FTC Staff Comment Before the Federal Energy Regulatory Commission Concerning Analysis of Horizontal Market Power under the Federal Power Act (Docket No. RM11-14-000)

UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Analysis of Horizontal Market Power 	) 	Docket No. RM11-14-000
Under the Federal Power Act 	)
COMMENT OF THE STAFF OF THE FEDERAL TRADE COMMISSION
June 1, 2011
I. 	Introduction and Summary
The Federal Trade Commission (FTC) Office of the General Counsel, Bureau of Economics,
and Bureau of Competition1 appreciate this opportunity to comment on the Federal Energy
Regulatory Commission’s (FERC’s) Notice of Inquiry (NOI) concerning horizontal market
power. 2 FERC asks whether – and, if so, how – it should revise its approach for examining
market power concerns arising from horizontal mergers to reflect the revised Horizontal Merger
Guidelines (2010 Guidelines) issued by the U.S. Department of Justice (DOJ) and the FTC (the
Agencies) on August 19, 2010.3 The NOI also asks what impact the 2010 Guidelines should
have on FERC’s analysis of horizontal market power in its electric market-based rate program.
FERC, DOJ, and the FTC share the mission of ensuring that mergers and acquisitions do not
harm consumers. To achieve that goal, the three agencies should follow consistent approaches in
assessing whether a transaction is likely to diminish competition. Inconsistent approaches may
make the antitrust review process longer, more confusing, and more costly than necessary. In
addition, a consistent approach ensures that any FERC merger remedy would protect
competition. Consequently, the FTC staff welcomes this inquiry and encourages FERC to adopt
the approach set out in the entire 2010 Guidelines (rather than, for example, just the revised
Herfindahl-Hirschman Index (HHI) thresholds) as the foundation for its competition assessments
of proposed horizontal mergers.
1 This comment expresses the views of the FTC’s Office of the General Counsel, Bureau of
Economics, and Bureau of Competition. The comment does not necessarily represent the views
of the FTC or of any individual Commissioner. The Commission, however, has voted to
authorize the filing of this comment.
2 The FTC staff respectfully requests that FERC consider this out-of-time comment. The press
of other matters for which the FTC is responsible prevented the submission of this comment by
the May 23, 2011, deadline. We understand that the short delay in the filing of this comment, as
well as the absence of deadlines for reply comments and action by FERC, will prevent prejudice
to any other party associated with FERC’s consideration of this comment.
3 Analysis of Horizontal Market Power under the Federal Power Act, Notice of Inquiry, 134
F.E.R.C. ¶ 61,191 (2011).

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The NOI highlights the 2010 Guidelines’ HHI threshold revisions and asks specifically
whether FERC should adopt the revised thresholds contained in the 2010 Guidelines.4 We are
concerned that by focusing on changes in the HHI thresholds, FERC is missing a critical thrust
of the 2010 Guidelines, viz., that merger analysis should examine all dimensions of a
transaction’s likely competitive effects and should not focus unduly on market concentration.
Concentration analysis in the 2010 Guidelines is just one of numerous tools used to determine
whether a proposed horizontal merger threatens to lessen competition and harm consumers. 5
We do not intend by this comment to advise FERC on the procedures for conducting its own
merger reviews. As we discuss below, however, excessive reliance on HHIs – especially in
electricity markets – can lead to conclusions that are too lenient or too restrictive in an
assessment of market power. Given the characteristics of these markets, if FERC adopted the
2010 Guidelines’ updated concentration thresholds but did not also revise its approach to place
more emphasis on competitive effects – including examination of such effects even when the
merger does not exceed the concentration screen – then it could potentially approve mergers that
pose serious threats to competition, with significant harmful effects on consumers.
We recognize that, in order to apply the full Guidelines analysis, FERC may need access to
information that is different from (or in addition to) that which it typically receives or requests.
For example, in a 1998 comment on FERC’s then-proposed Appendix A requirements, the FTC
staff identified various types of information that the FTC finds useful in reviewing proposed
horizontal mergers.6 To the extent that FERC grapples with insufficient information for
conducting a thorough merger analysis, FERC may wish to revise its Policy Statement (including
Appendix A) to incorporate this additional information. FERC’s existing regulations state that
“[a]pplicants should provide data adequate to allow analysis under the Department of
Justice/Federal Trade Commission Merger Guidelines, as described in the Policy Statement and
Appendix A to the Policy Statement.” 7 Hence, FERC’s merger analysis process does not appear
to preclude obtaining information sufficient to enable it to follow the 2010 Guidelines fully.
