Examination of Witnesses (Questions 580
- 599)
TUESDAY 15 MAY 2007
MR ALISTAIR
BUCHANAN, MS
SARAH HARRISON
AND MR
CHARLES GALLACHER
Q580 Chairman:
Welcome this afternoon. I am pleased to say that we have with
us Charles Gallacher, who was not supposed to be here so thank
you very much for your attendance. It would have made our job
easy if you had been listening to the first evidence because I
am sure Committee members would like to raise a lot of questions.
Can I ask you to introduce yourselves for the record?
Mr Buchanan: If I can introduce
the Ofgem team, my name is Alistair Buchanan, Chief Executive
at Ofgem; and I am joined today by Sarah Harrison, who is Managing
Director of Corporate Affairs under which social policy sits,
and Charles Gallacher, who is our newly-appointed director for
Scotland and corporate affairs. Corporate Affairs covers both
England, Wales and Scotland.
Q581 Chairman:
Despite all the initiatives to tackle fuel poverty, why is it
getting worse? How many of the 600,000 households estimated to
be in fuel poverty at the end of 2006 were in severe fuel poverty?
Mr Buchanan: It is a great concern
and in a way we are looking at a "U" curve in terms
of numbers in fuel poverty. There were about 800,000 in 1996/1997,
and you now have the figures from the Scottish housing data down
to the bottom at 286,000; and I agree with you that, very sadly,
we are up at around 600,000 at the moment. Clearly, our aim is
to minimise the effect of the prices. As you will be aware from
the data that you have received, when you look at the impact of
fuel poverty it appears to be 50% income, 35% fuel prices and
15% energy efficiency. Quite clearly, Ofgem's focus is on the
35% prices and 15% energy efficiency, and the extent to which,
through our actions, we can alleviate those who are in fuel poverty.
Clearly, there are primary responsibilities here upon the Government
and also very onerous responsibilities upon the companies. I am
very happy to go into all of those areas, if you wish.
Q582 Chairman:
How many people are in severe fuel poverty?
Mr Buchanan: From the data that
I have seen, of that 286,000 who were in fuel poverty it would
suggest it is around 70,000.
Q583 Chairman:
But that was in 2002.
Mr Buchanan: Yes. We have obviously
spoken about that increase. It is a little bit concerning that
we have no firm data at the moment, and obviously EAS is very
helpful in giving us guidance on the data but I would assume that
those in severe fuel poverty are broadly in the same ratio.
Q584 Chairman:
Will higher oil prices and growing global demand for energy, which
are like to push up prices, constrain our ability to meet the
2016 targets? Can the targets be met by action on incomes and
on energy efficiency alone?
Mr Buchanan: I think a lot is
going to have to be done here with the effectiveness of institutional
focus, and I would have particular regard to ensuring that the
benefits that are availableagain you will have seen from
the EAS submission that they have a figure of £7.3 billion
that is not being claimedupon those that clearly need them.
We seek to get information to those who are not aware of the benefits,
for example, that a competitive market provides, which is that
of switching. At the moment that provides over £125 differential,
if you look in Glasgow at the moment, between the Scottish and
Southern offering and the Scottish Power offering. Quite clearly,
one of the responsibilities on usand I believe you have
had Energywatch in this afternoon as wellis to ensure that
we seek to get that information to consumers so that they can
take advantage of that. In addition to that, I am sure we are
going to come on to talk about pre-payment meters, and I would
be just amazed if we did notbut the advantage if you change
your payment methodology is that you could potentially save if
you were both switching and moving to a direct debit approach.
I am sure we will also get on to bank accounts and whether people
have bank accounts, but the potential saving there is £200.
On the average bill at the moment from Scottish and Southern in
Glasgow, which is around £825, you are looking at quite a
substantial saving. We take this target very seriously. That is
one of the reasons why Ofgem has continued to run the Energy Smart
Campaign. We believe, certainly from the evidence we had, that
there is active switching in the market place. Switching is not
for those in a non-vulnerable category either. You may have seen
the reports that we have published. The vulnerable categories
are split up into sub-categories and there are some categories,
for example disabled people, which appear to switch more than
the average across Gt. Britain. Sadly, those on low incomes are
switching at about 44%, whereas the average in the UK is 50%.
