Below are a few letters received at EnergyBiz Insider on topics that appeared in the past few weeks. They capture the essence of how many readers say they feel.
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Letters from Readers - March 19, 2009
When will Energy Insider begin to be more direct about wind energy advocates? They promote basically junk energy and no one challenges them. The NEWC advocates tearing down the Snake River Dams thereby eliminating over 1000 MW of hydropower. They oppose everything except wind power -- no coal or nuclear for sure. Wind Power is the most subsidized renewable that wouldn't be built otherwise -- the most undependable power out there. Furthermore, it's useless without backup power and transmission which they always want someone else to pay for.
Shouldn't EnergyBiz Insider take these people on and give them a reality check?
Ron Corso
Cap-and-Trade Issues - March 16, 2009
The D.C. Court of Appeals vacated the Clean Air Mercury Rule (CAMR) because the court said the EPA did not follow proper administrative procedures for de-listing power plants as a Section 112 source of mercury emissions, even though the EPA admitted that it errored when it originally listed power plants as a Section 112 source for mercury emissions. Since EPA did not properly de-list power plants as a Section 112 mercury source, the court ruled the EPA could not regulate mercury emissions under Section 111 of the Clean Air Act. Without a Section 111 basis for regulation, there was no legal foundation for CAMR, so the court vacated CAMR. Thus, in our Kafkaesque EPA regulatory/federal court world, a federal court prevents the correction of an error and puts back in force a regulatory basis that was put in place in error.
Now the Obama Administration plans to promulgate new rules based the original flawed EPA reasoning. This is a lawsuit waiting to happen where EPA's own statements and records will be the strongest part of the plaintiffs' case. Moreover, the utility industry also appears to have a second strong case that the EPA selected an unrepresentative sample set to determine mercury emissions from existing coal-fired power plants. This emissions sampling was used to determine Maximum Achievable Control Technology (MACT) emissions limits. Thus, the most probable outcome of this Kafkaesque regulatory/legal world where errors are not rectified, but perpetuated, is that trial lawyers will get rich.
It is important to recognize that coal fired power plants only represent 4 percent of mercury deposition in the U.S. Natural sources of mercury are the dominant source of mercury deposition, not only for the U.S., but also for the world. It is extremely unlikely that anybody will be able to discern any measurable change in mercury deposition as a result of any regulation of U.S. coal-fired power plant mercury emissions. Thus, the American public could pile all the money spent on power plant mercury emission controls and light a giant bonfire for all the environmental benefit these regulations will provide. The lone benefit of CAMR is the pile of money in the bonfire ($10 billion-$20 billion) would be smaller than with EPA's probable MACT standard (assuming it survives legal challenges).
However, aside from the wasted money, there is an even more pernicious problem with the concentration on regulating mercury emissions from power plants -- it diverts attention from a real environmental problem as the U.S. still allows the mercury cell chlor-alkali process for producing chlorine and sodium hydroxide.
Ben Ziesmer, P.E.
Yucca Mountain Flattened - March 25, 2009
Thank you for writing about the administration's reduction in funding for Yucca Mountain, but your conclusion that YM is dead is very premature and it is not helpful to the industry to keep repeating assertions from other sources that are not as informed about the political realities of the Yucca Mountain project as they should be.
First of all, the Nuclear Waste Policy Act which set out the process for selecting the site and getting it licensed is still in place. The site was selected by a vote of both houses of Congress in 2002 with overwhelming majorities. There is no appetite in Congress to change that law because representatives of the 39 states with high-level waste in them like the law just as it is. They all recognize that this is an issue now only because the President made a commitment to the Senate Majority Leader during the Nevada primary to be against the project (the politically smart thing to do while in Nevada).
Second, the budget will not stop the licensing process now in front of the NRC. It will slow it down enough so that the NRC can't make a decision during the first four years of the administration. We ere able to submit the license application last June despite budget cuts engineered in conference by Reid and I was congratulated by members in both houses and both parties when we did it. The political support is still there.
I argue that the correct interpretation of the YM budget cuts is: Administration decides not to fund Yucca Mountain engineering and pre-construction activities. No schedule for opening. Taxpayer liabilities continue to increase.
You will be able to correctly say that Yucca Mountain is dead when/if the Nuclear Waste Policy Act is repealed or amended. I don't see that happening any time soon.