FERC’s alignment of its competition analysis with those of the Agencies would improve the
efficiency and reliability of government-wide merger review processes in the energy sector.
Below, we identify revisions to a number of sections of the 2010 Guidelines that are likely to
be most pertinent to FERC’s review of horizontal electricity mergers. We conclude with a brief
discussion of how following the 2010 Guidelines is likely to affect FERC’s assessments of
market-based rates.
4 Id. PP 12, 15-18.
5 Compare 2010 Guidelines ¶ 5.3 with the remainder of the Guidelines.
6 See Comment of the Staff of the Bureau of Economics, Federal Trade Commission, Docket No.
RM98-4-000, Parts II and III (Sept. 11, 1998), available at http://ftc.gov/be/v980022.shtm; see
also infra note 36.
7 NOI P 5.

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II. 	Interest of the Federal Trade Commission
The FTC is an independent agency of the United States Government responsible for
maintaining competition and safeguarding the interests of consumers, both through enforcement
of the antitrust and consumer protection laws and through competition policy research and
advocacy. The FTC often analyzes regulatory or legislative proposals that may affect
competition or allocative efficiency in the electric power industry. The FTC also reviews
proposed mergers that involve electric and natural gas utility companies, as well as other parts of
the energy industry. In the course of this work, as well as in antitrust and consumer protection
research, investigations, and litigation, the FTC applies established legal and economic principles
and recent developments in economic theory and empirical analysis. The energy sector,
including the electric power industry, has been an important focus of the FTC’s antitrust
enforcement and competition advocacy.8 The FTC’s competition advocacy program has
produced two staff reports on electric power industry restructuring issues at the wholesale and
retail levels.9 The FTC staff also contributed (as did FERC staff) to the work of the Electric
Energy Market Competition Task Force, which issued a Report to Congress in 2007.10 In
addition, the FTC has held public conferences on energy topics, including Energy Markets in the
21st Century (April 10-12, 2007)11 and Carbon Offsets & Renewable Energy Certificates
(January 8, 2008). 12
8 See, e.g., Opening Remarks at the FTC Conference on Energy Markets in the 21st Century:
Competition Policy in Perspective (Apr. 10, 2007), available at
http://www.ftc.gov/speeches/majoras/070410energyconferenceremarks.pdf. 	FTC merger cases
involving electric power markets have included the DTE Energy/MCN Energy (2001) (consent
order), available at http://wwwftc.gov/os/2001/05/dtemcndo.pdf; and PacifiCorp/Peabody
Holding (1998) (consent agreement), available at
http://www.ftc.gov/os/1998/02/9710091.agr.htm. (The FTC subsequently withdrew the
PacifiCorp settlement when the seller accepted an alternative acquisition offer that did not pose a
threat to competition.)
9 FTC Staff Report, Competition and Consumer Protection Perspectives on Electric Power
Regulatory Reform: Focus on Retail Competition (Sept. 2001), available at
http://www.ftc.gov/reports/elec/electricityreport.pdf; FTC Staff Report, Competition and
Consumer Protection Perspective on Electric Power Regulatory Reform (July 2000), available at
http://www.ftc.gov/be/v000009.htm (compiling previous comments from the FTC staff provided
to various state and federal agencies).
10 See http://www.ferc.gov/legal/fed-sta/ene-pol-act/epact-final-rpt.pdf.
11 Conference materials available at
http://www.ftc.gov/bcp/workshops/energymarkets/index.shtml.
