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(Monday, June 10, 8:30 -9:15 a.m.)


Good morning, I'm Eve Atkinson. I'm director of athletics at Lafayette College and also serve on NACDA's Executive Committee. My co-moderator today, is Ken Free, Commissioner of dle Mid-Eastern Adlletic Conference. Our topic today is Slicing the Billion Dollar Pie, and dlat has to do widl distributions of revenues for dle seven-year contracts with CBS Sports and dle NCAA for $1 billion.

Today's format will be a point, counter-point format We will start off with Judy Sweet, president and chair of the NCAA Revenue Distribution Committee, and she will give a summary of that Committee's report That will then be followed by Dr. Roy Kramer, Commissioner of the Southeastern Conference, and he will present the point part of the debate. Followed by Dr. Kramer will be Jeffrey Orleans, Executive Director of The Ivy Group, and he will present the counter-point part of the debate. At that point in time, we will have questions from the audience, a rebuttal and summary statement will be done by Dr. Kramer and then, a rebuttal and summary by Jeff Orleans and closing remarks from Ken Free. We're ready to begin the debate.

Starting the presentation and representing the NCAA Committee, I would like to introduce Judy Sweet. Judy has been the director of athletics at the University of Califomia-San Diego since 1975, when she became one of the fIrst women in the nation selected to direct a men's and women's intercollegiate program. The University of Califomia- San Diego athletics program involves 23 sports and even distribution of men's and women's teams. She joined the NCAA in 1981 and the University of California-San Diego's athletics team have won 11 national championships and have been runner-up for 15 other NCAA championships. A native of Milwaukee, Judy is a graduate of the University of Wisconsin-Madison, where she majored in Physical Education and Mathematics. Judy served as the president of the Women ' s Recreation Association and national president of the Athletic and Recreation Federation of College Women. She earned a master of science from the University of Arizona and a master's in business administration from National University in San Diego. Judy was elected for a two-year term as president of the NCAA in January, 1991, and was secretary-treasurer for the NCAA from 1989 to 1991, becoming the fIrst woman to serve in each of those positions. She was Division III Vice President, the presiding officer of that Division from 1986 to 1988. Her presidential responsibilities include presiding over the NCAA Administrative Committee, the NCAA Council, the NCAA Executive Committee and the NCAA annual convention. She has chaired the NCAA Budget Committee and the NCAA Special Advisory Committee to review recommendations regarding distributions of revenue. This Committee was formed as a result of the successful negotiations with CBS Television personnel, of which Judy served as a representative in negotiating that contract. It is my honor and pleasure to present The president of the NCAA, Judy Sweet.


Thank you, Eve. It's a pleasure for me to be with you this morning and to share with you in what Eve has given me, eight-minutes, everything that the Advisory Committee has been doing for the last year and one-half. She's warned me that the hook comes out in eight-minutes, so I will try to be thorough and concise.

The Advisory Committee was appointed in December, 1989. We quickly recognized the importance of our assignment, the opportunities that were available to us, the responsibility that went along with that opportunity and also, the challenge that was before us. One billion dollars commands a lot of attention. I want to clarify that, while in the past, many of us would have thought, if we only had $1 billion, we could solve all of the problems of the world. You can't solve all of the problems with $1 billion. The Committee quickly came to that recognition. The $1 billion is spread out over seven years, beginning with $116 million in the fIrst year and escalating in the seventh year to $170 million plus.

In an attempt to try to make the right decisions in the right way, we felt that it was very important to involve the NCAA membership right from the start of our assignment. Consequently, we sent out letters to all four NCAA institutional representatives requesting input on how we should best allocate the $1 billion over the seven year time period. We got lots of responses. We received close to 400 letters from the membership with suggestions on what we should do. From these suggestions, the committee initially determined some guiding principles. These guiding principles included the following: I) the committee should listen to the suggestions from the membership. That the Committee remain open-minded and flexible and that it explored each proposal for recommendations submitted by the membership and other interested entities; 2) all institutions should benefit in some way. The distribution formula eventually developed should provide a mechanism for sharing the revenue equitably, though not equally, among all member-institutions; 3) that consideration be given to distributing some portion of the revenue based on the breath of an institution's athletic program; 4) that care be taken to avoid funding special interests of the various segments of the membership or items that may be more an institution's responsibility than that of the association; 5) that a common distribution formula be applied to revenue from all NCAA championships and that an institution's expenses for participating in any NCAA championship be more fully funded; 6) that the committee's recommendations address the image of the NCAA and intercollegiate athletics in genernl and that the welfare of the individual student-athletes, not solely that of the institutions, be considered. And, fmally, that the committee be cognizant of the fact that it may not be possible to develop a distribution plan that would fully satisfy the concerns of all institutions or programs.