Ward Sproat
Former Director
Office of Civilian Radioactive Waste Management
US DOE
Yucca Mountain was chosen for political reasons, the State of Nevada being politically weak in 1987. And now it is being stopped politically. You live by the sword; you die by the sword. One has to remember that Nevada, with no nuclear reactors, has given to the national efffort with atomic bomb tests and a radioactive burial ground.
From a scientific perspective, the view that Yucca Mountain is a disposal site rather than an underground storage site needs to be addressed. The nuclear industry and EnergyBiz would call Yucca Mountain a disposal site. But some of us would call it a storage site in an imperfect earthen container. According to the Energy Department's EIS, it is only an instant in geological time before very radioactive materials enter aquifers after high-level waste containers corrode.
The alternative, following the merger of many utilities, is to store high-level radioactive waste in a handful of regional storage facilities. If this waste has to be moved across the country at a later time, the risk will be greatly reduced.
Marvin Resnikoff
Radioactive Waste Management Associates
The author is a consultant to the State of Nevada on transportation issues.
We do NOT need a "scientific breakthrough that allows the spent fuel to be used again for the generation of power" -- what we need is a political breakthrough. Others do it, but we're chained politically to the Carter administration's refusal -- on tenuous ground -- to allow reprocessing.
Thomas Tanton
President, T2 & Associates
Sr. Fellow, Energy Studies, Pacific Research Institute
Perhaps Energy Secretary Chu is "dumb like a fox". The fact that the U.S. even needed to consider a repository goes back to the folly of "opening" the nuclear fuel cycle "temporarily" by President Ford (later made "permanent" by President Carter) by ending reprocessing used nuclear fuel. (The ban on reprocessing was lifted during Reagan's tenure, but by then, it was a dead issue.) Perhaps the "scientific debate" that Secretary Chu proposes to initiate will lead us back to the obvious conclusion that the U.S. should be reprocessing its used nuclear fuel to extract its vast energy value like other countries. Can we afford NOT to?
The proliferation risks seem to be far outweighed by the global energy mess (which spawned the "terrorism mess") we have today. Beyond this issue, we should seriously begin re-examining the U.S. decision to abandon fast reactor (breeder) designs. That decision was far more political than technical. What role (if any) did "Big Oil" or "King Coal" play in it?
Mark Miller
Certified Health Physicist
Well isn't this just ducky!
Another federal government NIMBY plan goes awry. With all these spend-it-at-all-costs alternative energy plans, and invest in "Green" jobs nobody wants the other guy's dirt.
It's absolutely incredible that all forms of "liberal" government want energy for nothing, yet when the bill comes to the table to pay for it, swish the door opens and the liberals all go running out the door without paying the bill. This is exactly what liberals do best, especially all those Sierra Club persons. They want all those great toys for the home, big screen televisions, air conditioning for the home, dishwashers, all kinds of stuff electrical for the home. But, the Green Glee Club doesn't want you to enjoy the same benefits and enjoyments that the Green Glee Club enjoys.
This brings us back to the Repository. That location was to be built to protect all this waste nuclear energy, and the secure it. It was to last longer than Pharaoh's mighty pyramid and then some. The nuclear waste "is" going to be deadly for tens of thousands of years. That's the price we as a humanity are going to pay for messing around with nuclear generation. It's also the main reason why NIMBY squashed the plans. Who wants to maintain integrity of that mess in the future. We cannot even read the scratching on the ancient pyramids, and that's a couple of thousand years old. We can barely read old English from Shakespeare, and we have to ensure total protection of a nuclear waste dump for twenty thousand.
Liberal governments are all passing the buck. We've got hundreds of years of coal available to us for use. Let's invest in cleaning it up before it goes up the stack. Its affordable generation for all people, especially our heavy industry sector. Let's keep jobs and heavy industry in North America. Let's keep energy affordable for all people, not the selected people. Let's ensure fossil fuel users don't get taxed unfairly on fictitious accounts of these global warming or climate change doomsayers. And where proven a secure site for waste disposal of nuclear materials.
J. Hagar
Niagara, Canada
Please stop calling it "spent fuel" or "nuclear waste." It is partially used fuel.
The technology that used it only partially may well be merely a temporary constraint on the further use of the fuel.
Now that Yucca Mountain appears off the table we need to relieve the temporary constraint. That's a technological and political challenge.
