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1...Welch will prepare a form DNRC personnel can fill out for this
CONTACTS
0201 - Department of Natural Resources 406 444 6699 fax 6721
020101 - Mr. Wayne Wetzel
020102 - Ms. Sarah Bond, Esquire
020103 - Department Counsel =406 444 6660; Legal Division
020104 - Mr. Walt Anderson; Hydro Power Section Supervisor
020105 - Engineering Division
020106 - Mr. Mike Sims; Plant Superintendent; Engineering Division
SUBJECTS
Voith Contract Closeout
Planning meeting, 911009
0404 - ..
0405 - Summary/Objective
0406 -
040601 - This meeting provided coordination between key DNRC personnel
040602 - involved in closing out the Voith contract and recouping extra
040603 - expenses owed to the Department.
040604 -
040605 - The Sep 3, 1989, Agreement for the Speed Increaser and Voith contract
040606 - closeout was reviewed along with the meetings of June 25 and 26 which
040607 - led to it. Current status on performance of the Agreement was also
040608 - reviewed.
040609 -
040610 - Task lists for DNRC personnel, consultants and contractors were made
040611 - and task dependencies were analysed. More needs to be done to
040612 - identify tasks, including obtain a CPM from Voith.
040613 -
040614 -
040615 - Follow Up Meeting
040616 -
040617 - This management group will meet again oa Oct 31, to review progress
040618 - and make adjustments to plans and assignments.
040619 -
040620 -
0407 -
SUBJECTS
Voith Agreement of Sep 3, 1991
Agreement 910903 to Replace or Retrofit
Speed Increaser Engineering Review to Order Replacing the Speed Incre
Notice of Defects/Failure
Engineering Management
Admissions
Vibration Data from Monitoring system
1210 -
121001 - ..
121002 - Scope of Broadwater Close-out Effort
121003 -
121004 - The agreement between DNRC and Voith dated 910903 defines major tasks
121005 - to closeout the Voith contract. It expressly calls out two tasks:
121006 -
121007 - [On 911104 discussed with Tudor's engineering manager, John
121008 - Williams. ref SDS 10 0084
121009 -
121010 - 1. Voith will replace the gear set in the speed increaser.
121011 -
121012 - 2. The final contract punch list will be prepared by DNRC and
121013 - will thereafter be performed by Voith.
121014 -
121015 - ..
121016 - Two additional tasks are implied in the Agreement:
121017 -
121018 - 3. Evaluate correctness of the Speed Increaser housing relative
121019 - to contract specifications, and replace the entire speed
121020 - increaser if it does not conform to contract, in lieu of
121021 - merely replacing the gear set, task 1.
121022 -
121023 - 4. DNRC will track extra expense incurred caused by Voith in
121024 - connection with steps 1 - 3, and make claim for recovery.
121025 -
121026 -
121027 - ..
121028 - Notice Procedures
121029 -
121030 - With respect to task two (2) it was recommended that Tudor commence on
121031 - behalf of DNRC the notice procedure prescribed in the Agreement such
121032 - that seven (7) day notices to correct defects (punch list items)
121033 - issued prior to Sep 3, be withdrawn so there is a single baseline date
121034 - from which to evaluate performance. The baseline date will be the date
121035 - of submission of the "Final Punch" list called out in the Agreement.
121036 -
121037 - This procedure will avoid confusion in the record and shows that
121038 - substantial completion has not occurred because the "Final Punch
121039 - List" was not determinable nor performed until at least Sep 1991.
121040 -
121041 - The procedure further appears to conform with the intent of the
121042 - parties that all outstanding punch list items are to be performed
121043 - under the Agreement, plus such other items that became known dur-
121044 - ing annual maintenance (see ref DIP 4 item #5).
121045 -
121046 -
121047 - ..
121048 - Speed Increaser Housing (SIH)
121049 - Basis for Independent Evaluation
121050 -
121051 - Task three (3) arises from the purpose of the Agreement that "... the
121052 - speed increaser [comply] with the specifications defined in Contract
121053 - 1189.1" (see DIP 4 p. 1 para 2).
121054 -
121055 - There is some evidence that the Speed Increaser housing (hereafter
121056 - SIH) does not comply with the contract in that suspension bolts broke
121057 - and the noise of the unit exceeds 87 db called out in contract (see
121058 - ref DIP 1 p 13, 14, and Supplemental Bid Data p. 4).
