Every Dollar to the Bay

IHow to count the money

Study VI asked what a pound of nitrogen costs. This one asks where the money comes from, who decides who gets it, and who is holding the contract when it is spent. The first thing to establish is that there is no single number, and that most public argument about Bay funding is conducted by people using different ones.

Four figures circulate for federal fiscal year 2024, and they measure four different things. The EPA Chesapeake Bay Program line — the number in every press release and every advocacy alert — was $92 million. All EPA spending in the watershed, which adds the Bay-attributed shares of the Clean Water State Revolving Fund and the section 319 and 106 grant programmes, was $182.75 million. Every federal agency together, on regular appropriations, was $591.05 million. Add the infrastructure law and the federal total was $838.85 million. Against roughly $1.45 billion of state spending, the federal share of the ~$2 billion total is about 29 percent.

There is a second counting trap, and it has produced published claims of a funding collapse that never happened. The Chesapeake Bay Crosscut Report — the OMB-prepared inventory of federal spending mandated by the Chesapeake Bay Accountability and Recovery Act — is issued in editions, and in every edition the final column is the President's budget request, not an enacted or actual level. Chain the last columns of successive editions and FY2020 EPA appears as $71 million; take the same year from the later edition and it is $229 million. Every figure in this study is taken from the latest edition that reports the year.

IIThe federal machine

Six agencies do essentially all of it. USDA overtook EPA as the largest federal funder in 2023 and pulled well ahead in 2024, at $266 million against $183 million. Defense spending is real but lumpy — installations and their own stormwater obligations. The Army Corps line is the one to watch: it fell 71 percent between 2023 and 2024, from $44.1 million to $14.8 million, which is the funding cliff behind the region's oyster-reef construction programme, itself a roughly $115 million federal build across ten tributaries in Maryland and Virginia.

IIIHow EPA splits its own money

Of the $92 million, about two-thirds leaves the building. In FY2024: $42.4 million in non-competitive implementation grants to the seven signatory jurisdictions under section 117(e) of the Clean Water Act; $9.1 million in Small Watershed Grants and $8.7 million in Innovative Nutrient and Sediment Reduction grants, both administered by the National Fish and Wildlife Foundation; $8.0 million directed to "Most Effective Basins." The remaining $29.6 million runs the Program Office — the model, the monitoring network, the partnership machinery that produces the numbers Study VI is built on.

The allocation rule inside the largest bucket is the single most consequential structural fact in federal Bay funding, and it is published. Under EPA's 2025 grant guidance, 75 percent of implementation money is distributed by a fixed base: 20 percent each to Maryland, Pennsylvania and Virginia, 10 percent each to Delaware, New York, West Virginia and the District. Only the remaining 25 percent is weighted by water-quality performance, and even that carries an approximate 3 percent floor. Every grant requires a one-to-one non-federal match.

Three-quarters of the money is allocated by a split that does not move when the pollution does.

EPA does run one genuinely performance-allocated pot, and its history is instructive. The "Most Effective Basins" analysis scored state-river segments on how efficiently a pound removed there reaches tidal water and improves oxygen where it matters. The result put 24 of the top 29 basins in Pennsylvania. The first allocation, in 2020, followed the science: Pennsylvania took 61.6 percent. By the 2022 infrastructure-law round, a 40 percent set-aside for overburdened communities had been layered on, and Pennsylvania's share fell to 37 percent. Both objectives are defensible. The point is that the region has one instrument capable of directing money at cost-effectiveness, and it has been used at full strength once.

IVThe flat line and the volatile money

Congress has protected the Bay Program line through two hostile budget cycles. It appropriated $93 million for FY2026 against a $92 million request, and the FY2027 request trims the line only 1.3 percent inside a proposed 52 percent cut to EPA overall — while zeroing San Francisco Bay entirely. Measured by the headline, Bay funding is the most stable environmental appropriation in the country.

Measured by what actually pays for construction, it is not stable at all. The Bay-attributed share of the Clean Water State Revolving Fund — the money that built the treatment plants — ran at $88.7 million in FY2022, $62.6 million in FY2024, and zero in the FY2025 request. The Army Corps line fell by three-quarters in a year. Infrastructure money fell from $298 million to $49 million. And the FY2027 request would cut the national revolving fund by about 90 percent, to $155 million, on an explicit rationale of "aligning the responsibility of infrastructure funding to the states."