W. R. Corcoran, Ph.D., P.E.
Nuclear Safety Review Concepts Corporation
Editor: This writer is not really too unhappy to hear that Yucca mountain may be done as a nuclear waste repository. In this nation and at the moment (and for probably the next 100+ years) we don't need nuclear. We have more than enough coal to keep this nation in energy for this time period. Coal can be gasified, liquified and even utilized as a solid. In the article you mention that the French are conducting extensive research into what to do with the waste. Great! There may be an answer to nuclear waste that is both politically and environmentally acceptable, in this nation we can either conduct our own research programs or work with the French or other nations in a joint effort to seek an acceptable solution. The situation in other countries is different from the situation we face in this nation, we have other options, less expensive and less dangerous than nuclear.
After 9-11 the question arises, how do we protect our containment structures against terrorist attack? Keep the nuclear research going, YES! Build new nuclear plants at this time in this nation, NO! going nuclear is not a necessity in this nation!
Joseph Langenberg
The initial, success-based Atomic Energy Commission program for disposition of used fuel from nuclear power plants was cancelled in 1962 when nuclear plant operators and vendors and others accepted gross misinformation from the AEC about the success of a low-cost reprocessing plant that had failed, and AEC estimates that used fuel could be reprocessed for less than $20 per kilogram (present charges by France are about $1000 per kilogram). After failure of commercial reprocessing and detonation by India of a nuclear explosive recovered with the laboratory reprocessing technology supplied by the US, the AEC carried out reviews of reprocessing experience and made changes to build on successes and avoid failures.
Designs were completed of facilities that would have avoided problems, but these were rejected by DOE in order to support other laboratory concepts that had no potential for success. The decisions to indefinitely defer proper management of used nuclear fuel were political, made by Presidents Gerald Ford and Jimmy Carter with no awareness of programs that would have resolved problems nor input from experienced spent fuel managers.
An underlying problem is that nuclear engineers, nuclear plant managers and DOE lab officials do not understand the complex chemical engineering technology of reprocessing. I had lead responsibility for successful and success-based programs and was aware of failures, but the nuclear bureaucracy was simply not interested. I have written a good bit and will write more, but DOE is still trying to address the challenges with DOE labs -- the path to failure.
Final note: Nuclear waste from the Savannah River Plant was to have been disposed of in bedrock where, unlike Yucca Mouintain, formidable geologic barriers assured isolation, and a committee appointed by the governor of South Carolina endorsed the project.
Clinton Bastin
Chemical Engineer/Nuclear Scientist
US Department of Energy (Retired)
The problem with Yucca Mountain has very little to do with the storage of nuclear waste. It has everything to do with how the waste is transported into Yucca Mountain. Radioactive nuclear waste rolls through the population center of the city of Las Vegas and its suburbs on the interstates and highways. The public is not protected from exposure if an accident occurs. The drivers of the tractor trailers -- the vehicle often used to transport the waste -- are seldom certified to haul this type of cargo. In addition, the highway patrol systems are not equipped for immediate response of a nuclear or radioactive waste spill. Until serious protective measures are made, Yucca Mountain, or any other location, should not be utilized.
Do you have any solutions to offer, rather than complain about funding losses?
Monica Turner
In my opinion, Yucca Mountain project has been a fiasco for decades. Water leaks all the way down from the surface - when 10 inches falls on top of the mountain, 10 inches appears in the storage void having filtered through the pumice (volcanic ash). A much better option is mined salt which is deeper, has solid rock on top, is much less (like totally im-) permeable and will isolate the waste literally "forever". There are salt layers that are mineable many places in the US .
Robert Weinberg
Once again I want to thank you for this newsletter. You cover an impressive array of topics in quite a bit of detail and often make it interesting. On the nuclear issue, though, I recommend you look into Europe's experience with reprocessing before you flippantly mention it as if it's a solution. The pro-nuclear crowd likes to brag about France's commitment to nuclear power and talk about reprocessing as "recycling" to make it sound like it is simply re-using nuclear waste as fuel with little or no waste. That's not accurate at all. To read about France's experiences, including the failure of reprocessing to solve the waste problem, see Jan. 2008 issue of Science for Democratic Action by the Institute for Energy and the Environment (IEER) at http://www.ieer.org/sdafiles/15-2.pdf
As of 2005, 81 metric tons of (bomb-grade) plutonium are in "temporary" storage at La Hague.