With those principles in mind, the committee developed some initial recommendations which were distributed to the membership through the NCAA News and through letters to the membership and held hearings a year ago last June, to receive input from the membership on what makes sense and what didn't make sense, As a result of these hearings, there were a couple of the original recommendations that were scrapped and a couple of things that were added. The consistent message that we heard was, "Do something different that's what was done in the past, Move away from distributing money based solely on a team's performance in the Division I men's basketball tournament,"

As a result of that, there were general concepts that were approved in August of 1990 and these include the following: I) Eliminate distribution of net receipts based upon performance or participation in NCAA championships; 2) Increase official travelling parties and per diem allowance for national collegiate and Division I, II and III championships; 3) Provide catastrophic injury insurance for student-athletes in all three Divisions; 4) Provide an inflationary increase for the conference grant program; 5) Provide a graduated financial enhancement for Division II - $1 million in 1990-91, $2 million in 1991-92 and $3 million in 1992-93 and for each remaining year of the contract, a $3 million dollar allocation; 6) Distribute monies to Division I conferences based upon the number of units earned by the teams in the Division I basketball championship using a rolling six-year period. This has become known as a basketball pool; 7) Distribute monies to Division I institutions based upon the number of intercollegiate sports sponsored above the minimum requirement for membership and the number of athletically related grants-in-aid awarded above a minimum number. This has become known as a broad-based pool; 8) Distribute a portion of the monies for academic enhancement; 9) Establish a fund to which needy Division I student-athletes could apply for financial assistance with no obligations to pay back the money.

Detailed recommendations for the distribution were distributed in October, 1990 and further feedback was requested. It resulted in many more suggestions and it also resulted in many more questions. It appears that whenever we feel that we're close to resolving an issue, 10 new questions arise that then create 10 more questions and the questions still are coming to us and have not all been answered.

The final recommendations that were presented to the Executive Committee last May are as follows: $3 million has been allocate for the needy student-athlete fund. Division I student-athletes who are receiving a Federal Pell

Grant may apply for a grant to be used in emergency situations that have been clearly defined. There is no obligation to repay the money. $3.5 million has been allocate for catastrophic injury insurance for student-athletes in all three Divisions of the association. $7.4 million has been allocated for academic enhancement. Each Division I member will receive $25,000 to be used for academic programs for student-athletes. $1.3 million has been allocated for scholarships. Awards are made to student-athletes to complete their degrees and for post-graduate work.

Further awards are made to ethnic minorities and women to obtain advanced degrees in athletics administration. $24.67 million has been allocated for championships. Transportation and per diem for official travelling parties for all championships in all divisions will be funded from this allocation. $20.83 million will be a part of the grants-in-aid fund which will be distributed among Division I institutions based upon the number of athletics grants-in-aid they award to both men and women. $10.42 million will be distributed based on sports sponsorships. It will be distributed among Division I institutions based upon the number of mens and womens sports they sponsored. $31.25 million is the basketball fund which will be distributed based on the six-year rolling average performance of conferences in the Division I men's basketball championship. $4.93 million will be distributed for grants and royalties. This includes grants to Division I conferences which also will have an inflationary increase built in. $1.1 million in the fIrst year will be distributed to Division II for enhancement of Division II. This totals $108.35 million that will be distributed to the membership of the NCAA in direct benefits and services.

Some portions of this distribution have already reached your campuses. The last distributions will take place at the end of August. A special advisory committee has been asked to remain in place for the next year to receive input from the membership based on the effectiveness of the plan I just described to you. I want to emphasize that this plan is for 1991-92. It is not a plan that is locked in stone over the seven-year of the contract history. We very much would appreciate your input I would like to thank those of you that have provided us with feedback up to this point While we would like to do everything for everyone, it's not possible, but we hope to do the best for as many as possible. Thank you.


