A CEO Vision For America's Energy Future

Feb 25: The Business Roundtable (BRT), an association of chief executive officers of leading U.S. companies, released a report entitled, Taking Action on Energy: A CEO Vision for America's Energy Future, a detailed, comprehensive national energy strategy to capitalize on U.S. strengths and accelerate economic growth and job creation. David Cote, Chairman and CEO of Honeywell International, Inc., and Chair of BRT's Energy and Environment Committee said, "America's energy economy is firing on all cylinders -- efficiency, renewable power, oil and gas production, and advanced coal and nuclear power technology. North American energy self-sufficiency is within reach, but the missing piece is an effective strategy to capitalize on U.S. advantages.Taking Action on Energy is that strategy."

    In Taking Action on Energy, CEOs, who lead major U.S. companies that operate in every sector of the economy -- and represent energy producers, consumers and technology suppliers -- offer a vision for America's energy future that is more affordable, more secure and more sustainable. John Watson, Chairman and CEO of Chevron Corporation said, "Driven by private sector innovation and investment, the United States is poised to regain its status as an energy superpower. The dramatic rise in U.S. oil and natural gas production is creating jobs and economic growth across America, but our ability to take full advantage of the historic opportunity in front of us depends upon the right policy framework."

    Andrew Liveris, Chairman and CEO of The Dow Chemical Company said, "Reliable, affordable energy makes the United States the location of choice for manufacturing. We have outlined a strategy to ensure America stays on top." Nicholas Akins, President and CEO of American Electric Power said, "America's electric power infrastructure has long delivered value to consumers and enhanced industrial competitiveness. To preserve that value, sound energy strategy must maintain fuel diversity for power generation, support investment in our nation's transmission system, provide a long-term solution for storing spent nuclear fuel and consider the economic consequences of energy and environmental regulation."

    In Taking Action on Energy, BRT CEOs call on Congress and the Administration to adopt policies that will enhance U.S. self-sufficiency, boost economic growth and promote environmental stewardship. The plan includes detailed and specific recommendations in each of four areas -- energy efficiency; traditional energy production; renewable energy production; and electric power generation, transmission and distribution -- including measures to:

• Foster innovation by sustaining public investments in a diverse portfolio of pre-commercial research and development (R&D) activities, including:
  • R&D on cost-effective technologies that have the potential to improve energy efficiency while diversifying energy sources;
  • Projects to demonstrate the commercial viability of carbon capture, utilization and storage, provided that such funding is offered for a finite timeframe and limited in scope; and
  • R&D and demonstration projects for pre-commercial renewable electricity generation and transportation fuels, with an emphasis on performance, emissions reductions and technology neutrality.
• Drive increased energy efficiency by:
  • Ensuring that state legislatures and public utility commissions consider policies that promote investment in cost-effective energy efficiency measures, and ensure that such investments are as profitable for utilities as generation and distribution assets;
  • Expanding the use of Energy Savings Performance Contracts (ESPCs) and Utility Energy Services Contracts (UESCs) in the federal government, as well as training and education for federal energy managers, policymakers and procurement/legal staff regarding the use and benefits of these contracts; and
  • Encouraging energy efficiency measures at the state level based on effective federal policy guidelines that can be cost-effectively implemented; and giving states the flexibility to account for local differences in regulatory approaches. 
• Improve access to promising energy resources by:
  • Increasing access to onshore and offshore federal lands to ensure reliable supplies of coal, oil and natural gas;
  • Streamlining the permitting and approval processes to expedite critical infrastructure projects;
  • Respecting the role that states have traditionally played in regulating oil and natural gas activity on non-federal lands, and ensuring that new regulations for federal lands are developed in consultation with states and are consistent with state regulations; and
  • Ensuring that EPA regulations are based on sound science, undergo thorough net cost-benefit analysis, and take into consideration the net cumulative impact these regulations have on energy costs, economic growth and job creation, while being protective of human health and the environment.
• Reform incentives for renewable power technology deployment by:
  • Providing wind-powered electricity generation with a smooth transition to an era of unsubsidized competitiveness by extending the wind production tax credit so that the benefit is gradually reduced and ultimately eliminated;
  • Ensuring that decisions regarding tax incentives for renewable resources are designed to address well-documented market inefficiencies, applied only to those fuels and technologies with a credible path to unsubsidized competitiveness and finite in duration and eventually phased out in a predictable fashion;
  • Accounting for regional variations in renewable energy resource availability when developing legislation and regulation; and
  • With respect to the renewable fuel standard, policymakers should consider the limitations of the current vehicle fleet, fuel distribution infrastructure and actual production capacity, and adopt targeted modifications as needed.
• Encourage accelerated modernization of the electric power sector by:
  • Carefully evaluating the timing and cumulative impact of EPA regulations on the electric utility industry and, as appropriate, modifying these regulations to ensure continued reliability, avoid unreasonable rate impacts, and maintain a diverse, market-driven portfolio of baseload electricity generation fuel options;
  • Devising a long-term solution to remove and manage nuclear spent fuel;
  • Providing transparent rate incentives for cost-effective upgrades to the nation's transmission infrastructure in order to facilitate grid modernization and support competitive wholesale electricity markets;
  • Improving coordination among federal agencies, such as the Federal Energy Regulatory Commission and U.S. Department of Energy (DOE), state commissions and other stakeholders, to address the complexity, unpredictability and inefficiency of transmission planning, siting and cost allocation decisions for interstate projects;
  • Supporting DOE and National Institute of Standards and Technology efforts to accelerate and coordinate the development of "smart grid" standards; and
  • Requiring actionable and timely cybersecurity threat intelligence sharing from government to critical infrastructure owners and operators.   

    The BRT is an association of chief executive officers of leading U.S. companies with over $6 trillion in annual revenues and more than 14 million employees. Our companies generate an estimated $420 billion in sales for small and medium-sized businesses annually. BRT members comprise nearly a third of the total value of the U.S. stock market and invest more than $150 billion annually in research and development -- nearly half of all private U.S. R&D spending. BRT companies pay $163 billion in dividends to shareholders and give nearly $9 billion a year in combined charitable contributions.

