Energy Markets: Mergers and Other Factors that Affect the U.S. Refining Industry
Published: 2004-07-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Gasoline is subject to dramatic price swings. A multitude of factors affect U.S. gasoline markets, including world crude oil costs and limited refining capacity. Since the 1990s, another factor affecting U.S. gasoline markets has been a wave of mergers in the petroleum industry, several between large oil companies that had previously competed with each other. For example, in 1999, Exxon, the largest U.S. oil company, merged with Mobil, the second largest. This testimony is based primarily on Energy Markets: Effects of Mergers and Market Concentration in the U.S. Petroleum Industry ( GAO-04-96 , May 17, 2004). This report examined mergers in the industry from the 1990s through 2000, the changes in market concentration (the distribution of market shares among competing firms) and other factors affecting competition in the industry, how U.S. gasoline marketing has changed since the 1990s, and how mergers and market concentration in the industry have affected U.S. gasoline prices at the wholesale level. To address these issues, GAO purchased and analyzed a large body of data and developed state-of-the art econometric models for isolating the effects of eight specific mergers and increased market concentration on wholesale gasoline prices. Experts peer-reviewed GAO's analysis.
section_title: What GAO Found
paragraphs: Mergers have altered the structure of the U.S. petroleum industry, including the refining market. Over 2,600 mergers have occurred in the U.S. petroleum industry since the 1990s, mostly later in the period. Industry officials cited various reasons for the mergers, particularly the need for increased efficiency and cost savings. Economic literature also suggests that firms sometimes merge to enhance their ability to control prices. Partly because of the mergers, market concentration has increased in the industry, mostly in the downstream (refining and marketing) segment. For example, market concentration in refining increased from moderately to highly concentrated in the East Coast and from unconcentrated to moderately concentrated in the West Coast. Concentration in the wholesale gasoline market increased substantially from the mid-1990s so that by 2002, most states had either moderately or highly concentrated wholesale gasoline markets. Anecdotal evidence suggests that mergers also have changed other factors affecting competition, such as the ability of new firms to enter the market. Two major changes have occurred in U.S. gasoline marketing related to mergers, according to industry officials. First, the availability of generic gasoline, which is generally priced lower than branded gasoline, has decreased substantially. Second, refiners now prefer to deal with large distributors and retailers, which has motivated further consolidation in distributor and retail markets. Based on data from the mid-1990s through 2000, GAO's econometric analyses indicate that mergers and increased market concentration generally led to higher wholesale gasoline prices in the United States. Six of the eight mergers GAO modeled led to price increases, averaging about 1 cent to 2 cents per gallon. Increased market concentration, which reflects the cumulative effects of mergers and other competitive factors, also led to increased prices in most cases. For example, wholesale prices for boutique fuels sold in the East and Gulf Coasts--fuels supplied by fewer refiners than conventional gasoline--increased by about 1 cent per gallon, while prices for boutique fuels sold in California increased by over 7 cents per gallon. GAO also identified price increases of one-tenth of a cent to 7 cents that were caused by other factors included in the models, particularly low gasoline inventories relative to demand, supply disruptions in some regions, and high refinery capacity utilization rates. For example, we found that a 1 percent increase in refinery capacity utilization rates resulted in price increases of one-tenth to two-tenths of a cent per gallon. FTC disagreed with GAO's methodology and findings. However, GAO believes its analyses are sound.

section_title: Letter
paragraphs: We are pleased to be here today to participate in discussing issues related  to the “Status of the U.S. Refining Industry.” Refining transforms crude oil  into a wide range of petroleum products, with gasoline accounting for  about half of U.S. refinery output.
Data from the Energy Information Administration (EIA) indicate that there  are currently 149 refineries in the United States with a total crude oil  distillation capacity of about 16.9 million barrels per day. As we testified in  2001, each day vehicles in the United States consume about 10 million  barrels of petroleum fuels, primarily gasoline and diesel, and according to  projections, the figure will rise to about 15 million barrels per day by 2010,  raising concerns about our ability to satisfy this growing demand.  According to the United States Energy Association, no new major refinery  has been built on the U.S. mainland in the last 25 years, and the nation’s  overall distillation capacity has declined more than 10 percent since the  peak in 1981.