121059 -
121060 - External Support Bolting Defective
121061 -
121062 - The original support bolting scheme failed and was modified by
121063 - Voith. This was not discussed at the Jun 25 and 26, meetings and
121064 - is not part of the Sep 3, 1991, Agreement, but it comprises an
121065 - issue to be reviewed in connection with approving the speed
121066 - increaser once Voith submits its shop drawings.
121067 -
121068 - It appears Voith did not submit the design of its corrections and
121069 - Tudor did not approve the corrections.
121070 -
121071 - ..
121072 -
121073 - Voith admits the SIH was designed and manufactured defectively (see
121074 - ref DIP 1 line 15 - relating to the gears being supported with bolts
121075 - from the top rather than the bottom). Voith has indicated it used a
121076 - "prototype design" (ref DIP 1 p 18), but promised to "...fix that and
121077 - improve [DNRC's] confidence.
121078 -
121079 - [The other bolting issue further indicates product defects and
121080 - that the unit was a "prototype."]
121081 -
121082 - Voith maintains that it corrected all defects by making field modifi-
121083 - cations to bolt the SIH from the bottom (DIP 2 p 15). However, Voith
121084 - has admitted it does not "know," for example, if the bolting changes
121085 - it made corrected the vibration problem (ibid). DNRC needs substan-
121086 - tive and objective evidence that SIH is adequate in order to decide
121087 - whether to demand a new speed increaser, rather than merely replace
121088 - the gear set, as expressly called for in the Sep 3, 1991, Agreement.
121089 - This is the only means to improve DNRC's confidence.
121090 -
121091 - [On 911104 discussed with Tudor's engineering manager, John
121092 - Williams. ref SDS 10 0084
121093 -
121094 - DNRC's position is justified on the following grounds:
121095 -
121096 - ..
121097 - Unauthorized Substitution
121098 -
121099 - It appears Voith has not complied nor even attempted to comply
121100 - with the contract provisions relating to review and approval of
121101 - the speed increaser design, and in fact furnished a unit that does
121102 - not comply with the specifications rendering it an unauthorized
121103 - substitution (discussed more fully below).
121104 -
121105 - Voith's reticence in submitting shop drawings does not instill
121106 - confidence that the speed increaser meets the specification or
121107 - that Voith is endeavoring to perform its contract.
121108 -
121109 - ..
121110 - Lost Revenue
121111 -
121112 - If the SIH requires future repairs, DNRC may loose considerable
121113 - revenue that would more likely not be lost if Voith installs a
121114 - properly designed and manufactured speed increaser that conforms
121115 - with the contract requirements, rather than repair its prototype.
121116 -
121117 - If Voith assumed the risk of DNRC's lost revenue through the 30
121118 - year life of the speed increaser, then the Department may be
121119 - justified in relying on Voith's unsupported assurances that the
121120 - existing SIH is adequate [except for the potential of injury
121121 - to people, discussed below].
121122 -
121123 - While DNRC contends it can recover lost revenue, the risk that
121124 - it cannot do so arising from Voith's refusal to so agree, means
121125 - that evidence the speed increaser complies with the contract is
121126 - the only source of confidence that it will last through its 30
121127 - year design life. Voith's agreement to merely extend the
121128 - warranty period by 2 years does not cover DNRC's exposure from
121129 - a product that does not meet the contract specifications.
121130 -
121131 -
121132 - Collateral Damage
121133 -
121134 - The risk of collateral damage and attendant administration,
121135 - litigation and repair costs is inherent in complex equipment as
121136 - involved here. Recent observations of cracked concrete while not
121137 - conclusive, indicate a serious potential risk to DNRC that can
121138 - only be assuaged by evidence that the speed increaser meets the
121139 - contract specifications.
121140 -
121141 -
121142 - Liability for Injury to People
121143 - Duty to Investigate & Take Precautions
121144 -
121145 - Since DNRC is now aware of potential problems, it has a duty to
121146 - take reasonable care to avoid the occurrence of same which could
121147 - result in injury. DNRC must insist upon evidence from Voith that
121148 - its speed increaser is safe and conforms to the contract specifi-
121149 - cations in order to avoid liability for future failure that
121150 - injures someone.
121151 -
121152 - ..