Thank you, Judy. Some people with this distinct honor would get up and start off by saying this man needs no introduction. Well, I'm not going to say that this morning because this giant of an athletic man is a privilege for me to introduce this morning. Roy Kramer spent ll-years with Vanderbilt as the athletic director. He was named in January as the Commissioner of the SEC. He is a leader in intercollegiate athletics and has served on numerous committees, such as the NCAA Advisory Committee to Review the Distribution of Revenue, the NCAA Television Negotiating Committee, the NCAA Committee on Infractions, the NCAA Basketball Committee, the NCAA Committee for National Drug Testing Policy, the NCAA Select Committee to study intercollegiate athletics, the NCAA Investments Committee, to name a few.

At Vanderbilt, Dr. Kramer was a leader in establishing conference policies. He is the past chainnan of the League of Athletic Directors and was influential in bringing the SEC Basketball Tournament to Nashville. In addition, Dr. Kramer helped to land an SEC tournament at Vanderbilt in 1991 and had the only sell-out in 30-years. Other highlights around Dr. Kramer included adding a $ 6 million addition and renovation to McGoughan Center which houses a complete athletic program, and the construction of Vanderbilt Stadium in 1981. The Maryville, Tennessee native was inducted into the Tennessee Sports Hall of Fame in February, 1989. After an eight-year stint as a high school football coach in Michigan, which included two state championships, Kramer served as head coach at Central Michigan University from 1966 to 1971. He compiled an 83-32.2 record. Dr. Kramer obtained his bachelor's degree from Maryville Tennessee College in 1953 following a standout football career and received the school's distinguished alumnus award in 1982. He added a master's at the University of Michigan and spent three-years in the U.S. Army. He is married and has three children and six grandchildren. On a personal note, 1" d have to say that this is a man of character, integrity and honesty .I present, Commissioner Roy Kramer .


I'm not sure why I'm here, because Judy was chairman of this committee that put together the plan. I simply want to talk a little bit about the politics that occurred during that process, what happened and where we are today. I certainly want to give Judy an enormous amount of credit for chairing this committee. It was a very difficult task because we had a tremendous amount of different ideas and a tremendous amount of different opinions. She held those of us in that room together.

As I sat here this morning and listened to the speakers, the theme that seemed to run through all of them is that we need to do something about the image and perception of intercollegiate athletics. I'm not sure what all of that means, but we certainly got a lot of advice about how to do it. I suspect that if we talked about intercollegiate athletics SO-years ago, we would have had people telling us about the same thing. I'm not sure that all of that changes a great deal. Certainly, we are aware of what's going on all about us and that perception and those images are in constant conflict today.

Typically, we get all kinds of commissions appointed. We have a Knight Commission. We have a Presidents Commission and we come out with all kinds a platitudes. Unfortunately, those of us who deal with the day-to-day life of intercollegiate athletics cannot deal on the level of platitudes, but have to deal with basic and practical solutions. Those of us who participated in this exercise to distribute the monies learned that we can listen to all of these great statements about how we were going to change the image of athletics by the way we distribute money from the NCAA will solve all of our image problems. We all know that's not the case. We had to come up with some very practical solutions.

We did have a billion dollars that comes to the NCAA over the course of seven years. From the day that we start, we have to understand where that billion dollars came from. It did not come out of the sky. It did not drop on us from heaven. It was not created by the solution of some great commission in Washington that suddenly said, "here's a billion dollars." It came as a result of the popularity of what is now one of the premiere sporting events in all of intercollegiate sports and probably all sports in general and that's the NCAA basketball tournament The heightened interest, the competitive spirit of that tournament has lead to a tremendous interest throughout this country . That was evidenced as we moved through the negotiation process with the various networks to determine what those television rights might be. It was created because of the greatness of the tournament.

The greatness of that tournament was, by and large, created by a significant number of teams, but not all of the teams spread across Division I. As a result, as we began to look at that formula and the way that money was distributed in the past, it was absolutely necessary, if politically we were going to change the distribution system, to acknowledge the fact that there were certain institutions and certain conferences that made a premiere contribution to the development of the situation that provided the billion dollars in the first place. Without that. politically, it probably was not within our capacity to sell the change in the concept in distributing this money. For that reason, the fifty percent historical pool was put together. Fifty-percent of the money, as Judy said, would be distributed back to the membership based not on an individual team's performance in a particular year, but a conference's performance over a rolling six-year period.

