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Document 1 of 15.

July 18, 2000, Tuesday

SECTION: PREPARED TESTIMONY

LENGTH: 5426 words

HEADLINE: PREPARED TESTIMONY OF RED CAVANEY PRESIDENT AND CEO AMERICAN PETROLEUM INSTITUTE

BEFORE THE SENATE FINANCE COMMITTEE SUBCOMMITTEE ON TAXATION

SUBJECT - TAX ISSUES RELATING TO U.S. DEPENDENCE ON OIL IN THE TRANSPORTATION SECTOR

BODY:
I. INTRODUCTION

These comments are submitted by the American Petroleum Institute (API) for inclusion in the record of the July 18, 2000 Senate Finance Committee Subcommittee on Taxation and IRS Oversight hearing on federal income tax issues relating to proposals to lower U.S. dependency on foreign oil. API represents almost 500 companies involved in all aspects of the oil and gas industry, including exploration, production, transportation, refining, and marketing.

For over half a century, the United States has relied to varying degrees on imports for a portion of its oil needs. As dependence on global oil markets has grown, we have learned that this dependence carries both opportunities and risks. On the one hand, it affords us access to energy supplies less costly than could be produced domestically. On the other hand, it exposes us to two inherent risks associated with that marketplace, namely the potential for short-term supply interruptions, and the potential for long run vulnerability to adverse actions by OPEC. But the experience of growing dependence has also taught us a few important lessons about the potential for U.S. policies to successfully manage these risks, and the hazards of misguided policies that have aggravated them. As this committee proceeds with its task, it is essential that we retain an awareness of these lessons. At the start, we should be clear about the nature of the problem being addressed. It is frequently--too frequently--characterized as the "import problem" faced by the "domestic industry," usually defined as the producers of domestic oil and gas. In this guise, our industry is often portrayed as hapless high cost producers seeking protection from the harsh discipline of the global marketplace in which they find themselves. This portrayal could not be further from the truth. First, the U.S. petroleum industry does not consist solely of producers of domestic oil and gas. Predominantly, upstream producers are involved in global operations, and drilling and support companies in the United States are increasingly dependent on the global activities of these and other companies around the world. Second, the U.S. petroleum industry is one of the most technologically advanced and competitive players in the world economy. Our recommendations to this committee are not a request for the construction of protectionist barriers, but a request for removal of the barriers that currently impede our ability to compete, both domestically and abroad. Seen in this light, the problem is not one of imports, but one of preserving the competitiveness of U.S. industry in the global marketplace.

Today, that global market is expanding. Oil is essential to sustaining the economic growth of both the U.S. and the global economy, and recent forecasts expect global demand to expand by over 15 million barrels per day in the next decade. While the U.S. industry is poised to play a key role in that expansion, current U.S. policies impede our participation. Domestically, U.S. oil production has fallen by nearly 3.7 million barrels a day since 1970, a loss of about 38%. Ironically, some of the most severe recent declines have been on our most promising frontiers, such as Alaska, despite increasingly optimistic assessments of the underlying resource base in those areas. Internationally, while the overseas production of U.S. companies has increased, it continues to lag the growth experienced by a host of competitors, due in part to U.S. tax policies that put these U.S. firms at a competitive disadvantage.

Realistically, we cannot expect to supply all of the oil required for the growth of the U.S. economy from domestic sources. Imports will be a part of any realistic scenario, and we need to accept that fact and work to maintain the global competitive position of the U.S. oil and gas industry. If U.S. companies cannot economically compete overseas, those foreign resources will still be produced. However, they will be produced without the security of supply that would be realized with U.S. firms producing the oil, any benefit to the U.S. economy and without U.S. companies, their shareholders, or American workers deriving any direct or indirect income from the foreign production activity.

One of the central lessons learned in our experience over the past several decades is that the principal risks associated with global oil markets have arisen from excessive concentration of supply into "pockets of vulnerability." These pockets may be regional, such as the Persian Gulf, economic, such as the OPEC cartel, or political, such as Iraq. As supply becomes unduly concentrated into such groupings, consumers grow increasingly vulnerable to supply interruptions or restrictions, whether intended or accidental. The only viable response to that risk, which is the one we now face-- must be the sustained development of diverse sources of supplies---both domestically and internationally. We effectively countered OPEC in the 1980s with the development of massive new sources of supply--in Alaska, on the Outer Continental Shelf, in the North Sea, and in numerous new locations scattered throughout the globe. Competition was. and is, the key to reducing dependence on OPEC, and the challenge today is to renew the competitive fervor that so effectively managed this risk in the past.Ironically, in much of the world this growth in non-OPEC supply continues, though not in the United States. Restrictions on the ability of U.S. firms to supply energy, both domestic and international, are increasingly imposed with casual regard to their implications for ensuring the future availability of oil supply.