We have to target both those on low incomes and another category
that is falling below that 50%, which is the over 65s. We have
to target them to make sure that they understand the benefits
that they could get from changing their supplier.
Q585 Chairman:
Obviously this is a universal problem in the country; that people
are able to take benefits from the Government or the companies
but some do not know the benefits available to them and some cannot
be bothered filling out the applications and going from department
to department. How do you think we can have an awareness campaign
so that people know what benefits are available to them?
Mr Buchanan: We currently carry
that out. We work with Energywatch and we will effectively blitz
through a media campaign. Two of the three Scottish companies
have also launched focused campaigns, using charity groups to
help them target the fuel poor. For example, the Essentials tariff
campaign launched by Scottish Gas and British Gas relatively recently
offers effectively a price cut of £285 off the Scottish Gas/British
Gas bill. They are working with Help the Aged and various charities
to ensure that they get the benefits of that package, which is
not available to everybody else. Everybody else is being offered
£170 off, so they get the benefits of that package targeted
to them. Companies are carrying out part of the process; we are
carrying out part of the process; but the final element to this
is that there has got to be a degree of joined-up government here,
and this was one of the recommendations from the EAS, which we
would endorse and brought out in our energy review. One of the
roles we find ourselves in is as a facilitator amongst government.
We find that we are having to pull DWP, Defra, DTI and a number
of the interested parties together to try and find a way through.
Sarah, do you want to talk about last winter, when we did just
this?
Ms Harrison: One of the biggest
challenges in respect of fuel poverty is that of identifying those
households most in need of help, and effectively targeting a package
of measures, which is not just about helping with tariffs. As
we know, fuel poverty is a symptom of a wider problem of poverty
where the household will probably have experience of debt problems
generally or getting access to financial services. It is a whole
household approach that is needed. Building on that, in our energy
review response we basically made the case for a renewed programme
of what we called "find-and-fix"a better drive
to identify customers who are most in need, and then get a package
of measures targeted at those customers. The Government responded
to that by basically calling for a winter initiative, which took
place over the last winter, and which Ofgem's Chairman, Sir John
Mogg led. That was an exercise to bring together the Department
for Work and Pensions, the companies, agencies such as EAGA, in
order to get together an initiative to target help into pensioners
who are in receipt of pension credit. It was a pilot project and
a relatively unambitious one for a number of reasons, and it targeted
100,000 customers, but nonetheless the response to it, in terms
of the initial response from householders who received the package
of help, was very positive. That sets the kind of model for the
future in pooling together initiatives and suppliers, help from
DWP, in particular the pension service, with access to benefits,
and ultimately other financial help to get much better targeting
to households that are most in need.
Q586 Danny Alexander:
What I would like to get a handle on are the powers of Ofgem in
relation to the issue of fuel poverty that you are describing.
It is clear from the evidence we have heard that there is a significant
problem with rapidly rising fuel poverty. The points you made
earlier have generally been on either an enabling role or encouraging
people to get the best deals that are currently available within
the market. However, I think that anyone looking at the market
currently as it is for these customers at this end would have
to conclude that there is a degree of market failure here. For
example, you opened the door to social tariffs, and when the research
was done to look at social tariffs that companies were bringing
forward, it was clear that those tariffs were less good than some
of the open-market tariffs they were offering. What powers do
you have, as the regulator, to force companies to address the
situation more directly, and suppliers, and how are you using
those powers at the moment?
Mr Buchanan: It is a very good
question. Perhaps I can take a step back by way of answering it.
Formally, our primary power sits in the Utilities Act, and there
we are empowered to promote and protect consumers' interests through
markets and competition, but with some very important provisos.
One of those is to be minded towards vulnerable customers. If
you roll on three years from when the Utilities Act was struck,
which was 2000, we were then given social guidance by the Secretaries
of State of DTI and Defra. There, what was said to the board at
Ofgem, was they should be minded to social issues, but if there
is a significant financial impact from a decision, they have to
send it back to the Secretary of State to sort out.
Q587 Danny Alexander:
Can I interrupt for a second? That is a very clear explanation.
Are you required to follow that guidance or does the law empower
you to take your own path?