    Access a release from BRT with links to summaries of the complete report and each sector recommendations (click here). Access the complete 76-page report (click here). [#Energy]

 

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Business Coalition Appeals E15 Use To Supreme Court

Feb 21: The American Petroleum Institute (API) and other groups announced that they have appealed to the U.S. Supreme Court, a D.C. Circuit Court decision rejecting a challenge to EPA's grant of partial waivers for use of the ethanol-gasoline blend, E15. On January 15, 2013, D.C. Circuit, denied an en banc reconsideration [See WIMS 1/16/13] of Grocery Manufacturers Association v. U.S. EPA (consolidated with a number of other cases) and thus the original 2-1 decision was upheld. That decision ruled "that no petitioner has standing to bring this action, we dismiss all petitions for lack of jurisdiction." [See WIMS 8/17/12].

 

    API's group director for downstream and industry operations Bob Greco told reporters at a press briefing teleconference, "We've filed this petition because the D.C. Circuit incorrectly concluded that none of the 17 petitioners had standing to challenge the E15 partial waivers -- not the engine manufacturers whose products will run on this new fuel blend, not the petroleum industry who must undertake massive infrastructure changes to accommodate the blend and meet the renewable fuel mandate, and not the food producers who now face significantly greater competition in the commodities market for corn, the conventional feedstock for ethanol.

    "Had EPA stayed within its statutory authority and followed proper procedures, it would have waited until ongoing E15 testing on engines and fuel systems was completed before allowing the use of E15. Then it would have discovered that E15 is not safe for millions of vehicles now on the road. Although we hope the court will resolve the E15 problem, we also believe our experience here represents only one of many underlying problems with the Renewable Fuel Standard, so we are calling on Congress to repeal the program."

 

    The Grocery Manufacturers Association (GMA), Executive Vice President for Government Affairs Louis Finkel, a part of the coalition petitioning the Supreme Court said, "The procedural grounds on which the DC Circuit Court based its split decision to dismiss our petition are unfounded. All the while, the significant issues at the heart of our case continue to go unanswered. In the end, it's consumers who will pay the heaviest toll for the court's decision, as it cleared the way for an expansion of misguided food–to-fuel policies at a time when Americans can least afford it. 

    "The DC Circuit's decision came as the most devastating drought the U.S. had experienced in 50 years was driving the price of corn up nearly 40 percent. The decision effectively increased demand for a crop that was already in extremely short supply, thanks to Mother Nature and an unworkable Renewable Fuels Standard (RFS) policy. A few short months later, the Environmental Protection Agency denied the petitions of eight governors asking the agency to waive in whole or in part the RFS mandate requirements in response to the drought-induced low level of stocks.

    "If the lower court and the regulating agency are unable or unwilling to provide relief under these most extreme circumstances, it's clear that further action is needed to pursue responsible energy policies that don't pit our nation's energy needs against food security for families. That is why GMA is elevating this issue to the highest court in the land. Implementation of the RFS has had a profound negative impact on the economy and the structure of markets in energy, agricultural commodities and food manufacturing. The application of the RFS to allow E15 into the market will only exacerbate a situation that is already having a negative impact on consumers and the economy.

 

    "Corn acreage increased from nearly 82 million acres planted in 2005 to more than 96 million acres in 2012. By comparison, the acreage planted with the next two biggest crops, soybean and wheat, stayed flat. From 2005 through 2011, the price of: corn rose by $4.05; soybean rose by $6.85; and wheat rose by $4.08. By comparison, in the previous six year period, commodities rose only modestly. These increased acres planted should provide some price relief by adding additional supply. However, any gains in supply are largely offset by the fact that 40 percent of production acreage planted is devoted to ethanol production. 

 

    "The available supply and price of corn and other affected commodities has an enormous impact on the cost inputs to food production. As hard as food and beverage companies work to deliver safe, nutritious food to consumers at affordable prices, the laws of economics dictate that consumers will feel the effects of these higher input costs at the retail level at a time when many families are struggling. The original suit filed argued that EPA had exceeded its authority and violated the law when approving the use of E15; but more importantly, it put consumers at risk of food insecurity. These facts have not changed. We continue to support this position and are now looking to the Supreme Court to overturn the decision of the lower court to ensure that GMA and the coalition's arguments are heard."

 

    Other groups participating in the legal action include: American Meat Institute; National Chicken Council; National Council of Chain Restaurants of the National Retail Federation; North American Meat Association; National Pork Producers Council; National Turkey Federation;and Snack Food Association.

 

    Bob Dinneen, president and CEO of the Renewable Fuels Association (RFA), issued a short reply saying, "Good luck with that. We now know why gas prices keep going up and up -- to fund unnecessary Big Oil lawsuits to protect their monopoly on the fuel market. I wonder if food prices will spike as well to cover the cost of this Supreme Court challenge?"

 

    Access a release from API and link to the lengthy teleconference transcript for more details (click here). Access the GMA release (click here). Access the RFA response (click here). Note: See the WIMS links above for legal and regulatory background. [#Energy/E15, #Energy/RFS]

 

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Final ROD & IAP/EIS For National Petroleum Reserve In Alaska

Feb 21: Outgoing Secretary of the Interior Ken Salazar signed the Record of Decision (ROD) for the National Petroleum Reserve in Alaska (NPR-A). The final action allows for the development of 72 percent of the estimated economically recoverable oil in the nearly 23-million-acre Reserve, while protecting the vital subsistence resources of Alaska Natives and the habitat of world-class wildlife populations. Salazar said, "The balanced approach under this plan is the result of extensive local input and will help guide the responsible production and transport of the substantial oil and gas resources in and around the Reserve. This comprehensive plan will allow us to continue to expand our leasing in the NPR-A, as has happened over the last three years, while protecting the outstanding and unique resources that are critically important to the culture and subsistence lifestyle of Alaska Natives and our nation's conservation heritage."

    The Record of Decision addresses two key issues that Secretary Salazar identified for special attention when he released the final Environmental Impact Statement for the NPR-A Integrated Activity Plan. First, the ROD provides explicit confirmation that potential pipelines carrying oil or gas from operations in the Chukchi and Beaufort Seas can be constructed through the NPR-A. Second, following additional consultations with North Slope communities, the Record of Decision requires that BLM establish an "NPR-A Working Group" that will include representatives of North Slope tribal entities, Native corporations and local governments.