Concerns have also been raised about recent price increases for gasoline.  EIA data show that the average retail price for regular gasoline (the type of  gasoline used most in the United States) recently hit a nationwide high of  $2.06 cents/gallon by the end of May 2004, an increase of about 58  cents/gallon or 39 percent over the same time last year. In some parts of  the country, such as the West Coast, gasoline prices reached an average of  $2.34 cents/gallon by the end of May 2004, an increase of about 65  cents/gallon or 38 percent over the same time last year. Although prices  have recently begun to fall, elevated gasoline prices can be an economic  burden to American consumers and the economy.
A broad range of factors affects gasoline prices and its volatility. These  factors typically include changes in crude oil costs, refinery capacity,  inventory levels relative to demand, supply disruptions, and regulatory  factors—such as many different gasoline formulations that are required to  meet varying federal and state environmental laws. Federal and state taxes  are also a component of U.S. gasoline prices, but these do not fluctuate  often. We have addressed many of these issues in several studies on  energy markets. Among other things, our past studies showed that  the U.S. economy is vulnerable to oil supply disruptions and options were  identified to mitigate their effects; the Clean Air Act specifically requires refiners to produce reformulated  gasoline, and the requirement to provide a specific blend for a specific  area can present challenges to refiners and other suppliers if there are  supply disruptions;   most spikes in gasoline prices appear to result from such factors as  increases in world crude oil prices, unexpected refinery outages, or larger- than-expected increase in demand; and   gasoline price spikes were generally higher in California from January  1995 through December 1999 than in the rest of the nation, partly because  there were unplanned refinery outages and it was difficult to substitute for  the loss of supply of CARB, the special reformulated gasoline used in  California.
Market consolidation is another factor that can affect the price of gasoline.  Our testimony today will focus on our recent study that examined the  effects of market consolidation—including increased market  concentration in refining—and other factors related to the U. S. petroleum  industry.
Since the 1990s, the U.S. petroleum industry has experienced a wave of  mergers, acquisitions, and joint ventures, several of them between large oil  companies that had previously competed with each other for the sale of  petroleum products. A few examples include the merger between British  Petroleum (BP) and Amoco in 1998 to form BPAmoco, which later merged  with ARCO, and the merger in 1999 between Exxon, the largest U.S. oil  company, and Mobil, the second largest. In general, mergers raise  concerns about potential anticompetitive effects on the U.S. petroleum  industry and ultimately on gasoline prices because mergers could result in  greater market power for the merged companies, potentially allowing  them to increase prices above competitive levels. On the other hand,  mergers could also yield cost savings and efficiency gains, which may be  passed on to consumers in lower prices. Ultimately, the impact depends  on whether market power or efficiency dominates.
Our report examined mergers in the U.S. petroleum industry from the  1990s through 2000; the changes in market concentration (the distribution  of market shares among competing firms) in the different segments,  including refining, and other factors affecting competition in the U.S.  petroleum industry; how U.S. gasoline marketing has changed since the  1990s; and how mergers and market concentration in the U.S. petroleum  industry have affected U.S. gasoline prices at the wholesale level.
To address these issues, we purchased and analyzed a large body of data  on mergers and wholesale gasoline prices, as well as data on other  relevant economic factors, including refinery capacity. We also developed  econometric models for examining the effects of eight specific mergers  and increased market concentration on U.S. wholesale gasoline prices  nationwide. It is noteworthy that using econometric models allowed us to  measure the effects of mergers and market concentration while isolating  the effects of several other factors that could influence wholesale gasoline  prices, such as world crude oil costs, limited refining capacity, or low  inventories relative to demand. For our market concentration model, we  used concentration data measured at the refining level. We believe that the  source of potential market power in the wholesale gasoline market is at  the refining level because the refinery market is imperfectly competitive  and refiners essentially control gasoline sales at the wholesale level.
In the course of our work, we consulted with Dr. Severin Borenstein, a  recognized expert in the modeling of gasoline markets; interviewed  officials across the industry spectrum; and reviewed relevant economic  literature and numerous related studies. We also used an extensive peer  review process to obtain comments from experts in academia and relevant  government agencies. We conducted our work in accordance with  generally accepted government auditing standards.