Mr Buchanan: We are required there,
but in addition the following year we were given the Sustainable
Energy Act, and quite clearly social is very much part of that
sustainability duty. So within the template of Ofgem the requirements
on us have changed quite substantially. In terms of dealing with
what are policing roles and what are punching roles, and what
are encouraging roles, I would highlight the policing role as
being two sets. We have a formal enforcement route. We can effectively
go down a route of saying to the companies, "You will do
something or we will put a condition on you and you will get into
trouble if you do not do that." For example, last year we
announced that back billing was going to be a thing of the past,
that the industry had to sort out an ombudsman and that they had
a year to do it. They did it. In a couple of weeks we are going
to put some very attractive licence conditions to protect consumers
over standards within the current price review that we are doing
on the gas network. That is effectively where we can enforce.
We will come on to talk about pre-payment meters in a minute.
That is an area where the industry will see that we are going
to put terms in place in the supply licence review this summer
which effectively prohibit the extremely uncomfortable practices
that three of the companies have decided to pursue on recalibration.
That is the formal route.
Q588 Danny Alexander:
On the formal front then licence conditions are clearly a major
part of the way in which you interact with energy suppliers. What
steps have you taken within licence conditionsand it sounds
as though that is something that is under review at the momentto
place greater obligations on any suppliers to tackle fuel poverty,
for example introducing social tariffs or any other methods that
are out there? It sounds like you have the power to use licensing
to drive through quite radical change in this area but you are
slightly hanging back because you think that you want to try the
less formal route first.
Mr Buchanan: Yes. As a generalisation,
I suspect as you would want to encourage we are trying to simplify
what we do, and the Better Regulation Commission has beaten us,
like it does everybody else, to try and make the terms and conditions
within the supply market more simple. We will be announcing this
summer a substantial reduction of the terms, the rules and regulations
in the market, except for the vulnerable customer. When you look
at the social tariffs, to a certain extent our reaction to that
is to say: "Is the market profoundly failing to deliver here?"
If we look into Scotland, two of the three players have substantial
propositions on the table. One is the Essentials offering from
Scottish Gas/British Gas, which was announced a few weeks ago
and is a substantial reduction£285 off the bill for
750,000 fuel poor. Clearly, they want to target them and that
is why they are working with Help the Aged in particular. It is
£170 off for everybody else. It is a quite substantial offering.
The Energy Plus scheme from Scottish and Southern, which is aimed
at, from memory, 30,000 customers, gives them a 20% cut. To a
certain extent therefore two out of the three companies in Scotland
are already doing that. Scottish Power has gone down a slightly
different route, and in terms of their social offering they have
gone down a trust-based route, particularly with regard to children,
which is quite interesting. Equally, they have taken a strategic
decision in their boardroom to play the pre-payment meter card,
so currently Scottish Power uniquely has a pre-payment charge
lower than the standard credit charge. We are looking at the industry,
and saying: "Do we need to act here?"
Q589 Danny Alexander:
You think there is not a market failure in relation to the fuel
poor.
Mr Buchanan: I think the companies
are very alive to the danger of the fact that if they do not take,
sadly, this large proportion of the population seriously, action
will be taken against them, almost certainly coming from Government.
I am very interested to see what the White Paper carries on fuel
poverty next week. That is extremely bad news for the companies
and their shareholders if that happens.
Q590 Chairman:
You are telling us that companies are very generous and meeting
their obligations. My constituents come to me, elderly people,
who were paying £30 a month on direct debit, and have received
letters from the companies saying "from next month you have
to pay £55" which is almost a 100% increase.
Mr Buchanan: To answer your question,
and I do mean this quite seriouslyI have been in the industry
since 1987 and a lot of the people who work in these companies
really do care about social tariffs. One of the reasons they chose
to work in a utility rather than another kind of company is because
they do care. It is worth saying that. Then you can stand back
and say, "Yes, but ultimately they are answerable to their
shareholders." However much they might care, they have to
deliver a dividend and a profit figure to keep their shareholders
off their back. One of the naked self-interest aspects of fuel
poverty to them is that should they fail in that, then the shareholder
is fully alive to the fact that almost certainly the Government
will take action against the companies, and that ultimately will
be far worse for the shareholder than if the company had taken
the initiative.
Q591 Chairman:
There were 286,000 living with fuel poverty in Scotland, and that
figure has increased to 600,000. One of the main reasons that
we have found has been the increase in oil and gas prices. The
Scottish Executive has more initiatives and the Government has
more initiatives to help eliminate fuel poverty, but just one
single issue, the increase in oil and gas prices, has increased
the number of people in fuel poverty to 600,000.
