1. Transmission system operators shall ensure firm capacity for the access of production facilities of renewable gas and low-carbon gas connected to their grid. To that end, transmission system operators shall, in cooperation with the distribution system operators, develop procedures and arrangements, including investments, to ensure reverse flow from the distribution network to the transmission network. Major investments shall be reflected in the ten-year network development plan pursuant to Article 55(2), point (a), of Directive (EU) 2024/1788.
2. Paragraph 1 shall be without prejudice to the possibility for transmission system operators to develop alternatives to reverse-flow investments, such as smart grid solutions or connection to other network operators including the direct connection of production facilities of renewable gas and low-carbon gas to the transmission network. Firm capacity access may be limited to offering capacities subject to operational limitations, in order to ensure infrastructure safety and economic efficiency. The regulatory authority shall be responsible for reviewing and approving the transmission system operators’ conditions for conditional capacity and shall ensure that any limitations in firm capacity or operational limitations are introduced by transmission system operators on the basis of transparent and non-discriminatory procedures and do not create undue barriers to market entry. Where the production facility bears the costs related to ensuring firm capacity, no limitation shall apply.
Cross-border coordination with regard to gas quality in the natural gas system
1. Transmission system operators shall cooperate to avoid restrictions to cross-border flows due to gas quality differences at interconnection points between Member States. When so cooperating, transmission system operators shall take into account the characteristics of installations of final natural gas customers.
This Article shall not apply to hydrogen blends where the hydrogen content blended into the natural gas system exceeds 2 % by volume.
2. Member States shall ensure that diverging technical specifications, including gas quality parameters such as oxygen content and hydrogen blending in the natural gas system, are not used to restrict cross-border natural gas flows. In addition, Member States shall ensure that hydrogen blends in the natural gas system are aligned with the technical specifications acceptable to customers.
3. Where a restriction to cross-border flows due to gas quality differences cannot be avoided by the transmission system operators concerned in their standard operations, they shall inform the regulatory authorities concerned without delay. The information shall include a description and the reasons justifying any measures already taken by the transmission system operators.
4. The regulatory authorities concerned shall jointly agree, within six months of receipt of the information referred to in paragraph 3, whether to recognise the restriction.
5. As regards restrictions to cross-border flows caused by differences in hydrogen blending in the natural gas system and that are recognised pursuant to paragraph 4, transmission system operators shall accept natural gas flows with a hydrogen content at interconnection points between Member States in the natural gas system subject to paragraphs 6 to 13, and after completion of the procedure laid down therein.
6. Where the regulatory authorities concerned recognise the restriction pursuant to paragraph 4, they shall request the transmission system operators concerned to perform, within 12 months of the recognition of the restriction as referred to in that paragraph, the following actions in sequence:
(a)
to cooperate and develop technically feasible options, without changing the gas quality specifications, which may include flow commitments and natural gas treatment, in order to remove the recognised restriction taking into account information provided by final customers directly connected to the natural gas system of the transmission system operator concerned or any other stakeholder that could be affected by that procedure;
(b)
jointly to carry out a cost-benefit analysis on the technically feasible options to define economically efficient solutions which shall specify the breakdown of costs and benefits among the categories of affected parties;
(c)
to produce an estimate of the implementation time for each potential option;
(d)
to conduct a public consultation, in particular of final customers affected that are connected to the natural gas system, on identified feasible solutions and take into consideration the results of that consultation;
(e)
to submit a joint proposal, on the basis of the cost-benefit analysis and results of the public consultation, for a solution removing the recognised restriction, including the timeframe for its implementation, to their regulatory authorities concerned for approval and to the other competent national authorities of each Member State concerned for information.
7. Where the transmission system operators concerned do not reach an agreement to submit a joint proposal pursuant to paragraph 6, point (e), each transmission system operator shall inform its regulatory authority without delay.
8. The regulatory authorities concerned shall take a joint coordinated decision to remove the recognised restriction, taking into account the cost-benefit analysis carried out by the transmission system operators concerned and the results of the public consultation conducted pursuant to paragraph 6, point (d), of this Article within six months of receipt of the information referred to in paragraph 7 of this Article in accordance with Article 6(10) of Regulation (EU) 2019/942.
