John L. Knapp – Chairman RBSTA, on successfully unlocking the energy resources in the Black Sea
Bio John L. Knapp – Chairman RBSTA
ExxonMobil Exploration and Production Romania Limited currently chairs the Romanian Black Sea Titleholders Association (RBSTA), through its representative John L. Knapp, Managing Director. John L. Knapp has been the Managing Director of ExxonMobil Exploration and Production Romania Limited since January 2013. Prior to this, he was the Safety, Security, Health and Environment Manager for ExxonMobil Exploration Company in Houston, Texas. He has 33 years of technical and management experience with ExxonMobil. He has worked internationally throughout his career, including assignments in Egypt, Norway and Brazil.
The Romanian Black Sea Titleholders Association (RBSTA) has been founded relatively recently. How did this initiative start and what are the Association’s objectives and main activities?
Most of you know that Romania has a long and rich history in the onshore oil and gas industry. Given the significant progress and potential for the industry offshore, in particular in deep waters, there’s a need for a specific industry association to support the pioneering work of the companies involved. Today, technology enables industry to drill efficiently and safely in over 3000 m of water. We are now able to produce offshore oil and gas deposits in water depths that were impossible a generation ago. RBSTA believes that the Romanian part of the Black Sea is a promising, yet challenging, area in terms of its potential energy resources. Developed with care, the resources are expected to play a strategic role in Romania’s future energy mix.
However, developing these resources has many challenges that require a cooperative dialogue and proactive action between the offshore investors, the stakeholders and the Government of Romania. For the offshore titleholders, exploration activities in the Romanian Black Sea represent significant financial investments, and come at considerable risk. To successfully address these challenges there needs to be commitment from both industry and government. Industry needs to find new solutions to the unique Black Sea challenges; to operate safely while protecting the environment; to invest with a long term, disciplined focus and be satisfied with nothing less than excellence in its operations. Governments will need to make investments attractive by encouraging profitable opportunities, supporting open, competitive markets and above all providing a stable fiscal and regulatory environment in which long-term investment decisions can be made with confidence.
RBSTA is the only association dedicated to the exploration and development of Romania’s Black Sea hydrocarbon resources and is formed by titleholders of concessions offshore Romania. RBSTA was established in 2013 and has as members the following titleholders of concessions offshore Romania: Black Sea Oil & Gas S.R.L., ExxonMobil Exploration and Production Romania Limited, Gas Plus International B.V., Lukoil Overseas Atash B.V., OMV Petrom S.A., Petro Ventures Europe B.V., and SNGN ROMGAZ S.A. RBSTA aims to facilitate the realization of the full economic potential of Black Sea oil and gas resources while protecting the environment, as well as the health and safety of those involved in offshore activities.
Although we come from very different backgrounds, we share a common belief in the importance of safe, environmentally responsible operations, conducted at the highest ethical standards. These are core values for us and I believe these common values are the foundation of the positive and constructive collaboration. A key goal of the Association is to become the recognized focal point of knowledge and best practices among offshore oil and gas operators in Romania. Establishing such collaboration and cooperation between the Romanian Black Sea operators should contribute to the country’s economic development. The energy sector is a key driver of economic growth. The combination of Romania’s natural resource endowment in conjunction with its strategic geographical location places the country in an advantageous position to become a regional energy hub. The RBSTA members are looking to help Romania expand its offshore hydrocarbon production and to fulfil this potential.
What are the most important topics addressed by the association?
It is important to remember that offshore exploration is a high-risk investment. The main activities undertaken by the RBSTA members in the Romanian sector of the Black Sea – especially in deep waters – are frontier exploration activities, where there is no certainty of commercial development. It is a major undertaking to coordinate such pioneering activities. It would not be possible without the titleholders’ cooperation and support of the Romanian authorities. And, on behalf of the titleholders I thank the various Romanian authorities, in particular National Agency for Mineral Resources (NAMR), who are fulfilling their roles in a constructive manner, consistent with the industry’s offshore drilling procedures.