Mr Buchanan: Yes, indeed. We have
been through a very tumultuous period. You can see from the submission
we gave you that wholesale prices from the middle of 2003 to the
middle of 2006 rose by 190% and retail prices rose by just short
of 50%. It has been a very uncomfortable period. For the ten years
before that UK prices were amongst the lowest in Europe. In fact,
even through the last three years the UK domestic gas price has
been amongst the lowest of the EU countries. Frankly, that is
fat all good to somebody who is in fuel poverty. They do not care
what the UK relative position is with another EU country, but
it is worth putting an element of background on to the canvas
there. We have this problem. How do we try and help the lot of
the fuel poor? We will go down the route of promoting the opportunity
to get a substantial amount off their bill, which effectively
the market has provided. We will go down the route of providing
moneys for researchand Sarah will talk more about the research
we have carried out with the University of Bristol on targeting.
There are two elements we have not discussed yet, which we are
very responsible for. One is low usage, and that brings into play
where we might go on smart metering; and the other is on barriers
that Ofgem might help to knock down. This is with particular regard
to the rural communities. Some of the rules and regulations with
regard to local microgen were, frankly, absurd. Maybe we came
to that too late, but last year we started to sort that out. I
think there are a number of things that Ofgem can do, but I was
very taken by the EAS submission to yourselves and their recent
report because the first four issues that EAS focused on were
all things that the Government could do. I am not advocating that
Ofgem should not continue to do what it is doing, and also to
give consumers confidence that we will use both our formal policing
powers and our informal name-and-shame powers, which we have done
in the last couple of years; but it should pick the right moment
to use those powers. We will do our very best to try and alleviate
it.
Q592 Chairman:
Do you think the gas and oil companies have to do more to tackle
fuel poverty, and that, as a regulator, Ofgem has to do more to
deal with fuel poverty?
Mr Buchanan: Yes. I think any
relaxation in the effort that we place on the programmes that
I have outlined to youwe would be failing the consumer
profoundly.
Q593 Danny Alexander:
It sounded like, from your comment on the Energy Action Scotland
submission that you were implying that there is more that the
Government could do to strengthen your hand in making more progress
on this issue. Are there specific things that you would have in
mind that Government could do to enable you to press the energy
companies to deliver more?
Mr Buchanan: That is very interesting.
I will let Sarah answer that, but can I clarify something in case
there is a misunderstanding? From my memory of the EAS submission
to yourselves, the top four recommendations were about ensuring
that the winter allowance was properly slanted. Has the Government
looked at VAT from the increase in prices and tried to utilise
that? It was all very much focused on fiscal measures or how you
handle the benefits rather than, "if you do this it will
help Ofgem's lot".
Ms Harrison: Can I make one comment
on the fuel poverty target and the way we are measuring fuel poverty,
and then I would like to come back on social tariffs in answer
to your question? Do not misunderstand my remarks. Ofgem does
not want any attention taken away from the need to get action
to help customers who are finding it difficult to keep themselves
warm and comfortable in the winter; but the present measurement
of fuel poverty is based around the relationship to the energy
bill. What it does not allow, for example, is income from the
winter fuel allowance to be taken into account in considering
the householder's position. One of the points we made in our energy
review response was that for the longer term it might be worth
taking a wider look at whether this is the right way to measure
this issue, or whether a measurement that ought to get more an
assessment of incomes, an assessment of housing condition, as
well as energy efficiency, might be a better way to get a stronger
view on how we are going about the business of helping households
where it is most needed. My second point on the social tariffs,
which is your point that Ofgem had taken a step to give clarity
to suppliers on how they could develop social tariffs in a competitive
market; and that saw an upsurge in the number of initiatives and
measures that suppliers produced, and we very much welcomed that.
