Performance-Based Regulation as a Potential Incentive Mechanism for the IMO

-- Draft Report for Discussion on June 28, 2002 --

     Performance-Based Regulation as a Potential Incentive
                  Mechanism for the IMO

                                    Prepared by:

                 IMO - Regulatory and Government Affairs

                    Version 1.0 Released on June 26, 2002.

This report starts discussion with IMO Stakeholders regarding the feasibility of applying
       performance-based regulation or other incentive mechanisms to the IMO.

TABLE OF CONTENTS:
1.     INTRODUCTION AND OVERVIEW ............................................................................................... 3

2.     CURRENT IMO PERFORMANCE MANAGEMENT MECHANISMS....................................... 4
     2.1.     PERFORMANCE MEASURES.............................................................................................................. 5
     2.2.     LINKS TO COMPENSATION ............................................................................................................... 5
     2.3.     CONSULTATIVE, TRANSPARENT BUSINESS PLAN DEVELOPMENT ................................................... 5
     2.4.     APPROVAL OF MEASURES, COMPENSATION, AND BUSINESS PLAN BY IMO BOARD ....................... 5
     2.5.     BENCHMARKING.............................................................................................................................. 6
     2.6.     TRACKING OF IMO OBLIGATIONS ................................................................................................... 7
     2.7.     CONTINUOUS BUSINESS PLANNING PROCESS .................................................................................. 7

3.  TRADITIONALLY DEFINED PERFORMANCE-BASED REGULATION IS NOT SUITED
FOR THE IMO............................................................................................................................................. 9

4.     CONCLUSION ....................................................................................................................................11
     APPENDIX 1: INTRODUCTION TO TRADITIONAL PERFORMANCE-BASED REGULATION ...............................12
     APPENDIX 2: SELECTED IMO PERFORMANCE MEASURES .........................................................................15

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Discussion Report:
Performance-Based Regulation as a Potential Incentive Mechanism for
                            the IMO

1.     Introduction and Overview

The IMO is dedicated to providing effective service and value to its stakeholders, market
participants, and regulators. Accordingly, the IMO is supportive of measures that
promote the ongoing enhancement of its performance. In this regard, the IMO has
developed and implemented into its business model a detailed and rigorous performance
management regime as well as several other incentive mechanisms – a number of which
are stakeholder-based.

In taking further steps to address and respond to stakeholder objectives and other
commitments, the IMO has prepared this report to further discuss the feasibility of
applying additional performance management mechanisms to the IMO’s operations.

Specifically, this report starts the discussion with Stakeholders regarding the feasibility of
applying performance-based regulation (PBR) or similar incentive mechanisms to the
IMO.

The report supports the adoption of performance incentive mechanisms into the IMO’s
business model. However, the report recognizes that while applying incentive and
performance measures is entirely feasible, PBR - in its traditional definition - is not an
appropriate mechanism for the IMO to adopt at this time for the following reasons:

1. In its current development, PBR is applicable only to for-profit organizations. As
   such, PBR is fundamentally incongruous with the IMO’s not-for-profit, without share
   capital business model.

2. PBR has no precedent in the context of RTOs/ISOs. As such, there is no working
   PBR model for the IMO to reference.

3. The experience with PBR in the electricity industry, and particularly in Ontario, is
   presently too limited to permit thorough and authoritative conclusions as to its
   effectiveness. In fact, at this point, there is compelling analysis of PBR’s experience
   in gas distribution in Canada that shows very limited success. In Ontario, electricity
   distributors are under “first generation” PBR while the decision on transmitters is to
   postpone adopting any PRB model at the present time. These are not encouraging
   signs when applied to those electricity industry participants that are said to be well
   suited for PBR (i.e. for-profit, numerous to permit comparability, long-standing
   business to permit stable model), let alone for those participants for whom the
   appropriateness of PBR has yet to be practically demonstrated (i.e. not-for-profit, new
   business, RTOs/ISOs).

The above context suggests that the IMO and Stakeholders have little industry
information and experience on which to assess effective traditional PBR designs and
practices for the IMO. However, the above context does support pursuing various other
types of performance management mechanisms.

