EMPLOYEE BENEFIT PLANS

We measure the assets and obligations of the defined benefit pension plans and other postretirement benefits plans to determine the plans’ funded status as of the end of the year as an asset or a liability on our consolidated balance sheets. We record as a component of other comprehensive income/loss or a regulatory asset the changes in funded status that occurred during the year that are not recognized as part of net periodic benefit costs.

Defined Benefit Pension Plans

We sponsor three defined benefit pension plans: the Chesapeake Pension Plan, the FPU Pension Plan and the Chesapeake SERP.

The Chesapeake Pension Plan was closed to new participants effective January 1, 1999, and was frozen with respect to additional years of service and additional compensation effective January 1, 2005. Benefits under the Chesapeake Pension Plan were based on each participant’s years of service and highest average compensation, prior to the freezing of the plan.

The FPU Pension Plan covers eligible FPU non-union employees hired before January 1, 2005 and union employees hired before the respective union contract expiration dates in 2005 and 2006. Prior to the merger, the FPU Pension Plan was frozen with respect to additional years of service and additional compensation, effective December 31, 2009.

The Chesapeake SERP was frozen with respect to additional years of service and additional compensation as of December 31, 2004. Benefits under the Chesapeake SERP were based on each participant’s years of service and highest average compensation, prior to the freezing of the plan.

In January 2011, a former executive officer retired and received lump-sum pension distributions of $844,000 and $765,000 from the Chesapeake Pension Plan and Chesapeake SERP, respectively. In connection with these lump-sum payment distributions, we recorded $436,000 in pension settlement losses in addition to the net benefit cost in 2011. Based upon the current funding status of the Chesapeake Pension Plan, which does not meet or exceed 110 percent of the benefit obligation as required per the Department of Labor regulations, our former executive officer was required to deposit property equal to 125 percent of the restricted portion of his lump sum distribution into an escrow. Each year, an amount equal to the value of payments that would have been paid to him if he had elected the life annuity form of distribution will become unrestricted. Property equal to the life annuity amount will be returned to him from the escrow account. These same regulations will apply to the top 20 highest compensated employees taking distributions from the Pension Plan.

The following schedule sets forth the funded status at December 31, 2013 and 2012 and the net periodic cost for the years ended December 31, 2013, 2012 and 2011 for the Chesapeake and FPU Pension Plans:



	Chesapeake Pension Plan						FPU Pension Plan
At December 31,	2013			2012			2013			2012
(in thousands)
Change in benefit obligation:
Benefit obligation — beginning of year	$	11,933		$	11,672		$	64,512		$	57,999
Interest cost	405			458			2,367			2,577
Actuarial loss (gain)	(1,092		)	726			(8,007		)	6,915
Benefits paid	(978		)	(923		)	(2,996		)	(2,979		)
Benefit obligation — end of year	10,268			11,933			55,876			64,512
Change in plan assets:
Fair value of plan assets — beginning of year	8,430			7,162			41,954			37,836
Actual return on plan assets	967			849			4,747			4,526
Employer contributions	324			1,342			632			2,571
Benefits paid	(978		)	(923		)	(2,996		)	(2,979		)
Fair value of plan assets — end of year	8,743			8,430			44,337			41,954
Reconciliation:
Funded status	(1,525		)	(3,503		)	(11,539		)	(22,558		)
Accrued pension cost	$	(1,525	)	$	(3,503	)	$	(11,539	)	$	(22,558	)
Assumptions:
Discount rate	4.25		%	3.50		%	4.75		%	3.75		%
Expected return on plan assets	6.00		%	6.00		%	7.00		%	7.00		%



	Chesapeake Pension Plan									FPU Pension Plan
For the Years Ended December 31,	2013			2012			2011			2013			2012			2011
(in thousands)
Components of net periodic pension cost:
Interest cost	$	405		$	458		$	520		$	2,367		$	2,577		$	2,695
Expected return on assets	(486		)	(418		)	(424		)	(2,866		)	(2,627		)	(2,783		)
Amortization of prior service cost	(1		)	(5		)	(5		)	—			—			—
Amortization of actuarial loss	322			255			156			330			196			—
Net periodic pension cost	240			290			247			(169		)	146			(88		)
Settlement expense	—			—			217			—			—			—
Amortization of pre-merger regulatory asset	—			—			—			761			761			761
Total periodic cost	$	240		$	290		$	464		$	592		$	907		$	673
Assumptions:
Discount rate	3.50		%	4.25		%	5.00		%	3.75		%	4.50		%	5.25		%
Expected return on plan assets	6.00		%	6.00		%	6.00		%	7.00		%	7.00		%	7.00		%