    The NPR-A Working Group will provide input on the full range of management issues and possible future development in the NPR-A, including pipelines and related oil and gas infrastructure development. The Working Group also will be a forum to gather additional scientific information and traditional knowledge about wildlife populations and needs, and it can inform potential adjustments to the boundaries of special areas including, for example, potential future adjustments to the southernmost boundary of the Teshekpuk Lake special area. The Plan itself is consistent with the Congressional intent that oil and gas leases be offered in the NPR-A while providing significant protections for the subsistence resources of Alaska Native residents of the area and the Reserve's extensive wildlife and recreational values. 

    After receiving more than 400,000 public comments and following two days of meetings and visits with North Slope leaders in August 2012, Salazar announced the Preferred Alternative, which was adopted by the ROD that he signed today. The ROD includes the creation of the Peard Bay Special Area and enlarges the Teshekpuk Lake and Utukok River Uplands Special Areas, expanding Special Areas in the NPR-A from 8.3 million acres to 13.35 million acres.

    The Bureau of Land Management (BLM) has estimated that the NPR-A lands made available for development under this plan contain nearly three-fourths of NPR-A's estimated economically recoverable oil and over half of the estimated economically recoverable gas. The plan will allow for access to oil and gas resources on 11.8 million acres, which are estimated to hold 549 million barrels of economically recoverable oil and 8.7 trillion cubic feet of economically recoverable natural gas.

    Following President Obama's directive in May 2011 that annual oil and gas lease sales be conducted in the NPR-A, BLM offered three million acres in December 2011. That sale generated 17 winning bids covering more than 120,000 acres. Another lease sale on November 7, 2012, offered 4.5 million acres and received 14 winning bids on 160,088 total acres. There are now 191 authorized oil and gas leases in the NPR-A, encompassing 1.5 million acres. To date, only exploratory drilling has occurred, but in 2011, with the assistance of the President's Interagency Working Group on Coordination of Domestic Energy Development and Permitting in Alaska, the Corps of Engineers issued permits to ConocoPhillips that will allow for the first commercial oil and gas production in the Reserve.

    The ROD makes all lands along the Chukchi Sea coast, most of the lands along the Beaufort Sea coast, and other lands available for application for a wide range of route options for pipelines and other infrastructure that would support offshore development. The decision concurrently protects a wide range of resources, including critical areas for sensitive bird populations from all seven continents and for the roughly 400,000 caribou found in the Teshekpuk Lake and Western Arctic Caribou Herds. Subsistence users in more than 40 villages in northwest Alaska rely on these caribou herds.

    The plan, which is detailed in the Final Integrated Activity Plan and Final Environmental Impact Statement (Final IAP/EIS) for the NPR-A, is the first management plan that covers the entire Reserve, including 9.2 million acres in the southwest area. Previous plans covered the northeast and northwest planning areas only. The Final IAP/EIS for the NPR-A, released in December 2012, was developed through extensive consultations that considered the viewpoints of Alaskans who live in the region, tribal governments, the State of Alaska, industry, environmental organizations and other stakeholders and federal partners. The BLM hosted seven public meetings and Alaska National Interest Lands Conservation Act subsistence hearings in North Slope villages. The BLM also held meetings in Fairbanks and Anchorage. Also, following release of the Final IAP/EIS, the BLM conducted meetings in communities on the North Slope to receive recommendations on future ongoing outreach efforts with communities located within or near the NPR-A.

    Environmental and conservation groups applauded the plan and said they look forward to continuing to work with the DOI to refine needed protections for key special areas within the Reserve. Cindy Shogan, Executive Director, Alaska Wilderness League said,. "We thank the Department of the Interior for protecting special areas within the National Petroleum Reserve-Alaska. The Department of the Interior has crafted a plan that protects and recognizes the vital role of subsistence, scenic and recreational values, and unique wildlife values. The Reserve is home to our most iconic wildlife, like caribou, muskoxen, grizzly bears and beluga whales. Thank you for protecting this special place for future generations."

    Martin Hayden, Vice President, Policy and Legislation for Earthjustice said, "The plan is a huge step for conservation of the Western Arctic, an area increasingly stressed by climate change, and provides critical protections for key lands in the Reserve and the wildlife dependent on it, including migratory birds from around the world, caribou, bears, wolves, beluga whales, and walrus." Jamie Williams, president of The Wilderness Society said, "We are grateful to the Obama administration for a fair and thoughtful decision that balances conservation, Alaska Natives' needs for subsistence resources, and the nation's demand for energy. This strategy protects incredibly valuable wildlife habitat for caribou, bears and migratory waterfowl in the Western Arctic, yet still allows industry access to the majority of economically recoverable oil in the reserve. It's a plan that meets the needs of all Americans."

    Access a lengthy release from DOI with links to related information (click here). Access the NPR-A ROD and related documents (click here). Access a release from Earthjustice with comments from many organizations (click here). [#Energy/NPR-A, #Land, #Wildlife, #Water]

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International Climate & Clean Air Coalition 1st Year Anniversary

Feb 20: The Climate and Clean Air Coalition (CCAC) -- a global movement to significantly reduce emissions of black carbon, methane and other substances known as "short-lived climate pollutants" (SLCPs) - celebrates its first anniversary today [See WIMS 1/15/13]. The Coalition, comprised of more than 50 partners, has been collaboratively spearheading international efforts to raise awareness of the major environmental and economic benefits that can be achieved by lowering emissions of SLCPs alongside catalyzing action.

    Since its launch in February 2012 [See WIMS 2/16/12], the Coalition has grown from 7 partners to more than 50, currently consisting of Australia, Bangladesh, Canada, Chile, Colombia, Cote d'Ivoire, Denmark, Dominican Republic, Ethiopia, Finland, France, Germany, Ghana, Israel, Italy, Japan, Jordan, Mexico, Netherlands, Nigeria, Norway, Republic of Korea, Republic of Maldives, Sweden, Switzerland, United Kingdom, and United States, as well as other key parties like the European Commission, the UN Environmental Programme, the World Bank, and the UN Development Programme. The Coalition expresses support for scaled-up actions across a range of economic sectors, including transport, oil and gas, and waste, to ensure reductions of emissions from SLCPs.   

    According to studies by the United Nations Environment Programme (UNEP), fast action on black carbon and methane have the potential to slow global temperature rise by up to 0.5°C by 2050, reduce air pollution-related deaths by as much as 2.4 million, and avoid around 30 million tonnes of crop losses annually. Scientific assessments indicate that the near term benefits in places like the Arctic and on glaciers in mountain regions could be even higher.