This report is structured as follows:

Section 2 discusses some of the IMO’s current performance management initiatives.
These initiatives reflect the IMO’s commitment to delivering effectiveness and value in
an open, inclusive, and transparent manner. Mentioned initiatives include:

·    Ongoing stakeholder-based input to relevant performance factors or “outputs”
·    Setting, analysis, and evaluation of corporate performance targets with links to the
     IMO’s management compensation process
·    Business plan development and Settlement Agreement approval process featuring
     stakeholder participation, scrutiny, and input
·    Linking budget savings to consumer savings on the following year’s IMO fee
·    Proactive investigation into the feasibility of applying benchmarking or comparative
     information mechanisms to the IMO, and
·    Listing and assignment of IMO obligations.

Section 2 also emphasizes that the IMO supports the development and adoption of other
appropriate performance mechanisms in view of further enhancing the ongoing efficiency
and effectiveness of IMO operations.

Section 3 discusses the feasibility of incorporating PBR as an incentive model for the
IMO. As stated above, this report observes that PBR - in its traditional definition - is not
an appropriate mechanism for the IMO to adopt at this time. Section 3 discusses the
reasons underlying this observation in greater detail.

Readers will find attached to the end of this report an appendix that provides a brief
introduction to the principles of traditional PBR.

2.      Current IMO Performance Management Mechanisms

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The IMO is actively engaged in performance management. The following section
describes some of the IMO’s initiatives in this regard.

2.1.   Performance Measures

By means of a consultation process, the IMO has invited stakeholders to provide views
on how much weight to assign to various measures for compensation purposes. The IMO
will continue to seek better understanding of which of its “outputs” are most valuable to
IMO stakeholders and which best help support stakeholder objectives. Based on these
and other deliberations, the IMO has established a number of meaningful and stringent
corporate performance targets that reflect the IMO’s key business and operations
objectives for the first year of Ontario’s restructured wholesale electricity market. In
broad terms, these performance measures address the effective use of funds, wholesale
market functionality, Market Participants' and Stakeholders' needs, and reliability
standards. Within each of these broad categories are a number of specific measures and
targets (see Appendix 2 for a sample of some of the IMO’s performance measures and
targets).

2.2.   Links to Compensation

The IMO’s management compensation is linked to the above-mentioned performance
targets.

2.3.   Consultative, Transparent Business Plan Development

Each year, the IMO prepares and files its business plan and fees submission with the
Ontario Energy Board (OEB) for an order or orders approving the IMO’s proposed
expenditure and revenue requirements and fixing the fees which it may charge for that
year. Prior to its filing with the OEB, the IMO’s annual business plan is shared with the
IMO Stakeholder Regulatory Standing Committee for early input, and for scrutiny and
comment. The plan is subsequently presented to the IMO Board of Directors for approval
(the IMO Board of Directors includes representatives from various Stakeholder groups).
In so doing, the IMO ensures that its budget process is inclusive of stakeholders, and that
stakeholder concerns regarding the IMO’s performance are both addressed and
incorporated into the business plan.

2.4.   Approval of Measures, Compensation, and Business Plan by IMO Board

A main driver for IMO performance is the IMO Board of Directors. The Board includes
stakeholder representation.

                                                                                         5

In recognition of this important feature of the IMO budget development process, the OEB
makes the following remark in its January 28th 2002 statement of decision with reasons
on IMO’s year 2002 Settlement Agreement:

          In considering the IMO’s revenue     requirement and related proposals, the Board takes
          comfort that such proposals are      first scrutinized by the IMO Board, which is a
          stakeholder board. In considering    the results of the Settlement Agreement, the Board
          also takes comfort that there were   many parties to the proceeding representing a wide
          array of interests1.

Indeed, the IMO’s business plan development and budget approval process reflects the
IMO’s commitment to establishing and meeting financial performance targets that are
meaningful to IMO stakeholders, help promote efficient IMO operation, and that are
developed in an open, inclusive, and transparent way.

Further, where there is a surplus between the OEB approved budget and IMO expenditure
in a given year, the difference is passed on to consumers as a saving on the following
year’s IMO charge.

2.5.      Benchmarking

The IMO has initiated the collection and analysis of information regarding comparable
organizations in order to help make assessments to guide the IMO in its own business
planning activities, and to offer evidence to stakeholders, regulators, or intervenors as to
the IMO’s performance relative to peer organizations. Efforts to date have been
successful in forging good working relationships with, among others, PJM
Interconnection, New York ISO, New England ISO, ERCOT, and California ISO. The
IMO has been successful in gathering high level information from ISO NE and NY ISO,
although these organizations are not participating in formal benchmarking. The IMO will
continue to collect and analyze such information where it is assessed that doing so is
likely to be cost effective.