VThree state machines

The states put up about $1.45 billion of the $2 billion, and they raise and spend it in three fundamentally different ways. Maryland taxes ratepayers directly and bonds against the proceeds. Virginia funds from general-fund surplus under a statutory sharing rule and pays it out as reimbursement. Pennsylvania has no dedicated Bay revenue and runs on a landfill tipping fee, a one-time federal windfall, and federal pass-through.

Maryland: the dedicated fee

The Bay Restoration Fund — the flush tax — charges $5 a month per household on sewer and $60 a year per septic system, and has collected $2.19 billion since 2004. It is the clearest example in the country of hypothecated environmental revenue: the money arrives automatically, the State bonds against it, and the bonds built the enhanced nutrient removal upgrades that Study VI shows delivered two-thirds of all Bay nitrogen reductions. Sixty-six of 67 major plants are now upgraded. The fund's statutory authority changes on 1 July 2030, and its final bond payment falls in the same year.

Virginia: reimbursement out of surplus

Virginia's Water Quality Improvement Fund is fed by a statutory share of good years: 10 percent of general fund revenue above the official estimate, plus 10 percent of any uncommitted year-end balance. There is no fixed split between point and nonpoint accounts; the Appropriation Act sets it annually. Since the 2021 Enhanced Nutrient Removal Certainty law, the fund has functioned less like a grant programme and more like a debt-service obligation: the 2026 session capped reimbursement to the Hampton Roads Sanitation District at $190 million a year from FY2026 through FY2031, with any unpaid amount deferred — an entitlement of up to $1.14 billion to a single utility.

Alongside that, Virginia runs the largest agricultural cost-share programme in the watershed: $223 million in FY2026 and a record $304 million in FY2027, allocated to 47 soil and water conservation districts by a published formula — 70 percent to the Bay watershed by statute, and within each basin 50 percent of the money to hydrologic units ranked high for nutrient and sediment load, 30 percent to medium, 20 percent to low, with a $300,000 cap per applicant. Its urban equivalent is $2 million.

Pennsylvania: the state that publishes its own shortfall

Pennsylvania holds the largest nitrogen obligation in the watershed and the least money. Its Department of Environmental Protection states on a public webpage that the investment needed is about $521 million a year against roughly $197 million available — a $324 million annual gap. It is the only Bay jurisdiction that publishes that arithmetic about itself.

What it does have is a recurring $50 million Clean Streams Fund, 71.5 percent of which goes to the Agricultural Conservation Assistance Program and is allocated to all 67 counties by a formula of farms, livestock operations and impaired stream miles — then awarded to individual farmers by county conservation districts. That is the most decentralised award structure of the three states: 67 separate local processes. Its origin was one-time: $220 million of federal pandemic relief, of which $154 million went to the programme, with a hard requirement to commit by the end of 2024 and spend by the end of 2026.

VIHow a dollar becomes a project

The chain from an appropriation to a crew on a stream bank has a fixed number of links, each of which takes a share and imposes a rule.

1. Congress appropriates. The Bay Program line, or a Farm Bill programme, or a capitalisation grant for the state revolving fund.
2. EPA awards a grant to the jurisdiction under CWA §117(e), with a one-to-one non-federal match — every federal dollar must be met by a state or local dollar before it can be spent.
3. The state passes it through. Sub-awards are governed by 2 CFR 200: the pass-through must supply a defined data set, assess each subrecipient's fraud and compliance risk, and monitor performance. A recipient without a negotiated indirect rate may charge up to a 15 percent de minimis rate; state programmes often cap administration at 10 percent of the award.
4. The local government, nonprofit or farmer receives it — as a competitive grant, a formula cost-share, or a loan.
5. A design consultant is procured, typically under a professional-services or on-call contract.
6. A construction contractor is procured, under design-bid-build, design-build, or a full-delivery contract that bundles the two and pays on results.
7. Subcontractors do most of the work, subject to participation goals: Maryland's statewide minority business enterprise goal is 29 percent; Baltimore County sets an overall 15 percent MBE/WBE goal; the District requires 35 percent subcontracting to small business enterprises on contracts over $250,000.