12 Conference materials available at
http://www.ftc.gov/bcp/workshops/carbonoffsets/index.shtml. Other programs have included the
FTC’s public workshop on Market Power and Consumer Protection Issues Involved with
Encouraging Competition in the U.S. Electric Industry, held on September 13-14, 1999

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The FTC and its staff have filed numerous competition advocacy comments with FERC –
including comments closely related to the present inquiry – and have participated in FERC
technical conferences on market power issues. For example, in March 2007, the Deputy Director
for Antitrust in the FTC’s Bureau of Economics served as a panelist for a technical conference
on FERC’s merger and acquisition review standards under Federal Power Act Section 203
(Docket No. AD07-2-000). In March 2010, the FTC submitted comments on FERC’s proposed
rule concerning FERC’s competitive assessments of acquisitions of minority interests in other
firms (Docket No. RM09-16-000), which is an issue addressed by the 2010 Guidelines. 13
Similarly, the FTC submitted comments in December 2009 in FERC’s proceedings on
possible elements of a National Action Plan on Demand Response (Docket No. AD09-10-000)14
and on transmission planning processes (Docket No. AD09-8-000).15 In March 2010, the FTC
filed a comment on performance metrics for RTOs and ISOs (Docket No. AD10-5-000),16 and
more recently the FTC staff commented in response to FERC’s Notice of Proposed Rulemaking
concerning integration of variable energy resources (Docket No. RM10-11-000).17 The FTC also
has commented on FERC’s initiatives to promote wholesale electricity competition and on
various state issues associated with restructuring the electric power industry.18
III. 	The Role of Concentration and Market Definition in Identifying Anticompetitive
Effects
The NOI focuses on the 2010 Guidelines’ revisions to concentration thresholds. It is easy to
understand why there is a tendency to place such an emphasis on concentration measures.
Information bearing on concentration often is relatively easy to obtain quickly but, because it is
quantitative, such information may carry a potentially misleading aura of precision as an
(workshop materials available at http://www/ftc.gov/bcp/elecworks/index.shtm); and the
Department of Justice and FTC workshop on Electricity Policy, held on April 23, 1996.
13 This comment is available at http://www.ftc.gov/os/2010/03/V090008ferc.PDF.
14 This comment is available at http://www.ftc.gov/os/2009/12/V100002ferc.pdf.
15 This comment is available at http://www.ftc.gov/os/2009/12/V100001ferc.pdf.
16 This comment is available at http://www.ftc.gov/os/2010/03/100319performancemetrics.pdf.
17 This comment is available at http://www.ftc.gov/os/2011/03/110304fercenergyresources.pdf.
18 See, e.g., Federal Trade Commission, Comment before the Federal Energy Regulatory
Commission on Wholesale Competition in Regions with Organized Electric Markets, FERC
Docket Nos. RM07-19-000 and AD07-7-000 (Apr. 17, 2008), available at
http://www.ftc.gov/be/v070014b.pdf. A listing of FTC and FTC staff competition advocacy
comments to federal and state regulatory agencies (in reverse chronological order) is available at
http://www.ftc.gov/opp/advocacy_date.shtm.

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indicator of market power or the potential for its exercise. Experience has taught the Agencies
that merger analysis should not rely on a single measurement. “The measurement of market
shares and market concentration is not an end in itself, but is useful to the extent it illuminates
the merger’s likely competitive effects.”19 Relying on concentration alone (under either the 1992
or the 2010 concentration thresholds) to determine whether a transaction is likely to substantially
lessen competition is an insufficient approach that is prone to error. Merger analysis should be a
fact-specific process in which analysts use a variety of tools and forms of evidence to determine
whether a merger may substantially lessen competition. Accordingly, “[t]he Agencies consider
any reasonably available and reliable evidence to address the central question of whether a
merger may substantially lessen competition.”20
The Agencies often calculate an HHI to measure market concentration, which is derived by
summing the squares of individual firms’ market shares. Both the post-merger HHI and the HHI
increase resulting from the merger are considered. The HHI thresholds, however, do not
“provide a rigid screen to separate competitively benign mergers from anticompetitive ones,
although high levels of concentration do raise concerns.”21 Rather, the Guidelines’ thresholds
“provide one way to identify some mergers unlikely to raise competitive concerns and some
others for which it is particularly important to examine whether other competitive factors
confirm, reinforce, or counteract the potentially harmful effects of increased concentration.”22
Overreliance on HHIs, particularly in electricity markets, can yield conclusions that are too
lenient or too restrictive in an assessment of market power. Among the distinguishing
characteristics of electricity markets are the prevalence of relatively inelastic demand, capacity-
constrained firms, transmission congestion, and long-term supply contracts. For example,
inelastic demand tends to make supply restrictions more profitable, thereby increasing the risk of
substantial consumer harm associated with any given HHI level. Although demand can be
expected to be somewhat more responsive to wholesale price changes in the future – as demand
response technologies and dynamic prices at the retail level are implemented – that alone is
unlikely to make HHIs so robust a predictor of competitive effects that other indicators can be
neglected. In addition, when suppliers are capacity-constrained, a decision by one or more
sellers to restrict supply is less likely to be undermined by increased output on the part of rival
suppliers. This also increases sellers’ incentives to restrict supply beyond what a given HHI
level would lead one to expect. Transmission congestion is a particular form of capacity
constraint with the same increased risk of substantial anticompetitive effects and harm to
consumers. Conversely, the presence of existing supply contracts with long durations tends to
lessen the risk of substantial consumer harm from high HHIs by reducing the profitability of
efforts to restrict supply in spot markets. The profitability is reduced because the higher spot
19 2010 Guidelines, § 4.