    UN Under Secretary-General and UNEP Executive Director Achim Steiner said, "The success of the CCAC shows that more and more countries are now recognizing the multiple, cost-effective benefits that swift, coordinated action on SLCPs can deliver. UNEP has partnered with researchers for over ten years to bring the science of short-lived climate pollutants to the fore. This research clearly shows that action on SLCPs can deliver important near-term climate gains, contribute to the achievement of internationally-agreed development goals, and support the transition to a green economy."

    Among its many activities, the CCAC is working closely with an initial group of 10 major cities including Rio de Janeiro, Lagos, Stockholm, Accra, and Tokyo to accelerate methane reductions from landfills and black carbon or 'soot' from burning wastes. It has also joined forces with the Partnership for Clean Fuels and Vehicles to reduce black carbon emissions or 'smoke' from heavy duty vehicles such as trucks by accelerating the introduction of low sulfur fuels and tighter emission standards in Asia and Latin America.

    The Coalition is also coordinating actions to address hydrofluorocarbons (HFCs) -- commonly found in air conditioners and refrigerators -- which are a major short-lived climate pollutant. While HFC emissions currently represent less than 1 per cent of current total greenhouse gases their warming impact is particularly strong and, if left unchecked, they could account for 7 to 19 per cent of carbon dioxide emissions by 2050. The CCAC hosted the second International Technology Forum in 2012 to showcase a range of climate-friendly alternatives to HFCs for use in refrigeration and other kinds of equipment.

    Other CCAC initiatives are focusing on reducing emissions from brick production and assisting countries in developing national action plans to prioritize action for SLCP reductions. The Coalition underlines the fact that actions to reduce SLCPs must be complemented by immediate deep and persistent cuts in carbon emissions if global mean temperature rise over the 21st century is to be held below 2°C. UNEP's 2011 report Near-Term Climate Protection and Clean Air Benefits outlines 16 measures to be implemented immediately in order to ensure significant emissions reduction of SLCPs.

    Access a release from UNEP with extensive links including the 2011 report, a chronology of CCAC events this past year and a video (click here). Access the CCAC website for complete information (click here). [#Climate, #Air]

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35-40,000 Protest KXL At DC "Forward On Climate" Rally

Feb 17: During President's Day weekend, some 35,000 - 40,000 people marched to the President's doorstep (although he wasn't there) to support immediate action to contain climate change and urge the President to deny permits for the Keystone XL pipeline (KXL). In a release from the sponsoring organizations they indicate that people from more than 30 states across the country whose land, homes and health are being threatened by the climate crisis, as well as students, scientists, indigenous community members and many others participated in this largest climate rally in U.S. history.

    350.org founder Bill McKibben, one of the major sponsors of the event said, "For 25 years our government has basically ignored the climate crisis: now people in large numbers are finally demanding they get to work. We shouldn't have to be here -- science should have decided our course long ago. But it takes a movement to stand up to all that money."

    Rally participants called on President Obama to reject the Keystone XL tar sands pipeline and put limits on dangerous carbon pollution from the nation's dirtiest power plants. They said much of President Obama's legacy will rest squarely on his response, resolve, and leadership in fighting the climate crisis. Rally participants are looking for him to move forward on his recent State of the Union address declaration when he said, "For the sake of our children and our future, we must do more to combat climate change."

    Michael Brune, Executive Director of the Sierra Club said, "Twenty years from now on President's Day, people will want to know what the president did in the face of rising sea levels, record droughts and furious storms brought on by climate disruption. President Obama holds in his hand a pen and the power to deliver on his promise of hope for our children. Today, we are asking him to use that pen to reject the Keystone XL tar sands pipeline, and ensure that this dirty, dangerous, export pipeline will never be built."

    The organizations said the Keystone XL tar sands project would pipe some of the dirtiest oil on the planet through the breadbasket of America to be shipped overseas through the Gulf of Mexico. It would be a disaster for our climate, producing tar sands crude that kicks out two or three times as much carbon pollution as producing conventional crude oil.

    Chief Jacqueline Thomas, immediate past Chief of the Saik'uz First Nation in British Columbia and co-founder Yinka Dene Alliance (People of the Earth) said, "The Yinka Dene Alliance of British Columbia is seeing the harm from climate change to our peoples and our waters. We see the threat of taking tar sands out of the Earth and bringing it through our territories and over our rivers. The harm being done to people in the tar sands region can no longer be Canada's dirty secret. We don't have the billions of dollars that industry has. But we do have our faith that people will do the right thing to protect Mother Earth. The Forward on Climate Rally shows that we are not alone in the fight to stop tar sands expansion and tackle climate change."

    Van Jones, Natural Resources Defense Council (NRDC) Trustee and President of Rebuild the Dream said, "This President has the power to achieve the single biggest carbon reduction ever, by holding our biggest carbon polluters -- dirty power plants -- accountable for what they dump into the air. Cleaning up this pollution and using more clean energy will provide jobs to thousands of Americans, save families real money when it comes to electricity bills and, most important, will make a real difference in our health and the health of our children."

    The groups indicated that the historic rally to call for climate leadership reflects Americans' recognition of the threats of climate change and their support for meaningful action now. The groups cited a Public Policy Polling (PPP) immediately after the President's State of the Union address indicating that 65 percent of Americans think that climate change is a serious problem and a substantial majority of Americans support President Obama using his authority to reduce its main cause, dangerous carbon pollution. The "Forward on Climate" rally was organized by 350.org; Sierra Club, Hip Hop Caucus; Natural Resources Defense Council and many other organizations.

    Other speakers included: the Rev. Lennox Yearwood, Hip Hop Caucus President and CEO; Sen. Sheldon Whitehouse (D-RI); Crystal Lameman, Beaver Lake Cree First Nation; Maria Cardona, Latinovations Founder, Dewey Square Group Principal; and Tom Steyer, Investor and founder of the Center for the Next Generation.

 

        As WIMS has pointed out before [See WIMS 1/24/13], the recent approval of the Nebraska Governor on an alternate routing, combined with intense and growing Congressional political pressure to approve KXL is setting the stage for a highly controversial decision by the President and his Administration -- particularly in light of the President's Inaugural commitment to address the issue of climate change [See WIMS 1/22/13] followed up by an even stronger commitment in this State of the Union address [See WIMS 2/13/13]. Additionally, former Senator John Kerry (D-MA), the new Secretary of State, who has primary authority over reviewing and recommending the KXL Presidential permits, is a strong advocate for addressing the climate change issue. Kerry said previously that one of his greatest disappointments as a Senator was not getting a climate change bill passed. On February 6, sixty leading environmental, conservation, development, faith-based, and social justice organizations urged Kerry to reject any new or expanded infrastructure for tar sands oil, starting with the Keystone XL pipeline [See WIMS 2/6/13].