Included in the net periodic costs for the FPU Pension Plan is continued amortization of the FPU pension regulatory asset, which represents the portion attributable to FPU's regulated operations of the changes in funded status that occurred but were not recognized as part of net periodic cost prior to the merger with Chesapeake in October 2009. This was previously deferred as a regulatory asset by FPU prior to the merger to be recovered through rates pursuant to an order by the Florida PSC. The unamortized balance of this regulatory asset was $4.3 million and $5.1 million at December 31, 2013 and 2012, respectively.

The following sets forth the funded status at December 31, 2013 and 2012 and the net periodic cost for the years ended December 31, 2013, 2012 and 2011 for the Chesapeake SERP:



At December 31,	2013			2012
(in thousands)
Change in benefit obligation:
Benefit obligation — beginning of year	$	2,352		$	2,160
Interest cost	81			90
Actuarial loss (gain)	(134		)	191
Benefits paid	(89		)	(89		)
Benefit obligation — end of year	2,210			2,352
Change in plan assets:
Fair value of plan assets — beginning of year
Employer contributions	89			89
Benefits paid	(89		)	(89		)
Fair value of plan assets — end of year	—			—
Reconciliation:
Funded status	(2,210		)	(2,352		)
Accrued pension cost	$	(2,210	)	$	(2,352	)
Assumptions:
Discount rate	4.25		%	3.50		%



For the Years Ended December 31,	2013			2012			2011
(in thousands)
Components of net periodic pension cost:
Interest cost	$	81		$	90		$	107
Amortization of prior service cost	19			19			19
Amortization of actuarial loss	64			46			38
Net periodic pension cost	164			155			164
Settlement expense	—			—			219
Total periodic cost	$	164		$	155		$	383
Assumptions:
Discount rate	3.50		%	4.25		%	5.00		%

Our funding policy provides that payments to the trustee of each qualified plan shall be equal to at least the minimum funding requirements of the Employee Retirement Income Security Act of 1974. The following schedule summarizes the assets of the Chesapeake Pension Plan and the FPU Pension Plan, by investment type, at December 31, 2013, 2012 and 2011:



	Chesapeake Pension Plan						FPU Pension Plan
At December 31,	2013		2012		2011		2013		2012		2011
Asset Category
Equity securities	54.40	%	52.07	%	51.75	%	55.02	%	52.81	%	51.98	%
Debt securities	36.54	%	38.00	%	37.88	%	36.54	%	38.04	%	38.05	%
Other	9.06	%	9.93	%	10.37	%	8.44	%	9.15	%	9.97	%
Total	100.00	%	100.00	%	100.00	%	100.00	%	100.00	%	100.00	%

The investment policy of both the Chesapeake and FPU Pension Plans is designed to provide the capital assets necessary to meet the financial obligations of the plans. The investment goals and objectives are to achieve investment returns that, together with contributions, will provide funds adequate to pay promised benefits to present and future beneficiaries of the plans, earn a long-term investment return in excess of the growth of the Plans’ retirement liabilities, minimize pension expense and cumulative contributions resulting from liability measurement and asset performance, and maintain a diversified portfolio to reduce the risk of large losses.

The following allocation range of asset classes is intended to produce a rate of return sufficient to meet the Plans’ goals and objectives:



Asset Allocation Strategy
Asset Class	Minimum Allocation Percentage		Maximum Allocation Percentage
Domestic Equities (Large Cap, Mid Cap and Small Cap)	14	%	32	%
Foreign Equities (Developed and Emerging Markets)	13	%	25	%
Fixed Income (Inflation Bond and Taxable Fixed)	26	%	40	%
Alternative Strategies (Long/Short Equity and Hedge Fund of Funds)	6	%	14	%
Diversifying Assets (High Yield Fixed Income, Commodities, and Real Estate)	7	%	19	%
Cash	0	%	5	%

Due to periodic contributions and different asset classes producing varying returns, the actual asset values may temporarily move outside of the intended ranges. The investments are monitored on a quarterly basis, at a minimum, for asset allocation and performance.

