electricity to customers who ha~~e.chosen not to receive electricity from t1e:IQ,LJ or°publidy'owned utility that wotild:ocherwise serve their geographic area. Under this aliproach,.an electricity.customer enters into whax is termed a "direct access" contract with an ESI? that>deliverselectriciiy to the customer through die local uti.lity's transmission and distribution system. The Creationand Expansion of~Putificly Provided Electrii:ity Services Community Choice Aggregation: In addinon• to the ESP arrangements discirssed.above; state law allows a city or a. county, ora,cnmbinatlionofrhe two, ro arrange to provide electricity within their jurisdiction through a contracrwith an electricity provider ocher than the IOU that-would',otherwise serve that local. area. This is referred to as "community choice aggreganon," Although only one community choice aggregatgr:(CCtC) currently exists to provide electricity in California, several communities are exploring this option. A CCA could get its electricity from an ESP, using the transmission. and distribution system of the IOU serving chat local area. Electricity customers within, that area would automatically get their electricity-from the CCA unless they elected to continue to receive service fruit .the lOU. Prop~skls to Create and Ex~iand Public Electricity Providers. In recent years, a lrnted number oflocal-governments inahe stare. have explored zhe:idea of creating ne~y public providers of electricity or expanding publicly owned utilities into.new territory currently served;by an IOU. For example; the City and Gounry,of San Traneisco has considered creating;a C;CA that would.include #erritory currently served by PG&E.,As another example, Polo-:County explored having SMUU provide electricity service to eerritory within' the county curreitrlyserved by PG&F: In some cases; these proposals have been put before the voters for their approval; under~proyisions ofstate law discussed: below. Fnr text of PFoporition 16, .tee page 75. CONTINUED Voter Approval Require~rzeszts far Publicly Owned Electricity Providers: As noted above, publicly owned utilities can ,be organized under several different types of government structures. Each type°of local government entity tharis autlicirir_ed to provide electricity-service,, and that is considering-.either the start-up of electricity service or the expansion of existing service beyond its current service'area,'is subject to certain state requirements. Various stafiites specify ;whether voter approval is required for the start-up of electricity service by authorized local governmenc.entities. Under state law, if a local;government;rtfends to expand'its electricity service into anew territory, drat new area must be annexed and, in certain cases; a majority of the voters in the area proposed for annexatiorr must approve the expansion. In such .cases, however; no gore of the public is generally required withii4 rlie.existingsei-vice territory of the local governmental entity that is proposing the, expansion. {In some cases, a local commission recjuires such a vote as a condition of approving .the annexation.) In contrast, Deal agency action to create and begin implementation+ofa CCA may be undertaken upon a vote of the.local agency .governing. boarii' and does not require local voter approval. PROPOSAL The meastire places new voter approval requirements on local governments before they caii use `ptililicfunds"-defined broadly itt the measure cp~~ndudc tax rcvcnues,warious forms of debt, and ratepayer'funds-to start up electricity service, expand;electricity~service irtEo a new territory, or implement a CCA: • First; before anyauthorized local government entity can start upelectriciry,serviee, it must receive approval by two-thirds of t$e voters in the area proposed to be served. • Second, before an existing publicly owned utility can expand its electric delivery service Analyri.r ~ 27 6 PRDP IMPDSESHEWTWO-THIRDSVDTER"APPROVAL REQUIREMENTFDR-LOCAL PUBEIC ELECTRICITY ARDYIDEAS:lNITIATIVECDNSTITU110NAL AMENDMENT: ANALYSIS BY THE LEGISLATIVE ANALYST into a.;;new territory; is-,must receive approval by two-thuds of the voters in the area currentlyservedby•ght utility and.two-thirds of the voters in the new area proposed.to