Projects in Romania’s Black Sea territory are complex and are characterized by a number of specific challenges. Most ongoing projects are still in the exploration phase, as the Romanian Black Sea is a virtually unexplored basin. Investors take on all the risks and costs of the exploration phase which can last ten years or more. This is the period required for seismic surveying, drilling, evaluation and assessment studies – all these activities are carried out prior to any production. The offshore investments require cutting-edge technology and are therefore very expensive. Moreover, potential developments in the Romanian Black Sea also have the added complexity and cost of access and mobilization due to the challenging transit of equipment and materials through the Bosphorus and Dardanelles Straits. There is limited geological knowledge of the area. Exploration drilling, especially in such frontier, unexplored areas as the Romanian Black Sea deep waters holds no guarantee of commercial success, even with the significant investments involved. Moreover, the upstream offshore transportation infrastructure still needs to be built. In this context it is important to note that development work undertaken, in the event that commercial volumes are confirmed, will not benefit from existing pipelines and, on the contrary, will add additional costs required to provide a route to shore via up to 200 km of subsea pipelines.
These are some of the major challenges to exploration but, of course, even if successful exploration drilling results in hydrocarbon discoveries there are other challenges that must be overcome in order to develop a commercial project. The RBSTA is committed to the development of Romania’s energy resources in the Black Sea. However, due to elevated costs and longer timelines, offshore projects in the Romanian Black Sea have specific investment risk profiles. This is the why RBSTA has always emphasized that the stability and predictability of Romania’s legislative environment in general, and its fiscal regime in particular, is a pre-requisite for successfully unlocking Romania’s offshore energy resources to the fullest possible extent. In this respect, a main objective is to support the development of a regulatory framework aimed at avoiding any obviously unintended, yet detrimental effects on developing the Black Sea’s potential energy resources.
RBSTA believes that the Romanian part of the Black Sea is a promising, yet challenging, area in terms of its potential energy resources. Developed with care, the resources are expected to play a strategic role in Romania’s future energy mix.
Could you explain further regarding the major problems faced by the offshore operators in the Romanian sector of the Black Sea in general and what do you think would be the most important measures in order to attract investment in the Romanian energy sector?
In our opinion, the key objective to support the business environment in the energy field should be to ensure the stability and predictability of Romania’s legislative framework in general, and of its fiscal regime in particular, through adopting and following a clear long term energy policy and more efficient regulations enforced by empowered authorities.
Of significant concern, for example, is the current trend to expand the scope of taxation and duties for the energy sector. Such decisions have severe negative impacts on project economics and will be a factor, along with the overall fiscal structure and any changes thereto, in any decisions about whether to explore for or develop other potential offshore discoveries. Offshore projects have high upfront costs and geological uncertainties during the exploration and appraisal phases followed by very significant up front infrastructure development costs over a prolonged period prior to obtaining revenues from production. In order to make these significant investment decisions the investor needs confidence that the fiscal terms are stable over the entire life of the Concession. Adverse fiscal amendments or even the threat of enacting fiscal amendments could result in a number of potential projects becoming uneconomic.
Another concern we have is around the unintended consequences of overnight government decisions. For our industry, it is vital to have the confidence that the decision making process impacting the energy sector is based on a constant, effective and meaningful consultation with relevant stakeholders, including the offshore investors.
However, there is important progress as well and RBSTA welcomes the efforts of the Romanian Government to finalize the National Energy Strategy and is encouraged to see that recognition is given to the tasks ahead, particularly with respect to compliance with European Union legislation. The relevance of this document for investors is that it should reconfirm long term objectives and priorities for the Romanian energy industry. Moreover, for both investors and the Romanian state, it is important to continue reforms of the energy market legislative framework by creating an integrated, competitive, open market, including integrating the Romanian energy market further into the wider EU energy market. These are very important factors for achieving energy security and Romania should continue promoting diversity of supply and access to both internal and external markets.
The Romanian authorities have made significant progress towards a comprehensive implementation of European directives, correlated with existing Romanian legislation. However, RBSTA believes that relevant legislation for oil and gas industry contains issues which still need to be clarified. Some issues are related to ambiguous wording, while others require amendments in order to simplify, standardize, and clarify bureaucratic procedures in order to reduce the administrative burden associated with authorization processes.