A note on who wins competitive grants, because it shapes the whole nonprofit economy of the region. The February 2026 NFWF round awarded $44.2 million across 72 grants — a mean of about $614,000 — leveraging $31 million of match. Small Watershed Grants run $150,000 to $750,000 for implementation and up to $150,000 for planning; the innovative-reduction grants go up to $1 million. Match is "encouraged, but not required," and volunteer hours count. Eligible applicants include businesses, but the winners are overwhelmingly land trusts, watershed associations, conservancies and universities. That is the pipeline through which a very large share of the region's on-the-ground restoration is actually commissioned.

VIIBuying the outcome

Four programmes in the region have stopped buying assets and started buying results. They are small, they are the most interesting thing happening in Bay finance, and their prices are wildly inconsistent.

Maryland's Clean Water Commerce Act transfers $20 million a year out of the flush tax to buy verified reductions. The statute permits purchase only of outcomes with an expected life of at least ten years, and sets sector minimums — at least 35 percent agriculture, at least 20 percent in environmental-justice communities, at least 10 percent non-agricultural landscape restoration. Bids are scored out of 100: 60 points for cost-effectiveness, 40 for co-benefits, with the cost points awarded by rank rather than absolute price — lowest price takes 60, second 45, third 30, fourth 15, everyone else zero. Contracts run up to 20 years. The FY2024–25 round drew 22 applications requesting $77 million against roughly $47 million available.

Pennsylvania's Clean Water Procurement Program, created by Act 54 of 2022, scores 60 points technical and 40 cost, requires a DEP-approved verification plan before bidding, and has run three rounds of descending size: $14.8 million, $7.1 million, $4.2 million.

Virginia put $20 million into a one-year pay-for-outcomes pilot in the 2024 budget, paying farmers on pounds actually removed. Anne Arundel County runs the model at county scale: private firms find the site, front the construction cost, and are reimbursed only after the county verifies the credits, with maintenance payments released annually for five years and bids ranked on cost per equivalent impervious acre.

And DC Water's Environmental Impact Bond — $25 million, placed privately with Goldman Sachs and Calvert Impact Capital — is the purest risk-transfer instrument the sector has tried: if green infrastructure on 365 acres reduced runoff by less than 18.6 percent, investors would pay the utility $3.3 million; above 41.3 percent, the utility would pay investors $3.3 million. Performance landed at about 20 percent, inside the band. No payment moved in either direction. The much-praised risk transfer was never actually tested.

VIIIThe credit markets

Underneath the government purchases sits a set of private markets in which a permittee buys compliance from someone else. Each jurisdiction runs its own, with its own discount factors, and none of them publishes a market price.

The discounts are the substance. Pennsylvania withholds a 10 percent reserve and applies a 3:1 uncertainty ratio to nonpoint credits — three pounds reduced for one pound sold. Maryland withholds 5 percent and applies 2:1 for nonpoint-to-wastewater trades, with verification at least every three years and a public registry giving every credit a registration number. Virginia applies 2:1, reducible with direct measurement or permanent land protection. Delaware, New York and West Virginia have no comparable programme at all.

The volumes tell you how thin these markets are. Maryland had certified nine trades between 2018 and 2021. Pennsylvania's own auction programme ran from 2010 to 2018 and was discontinued for lack of use. Virginia's exchange — 70-odd owners of about 105 treatment facilities — reports full compliance every year, but EPA's case study notes the structural weakness: when supply far exceeds demand, prices collapse and members trade bilaterally outside the exchange.

The District runs the region's most transparent market by refusing to set a price and instead publishing both bounds. A Stormwater Retention Credit is one gallon of retention for one year. The ceiling is the in-lieu fee a developer may pay instead — $5.01 per gallon-year from August 2026, inflation-adjusted annually, set at the District's own cost of delivering that gallon. The floor is the Price Lock programme, which guarantees $2.03 for non-tidal and $1.77 for tidal credits in years one to six, dropping to $0.42 thereafter, backed by about $1.25 million a year. Between those bounds, more than 1.7 million credits have sold from 26 distinct sellers.

IXThe private vertical

Now the question that prompted this study: how a private, for-profit company buys or generates credits, becomes the prime contractor, and awards the work.

The full-delivery contract

The mechanism is simple and, on its face, excellent public policy. Instead of the county designing a project, bidding it, and hoping it performs, the county publishes a price it will pay for a verified outcome. A private firm finds the site, negotiates with the landowner, designs and builds the project with its own money, and is paid only when the county verifies the credits — with a portion held back over five years of maintenance. Anne Arundel County has run this since 2018, with awards from $363,000 to $3 million, ranked on cost per equivalent impervious acre. Its awardees have included BayLand Consultants & Designers, Underwood & Associates, Wildlands Engineering, Restoration Systems, and Resource Environmental Solutions.