Your point was whether those are real, or whether is some question
over the quality of some of those measures. That is very much
the area where Ofgem does have a role, to keep the companies in
check and call them to account and make sure that the measures
that are operating under the banner of social tariffs are indeed
such. In 2005 we did substantial research on all the different
measures that the companies employed and evaluated those, and
will do so again. We will look at all the measures and develop
a reporting framework so that customers have more visibility of
the value of some of these measures, and whether they really are
going to help, or whether customers might be better to switch
to a different provider or to switch to a different tariff. The
other benefit of shining a bright light on what the suppliers
are producing and the value of that is that it engenders stronger
competition between them, which is more advantageous to customers,
and it helps consumer advisors, those on the front line. Even
within your own constituency office you might be trying to give
advice to customers on what might be best for them, but it gives
more visibility and more transparency on these matters and whether
they are going to be of benefit to customers. That is the way
we very much see a role for ourselves, keeping the companies in
check and shining a bright light on what is happening, in order
to promote further improvements for households.
Q594 Danny Alexander:
I share your agenda of shining a bright light to try and understand
the reasons behind some of these things. The comparison was made
with continental consumers. As I understand it, in some continental
countries social tariffs are available that allow, for example,
a rising tariff where the first proportion of units would be entirely
free and the tariffs would rise thereafter. In other places standing
charges are not payable and the entire thing is done through the
tariff. Are you saying that companies in this country would be
entirely free to develop products of that nature?
Mr Buchanan: They are, and it
is not quite the product that you mentioned because there have
been fixed deals on offer; indeed 4 million odd, 16% of all consumers,
have missed the last three years' price horrors because they were
locked into those deals, so companies have offered them. Coming
back to development of, frankly, more sophisticated tariffs, I
am aware of one of the three Scottish companiesand it would
be improper for me to say which oneis very close to launching
quite an exciting tariff in this area.
Q595 Danny Alexander:
I think I know the one you mean, but I will not mention it either.
Looking specifically at the Scottish context, the evidence we
have seen suggests that consumers in Scotland pay more for their
energy than consumers in the rest of the UK. Why do you think
that is?
Mr Buchanan: At the moment the
information I will give you obviously is that that is not the
case. The very latest figures I was given on my way here is that
the wholesale price comparison is 855 plays 858, so it is extremely
close on dual fuel between an English and a Scottish customer.
However, back in 2003/2004, the Scottish consumer was paying £40
more, so there does appear to have been an equalisation.
Q596 Danny Alexander:
We have heard evidence about smarter metering and initiatives
like micro generation, which might have an impact in rural areas
where you are off the mains gas network, and you have electricity
and might be relying on heating oil, which is even more expensive
than gas and a major cause of fuel poverty, where houses are old-fashioned
stone houses which are much harder to put the energy efficiency
measures into. On those two things, what needs to happen to encourage
those to take off so that customers in rural areas can benefit
from some of the measures that urban customers have?
Mr Gallacher: These are two initiatives
that we are extremely keen to explore. We have been working with
others in Scotland, in particular the Scottish Executive, on micro
generation. Clearly, if micro generation devices can be fitted
to the off-gas network in rural areas, there is a strong possibility
that it could alleviate fuel poverty. At the moment there is a
trial on the go sponsored by the Scottish Executive through their
central heating programme with the Energy Savings Trust in Edinburgh,
where they are looking at 170 rural fuel poor households and trialling
different devices over last and next winter to see if they can
make a difference. That is something we are extremely interested
in, and the Ofgem role there would be, as Alistair said before,
to make sure there are not any barriers to allowing that to happen.
That is where smart metering comes into play. Clearly, if you
are in the fortunate position of being able to sell power back
to the network, it is important that you are able to measure that
power to make sure you are getting a reasonable deal, and that
would be one aspect of smart metering. Probably a more important
aspect would be the provision of information and one that is understandable
to normal householders to enable them to adjust their consumption
perhaps for different time of day tariffs, or perhaps to save
overall on their consumption by being able to understand the data
from the meter.
Mr Buchanan: It is very much linked
to Ofgem, but not in our regulatory role, in our auditing role.
One of the real benefits that came out of the Lazarowitz Bill,
which came out last year, was the aggregation for individuals
of the renewable obligation certificate. This is not a fun figure:
80,000 people in the country have local microgen or CHP units
in the home: only 185because the administration had been
so nightmarish to get throughhave been seeking to get the
benefits of that. There will be aggregation, and this means that
this subsidy will be made available to those who have these local
individual units, which is very good news indeed.