Jack Zeiger
The Arctic Divide - March 27, 2009
At a rate of consumption of 21 million bpd in the US, the 10.36 billion barrels in the arctic are about 493 days worth of oil. And the 8.6 trillion cu. ft. of natural gas is only about 150 days worth.
Looks to me like this too, is just delaying the inevitable. And for a little over a year's worth of oil, it this worth it?
Jack B. Quinlan
Senior Engineer | ILPS
Science Applications International Corporation
According to the National Renewable Energy Lab, greenhouse gas emissions from production and transportation of natural gas adds another 25 percent to emissions. The price is EXTREMELY volatile, and once natural gas is over $10 per MMBtu, renewables are cheaper.
We have many GW of natural gas plants on stand-by in the U.S., and can hybridize them with Concentrating Solar Power in the Western and Southwestern U.S. now. This will give us valuable experience in hybridization and allow us to reduce our reliance on valuable and irreplaceable natural gas, which is a limited resource. Various groups differ as to when we'll hit "peak" natural gas production, but we should start long-term planning today so that we can transition gracefully to a time when natural gas is more limited and far more expensive.
Nancy LaPlaca, J.D.
Energy Consultant
Bardwell Consulting Ltd
The ability of Alaska to supply seven years of oil and 8 years of natural gas to the lower 48 states is not a mixed blessing, it could and likely will become an essential oil energy resource. Fortunately, there have been huge discoveries of natural gas in the lower 48 which have been unleashed by cutting edge drilling and recovery technologies, otherwise, these would remain untapped energy resources. You see advertisements on the abundance of these gas supplies every day, and they largely account for the low price of natural gas at this time.
It is unfortunate and I'm sure frustrating to present generations that they face a future of peaked oil supplies at a time when oil and gas use are skyrocketing globally. But there is a ready answer, President Obama's energy program.
It's also well to never forget that World War II was fought largely over the control of oil resources. The Vietnam war was too in large part because the Gulf of Tonkin was thought to have oil reserves; it didn't, so we left. The Iraqi war is also all about oil.
We are fast headed to a future of electricity as the primary source of our energy, which has hit Detroit right between the eyes. But everybody knew EVs were much needed. Indeed, if GM had followed up on their great EV1 design in the early '90s, they would be sitting pretty today with the lions share of the EV market globally.
Electricity can even cost effectively make the ammonia we need to grow our food; that ammonia is now 75 percent imported. So, we are subject to cartels for transportation fuel and ammonia for food production. But I'm personally not the slightest worried about our future energy resources, I'm just going to follow Obama's lead, and you should too.
Lloyd Weaver, President
LEW Holdings LLC
Jolting the Energy Sector - March 30, 2009
Regarding the article "Jolting the Energy Sector" I do agree that we are making forward progress toward the Next Generation Utility (NGU). The NGU will bring more intelligence to the end users, providing greater control and consciousness of the energy we consume. While the article did a good job talking about optimization on the consumer end of the line, the topic of resource planning optimization should also be on the table. As developers, utilities, regulatory agencies, and others pull the trigger on renewable and traditional energy development we should not only assess the amount of renewable energy produced but the timing of that energy and how that will impact our electrical energy systems ability to cope with variability. By optimizing the locations and types of renewable energy development we can drastically reduce the variability of those resources making the integration challenge less difficult and increasing the total amount of inter-connectable renewable energy. In many cases reducing variability has the effect of reducing energy production but increasing reliable capacity. This set of trade-offs should be optimized to bring the most cost effective suite of energy systems onto the grid.
A "Smart Grid" should be optimized from the top down -- resource planning- looking at suites of resources to increase renewable penetration, generation, and capacity. A "Smart Grid" should also be optimized in real time operation by providing the nodal communications discussed in "Jolting the Energy Sector".
Jonah Levine
University of Colorado-Boulder
There are a couple of points in your article I'd like to comment on.
First, industry restructuring absolutely has made utilities more cost conscious and more efficient. Merchant energy companies were leaders in building and operating gas-fired combined cycle plants. Utilities followed. Merchants and IPPs were leaders in lean staffing at power plants and fast turnarounds. Utilities must follow or explain to their regulators why an unregulated company can change an engine in three days while they require two weeks. Wholesale energy markets help regulators better assess the operating efficiency of utility generation.
