19–006 

112TH CONGRESS REPT. 112–343 " ! HOUSE OF REPRESENTATIVES 2d Session Part 2 

BUSINESS RISK MITIGATION AND PRICE STABILIZATION 

ACT OF 2012 

FEBRUARY 8, 2012.—Committed to the Committee of the Whole House on the State 

of the Union and ordered to be printed 

Mr. LUCAS, from the Committee on Agriculture, 

submitted the following 

R E P O R T 

together with 

ADDITIONAL VIEWS 

[To accompany H.R. 2682] 

[Including cost estimate of the Congressional Budget Office] 

The Committee on Agriculture, to whom was referred the bill 

(H.R.2682) to provide end user exemptions from certain provisions 

of the Commodity Exchange Act and the Securities Exchange Act 

of 1934, and for other purposes, having considered the same, report 

favorably thereon with an amendment and recommend that the bill 

as amended do pass. 

The amendment is as follows: 

Strike all after the enacting clause and insert the following: 

SECTION 1. SHORT TITLE. 

This Act may be cited as the ‘‘Business Risk Mitigation and Price Stabilization 

Act of 2012’’. 

SEC. 2. MARGIN REQUIREMENTS. 

(a) COMMODITY EXCHANGE ACT AMENDMENT.—Section 4s(e) of the Commodity Exchange Act (7 U.S.C. 6s(e)), as added by section 731 of the Dodd-Frank Wall Street 

Reform and Consumer Protection Act, is amended by adding at the end the following new paragraph: 

‘‘(4) APPLICABILITY WITH RESPECT TO COUNTERPARTIES.—The requirements of 

paragraphs (2)(A)(ii) and (2)(B)(ii) shall not apply to a swap in which a 

counterparty qualifies for an exception under section 2(h)(7)(A) or satisfies the 

criteria in section 2(h)(7)(D).’’. 

(b) SECURITIES EXCHANGE ACT AMENDMENT.—Section 15F(e) of the Securities Exchange Act of 1934 (15 U.S.C. 78o–10(e)), as added by section 764(a) of the DoddVerDate Mar 15 2010 07:02 Feb 09, 2012 Jkt 019006 PO 00000 Frm 00001 Fmt 6659 Sfmt 6621 E:\HR\OC\HR343P2.XXX HR343P2

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Frank Wall Street Reform and Consumer Protection Act, is amended by adding at 

the end the following new paragraph: 

‘‘(4) APPLICABILITY WITH RESPECT TO COUNTERPARTIES.—The requirements of 

paragraphs (2)(A)(ii) and (2)(B)(ii) shall not apply to a security-based swap in 

which one of the counterparties to the security-based swap is not a financial entity as described in section 3C(g)(3), and such counterparty is eligible for the 

exception under section 3C(g)(1).’’. 

SEC. 3. IMPLEMENTATION. 

The amendments made by this Act shall be implemented— 

(1) without regard to— 

(A) chapter 35 of title 44, United States Code; and 

(B) the notice and comment provisions of section 553 of title 5, United 

States Code; and 

(2) through the promulgation of an interim final rule. 

BRIEF EXPLANATION

The bill amends Section 4s(e) of the Commodity Exchange Act 

(CEA) as added by Section 731 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111–203) (the Dodd-Frank 

Act) to provide an explicit exemption from margin requirements for 

swap transactions involving end-users that qualify for the clearing 

exception under 2(h)(7)(A). The bill includes mirroring provisions to 

Section 15F(e) of the Securities Exchange Act with respect to security-based swap transactions. 

PURPOSE AND NEED

End-users are the thousands of businesses across the country 

that use derivatives to hedge the risks associated with their dayto-day operations. Because end-users’ swap transactions do not 

pose a systemic risk to the financial system, Congress provided an 

exemption for over-the-counter swap transactions from the margin 

requirements in Title VII of the Dodd-Frank Act. 