At December 31, 2013, the assets of the Chesapeake Pension Plan and the FPU Pension Plan were comprised of the following investments:



	Fair Value Measurement Hierarchy
Asset Category	Level 1		Level 2		Level 3		Total
(in thousands)
Equity securities
U.S. Large Cap ⁽¹⁾	$	3,964	$	4,118	$	—	$	8,082
U.S. Mid Cap ⁽¹⁾	—		3,412		—		3,412
U.S. Small Cap ⁽¹⁾	—		1,736		—		1,736
International ⁽²⁾	10,687		—		—		10,687
Alternative Strategies ⁽³⁾	5,235		—		—		5,235
	19,886		9,266		—		29,152
Debt securities
Inflation Protected ⁽⁴⁾	2,462		—		—		2,462
Fixed income ⁽⁵⁾	—		14,305		—		14,305
High Yield ⁽⁵⁾	—		2,629		—		2,629
	2,462		16,934		—		19,396
Other
Commodities ⁽⁶⁾	1,939		—		—		1,939
Real Estate ⁽⁷⁾	1,991		—		—		1,991
Guaranteed deposit ⁽⁸⁾	—		—		602		602
	3,930		—		602		4,532
Total Pension Plan Assets	$	26,278	$	26,200	$	602	$	53,080


⁽¹⁾	Includes funds that invest primarily in United States common stocks.


⁽²⁾	Includes funds that invest primarily in foreign equities and emerging markets equities.


⁽³⁾	Includes funds that actively invest in both equity and debt securities, funds that sell short securities and funds that provide long-term capital appreciation. The funds may invest in debt securities below investment grade.


⁽⁴⁾	Includes funds that invest primarily in inflation-indexed bonds issued by the U.S. government.


⁽⁵⁾	Includes funds that invest in investment grade and fixed income securities.


⁽⁶⁾	Includes funds that invest primarily in commodity-linked derivative instruments and fixed income securities.


⁽⁷⁾	Includes funds that invest primarily in real estate.


⁽⁸⁾	Includes investment in a group annuity product issued by an insurance company.

At December 31, 2012, the assets of the Chesapeake Pension Plan and the FPU Pension Plan were comprised of the following investments:



	Fair Value Measurement Hierarchy
Asset Category	Level 1		Level 2		Level 3		Total
(in thousands)
Equity securities
U.S. Large Cap ⁽¹⁾	$	3,504	$	3,443	$	—	$	6,947
U.S. Mid Cap ⁽¹⁾	—		3,078		—		3,078
U.S. Small Cap ⁽¹⁾	—		1,523		—		1,523
International ⁽²⁾	10,019		—		—		10,019
Alternative Strategies ⁽³⁾	4,978		—		—		4,978
	18,501		8,044		—		26,545
Debt securities
Inflation Protected ⁽⁴⁾	2,507		—		—		2,507
Fixed income ⁽⁵⁾	—		14,109		—		14,109
High Yield ⁽⁵⁾	—		2,547		—		2,547
	2,507		16,656		—		19,163
Other
Commodities ⁽⁶⁾	1,918		—		—		1,918
Real Estate ⁽⁷⁾	2,048		—		—		2,048
Guaranteed deposit ⁽⁸⁾	—		—		710		710
	3,966		—		710		4,676
Total Pension Plan Assets	$	24,974	$	24,700	$	710	$	50,384


⁽¹⁾	Includes funds that invest primarily in United States common stocks.


⁽²⁾	Includes funds that invest primarily in foreign equities and emerging markets equities.


⁽³⁾	Includes funds that actively invest in both equity and debt securities, funds that sell short securities and funds that provide long-term capital appreciation. The funds may invest in debt securities below investment grade.


⁽⁴⁾	Includes funds that invest primarily in inflation-indexed bonds issued by the U.S. government.


⁽⁵⁾	Includes funds that invest in investment grade and fixed income securities.


⁽⁶⁾	Includes funds that invest primarily in commodity-linked derivative instruments and fixed income securities.


⁽⁷⁾	Includes funds that invest primarily in real estate.


⁽⁸⁾	Includes investment in a group annuity product issued by an insurance company.