The risk transfer is real, and so is the barrier to entry. Virginia's equivalent programme requires payment and performance bonds equal to the full cost of implementing the design, from a surety rated A− or better, and requires the contractor to find a third party willing to hold perpetual stewardship. That is a balance-sheet test, and it systematically favours private-equity-backed national firms over the local specialists who invented the techniques.

The programme manager

Prince George's County went further and hired a manager for the whole programme. Corvias — a firm whose original business was privatised military housing — holds a three-year master programme agreement and a thirty-year maintenance agreement. It does not build: CH2M Hill Constructors was the general contractor, Bowman Consulting and CH2M Hill the design engineers, Stormwater Maintenance LLC the maintenance prime, and Maryland Environmental Service the independent certifier. Corvias earns $1 million on execution, design fees at 30/60/90/100 percent milestones, a base fee calculated as a percentage of all project costs, a 5 percent base fee on annual operations and maintenance, and incentive fees of up to another 5 percent.

What it is scored on is unusual and worth reproducing exactly: 35 percent on impervious acres credited, 15 percent on schedule, 15 percent on the mentor–protégé programme, 10 percent on county-resident workforce, and 10 percent on local, small, minority and women-owned business participation. Hit 75 percent of the metrics and the second 2,000-acre tranche follows. The programme reports 428 sites, 4,658 completed credit acres, $329.6 million expended, and $257.2 million — 78 percent — to local and minority businesses.

The bankers who are also the builders

The firms that dominate this market are vertically integrated by design, and several say so in their own marketing. Resource Environmental Solutions — backed by KKR since 2017 and Onex since 2022 — calls itself the country's largest ecological restoration company and sells "full delivery, long-term stewardship, and guaranteed performance." It entered Maryland by acquiring Environmental Banc & Exchange in 2014 and the Virginia–Maryland builder Angler Environmental in 2016, and lists work for the State Highway Administration and six Maryland counties. Ecosystem Investment Partners has raised nearly $1.5 billion across five institutional funds, the latest closing at over $400 million in October 2025, and describes its Cecil County work for Maryland DNR and SHA as a pay-for-performance package covering "land acquisition, restoration design, permitting, construction, financial assurances, monitoring and maintenance." Wildlands Engineering owns and operates more than 60 mitigation banks and reports over $200 million in turnkey and full-delivery contracts. Ecotone, of Forest Hill, Maryland, advertises mitigation credit inventory and design-build services in the same brochure — the model in its purest published form: bank the credit, design it, build it, monitor it.

Two facts about this market's governance deserve to sit next to each other. The founder of Wetland Studies and Solutions, one of the region's largest wetland consultancies and mitigation bankers, was appointed Director of the Virginia Department of Environmental Quality — the agency that certifies nutrient credits and co-administers the state's in-lieu fee. And a Maryland restoration contractor formally lobbied the General Assembly for a statutory definition of "ecological restoration" and a separate, faster permitting track for the projects it sells.

Pennsylvania's outcome purchase, and who won it

Which brings us to the finding that changes how the region's flagship pay-for-results programme should be read. Across three rounds, Pennsylvania's Clean Water Procurement Program has awarded roughly $28 million. One bidder, named in every announcement only as "HGS, LLC," took $22.6 million of it — 81 percent. The other named awardees were an engineering firm, a land trust and a conservancy.

HGS, LLC is not an unknown local operator. Florida's engineering business registry lists "HGS, LLC" as the primary licensee name with the trade name "RES Environmental Operating Company," at 6675 E Pine Street, Bellaire, Texas — the corporate address of Resource Environmental Solutions. A federal contracting database indexes the same vendor as "HGS LLC (Angler Environmental, a RES company)." We could not locate a Pennsylvania fictitious-name filing making the link on the Commonwealth's own records, so we present the identification with its evidence rather than as a settled corporate fact; but on the face of the public licensing record, the great majority of Pennsylvania's pay-for-results money has gone to the Chesapeake arm of a KKR- and Onex-backed national firm, under a name that does not obviously connect to it.

A programme designed to discover the cheapest pound in Pennsylvania has, so far, mostly discovered one company.