Specific to our industry’s operations, I would like to say that due to the unique challenges associated with carrying out oil and gas operations in the Black Sea and consistent with worldwide offshore petroleum industry best practices, appropriate legislation needs to be adjusted and enacted in order to facilitate the optimal development of the offshore Romanian hydrocarbon industry, and in certain cases, remove blockages that have the effect of potentially stranding significant resources offshore Romania. The RBSTA members’ priority is to make sure that all operations performed in the Romanian sector of the Black Sea are carried out efficiently and observe technical best practices, and reflect the highest standards of operational safety and security. In this context, the RBSTA has identified the need to adapt the existing regulatory framework to the specifics of offshore activities, following the European standards and the best practices in the field. Accordingly, RBSTA has proposed to the Romanian Government a set of legislative solutions meant to make the applicable regulatory framework more suitable for the complex specifics of offshore operations.
Our association believes in Romania’s energy potential generally, including the country’s potential to become a regional energy supplier. At the same time, the development and use of new energy resources and technologies in the country’s energy mix, such as offshore hydrocarbons development, could foster industrial innovation and contribute to developing highly competitive industries in the country (e.g. producing auxiliary equipment, infrastructure, etc.). In addition, the successful commercial development of these resources would create significant new fiscal revenues for the Romanian state.
Finally, our main concern is related to ongoing discussions about changing the existing fiscal framework. Offshore investments require a stable regulatory and fiscal environment. Stability clauses in existing petroleum agreements must be properly considered and respected. Stability and predictability are key premises to maintain an attractive environment for such investments. This is the only way to build a long-term, win-win partnership between the state and offshore investors. It is to be noted that because of the multiplier effect associated with the energy industry, an over-taxation of the energy sector may have an adverse impact on the investments in other industries and therefore on Romania’s overall economic growth.
Related: Artur Stratan: ROPEPCA supports a progressive royalty system
The Minister of Finance, Mrs. Anca Dragu, announced in the beginning of March that the draft law on royalties will be discussed in a few weeks with the operators from the oil and gas industry, and then will be subject to public debate. Also, the minister mentioned that the need to promote investments is being considered. What amendments is RBSTA proposing in this respect and what are, in your opinion, the mandatory provisions of a legislation that would encourage investors?
In our opinion, oil and gas fiscal terms should allow the country to realize fair value from the resources; should reflect all factors impacting investment decisions and the investors’ risk tolerance at the time the initial investment is made; and should consider the total value equation (energy security of supply; indirect revenues; potential development of new local support industries). Most fiscal terms around the world have been designed to be consistent with the challenges of monetizing hydrocarbon resources in each country’s particular environment, recognizing the geologic potential and risks; physical environment; technical challenges; available infrastructure; challenges in recovering the resource from the reservoir; challenges in bringing the resource to market; value of the resources, and investors’ exposure to financial risks.
In view of all these aspects we would therefore expect the Romanian Authorities to take into consideration the fact that offshore projects in the Romanian Black Sea have highly specific risk profiles and elevated costs. It should also be acknowledged that in order to maintain current investments or to attract new investments in a country, a tax regime should not only be stable but also be competitive. When compared to already developed areas, the offshore projects of the Black Sea represent extreme challenges as far as exploration and development are concerned. When referring to and comparing with tax regimes applicable in other countries, aspects like the maturity of the area, infrastructure and technical challenges should be taken into account when determining the fairness of the overall government take.
It is therefore justified to address specific challenges associated with offshore business and, to this extent, stability and predictability are key premises to maintain an attractive environment for investments. Consequently, any increase in the level, scope or timeframe of the application of an agreed fiscal instrument is going to have a negative impact on the long term economic viability of current operations and planned investments, especially given that all of these investments are budgeted and scheduled long in advance.
Any increase to the overall government take applicable at the moment of initial investment decision would undermine investors’ confidence in the long term stability of the fiscal and regulatory environment and would be viewed as punitive to those companies who have taken the risk and made the investments that have brought offshore exploration in Romania to the stage it is at today. In addition, any such decision would be a disincentive to further offshore exploration and increases the risk of stranded fields for some offshore resources, considering their specific geological and technical challenges.
The energy sector is a key driver of economic growth. The combination of Romania’s natural resource endowment in conjunction with its strategic geographical location places the country in an advantageous position to become a regional energy hub.
At the same time, it is our opinion that a decision to support potential development of offshore resources by maintaining overall taxation at the level existing when offshore concessions were granted should have no negative impact on the federal budget in the near or medium term, whereas in case of development there would be a positive impact for the mid to long term. An optimal fiscal and regulatory frame to encourage development of such new resources will ensure additional revenues by bringing additional volumes to the market. It is our view that the magnitude of investments specific to offshore projects will have a positive impact on the Romanian economy overall.