9. By way of derogation from paragraph 8 of this Article, for restrictions to cross-border flows caused by differences in hydrogen blending in the natural gas system, the regulatory authorities concerned may jointly declare that no further action is to be pursued to remove such restrictions. The joint coordinated decision shall be taken within six months of receipt of the information referred to in paragraph 7 of this Article in accordance with Article 6(10) of Regulation (EU) 2019/942 and shall take into account the cost-benefit analysis and the results of the public consultation conducted pursuant to paragraph 6, point (d), of this Article. The regulatory authorities concerned shall review a decision to maintain the recognised restriction pursuant to this paragraph every four years.
10. The joint coordinated decision of the regulatory authorities concerned referred to in paragraph 8 shall include a decision on the allocation of the investment costs to be borne by each transmission system operator for implementing the agreed solution, as well as their inclusion in the allowed or target revenue of transmission system operators, taking into account the economic, social and environmental costs and benefits of the solution in the Member States concerned and its consequences for tariffs.
11. ACER may issue recommendations to the regulatory authorities on the details of such cost allocation decisions as referred to in paragraph 10.
12. Where the regulatory authorities concerned cannot reach an agreement as referred to in paragraph 4 of this Article, ACER shall decide on the restriction in accordance with Article 6(10) of Regulation (EU) 2019/942. Where ACER recognises the restriction, it shall request the transmission system operators concerned to perform, within 12 months, the actions referred to in paragraph 6 of this Article in sequence.
13. Where the regulatory authorities concerned cannot take a joint coordinated decision as referred to in paragraphs 8 and 10 of this Article, ACER shall decide on the solution to remove the recognised restriction and on the allocation of the investment costs to be borne by each transmission system operator for implementing the agreed solution or stating that no further action is to be pursued pursuant to paragraph 9 of this Article, in accordance with Article 6(10) of Regulation (EU) 2019/942. A decision to maintain the recognised restriction pursuant to this paragraph shall be reviewed every four years by ACER.
14. Further details required to implement this Article, including details on the cost-benefit analysis, shall be laid down in a network code established pursuant to Article 71(2).
Presumption of conformity of practices with harmonised standards for natural gas
Practices which are in conformity with harmonised standards, or parts thereof, the references of which have been published in the Official Journal of the European Union shall be presumed to be in conformity with the requirements laid down in implementing acts adopted pursuant to Article 71(2), first subparagraph, point (a).
1. The Commission may adopt implementing acts establishing common specifications for facilitating the cost-effective integration of large volumes of biomethane in the existing natural gas system, including at cross-border interconnection points, or may establish those specifications in a network code pursuant to Article 71(2), first subparagraph, point (a), where:
(a)
those requirements are not covered by harmonised standards, or parts thereof, the references of which have been published in the Official Journal of the European Union;
(b)
the Commission has requested, pursuant to Article 10(1) of Regulation (EU) No 1025/2012, one or more European standardisation organisation to draft a harmonised standard for those requirements and at least one of the following conditions has been fulfilled:
(i)
the request of the Commission has not been accepted by any of the European standardisation organisations;
(ii)
the Commission observes undue delays in the adoption of the requested harmonised standards;
(iii)
a European standardisation organisation has delivered a standard that does not entirely correspond with the request of the Commission; or
(c)
the Commission has decided in accordance with the procedure referred to in Article 11(5) of Regulation (EU) No 1025/2012 to maintain with restriction or to withdraw the references to the harmonised standards, or parts thereof, by which those requirements are covered.
The implementing acts referred to in the first subparagraph of this paragraph shall be adopted in accordance with the examination procedure referred to in Article 81(3).
2. In the early preparation of the draft implementing act establishing the common specifications referred to in paragraph 1, the Commission shall gather the views of relevant bodies or expert groups established under relevant sectorial Union law, and shall duly consult all relevant stakeholders. On the basis of that consultation, the Commission shall prepare the draft implementing act.
3. Practices which are in conformity with common specifications, or parts thereof, shall be presumed to be in conformity with the requirements laid down in the implementing acts adopted pursuant to Article 71(2), first subparagraph, point (a), to the extent that those requirements are covered by such common specifications or parts thereof.