Second, the industry and its suppliers are still largely stuck in the command-and-control paradigm where the Transmission System Operator (TSO) needs to know everything it can about the state of power production and customer energy usage, with a unilateral ability to and control what customers do, all facilitated by a Smart Grid that has yet to be well defined.
At least this is the way I've seen most commentators approach the problem. I would argue that the grid need not be that smart at all. Like the Internet, our electric grid is a collection of largely passive devices that carries electricity (content) from where it is produced (content providers) to where it is consumed (your PC). In fact, the Internet is one step more sophisticated than the electric grid because it allows largely unrestricted, two-way flows on the network whereas the electric grid is still largely limited to producers that only inject power and consumers that only consume power with few instances where a customer could take power off the grid at times and inject power at others. Since the flow of electrons in an AC network can't easily be directed, we don't need routers, but technology that provides a more accurate, more complete view of network activity so that TSOs can stay on top of potential problems that can cause massive disruption would be useful.
Instead, we need Grid Smart consumers and a value proposition for intelligence on the edge of the network in power plants, homes, commercial buildings and factories that helps users of the grid make decisions about when to produce electricity and how much, and when to consume electricity and how much, all based on prices. We don't need the equivalent of a "Great Oz", who stands behind an iron curtain and pulls levers that "control devices". That's not how the rest of our economy works and a 21st century electric grid shouldn't have to work that way either.
Third, I dispute the assertion that Smart Grid will yield dramatic improvements in reliability. Lack of technology has not a major factor in major blackouts. Instead, widespread blackouts have typically been the result of inadequate maintenance (vegetation management and relay inspections) or lack of attention. Our industry should not forget about the importance of basics like tree trimming and periodic relay calibration as it prepares to spend billions on fancy new gadgets.
Finally, the Smart Grid will be a failure if all it does is put more control in the hands of TSOs and utilities. Regulators are understandably afraid of more "deregulation" or a restructuring that further decentralizes the industry and potentially puts large numbers of market actors beyond their control. However, concepts like Home Area Networks, electric vehicles and smart appliances won't work unless they're designed, built and operated from a strictly customer-centric viewpoint so that consumers will buy them in the same way they buy DVD players and LCD TVs. The industry has to focus less on what's best for TSOs, utilities and their suppliers and focus more on what works for consumers.
Jack Ellis
Resero Consulting
The premise of this article "... on controlling energy use, which in turn limits emissions, helps preserve the environment and increases grid reliability" is correct. But it's not just about energy conservation in my opinion.
Energy efficiency is another major opportunity and challenge for many utilities. Peak demand drives a utility's capacity requirement -- for generation, transmission and distribution. That's a lot of investment.
For utilities in the southwest, those until recently with a lot of growth, the challenge has been to add infrastructure to meet demand. One of increasing challenges has been determining what generation fuel source is an optimum solution.
With some emerging technologies, another approach is becoming viable. This would be to manage customer demand and thus be able to utilize current generation sources to meet growth. This actually could work very well with integrating renewable energy sources into an increasing portion of the energy supply mix.
With hybrid air conditioning with thermal storage technology, combined with smart metering, utilities have an opportunity to leverage Time Of Use (TOU) rates to manage customer load. Typically, the residential sector offers a substantial opportunity to shift a significant percentage of their load off-peak.
This would delay any new generation requirements until long-term solutions can be found. It would not only save the consumer the cost of short-term generation investment, but benefit all stakeholders in the long run.
Conservation is a key component, but efficiency also has a significant opportunity to play an even larger role with some utilities energy plans.
Tim King
What a scary Op-Ed piece that you write! I don't want Microsoft, or for that matter anyone else, reaching into my home and monitoring my spending habits, never mind controlling my appliance use.
The term "Brave New World" is a disparagement, underlying the intention of the author, Huxley. You use it to describe deregulation, which was hijacked to became just a sideways step towards re-regulation. Yet what you submit truly looks like an element of the Brave New World dystopia. When once you use a term like "holistic", one intuitively knows that the underlying thought must be harmless gibberish. But then, later phrases such as "online software", "tracking", and "makes note" are such that it ought to give rise to concern amongst your readers.