Domestically, access to federal land has become an acute problem. Since 1983, access to federal land in eight Western states has declined by more than 60 percent. In Alaska, the industry is being denied access to some of the most promising areas of the domestic resource base, in the National Petroleum Reserve and the Arctic National Wildlife Refuge. Offshore, continued government moratoria on key acreage impedes development, and restricts the application of some of our most promising new technologies. These restrictions flourish despite the exemplary environmental record that the industry has compiled in its development offshore and in sensitive onshore areas.

Internationally, the U.S. has a strong strategic interest in the growing availability of new supplies, both as a source of its own imports and as a source of energy to fuel economic prosperity elsewhere in the world. The U.S. petroleum industry has much to offer in terms of sustaining this supply diversity via the contributions of U.S. energy companies to supply growth outside of the United States. Numerous new opportunities have opened up worldwide over the past decade-- in Russia, the Caspian Sea Region, Asia, West Africa and Latin America. Generally, U.S. firms in recent years have been welcomed by many of these new frontier countries for their experience, capital and technical prowess. Increasingly, however, these activities are being threatened by the unintended consequences of two sets of U.S. policies, namely the increasingly adverse tax treatment of foreign source income earned by U.S. companies operating overseas, and the growing tendency for the United States to utilize unilateral economic sanctions against oil producing countries as an instrument of foreign policy.

Changes in U.S. international tax policy will help to enhance the global competitive position of the U.S. oil and gas industry.

The U.S. international tax regime already imposes a substantial economic burden on U.S. multinational companies by exposing them to potential double taxation, that is, the payment of tax on foreign source income to both the host country and the United States. In addition, the complexity of the U.S. tax rules imposes significant compliance costs. As a result, U.S. companies are forced to forego foreign investment altogether based on projected after-tax rates of return, or they are preempted in bids for overseas investments by global competition. Congress can help to stem further losses in the global competitive position of the U.S. oil and gas industry by adopting tax measures that allow U.S. oil and gas companies to compete more effectively both at home and in the international marketplace.

We cannot afford to constrain the development of supplies at home and abroad without regard to the potential vulnerability threatened by such neglect. Recent Department of Energy (DOE) and International Energy Agency (IEA) forecasts expect daily demand for oil to grow by nearly 15 million barrels over the next decade. It must be remembered that oil and gas projects require large amounts of capital and are high risk, long lead-time ventures. The tax treatment of the financing and structuring of these ventures is one of the essential elements of decisions whether to proceed. If allowed to compete, our industry has the capability to capture a significant share of the expected growth in demand, limiting OPEC's market share and contributing to the diversity of global supply. But barriers to supply expansion offer the threat of renewed vulnerability. Given this prospect, the current crisis should be a wakeup call to begin to tear down these barriers.

II. DOMESTIC TAX INCENTIVES

While most other countries encourage energy development, flawed public policies-especially discriminatory tax provisions and excessive restrictions on access to federal lands---continue to place substantial restrictions on the exploration and production of oil and gas in this country. The most important thing that Congress and the Administration can do is to change these policies to permit the economic recovery of domestic reserves, and thus help reduce U.S. reliance on imported oil.

In 1999, a united oil and gas industry proposed a series of tax incentives designed to spur domestic oil and gas production. The need for these incentives has only intensified over the last year as OPEC has reestablished its ability to profoundly impact the available supply of oil--and most importantly, the price paid by consumers. While not the sole answer to ensuring adequate U.S. oil and gas supplies, tax measures such as Alternative Minimum Tax (AMT) relief, expensing of geological and geophysical (G&G) costs and delay rental payments, a marginal domestic oil and natural gas well production credit, and eliminating limitations on use of percentage depletion of oil and gas by independent producers will promote U.S. exploration and production. Most of these items were previously adopted by both the Senate and the House of Representatives as part of the conference report to the Taxpayer Refund and Relief Act of 1999 (H.R. 2488), which was ultimately vetoed by President Clinton. Expanding the enhanced oil recovery (EOR) credit to include certain nontertiary methods would also serve to encourage increased domestic petroleum activity.