4. Where a harmonised standard is adopted by a European standardisation organisation and proposed to the Commission for the purpose of publishing its reference in the Official Journal of the European Union, the Commission shall assess the harmonised standard in accordance with Regulation (EU) No 1025/2012. When the reference of a harmonised standard is published in the Official Journal of the European Union, the Commission shall repeal implementing acts referred to in paragraph 1 of this Article, or parts thereof which cover the same requirements referred to in paragraph 1 of this Article.
5. In setting the common specifications pursuant to this Article, the Commission shall take the utmost account of the safety requirements necessary for the safe operation of the natural gas system, in particular of the safe operation of the natural gas storage facilities across the Union.
European network of transmission system operators for gas
All transmission system operators shall cooperate at Union level through the ENTSO for Gas, in order to promote the completion and proper functioning of the internal market for natural gas and cross-border trade and to ensure the optimal management, coordinated operation and sound technical evolution of the natural gas transmission network.
1. The ENTSO for Gas shall, on their own initiative or upon a reasoned request of the Commission or ACER, publish and submit to the Commission and to ACER any draft amendment to the statutes, list of members or rules of procedure, including the rules of procedure on the consultation of other stakeholders, of the ENTSO for Gas.
2. Within four months of receipt of the documents referred to in paragraph 1, ACER shall, after formally consulting the organisations representing all stakeholders, in particular the system users including customers, provide an opinion to the Commission on the draft amendment to the statutes, list of members and rules of procedure of the ENTSO for Gas.
3. The Commission shall issue an opinion on the draft amendment to the statutes, list of members and rules of procedure of the ENTSO for Gas, taking into account ACER’s opinion referred to in paragraph 2, within three months of the date of receipt of that opinion.
4. Within three months of receipt of the Commission’s favourable opinion, the ENTSO for Gas shall adopt and publish the revised statutes, list of members and rules of procedure of the ENTSO for Gas.
1. The ENTSO for Gas shall elaborate network codes in the areas referred to in Article 71(1) and (2) upon a request addressed to it by the Commission in accordance with Article 71(9).
The network code referred to in Article 71(2), first subparagraph, point (d), shall be developed jointly with the ENNOH.
2. The ENTSO for Gas may elaborate network codes in the areas set out in Article 71(1) and (2) with a view to achieving the objectives set out in Article 24, where those network codes do not relate to areas covered by a request addressed to it by the Commission. Those network codes shall be submitted to ACER for an opinion. That opinion shall be duly taken into account by the ENTSO for Gas.
3. The ENTSO for Gas shall adopt:
(a)
common network operation tools to ensure the coordination of network operation in normal and emergency conditions, including a common incidents classification scale, and research plans;
(b)
a non-binding Union-wide ten-year network development plan for natural gas referred to in Article 32 (the ‘Union-wide network development plan for natural gas’), including a European supply adequacy outlook, every two years;
(c)
recommendations relating to the coordination of technical cooperation between Union and third-country transmission system operators;
(d)
recommendations to transmission system operators on their technical cooperation with distribution system operators and hydrogen network operators;
(e)
an annual work programme;
(f)
an annual report;
(g)
annual summer and winter supply outlooks;
(h)
a gas quality monitoring report by 1 January 2025 and every two years thereafter, including developments of gas quality parameters, developments of the level and volume of hydrogen blended into the natural gas system, forecasts for the expected development of gas quality parameters and of the volume of hydrogen blended into the natural gas system, the impact of blending hydrogen on cross-border flows as well as information on cases related to differences in gas quality specifications or in specifications of blending levels and how such cases were settled, with a view to meeting the quality requirements of different end-use applications;
(i)
an annual report including the quantity of renewable gas and low-carbon gas injected into the natural gas network.
The gas quality monitoring report referred to in the first subparagraph, point (h) shall also cover the development for the areas listed in that point, as far as relevant for the distribution network, on the basis of information provided by the European entity for distribution system operators (the ‘EU DSO entity’) established pursuant to Article 52(1) of Regulation (EU) 2019/943 of the European Parliament and of the Council ( 39 ) .
4. The European supply adequacy outlook referred to in paragraph 3, point (b), shall cover the overall adequacy of the natural gas system to supply current and planned demands for natural gas for the next five-year period as well as for the period between five and 10 years from the date of that outlook. The European supply adequacy outlook shall build on national supply outlooks prepared by each individual transmission system operator. The European supply adequacy outlook shall specifically provide for monitoring of progress on the annual production of sustainable biomethane.