be served: r Third; the measure regiires,two-thirds.voter approval for a Iocal government to implemenC a CCA. .The measure provides three exempeions to local governments~from these voter approval requirements: • If the use of public~funds,has been previously approved by the voters both within-the existing local jurisdiction and the territory proposed~~ for. expansion. • If the public funds'would be used solely o purchase, provide, of supply specified-types of electriciry from renewable sources, such as wind or solar,power: • If the pthlic funds would,be used only to . provide electric dzliyery service for. the local govermnent's own use. FISCAL EFFECTS Local'Administrative .Costs for Elections: Because dais measure requires voter approval„for specified,local,governmeiir actions chat can. currently~be accomplished without such ,votes, it wotild result.in additioital.elections,costs. These costs wotiid~rimarily be relatedao°prepariii~:and rnatlin~~~election-"elate ritaterials.!In most eases, the alhttng~cquld be consolidated`with•already' scheduled elections. As a result, the increased election related costs due to this measure would probably be,minor. CONTINUED Potentialhnpaet on State anti Local Government Costs lzntl.Xevenues. This measure could affect local governmenrcosts and revenues due to its .potential effects oit the operation of publicly owned utilities end CCAs. Ircould also affect the finances of stare and local government agencies inaCalifornia because of its potential impact on electricity rates. These effects wotild largely-depend upon future actions.of voters and Iocal governments.. We discuss these potential effects•iit.more detail;below: First,•the new public voter<approval requ.rements.:for2heararc-up or expansion of publicly owned utilities or the implementation of CCAs could restilt in public. disapproval of such changes. Also, the cxistence.of these.new voter approval requirements could deter some local goyernmenr;agencies from- proceeding with such plans. To the extent that this occurred; these local government~agencies would besomewhat smaller in size and have fewer customers than would otherwise be the ease..As a result, they would-have lower total revenues and costs. Second, the enactment o'f this measure could also,affeet the finances ofstateand local governmc:nt:agencics in California due to its pgtential.rnpact on electriciry rates: tls.noted above,some local ggvernmenragencies might not startup or expand a publicly owned utility into a new,territoryor implement a CCA. as a.result of thetmeasu"re's. new voter approval requremenrs.'In this event, the;rates.:paid by electriciry customers in that and neighboi-ingjurisdictions could be higlicror lower Cha~a would otherwise have been the case. For'example; ifrhis measure prevented la ~ A6alyrzr PRbP 'IMPOSES NEW=TWO-TNIROS VOTER APPROVAL REQUIREMENT fOR LOCAL Pl18CIC FLECTRICITY>PROVIDERS. INITIATIVE CONSTITUTIONALAMENDMENT. ANALYSIS BY TNf LEGISLATIVE ANALYST the expansion ~f publicly provided electrical service that depended upon the c~nstrueton of new:energy infrastructure, rates might be held lowci than might otherwise gccur.,On the'other hand, lf,this measure lessened the competitive pressureson private electricity providers by reducingahe,opportunities for expansion of publicly provided electrical service;. the races charged to electricity euscptners might evenru.ally 6e higher than otlieiwise. These impacts could' affect state.arcd local governtnenr costs, since many liublicagences are themselves large consumers of electriciry.'To the extenti"iliac changes iii electricity Fortcxt ofY'ropositiom I'6;,tee pdge 75. CONitNUEf) rates affect business.. profits, sales, and taxable income, these factors could also affect state and local tax revenues. In the short tun,'the net fiscal effect of all of these factors•on the~~nances of state and Local government'agencies is `unlikely to be significant on a statewide'basis. This is diie;to the relatively limited nuiiiber ofaocal government agencies considering the start-up or expansion of electricity services into""new territory. In the long run, the net fiseal;effcct of the measure is unknown and would depend on fiitiue actions of localgovernmentsand ygters. Analyr:t ~ 29. 