 

    Access a release from the organizations (click here). Access the ForwardOnClimate website for complete background, videos and images from the rally (click here). [#Climate, #Energy/KXL]

 

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House Hearing On States Role In Environmental Protection

Feb 15: The House Energy & Commerce Committee, Subcommittee on Environment and the Economy, Chaired by Representative John Shimkus (R-IL), kicked off its agenda for the 113th Congress with a hearing on "The Role of the States in Protecting the Environment Under Current Law." Witnesses featured representatives from state offices that oversee groundwater, drinking water, oil and gas, and solid and hazardous wastes. While speaking from their state perspectives, the witnesses also represented major associations including: the Environmental Council of the States; the Association of State Drinking Water Administrators; the Association of State and Territorial Solid Waste Management Officials; the Ground Water Protection Council; the Interstate Oil and Gas Compact Commission; the National Caucus of Environmental Legislators; and the National League of Cities.

 

    Chairman Shimkus convened the hearing to highlight the role state officials play in protecting the environment and public health under several of the Federal laws in the subcommittee's jurisdiction, including the Safe Drinking Water Act (SDWA), the Resource Conservation and Recovery Act (RCRA), and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

 

    Chairman Shimkus said, "This hearing will help raise awareness and set the stage for future discussions we are going to have on environmental protection. Many of us get caught up with what the U.S. EPA thinks or what it can do and fail to focus on the states and what they can and must do. The states are by no means 'junior regulators' or the minor leagues of environmental protection. Rather, their plate is twice as full. To carry out federal environmental law, states have a lot of delegated authority. But states also have their own protective laws. Often, beyond anything the federal government has asked."

 

    The witnesses described their first-hand experiences as state and local regulators and highlighted the work states are already doing under existing law to protect the environment. Some testimony included for example: Arkansas Department of Environmental Quality Director Teresa Marks, testifying on behalf of the Environmental Council of States, noted, "State agencies conduct over 90 percent of the environmental inspections, enforcement, and environmental data collection, and issue a similar amount of all the environmental permits." She explained that in many instances, due to proximity and expert understanding of localities, states are better equipped to conduct effective regulation, saying, "The states, having more familiarity with their regulated industries and being located in closer proximity thereto, generally provide timelier compliance assistance and response to citizen concerns and complaints."

 

    Representing the Michigan Department of Environmental Quality (MDEQ) Office of Oil, Gas, and Minerals, and also the Interstate Oil and Gas Compact Commission, Harold Fitch explained that states often have greater flexibility in implementing regulations, stating, "Our regulatory structures are adaptable in addressing new technologies and new concerns, and they yield consistent results tailored to our specific needs and priorities."  Describing the success state regulators have had in protecting the environment, Fitch highlighted Michigan's oversight of hydraulic fracturing and said, "Hydraulic fracturing was first used in Michigan in 1952. Since then, we have had over 12,000 wells hydraulically fractured and there have been no instances of environmental contamination related to the practice."

 

    Chairman Shimkus described another example where the states have demonstrated strong regulatory leadership -- Maryland's management of coal ash within its state. He said, "The state did not sit by powerless. Rather, in December 2008 the Maryland Department of the Environment issued one of the more robust sets of coal ash rules in the country. Maryland is not the only state, Pennsylvania and Wisconsin have demonstrated strong programs that are serious, flexible, and successful." Full Committee Chairman Fred Upton (R-MI), added, "It is important to understand the important role states play in protecting the environment. One thing we already know is that Washington does not always know best."

 

    Ranking Member Henry Waxman (D-CA) explained in an opening statement that the state-Federal model includes EPA setting minimum standards that states can exceed if they so choose. Implementation can be delegated to states on a showing that they have requirements in place that are at least as stringent as the federal floor. He said, "As we will hear from the panel, this model has worked. States have received delegation for over 96% of the environmental programs that can be delegated." He pointed out that, "Despite these successes, there have been recent proposals to abandon the proven models and abdicate responsibilities to the states. One of the most immediate examples is the coal ash legislation from last Congress."

 

    Rep. Waxman also highlighted, "As we hear from state regulators about the good work they are doing, we should be mindful of the serious threat the sequester and the Republican budget pose to this proven model of environmental protection. Without federal technical assistance and funding, states may be unable to maintain their delegated programs. If the programs are handed back to EPA, EPA may not have the resources to take on this added implementation. . . According to EPA, if sequestration goes into effect, there will be nearly 300 fewer cleanups under the leaking underground storage tank program. There could be a 1,000 fewer inspections to protect communities from toxic air pollution and other pollution that can cause illnesses and death. And essential services to industry like EPA's certification of auto engines for emissions standards could be curtailed."

 

    Access a Republican release on the hearing (click here). Access the Republican website for the hearing with a background memo, opening statements, and witness testimony (click here). Access the Democratic website for the hearing with an opening statement, testimony and a webcast (click here). [#All, #MIAll]

 

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GAO Adds Climate Change To "High-Risk" Government Operations

Feb 14: The Government Accountability Office (GAO) has added climate change to its list of government operations that it identifies as high risk. In a new report -- GAO's 2013 High-Risk Series An Update -- and testimony before the Committee on Oversight and Government Reform, House of Representatives,  GAO indicates that, "Climate change creates significant financial risks for the federal government, which owns extensive infrastructure, such as defense installations; insures property through the National Flood Insurance Program; and provides emergency aid in response to natural disasters. The federal government is not well positioned to address the fiscal exposure presented by climate change, and needs a government wide strategic approach with strong leadership to manage related risks." GAO indicates further:

"Climate change poses risks to many environmental and economic systems -- including agriculture, infrastructure, ecosystems, and human health -- and presents a significant financial risk to the Federal government. The United States Global Change Research Program (USGCRP) has observed that the impacts and costliness of weather disasters will increase in significance as what are considered 'rare' events become more common and intense due to climate change [See WIMS 1/14/13]. Among other impacts, climate change could threaten coastal areas with rising sea levels, alter agricultural productivity, and increase the intensity and frequency of severe weather events such as floods, drought, and hurricanes.