In conclusion, we recommend for the Romanian Authorities to consider all the unique circumstances for the offshore industry. And, the RBSTA encourages the Government of Romania to develop a solution aimed at mitigating an obviously unintended, yet detrimental effect on developing the Black Sea’s energy resource potential.
Another piece of legislation published for public debate is the draft law on safety of offshore oil and gas operations, to transpose the provisions of Directive 2013/30/EU in the Romanian legislation. What is RBSTA’s position on the draft law?
The RBSTA’s approach to safety and environment is clear: we are committed to high standards of operations. The association’s members seek to comply with all applicable environmental and regulatory requirements. Providing a regulatory system that ensures effective and appropriate safety and environmental standards, and optimizes the impact on industry should be the objective of both, regulatory authorities and stakeholders. Based on its members’ extensive global experience in the offshore industry, we believe that the Romanian authorities have made significant steps towards a comprehensive implementation of Directive 2013/30/EU provisions in the Romanian legislation. However, RBSTA believes the most recent draft still contains issues which need to be clarified before a final decision is taken. It is our understanding that authorities will address all aspects raised by operators related to additional bureaucracy aspects, such as: existing application and reporting requirements and avoiding additional administration and duplication; ensuring correlation with existing legislation. And, best efforts need to be made into setting up a competent authority for offshore safety, properly resourced, that could carry out all its duties in the best interest of all parties involved.
Due to elevated costs and longer timelines, offshore projects in the Romanian Black Sea have specific investment risk profiles. This is why RBSTA has always emphasized that the stability and predictability of Romania’s legislative environment in general, and its fiscal regime in particular, is a pre-requisite for successfully unlocking Romania’s offshore energy resources to the fullest possible extent.
To continue with the most important initiatives for the industry, what is RBSTA’s perspective on the new national energy strategy? What suggestions and proposals has the association made in the consultative sessions held for the elaboration of the strategy?
Due to the natural decline of Romania’s hydrocarbon production over time, the development of new indigenous sources is an economic and energy security imperative. Romania needs energy policy based on a long term overall Energy Strategy and the RBSTA welcomes the efforts of the Romanian Government in this regard. However, the documents presented for public debate so far include relatively little detail showing how Romania intends to implement the necessary changes.
It is our opinion that any country’s Energy Strategy should address three equally important objectives regarding energy supplies:
- Security of Supply – Ensuring a reliable and diverse energy supply. This is different from energy independence and is heavily dependent on cross-border trade. In this respect, we believe all the plans from Transgaz’ network development plan should be captured in the final draft strategy.
- Affordability – Ensuring consumers have access to energy at competitive prices. In addition to Security of Supply, affordability is also dependent on cross-border trade, allowing the market to access the most economically attractive energy supplies. This is a particularly pertinent issue given the amount of investment Romania needs to attract in order to efficiently and effectively modernize its energy infrastructure. In parallel to this, there is the need for a well-structured plan for the welfare of vulnerable consumers and the end of subsidizing energy prices for the whole population. This policy limits the ability to attract energy investors and new market participants.
- Sustainability – Encouraging lower carbon energy production. In our opinion, the use of energy generation technologies based on cleaner and highly efficient fuels such as natural gas can make a significant contribution to lowering greenhouse gases emissions associated with the energy production industry. However, it is imperative that all energy sources be able to compete on equal terms.
Moreover, a country’s energy strategy needs to recognize and cater for a range of demand projections. It is important that Romania’s energy policy addresses both supply and demand. Energy efficiency is an important first option when looking at the most effective ways to lower energy costs, but any policy should also have as its objective safeguarding a secure and sustainable energy supply, in addition to employing diversified and affordable energy resources.
The challenge is – on one hand – finding the most appropriate combination of measures to optimize consumption through increased efficiency, and – on the other hand – energy generation through a mix of efficiently used resources and technologies which are available to the country. We believe the most effective energy policies are transparent, predictable, based on cost/benefit analysis, and allow market prices and open competition to determine the solutions and investments necessary to achieve societal goals at the lowest cost. The power generation mix necessary to balance an internationally competitive and environmentally sound economy should be based on a diverse range of fuels to accommodate the benefits and limitations of each. Good policy requires disclosure of full and transparent costs.