8 PROP IMPOSES'NEW TWO-THIRDS~YOTER`APPROYRI REQUIREMENT FOR„LOCAL PUBLIC ELECTRICITY BROVIDERS. INITIATIVE CONSTITUTIONALAMENDMENT. Vote YES on Proposition IG, the Taxpayers Right w Ueite Act. Pr~posirii>n 1'6, the Taxpayers, Right to Vore,Act; does . one simple thing; Irrequires voter approvahb'efore,local governments'can spend pyibhc+money orincur public debt co get into the electricity business. And like mosclocaI special tax and bb+fd decisions in Califixna„two-thirds eater approval will be^required. In tough ecogomic'timeslike'these, local voters have every right co have the final say on an issue as important as who provides Sherri with local electric service, and,how much it will cost. Twci-thirds voter approval is our best ptoteciion,against cgsdy:and risky government schemes to>rake,over local elecn`ic servicx: Several local governments tit California are trying'to take ever private electric businesses-ofcrn using gniinent . dgmain-and`are refusing torlet local voters have the,final sayin chedecision, because'stateaaw-doesn't requite it. This measure establishes clear vo~er'approval'requirements before local governments canapend public money or incur,public debt to go intoihe local-electricity business. 'These da~:s, with government spending our of control and mounting govcciin,encdebt-the best financia] saFeguard' fnr taxpayers is ro;live voters the final say in these decisions. :Supporters of P_ropositign :16, theTaxpayers Right to Vote`Act, indudrig the Calfgrnia Taxpayers' Association, the CaliforniaiChamber oF'Comtnerce and Pacific Gasand Electric:Gompany,.believertharahe votcrsshould decide. it`#is oucelectnc service 'our puhlic money and, in the end, it is everyone's problemcif a governmentrrun electricity business (ails. We, the vorers;;dese:i-vc the right tv have the final sae about how our money-is spent. Vote YES.on I?rop~sition T6; rheTaxpayers Right co Vote Act. www. taxpayersrigh tto vgte.:cttm TERESA CASAZZA, President Californr~t Taxpayers Association ALLAN ZAREMBER6, President California Chamber of Commerce VoteNo~on-Prciposition 16tgstop the worst case-yet. qfa big special interest=tkiis rime it's PG&E; the gianq for-profit private tttliry_-misusing the init+ative;grocess. Don't let PCatStE foolryou..Pioposition 4.6 doesn't touch your taxrs,one wayor the other; hs a1ls;aboutPGtkE mainrainirig its,monopply and eliminaing:its cgmpetition. Tharcoutd'mean higher electtio-bills and poorer service for all Galiforniatts-regardless of cohere you live. 17C'&E is making up a threat rhat:doesn'rexisrwdistract you What's really bothering PGL4CE"is many communities .... .,. prices We fiehese that residents should be;aDow - o'have choice,o oven e ec~riaty'at 'ower costiwithoue_re uirin a.213 su Derma or+rv vole. ?,uct far c}ioice is wf3t U&E designed`Proposit+on 1 co~stop. So when yen ee TV ads for~Proposie_ion 16, re,rt?ember that most okthe-money foreach one came from peoples utility bills. The Utility Reform Network says; "lr's just wrong for P,GLtE to take':money from families; and then spend ie on a pvliticalcampaign w ~enefio-itself." Especially considering that PG&E recently paid big bonuses tp its executives after going bankrupt-just like'Wall Street.. The;I:eague of'Women Vptcrs oPCalifornia urges you tg Vote NO, joining AARP,;every newspaper tliiit's reviewed`rr, and grqups _representing,Galiforniasconsumers, taxpayers,. environmentdli'srs'an8 farmers. Vote NO to give local, nonprofit utilities-the chance to compete for your service- wirhaow cost; rencwaole energy. MICHAEL BOCCADORO, Exeattive:Director Agricultural.'Energy;Consumers Association LENNY 60LDBERG; Executiv"r Director GaliforniaTax Reform Association JANIS`R. HIRDHAMA,:President League;pfWomen Voters oECalifornia: 30 ~ Argumtntr Argument printed nn"tbu page arc tfie'apiniaai fehe antharx and bave not Gem cberkedfor a~rrrrary by any anal agency PROP IMPOSES.NEW IWO-iHIROS VOTER APPROVAL REQUIREMENT FOR LOCAL 1 PUBLIC ELECTRICITY PROVIDERS: INITIATIVE CONSTITUTIONAL AMENDMENT. I?roposition 16 does two things: hirsc, it drastically limits your choices on who provides you with electricity. Second, it makes it easier for the for-profit utilities in Cali{ornia to raise your electricity rates. ]t's-cleverly