Where both the European supply adequacy outlook and the final updated integrated national energy and climate plans show that the annual production is not sufficiently progressing or that the natural gas consumption is not sufficiently decreasing in view of the available potential, the Commission may issue recommendations to the Member States, if necessary to achieve the objectives of the Energy Union, pursuant to Article 34 of Regulation (EU) 2018/1999.
The Union-wide network development plan for natural gas shall include the modelling of the integrated network, including hydrogen networks, scenario development, a European supply adequacy outlook and an assessment of the resilience of the system. That plan shall promote the energy efficiency first principle and energy system integration.
5. The annual work programme referred to in paragraph 3, point (e), shall contain a list and description of the network codes to be prepared, a plan on the coordination of the operation of the network, and a list of research and development activities, to be realised in the course of that year, and an indicative calendar.
6. The network codes shall be developed for cross-border network issues and market integration issues and shall be without prejudice to the Member States’ right to establish national network codes which do not affect cross-border trade.
7. The ENTSO for Gas shall monitor and analyse the implementation of the network codes and the guidelines adopted by the Commission in accordance with Article 71(13) or Article 74, and their effect on the harmonisation of applicable rules aimed at facilitating market integration. The ENTSO for Gas shall report its findings to ACER and shall include the results of the analysis in the annual report referred to in paragraph 3, point (f), of this Article.
8. The ENTSO for Gas shall make available all information required by ACER to fulfil its tasks under Article 27(1).
9. ACER shall review national ten-year network development plans to assess their consistency with the Union-wide network development plan for natural gas. If ACER identifies inconsistencies between a national ten-year network development plan and the Union-wide network development plan for natural gas, it shall recommend amending the national ten-year network development plan or the Union-wide network development plan for natural gas as appropriate. If such national ten-year network development plan is elaborated in accordance with Article 55 of Directive (EU) 2024/1788, ACER shall recommend that the relevant regulatory authority amend the national ten-year network development plan in accordance with Article 55(5) of that Directive and inform the Commission thereof.
10. Upon request of the Commission, the ENTSO for Gas shall give its views to the Commission on the adoption of the guidelines as laid down in Article 74.
11. The ENTSO for Gas shall cooperate with the European Network of Transmission System Operators for Electricity (the ‘ENTSO for Electricity’) and with the ENNOH.
1. ACER shall monitor the execution of the tasks of the ENTSO for Gas referred to in Article 26(1), (2) and (3) and report its findings to the Commission.
ACER shall monitor the implementation by the ENTSO for Gas of network codes elaborated pursuant to Article 26(2) and network codes which have been developed in accordance with Article 71(1) to (12) but which have not been adopted by the Commission pursuant to Article 71(13). Where the ENTSO for Gas has failed to implement such network codes, ACER shall request the ENTSO for Gas to provide a duly reasoned explanation as to why it has failed to do so. ACER shall inform the Commission of that explanation and provide its opinion thereon.
ACER shall monitor and analyse the implementation of the network codes and the guidelines adopted by the Commission as laid down in Articles 70, 71, 73 and 74, and their effect on the harmonisation of applicable rules aimed at facilitating market and energy system integration as well as on non-discrimination, effective competition and the proper functioning of the market, and report to the Commission.
2. The ENTSO for Gas shall submit the draft Union-wide network development plan for natural gas, the draft annual work programme, including the information regarding the consultation process, and the other documents referred to in Article 26(3), to ACER for its opinion.
Within two months of the date of receipt, ACER shall provide a duly reasoned opinion as well as recommendations to the ENTSO for Gas and to the Commission where it considers that the draft annual work programme or the draft Union-wide network development plan for natural gas submitted by the ENTSO for Gas does not contribute to non-discrimination, effective competition, the proper functioning of the market or a sufficient level of cross-border interconnection open to third-party access. The ENTSO for Gas shall duly take into account ACER’s opinion and recommendations.
When carrying out their duties and exercising their powers under this Regulation, the regulatory authorities shall ensure compliance with this Regulation, the network codes and the guidelines adopted pursuant to Articles 70 to 74.
Where appropriate, they shall cooperate with each other, with the Commission and ACER pursuant to Chapter V of Directive (EU) 2024/1788.