Q597 Danny Alexander:
In relation to the energy efficiency commitment, which is another
way of getting measures in to help people improve their homes
through the energy companies, I am concerned that the way the
energy efficiency commitment operates at the moment mitigates
against improvements being made to homes in rural areas, because
crudely speaking if you are an energy company with a customer
base in, for example, the north of Scotland and the south of England,
then in terms of the number of houses that you can improve for
the money, you are much better advised to invest in the low-hanging
fruit of relatively easy-to-improve homes in the south of England
than, for example, the rather more difficult and expensive homes
to improve in the north of Scotlandold-fashioned stone-built
houses being one example. Are you looking again at the way the
energy efficiency commitment operates to try and ensure the benefits
are spread more to the houses that might need them most where
the benefit would be greatest in terms of fuel poverty?
Mr Buchanan: We have been active
supporters when the EEC goes to its next phase in 2008 of keeping
the priority group at 50%. As you know, there have been some pressures
to try and bring that down. One of the things we did in the last
couple of years was to effectively carry out a review of how many
people knew they were in the priority group. This comes back to
information we were talking about on switching. Seventy-five per
cent did not know they were in the group so you have got this
opportunity, and again this falls back on Government and falls
on us to seek to have involvement in getting much better information
across. There are concerns, looking at the next phase of EEC.
It looks as though microgen will be in the next phase, and one
of the concerns we have, for example, is to what extent it could
gobble up all the EEC and therefore leave nothing for anything
else. These are issues that we are presenting. We are not the
decision-maker hereDefra is. We are just one of many voices
into Defra's decision.
Ms Harrison: I do not have much
to add to that apart from the fact that we welcome very much the
scale, which is substantially greater than its predecessors. We
want to ensure there is fair treatment between measures and effects
on priority and non-priority groups. We also welcome broadening
the EEC, especially in respect of micro generation and smart metering.
We also welcome the potential for more flexibility to allow suppliers,
provided they have met certain obligations in respect the priority
group, to flex some of their obligation out into a non-priority
group if that is the most efficient way to meet those targetsbut
a limited degree of flexibility to ensure focus still remains
on those who are most in need.
Mr Buchanan: Coming back to rural
communities, I cannot say too much because we are waiting for
the White Paper, but my board has not seen our recommendations
for the price review for the local gas network, but they will
do in two weeks' time and then they will be publishing that shortly
thereafter, but they will be very pleased to write to you, Chair,
or to any of your members individually about what we are proposing.
It is a step forward in terms of the rural network and where you
might be able to take that.
Q598 Mr Davidson:
I apologising for arriving late for your evidence. Can I pick
up the point about dialogue between yourselves and other bodies?
I particularly want to clarify the level of discussion and dialogue
between yourselves and Government here, the Scottish Executive
and other voluntary and charitable groups in the area. One of
the things that struck us on a number of occasions was that there
seemed to be a large number of players in this field and a substantial
degree of duplication and confusion about who exactly is doing
what. I am not quite sure whether or not you see yourselves as
playing a role in coordinating all that, or whether you are trying
to keep yourselves as distant from it as possible.
Mr Buchanan: I think you do put
a finger on a very uncomfortable aspect of this issue. We raised
it in response to the energy review. EAS raises it again in its
submission to you. Getting a focus on to this issue would be extremely
good news. We are actively involved, both hereand we are
also a member of the Scottish Executive's Fuel Poverty Forum.
Charles and his team are actively involved in Scotland. I spoke
at the EAS conference. I know you are regularly working on this.
We are as involved as we can be, but in terms of particularly
benefits, we try to say, "here is the issue". If you
look at Fuel Direct, in the mid-nineties it had 230,000 people,
very much helping them. That withered to about 43,000 in 2004
and it is now down to about 24,000. I went up to see Scottish
Gas on one of my walks around the companies, which I like to do
fairly regularly, and wanted to know about this. One of the answers
they gavebut it might not be the answerwas
that only a little time back DWP seconded somebody into the utility
companies. There was a DWP secondee in Scottish Gas, and they
went with the Scottish Gas employees to those who are fuel poor
and therefore they could work it through in a fairly holistic
way. What now happens is that the company has to say to the individual,
"You have to approach DWP; we cannot, you have to do it".
You can immediately see a barrier that is created to ensure that
that kind of route can be created. To me this is just a classic
example of the kind of thing we have to try and break.
Q599 Mr Davidson:
I can see how that possibly is the fault of both the DWP and the
individual companies.
Mr Buchanan: I am not trying to
lay fault.
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