The concept to take the other fifty percent and distribute it in a novel and new way caused, perhaps, the most discussion. There was a great deal of discussion about broad based and what do we mean by broad based. Do we mean just sports sponsorship or do we mean a commitment beyond sports sponsorship to a total commitment, as we understand it, to Division I with the permissible scholarships that are involved? Furthermore, even beyond that, the performance of those programs within Division I championships and, therefore, rewarding the institutions based on its performance in NCAA championships beyond the basketball tournament.

From the standpoint that we felt we were rewarding twice for performance, once in the basketball tournament and once for our other sports, we eventually dropped the concept of rewarding performance in NCAA championships in other sports. We put together a formula which basically rewards institutions, fIrst of all, on the number of sports sponsored above the minimum levels required for Division I membership. Number two, the scholarship contribution to those sports that are sponsored. I think we must remember that this is a Division I tournament. The billion dollars was created by the Division I membership and, by-and-large, that money needs to be distributed back based on the commitment that the member-institutions have to the criteria which we have set for Division I. That's where the broad base concept came from as two fold; one-third of that money distributed on the sport you sponsored and two- thirds based on an evidence of your commitment to those sports beyond just having a team and a part-time coach and saying we have a sport, but to the broad support of that program in the form of scholarships to the student-athletes who participate. Based on that, the formula was put together .

We have discussed for a long time the differences and the concepts of membership in Divisions I, II and III and perhaps we haven't always clearly delineated what that means. Whether we like it or whether we don't, this distribution does delineate that But, I would also point out that in so doing, the committee rewarded every single Division I conference in the country from an amount of about $275,000 for a one unit's participation in the tournament the previous year, to approximately one-half million dollars, or more, for the lowest ranking conference in the nation. It increased anywhere from 100 to 200 percent Any conference that had been in existence for any major period of time jumped up to somewhere around three-quarters of a million dollars to $1 million when you add the conference grant

This is an enormous change in the way the NCAA is distributing their funds back to the member institutions. We have never done this on any basis in any process before. It is a tremendous change. It may not be the change that some would advocate, but it is a far different change from what we anticipated when we started this process. It is one that can be defended and one which is logical. It is not to say that it is final. I'm sure there will be further adjustments. We've got a lot of problems out there. In large measure, we have taken the steps that we said we would and that is to distribute the money back to the individual member-institutions, not based on a single free throw or not based on a single outcome on a last second overtime g~e, but rather on a broad based basis and on the total historical contribution of that conference to the NCAA basketball tournament. Thank you.


Thank you very much, Roy. As Executive Director of the Council of The Ivy Group presidents, Jeff Orleans h served as commissioner of The Ivy League, the nation's broadest based collegiate athletic conference since 1984. J( Orleans is a graduate of Yale College, class of 1967 and Yale Law School. From 1975 to 1984, he was special counsel to the president of the University of North Carolina and from 1971 to 1974, he was an attorney in the Department of Health, Education and Welfare and the Equal Employment Opportunity Commission. In 1990-91, JeJ served as secretary/treasurer of the University Commissioners Association. From 1987 through 1989, he was an original member on the NCAA Committee on Financial Aid and Amateurism. Jeff is an invited speaker at the NCj Presidents Commission sessions and at the NCAA Conventions in 1988 and 1989. Jeff Orleans has been active for more than a decade in the National Association of Collegiate and Universities Attorneys. His contributions were recognized in 1990 when he was named that association's Fellow. It is my pleasure at this time to present, Jeff Orleans.


Thank you, Eve. The NCAA has done long, hard work and they have moved the concept of revenue distributi< in the association in very good directions and very new directions and in ways which, when we look back IO-years from now, will seem revolutionary. My purpose this morning is not to dispute the details of any of those distributions and certainly not to impugn any of the work the committees have done. But, I would like to try and t as practical as Roy has been and tell you why I think the pattern of that distribution, in particularly, the way the committee has dealt with the phrase, "equitable, but not equal." This carries the seeds of real danger for those of u in intercollegiate athletics all through Division I and in all three Divisions.