During floor debate on the conference report for the Dodd-Frank 

Act, two colloquies among the then-chairmen of the four committees with primary jurisdiction over Title VII clarified Congressional 

intent that the Dodd-Frank Act did not grant regulators the authority to impose margin requirements on end-user derivatives 

transactions. Subsequently, the principal authors of Title VII, Senators Blanche Lincoln and Senators Chris Dodd sent a letter to 

Reps. Barney Frank and Collin Peterson to set forth and clarify 

congressional intent. In the letter they state: ‘‘The legislation does 

not authorize the regulators to impose margin on end users, those 

exempt entities that use swaps to hedge or mitigate commercial 

risk. If regulators raise the costs of end user transactions, they 

may create more risk. It is imperative that the regulators do not 

unnecessarily divert working capital from our economy into margin 

accounts, in a way that would discourage hedging by end users or 

impair economic growth.’’ 

Nevertheless, some regulators have interpreted Title VII as a 

grant of new authority to impose margin requirements on endusers merely because they are counterparties to swaps with a regulated entity, such as a swap dealer or financial institution. The 

prudential regulators are responsible for setting margin requirements for transactions involving swap dealers that are banks. It is 

important to note that most end-users enter into hedging transactions with bank swap dealers, so it is the prudential regulators 

that will be setting the margin requirements for most end-user 


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transactions. In April of 2011, the prudential regulators issued a 

joint proposal that would in fact require non-financial end-users to 

post margin to their bank counterparties. 

Although not a concern shared widely, some have argued that 

the prudential regulators have authority to impose margin on enduser transactions that is independent of any new authority in 

Dodd-Frank, and that these agencies will impose margin on endusers despite enactment of H.R. 2682. 

However, it is clear in the prudential regulators’ joint rule proposal that their interpretation of Title VII of the Dodd-Frank Act 

requires that they impose margin on end-users, and that the requirement is the reason for proposing that non-financial end-users 

post margin to their bank swap counterparties. As stated in the 

rule (http://www.fdic.gov/regulations/laws/federal/2011/11proposed 

AD79.pdf): 

Following passage of the Dodd-Frank Act, various observers expressed concerns regarding whether sections 731 and 764 of the 

Dodd-Frank Act authorize or require the CFTC, SEC and Agencies 

to establish margin requirements with respect to transactions between a covered swap entity and a ‘‘commercial end user’’ (i.e. a 

nonfinancial counterparty that engages in derivatives activities to 

hedge commercial risk), and have argued that swap and securitybased swap transactions with these types of counterparties should 

be excluded from the scope of margin requirements imposed under 

sections 731 and 764 because commercial firms engaged in hedging 

activities pose a reduced risk to their counterparties and the stability of the U.S. financial system. In addition, statements in the 

legislative history of sections 731 and 764 suggest that Congress 

did not intend, in enacting these sections, to impose margin requirements on nonfinancial end users engaged in hedging activities, even in cases where they entered into swaps or security-based 

swaps with swap entities. 

In formulating the proposed rule, the Agencies have carefully 

considered these concerns and statements. The plain language of 

sections 731 and 764 provides that the Agencies adopt rules for 

covered swap entities imposing margin requirements on all noncleared swaps. Those sections do not, by their terms, exclude a 

swap with a counterparty that is a commercial end-user. 

By the agencies’ own terms, their proposal to require margin 

stems directly from what they view to be a legal obligation under 

Title VII. By providing an explicit exemption under Title VII 

through enactment of HR 2682, the agencies will no longer have a 

legal obligation, and congressional intent as they acknowledge in 

the proposed rule will be implemented. 

Several end-users that testified before the Committee in 2011 

spoke to the harmful economic impact a margin requirement would 

have for end-users and the need for Congress to clarify its intent. 

On February 10, 2011, Scott C. Morrison, Chief Financial Officer 

for the Ball Corporation, testifying on behalf of the Coalition for 

Derivatives End-Users stated: ‘‘A requirement for end-users like 

Ball Corporation to post margin to its counterparties would have 

a serious impact on our ability to invest in and grown our business. 

For example, Ball Corporation is currently investing significant 

amounts of capital in plant expansions we are currently executing 

in Texas, Indiana, California and Colorado. Those expansions alone 


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are investments totaling well in excess of $150 million and will add 

several hundred jobs when complete. Tying up capital for initial 

and variation margin could put those types of projects at risk at 

a time when our economy can ill afford it.’’ 

On July 21, 2011, Neil Schloss, Vice President and Treasurer of 

Ford Motor Company stated: ‘‘Similar to other end-user corporations and manufacturers, we are concerned that imposing margin 

requirements would significantly increase our cash requirements 

and costs, and provide a disincentive to hedge legitimate business 

risks, which would seemingly increase systemic risk.’’ 