1. While preparing the network codes, the draft Union-wide network development plan for natural gas and the annual work programme referred to in Article 26(1), (2) and (3), the ENTSO for Gas shall conduct an extensive public consultation process, at an early stage and in an open and transparent manner, involving all relevant market participants, and, in particular, the organisations representing all stakeholders, in accordance with the rules of procedure referred to in Article 25(1). That consultation shall also involve regulatory authorities and other national authorities, supply and production undertakings, network users including customers, distribution system operators, including relevant industry associations, technical bodies and stakeholder platforms. The ENTSO for Gas shall publish drafts of the network codes, the Union-wide network development plan for natural gas and the annual work programme for comments by the stakeholders and provide sufficient time for them to participate in the consultation process effectively. The aim of that consultation is to identify the views and proposals of the relevant stakeholders during the decision-making process.
2. All documents and minutes of meetings related to the consultations referred to in paragraph 1 shall be made public.
3. Before adopting the annual work programme and the network codes referred to in Article 26(1), (2) and (3), the ENTSO for Gas shall indicate how the observations received during the consultation have been taken into consideration. It shall provide reasons where observations have not been taken into account.
The costs related to the activities of the ENTSO for Gas referred to in Articles 24, 25, 26, 70 and 71 of this Regulation, and in Article 11 of Regulation (EU) 2022/869, shall be borne by the transmission system operators and shall be taken into account in the calculation of tariffs. Regulatory authorities shall approve those costs provided that they are reasonable and appropriate.
Regional cooperation of transmission system operators
1. Transmission system operators shall establish regional cooperation within the ENTSO for Gas to contribute to the tasks referred to in Article 26(1), (2) and (3).
2. Transmission system operators shall promote operational arrangements in order to ensure the optimum management of the network and shall promote the development of energy exchanges, the coordinated allocation of cross-border capacity through non-discriminatory market-based solutions, paying due attention to the specific merits of implicit auctions for short-term allocations and the integration of balancing mechanisms.
3. For the purposes of achieving the objectives set out in paragraphs 1 and 2 of this Article, the Commission is empowered to adopt delegated acts in accordance with Article 80 to supplement this Regulation by establishing the definition of the geographical area covered by each regional cooperation structure, taking into account existing regional cooperation structures. Each Member State shall be allowed to promote cooperation in more than one geographical area.
For the purpose of drawing up the delegated acts referred to in the first subparagraph, the Commission shall consult ACER and the ENTSO for Gas.
Union-wide network development plan for natural gas
The ENTSO for Gas shall adopt and publish the Union-wide network development plan for natural gas every two years. The Union-wide network development plan for natural gas shall include the modelling of the integrated network, scenario development, a European supply adequacy outlook and an assessment of the resilience of the system, including infrastructure to be decommissioned.
The Union-wide network development plan for natural gas shall, in particular:
(a)
build on national investment plans and Chapter IV of Regulation (EU) 2022/869;
(b)
regarding cross-border interconnections, also build on the reasonable needs of different network users and integrate long-term commitments from investors as referred to in Article 55(7) of Directive (EU) 2024/1788; and
(c)
identify investment gaps, in particular with respect to cross-border capacities.
With regard to the second paragraph, point (c), a review of barriers to the increase of cross-border capacity of the network arising from different approval procedures or practices may be annexed to the Union-wide network development plan for natural gas.
Transparency requirements concerning transmission system operators
1. The transmission system operator shall make public detailed information regarding the capacity and services it offers and the relevant conditions applied, together with the technical information necessary for network users to obtain effective network access.
2. In order to ensure transparent, objective and non-discriminatory tariffs and facilitate efficient utilisation of the natural gas network, transmission system operators or relevant regulatory authorities shall publish reasonably and sufficiently detailed information on tariff derivation, methodology and structure.
3. For the services provided, each transmission system operator shall make public information on technical, contracted and available capacities on a numerical basis for all relevant points including entry and exit points on a regular and rolling basis and in a user-friendly and standardised manner in accordance with the guidelines laid down in Annex I.
4. The relevant points of a transmission system on which the information is to be made public shall be approved by the competent authorities after consultation with network users.
5. The transmission system operator shall always disclose the information required by this Regulation in a meaningful, quantifiably clear, easily accessible and non-discriminatory manner.
6. The transmission system operator shall make public ex ante and ex post supply and demand information, on the basis of nominations and allocations, forecasts and realised flows in and out of the system. The regulatory authority shall ensure that all such information is made public. The level of detail of the information that is made public shall reflect the information available to the transmission system operator.