121153 - Effect of Unauthorized Substitution
121154 -
121155 - The express purpose of the Sep 3, 1991, Agreement is to replace the
121156 - gear set of the speed increaser. The language throughout the document
121157 - limits the scope of speed increaser work to just the gear set. If the
121158 - speed increaser is an unauthorized substitution that has never been
121159 - reviewed for compliance with the contract, it is not clear what weight
121160 - the Sep 3, Agreement can have in light of Voith's threshold duty to
121161 - submit information to obtain approval for alternates.
121162 -
121163 - [On 911104 discussed with Tudor's engineering manager, John
121164 - Williams. ref SDS 10 0084
121165 -
121166 - Even if the substitution is ultimately approved, the duty of care on a
121167 - wide variety of issues would seem to mandate that such approval be
121168 - granted only after heightened scrutiny of all design information
121169 - contemplated by the contract, rather than the limited review called
121170 - for in the current Agreement which seems to extend and accept Voith's
121171 - refusal to perform its contract submittal requirement.
121172 -
121173 - Thus, does the Agreement fundamentally conflict with the contract
121174 - under the record here?
121175 -
121176 -
1212 -
SUBJECTS
Speed Increaser
Submittals; Housing, Gears
Alternative Designs
Tudor's Failure to Perform
Speed Increaser
Defective Speed Increaser Must be Replaced
Expert Opinion
Vibration Data from Monitoring system
Disclose alternate design for speed increaser
2012 - Areas of Discussion
2013 -
201301 - It appears that Voith improperly installed a speed increaser which is
201302 - defective and does not meet the contract spec. DNRC may properly
201303 - insist and likely should insist that Voith comply with the contract
201304 - approval procedures for alternates, in order to cure its failure to
201305 - perform.
201306 -
201307 - Thus far the effort has been directed toward evaluating particular
201308 - narrow (though critical) aspects of the design under the Sep 3, 1991,
201309 - Agreement.
201310 -
201311 -
201312 - Gear Set
201313 -
201314 - DNRC has hired Geartech to evaluate only the gear set.
201315 -
201316 - Walt indicated Voith has met its obligations under the agreement
201317 - to submit within 7 days "...drawings and documentation regarding
201318 - the existing design," and to submit within 65 days similar data
201319 - for the new design.
201320 -
201321 - Walt indicated Geartech has completed its review and returned its
201322 - comments through DNRC to Voith.
201323 -
201324 - This task results from the Sep 3, Agreement, but does not address the
201325 - matter of the unauthorized substitution.
201326 -
201327 -
201328 - Housing Vibration & Alignment
201329 -
201330 - Maritech is evaluating the vibration (and alignment ?) of the SIH.
201331 - Part of its evaluation consists of measuring actual vibrations occur-
201332 - ring at the plant.
201333 -
201334 - Its report is due Friday, 911025.
201335 -
201336 -
201337 - Finite Element Analysis
201338 -
201339 - Maritech will also review a "Finite Element Analysis" of vibration
201340 - problems. Voith promised to supply information needed for this task
201341 - under item #2a of the Agreement, ref DIP 3, but has not done so
201342 - contrary to its assurances to "cooperate" (see ref DIP 1 p 19).
201343 -
201344 - Maritech's interim report submitted by DNRC to Voith on Oct 21 (ref
201345 - DIT 1), shows that in fact a serious vibration problem may occur if
201346 - the existing housing is re-used, as Voith intends. DNRC's Oct 21,
201347 - letter restates earlier written requests on Oct 9, and Oct 15, for the
201348 - "Finite Element Analysis."
201349 -
201350 - If Voith fails to provide its Finite Element Analysis Information by
201351 - Oct 25, DNRC may contract with Maritech to perform an independent
201352 - study to develop this information.
201353 -
201354 - This task results from the Sep 3, Agreement, but does not address the
201355 - matter of the unauthorized substitution.
201356 -
201357 -
201358 - Vibration Detector
201359 -
201360 - This part of the speed increaser is not working due to incorrect
201361 - design of the interface with the electrical system.
201362 -
201363 -
201364 - Unauthorized
201365 - Speed Increaser Substitution
201366 -
201367 - Voith installed an "alternate design" speed increaser under section
201368 - 11257 para 2.1I, and admits the ring gear suspension bolting system
201369 - was a "new idea" which did not work, and which had not been used on
201370 - other projects, contrary to the contract. The structural bolting
201371 - scheme failed and required modification which has never been submitted
201372 - by Voith for Engineering approval, which must still be rendered.