Where the safeguards are thin

None of this is unlawful, and most of it is the predictable result of asking private capital to carry construction and performance risk. But four weaknesses are documented in the public record and should be named.

First, verification sits close to the seller. In the full-delivery model the county verifies, which is sound. In credit generation the seller produces the verified reductions under an approved plan. Where a single firm banks, designs, builds and monitors, the only independent check is a state certification that, in Maryland's case, has been applied to nine trades since 2018.

Second, financial assurance is rarely tested. Bonds, letters of credit and escrow are required and are held by a party acceptable to the Corps rather than by the Corps, and are phased out as milestones are met. EPA's own fact sheet notes that few claims have ever been made on them.

Third, long-term liability is designed to be handed off. Virginia's in-lieu fund explicitly declines to hold the easement or act as long-term steward; the contractor must find someone who will, in perpetuity.

Fourth, the product itself is contested. The Bay Program's own science committee found in 2024 that significant biological uplift from stream restoration is rare. Testimony filed with the Maryland General Assembly lists failed restorations by name, including one requiring $3.6 million in repairs. The Center for Progressive Reform argues Maryland's trading rules award credits for reductions taxpayers already bought through the flush tax. None of that is an argument against paying for outcomes; it is an argument for measuring them.

XThe calendar and the money

Two views of the same thing. The first is the schedule: when each fund, permit, authorisation and deadline starts and stops. The second is the same calendar with the dollars attached, so that the cliffs are visible.

XIWhat comes next

Three things can be said about future spending with reasonable confidence, and one cannot.

The federal headline will hold and the federal substance will shrink. The America's Conservation Enhancement Reauthorization Act authorises $92 million a year for the Bay Program through FY2030, and Congress has appropriated at or above that in each of the last two cycles against hostile requests. But the FY2027 request would cut the Clean Water State Revolving Fund by roughly 90 percent on an explicit federalism rationale. If that survives even partially, the states lose the cheapest construction capital they have, and the loss will not appear in any "Chesapeake Bay funding" headline.

State money is committed years out, and unevenly. Virginia has forward-committed up to $1.14 billion to one utility through 2031 and put agricultural cost-share at a record $304 million. Maryland has $790 million programmed for highway stormwater across FY2026–31 and a Trust Fund whose balance falls to $11 million. Pennsylvania has $50 million a year against a $324 million gap. Nobody has published a cost to reach the 2040 targets.

The private vertical will consolidate. Bonding requirements, perpetual stewardship obligations and multi-decade maintenance agreements are balance-sheet tests. They are met most easily by firms with institutional capital behind them, which is why a Texas company with private-equity ownership won 81 percent of Pennsylvania's outcome money and appears on Anne Arundel's bidder list, in Prince George's as a subcontractor, and on Maryland SHA's rolls. If the region wants a competitive market of local specialists, it will have to design for one deliberately — through smaller lots, shared surety facilities, or the mentor–protégé structures Prince George's already scores its partner on.

What cannot be said is what any of it buys. No jurisdiction has published a cost to reach the 2040 targets, and the one instrument that prices outcomes directly returns numbers a hundredfold apart for the same pollutant in the same programme.

XIIWhat we would do

1. Publish one number, four ways, every year. The region cannot argue about funding while four defensible totals are in circulation. Whoever publishes the Crosscut should publish a single reconciliation table — programme line, all-agency appropriation, capital finance, and infrastructure money — and label every column enacted, actual or requested.
2. Move the formula. Seventy-five percent of EPA's implementation grant is allocated on a split unchanged by evidence. EPA's own Most Effective Basins work shows it knows how to target. Shifting the base-to-performance ratio from 75/25 toward 50/50 over three cycles would redirect roughly $10 million a year toward the basins that hold the remaining load, without a new appropriation.
3. Defend the revolving fund, not just the line item. The advocacy energy spent protecting a $93 million appropriation should be spent at least equally on the state revolving fund, which delivered more Bay construction than the Bay Program ever has and is the actual target of the FY2027 request.
4. Buy outcomes, but publish the unit price every time. Maryland, Pennsylvania and Virginia should each publish, for every outcome contract: dollars, pounds, contract years, dollars per pound-year, and the verification method. Today a reader cannot tell whether a $8.4 million purchase is a bargain or ten times the going rate, because the pounds and the term are reported inconsistently.
5. Disclose beneficial ownership in outcome procurements. A state buying results from "HGS, LLC" should say on the award notice who that is. This costs nothing, is standard in other procurement regimes, and would let the public see concentration as it happens rather than two years later.
6. Separate the seller from the verifier, in writing. Where a firm banks, builds and monitors, require independent third-party verification paid for by the buyer, not the seller — the model Prince George's already uses with an independent completion certifier.
7. Design for a local market. Bonding and perpetual-stewardship requirements are sound risk management and a structural barrier to the regional specialists who invented these techniques. Smaller contract lots, a shared surety facility, and stewardship held by a public land trust would keep more of the money in the watershed that generates it.