"Weather-related events have cost the nation tens of billions of dollars in damages over the past decade. For example, in 2012, the administration requested $60.4 billion for Superstorm Sandy recovery efforts. These impacts pose significant financial risks for the federal government, which owns extensive infrastructure, insures property through federal flood and crop insurance programs, provides technical assistance to state and local governments, and provides emergency aid in response to natural disasters. However, the federal government is not well positioned to address this fiscal exposure, partly because of the complex, cross-cutting nature of the issue. Given these challenges and the nation's precarious fiscal condition, we have added limiting the federal government's fiscal exposure to climate change to our 2013 list of high-risk areas.

"Climate change adaptation -- defined as adjustments to natural or human systems in response to actual or expected climate change -- is a risk-management strategy to help protect vulnerable sectors and communities that might be affected by changes in the climate. For example, adaptation measures may include raising river or coastal dikes to protect infrastructure from sea level rise, building higher bridges, and increasing the capacity of storm water systems. Policymakers increasingly view climate change adaptation as a risk-management strategy to protect vulnerable sectors and communities that might be affected by changes in the climate, but, as we reported in 2009, the federal government's emerging adaptation activities were carried out in an ad hoc manner and were not well coordinated across federal agencies, let alone with state and local governments.

"The federal government has a number of efforts underway to decrease domestic greenhouse gas emissions, but decreasing global emissions depends in large part on cooperative international efforts. Further, according to the National Research Council [See WIMS 1/9/12] and USGCRP, greenhouse gases already in the atmosphere will continue altering the climate system for many decades. As such, the impacts of climate change can be expected to increase fiscal exposure for the federal government in many areas."

    GAO concludes that the increasing fiscal exposure for the Federal government calls for more comprehensive and systematic strategic planning including, but not limited to, the following:

• A government-wide strategic approach with strong leadership and the authority to manage climate change risks that encompasses the entire range of related federal activities and addresses all key elements of strategic planning.
• More information to understand and manage Federal insurance programs' long-term exposure to climate change and analyze the potential impacts of an increase in the frequency or severity of weather-related events on their operations.
• A government-wide approach for providing: (1) the best available climate-related data for making decisions at the state and local level; and (2) assistance for translating available climate-related data into information that officials need to make decisions.
• Potential gaps in satellite data need to be effectively addressed.
• Improved criteria for assessing a jurisdiction's capability to respond and recover from a disaster without federal assistance, and to better apply lessons from past experience when developing disaster cost estimates.

    Representative Elijah Cummings, Ranking Member of the House Committee on Oversight and Government Reform, sent a letter to Chairman Darrell Issa (R-CA) requesting that the Committee hold a series of hearings in light of what he called "the historic announcement that the nonpartisan experts at the Government Accountability Office (GAO) for the first time have added climate change to their High Risk Report warning about the most pressing challenges facing the nation and the federal government."

 

    Representative Cummings said, "GAO's landmark decision to list climate change in its High Risk Report is a critical wake-up call for Congress and the country. Although some may continue to disregard the science, this report warns that climate change is real, it is here now, and the economic consequences to our nation will be catastrophic if Congress ignores it any longer. It is my hope that Chairman Issa agrees to convene oversight hearings to examine GAO's findings and recommendations."

 

    Chairman Issa issued a brief statement saying, "The GAO's latest High Risk List includes seventeen items that have been on the list more than a decade, and six that have been on the list since it began in 1990. The inability of government to effectively address ongoing concerns about health care and insurance programs that have become fixtures on the high risk list, as well as new additions like our government's ability to prepare for and respond to future weather events and concerns about the solvency of the Federal Housing Agency, are all reminders that taxpayers deserve better from their government."

 

    Access the GAO testimony (click here). Access the complete GAO 275-page report which includes much more on the climate change risk (click here). Access a short video on GAO climate change risks (click here). Access more information from GAO on better managing climate change risks (click here). Access a video of the GAO testimony at the Oversight Committee hearing (click here). Access a release from Rep. Cummings with a link to his letter to Rep. Issa and his opening statement at the hearing (click here). Access the statement from Rep. Issa (click here). [#Climate]

 

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President Highlights Climate, Energy & Infrastructure In SOTU Address

Feb 12: President Obama, built on his Inaugural address, by adding a few more details in his State of the Union (SOTU) address to Congress and the nation. He spent a fair amount of time discussing his vision for energy development, climate change and infrastructure. On climate change he urged Congress to develop a market-based solution to climate change, saying if they don't he will use "executive actions" to address the issue. He said, his proposals "are fully paid for and fully consistent with the budget framework both parties agreed to just 18 months ago.  Let me repeat -- nothing I'm proposing tonight should increase our deficit by a single dime.  It is not a bigger government we need, but a smarter government that sets priorities and invests in broad-based growth. It is not a bigger government we need, but a smarter government that sets priorities and invests in broad-based growth.  Specifically, he said:

". . .Now is not the time to gut these job-creating investments in science and innovation.  Now is the time to reach a level of research and development not seen since the height of the Space Race.  We need to make those investments. 

  

"Today, no area holds more promise than our investments in American energy.  After years of talking about it, we're finally poised to control our own energy future.  We produce more oil at home than we have in 15 years. We have doubled the distance our cars will go on a gallon of gas, and the amount of renewable energy we generate from sources like wind and solar -- with tens of thousands of good American jobs to show for it.  We produce more natural gas than ever before -- and nearly everyone's energy bill is lower because of it.  And over the last four years, our emissions of the dangerous carbon pollution that threatens our planet have actually fallen.

 

"But for the sake of our children and our future, we must do more to combat climate change. Now, it's true that no single event makes a trend.  But the fact is the 12 hottest years on record have all come in the last 15.  Heat waves, droughts, wildfires, floods -- all are now more frequent and more intense.  We can choose to believe that Superstorm Sandy, and the most severe drought in decades, and the worst wildfires some states have ever seen were all just a freak coincidence.  Or we can choose to believe in the overwhelming judgment of science -- and act before it's too late.

 

"Now, the good news is we can make meaningful progress on this issue while driving strong economic growth.  I urge this Congress to get together, pursue a bipartisan, market-based solution to climate change, like the one John McCain and Joe Lieberman worked on together a few years ago.  But if Congress won't act soon to protect future generations, I will. I will direct my Cabinet to come up with executive actions we can take, now and in the future, to reduce pollution, prepare our communities for the consequences of climate change, and speed the transition to more sustainable sources of energy.

