Comments of the Virginia Retail Merchants Association ("VRMA")
On Aggregator Definition/Licensing Provisions

These proposed amendments are offered on behalf of the Virginia Retail Merchants Association ("VRMA") in response to the request of the Legislative Transition Task Force that interested Stakeholders submit proposed amendments to the Restructuring Act to the Division of Legislative Services by December 17, 1999. The VRMA has participated in numerous meetings with the State Corporation Commission’s ("Commission" or "SCC") Staff ("Staff"), the Office of Attorney General ("Attorney General" or "OAG"), and other Stakeholders to reconcile conflicting positions as to the identification and resolution of appropriate issues related to the Restructuring Act that was signed into law this year. While the Virginia Retail Merchants Association offers these amendments to preserve its ability to introduce legislation on these issues, the VRMA is committed to continuing its dialog with the Commission, the Attorney General, and other Stakeholders to narrow the differences that remain on these issues.

The VRMA Supports Changes To The Aggregator Definition/Licensing Provisions:

The VRMA continues to work with interested parties to address changes to the definition of "Aggregator" set forth in §56-576, and, if appropriate, to the licensing provisions for aggregators set forth in §56-588. The Virginia Retail Merchants Association offers its support at this time for the following changes to the definition of "Aggregator" found in §56-576. As indicated previously, the VRMA will continue its discussions with other interested parties on the appropriate resolution of these and other issues.

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