201373 - ..
201374 - On July 3, 1989, Tudor's Resident Engineer, Kurt Shulz, reported
201375 - to John Williams and Roberto Iniguez that Voith had installed a "pre-
201376 - sumably unauthorized substitution." There are no shop drawings,
201377 - change orders or other record of approval of this substitution. Voith
201378 - submitted on July 14, 1989, as its only support for the substitution
201379 - minutes of the post-award meeting on Nov 4, 1987, the following two
201380 - line comment:
201381 -
201382 - 2.1.A - The speed increaser is not double helical, it is a spur
201383 - gear. Renk will meet the AGMA specs, thus this is acceptable.
201384 -
201385 - This comment merely indicates willingness by the Engineer to approve
201386 - the change, if Voith can demonstrate through shop drawings and other
201387 - standard submittal information that its assertion is true. However,
201388 - it has not done so. Tudor's submittal log (file 00730) indicates
201389 - Voith did not submit shop drawings or documentation of satisfactory
201390 - use on other projects as provided in contract section 11257 para
201391 - 2.1 I.
201392 -
201393 - Therefore, apart from whether DNRC can satisfy itself with respect to
201394 - particular sub-systems (e.g. gear set) of the speed increaser, DNRC
201395 - should insist that Voith now comply with the contract requirements to
201396 - obtain approval for its alternate and if an an adjustment in price is
201397 - warranted relative to the contract specification, it should be made
201398 - to the benefit of DNRC.
201399 -
201400 - Voith maintains the SIH is "...similar to other projects, typical. We
201401 - are willing to cooperate," and has offered to supply a list of other
201402 - projects where this SIH design is installed (ref DIP 4 p 19.) Voith's
201403 - position in this regard appears to conflict with its admission that it
201404 - tried a "new idea" with the design of the speed increaser for
201405 - Broadwater (ref DIP 4 p 16.).
201406 -
201407 -
201408 - Follow Up
201409 -
201410 - DNRC is well positioned to demand that Voith comply with the contract
201411 - provisions to support substitutions. It would be helpful to have a
201412 - single Engineer carry out this task, as contemplated by Voith's con-
201413 - tract, the cost of which should be chargeable to Voith. DNRC is
201414 - mitigating the damage by its diligence in arranging the aspects cited
201415 - above. Voith seems to be compounding the damage by failing to cooper-
201416 - ate.
201417 -
2015 -
2016 -
SUBJECTS
Speed Increaser
Vibration Detector
Collateral Damage
Mitigation (Voith
Instructions)
2308 - General
2309 -
230901 - The specified vibration detection system has not worked.
230902 -
230903 - Voith committed to provide within seven (7) days of signing the Sep 3,
230904 - 1991, Agreement, a plant operations plan to be followed by DNRC and a
230905 - comprehensive vibration monitoring system, including a computer to
230906 - capture critical data. It failed to perform either task.
230907 -
230908 - DNRC has been operating the plant based on Voith's recommendations of
230909 - July 29, 1991.
230910 -
230911 - ..
230912 - Collateral Damage & Notice
230913 -
230914 - Evidence of possible collateral damage from excessive vibration has
230915 - emerged within the past week or so.
230916 -
230917 - Hire Structural Engineer
230918 -
230919 - DNRC or Tudor will hire a structural engineer to investigate and
230920 - report on the cause of the observed damage to the plant.
230921 -
230922 -
230923 - Welch submitted a proposed notice to Voith and demand to perform with
230924 - respect to this matter, ref SDS 9 and DIP 5.
230925 -
230926 - Sarah is editing this notice and will issue a demand that Tudor
230927 - "direct" that Voith perform its agreement and that Tudor inform
230928 - DNRC of any additional steps Tudor believes should be taken in
230929 - connection with this matter to protect DNRC's interests.
230930 -
230931 -
230932 - Installation by Voith
230933 -
230934 - Walt indicated some monitoring equipment has been delivered to the
230935 - plant within the past few days. Walt understands from discussions
230936 - with a Voith vendor that work may commence next week on installation.
230937 -
230938 - Subsequently this has been changed to mid-November.