 

"Four years ago, other countries dominated the clean energy market and the jobs that came with it.  And we've begun to change that.  Last year, wind energy added nearly half of all new power capacity in America.  So let's generate even more.  Solar energy gets cheaper by the year -- let's drive down costs even further. As long as countries like China keep going all in on clean energy, so must we.

 

"Now, in the meantime, the natural gas boom has led to cleaner power and greater energy independence.  We need to encourage that.  And that's why my administration will keep cutting red tape and speeding up new oil and gas permits. That's got to be part of an all-of-the-above plan.  But I also want to work with this Congress to encourage the research and technology that helps natural gas burn even cleaner and protects our air and our water.

 

"In fact, much of our new-found energy is drawn from lands and waters that we, the public, own together.  So tonight, I propose we use some of our oil and gas revenues to fund an Energy Security Trust that will drive new research and technology to shift our cars and trucks off oil for good.  If a nonpartisan coalition of CEOs and retired generals and admirals can get behind this idea, then so can we.  Let's take their advice and free our families and businesses from the painful spikes in gas prices we've put up with for far too long.

 

"I'm also issuing a new goal for America:  Let's cut in half the energy wasted by our homes and businesses over the next 20 years. We'll work with the states to do it.  Those states with the best ideas to create jobs and lower energy bills by constructing more efficient buildings will receive federal support to help make that happen.

 

"America's energy sector is just one part of an aging infrastructure badly in need of repair.  Ask any CEO where they'd rather locate and hire -- a country with deteriorating roads and bridges, or one with high-speed rail and Internet; high-tech schools, self-healing power grids.  The CEO of Siemens America -- a company that brought hundreds of new jobs to North Carolina -- said that if we upgrade our infrastructure, they'll bring even more jobs.  And that's the attitude of a lot of companies all around the world.  And I know you want these job-creating projects in your district.  I've seen all those ribbon-cuttings.  

 

"So tonight, I propose a "Fix-It-First" program to put people to work as soon as possible on our most urgent repairs, like the nearly 70,000 structurally deficient bridges across the country. And to make sure taxpayers don't shoulder the whole burden, I'm also proposing a Partnership to Rebuild America that attracts private capital to upgrade what our businesses need most:  modern ports to move our goods, modern pipelines to withstand a storm, modern schools worthy of our children. Let's prove that there's no better place to do business than here in the United States of America, and let's start right away.  We can get this done. . ."

    The Republican response to the SOTU, delivered by Senator Marco Rubio (R-FL) contained no mention of climate change. The response stated, "One of the best ways to encourage growth is through our energy industry. Of course solar and wind energy should be a part of our energy portfolio. But God also blessed America with abundant coal, oil and natural gas. Instead of wasting more taxpayer money on so-called "clean energy" companies like Solyndra, let's open up more federal lands for safe and responsible exploration. And let's reform our energy regulations so that they're reasonable and based on common sense. If we can grow our energy industry, it will make us energy independent, it will create middle-class jobs and it will help bring manufacturing back from places like China."

 

    Both the Speaker of the House, John Boehner (R-OH) and the Senate Minority Leader, Mitch McConnell (R-KY) responded negatively to the President's address. Speaker Boehner said in part, "Four years after the president first addressed a joint session of Congress, Americans are still asking, 'where are the jobs?'   Tonight, he offered them little more than more of the same 'stimulus' policies that have failed to fix our economy and put Americans back to work. We cannot grow the middle class and foster job creation by growing government and raising taxes. . ." Senator McConnell said, "To me at least, the occasion cried out for bold and courageous leadership from a re-elected President who has run his last campaign it called for a President who was willing to stare down America's challenges, reject the easy choices, and step outside his political comfort zone -- to unite a deeply divided public behind a common goal. Sadly, history will record no such moment. . . Following four years of this President's unwillingness to challenge liberal dogma, we got more of the same. . ."

 

    The U.S. Chamber of Commerce President and CEO Thomas J. Donohue issued a statement saying in part, "The president's return to a focus on jobs and growth is overdue and we welcome his call for immigration reform and trade expansion. The question is whether the totality of his agenda is designed to grow our economy or simply to grow the government. More spending, higher taxes, and massive federal rule-making will not put Americans back to work or stop the slide of middle-class incomes. To revive our economy, restore confidence, and put millions of unemployed Americans back to work, jobs and growth cannot be an occasional priority, it must be the top priority at all times. . ."

 

    The American Petroleum Institute (API) President and CEO Jack Gerard commented saying, "President Obama recognized the oil and natural gas industry as a robust economic engine that is investing in American jobs, generating billions of dollars for the government each year, and making our country more energy secure. Even with the aggressive expansion of renewable and alternative energy, oil and natural gas will continue to provide the majority of the energy necessary to heat our homes, run our businesses, and fuel our cars for decades to come. We're going to need all sources of energy to fuel a growing economy. Unfortunately, 83 percent of the land and offshore areas controlled by the federal government are still off-limits to oil and natural gas development. . ."

   

    Michael Brune, Sierra Club Executive Director issued a statement saying, "As the president put it tonight, we must act on the climate crisis 'before it's too late.' We couldn't agree more. . . we applaud his vow to prioritize innovative climate solutions, including  investments in job-producing solar and wind energy as well as a focus on energy and fuel efficiency. These are critical steps forward in the fight against climate disruption, but that progress would be rolled back by more destructive oil drilling and gas fracking, and the burning of toxic tar sands. . ."

 

    Frances Beinecke, president of the Natural Resources Defense Council (NRDC) said, "The president has a full box of tools to strike back at climate chaos. The best tool he has is the Clean Air Act. It gives him the authority to reduce the carbon pollution from our dirtiest power plants, the single greatest threat to our climate future. That will take presidential leadership. Americans are counting on it -- and that's what the president delivered tonight. The president also laid out an assertive agenda for reducing dangerous carbon pollution more broadly, promising to lead a national effort to cut energy waste in half by 2030 and advance our use of renewable power. . ."

 

   The American Council for an Energy-Efficient Economy (ACEEE) said, "The inspiring goal President Obama has set clearly indicates that he understands the importance of energy efficiency, and that he is committed to pursuing both administrative and legislative steps to tap this essential resource that will save the nation billions, create domestic jobs and reduce harmful pollution. We applaud Obama's initiative and look forward to working with the Administration and Congress to achieve the President's goal."