On October 12, 2011, Scott Cordes, President of Country Hedging, on behalf of the National Council of Farmer Cooperatives stated: ‘‘Under the proposed rule requiring end users to post margin, 

costs to businesses will increase as more cash is tied up to maintain those hedges. The additional capital requirements will be siphoned away from activities and investment in cooperatives’ primary business ventures. Furthermore, cash for margin is often borrowed from lenders through the use of credit lines. As a result, we 

could see a situation where a commercial end-user would have to 

borrow cash from its lender, and pay interest on it, just to give it 

back to the same lender to hold as margin.’’ 

H.R. 2682 clarifies congressional intent to provide an explicit exemption for swap transactions involving non-financial end-users 

from the margin requirements under Title VII of the Dodd-Frank 

Act. 

SECTION-BY-SECTION

Section 1 is the short title of the bill, ‘‘The Business Mitigation 

and Price Stabilization Act of 2012.’’ 

Section 2(a) amends section 4s(e) the Commodity Exchange Act 

(as added by section 731 of the Dodd-Frank Act) to clarify that initial and variation margin requirements shall not apply to a swap 

in which one of the counterparties to the swap is not a financial 

entity, and qualifies for the end-user clearing exception in Section 

2(h)(7)(A). 

Section 2(b) is a similar amendment to the Securities and Exchange Act. 

Section 3 excludes the amendments made by this bill from the 

requirements of the Paperwork Reduction Act and from notice and 

comment requirements of the Administrative Procedure Act. 

COMMITTEE CONSIDERATION

I. HEARINGS

In the 112th Congress, the Committee has held seven hearings, 

four Full Committee and two General Farm Commodities and Risk 

Management Subcommittee hearings to examine the implementation of Title VII of the Dodd-Frank Act and one Full Committee 

hearing to examine legislative proposals related thereto, including 

H.R. 2682. The Committee took testimony from witnesses that represented a broad spectrum of participants in the derivatives markets. 

In the following hearings, witnesses testified to the importance 

of a clear, explicit margin exemption for end-users. 


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Public hearing to review implementation of title VII of the 

Dodd-Frank Wall Street Reform and Consumer Protection Act: February 10, 2011 

Defining the Market: Entity and Product Classifications 

Under Title VII of the Dodd-Frank Wall Street Reform 

and Consumer Protection Act: March 31, 2011 

Derivatives Reform: The View from Main Street: July 21, 

2011 

To review legislative proposals amending Title VII of the 

Dodd-Frank Wall Street Reform and Consumer Protection Act: October 12, 2011 

On October 12, 2011, Mr. Scott Cordes, President of Country 

Hedging testified on behalf of the National Council of Farmer Cooperatives: 

‘‘Under the proposed rule requiring end-users to post 

margin, costs to businesses will increase as more cash is 

tied up to maintain those hedges. The additional capital 

requirements will be siphoned away from activities and investment in cooperatives’ primary business ventures. . . . 

Congressional intent was clear on this point—end-users 

were not to be required to post margin. We support legislation that would reaffirm this intent.’’ 

On October 12, 2011, Ms. Brenda Boultwood, of Constellation Energy on behalf of the Coalition for Derivatives End-Users testified: 

‘‘ A survey conducted by the Coalition found that companies would have to hold aside an average of $269 million 

of cash or immediately available bank credit to meet a 3% 

margin requirement. . . . the . . . study extrapolated the 

effects across the S&P 500 to predict the consequent loss 

of 100,000 to 130,000 direct and indirect jobs. . . . We 

need Congress to step in and clarify the ability of endusers and banks to continue to manage counterparty risk 

without unnecessary initial and variation margin requirements.’’ 

II. FULL COMMITTEE

The Committee on Agriculture met, pursuant to notice, with a 

quorum present, on January 25, 2012, to consider H.R. 2682, to 

provide end user exemptions from certain provisions of the Commodity Exchange Act of 1934, and other pending business. Chairman Lucas offered an opening statement, as did Ranking Member 

Peterson. 

By unanimous consent, the Subcommittee on General Farm Commodities and Risk Management was discharged from further consideration and the bill, H.R. 2682 was placed before the Committee 

for consideration and without objection a first reading of the bill 

was waived and it was opened for amendment at any point. The 

Chairman offered an Amendment in the Nature of a Substitute to 

the bill, and counsel provided a brief explanation of the amendment. 


