In re New England Tel. & Tel.

 NOTICE:  This opinion is subject to motions for reargument under V.R.A.P.
 40 as well as formal revision before publication in the Vermont Reports.
 Readers are requested to notify the Reporter of Decisions, Vermont Supreme
 Court, 109 State Street, Montpelier, Vermont 05609-0801 of any errors in
 order that corrections may be made before this opinion goes to press.


                                 No. 92-005


 Petition of New England Telephone and        Supreme Court
 Telegraph Co. and Department of Public
 Service to Extend Telecommunications         On Appeal from
 Agreement                                    Public Service Board

                                              October Term, 1992


 Richard A. Cowart, Chair

 Kathleen Davis of Downs Rachlin & Martin, Burlington, for appellant

 Joseph E. Frank of Paul Frank & Collins, Burlington, and Bartlett L.
   Thomas, Boston, Massachusetts, for appellee New England Tel. & Tel. Co.

 Heather R. Wishik, Special Counsel, and James Volz, Director for Public
   Advocacy, Montpelier, for appellee Department of Public Service


 PRESENT:  Allen, C.J., Gibson, Dooley, Morse and Johnson, JJ.


      ALLEN, C.J.   RCI Long Distance New England, Inc. d/b/a Long Distance
 North (LDN) appeals from a Public Service Board order approving an Extended
 Vermont Telecommunications Agreement (EVTA).  LDN argues that the Board did
 not meet the statutory requirements of 30 V.S.A. { 226a(c) and that the
 Board treated the EVTA as an extension when it was actually a modification.
 We affirm.
      New England Telephone and Telegraph Company (NET) and the Vermont
 Department of Public Service (DPS) jointly petitioned the Board for
 contract-based rate regulation under 30 V.S.A. { 226a.  Section 226a
 authorizes contract regulation, in lieu of traditional rate regulation, of
 any company that provides basic exchange telecommunications service in lieu
 of traditional rate regulation.  Contract regulation is established through
 a Board-approved agreement between a company and the DPS.  The Board
 rejected petitioners' Vermont Telecommunications Agreement (VTA), but
 suggested that a modified contract would be acceptable if it adequately
 addressed certain enumerated deficiencies in the VTA.  On December 12, 1988,
 the Board approved petitioners' modified contract (MVTA).
      This appeal arises from the approval by the Board on December 4, 1991
 of a one-year extension of the MVTA.  LDN, a competitor of NET, argues that
 the Board's findings do not support the conclusion that the extended
 contract (EVTA) satisfied the 30 V.S.A. { 226a(c) statutory criteria, and
 therefore, the EVTA should not have been approved.  LDN also argues that the
 extended contract (EVTA) was actually a modification of the MVTA and that
 the Board failed to follow the MVTA's procedure on modifications, which
 would have required an external change in circumstances before the contract
 could have been modified.  Because such an external change in circumstances
 did not exist, LDN argues that the MVTA could not have been modified.
                                     I.
      LDN argues that the Board's findings do not support its conclusion that
 the contract satisfies the criteria of 30 V.S.A. { 226a(c).  Specifically,
 LDN argues that the Board failed to make findings on the criteria set forth
 in the statute. (FN1) Under the statute, as it existed at the time of approval
 of the MVTA, the Board may grant approval of a contract
      only if it finds that a contract in its entirety is just and
      reasonable giving due consideration to the services and price
      levels covered and any risk of cross-subsidization, promotes the
      general good of the state, supports reasonable competition, and
      takes into consideration any state telecommunications plan or
      policy adopted pursuant to section 202d.

 30 V.S.A. { 226a(c) (prior to 1991 amendment).
      Where the findings of an administrative agency "fairly and reasonably"
 support the agency's conclusions of law, this Court will uphold the agency's
 decision.  Caledonian Record Publishing Co. v. Department of Employment and
 Training, 151 Vt. 256, 260, 559 A.2d 678, 681 (1989).  Moreover, decisions
 made within an agency's area of expertise "are presumed correct, valid and
 reasonable," absent a clear showing to the contrary.  Id.  Throughout the
 Board's order, reference is made to its July 12, 1988 order, which rejected
 the VTA, and the subsequent MVTA, which was approved in the Board's December
 30, 1988 order.  Where identical factual considerations governed the
 application of { 226a(c), the Board's reliance on portions of the earlier
 orders was appropriate and removed the necessity of readdressing identical
 issues.
      Under the first statutory criterion, the Board considered the services
 and the price levels and any risk of cross-subsidization.  The Board found
 that the specified service quality levels in the EVTA were identical to
 those set forth in the MVTA.  This finding supports the Board's conclusion
 that the EVTA will maintain the service quality of the MVTA.  The Board also
 found that the proposed rate increase would be "less than the basic exchange
 rates established in 1985, adjusted for inflation through 1991."  This
 finding supports the Board's conclusion that the price levels were
 reasonable because they were lower than they would otherwise have been.
      LDN's argument under this first criterion focuses on the Board's
 alleged lack of findings on the cross-subsidization risk under the EVTA.
 NET's potential for cross-subsidization arises from the fact that NET
 provides monopolized services (local service) and competitive services
 (intrastate services).  As the Board explained in its July 12, 1988 order,
 the risk of cross-subsidization will be adequately controlled where NET has
 no pool of local service revenues available to offset losses due to anti-
 competitive pricing in other services.  Although the Board's finding was
 interspersed in the discussion section of the order, the Board stated:
      [W]e explicitly recognize that the revenue increase will not fully
      compensate the Company for the costs it incurs to meet its
      obligations and that NET still faces a considerable financial
      incentive to improve the efficiency of its own operations.
      Furthermore, the rate level approved here also ensures that NET
      will not have available a pool of monopoly profits to cross-
      subsidize anti-competitive offerings in more highly contested
      markets.  These features are critical components of the current
      VTA, and they are preserved by the extension.