20 Id. § 2.
21 Id. § 5.3.
22 Id. (emphasis added).

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market price applies to less output when some of the output has already been committed at a
lower price.23
The Guidelines also focus on alternatives available to customers as the basis for the use of
the “hypothetical monopolist” test that the Agencies employ to define a relevant market. Section
4 of the 2010 Guidelines presents the hypothetical monopolist test, offers several examples, and
identifies significant alternative ways to apply this test in different circumstances. Strict market
definition, however, is not the only appropriate starting point for merger analysis, and in some
situations it may not even be a required element of the analysis. Some transactions may present
evidence of anticompetitive effects that is itself useful in identifying relevant markets.24 Some of
the analytical tools used by the Agencies to determine competitive effects do not rely on market
definition, although they do focus on competitive alternatives to which customers can turn. 25
IV. 	Evidence and Theory of Competitive Effects
To emphasize the insights developed since the 1992 Guidelines were issued, the 2010
Guidelines contain a new Section 2 on evidence of adverse competitive effects. The Agencies
have found this type of evidence useful in predicting the likely competitive effects of mergers.
The new section discusses market shares and concentration as one of several indicators of a
merger’s potential competitive effects. The 2010 Guidelines include the observation that
presumptions of market power based on concentration measures can be “rebutted by persuasive
evidence showing that the merger is unlikely to enhance market power.”26 Other types of
evidence listed in new Section 2 include the actual effects observed in a consummated merger,
direct comparison based on experience, substantial head-to-head competition, and the potentially
disruptive role of a merging party.27 We believe that consideration of these types of evidence
would enrich FERC’s competition analysis of mergers. FERC also may identify additional types
of evidence of competitive effects that have special significance in electricity mergers.
A thorough assessment of a merger’s competitive effects requires consideration of the
probable unilateral and coordinated effects of the transaction. The elimination of competition
23 For additional explanations of the potential effects of existing contracts on market power, see
David Newbery, “Predicting Market Power in Wholesale Electricity Markets,” European Univ.
Inst., Robert Schuman Centre for Advanced Studies, Loyola de Palacio Programme on Energy
Policy EUI Working Paper RSCAS 2009/03 (2009), available at
http://cadmus.eui.eu/bitstream/handle/1814/10620/EUI_RSCAS_2009_03.pdf?sequence=1.
Distinguishing aspects of electricity markets are also discussed in the Electric Energy Market
Competition Task Force’s Report to Congress, supra note 10, Chs. 3 and 4.
24 2010 Guidelines, § 4.
25 Id.
26 Id. § 2.1.3.
27 This list is illustrative but not comprehensive.

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between two firms (unilateral effects) may by itself constitute a substantial lessening of
competition. Section 6 of the 2010 Guidelines discusses several common types of unilateral
effects. One such effect, “unilateral output suppression strategy,” exemplifies a type of concern
that can arise in electricity markets:
A unilateral output suppression strategy is more likely to be profitable when
(1) the merged firm’s market share is relatively high; (2) the share of the merged
firm’s output already committed for sale at prices unaffected by the output
suppression is relatively low; (3) the margin on the suppressed output is relatively
low; (4) the supply responses of rivals are relatively small; and (5) the market
elasticity of demand is relatively low. 28
Although FERC has recognized that a merger could give the merged firm the incentive and
ability to undertake a unilateral output suppression strategy, FERC has stated that it would
examine the potential for such a strategy only if concentration thresholds were exceeded.29
Under the 2010 Guidelines, however, the Agencies may consider the risks of such a strategy,
even if the merger does not exceed the market concentration screens. Thus, as we said above, if
FERC adopted the 2010 Guidelines’ updated concentration thresholds but did not also revise its
approach to place more emphasis on competitive effects – including examination of such effects
even when the merger does not exceed the concentration screen – then it could potentially
approve mergers that pose serious threats to competition. Where the factors raising concerns
about unilateral output suppression are present in electricity markets, FERC should be
particularly attentive to the anticompetitive effects of mergers – even when post-merger
concentration levels are below the thresholds set forth in the 2010 Guidelines.