A note on our interest, as in Study VI. This firm's principal works in the stormwater and landscape construction trade in the Maryland–Virginia–District market, which is to say inside the last link of the chain this study describes. We have written the numbers as the sources give them, including the ones that are uncomfortable for the trade.

XIIIWhat we could not verify

Sought and either not found in a primary source, found only in secondary coverage, or found in a form we could not read. None is used as a load-bearing figure.

• A Pennsylvania corporate filing linking HGS, LLC to RES. The identification rests on Florida's engineering business registry (licence 35185, primary name HGS, LLC, trade name RES Environmental Operating Company, at RES's Bellaire, Texas address) and a federal contracting index. We did not confirm whether PENNVEST's evaluators knew, and we make no claim that anything improper occurred.
• The Crosscut's Forest Service line, which does not reconcile with its own USDA subtotal; and per-state NRCS obligation totals for the watershed portions of Maryland, Virginia and Pennsylvania.
• Why FY2024 implementation grants to the District and West Virginia appear at about $0.09 million each when the published formula implies roughly $4.2 million; and the current status and dollar value of the Chesapeake Bay Regulatory and Accountability Program, which appears on Bay Program pages but not in the 2025 grant guidance.
• The reconciliation of EPA's FY2025 Bay Program actuals ($86.9 million) with the appropriated level (about $92 million).
• The composition of the FY2022 infrastructure tranche, whose published categories sum to $47.8 million against a $40 million headline.
• The disposition of Inflation Reduction Act conservation money in the watershed after 2025; the relevant Congressional Research Service products are blocked to automated retrieval.
• Corvias's base fee percentage on construction and programme costs — only the 5 percent operations-and-maintenance base fee and up to 5 percent incentive are disclosed — and any genuinely independent audit of the partnership. The most cited evaluation is a Harvard Extension School capstone announced through the partnership's own press channel.
• Whether Anne Arundel's $8,662 per impervious acre and Prince George's $70,760 are computed on comparable bases; the gap is an order of magnitude and neither county publishes a reconciliation.
• Actual proposal counts, as opposed to registered plan holders, on county full-delivery solicitations; contractor margins on full-delivery work, which appear nowhere in the public record.
• Private mitigation bank credit prices anywhere in Maryland, Virginia or Pennsylvania; the commercial price series is paywalled. Pennsylvania publishes credit volumes and parties by design but no prices at all.
• Virginia's Water Quality Improvement Fund year-by-year deposit history and point/nonpoint split; the statewide total cost of its Enhanced Nutrient Removal Certainty programme; the Stormwater Local Assistance Fund's cumulative awards; and the Virginia Clean Water Revolving Loan Fund's annual capitalisation and terms.
• Pennsylvania's per-county ACAP allocation table and cost-share caps; the enacted rather than proposed Clean Streams Fund figure; and whether the $521M/$197M/$324M gap figures have been updated since the Phase III plan.
• Maryland's Trust Fund revenue rates in statute; the internal allocation rules of the Bay Restoration Fund's wastewater account; county-by-county stormwater fee revenue; and the Clean Water Commerce Act's maximum price per pound, if any.
• Army Corps oyster-restoration cost shares per tributary; Chesapeake Bay Trust and Alliance for the Chesapeake Bay pass-through amounts from the Bay Program.

XIVSources

Method. Figures are quoted as published and labelled enacted, actual, appropriated, allowance or requested wherever the source distinguishes them; dollar-years are not inflated to a common year. Where we computed a figure it is marked as ours in the exhibit note. Each exhibit's data is available as a CSV of the name given in its note. This study names private companies only where a primary public record supports the claim, and makes no allegation of wrongdoing by any firm or official mentioned. Higgins Strategy is registered and disclosed; one principal is in every meeting; we never take both sides of a matter.