      The Vermont Administrative Procedure Act requires that findings of fact
 and conclusions of law be separately stated.  3 V.S.A. { 812(a).  Where
 findings of fact, however, are "interspersed throughout [the Board's]
 discussion" such that there is "no doubt as to what [the Board] decided and
 how its decision was reached," the Board's order will stand.  Petition of
 Village of Hardwick Electric Department, 143 Vt. 437, 444-45, 466 A.2d 1180, 1184 (1983).  The finding at issue here adequately addresses the complicated
 issue of cross-subsidization; moreover, other factual findings regarding
 NET's revenues, earnings and expected rates of return supplement the
 finding.  In addition, the Board explicitly referred to the July 12, 1988
 order's discussion of cross-subsidization, which leaves no doubt as to the
 Board's reasoning.
      LDN argues that the court failed to make findings on the second
 statutory criterion:  that the EVTA promote the general good.  The Board
 stated, "We find . . . that the proposed $5.5 million increase is consistent
 with the general good of the state."  Specifically, the Board found that the
 rate increase would result in rates that were lower than they would have
 been under traditional rate regulation and as compared to the 1985 rates
 adjusted for inflation.  Although the Board used the word "consistent"
 instead of "promotes," this choice of word is not grounds for reversal.
 LDN's argument to the contrary is based on a case that is not on point.  In
 In re Reclassification of Ranch Brook, the statute required a finding that
 "the established classification is contrary to the public interest."  146
 Vt. 602, 604, 508 A.2d 703, 704 (1986)(quoting 10 V.S.A. {1253(c)).  In that
 case, the Water Resources Board found only that reclassification was in the
 public interest and neglected to make a finding regarding the established
 classification.  Id. at 605, 508 A.2d  at 704.  Thus, the Water Resources
 Board did not make findings allowing for the application of the statutory
 standard.  In the present case, the Public Service Board made the necessary
 findings to support its conclusion under the statute but used language
 different from the statute in its conclusion.  As the rate increase was the
 only substantive change in the EVTA, the Board's finding, and its subsequent
 approval of the petition, supports the Board's conclusion that the EVTA will
 promote the general good.
      LDN also argues that the Board neglected to make any findings on the
 third statutory criterion:  that the EVTA support reasonable competition.
 As the Board stated in its July 12, 1988 order, this criterion is closely
 tied to the analysis of the risk of cross-subsidization.  As stated above,
 the Board made adequate findings that there was no risk of cross-
 subsidization.  Moreover, the Board also found that the EVTA preserved
 nondiscriminatory access tariffs and a 33.33% minimum differential between
 aggregate toll charges and its aggregate access charges that were present in
 the MVTA, thereby insuring access for competitors.  Although the Board did
 not address the issues of market flexibility regarding new services, notice
 to consumers and anti-bundling provisions, these issues were discussed in
 the July 12, 1988 order and the MVTA was approved only when protections
 against these potential problems were added. These protections were
 preserved in the EVTA.  Although the Board did not explicitly state that the
 EVTA supports reasonable competition, the Board's conclusion to that effect
 is apparent when the Board's order is read in conjunction with the VTA and
 MVTA orders.
      LDN argues that the Board erred when it decided not to address the
 fourth statutory criterion because there was no state telecommunications
 plan at the time of the hearing.  Section 226a(c) requires that the
 contract "take[] into consideration any state telecommunications plan or
 policy adopted pursuant to section 202d."  The Board made the finding that
 no such plan had been adopted.  LDN contends that this finding supports a
 holding that the Board failed to meet the requirements of { 226a(c) because
 { 202d makes the creation of such a plan mandatory by January 1, 1989,
 nearly three years prior to the Board's Order.
      Section 226a(c) requires consideration of only "any" telecommunication
 plan that has been "adopted" by the Board.  The plain meaning of this
 language is clear, and the statute will be enforced according to its express
 terms.  Cavanaugh v. Abbott Laboratories, 145 Vt. 516, 529, 496 A.2d 154,
 162 (1985).  Although { 202d makes adoption of the telecommunications plan
 mandatory, { 226a(c) itself does not suspend the Board's powers under { 226a
 in the absence of a telecommunications plan.
      LDN compares { 226a(c) to 30 V.S.A. { 248(b)(7), which requires that a
 new gas and electric facility be "in compliance with the electric energy
 plan approved by the department under section 202 of this title, or that