Coordinated anticompetitive effects also occur when a merger affects the supply decisions of
the firms remaining in the post-merger market in ways that harm consumers. Outright collusion
is one important kind of coordinated effect, but less explicit forms of coordination can also
significantly lessen competition. Section 7 of the 2010 Guidelines discusses coordinated effects.
An important update in the 2010 Guidelines is increased attention to competitive effects on
dimensions of competition other than price, including product variety, product quality, and
innovation.30 As electricity markets move beyond the one-product-fits-all model, this aspect of
merger analysis will likely become more important to FERC.
V. 	Other Features of the 2010 Guidelines that Bear on Proper Merger Analysis
We also highlight certain other sections of the 2010 Guidelines that describe important
elements of the Agencies’ merger review process and should enrich FERC’s analysis of mergers.
28 2010 Guidelines, § 6.3.
29 FPA Section 203 Supplemental Policy Statement, 120 F.E.R.C. ¶ 61,060, P 60 (2007), order
on clarification, 122 F.E.R.C. ¶ 61,157 (2008).
30 2010 Guidelines, § 6.4.

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We address several of these topics because the revisions in the 2010 Guidelines also address
them. Not all of these sections will be relevant to every merger or acquisition under review, but
any of them may be applicable depending on the characteristics of the transaction.
A. 	Powerful Buyers and Monopsony
The 2010 Guidelines include a new Section 8 on the competitive effects analysis involved
when powerful buyers are present. This section points out that powerful buyers may be able to
negotiate to avoid some or all anticompetitive effects of a merger. “However, the Agencies do
not presume that the presence of powerful buyers alone forestalls adverse competitive effects
flowing from the merger.”31 The Agencies examine the choices available to powerful buyers and
how those choices would change due to the merger. The Agencies also examine whether the
negotiating strengths of some buyers impact the competitive effects of a merger on other buyers.
The 2010 Guidelines also contain a new Section 12 on the competitive effects of mergers of
competing buyers. This analysis focuses on alternatives available to suppliers (rather than
customers) when a merger reduces the number of buyers. In the analysis of mergers of
competing buyers, the “hypothetical monopolist” test based on a price increase – which is at the
core of the usual 2010 Guidelines analysis of mergers of suppliers – is converted to a
“hypothetical monopsonist” test based on a price decrease.
B. 	Entry and Efficiencies
The 2010 Guidelines discuss entry32 and merger-specific efficiencies33 as market conditions
and effects that may alleviate concerns about adverse competitive effects of a merger. Given the
capital-intensive nature of many investments in the energy industry (other than some demand-
side resources), and the resulting long lead times often required, reliance on entry to address
adverse effects on competition would seem to be the exception, not the rule. Nonetheless, the
Guidelines recognize that easy, rapid, and substantial entry into the relevant market could
discipline efforts by the merged firm to exercise unilateral market power, or by the firms
remaining in the market post-merger to coordinate their behavior.
Efficiencies generated by a merger could enhance competition by spurring innovation,
reducing costs, or improving quality. Normally, however, competition itself spurs these efforts.
Thus, efficiencies carry weight in merger analysis only when they would not be achieved absent
the merger (or a comparably anticompetitive alternative). The Agencies are likely to view
efficiency claims substantiated by analogous past experience as most persuasive as to whether
the asserted efficiencies suffice to counteract any harm to customers from the transaction.