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Mr. Peterson was recognized to offer and explain an amendment 

to expedite implementation by excluding the amendments made by 

the bill from the requirements of the Paperwork Reduction Act and 

from notice and comment requirements of the Administrative Procedure Act. By a voice vote the Peterson amendment was adopted. 

There being no further amendments, the Peterson motion to approve the Amendment in the Nature of a Substitute to H.R. 2682, 

as amended was adopted by a voice vote. 

By a voice vote, the Peterson motion to report the bill favorably 

to the House with the recommendation that it do pass was adopted. 

The Committee then moved onto other pending business, where 

at the conclusion of the meeting, Chairman Lucas advised Members that pursuant to the rules of the House of Representatives 

that Members have 2 calendar days to file such views with the 

Committee. 

Without objection, staff was given permission to make any necessary clerical, technical or conforming changes to reflect the intent 

of the Committee. 

Chairman Lucas thanked all the Members and adjourned the 

meeting. 

REPORTING THE BILL—ROLL CALL VOTES

In compliance with clause 3(b) of rule XIII of the House of Representatives, H.R. 2682 was reported by voice vote with a majority 

quorum present. There was no request for a recorded vote. 

COMMITTEE OVERSIGHT FINDINGS

Pursuant to clause 3(c)(1) of rule XIII of the Rules of the House 

of Representatives, the Committee on Agriculture’s oversight findings and recommendations are reflected in the body of this report. 

BUDGET ACT COMPLIANCE (SECTIONS 308, 402, AND 423) 

The provisions of clause 3(c)(2) of rule XIII of the Rules of the 

House of Representatives and section 308(a)(1) of the Congressional 

Budget Act of 1974 (relating to estimates of new budget authority, 

new spending authority, new credit authority, or increased or decreased revenues or tax expenditures) are not considered applicable. The estimate and comparison required to be prepared by the 

Director of the Congressional Budget Office under clause 3(c)(3) of 

rule XIII of the Rules of the House of Representatives and sections 

402 and 423 of the Congressional Budget Act of 1974 submitted to 

the Committee prior to the filing of this report are as follows: 

FEBRUARY 7, 2012. 

Hon. FRANK D. LUCAS, Chairman, Committee on Agriculture, 

House of Representatives, Washington, DC. 

DEAR MR. CHAIRMAN: The Congressional Budget Office has prepared the enclosed cost estimate for H.R. 2682, the Business Risk 

Mitigation and Price Stabilization Act of 2011. 

If you wish further details on this estimate, we will be pleased 

to provide them. The CBO staff contact is Susan Willie. 

Sincerely, 

DOUGLAS W. ELMENDORF. 


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Enclosure. 

H.R. 2682—Business Risk Mitigation and Price Stabilization Act of 

2012 

H.R. 2682 would allow certain nonfinancial entities that are 

counterparties in a swap or a security-based swap transaction to be 

exempted from provisions in current law that require such entities 

to meet certain margin requirements. (A swap is a contract that 

calls for an exchange of cash between two participants, based on 

an underlying rate or index or on the performance of an asset.) 

Both the Commodity Futures Trading Commission (CFTC) and the 

Securities and Exchange Commission (SEC) are developing regulations relating to margin requirements in swap transactions as the 

result of the enactment of the Dodd-Frank Wall Street Reform and 

Consumer Protection Act (Public Law 111–203); however, neither 

agency has finalized such regulations. (Margin requirements are 

minimum amounts of collateral that must be deposited, often with 

a broker or exchange, to cover some or all of the risk of a counterparty.) 

Based on information from the two agencies, CBO expects that 

incorporating the provisions of H.R. 2682 at this point in the regulatory process would not require a significant increase in the workload of either agency. Therefore, CBO estimates that any change 

in net discretionary spending to implement the legislation, which 

would be subject to the availability of appropriated funds, would 

not be significant. Further, under current law, the SEC is authorized to collect fees sufficient to offset its appropriation each year; 

CBO expects that the agency would set fee rates each year to offset 

amounts provided in appropriation acts. Enacting H.R. 2682 would 

not affect direct spending or revenues; therefore, pay-as-you-go procedures do not apply. 