230939 -
230940 -
230941 - Computer by DNRC
230942 -
230943 - Walt indicated DNRC intends to supply the computer for the vibration
230944 - monitoring plan which Voith agreed to furnish under the Sep 3,
230945 - Agreement.
230946 -
230947 - Action needs to be taken so the computer is available when Voith
230948 - completes its monitoring system installation, which appears now like
230949 - it will be between mid and late November.
230950 -
2310 -
SUBJECTS
Claims by DNRC Against Voith
Procedures & Accounting
Expert opinions
2606 -
260601 - ..
260602 -
260603 - Procedures were considered for capturing DNRC cost chargeable to
260604 - Voith. Adjustments to existing practice were developed to support
260605 - claims DNRC expects to make against Voith.
260606 -
260607 - Contract v. Operations
260608 -
260609 - Procedures for segmenting contract closeout work and expense from
260610 - other DNRC operations were considered.
260611 -
260612 - This meeting sets out some of major tasks that distinguish contract
260613 - closeout work from plant operations.
260614 -
260615 -
260616 - Minor Corrections/Mitigation
260617 -
260618 - DNRC has been absorbing the expense of "minor" corrections, as a
260619 - courtesy to Voith and to expedite the work. It was decided to adopt a
260620 - procedure of notifying Voith and Tudor of such corrections, to permit
260621 - them to authorize same in order to avoid inadvertent damage to other
260622 - aspects of the plant which would otherwise be the responsibility of
260623 - Voith.
260624 -
260625 - Welch will prepare a form DNRC personnel can fill out for this
260626 - purpose.
260627 -
260628 -
260629 - Voith Backcharge Account #
260630 -
260631 - Walt will obtain from DNRC accounting an account number for
260632 - identifying DNRC activities chargeable to Voith. This will be used by
260633 - DNRC to charge time and other expense incurred to correct Voith's
260634 - failure to perform its contract obligations.
260635 -
260636 -
260637 - Record keeping Procedures
260638 -
260639 - Mike and Brian are entering in a plant "log" explanations of work
260640 - performed and problems encountered. Matters chargeable to Voith will
260641 - be identified by contract plan and/or specification section with an
260642 - explanation of what was found, what was done and how long it took.
260643 -
260644 -
260645 - Documentation by Experts
260646 -
260647 - DNRC should strive to have any requests or demands it makes to Voith
260648 - supported by written reports from its experts. If an expert needs
260649 - information to perform its work, it should be requested to write a
260650 - letter stating what it needs and why. This removes some of the burden
260651 - DNRC has been forced to assume by the absence of Tudor.
260652 -
260653 - It also helps build chronologies of what is done and why, which will
260654 - be helpful in both continuing management of issues and resolution of
260655 - claims.
260656 -
260657 -
2607 -
2608 -
SUBJECTS
Planning
Legal overview, strategy and opinion
Presumed Damages, Voith
CPM showing expected progress and constraints
Record of Plant Problems
Engineer's duty to determine disputes
3109 - General
3110 -
311001 - The Agreement with Voith gives rise to the following planning
311002 - requirements:
311003 -
311004 - 1. Identify the key players (including Engineering Manager)
311005 -
311006 - 2. DNRC needs a CPM showing major activities to complete the
311007 - contract and the dependency relationships thereof to insure
311008 - timely support of vendors and minimal down time of the plant,
311009 - and overall expense to DNRC.
311010 -
311011 - 3. Voith, as the major contractor, needs to supply CPM scheduling
311012 - information to support DNRC's management and oversight of the
311013 - contract.
311014 -
311015 - DNRC needs to complete the CPM analysis of the tasks DNRC needs to be
311016 - doing, which was begun today in the meeting.
311017 -
311018 -
311019 - Closeout and Settlement/Litigation Strategy
311020 -
311021 - Sarah will prepare a memo opinion explaining DNRC's strategy and
311022 - options in closing out the contract and settling disputes. Wayne
311023 - feels this is a good idea because her work product is not
311024 - discoverable.
311025 -
311026 - Engineering needs a legal opinion on what constitutes contract
311027 - completion, and substantial completion. DNRC has done some work on
311028 - defining substantial completion relative to the Full Operation date.
311029 - Wayne presented some ideas today that would result in the Full
311030 - Operation Date still being open.