written, brcause the backers of Proposition l6 want to fool the vnters.'Pheysay c{ijs measure is about protecting taxpayers. But what it teally protects is the monopoly enjoyed by a giant,.for,profie elecuic utility. You should be :dlowed to have more choices in who provides your electricity, if chose choices would give you lower cost and better service. Vote No on Proposition 16. Most people would agree that if a local nonprofit organization wants to buy green powet at wholesale rates, atSd sell it to communities ar an affordable cost, it should be allowed to do so. But Proposition 16 makes it just about impossible. Severelylimiting your choice in the source of your electricity. No lower cost green energy. Fewer choices and higher costs. Thars what Proposition 16 does to you. Who's the role sponsor of Proposition 16? PG&E, the largest for-profit utility in the state. When this argument was written, PG&E had contributed $6.5 million ro the "yes' campaign and signaled they're prepared to spend tens of millions more. PG&E was the,only contributor ro put this proposition on the ballot. Why? Again, PG&E wants to protect its monopoly. Proposition 16 isn't about protecring taxpayers-it's about protecting PG&E's for-proftt monopoly on electricity. JtLSt read die hallos title and summary, and you'll see. As the Fresno Bee pacts, "The PG&E ballot measure (Proposition 1G) is another example ofthe initiative process goingawry'in California, of a powerful special interest seizing the initiative process for its own nan'ow benefit." Why are the opponents of Proposition lG:afraid to give taxpayersche right to vote? Voting gives you the ultimate choice on bow government spends your money. Opponents of Proposition 16 want to,deny you that right. Opponents of Proposition ]6 are nortrlling the truth. Leis be clear: • Proposition 16 dots NOT affect electric rates. • 1?roposition l6 does NOTxhreatep green power. Yes on Proposition I6 simply gives taxpayers the right to vote.before local governments spend your money or go deeper into debt rq get into the retail electricity business. Therlasctirnegovernment thought they knrw more about thr electricity business than the electric utility wmpanies, AARP urges No on Proposition 16 because srrictina com}}etirion, Proposition 16 could mean higher electricuy costs for' ou: A No vote protects you against the potential for rtpp mg rate ikes. In fact, PG&E and oth r f rv rofir uti i ' ~ e hi her a t munici al non ro t utilities. And now they want to increase rates another$5 bil ion. The Consumer Federazion of California-says VOTE NO because Like Wall`Street, PG&E paid huge bonuses co its executives, even afrec it went bankrupt and ratepayers bailed icout. Vow 1'GtkEwanes to lock-in its monopoly once and for all-so smaller, local nonprofit utilities are not allowed ro compete. Sierra Club says VOTE NO because Proposition 16 requires a 2/3 supermajority vote before communities can purchase clean power and other power at competitive prices. These community choice programs are voluntary and do not raise taxes. Proposition 16 "is a dagger aimed directly at a movement to enable municipalities to offer renewable green power to their residents in competition with private utilities,° said Michael Hilaik, a columnist for the Los Angeles Times. Say NOao.,another wasteful initiative that says one thing but really doessomething very different. Votr No on Proposition 16 to keep money in your pocket and to protect your utility choices. IEANNINE ENGLISH, California State President AARP ANDY KATZ, Chair Sierra Club California RICHARD HOCOBER, Executive Director Consumer Federation of California we had the 2001 energy crisis. Rates skyrocketed and we had rolling blackouts. The:cost ro consumers was devastating and it orated chaos throughout California. Yes on 1?tgpositioq I6. Voter approval is everyone's best protection against cosily and risky local government schemes to get,into rtSe retail electririty business. www. taxpayersrighaovote.com TERESA CASAZZA, President California Taxpayers' Association ALLAN ZAREMBERG,1'resident California Chamber oFCommcrcr ArgusnennprinrrA on rhirpage art rGe opinions of'the curl orr and~bave not G'een ~herkedfnr accuracy by any ~cial agenry. ~ Argum rntr 31 10