The transmission system operator shall make public measures taken as well as costs incurred and revenue generated to balance the system.
The market participants concerned shall provide the transmission system operator with the data referred to in this Article.
7. The transmission system operators shall make public detailed information regarding the quality of natural gas transported in their networks, which might affect network users, pursuant to Articles 16 and 17 of Regulation (EU) 2015/703.
Transparency requirements concerning natural gas storage facilities, hydrogen storage facilities, LNG facilities and hydrogen terminals
1. LNG system operators, natural gas storage system operators, hydrogen terminal operators and hydrogen storage operators shall make public detailed information regarding all services they offer and the relevant conditions applied, together with the technical information necessary for users of LNG facility, natural gas storage facility, hydrogen storage facility and hydrogen terminal to obtain effective access to the LNG facilities, natural gas storage facilities, hydrogen storage facilities and hydrogen terminals. Regulatory authorities may request those operators to make public any additional relevant information for system users.
2. LNG system operators shall provide user-friendly instruments for calculating tariffs for the services available.
3. For the services provided, LNG system operators, natural gas storage system operators, hydrogen terminal operators and hydrogen storage operators shall make public information on contracted and available LNG facility, natural gas storage facility, hydrogen storage facility and hydrogen terminal capacities on a numerical basis on a regular and rolling basis and in a user-friendly standardised manner.
4. LNG system operators, natural gas storage system operators, hydrogen terminal operators and hydrogen storage operators shall disclose the information required by this Regulation in a meaningful, quantifiably clear, easily accessible and non-discriminatory manner.
5. LNG system operators, natural gas storage system operators, hydrogen terminal operators and hydrogen storage operators shall make public the amount of natural gas or hydrogen in each LNG facility, natural gas storage facility, hydrogen storage facility and hydrogen terminal, or group of storage facilities if that corresponds to the way in which the access is offered to system users, inflows and outflows, and the available LNG facility, natural gas storage facility, hydrogen storage facility and hydrogen terminal capacities, including for those facilities exempted from third-party access. That information shall also be communicated to the transmission system operator or to the hydrogen network operator for hydrogen storage and terminals, which shall make it public on an aggregated level per system or subsystem defined by the relevant points. The information shall be updated at least daily.
Where a natural gas or hydrogen storage facility user is the only user of a natural gas storage facility or hydrogen storage facility, the natural gas or hydrogen storage system user may submit to the regulatory authority a reasoned request for confidential treatment of the data referred to in the first subparagraph. Where the regulatory authority comes to the conclusion that such a request is justified, taking into account, in particular, the need to balance the interest of legitimate protection of business secrets, the disclosure of which would negatively affect the overall commercial strategy of the storage user, with the objective of creating competitive internal markets for natural gas and hydrogen, it may allow the natural gas storage system operator or hydrogen storage operator not to make public the data referred to in the first subparagraph, for a duration of up to one year.
The second subparagraph shall apply without prejudice to the obligations referred to in the first subparagraph, unless the aggregated data are identical to the individual natural gas or hydrogen storage system data for which the regulatory authority has approved non-publication.
6. In order to ensure transparent, objective and non-discriminatory tariffs and facilitate efficient utilisation of the infrastructures, the LNG system operators, natural gas storage system operators, hydrogen terminal operators and hydrogen storage operators or relevant regulatory authorities shall make public sufficiently detailed information on tariff derivation, the methodologies and the structure of tariffs for infrastructure under regulated third-party access. LNG facilities that have been granted an exemption, pursuant to Article 78 of this Regulation, Article 22 of Directive 2003/55/EC and Article 36 of Directive 2009/73/EC, and natural gas storage system operators under the negotiated third-party access regime shall make public tariffs for infrastructure in order to ensure a sufficient degree of transparency.
LNG system operators and natural gas storage system operators shall each publish in a transparent, continuous and user-friendly manner the information required pursuant to this Article on a single European platform that shall be maintained by those operators.
Transmission system operators, natural gas storage system operators and LNG system operators shall keep at the disposal of the national authorities, including the regulatory authorities and the national competition authorities, and the Commission, all information referred to in Articles 33 and 34 and in point 3 of Annex I for a period of five years.