The result of the energy strategy project will hopefully lead to the design of the most appropriate mix of energy resources and technologies for Romania, taking into account the totality of available and potentially available energy resources for the country and the relative environmental impacts of these different energy sources, including fossil fuels, nuclear and renewable. It is important to remember that the energy we use today is the product of investment decisions and technical work undertaken decades ago, and the energy we use in the future will be the product of decisions that we make today. Energy policy development should reflect long term thinking and involve all participants in the energy chain. Romania has an ambitious energy agenda and needs large investment projects, so it is good to see the involvement of suppliers, transporters and government agencies in the ongoing policy development process.
Diversity of supply is important too and this will be encouraged by an attractive investment climate with stable policies, particularly fiscal and regulatory policies that help energy companies think long-term about new investment opportunities that can help fuel economic growth. Diversity also means geographic diversity and we believe that governments are best served when they encourage open international trade and free markets, so that energy can flow easily to where it is needed and competition keeps prices affordable.
It is important to remember that the energy we use today is the product of investment decisions and technical work undertaken decades ago, and the energy we use in the future will be the product of decisions that we make today.
In case of development, offshore Black Sea production is expected to play a strategic role in Romania’s future energy mix. Can you summarize success factors for developing new hydrocarbons resources offshore Romanian Black Sea?
Our association believes in Romania’s energy potential, including the country’s potential to become a regional energy supplier. And, the RBSTA is committed to the Black Sea’s success in terms of developing Romania’s energy resources. However, successfully unlocking the Romanian sector of the Black Sea’s energy resources requires world scale investments and use of world leading technologies. As I’ve already mentioned it is important to understand offshore projects are complex and are characterized by a number of specific challenges, including:
- Long term investment cycle is something specific to the offshore industry. The exploration phase for offshore operations in the Black Sea may last for ten years or more, representing the time required for seismic acquisition, drilling, evaluation and assessment. All these activities are required prior to determining the best economic development scenario and the investors take on all risks and costs. If commercial, the development phase requires considerable time for the design and construction of infrastructure and production facilities.
- Exploration uncertainty is a key element which people tend to ignore. As you know there is no decision yet for the commercial development of any new offshore project. The Domino 1 well drilled by ExxonMobil and OMV Petrom is the first gas discovery in the deepwater Black Sea.
- The Black Sea environment is associated with specific technical challenges such as an increased corrosion risk due to the anoxic nature of deep waters, or the challenge related to its seabed topography. Moreover, the transit through the Bosphorus and Dardanelles Straits results in additional costs to transport specialized equipment.
- There is no existing upstream infrastructure in the Black Sea. As I mentioned earlier, in the event of confirmation of commercial volumes, ongoing projects will not benefit from existing pipelines and, on the contrary, will incur added costs to build infrastructure needed to bring production onshore Romania.
For a successful development, all the above aspects should be recognized and appropriately reflected in the Romanian legislative framework.
In our opinion, the size of investments and the length of time before any return on those investments, the geologically and technically challenging circumstances and the uncertainties involved justify specific considerations for the offshore part of the upstream business so the competitiveness of the system and a balanced government take are maintained. Investors will only make such massive, long-term investments if the fiscal and regulatory regime is appropriate, stable, and clear and if the opportunity is competitive relative to other opportunities available to such investors elsewhere around the world.
Appropriate legislation therefore needs to be confirmed in order to facilitate the development of a successful Romanian offshore oil and gas industry. Thus, we strongly believe that the fiscal terms for offshore licenses (i.e. those in effect on the date a license is granted) need to remain unchanged as they are consistent with the subsurface geological uncertainties and technical challenges in place at the time of the initial investment decision.
It is evident that exploration drilling is vulnerable to fiscal changes. Examples from around the world show that increases in tax rates on offshore producers can have an immediate impact on the amounts invested in exploration drilling. A relevant example for EU countries is the “Decommissioning Relief Deed” system in the UK where tax relief relating to decommissioning expenditure is guaranteed by the State. The relief is secured via a contract between the Government and the companies. The system was established in order to increase certainty for companies making oil and gas investments on the UK continental shelf.
Exploration capital is very mobile and so can be quickly moved to other parts of the world. Without fiscal stability, the Government’s intention to encourage future offshore investments would be directly and adversely impacted by the introduction of additional risk of increased taxation.