I think the argument is very simple. You may remember at an NCAA meeting several years ago, John ThomI asked a packed auditorium, II Am I the only capitalist in the room?" The point of his remark, and a well-taken poi was that for many of us in intercollegiate athletics, one of the goals of an athletics program is not only to be self- sufficient, but, if possible, to generate net revenue. As an institutional matter, and perhaps, even as a conference and a divisional matter, it seems to me that that is an entirely appropriate choice to make from among the many choices we've got

My concern is that if we as an association are viewed as being capitalist foremost, there are plenty of people in the Congress and in the executive branch and in all types of state and local governments who are willing to treat us as capitalists. If they treat us as capitalists, they will tax intercollegiate revenues in ways that have never happened before and they will regulate intercollegiate athletics in ways that have never happened before, in ways that no one will be eager to see. The pattern of distribution which the executive committee has approved because it is, admittedly, conditioned so strongly on the contributions of a certain number of Division I institutions, and on the expectations that they will get back about two-thirds of the total revenue distributed under any formula in any year, will cause people on the hill and people in state and local governments to decide that it is time to treat all of intercollegiate athletics as a revenue making enterprise, whether the school is Division lor Division III, whether the revenue is CBS Television or Saturday afternoon revenues at the stadium.

Lest you think that I am trying to make a political point, let me go through with you six different ways in which, in the last two years, we have seen attention to collegiate athletic finances that we have never seen before. First, on Capitol Hill, we have seen Congressman McMillen, a member of the Knight Commission, take the time to write special footnotes to that Commission's report saying that the NCAA has not done well in dealing with the revenue distribution. Congressman McMillen also spent some time two years ago at an NCAA forum talking about extending the unrelated business income tax to all of collegiate athletic revenues. He has a counterpart from Michigan, Congressman Henry , who happens to be on the other side of the aisle, who has introduced legislation to require very detailed financial audits of all intercollegiate athletics programs. We have had hearings on the Hill within the last year about whether collegiate athletics will be on free television or pay television. If you put all of that together, it is an interest on the part of the Congress in how we get and spend our money, which is simply unprecedented.

Second, that interest is replicated in state and local governments across the country. We are in a terrible year, as all of you know, in terms of state and local government finance for higher education. A year when the needs of elementary and secondary schools are squeezing our budgets badly. In this year, it is not wise for state and local governments to see the need to subsidize intercollegiate athletics, as it has done in many I-AA and I-AAA and Division II programs. It is not wise to raise student's fees to cover intercollegiate athletics deficits, as is true in many of those programs. It is hard to maintain property tax exemptions which produce millions of dollars. State and local government regulators and legislators who are looking at their own fmances will look at the division of billion dollar contracts and want to know why that revenue is not distributed more equally.

Third, we have, in the Internal Revenue Service, a level of scrutiny about intercollegiate athletics money which has never happened before. The IRS has announced that it is going to tax sponsorship revenues at bowls. It is going to tax program revenue. It is going to tax revenue that goes on your scoreboards. There has been talk within the IRS of taxing that part of a grant-in-aid which is not related to need, taxing income to student-athletes. You will all remember the IRS's action several years ago, which would have taxed the amount of a ticket donation which is above the face value of the ticket Put all of this together and you have the IRS saying, we believe that you are a business and we are going to tax you as a business. If we have a revenue distribution which reinforces that conclusion on the part of the IRS, we will have the IRS not simply taxing individual parts of athletics programs, but simply taxing all of the revenue that goes to all athletics programs as a whole.

Fourth, we have, in the unrelated business income tax, the vehicle that, not only the IRS, but many individual legislators want to use, not only in athletics, but throughout higher education. There have been hearings for the last four years to tax an endowment income, to tax all kinds of income which higher education has always thought was non-taxable. The last thing our presidents, trustees and general counsels want is for that tax to be applied fIrst to collegiate athletics and then, to the rest of collegiate financing.

We have, fifth, a new level of anti-trust scrutiny. It's not just a Federal Trade Commission trying to scrutinize and change the College Football Association's contract, it is concerned that eligibility rules, if they relate to the economics of athletics rather than just to the student-athlete's academic progress, that eligibility rules will be violations of the Sherman Act. It is concerned that agreements not to pay athletes income would violate the Sherman Act if collegiate athletics in a profit-making enterprise.

Finally, we have concerns about the student-athletes ranging from the idea that their grants-in-aid should be taxed to the idea that because they, in Division I, are in a profit making or a commercial activity, should be entitled to Workmen's Compensation, entitled to salary and entitled to collective bargaining.