In summary, we found the following:    Over 2,600 mergers occurred in the petroleum industry from 1991 through  2000, mostly during the second half of the decade. Petroleum industry  officials cited various reasons for this wave of mergers, particularly the  need for increased efficiency and cost savings. Economic literature  suggests that firms also sometimes use mergers to enhance their market  power. Ultimately, the reasons cited by both sources generally relate to  the merging companies’ desire to maximize profit or shareholder wealth.
Market concentration, which is commonly measured by the Herfindahl- Hirschman Index (HHI), has increased in the downstream (refining and  marketing) segment of the U.S. petroleum industry since the 1990s, partly  as a result of merger activities, while changing very little in the upstream  (exploration and production) segment. Of particular interest to this  subcommittee, market concentration in refining increased, although the  levels as well as the changes varied geographically. For example, market  concentration in refining increased from moderately to highly  concentrated in the East Coast and from unconcentrated to moderately  concentrated in the West Coast; it increased but remained moderately  concentrated in the Rocky Mountain region. Concentration in the  wholesale gasoline market increased substantially from the mid-1990s so  that by 2002, most states had either moderately or highly concentrated  wholesale gasoline markets. Anecdotal evidence suggests that mergers  may also have affected other factors that impact competition, such as the  ability of new firms to enter the market.
According to industry officials, two major changes have occurred in U.S.  gasoline marketing since the 1990s, partly related to mergers. First, the  availability of unbranded (generic) gasoline has decreased substantially.  Unbranded gasoline is generally priced lower than branded gasoline,  which is marketed under the refiner’s trademark. Industry officials  generally attributed the decreased availability of unbranded gasoline to,  among other factors, a reduction in the number of independent refiners  that typically supply unbranded gasoline. Second, industry officials said  that refiners now prefer dealing with large distributors and retailers. This  preference, according to the officials, has motivated further consolidation  in both the distributor and retail markets, including the rise of  hypermarkets—a relatively new breed of gasoline market participants that  includes such large retail warehouses as Wal-Mart and Costco.
Our econometric analyses, using data from the mid-1990s through 2000,  show that oil industry mergers generally led to higher wholesale gasoline  prices (measured in our report as wholesale prices less crude oil prices),  although prices sometimes decreased. Six of the eight specific mergers we  modeled—which mostly involved large, fully vertically integrated  companies—generally resulted in increases in wholesale prices for  branded and/or unbranded gasoline of about 2 cents per gallon, on  average. Two of the mergers generally led to price decreases averaging  about 1 cent per gallon. The preponderance of price increases over  decreases indicates that the market power effects, which tend to increase  prices, for the most part outweighed the efficiency effects, which tend to  decrease prices.
Our econometric analyses also show that increased market concentration,  which captures the cumulative effects of mergers as well as other market  structure factors, also generally led to higher prices for conventional  gasoline and for boutique fuels—gasoline that has been reformulated for  certain areas in the East Coast and Gulf Coast regions and in California to  lower pollution. The price increases were particularly large in California,  where they averaged about 7 cents per gallon.
Higher wholesale gasoline prices were also a result of other factors: high  refinery capacity utilization rate; low gasoline inventories, which typically  occur in the summer driving months; and supply disruptions, which  occurred in the Midwest and on the West Coast. We identified price  increases of one-tenth of 1 cent to 7 cents per gallon that were caused by  other factors included in our models—particularly low gasoline  inventories relative to demand, high refinery capacity utilization rates, and  supply disruptions that occurred in some regions. For example, we found  that a 1 percent increase in refinery capacity utilization rates resulted in  price increases of one-tenth to two-tenths of a cent per gallon. We found  that prices were higher because higher refinery capacity utilization rates  leave little room for error in predicting short-run demand. During the  period of our study, refinery capacity utilization rates at the national level  averaged about 94 percent per week. Just last week, DOE testified that  U.S. refineries are running at near total capacity of about 96 percent.