At December 31, 2013 and 2012, all of the investments classified under Level 1 of the fair value measurement hierarchy were recorded at fair value based on unadjusted quoted prices in active markets for identical investments. The Level 2 investments were recorded at fair value based on net asset value per unit of the investments, which used significant observable inputs although those investments were not traded publicly and did not have quoted market prices in active markets. The Level 3 investments were guaranteed deposit accounts, which were valued based on the liquidation value of those accounts, including the effect of the balance and interest guarantee and liquidation restriction.

The following table sets forth the summary of the changes in the fair value of Level 3 investments for the years ended December 31, 2013 and 2012:



	For the Year Ended December 31,
	2013			2012
(in thousands)
Balance, beginning of year	$	710		$	897
Purchases	618			79
Transfers in	3,175			3,620
Disbursements	(3,966		)	(3,902		)
Investment income	65			16
Balance, end of year	$	602		$	710

Other Postretirement Benefits Plans

We sponsor two defined benefit plans: the Chesapeake Postretirement Plan and the FPU Medical Plan. In March 2011, new plan provisions for the FPU Medical Plan were adopted in a continuing effort to standardize FPU’s benefits with those offered by Chesapeake. The new plan provisions, which became effective January 1, 2012, require eligible employees retiring in 2012 through 2014 to pay a portion of the total benefit costs based on the year they retire. Participants retiring in 2015 and after will be required to pay the full benefit costs associated with participation in the FPU Medical Plan. The change in the FPU Medical Plan resulted in a curtailment gain of $892,000. Since we determined that the non-recurring gain resulted from the FPU merger and the related integration, we determined that the appropriate accounting treatment for the portion of the gain allocated to FPU's regulated operations prescribed deferral as a regulatory liability and amortization over a future period, as specified by the Florida PSC. We recorded $170,000 of this curtailment gain which was allocated to FPU's unregulated operations in 2012. We deferred $722,000 of this curtailment gain and included it as a regulatory liability.

The following sets forth the funded status at December 31, 2013 and 2012 and the net periodic cost for the years ended December 31, 2013, 2012, and 2011:



	Chesapeake Postretirement Plan						FPU Medical Plan
At December 31,	2013			2012			2013			2012
(in thousands)
Change in benefit obligation:
Benefit obligation — beginning of year	$	1,415		$	1,396		$	1,774		$	4,081
Service cost	—			—			—			1
Interest cost	47			55			63			79
Plan participants contributions	92			111			104			92
Curtailment gain	—			—			—			(2,651		)
Actuarial loss (gain)	(108		)	39			(165		)	500
Benefits paid	(184		)	(186		)	(257		)	(328		)
Benefit obligation — end of year	1,262			1,415			1,519			1,774
Change in plan assets:
Fair value of plan assets — beginning of year	—			—			—			—
Employer contributions⁽¹⁾	92			75			153			236
Plan participants contributions	92			111			104			92
Benefits paid	(184		)	(186		)	(257		)	(328		)
Fair value of plan assets — end of year	—			—			—			—
Reconciliation:
Funded status	(1,262		)	(1,415		)	(1,519		)	(1,774		)
Accrued postretirement cost	$	(1,262	)	$	(1,415	)	$	(1,519	)	$	(1,774	)
Assumptions:
Discount rate	4.25		%	3.50		%	4.75		%	3.75		%


⁽¹⁾	Chesapeake’s Postretirement Plan does not receive a Medicare Part-D subsidy. The FPU Medical Plan did not receive a significant subsidy for the post-merger period.

Net periodic postretirement benefit costs for 2013, 2012, and 2011 include the following components:



	Chesapeake Postretirement Plan									FPU Medical Plan
For the Years Ended December 31,	2013			2012			2011			2013			2012			2011
(in thousands)
Components of net periodic postretirement cost:
Service cost	$	—		$	—		$	—		$	—		$	1		$	125
Interest cost	47			55			64			63			79			176
Amortization of:
Actuarial loss	74			73			67			—			—			55
Prior service cost	(77		)	(77		)	(77		)	—			—			—
Net periodic cost	$	44		$	51		$	54		$	63		$	80		$	356
Curtailment gain	—			—			—			—			(892		)	—
Amortization of pre-merger regulatory asset	—			—			—			8			8			8
Net periodic cost	$	44		$	51		$	54		$	71		$	(804	)	$	364
Assumptions
Discount rate	3.50		%	4.25		%	5.00		%	3.75		%	4.50		%	5.25		%

Similar to the FPU Pension Plan, continued amortization of the FPU postretirement benefit regulatory asset related to the unrecognized cost prior to the merger with Chesapeake was included in the net periodic cost. The unamortized balance of this regulatory asset was $54,000 and $62,000 at December 31, 2013 and 2012, respectively.