Alternative Minimum Tax

The Alternative Minimum Tax was intended as an advance payment of federal income tax, and therefore, AMT payments are creditable in future years, though only against regular tax liability and not tentative AMT. However, companies within the capital intensive petroleum industry often find themselves in a position where they are consistently unable to use their AMT credits because their regular tax liability in future years does not exceed the tentative AMT. For those companies, the AMT constitutes a permanent tax increase and decreases the economic viability of certain domestic operations. In order to reverse the targeted adverse impact of the AMT on the U.S. oil and gas industry, Congress should, at a .minimum, eliminate the preference for intangible drilling and development costs (IDC), eliminate the depreciation adjustment for oil and gas assets placed in service prior to 1999, eliminate the impact of IDC and depreciation on oil and gas assets from the Adjusted Current Earnings (ACE) adjustment, and permit the EOR credit and Section 29 credit to reduce AMT. This proposed AMT relief would phase in and out as oil and natural gas prices fall and rise between specified levels, thereby providing the greatest assistance to producers in times of low prices.

Another non-industry specific way to mitigate the adverse impact of the AMT would be to allow AMT credits to be applied against future tentative AMT. This specific provision was included in the vetoed 1999 tax bill.

Geological and Geophysical Expenses

Oil and gas exploration companies incur huge up front capital expenditures, including geological and geophysical (G&G) expenses, in their search for new oil reserves. G&G expenses include costs incurred for geologists, surveys, and certain drilling activities, which are incurred to help oil and gas companies locate and identify properties with the potential to produce commercial quantities of oil and/or gas. Currently, these costs must be capitalized, suspended and then amortized over a period of years in the form of cost depletion after production begins. Forcing oil and gas companies to capitalize G&G costs exacerbates the economic burden imposed by these significant cash outlays that must be made prior to or at the beginning of an exploration project. In order to encourage the discovery of new domestic oil and gas reserves, and thus increase domestic supply, Congress should pass legislation to permit the expensing of G&G costs.

In addition to having been included in the vetoed 1999 tax bill, H.R. 2488, the expensing of both G&G costs and delay rental payments, was included in President Clinton's proposal to "strengthen America's energy security," introduced earlier this year. In addition, these items were also part of subsequent legislation (S. 2265), introduced by Sen. Kay Bailey Hutchison in March of this year, as well as the National Energy Security Act of 2000 (S. 2557), introduced by Senate Majority Leader Trent Lott in May.

Delay Rentals

Delay rentals are paid by oil and gas exploration companies to defer the commencement of exploration and production on leased property without forfeiting the lease. Treasury regulations and case law clearly support the option on the part of a lessee to expense or capitalize delay rental payments, and until 1987, this right was essentially uncontested. However, with the 1986 enactment of the uniform capitalization rules of Section 263A, the IRS began to challenge the deductibility of delay rentals during audits. In 1997, the IRS unequivocally adopted the position that for tax years beginning after December 31, 1993, delay rentals had to be capitalized unless the taxpayer could establish that the lease was acquired for some reason other than development. This position ignores forty years of history and long-established regulations. Congress should pass legislation that clarifies and reaffirms the long-standing rule that has permitted delay rentals to be expensed rather than capitalized. By decreasing the economic burden of paying delay rentals, more capital will be available for exploration and production.

Marginal Well Production Credit

A marginal well production credit of $3 per barrel for the first three barrels of daily production from an existing marginal oil well, and a 50 cent per thousand cubic feet (Mcf) tax credit for the first 18 Mcf of daily natural gas production from a marginal well, would help producers ensure the economic viability and slow the shutting-in of marginal wells. Like the proposed AMT relief, the credits would phase in and out as oil and natural gas prices fall and rise between specified levels providing the greatest benefit to producers when prices are low. Finally, the credit should be allowed against both regular and alternative minimum tax and to be carried back ten years.

This marginal oil and gas well production credit proposal was also included in S. 2265 and S. 2557, and the President pledged to continue to examine measures to preserve marginal well production in his March proposal.