Given the active involvement of IMO to date in performance management, as well as in
view of the nascence of Ontario’s restructured electricity market, the OEB offers the
following comments on benchmarking in its 2002 Settlement Agreement Decision:

          The Board recognizes the value of benchmarking. However, the Board considers
          benchmarking to be one tool of many in determining a reasonable level of revenue
          requirement. Given the embryonic stage and dynamic nature of market restructuring, the
          differences in market characteristics and functions of the independent operators, and the
          IMO’s undertakings related to Performance Management as set out in the Settlement
          Agreement, the Board is not persuaded that the IMO should be directed or expected at
          this time to go beyond its commitment set out in the Settlement Agreement2.

1
    Ontario Energy Board RP-2001-0046 Decision With Reasons, January 28, 2002.
2
    Ibid.

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The above OEB comments reinforce the point that there exists a variety of performance
management mechanisms that are available for adoption by the IMO, and that
benchmarking is but one of many of such mechanisms. Moreover, the OEB recognizes
the limitations of formal benchmarking for the IMO at the present time. Thus far, the
IMO has proactively initiated various investigations into the potential benefits of a
benchmarking or benchmarking-like mechanism, and has arrived at similar conclusions
to those of the OEB as noted above.

This does not speak to the point made in the introduction where the concepts of
benchmarking and incentive mechanisms are somehow linked. This suggests that the
intro needs to be revised.

2.6.   Tracking of IMO Obligations

In order to assess the IMO’s on-going performance and ability to meet the needs of the
new marketplace, customers, and Stakeholders, the IMO actively manages numerous
service deliverables, obligations, and responsibilities that have been identified in
legislation, regulations, market rules, regulatory licences, and codes. The current list of
obligations consists of about 750 items.

The IMO also ensures that various commitments and responsibilities are properly and
adequately delivered on an on-going basis. These commitments stem from
interconnection agreements with 8 entities in 5 interconnected jurisdictions, operating
agreements with 4 transmitters, and ancillary service contracts which cover the provision
of voltage support, automatic generation control, black start, or must-run facilities.

All of these deliverables facilitate the smooth operation and performance of the markets
and the electricity system.

2.7.   Continuous Business Planning Process

In order to better respond to the drivers of the business and manage its performance, the
IMO intends to further enhance its business planning and capital commitment process.
The IMO currently employs a capital planning and approval process. At a high-level, this
process involves numerous stages including: needs or opportunity identification, project
prioritization, specialized support of cost and technical details, business case review and
approval, ongoing project monitoring, and project completion review and analysis.

All resources, including capital resources, OM&A resources, and human resources, will
continue to be carefully allocated. All initiatives will be aligned to strategic objectives
with deliverables and performance measures reflected in executive performance
contracts. An Executive Planning Committee has been established to oversee this
process and guide the development of this plan.

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In conclusion, it is evident that the IMO actively promotes performance excellence. In
this regard, the IMO employs mechanisms that are suited for increasing performance
efficiency and effectiveness. Examples of such mechanisms initiated by the IMO thus far
include an ongoing stakeholder-based evaluation of relevant performance factors or
“outputs”, the setting, analysis, and evaluation of corporate performance targets that are
linked to the IMO’s management compensation process, a business plan development and
Settlement Agreement approval process which features stakeholder participation,
scrutiny, and input, a mechanism whereby budget savings are passed on to consumers as
a saving on the following year’s IMO charge, proactive investigation into the feasibility
of applying benchmarking to the IMO, the listing and assignment of IMO obligations,
and the development of a capital planning and approval process.

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3.    Traditionally Defined Performance-Based Regulation is not suited for the IMO

Regulatory Affairs staff at the IMO have reached the conclusion that performance-based
regulation is not an appropriate incentive mechanism for the IMO to adopt at this time for
several key reasons:

First, PBR theory as currently developed applies only to for-profit organizations.
Indeed, the fundamental principle underlying PBR is that good performance should lead
to higher profits while poor performance should lead to lower profits. The application of
PBR to a not-for-profit organization is thereby an oxymoron3. Thus, as a not-for-profit
organization, it is inappropriate for the IMO to undertake PBR as currently developed at
this time.