The following table presents the amounts not yet reflected in net periodic benefit cost and included in accumulated other comprehensive income/loss or as a regulatory asset as of December 31, 2013:



(in thousands)	Chesapeake Pension Plan		FPU Pension Plan		Chesapeake SERP		Chesapeake Postretirement Plan			FPU Medical Plan			Total
Prior service cost (credit)	$	—	$	—	$	28	$	(909	)	$	—		$	(881	)
Net loss	2,483		5,298		659		972			(142		)	9,270
Total	$	2,483	$	5,298	$	687	$	63		$	(142	)	$	8,389
Accumulated other comprehensive loss pre-tax⁽¹⁾	$	2,483	$	1,007	$	687	$	63		$	(27	)	$	4,213
Post-merger regulatory asset	—		4,291		—		—			(115		)	4,176
Subtotal	2,483		5,298		687		63			(142		)	8,389
Pre-merger regulatory asset	—		4,348		—		—			54			4,402
Total unrecognized cost	$	2,483	$	9,646	$	687	$	63		$	(88	)	$	12,791


⁽¹⁾	The total amount of accumulated other comprehensive loss recorded on our consolidated balance sheet as of December 31, 2013 is net of income tax benefits of $1.7 million.

The amounts in accumulated other comprehensive income/loss and recorded as a regulatory asset for our pension and postretirement benefits plans that are expected to be recognized as a component of net benefit cost in 2014 are set forth in the following table:



(in thousands)	Chesapeake Pension Plan		FPU Pension Plan		Chesapeake SERP		Chesapeake Postretirement Plan			FPU Medical Plan		Total
Prior service cost (credit)	$	—	$	—	$	19	$	(77	)	$	—	$	(58	)
Net loss	$	149	$	—	$	48	$	67		$	—	$	264
Amortization of pre-merger regulatory asset	$	—	$	761	$	—	$	—		$	8	$	769

Assumptions

The assumptions used for the discount rate to calculate the benefit obligations of all the plans were based on the interest rates of high-quality bonds in 2013, reflecting the expected lives of the plans. In determining the average expected return on plan assets for each applicable plan, various factors, such as historical long-term return experience, investment policy and current and expected allocation, were considered. Since Chesapeake’s plans and FPU’s plans have different expected plan lives and investment policies, particularly in light of the lump-sum-payment option provided in the Chesapeake Pension Plan, different assumptions regarding discount rate and expected return on plan assets were selected for Chesapeake’s plans and FPU’s plans. Since both pension plans are frozen with respect to additional years of service and compensation, the rate of assumed compensation increases is not applicable.

The health care inflation rate for 2013 used to calculate the benefit obligation is 5.5 percent for medical and 6.5 percent for prescription drugs for the Chesapeake Postretirement Plan; and 6.5 percent for the FPU Medical Plan. A one–percentage point increase in the health care inflation rate from the assumed rate would increase the accumulated postretirement benefit obligation by approximately $264,000 as of December 31, 2013, and would increase the aggregate of the service cost and interest cost components of the net periodic postretirement benefit cost for 2013 by approximately $10,000. A one-percentage point decrease in the health care inflation rate from the assumed rate would decrease the accumulated postretirement benefit obligation by approximately $228,000 as of December 31, 2013, and would decrease the aggregate of the service cost and interest cost components of the net periodic postretirement benefit cost for 2013 by approximately $8,000.