31 Id. § 8.
32 Id. § 9.
33 Id. § 10.

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C. 	Partial Acquisitions
The new partial acquisitions section of the 2010 Guidelines identifies significant potential
anticompetitive effects due to partial acquisitions, even when the partial acquisition does not
necessarily constitute a transfer of control to the acquirer.34 The Agencies will consider all ways
in which a partial acquisition may affect competition. Three aspects of a partial acquisition’s
competitive impact are of particular concern: (1) the acquirer’s influence over the competitive
conduct of the target firm, (2) reductions in the incentives of the acquiring and target firms to
compete with each other, and (3) access by the acquiring firm to non-public, competitively
significant information about the target firm.35
D. 	Information for 2010 Guidelines Analysis of Mergers
The 2010 Guidelines discuss sources of evidence to be obtained from merging parties,
customers, and other industry participants and observers. The FTC staff provided a similar list
of information sources and types in a 1998 comment to FERC concerning FERC’s then-proposed
revised filing requirements for merger applications in the electric industry.36 That earlier
discussion remains relevant as FERC undertakes merger analysis pursuant to the 2010
Guidelines. Moreover, given the detailed information available about electricity power flows
and transmission conditions, FERC may gain insights about the competitive effects of mergers
from computer modeling of merger effects under diverse scenarios. The FTC staff’s 1998
comment also addressed this potential source of improved merger analysis.37
34 Id. § 13.
35 For a more extensive discussion of these issues in the context of the electricity industry, see the
FTC’s 2010 comment on FERC’s proposed rule concerning competitive assessments of firms’
acquisitions of minority interests in other companies, supra note 13.
36 See Comment of the Staff of the Bureau of Economics, supra note 6, esp. Parts II and III. That
comment highlighted the following information sources used by the Agencies in merger
investigations: (1) internal documents of the merging parties (including, e.g., planning and
marketing documents; merger assessments; evaluations of current and projected technologies;
cost, quality, and reliability comparisons of firms and their individual production facilities; and
joint venture documentation); (2) documents from third parties, including industry trade
associations; (3) depositions of party and third-party executives and consultants; (4) relevant
previous antitrust cases (including collusion cases involving the same firms or the same
industry); (5) financial analysts’ reports; (6) employees’ notes concerning contacts with
competitors; (7) consultants’ reports on competitive conditions in the industry; (8) documents
from, and interviews with, executives of failed entrants, prospective entrants, and fringe firms;
(9) filings before other government agencies that bear on relevant competitive conditions; and
(10) documents from and interviews with customers.
37 Id. Parts IV and V.

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VI. 	Market Power Issues in Determining Whether to Authorize Market-Based Rates
The NOI also asks “what impact the 2010 Guidelines should have, if any, on [FERC’s]
analysis of horizontal market power in its electric market-based rate program.”38 The same
sources and types of information that are discussed in the 2010 Guidelines also are useful in the
determination of whether a supplier already has market power, although the inquiry is somewhat
different. In the evaluation of a merger, the analysis focuses on changes in competition due to
the merger. By contrast, the market definition exercise in a non-merger matter seeks to identify
customer alternatives at the competitive price. (The competitive price is likely to be lower than
the current price if the latter includes a market power component.)39 A failure to ensure that
customer alternatives are analyzed at the competitive price can result in a serious error, such as
defining the market too broadly if customers are searching more widely for alternatives in
response to an already supracompetitive price.40 Proper application of the Guidelines in the
context of market-based rate reviews will help avoid such errors.
38 NOI P 21.
39 2010 Guidelines, footnote 5.
40 This type of error in market definition is known as the “Cellophane fallacy,” after the product
sold by defendant du Pont in United States v. E.I. du Pont de Nemours and Co., 351 U.S. 377
(1956). The Supreme Court ruled that du Pont did not have market power for food wrapping
and, as the primary support for the broad product market that it found, observed that customers
were routinely substituting other food wrappings for cellophane. Economists generally find fault
with this decision because the Court did not account for du Pont’s existing market power when it
examined demand substitution by customers away from cellophane. In general, the price at
which to conduct the hypothetical monopolist test is the price that would prevail absent the
challenged practices. The original economic reviews of the Supreme Court’s decision include
George W. Stocking, “Economic Tests of Monopoly and the Concept of the Relevant Market,” 2
Antitrust Bull. 479 (1957); Donald F. Turner, “Antitrust Policy and the Cellophane Case,” 70
Harv. L. Rev. 281 (1956); George W. Stocking and Willard F. Mueller, “The Cellophane Case
and the New Competition,” 45 Am. Econ. Rev. 29 (1955).