Any of us may agree or disagree in principle with any of those concepts in those six areas. I submit to you that if you put them all together, they are a powerful force in American society which is saying that American collegiate athletics, particularly Division I, has become a business and that it ought to be taxed and regulated as a business. If the revenue sharing formula can be construed as clear evidence of that, it is dangerous from the perspective of this regulation. My point is that for all of the hard work and all of the efforts that the Revenue Committee has put in, the bottom line is still, as Roy has said, a view of many. The revenue derives from the efforts of some institutions is a profit made by those institutions and, whatever the formula is, the revenue should come back to those institutions as profit. I submit to you that that is a dangerous proposition to put before the Internal Revenue Service, before the Congress, before the state and local governments who are hungry for revenue. We would do well next year to reconsider the basic premise of how we divide that contract. We would do well, in the long run, in terms of all the revenues we receive from all sources, to spend more attention on the equal distribution of revenue, above and beyond the specific formula such as academic enhancement. We need to worry very much about whether the current formula will not subject us down the road to the kind of regulation and taxation which we should avoid if we possibly can. Thank you.


Thank you, Jeff. The floor is now open for questions.


I'm Bobbie Carson from Boston College. I'd like to address a question to Judy. Did I understand you correctly in saying that the funds available for needy students, one of the criteria will be holding a Fell Grant?


They will have to be Fell Grant eligible.


I would like to suggest that the idea just submitted on the financial aid study for the NCAA be analyzed in terms of the significance and relevance of this requirement and, if possible, to project any significant change in funding from the Federal government or change in eligibility requirements for this be looked at in terms of using this as primary criteria.


Thank you for that suggestion. If you wouldn't mind sending that recommendation on to the committee, we'd appreciate it


I'm Lee McElroy, from California State University/Sacramento. I'd like to direct my question to Jeff. It has to do with looking into your crystal ball. If we're going to have local and state government intervention in terms of broadening the tax base, what would you see in the future of intercollegiate athletics, let's say in five or 10 years?


I think if we do have that, I would predict two consequences. One is just the chance that all major revenue would be considered unrelated business income and would be taxable, whether or not the athletics program was financed under regular administration or whether or not it turned a profit

The second concern I would have is that state and local governments would be encouraged to stop permitting the use of mandatory student fees which some states have already begun to cap. Local governments would also be much more aggressive in trying to tax the income from arenas or put a property tax on arenas, not just for non-athletics uses like rock concerts, but for whatever gross revenue is produced within those arenas.


If there are no further questions. I would like to call on Dr. Roy Kramer to do his rebuttal and summary.


First of all, I don't believe it's going to be the role of the NCAA Advisory Committee to solve the problems of the federal government. There's a lot of other problems out there. All of these are issues, I admit this. I deal with them on a daily basis. I've won a few and I've lost a few and we will to. I don't think we can run scared every time the federal government runs up a flag. If we do, we might as well close up and forget about this business.

There will be those issues and there will always be those issues, but I'm an optimist to think that we will win some of those as we go along. We will be able to defend what we're doing. I believe it will be very difficult to construe what the action of this committee did to be in total violation of what some of these principles that Jeff has set forward. From the standpoint that when you re-distribute the monies from one conference this year in such a way that had we not had this formula, they would have received somewhere in the neighborhood of $112 million and this year somewhere in the neighborhood of $6.5 million is a significant re-distribution of funds. If that's not defensible, then maybe we need to get a new lawyer.

I still feel that we can win some of these battles. We've taken a positive stance in the right direction and we've made significant change. It is change that will speak well for the NCAA for many years to come. Thank you.


Thank you, Roy. To present his summary and rebuttal, Jeff Orleans.


I guess I would say that we have made significant change. It does not necessarily mean that we've made significant enough change. Dealing with the federal government is not a matter of running away whenever you see the government on the horizon. I come from an area where we had a Naval, Army and Air Force base closed. It seems to me that across the country the places that will do best in dealing with possibilities of bases closing are the people who have prepared for them over the years, and are willing to take the government at its word when the government says its coming after you and to do what needs to be done. I don't want to change what I do just because the government says it may be there. On the other hand. when I see the government come over the hill with flags flying and tanks rolling, it seems to me that I need to know what I'm doing and need to be sure that what I've done will deal adequately with the government contentions. They have a much deeper pocket. I'm concerned that however much change we've made, we may not have made enough change to deal with those possibilities.


On behalf of myself and Eve Atkinson, I would like to express our appreciation to this outstanding group of panelists and to you for attending this session. We stand adjourned.