I thought that smart systems were originally envisioned to be about information flow TO the home, not FROM the home. Smart Meters really need to be able to perform only one humble operation -- totalize the cost of electricity in real-time. Consumers need only one piece of critical information -- the real-time pricing of electricity. Let consumers decide for themselves whether to program their own refrigerators, air conditioners, etc., to operate, or to conserve. Real-time pricing is the most compelling way to economically induce clean distributed solutions, such as roof-top solar energy generation, and energy storage systems such as ice-banking.
Real-time pricing of electricity is the both the simplest and most powerful tool available to fix what ails the entire electrical energy system. Moreover, it contributes to personal freedom as a demand-side program, rather than detracting from freedom as a centrally-controlled supply-side mandate. Yet, such a real-time pricing plan doesn't allow for nearly as much of the future commercial revenue to be created from central control. I ask that you more carefully consider the implications of your ideas on your readers, and our larger society in general; and not to become beholden to the fancy technologies of your advertisers.
Tom Tillman
In the end, and that is what we face, government implementation of smart-grid rules means less -- less of everything: comfort, convenience, and supplies. If the US is to survive, we need to produce more energy and local goods and services powered by energy. Let American govern themselves and be responsible for themselves -- and they will do better than all the bureaucrats Washington can hire.
While curtailing the use of a piece of equipment could reduce emissions of a less efficient plant, the piece of equipment must then run on different hours -- or not produce that widget. Smart Grid will be used just like government healthcare -- to ration our energy, and to justify deferring new generation.
The first stage of any smart grid operation should address consumer demand via price. Sell the time-of-use meter. Inform the customers of the hourly price in the day ahead and as estimated via fundamentals. Empower the consumer to make the choice and they will do more with less government. I did just that. I bought a time-of use meter, applied for time of use rates, and I save $100/month in electricity, live just as comfortably. The government always has and always will make things worse.
Big Brother is now here -- and he is gunning for you!
Stuart Robertson, President
Robertson-Bryan, Inc.
Stimulus Funds Flow - April 02, 2009
Your article is one of the best I've seen in quite a while. Having been through the U.S. DOE process in 2006 let me assure you that it was flawed and the same goes true for the USDA RUS and the daddy of them all our commercial banking top ten.
Our enterprise is a base load design so unlike solar during cloudy days or wind during still days it puts out massive amounts of green power night and day. Our design will actually compete with a fossil fuel plant or a nuke plant so the costs are extensive compared to solar and wind. Our government naturally wants full engineering disclosures and complete technical details and so I ask you if you would be willing to disclose your competitive edge or advantages to the unsavory politics of the fossils and the nukes or their special interest and your competitors? That is why the system is fatally flawed. You have to trust that heavily infiltrated ranks of state government aren't conduits to their "business as usual" fossil politics.
Finally, the farce of our commercial banking system is that when you propose and alternative to a "tax and spend" funding or financing you cut the strings of the politicos to say "no" their true means of asserting control. Our banks are threatened to pull deposits tied to jobs at fossil plants so as a result the banks can't seem to remember how to conduit the funds from the FED to the project that competes or obsoletes their existing loan portfolio to the IOUs. Ours is the rare exception that has the required investment grade and sub-investment grade collateral required to obtain non-recourse interim funding. The credit decision is not made unless and until the plant is up and running meaning proven. The banks can't begin to get their heads around any commercial transaction north of $5 million that isn't a car loan, house loan, boat loan or SBA small business loan without running into a severe conflict of interest.
When you drill down into BofA's claim that they have $20 billion for renewable you start to overcome the hype of a "green policy" that is mostly perception rather than reality. Mr. Skiver their top renewable contact can't provide info beyond their bank financing their own "green" headquarters above $50 million and the entire portfolio is $5 million or less to a few schools or small local wind projects with a local government political subdivision.
So, whether by default or the most ardent of conspiracies the "system" supports regional monopoly control by fossils and nukes. Those enterprises have gotten 40 years of tax credits, subsidies, sustained regional monopoly authority, and government loan guarantees. They self deal their RECs between their SOLAR or WIND LLC and their parent company and after 30 years they haven't even added the least of all improvement a maglev bearing upgrade for frictionless spinning of their generator and prime mover shaft to eliminate lubricants and up performance.
Mark Alexander
Respond to the editor.