H.R. 2586 contains no intergovernmental or private-sector mandates as defined in the Unfunded Mandates Reform Act and would 

not affect the budgets of state, local, or tribal governments. 

On December 14, 2011, CBO transmitted an estimate for H.R. 

2682, the Business Risk Mitigation and Price Stabilization Act of 

2011, as ordered reported by the House Committee on Financial 

Services on November 30, 2011. The Financial Services Committee 

version of the bill would make similar changes in margin requirements for certain counterparties in swap transactions. CBO estimates that the cost to implement either version of the legislation 

would be insignificant. 

The CBO staff contact for this estimate is Susan Willie. The estimate was approved by Theresa Gullo, Deputy Assistant Director 

for Budget Analysis. 

PERFORMANCE GOALS AND OBJECTIVES

With respect to the requirement of clause 3(c)(4) of rule XIII of 

the Rules of the House of Representatives, the performance goals 

and objections of this legislation are to provide end user exemptions from certain provisions of the Commodity Exchange Act and 

the Securities Exchange Act of 1934, and for other purposes. 


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CONSTITUTIONAL AUTHORITY STATEMENT

The Committee finds the Constitutional authority for this legislation in Article I, section 8, clause 18, that grants Congress the 

power to make all laws necessary and proper for carrying out the 

powers vested by Congress in the Constitution of the United States 

or in any department or officer thereof. 

COMMITTEE COST ESTIMATE

Pursuant to clause 3(d)(2) of rule XIII of the Rules of the House 

of Representatives, the Committee report incorporates the cost estimate prepared by the Director of the Congressional Budget Office 

pursuant to sections 402 and 423 of the Congressional Budget Act 

of 1974. 

ADVISORY COMMITTEE STATEMENT

No advisory committee within the meaning of section 5(b) of the 

Federal Advisory Committee Act was created by this legislation. 

APPLICABILITY TO THE LEGISLATIVE BRANCH

The Committee finds that the legislation does not relate to the 

terms and conditions of employment or access to public services or 

accommodations within the meaning of section 102(b)(3) of the Congressional Accountability Act (Public Law 104–1). 

FEDERAL MANDATES STATEMENT

The Committee adopted as its own the estimate of Federal mandates prepared by the Director of the Congressional Budget Office 

pursuant to section 423 of the Unfunded Mandates Reform Act 

(Public Law 104–4). 

EARMARK STATEMENT REQUIRED BY CLAUSE 9 OF RULE XXI OF THE

RULES OF HOUSE OF REPRESENTATIVES

H.R. 2682 does not contain any congressional earmarks, limited 

tax benefits, or limited tariff benefits as defined in clause 9(e), 9(f), 

or 9(g) of rule XXI of the Rules of the House Representatives. 

CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED

In compliance with clause 3(e) of rule XIII of the Rules of the 

House of Representatives, changes in existing law made by the bill, 

as reported, are shown as follows (new matter is printed in italic 

and existing law in which no change is proposed is shown in 

roman): 

COMMODITY EXCHANGE ACT 

* * * * * * * 

SEC. 4s. REGISTRATION AND REGULATION OF SWAP DEALERS AND 

MAJOR SWAP PARTICIPANTS. 

(a) * * * 

* * * * * * * 

(e) CAPITAL AND MARGIN REQUIREMENTS.— 


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(1) * * * 

* * * * * * * 

(4) APPLICABILITY WITH RESPECT TO COUNTERPARTIES.—The 

requirements of paragraphs (2)(A)(ii) and (2)(B)(ii) shall not 

apply to a swap in which a counterparty qualifies for an exception under section 2(h)(7)(A) or satisfies the criteria in section 

2(h)(7)(D). 

* * * * * * * 

SECURITIES EXCHANGE ACT OF 1934 

TITLE I—REGULATION OF SECURITIES EXCHANGES 

* * * * * * * 

SEC. 15F. REGISTRATION AND REGULATION OF SECURITY-BASED 

SWAP DEALERS AND MAJOR SECURITY-BASED SWAP PARTICIPANTS. 