311031 -
311032 - After preparing the support and rationale of Tudor's Oct 5, 1989,
311033 - determination of backcharges from the Sletten contract to Voith, Welch
311034 - will prepare an analysis that develops the legal opinion and Wayne's
311035 - ideas into a claim against Voith to recover the actual delay damages
311036 - DNRC has suffered, for submission to the Engineer. The Engineer will
311037 - then make a determinations on all matters, and issue change orders as
311038 - warranted. Voith and DNRC can then arbitrate any differences with
311039 - Voith.
311040 -
311041 -
311042 - Lee Engineering Report
311043 -
311044 - This is required to support the punch list. Walt will meet with Lee
311045 - Engineering to determine progress and scope.
311046 -
311047 -
311048 - Submit Punch List
311049 -
311050 - DNRC will issue the Punch List to Voith after reviewing Lee
311051 - Engineering's report and after assigning contract plan and
311052 - specification identifications. This submittal will ask Voith to
311053 - provide a CPM showing when the tasks of re-design, submittal,
311054 - approval, procurement, manufacture and installation will occur.
311055 -
311056 -
3111 -
SUBJECTS
Punch List
3204 - Discussion
3205 -
320501 - This is the list requested in the Sep 3, 1991, Agreement. It is the
320502 - other major piece of work required to close out the contract.
320503 -
320504 - Mike will complete a list of all pending items by Friday, 911025.
320505 -
320506 - He will indicate the items that need to be done now and those
320507 - that can be done when Voith wishes to schedule them.
320508 -
320509 -
320510 - Warranty v. Contract Items
320511 -
320512 - Consideration was made to distinguish warranty from contract work. The
320513 - issue is whether the warranty has actually begun to run on anything.
320514 - It seems this may be so, but it is not clear how to set that date,
320515 - since DNRC has been producing power, albeit not at the capacity
320516 - expected in entering the project.
320517 -
320518 - The legal and engineering analyses are needed for this.
320519 -
320520 - Another method would be simply to submit everything as punch list and
320521 - let Voith present the case, if it wishes to do so, why a particular
320522 - item should be one thing or another.
320523 -
320524 -
3206 -
SUBJECTS
Organize existing record,
Claims by Owner against
Admin Procedures, Defective
3406 - Discussion
3407 -
340701 - Charity is working on completing chronologies of documents between
340702 - various parties.
340703 -
340704 - Sarah advised a meeting is scheduled for Friday to clarify the
340705 - direction of this work.
340706 -
340707 -
340708 - Tudor to Voith Documents Found
340709 -
340710 - The entire body of documents issued by Tudor to Voith from contract
340711 - inception to April 1989, seemed to be missing in the record.
340712 -
340713 - JoAnn Finn recently explained that Tudor filed these documents and
340714 - commingled them with those to others within the Sletten contract
340715 - records for documents issued by Tudor.
340716 -
340717 - It would be helpful if Charity could segment the following documents
340718 - so there are separate chronologies:
340719 -
340720 - Tudor to Voith source = Tudor files
340721 - Tudor to DNRC " " "
340722 - DNRC to Voith " DNRC "
340723 - DNRC to Tudor " " "
340724 -
340725 -
340726 -
340727 -
3408 -
SUBJECTS
Engineering Management
Scope Statement
Formulate Closeout Agreement
Need for Engineer
Engineer's duty to determine disputes
3908 - General
3909 -
390901 - There are a broad range of engineering management matters involved in
390902 - the successful closeout of the contract.
390903 -
390904 - Consideration was given to, at a minimum, develop a consulting
390905 - relationship with an Engineering firm that can coordinate the effort
390906 - and direct Voith to perform in the manner required by the contract.
390907 -
390908 - We would also like an Engineer to rule on DNRC claims.
390909 -
390910 - It might also be fruitful to contact other hydro plant owners who have
390911 - experience of this kind so see how these matters have been handled.
390912 -
390913 -
390914 - Tudor
390915 -
390916 - Wayne will call John Williams to request a meeting with Welch during
390917 - the week of Nov 4, to discuss the above matters.
390918 -
390919 -
390920 -
390921 -
390922 -
390923 -
390924 -
390925 -
390926 -
390927 -
390928 -
390929 -
3910 -
Distribution. . . . See "CONTACTS"