Second, while PBR has historically been applied to industries such as
telecommunications, railway, and utilities, PBR has no precedent in the context of
RTOs/ISOs. In recognition of this absence of precedent, and in consideration of the
sizeable degree of opposition in the U.S. to PBR for RTOs/ISOs among industry
participants, FERC Order 2000 concludes that PBR should not be a mandatory
requirement for RTOs/ISOs4. Moreover, FERC Order 2000 remarks that even among
several industry participants who are in favour of PBR for RTOs/ISOs, there exists an
emphatic contention that PBR is an inappropriate incentive model for not-for-profit
RTOs/ISOs in particular. This point is further underscored by regulatory specialist Dr.
Michael R. Schmidt (a fervent proponent of PBR for electric utilities):

        Saying that RTOs will face challenges is an understatement, since and RTO generally has
        no ownership interest in the transmission grid. The RTO has no ratebase and is
        responsible for few, if any, maintenance and operation expenses. Furthermore, the RTO
        generally is a not-for-profit agent of the transmission owners of the region […]. If FERC
        is to approve PBRs, it should apply them to the PTO, or private transmission owner5
        [Italics added].

 As such, owing to the absence of precedent of PBR for RTOs/ISOs as well as to the
distinct lack of consensus regarding which, if any, types of RTOs/ISOs should be eligible
for PBR adoption, the IMO feels that at the present time, PBR theory and practice is
insufficiently developed to offer a practical working PBR model for RTOs/ISOs –
especially for those that are not-for-profit - from which to cultivate insights in pursuit of
developing a potentially feasible and effective IMO PBR design.

Third, as pointed out by Gregory Basheda (former senior economist for the DOE Office
of Electricity Policy and current senior consultant at the Brattle Group), “the experience

3
  Personal correspondence with Schmuel Oren, University of California at Berkeley. Co-author of DOE
National Transmission Grid Study Issue Paper: Alternative Business Models for Transmission Investment
and Operation. May, 2002.
4
  Opponents of PBR for RTOs include the following FERC Order 2000 commenters: PJM/NEPOOL
Customers, Lincoln, NASUCA, NJBUS, Industrial Consumers, Williams, and CMUA.
5
  Schmidt, Michael R. Performance-Based Ratemaking: Theory and Practice. Public Utilities Reports, Inc.:
Vienna, Virginia, 2000. p. 167.

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with PBR in the electric utility industry is presently too limited […] to permit
conclusions” as to its effectiveness6. In other words, at this point, there is a paucity of
authoritative analysis of PBR’s effects on those electricity industry participants that are
said to be well suited for PBR (i.e. for-profit, numerous to permit comparability, long-
standing business to permit stable model), let alone for those participants for whom the
appropriateness of PBR has yet to be practically or even theoretically demonstrated. In
this sense, PBR’s embryonic state within the electricity industry - especially in the
context of RTOs/ISOs - and the attendant lack of suitable analysis of the matter offers
the IMO little industry information and experience on which to assess effective PBR
design and practice.

Further, it would be fallacious to simply transpose onto the IMO those regulatory patterns
observed in other industries possessing more experience with PBR models (e.g.
telecommunications, natural gas), as there exist vast and vital differences between those
industries and the IMO. In fact, the limited success of PBR in Canada’s natural gas
industry should deter any such transposition. For instance, as recently observed by the
Canadian Gas Association (CGA) in its study of PBR initiatives currently employed by
Canadian gas utilities, almost all study participants reported either no reduction in
regulatory costs as a result of PBR, or stated that it is too soon to tell with certainty7.
Likewise, most participants declared that they are currently uncertain as to whether PBR
has helped them lower their rates. Accordingly, all of the study’s participants stated that
they are planning to change their current PBR plan in some form, with most planning to
adopt a new model altogether. It would be similarly inappropriate to transpose the PBR
models currently adopted by electricity distributors in Ontario, as they have only recently
adopted a “first generation” PBR and can thereby provide only a limited degree of
practical insight. Finally, in accordance with the Ontario Energy Board’s decision on the
matter, there is currently no working PBR model for transmitters in Ontario. Namely,
Hydro One Networks proposed a PBR scheme for transmission in its first transitional rate
proceeding8. The OEB’s decision declared the proposal to be premature.