 

    The American Wind Energy Association (AWEA) Interim CEO Rob Gramlich said, "President Obama sets a goal tonight 'to once again double generation from wind, solar, and geothermal sources by 2020.' The President has called on Congress to make the renewable energy Production Tax Credit permanent and refundable, as part of comprehensive corporate tax reform, providing incentives and certainty for investments in new clean energy. . . Policymakers all over should be recognizing the opportunity and supporting the growth of clean energy in their own states, such as through robust state Renewable Portfolio Standards. . ."

 

    Access the full text of the President's SOTU address (click here). Access a video of the SOTU (click here). Access a fact sheet on Investing in Manufacturing (click here). Access a Policy Directive on Critical Infrastructure Security and Resilience (click here); and a fact sheet (click here). Access the GOP response (click here); and a video (click here). Access Speaker Boehner's response (click here). Access the statement from Sen. McConnell (click here). Access the U.S. Chamber statement (click here). Access the statement from API (click here). Access the statement from Sierra Club (click here). Access the statement from NRDC (click here). Access the statement from ACEEE (click here). Access the statement from AWEA (click here). Access a summary of more business reaction from the Business Roundtable (click here). [#Climate, #Energy, #Water, #Transport]

 

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RGGI Proposes 45% Cut In GHG Emissions Cap

Feb 7: After a comprehensive two-year program review, the nine Northeastern and Mid-Atlantic states participating in the Regional Greenhouse Gas Initiative (RGGI), the nation's first market-based regulatory program to reduce greenhouse gas (GHG) emissions, released an updated RGGI Model Rule and Program Review Recommendations Summary. The Updated Model Rule will guide the RGGI states as they follow state-specific statutory and regulatory processes to propose updates to their CO2 Budget Trading Programs.

    Five years ago the RGGI states -- Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont -- demonstrated leadership in addressing CO2 pollution and accelerating the region's transition to a clean energy economy by conducting the first ever regional auction for CO2 allowances in the nation. The changes outlined in the Updated Model Rule and Program Review Recommendations Summary build upon RGGI's success and strengthen the program moving forward. The improvements include:

• A reduction of the 2014 regional CO2 budget, "RGGI cap", from 165 million to 91 million tons -- a reduction of 45 percent. The cap would decline 2.5 percent each year from 2015 to 2020.
• Additional adjustments to the RGGI cap from 2014-2020. This will account for the private bank of allowances held by market participants before the new cap is implemented in 2014. From 2014-2020 compliance with the applicable cap will be achieved by use of "new" auctioned allowances and "old" allowances from the private bank.
• Cost containment reserve (CCR) of allowances that creates a fixed additional supply of allowances that are only available for sale if CO2 allowance prices exceed certain price levels ($4 in 2014, $6 in 2015, $8 in 2016, and $10 in 2017, rising by 2.5 percent, to account for inflation, each year thereafter.)
• Updates to the RGGI offsets program, including a new forestry protocol.
• Not reoffering unsold 2012 and 2013 CO2 allowances.
• Requiring regulated entities to acquire and hold allowances equal to at least 50 percent of their emissions in each of the first 2 years of the 3 year compliance period, in addition to demonstrating full compliance at the end of each 3 year compliance period.
• Commitment to identifying and evaluating potential tracking tools for emissions associated with electricity imported into the RGGI region, leading to a workable, practicable, and legal mechanism to address such emissions.

    With the release of the Updated Model Rule, the RGGI states now plan to revise their CO2 Budget Trading Programs through their individual state-specific statutory and regulatory processes. Each RGGI state seeks to complete their state specific processes such that the proposed changes to the program would take effect on January 1, 2014.

 

    An independent report by the Analysis Group found that the investment of RGGI proceeds from the first three years: Generates $1.6 billion in net economic benefit region-wide through the end of the decade; Puts $1.1 billion in electricity bill savings back into the pockets of consumers in the region over the next decade; Creates 16,000 job-years in the region; and Keeps $765 million in the local economy due to reduced fossil fuel demand.

 

    Collin O'Mara, Secretary of the Delaware Department of Natural Resources and Environmental Control and Chair of the RGGI, Inc. Board of Directors said, "Over the past five years, the RGGI states have demonstrated that a market-based program that spurs investments in energy efficiency and low-emission electric generation can simultaneously achieve the goals of cleaner, cheaper, and more reliable energy. Today, we are taking another significant step forward in realizing our common goal of reducing carbon emissions, driving energy efficiency investments, accelerating clean energy deployment, and providing economic benefits to the region's businesses and families."

 

    Dale Bryk, Director of the Energy and Transportation Program at the Natural Resources Defense Council issued a statement saying, "This program has shown the nation unequivocally that environmental and economic progress can indeed go hand in hand.

    "In the wake of Superstorm Sandy, RGGI is combating extreme weather at its source: climate change. At the same time, it has proved to be an economic engine for participating states: creating thousands of local jobs, generating millions for clean energy development, and lowering energy bills. Now that it will be nearly twice as strong, just imagine what it can do. As the EPA prepares to issue carbon pollution standards for existing power plants nationwide, other states would be wise to look to RGGI as a model. By following this lead, they too can reap similar economic benefits while helping to reduce the turbocharged weather that has been sweeping across the entire country."

    Judi Greenwald, Vice President, Technology and Innovation at the Center for Climate and Energy Solutions (C2ES) said, "We applaud today's plan by the nine states in the northeast Regional Greenhouse Gas Initiative to adjust their cap-and-trade program by tightening the cap and increasing compliance flexibility for businesses. Combined, the adjustments would significantly reduce greenhouse gas emissions and increase available funding for clean energy without unduly burdening businesses or consumers. C2ES believes that market-based policies are the most effective and efficient means of reducing greenhouse gas emissions, and we appreciate the continued leadership of the RGGI states."

    A long list of green energy companies in the Northeast have enthusiastically supported the RGGI and said it is a boost to the economy while "improving energy security." In letters to their respective state Governors they have said, ". . we encourage you to support and strengthen RGGI going forward."

    Access a lengthy release with more details and additional quotes from participating states (click here). Access the RGII website for more information (click here). Access a release from NRDC (click here). Access the C2ES release with links to more information (click here). Access support letter from green energy companies (click here). [#Climate]

 

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