(a) * * * 

* * * * * * * 

(e) CAPITAL AND MARGIN REQUIREMENTS.— 

(1) * * * 

* * * * * * * 

(4) APPLICABILITY WITH RESPECT TO COUNTERPARTIES.—The 

requirements of paragraphs (2)(A)(ii) and (2)(B)(ii) shall not 

apply to a security-based swap in which one of the counterparties to the security-based swap is not a financial entity as described in section 3C(g)(3), and such counterparty is eligible for 

the exception under section 3C(g)(1). 

* * * * * * * 


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ADDITIONAL VIEWS 

For the past year, our Committee has held several hearings and 

listened to a host of stakeholders who are concerned about how the 

Dodd-Frank Act is being implemented with regard to improving 

oversight and accountability in derivative markets. I recommended 

patience and caution for those seeking to change the law. It is premature to move on legislation until we see the final rules. Looking 

at the Dodd-Frank rules that have already been finalized by the 

CFTC, it is safe to say that, so far, the CFTC has done a pretty 

good job. 

When we crafted the derivatives title in this Committee and on 

the House floor, we wanted those responsible for the financial collapse of 2008, or those who could cause another collapse, to back 

their swap trades with more of their own money so the American 

taxpayer would not have to bail them out again. For those not responsible, we wanted them to be able to continue to use swaps to 

hedge the risk associated with their commercial businesses. 

Despite our legislative drafting, despite our colloquies, despite 

the letters written back and forth, the Prudential Regulators—i.e. 

the banking regulators—have chosen to ignore the intent of Congress. They are instead proposing that end-users post margin with 

regard to their swaps with swap dealers and major swap participants who are regulated by the Prudential Regulators. The CFTC, 

correctly understanding Congress’ intent, did not impose any such 

obligation. 

For some reason, despite repeated requests to the Majority, the 

Prudential Regulators have not appeared before our Committee to 

answer why they have ignored Congress’ intent. Why? What possible reason do we have to fear from bringing them here? Maybe 

it is to avoid an uncomfortable truth. Despite this legislation, the 

Prudential Regulators—through their other statutory power to ensure the safety and soundness of the banks under their jurisdiction—have the authority to require those they oversee to collect 

margin on the swaps they enter into, even from end users. 

Attached to these additional views are three letters from the Prudential Regulators—i.e. the Federal Reserve, the Federal Deposit 

Insurance Corporation and the Office of the Comptroller of the 

Currency—outlining their authorities. While these authorities were 

not previously utilized to require end users to post cash margin for 

their swaps with banking institutions, the fact that the Prudential 

Regulators have blatantly disregarded Congressional intent indicates a change in thinking among the Prudential Regulators that 

perhaps such margin is necessary. Given the criticism they faced 

in the aftermath of the 2008 meltdown, it is possible they do not 

want fingers pointing at them again should another meltdown 

occur. 


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If such thinking holds, enacting H.R. 2682 into law does not 

guarantee that Prudential Regulators will not utilize their other 

authorities to achieve a similar outcome as suggested in their proposed rule concerning margin. I support the intent of H.R. 2682 to 

protect end users from having to meet crippling margin requirements for their swap activity. The question remains, will it work? 

When crafting financial reform legislation, some of us did not 

want the Prudential Regulators involved in any part of the swap 

regulation, much less setting margin standards; we can all see 

why. If the Prudential Regulators fail to correct their error on their 

own, there is little doubt that the swap market will very quickly 

adjust. We’ll see fewer banks in the swap dealing business as end 

users look to non-bank swap dealers to meet their risk management needs without having to post margin. That would not necessarily be a bad outcome. 

Finally, the Committee approved the Peterson amendment, 

which includes language that should look very familiar to Farm 

Bill veterans. It is the exact same provisions that we incorporate 

in each Farm Bill for implementation of the Title I commodity programs. It that context, it exempts USDA from provisions of the Paperwork Reduction Act and notice and comment provisions of the 

Administrative Procedures Act. 

With this change, comments can still be sent to the CFTC. Anyone would still be able to meet with CFTC officials to share their 

thoughts on how these bills should be implemented. Farm groups 

certainly did not have any trouble sharing their views on Farm Bill 

implementation. Given the openness the CFTC has already demonstrated, this provision will not hurt anyone’s ability to provide 

input to the CFTC. 

COLLIN C. PETERSON. JOE COURTNEY. JAMES P. MCGOVERN. 

CHELLIE PINGREE. JIM COSTA. 

PETER WELCH. 


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