Percentage Depletion

Another way Congress could assist the domestic industry would be to permit, by annual. election, elimination of the 65 percent taxable income limitation on percentage depletion. In addition, independent producers and royalty owners should be permitted to carry forward percentage depletion deductions for ten years.

EOR Credit

Finally, the Enhanced Oil Recovery (EOR) credit provides a credit equal to 15 percent of costs attributable to qualified enhanced oil recovery projects. Since the enactment of the EOR credit in 1990, new technologies have greatly enhanced the ability of domestic producers to recover additional domestic reserves with minimal environmental impacts. Extending the EOR credit to horizontal drilling, gravity drainage, cyclic gas injection, and water flooding would greatly enhance the economic viability of these oil recovery methods as a means to increase domestic production.

III. RELIEF FROM DISCRIMINATORY INTERNATIONAL TAX RULES

In order to survive, the oil and gas industry must operate where it has access to economically recoverable oil and gas reserves. Since the opportunity for domestic reserve replacement has been substantially restricted by both federal and state government policies, the tax treatment of international operations is critical to the industry's continued ability to supply the nation's hydrocarbon energy needs.

With OPEC market share and influence once again rising, a key concern of federal policy should be that of maintaining the global supply diversity that has been the keystone of improved energy security for the past two decades. The principal tool for promotion of that diversity is active participation by U.S. firms in the development of these new frontiers. Therefore, while federal tax policy should promote domestic oil and gas production, it should also seek to enhance the competitiveness of U.S. concerns operating abroad, not reduce it with added tax burdens such as new limitations on the use of foreign tax credits.

Tax measures that would enable U.S. companies operating overseas to better compete in the global oil and gas business environment include, among others, repeal of Section 907, accelerate repeal of separate limitation basket requirement for dividends received from 10/50 companies (i.e., foreign companies owned between 10 and 50 percent by U.S. owners), provide look-through treatment for sales of partnership interests, provide look-through treatment for interest and royalties from 10/50 companies, allow recapture of overall domestic losses, extend carryback and carryforward periods for foreign tax credits, and modify the interest allocation rules to permit allocation on a world- wide basis. In addition, Congress should continue to reject Administration attempts to increase taxes on the foreign source income of U.S. oil and gas companies.

The Foreign Tax Credit Is Intended to Prevent Double Taxation

Since the beginning of Federal income taxation, the U.S. has taxed the worldwide income of U.S. citizens and residents, including U.S. corporations. The FTC is designed to allow a dollar for dollar offset against U.S. income taxes for taxes paid to foreign taxing jurisdictions in order to avoid double taxation.

Basic Rules of the FTC

The FTC is intended to offset only U.S. tax on foreign source income. Thus, an overall limitation on currently usable FTCs is computed by multiplying the tentative U.S. tax on worldwide income by the ratio of foreign source income to worldwide taxable income. The excess FTCs can be carried back two years and carried forward five years, to be claimed as credits in those years within the same respective overall limitations.

The overall limitation is computed separately for not less than nine "separate limitation categories." Separate limitations apply for income: (1) whose foreign source can be easily changed; (2) which typically bears little or no foreign tax; or (3) which often bears a rate of foreign tax that is abnormally high or in excess of rates of other types of income. In these cases, a separate limitation is designed to prevent the use of foreign taxes imposed on one category to reduce U.S. tax on other categories of income. Examples of foreign source income that must be placed in separate baskets include dividends received from 10/50 companies, gains on the sale of foreign partnership interests, and payments of interest, rents and royalties from non-controlled foreign corporations and partnerships.

Foreign Oil and Gas Extraction Income and Foreign Oil Related Income: Code Section 907

Under the separate basket rules, foreign oil and gas income falls into the general limitation basket for purposes of computing the overall FTC limitation. But before this limitation for general operating income, U.S. oil companies have to clear an additional tax credit hurdle.

Section 907 limits the utilization of foreign income taxes on foreign oil and gas extraction income (FOGEI) to that income multiplied by the current U.S. corporate income tax rate. The excess credits may be carried back two years and carried forward five years, with the creditability limitation of Section 907 being applicable for each such year.

Congress intended for the FOGEl and FORI rules to purport to identify the tax component of payments by U.S. oil companies to foreign governments. The goal was to limit the FTC to that amount of the foreign government's "take" which was perceived to be a tax payment versus a royalty as payment for the production privilege. But even the so identified creditable tax component should not be used to shield the U.S. tax on certain low-taxed other foreign income, such as shipping.