In sum, in its current stage of development, PBR is an inappropriate incentive
mechanism for the IMO at this time owing to its fundamental incongruity with the IMO’s
not-for-profit business model, the lack of a PBR precedent within the context of
RTOs/ISOs, the scarcity of critical and practical evaluation of PBR’s effectiveness within
the electricity industry thus far, and the apparent limited success of PBR in the Canadian
gas utility industry (an industry which is said to be well suited for PBR). Rather, the
IMO reckons that other mechanisms exist that are better suited than PBR at promoting
the reliable, responsive, efficient, and cost-effective execution of the IMO’s mandated
responsibilities. In other words, while the IMO cautions against the adoption of PBR for
IMO operations (for reasons outlined above), the IMO supports the adoption of other,
more appropriate performance management mechanisms. Accordingly, the IMO
welcomes stakeholder views in this regard.

6
  Basheda, Gregory et. al. The State of Performance-Based Regulation in the U.S. Electric Utility Industry.
The Electricity Journal. October, 2001. p.73
7
  CGA Survey in Performance Based Regulation: Utility Summary. CAMPUT Conference, May 5-8, 2002.
8
  OEB docket RP-1998-0001

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4.     Conclusion

This report has been prepared to focus discussion on options for incorporating additional
performance incentive mechanisms into the IMO’s business model. Moreover, this
report represents one further step in the IMO’s commitment to bring ongoing value and
effective performance to its stakeholders, market participants, and regulators.

This report particularly addresses the feasibility of applying performance-based
regulation or similar incentive mechanisms to the IMO. The report concludes that, in its
current development, PBR is not an appropriate incentive mechanism for the IMO to
adopt at this time for several key reasons outlined in section 3.

However, the report has emphasized in section 2 that the IMO supports the development
and adoption of other, more appropriate performance mechanisms. In fact, this report has
discussed several performance management mechanisms initiated by the IMO that are
currently employed in its business and operational model. Moreover, this report has
remarked that the IMO is committed to further enhancing the ongoing efficiency and
effectiveness of its operations. As such, the IMO welcomes stakeholder input regarding
additional performance management initiatives for the IMO.

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DRAFT
       Appendix 1: Introduction to Traditional Performance-Based Regulation

Performance-based regulation (PBR) represents an attempted improvement on the Cost of
Service (COS) regulatory model, in which a fundamental link is established between a
regulated firm’s prices and its costs. While such a link may be viewed as supportive of
economically equitable rates, COS regulation is widely acknowledged as entailing two
key disadvantages. Namely, “[…] tying each firm’s prices to costs diminishes the firm’s
incentives to reduce costs and increase market responsiveness, since gains from these
efforts will accrue largely to ratepayers, not shareholders. The firm’s incentive to
innovate is also attenuated since prices are based, not on value, but on costs […]”9.

As such, as an alternative COS regulation, PBR constitutes “[…] an effort by regulators
to decouple the linkage between […] prices and their costs under regulation by offering
financial incentives to […] lower rates or costs. Under PBR, good […] performance can
be rewarded with higher profits and poor performance can be penalized in some
manner”10. Therefore, in its essence, PBR is a “[…] ratemaking system – absent of cost-
of-service review by regulators – in which a [for-profit firm] is rewarded in its bottom
line for lowering costs through efficiency”11.

While PBR mechanisms can be designed in many ways, and can be tailored to achieve
many different objectives, PBR rate design is typically based on a formula whereby
specific rate changes are determined by using “[…] an escalation factor to reflect
expected growth in a [firm’s] input prices, less an allowance for an appropriate rate of
productivity gain. Unusual event and performance factors can also be added”12. The
generic PBR formula may be expressed as:

Rate t = Rate t-1 x (1 + PI – X) + Z + Q

Where

-   PI represents the change in some measure of inflation (e.g. Consumer/Producer Price
    Index, GDP, etc.)
-   X represents the change in a productivity factor
-   Z represents costs over which the firm has no control, and
-   Q represents the change in performance indicator factors.

In the abstract, PBR appears appealingly simple to understand, design, and administer.
However, in practice, PBR design is a complex and controversial undertaking.