 there exists good cause to permit the proposed action."   LDN argues that
 the Legislature, by providing an alternative in { 248 and not in { 226a(c),
 intended to make a consideration of the telecommunication plan mandatory
 under { 226a(c).  Although { 248 allows the Board an alternative method of
 approving a new facility absent compliance with the electric energy plan,
 neither statute specifically provides for the case where no plan has been
 adopted or approved.  Therefore, the language of { 248 does not assist the
 Court in construing the meaning of { 226a(c).  The Board's finding that no
 telecommunications plan was in existence at the time of approval of the EVTA
 supports its conclusion that the contract met the criteria of { 226a(c).
      In conclusion, the Board's findings, although interspersed throughout
 the discussion section, support its conclusion that the EVTA satisfies the
 { 226a(c) criteria.
                                     II.
      LDN's second major argument is that the EVTA was not an extension of
 the MVTA because the EVTA set forth new terms, including higher basic
 exchange rates and increased rates for special types of lines, such as
 Centrex service rates.  Instead, LDN contends that the EVTA was actually a
 modification of the MVTA, and Section XXX of the MVTA (modifications) should
 have governed the approval of the EVTA.  Because Section XXX has different
 procedural requirements than Section XXIX, LDN argues that the EVTA could
 not have been approved under section XXX.
      First, Section XXX requires an external change in circumstances,
 including "certain decisions of the FCC or other administrative, judicial or
 legislative body, or changes in technology or market conditions."  Second,
 Section XXX requires the Board to find that "such [rate] changes are
 required or desirable to bring the rates . . . into conformity" with such
 changes in circumstances, and that the contract meets the { 226a(c)
 standards.  According to LDN, the prerequisite changes in circumstances
 never occurred; therefore, the Board could not have found that the rate
 increase was required or desired to bring the rates into conformity with the
 new circumstances.
      LDN's contractual argument rests on its definition of a term in the
 MVTA.  The question of whether a contract term is ambiguous is a matter of
 law for the court to decide.  Isbrandtsen v. North Branch Corp., 150 Vt.
 575, 577, 556 A.2d 81, 83 (1988).  Where the language of a contract is clear
 and unambiguous, the plain meaning of the language applies.  Id. at 579, 556 A.2d  at 85.  Section XXIX (extensions) states that "the terms of this
 agreement may be extended . . . on terms to be negotiated by the COMPANY and
 the DEPARTMENT and upon approval, after hearing, by the Board."  [PC 143].
 This language is clear and unambiguous.  NET and DPS agreed to the terms of
 the EVTA, which included a negotiated rate increase, in order to extend the
 MVTA for one additional year.  Thus, the EVTA is an extension of the MVTA.
 The Board approved the EVTA and found that it met the requirements of {
 226a(c); therefore, the requirements of section XXIX for extensions of the
 contract were followed.
      LDN also contends that even if the EVTA is deemed to be an extension, {
 226a(b) precludes the Board from approving an extension which includes a
 rate change.  Section 226a(b) states that the contract "shall provide for
 specified basic exchange rates during the life of the contract."  The rates
 under the MVTA were specified and fixed for the three-year life of the
 contract and the new rates under the EVTA were also specified and fixed for
 its one-year life.  Thus, there could be no change in rates during the life
 of either the MVTA or the EVTA, and the extension meets the statutory
 requirements.
      Appellant raises other arguments, which we find meritless.  Appellant
 argues that the Board conducted an illegal, abbreviated rate regulation
 case.  The Board was required to use rate-making criteria to determine the
 reasonableness of the rate increase, but this did not convert the proceeding
 into a rate regulation case.  Rather, the Board followed the requirements of
 30 V.S.A. { 226a in reviewing the contract.  In addition, LDN contends that
 the Board improperly shifted the burden of proof and rested its decision on
 LDN's failure to submit evidence demonstrating that the extension of the
 MVTA would not be just and reasonable.  We disagree and hold that the Board
 made sufficient affirmative findings based on NET and DPS's evidence as
 required under { 226a(c).
      Affirmed.

                                         FOR THE COURT:




                                         Chief Justice



FN1.    Because we agree with the Board's conclusion that the EVTA is an
 extension of the MVTA and not a new contract we do not address LDN's
 argument that the 1991 amendment to { 226a(c) concerning customer privacy
 interests should have been applied in the Board's approval of a new contract.