As I noted earlier, we used extensive peer review to obtain comments  from outside experts, including FTC and EIA, and we incorporated those  comments as appropriate. FTC disagreed with our methodology and  findings and provided extensive comments, which we have addressed in  our report. Our findings are generally consistent with previous studies of  the effects of specific oil mergers and of market concentration on gasoline  prices. We believe, however, that ours is the first comprehensive study to  model the impact of the industry’s 1990s wave of mergers on wholesale  gasoline prices for the entire United States, an effort that required us to  acquire large datasets and perform complex analyses.
subsections: section_title: Background
paragraphs: Many firms of varying sizes make up the U.S. petroleum industry. While  some firms engage in only limited activities within the industry, such as  exploration for and production of crude oil and natural gas or refining  crude oil and marketing petroleum products, fully vertically integrated oil  companies participate in all aspects of the industry. Before the 1970s,  major oil companies that were fully vertically integrated controlled the  global network for supplying, pricing, and marketing crude oil. However,  the structure of the world crude oil market has dramatically changed as a  result of such factors as the nationalization of oil fields by oil-producing  countries, the emergence of independent oil companies, and the evolution  of futures and spot markets in the 1970s and 1980s. Since U.S. oil prices  were deregulated in 1981, the price paid for crude oil in the United Stated  has been largely determined in the world oil market, which is mostly  influenced by global factors, especially supply decisions of the  Organization of Petroleum Exporting Countries (OPEC) and world  economic and political conditions.
The United States currently imports over 60 percent of its crude oil supply.  In contrast, the bulk of the gasoline used in the United States is produced  domestically. In 2001, for example, gasoline refined in the United States  accounted for over 90 percent of the total domestic gasoline consumption.  Companies that supply gasoline to U.S. markets also post the domestic  gasoline prices. Historically, the domestic petroleum market has been  divided into five regions: the East Coast region, the Midwest region, the  Gulf Coast region, the Rocky Mountain region, and the West Coast region.  (See fig. 1.) These regions are known as Petroleum Administration for  Defense Districts (PADDs).
Proposed mergers in all industries, including the petroleum industry, are  generally reviewed by federal antitrust authorities—including the Federal  Trade Commission (FTC) and the Department of Justice (DOJ)—to assess  the potential impact on market competition. According to FTC officials,  FTC generally reviews proposed mergers involving the petroleum industry  because of the agency’s expertise in that industry. FTC analyzes these  mergers to determine if they would likely diminish competition in the  relevant markets and result in harm, such as increased prices. To  determine the potential effect of a merger on market competition, FTC  evaluates how the merger would change the level of market concentration,  among other things. Conceptually, the higher the concentration, the less  competitive the market is and the more likely that firms can exert control  over prices. The ability to maintain prices above competitive levels for a  significant period of time is known as market power.
According to the merger guidelines jointly issued by DOJ and FTC, market  concentration as measured by HHI is ranked into three separate  categories: a market with an HHI under 1,000 is considered to be  unconcentrated; if HHI is between 1,000 and 1,800 the market is  considered moderately concentrated; and if HHI is above 1,800, the market  is considered highly concentrated.
While concentration is an important aspect of market structure—the  underlying economic and technical characteristics of an industry—other  aspects of market structure that may be affected by mergers also play an  important role in determining the level of competition in a market. These  aspects include barriers to entry, which are market conditions that provide  established sellers an advantage over potential new entrants in an  industry, and vertical integration.
section_title: Mergers Occurred in All Segments of the U.S. Petroleum Industry in the 1990s for Several Reasons
paragraphs: Over 2,600 merger transactions occurred from 1991 through 2000 involving  all three segments of the U.S. petroleum industry. Almost 85 percent of the  mergers occurred in the upstream segment (exploration and production),  while the downstream segment (refining and marketing of petroleum)  accounted for about 13 percent, and the midstream segment  (transportation) accounted for over 2 percent. The vast majority of the  mergers—about 80 percent—involved one company’s purchase of a  segment or asset of another company, while about 20 percent involved the  acquisition of a company’s total assets by another so that the two became  one company. Most of the mergers occurred in the second half of the  decade, including those involving large partially or fully vertically  integrated companies.
Petroleum industry officials and experts we contacted cited several  reasons for the industry’s wave of mergers in the 1990s, including  achieving synergies, increasing growth and diversifying assets, and  reducing costs. Economic literature indicates that enhancing market  power is also sometimes a motive for mergers. Ultimately, these reasons  mostly relate to companies’ desire to maximize profit or stock values.
section_title: Mergers Contributed to Increases in Market Concentration and to Other Changes That Affect Competition
paragraphs: Mergers in the 1990s contributed to increases in market concentration in  the downstream (refining and marketing) segment of the U.S. petroleum  industry, while the upstream segment experienced little change.
Overall, the refining market experienced increasing levels of market  concentration (based on refinery capacity) in all five PADDs during the  1990s, especially during the latter part of the decade, but the levels as well  as the changes of concentration varied geographically.