9
  Ontario Energy Board Staff Report. PBR Options For Electricity Distribution in Ontario. October 15,
1998. p. 4.
10
   Energy Information Administration. Ratesetting and Customer Choice Issues in Electricity
Restructuring. http://www.eia.doe.gov/cneaf/electricity/chg_str_issu/chg_str_iss_rpt/chapter4.html
11
   Davis, Ron. Acting on Performance-Based Regulation. The Electricity Journal, May 2000. p.13.
12
   Schmidt, Michael R. Performance-Based Ratemaking: Theory and Practice. Public Utility Reports, Inc.;
Vienna, Virginia, 2000. p.51.

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DRAFT
Critical practical considerations of PBR design and implementation include

1.   identifying outputs
2.   determining which outputs matter most to stakeholders
3.   setting initial rates
4.   setting and resetting X, the productivity factor
5.   identifying an appropriate escalation index (PI)
6.   developing and monitoring Q, performance factors
7.   developing Z, the unusual event factor
8.   determining how often to update the PBR plan
9.   determining whether the chosen PBR plan yields better results than an alternative
     plan would have.

The most widely considered or implemented types of PBR models are:

1. Price Cap regulation
2. Revenue Cap regulation
3. Benchmark or “Yardstick” regulation

Key features of each model are briefly outlined below along with attendant
disadvantages:

1. Rate Cap regulation

Features:
· Specifies a commitment period during which the regulated firm’s rates are capped
   independent of costs.

Disadvantages:
· Tends to encourage sales by the firm since prices, not quantities, are constrained
   under the plan. This incentive, in some circumstances, may be inconsistent with DSM
   objectives13.
· May be less suitable in cases where the regulated firm has high fixed costs and faces
   volatility in revenue beyond its control14.
· If productivity factors (X) are set annually and estimates of the firm’s costs are used
   to determine these magnitudes, then rate cap regulation reduces to cost-of-service
   regulation15.
· Danger of excessive cost cutting, harming quality of service16
· Incentive to defer some investments that could result in cost savings17
· Less than optimal risk-taking18

13
   Ontario Energy Board Staff Report, p.13
14
   Ibid., p.13
15
   Wolak, Frank A. Price-Cap Regulation and its Use in Newly Privatized Industries. p.2
16
   CERA Chicago Roundtable presentation, October 2001.
17
   Ibid.
18
   Ibid.

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DRAFT
2. Revenue Cap regulation

Features:
· Caps the firm’s revenue independent of its costs and is set according to the previous
   year’s revenue indexed by and inflation factor (PI) adjusted by a productivity factor
   (X), unusual events factor (Z), performance factors (Q), and growth19.
· Since allowed revenue is constrained, the firm’s incentive is to not only reduce unit
   costs, but also the number of units sold such that total profits are maximized. Thus,
   revenue caps may be more fundamentally compatible than price caps with DSM
   initiatives20.
· Danger of excessive cost cutting, harming quality of service
· Incentive to defer some investments that could result in cost savings
· Less than optimal risk-taking

Disadvantages:
· May encourage the firm to raise prices while reducing sales
· Prices under a revenue cap model may exhibit greater variability than under a rate cap
   model.

3. Benchmark/Yardstick regulation

Features:
· Identifies a suitable peer group of firms (“comparators”) to which a firm’s
   performance and rates can be compared along a set of appropriate cost categories21.
   Benchmarking sets up an “efficiency tournament” within the identified peer group22.

Disadvantages:
· Entails controlling for intrinsic cost differences (comparing “apples with oranges”)
· Entails controlling for relative efficiencies: very inefficient firms find it easier to
   decrease their costs and earn large profits while very efficient firms find it more
   difficult to decrease costs and earn limited profits23.

It is important to note that none of the aforementioned examples of PBR mechanisms
have been applied to not-for-profit firms, or to RTOs/ISOs. Furthermore, although PBR
has been traditionally used in the telecommunications, railway, and natural gas industries,
the experience with PBR in the electric utility industry is presently too limited to permit
authoritative conclusions as to its effects.

19
   Ibid., p.13
20
   Ibid., p.14
21
   Schmidt, Michael R. p.87
22
   Ontario Energy Board Staff Report, p.15
23
   Bell, Mathew. Performance-based Regulation: A View from the Other Side of the Pond. The Electricity
Journal, January/February 2002. p.71

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DRAFT
Appendix 2: Selected IMO Performance Measures

                                                15

DRAFT

        16