Still, we have seen some announcements saying that results of the exploratory drilling campaign in the Black Sea are encouraging. Based on data collected so far, what are the estimated potential hydrocarbon reserves in Romania’s Black Sea offshore?
As said, the Romanian part of the Black Sea is a promising, yet challenging, area in terms of its potential energy resources. There is a range of offshore projects in Romania, however, most are still in the exploration phase, and, while some discoveries have been made, none has been declared commercial since the early 1980s.
For the shallow waters (< 100m water depth), the discovered resources are characterized as being relatively small. Despite the challenges of economically developing these fields, all the issues outlined above make Black Sea offshore operations substantially higher cost and pose significant technological and operational challenges.
For the deep waters, while exploration activities to date have shown that gas is present, no commercially viable hydrocarbon reserves have been confirmed yet. Deep waters operations involve the use of sophisticated techniques and processes being used for the first time in Romania. Titleholders need additional time to assess data collected so far.
RBSTA members remain encouraged by the various discoveries made so far; however, additional time is needed to acquire and interpret existing data, (both technical and economic) in order to confirm the size of the resources and project commerciality and to be able to proceed to the development phase.
Offshore investments require a stable regulatory and fiscal environment. Stability clauses in existent petroleum agreements must be properly considered and respected.
However, investments in the campaign of exploration of the Black Sea resources have reached impressive figures, not to mention the amounts necessary for exploitation and the extensive range of assumed risks. How are all of these justified?
Offshore exploration is a high-risk business and certainly carries no guarantee of success. Still, in our industry, uncertainties and risk are inseparable from performance and, rather than being desirable or undesirable, are simply something we must manage. Taking investment risks is a necessary step to meet people’s needs for reliable, affordable energy. However, understanding risks in their different forms is one of the most important parts of a successful development model for new offshore energy fields.
To date, the Romanian Black Sea has attracted significant investments of over two billion US dollars in exploration activities. While these are impressive figures, all the work done so far was absolutely required to better understand the geology. The Black Sea, especially the deepwater area is a virtually unexplored basin with only a handful of wells drilled to date and limited discoveries. Romania only confirmed first deepwater gas discoveries in 2012. Due to the nature of the complex geology several successful exploration wells were needed in order to best assess and determine commerciality. Therefore, full exploration programs require years for drilling, evaluation and assessment prior to determining the best economic development scenario. For RBSTA’s members this is a significant financial investment at considerable risk.
We believe that the Romanian sector of the Black Sea is a promising, yet challenging, area in terms of its potential energy resources. If developed with care, it is expected to play a strategic role in Romania’s future energy resources. In addition, the successful commercial development of these resources would create significant new fiscal revenues for the Romanian state and would have multiplier effects for Romania’s economy, placing Romania at the forefront of developments of such projects in the entire Black Sea area.
What can go wrong with Romania’s offshore potential?
Romania is in a unique situation, well positioned to attract required investments in the oil and gas sector in Romania. There is a visible increase of participation in the upstream sector with both domestic and foreign companies working together. State-owned companies have visible improvements and positive financial results. I think we can say that in recent years we have seen an increase in confidence that there are funds available to make needed infrastructure investments in the Romanian offshore energy sector.
All these factors should support Romania’s great potential for increasing diversity of supply. However, there are two major areas of concern that could adversely impact this potential for the country. Firstly, any revision of agreed contractual terms could jeopardize this positive outcome, and secondly the Authorities need to proactively make the necessary regulatory improvements to allow for the development of offshore resources. While investors are assuming geological uncertainties, deploying state-of-the-art technology, offshore project management and execution, progressing with exploration and evaluation activities, financial and investment capabilities – there is little tolerance for regulatory risks and any obstacle in this respect could lead to little to no investments in upstream production. In the medium to long term such an outcome would be detrimental to the country’s economy.
To be successful, government and industry must work together to find effective ways to expand supplies while increasing energy efficiency and reducing environmental impact. Industry needs to innovate, to operate safely while protecting the environment; to invest with a long term, disciplined focus and be satisfied with nothing less than excellence in its operations. Governments need to make investment attractive by encouraging profitable opportunities, supporting open, competitive markets and above all providing a stable environment in which long-term investment decisions can be made with confidence.