In PADD I—the East Coast—the HHI for the refining market increased  from 1136 in 1990 to 1819 in 2000, an increase of 683 (see fig. 2).  Consequently, this market went from moderately concentrated to highly  concentrated. Compared to other U.S. PADDs, a greater share of the  gasoline consumed in PADD I comes from other supply sources—mostly  from PADD III and imports—than within the PADD. Consequently, some  industry officials and experts believe that the competitive impact of  increased refiner concentration within the PADD could be mitigated.
For PADD II (the Midwest), the refinery market concentration increased  from 699 to 980 —an increase of 281—between 1990 and 2000. However,  as figure 3 shows, this PADD’s refining market remained unconcentrated  at the end of the decade. According to EIA’s data, as of 2001, the quantity  of gasoline refined in PADD II was slightly less than the quantity  consumed within the PADD.
The refining market in PADD III (the Gulf Coast), like PADD II, was  unconcentrated as of the end of 2000, although its HHI increased by 170— from 534 in 1990 to 704 in 2000 (see fig. 4). According to EIA’s data, much  more gasoline is refined in PADD III than is consumed within the PADD,  making PADD III the largest net exporter of gasoline to other parts of the  United States.
The HHI for the refining market in PADD IV—the Rocky Mountain  region—where gasoline production and consumption are almost  balanced—increased by 95 between 1990 and 2000. This increase changed  the PADD’s refining market from 1029 in 1990 to 1124 in 2000, within the  moderate level of market concentration (see fig. 5).
The refining market’s HHI for PADD V—the West Coast—increased from  937 to 1267, an increase of 330, between 1990 and 2000 and changed the  West Coast refining market, which produces most of the gasoline it  consumes, from unconcentrated to moderately concentrated by the end of  the decade (see fig. 6).
We estimated a high and statistically significant degree of correlation  between merger activity and the HHIs for refining in PADDs I, II, and V for  1991 through 2000. Specifically, the corresponding correlation numbers  are 91 percent for PADD V (West Coast), 93 percent for PADD II  (Midwest), and 80 percent for PADD I (East Coast). While mergers were  positively correlated with refining HHIs in PADDs III and IV—the Gulf  Coast and the Rocky Mountains—the estimated correlations were not  statistically significant.
In wholesale gasoline markets, market concentration increased broadly  throughout the United States between 1994 and 2002. Specifically, we  found that 46 states and the District of Columbia had moderately or highly  concentrated markets by 2002, compared to 27 in 1994.
Evidence from various sources indicates that, in addition to increasing  market concentration, mergers also contributed to changes in other  aspects of market structure in the U.S. petroleum industry that affect  competition—specifically, vertical integration and barriers to entry.
However, we could not quantify the extent of these changes because of a  lack of relevant data.
Vertical integration can conceptually have both pro- and anticompetitive  effects. Based on anecdotal evidence and economic analyses by some  industry experts, we determined that a number of mergers that have  occurred since the 1990s have led to greater vertical integration in the U.S.  petroleum industry, especially in the refining and marketing segment. For  example, we identified eight mergers that occurred between 1995 and 2001  that might have enhanced the degree of vertical integration, particularly in  the downstream segment.
Concerning barriers to entry, our interviews with petroleum industry  officials and experts provide evidence that mergers had some impact on  the U.S. petroleum industry. Barriers to entry could have implications for  market competition because companies that operate in concentrated  industries with high barriers to entry are more likely to possess market  power. Industry officials pointed out that large capital requirements and  environmental regulations constitute barriers for potential new entrants  into the U.S. refining business. For example, the officials indicated that a  typical refinery could cost billions of dollars to build and that it may be  difficult to obtain the necessary permits from the relevant state or local  authorities.
section_title: U.S. Gasoline Marketing Has Changed in Two Major Ways
paragraphs: According to some petroleum industry officials that we interviewed,  gasoline marketing in the United States has changed in two major ways  since the 1990s. First, the availability of unbranded gasoline has  decreased, partly due to mergers. Officials noted that unbranded gasoline  is generally priced lower than branded. They generally attributed the  decreased availability of unbranded gasoline to one or more of the  following factors:    There are now fewer independent refiners, who typically supply mostly  unbranded gasoline. These refiners have been acquired by branded  companies, have grown large enough to be considered a brand, or have  simply closed down.