Estimated Future Benefit Payments

In 2014, we expect to contribute $670,000 and $2.4 million to the Chesapeake Pension Plan and FPU Pension Plan, respectively, and $88,000 to the Chesapeake SERP. We also expect to contribute $95,000 and $245,000 to the Chesapeake Postretirement Plan and FPU Medical Plan, respectively, in 2014. The schedule below shows the estimated future benefit payments for each of the plans previously described:



	Chesapeake Pension Plan⁽¹⁾		FPU Pension Plan⁽¹⁾		Chesapeake SERP⁽²⁾		Chesapeake Postretirement Plan⁽²⁾		FPU Medical Plan⁽²⁾
(in thousands)
2014	$	494	$	2,814	$	88	$	95	$	245
2015	$	622	$	2,886	$	138	$	97	$	223
2016	$	572	$	2,946	$	146	$	98	$	203
2017	$	1,071	$	2,988	$	143	$	96	$	166
2018	$	634	$	3,048	$	140	$	95	$	133
Years 2019 through 2023	$	3,984	$	16,362	$	890	$	436	$	393


⁽¹⁾	The pension plan is funded; therefore, benefit payments are expected to be paid out of the plan assets.


⁽²⁾	Benefit payments are expected to be paid out of our general funds.

Retirement Savings Plan

Effective January 1, 2012, we sponsor one 401(k) retirement savings plan and the 401(k) SERP, a non-qualified supplemental executive retirement savings plan.

Our 401(k) plan is offered to all eligible employees who have completed three months of service, except for employees represented by a collective bargaining agreement that does not specifically provide for participation in the plan, non-resident aliens with no U.S. source income and individuals classified as consultants, independent contractors or leased employees. Effective January 1, 2011, we match 100 percent of eligible participants’ pre-tax contributions to the Chesapeake 401(k) plan up to a maximum of six percent of eligible compensation. In addition, we may make a supplemental contribution to participants in the plan, without regard to whether or not they make pre-tax contributions. Beginning January 1, 2011, the employer matching contribution is made in cash and is invested based on a participant’s investment directions. Any supplemental employer contribution is generally made in Chesapeake stock. With respect to the employer match and supplemental employer contribution, employees are 100 percent vested after two years of service or upon reaching 55 years of age while still employed by Chesapeake. Employees with one year of service are 20 percent vested and will become 100 percent vested after two years of service. Employees who do not make an election to contribute or do not opt out of the Chesapeake 401(k) plan will be automatically enrolled at a deferral rate of three percent, and the automatic deferral rate will increase by one percent per year up to a maximum of six percent.

We also offer the 401(k) SERP to our executive officers over a specific income threshold. Participants receive a cash-only matching contribution percentage equivalent to their 401(k) match level. All contributions and matched funds can be invested among the mutual funds available for investment. All obligations arising under the 401(k) SERP are payable from our general assets, although we have established a Rabbi Trust for the 401(k) SERP. Assets held in the Rabbi Trust for the 401(k) SERP had a fair value of $3.1 million and $2.2 million at December 31, 2013 and 2012, respectively. (See Note 9, Investments, for further details). The assets of the Rabbi Trust are at all times subject to the claims of our general creditors.

Contributions to all of our 401(k) plans totaled $3.7 million, $2.9 million and $2.7 million for the years ended December 31, 2013, 2012 and 2011, respectively. As of December 31, 2013, there are 580,484 shares of our common stock reserved to fund future contributions to the 401(k) plan.

Deferred Compensation Plan

On December 7, 2006, the Board of Directors approved the Deferred Compensation Plan as amended, effective January 1, 2007. At December 31, 2013, the Deferred Compensation Plan consisted solely of shares of our common stock related to the deferral of executive performance shares and directors’ stock retainers.

Participants in the Deferred Compensation Plan are able to elect the payment of benefits to begin on a specified future date after the election is made in the form of a lump sum or annual installments. Deferrals of executive cash bonuses and directors’ cash retainers and fees are paid in cash. All deferrals of executive performance shares, which represent deferred stock units, and directors’ stock retainers are paid in shares of our common stock, except that cash is paid in lieu of fractional shares. We established a Rabbi Trust in connection with the Deferred Compensation Plan. The value of our stock held in the Rabbi Trust is classified within the stockholders’ equity section of the consolidated balance sheet and has been accounted for in a manner similar to treasury stock. The amounts recorded under the Deferred Compensation Plan totaled $1.1 million and $982,000 at December 31, 2013 and 2012, respectively.

Effective January 1, 2014, our 401(k) SERP was amended, restated and renamed as the Chesapeake Utilities Corporation Non-Qualified Deferred Compensation Plan. In addition, the Deferred Compensation Plan was consolidated into this plan. As a result of these actions, the 401(k) SERP and the Deferred Compensation Plan are now administered as a single plan.