These concerns have been adequately addressed in subsequent administrative rulemaking and legislation. After several years of discussion and drafting, Treasury completed in 1983 the "dual capacity taxpayer rules" of the FTC regulations which set forth a methodology for determining how much of an income tax payment to a foreign government will not be creditable because it is a payment for a specific economic benefit. Such a benefit could, of course, also be derived from the grant of oil and gas exploration and development rights. These regulations have worked well for both IRS and taxpayers in various businesses (e.g., foreign government contractors), including the oil and gas industry. In addition, the multiple separate basket rules were enacted in 1986, restricting taxpayers from offsetting excess FTC's from high-taxed income against taxes due on low-tax categories of income.

Since the Section 907 legislation has been duplicated and improved in subsequent legislation and rulemaking, that Section has been rendered obsolete. Further, Section 907 has raised little if any additional tax revenue because excess FOGEl taxes would not have been needed to offset U.S. tax on other foreign source income. Nevertheless, oil and gas companies continue to be subject to burdensome compliance work. Each year, they must separate FOGEl from FORI and the foreign taxes associated with each category. These are time consuming and work intensive analyses, which have to be replicated on audit. Section 907 should be repealed as obsolete. This would promote simplicity and efficiency of tax compliance and audit with minimal loss of revenue to the government.

In fact, the Senate and House last year passed legislation that would repeal Section 907. Unfortunately, the President vetoed H.R. 2488.

Dividends Received from 10150 Companies

The 1997 Tax Act repealed the separate basket rules for dividends received from 10/50 companies, effective after the year 2002. A separate FTC basket will be required for post-2002 dividends received from pre-2003 earnings. Because of these limitations, U.S. companies operating overseas will continue to forego foreign projects through noncontrolled 10/50 corporations. Accordingly, the repeal will remove significant complexity and compliance costs for taxpayers and foster their global competitiveness.

The repeal of the separate limitation basket requirement with respect to dividends received from 10/50 companies therefore should be accelerated. This provision has been included in the last few Administration budget proposals, as well as in the vetoed 1999 tax bill, H.R. 2488. In addition, the requirement of maintaining a separate limitation basket for dividends received from earnings and profits accumulated before the repeal also should be eliminated.

Look.through Treatment for Sales of Partnerships

The distributive share of an at least 10% U.S. partner of a foreign partnership follows the partnership's income FTC basket classification. On the other hand, no such lookthrough applies to the gain on the sale of a 10% or more partnership interest in a foreign partnership. U.S. tax rules treat the gain as separate basket passive income, thereby limiting the opportunity of FTC utilization.

Economically, any gain on the sale of the partnership interest is attributable to unrealized or undistributed income. It is not only inequitable but also counterintuitive for the legal form of the value realization to control the FTC basket characterization. Accordingly, for a 10% or greater partnership interest, look-through should apply to the gain in the same way that it applies to the distributive share of partnership income.

Look-through Treatment for Interest, Rents, and Royalties With Respect To NonControlled Foreign Corporations and Partnerships

U.S. companies are often unable, due to government restrictions or operational considerations, to acquire controlling interests in foreign corporate joint ventures. To align their position with general participation situations in foreign projects, they also should be granted the look-through treatment for interest, rents and royalties received from foreign joint ventures as in the case of distributions from a CFC (controlled foreign corporation).

Current tax rules also require that payments of interest, rents and royalties from noncontrolled foreign partnerships (i.e., foreign partnerships owned between 10 and 50% by U.S. owners) must be treated as separate basket income to the joint venture partners. Again, as in the case of corporate joint ventures, look-through treatment should be extended to these business entities. This would abolish distinctions in treatment of distributions that are based on participation percentages that may be beyond the control of the U.S. taxpayer.

Recapture of Overall Domestic Losses

When foreign source losses reduce U.S. source income (overall foreign loss or OFL) in a tax year, the perceived tax benefit has to be "recaptured" by resourcing foreign source income in a subsequent tax year as domestic source. Of course, this recharacterization reduces the ratio of foreign source income to total income, which in turn reduces the ratio of tentative U.S. tax that can be offset against foreign taxes. However, if foreign source income is reduced by U.S. source losses, there is no parallel system of "recapture." Taxpayers are not allowed to recover or recapture foreign source income that was lost due to a domestic loss, resulting in the double taxation of such income. The U.S. losses thus can give rise to excess FTC's which, due to the FTC carryover restrictions, may expire unused. Only a corresponding re-characterization of future domestic income as foreign source income will reduce the risk that FTC carryovers do not expire unused.