Partially or fully vertically integrated oil companies have sold or  mothballed some refineries. As a result, some of these companies now  have only enough refinery capacity to supply their own branded needs,  with little or no excess to sell as unbranded.
Major branded refiners are managing their inventory more efficiently,  ensuring that they produce only enough gasoline to meet their current  branded needs. We could not quantify the extent of the decrease in the  unbranded gasoline supply because the data required for such analyses do  not exist.
The second change identified by these officials is that refiners now prefer  dealing with large distributors and retailers because they present a lower  credit risk and because it is more efficient to sell a larger volume through  fewer entities. Refiners manifest this preference by setting minimum  volume requirements for gasoline purchases. These requirements have  motivated further consolidation in the distributor and retail sectors,  including the rise of hypermarkets.
section_title: Mergers and Increased Market Concentration Generally Led to Higher U.S. Wholesale Gasoline Prices
paragraphs: Our econometric modeling shows that the mergers we examined mostly  led to higher wholesale gasoline prices in the second half of the 1990s. The  majority of the eight specific mergers we examined—Ultramar Diamond  Shamrock (UDS)-Total, Tosco-Unocal, Marathon-Ashland, Shell-Texaco I  (Equilon), Shell-Texaco II (Motiva), BP-Amoco, Exxon-Mobil, and  Marathon Ashland Petroleum (MAP)-UDS—resulted in higher prices of  wholesale gasoline in the cities where the merging companies supplied  gasoline before they merged. The effects of some of the mergers were  inconclusive, especially for boutique fuels sold in the East Coast and Gulf  Coast regions and in California.
For the seven mergers that we modeled for conventional gasoline, five led  to increased prices, especially the MAP-UDS and Exxon-Mobil mergers,  where the increases generally exceeded 2 cents per gallon, on average.
For the four mergers that we modeled for reformulated gasoline, two— Exxon-Mobil and Marathon-Ashland—led to increased prices of about 1  cent per gallon, on average. In contrast, the Shell-Texaco II (Motiva)  merger led to price decreases of less than one-half cent per gallon, on  average, for branded gasoline only.
For the two mergers—Tosco-Unocal and Shell-Texaco I (Equilon)—that  we modeled for gasoline used in California, known as California Air  Resources Board (CARB) gasoline, only the Tosco-Unocal merger led to  price increases. The increases were for branded gasoline only and  exceeded 6 cents per gallon, on average.
For market concentration, which captures the cumulative effects of  mergers as well as other competitive factors, our econometric analysis  shows that increased market concentration resulted in higher wholesale  gasoline prices.
Prices for conventional (non-boutique) gasoline, the dominant type of  gasoline sold nationwide from 1994 through 2000, increased by less than  one-half cent per gallon, on average, for branded and unbranded gasoline.  The increases were larger in the West than in the East—the increases were  between one-half cent and one cent per gallon in the West, and about one- quarter cent in the East (for branded gasoline only), on average.
Price increases for boutique fuels sold in some parts of the East Coast and  Gulf Coast regions and in California were larger compared to the increases  for conventional gasoline. The wholesale prices increased by an average of  about 1 cent per gallon for boutique fuel sold in the East Coast and Gulf  Coast regions between 1995 and 2000, and by an average of over 7 cents  per gallon in California between 1996 and 2000.
Our analysis shows that wholesale gasoline prices were also affected by  other factors included in the econometric models, including gasoline  inventories relative to demand, supply disruptions in some parts of the  Midwest and the West Coast, and refinery capacity utilization rates. For  refinery capacity utilization rates, we found that prices were higher by  about an average of one-tenth to two-tenths of 1 cent per gallon when  utilization rates increased by 1 percent. We found that prices were higher  because higher refinery capacity utilization rates leave little room for error  in predicting short-run demand. During the period of our study, refinery  capacity utilization rates at the national level averaged about 94 percent  per week.
Mr. Chairman, this concludes my prepared statement. I would be happy to  respond to any questions that you or other Members of the Subcommittee  may have.
section_title: GAO Contacts and Staff Acknowledgments
paragraphs: For further information about this testimony, please contact me at (202)  512-3841. Key contributors to this testimony included Godwin Agbara,  John A. Karikari, and Cynthia Norris.
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