Foreign Tax Credit Carryover Rules

The utilization of income taxes paid to foreign countries as FTC is limited to the U.S. tax that is owed on the foreign source income. Thus, an overall limitation on currently usable FTC's is computed by taking the ratio of foreign source income to worldwide taxable income and multiplying this by the tentative U.S. tax on worldwide income. The excess FTC's can be carried back to the two preceding taxable years, or to the five succeeding taxable years, subject in each of those years to the same overall limitation. If the credits are not used within this time frame, they expire.

Because of the ever-increasing limitations on the use of FTC's, coupled with the differences in income recognition between foreign and U.S. tax rules, excess credit positions are frequent. The present law's short seven-year carryover (two-year carryback and five-year carryforward) period easily results in credits being lost, most likely resulting in double taxation.

The long-standing policy of not taxing the same income twice dictates that the carryover periods for excess FTCs should be extended to allow for a five-year carryback and a 15-year carryforward.

Allocation of Interest Expense

Current law requires the interest expense of all U.S. members of an affiliated group to be apportioned to all domestic and foreign income, based on assets. The current rules deny U.S. multinationals the full U.S. tax benefit from the interest incurred to finance their U.S. operations. For example, if a domestically operating member of a U.S. tax consolidation with foreign operations incurs interest to finance the acquisition of new environmental protection equipment, a portion of the interest will be allocated against foreign source income of the group and therefore become ineffective in reducing U.S. tax. A U.S. subsidiary of a foreign corporation (or a U.S. corporation -- or affiliated group without foreign operations) would not suffer a comparable detriment.Unless allocation based on fair market value of assets is elected, allocation of interest expense according to the adjusted tax bases of assets assigns too much interest to foreign assets. For U.S. tax purposes, foreign assets generally have higher adjusted bases than similar domestic assets because domestic assets are eligible for accelerated depreciation while foreign-sited assets are assigned a longer life and limited to straight-line depreciation. For purposes of the allocation, the earnings and profits (E&P) of a CFC is added to the stock basis. Since the E&P reflects the slower depreciation, the interest allocated against foreign source income is disproportionately high.

Rules similar to the Senate version of interest allocation in the Tax Reform Act of 1986 would alleviate the current anti-competitive results by permitting the taxpayer to elect to allocate interest on a worldwide basis. The allocation group would include all companies that would be eligible for U.S. tax consolidation but for being foreign corporations. The interest allocated to foreign source income under this worldwide taxpayer rule would be reduced by the interest that would be allocable to foreign source income. Second, as an exception to the "one taxpayer" rule, "stand alone" subsidiaries could elect to allocate interest on certain qualifying debt on a mini-group basis, i.e., looking only to the assets of that subsidiary, including stock.

Furthermore, taxpayers should be allowed to elect to use the E&P bases of assets, rather than the adjusted tax bases, for purposes of allocating interest expense. Use of E&P basis would produce a fair result because the E&P rules are similar to the rules now in effect for determining the tax bases of foreign assets.

This measure, too, was included in the 1999 tax bill, H.R. 2488, vetoed by President Clinton.

IV. SUMMARY

Our industry strongly supports efforts to encourage increased petroleum activity in the United States through tax incentives. These incentives would further promote the use of new technologies for exploration, development and production, and would help to maintain the economic viability of mature production sites. Notwithstanding the benefits that would be provided by adoption of these tax measures, their potential to help increase and sustain domestic petroleum production will be limited unless Congress also acts to reduce restrictions on access to federal lands and to rationalize the increasingly burdensome regulatory apparatus. Moreover, it must be recognized that expected growth in the demand for oil and natural gas--both in the United States and abroad-- cannot be met merely through increased U.S. production. While U.S. reliance on imported oil can be reduced, maintaining the global competitive position of the U.S. oil and gas industry will be crucial to ensuring that U.S. consumers continue to enjoy adequate and cost-competitive supplies of our industry's major products.

END

LOAD-DATE: July 20, 2000

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