1) Washington Legislators Consider Proposals for Expanded Renewables/Efficiency
2) Washington Efficiency/Renewables Widely Supported, but Proposed Policy Paths Diverge
3) Alliance Seeks $100 Million Funding Extension Through 2008
4) New BPA Integration Services Mix Wind and Water
5) Visual Effects Identified as Most Notable Impact of Proposed Central Washington Wind Farm
6) Proposed 30-MW-Capacity Landfill-Gas-to-Energy Plant Near Seattle Passes Major Milestone
7) Puget Sound Energy to Issue RFP For Electric Energy Efficiency Proposals
8) Commercial Building Efficiency Opportunities Often Misunderstood, but Economics Can Work for Owners, Tenants, Says Consultant
Washington state legislators are considering proposals to expand renewable energy and energy efficiency in the Evergreen State.
But the legislative fates were uncertain as of Jan. 30.
One proposed legislation, House Bill 2333, would require utilities to meet increasing standards for renewables and efficiency over time, based on retail loads. Another proposed bill, HB 2477, also would establish renewables/efficiency standards for utilities, but would make them voluntary and, for renewables, based on load growth; it would offer tax benefits to complying utilities.
Both bills are in the House Technology, Telecommunications and Energy Committee, and compromise discussions were ongoing in late January.
"We've been negotiating," TTE committee chair Rep. Jeff Morris told Con.WEB Jan. 30. "We don't have agreement yet on a vehicle that's got bipartisan support Ö We're not quite there yet, but we're getting close."
Mandatory or voluntary standards are a big issue, he said, as is the very diverse nature of Washington's publicly owned and investor-owned utilities. Setting targets at retail loads or load growth is yet another question. So is renewables qualification.
Although no consensus had emerged as of Jan. 30, Morris described some potential concepts under consideration: mandatory standards with lower thresholds, voluntary standards with higher targets and tax incentives, and treating some public-power utilities separately from IOUs.
He anticipated committee action in early February. "I'm committed to have a vote," he said. "It's just a question of voting on something along partisan lines, or another vehicle that would have bipartisan support and [could reach] the governor's desk."
Proposed Efficiency/Renewables Standards Legislation
HB 2333 and HB 2477 both feature utility standards for energy efficiency and renewables.
But, as HB 2477 prime sponsor Rep. Toby Nixon noted, they "give different perspectives on how to address" expansion of renewables and efficiency in Washington.
HB 2333's introduction highlights its preferred strategy: "Aggregation of utility purchasing power under statewide goals to acquire additional renewable generation and energy efficiency resources on behalf of all ratepayers is vital to create high-quality jobs, promote rural economic development, and stabilize energy supplies and prices."
The bill would require Washington publicly owned and investor-owned utilities (except small utilities) to supply increasing percentages of annual retail load with renewables or renewables credits: a minimum 5 percent by 2010, 10 percent by 2015 and 15 percent by 2023. Eligible renewables are defined as newly upgraded Northwest hydro, wind, solar, geothermal, landfill gas, biomass (meeting certain criteria), wave or tidal power, and sewage gas.
Bonneville Power Administration renewables would count, though renewables from retail green power programs would not. Additional credits would be available for new resources located in Washington.
HB 2333 includes a maximum renewable resource cost of 4.5 cents per kilowatt-hour. If a utility can't meet targets "due to insufficient availability of eligible renewable resources and renewable energy credits in an amount equal to or below the cost cap," it can ask for lower standards.
Under HB 2333 energy efficiency standards also would apply to utilities. They would have to meet 0.75 percent of annual retail load with conservation program savings by 2006, and continuing annually through 2009. The requirement would increase to 0.85 percent from 2010 through 2012.
The bill would allow utility conservation with BPA credit or funding, as well as proportional shares of Northwest Energy Efficiency Alliance savings, which could furnish up to 20 percent of the annual requirement for utilities contributing to the Alliance. High-efficiency cogeneration could account for up to 15 percent of annual utility efficiency targets. At least 5 percent of energy savings would have to come from low-income efficiency services.
Energy-saving program portfolios would have to be cost-effective, and reach different customer classes. If a utility lacks "sufficient opportunities for acquiring conservation," it can ask for lesser targets.
HB 2333 efficiency/renewables standards also apply to market customers, for their non-utility loads.
Although the bill has some reporting requirements, there are no specified enforcement methods or penalties.
Voluntary, Incentive-Based Approach
HB 2477 opens with an indication of its voluntary, incentive-oriented nature: "Fuel diversity, economic, and environmental benefits from renewable energy and efficiency resources accrue to the public at large, and therefore all consumers and utilities should support consistent development of these resources to meet the state's electric demand and stabilize electricity prices through tax incentives for renewable resource and energy efficiency investments."
Like 2333, this bill would establish acquisition standards for utilities, but for renewables the targets would be based on load growth, not total loads. Utilities would choose whether to participate, and when. Proposed tax benefits would be available for complying utilities.
Within five years of the effective date of an agreement with the state Department of Revenue, participating utilities would need to acquire eligible renewables or credits equal to 15 percent of incremental retail load growth. The target rises to 25 percent within 10 years and 35 percent within 15 years. The renewables definitions are similar to HB 2333.
Utilities would need to prepare 20-year incremental load growth forecasts, prior to agreement with DOR. They would also have to analyze long-term costs; only those renewables that cost more than conventional power resources would get tax benefits, according to a bill summary.
Utility energy efficiency targets and criteria are virtually identical to HB 2333, though the target dates start within five years of a DOR agreement.
The bill also contains various additional credits, and the potential for lower standards under certain circumstances.
Utilities that meet the renewables standards would be eligible for certain income tax deductions for the public utility tax; sales and use tax exemptions for machinery and equipment; and sales tax exemptions for labor and services for renewables installations. For reaching the efficiency standards, an income tax deduction would be offered.--Mark Ohrenschall
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Expanding renewable energy and energy efficiency in Washington is a widely shared goal.
But how to pursue that goal through state energy policy is less agreed, as shown by two proposed renewables/efficiency bills in the Washington House of Representatives, and discussions about them.
The policy debates illustrate a wide range of beliefs and approaches on spurring efficiency and renewables, touching on the role of state government, along with economic perspectives and energy issues.
Both pieces of introduced legislation would set renewables/efficiency standards for utilities, increasing over time--but with major differences.
House Bill 2333 would link renewables/efficiency targets to retail electric loads and specific years, with some cost limitations. HB 2477 would also establish renewables/efficiency standards, but make them voluntary for utilities and base renewables targets on load growth, while offering tax exemptions and deductions.
Neither bill is expected to emerge whole from the House Technology, Telecommunications and Energy Committee; compromise legislation was reportedly in the works as of Con.WEB deadline (see related story).
Apple Pie, Motherhood and Renewables/Efficiency
More efficiency energy use and increased renewables are a commonly expressed aspiration among state legislators, utility officials, advocacy groups, business interests and other stakeholders discussing Washington standards legislation.
"It's clear we need to have state energy policy that encourages the deployment of more power generation through renewable resources," said Republican Rep. Toby Nixon, prime sponsor of HB 2477, at a Jan. 20 TTE committee hearing on his proposed legislation. "The question is how do we accomplish that."
He listed a number of attractions for more Washington renewables: greater energy independence, less reliance on long-distance power transmission and natural gas, reduced price fluctuations compared to fossil fuels, rural economic gains and environmental benefits.
Those are strikingly similar to the roll call of benefits mentioned by environmental lobbyist Clifford Traisman, at a Dec. 5 TTE hearing on what became HB 2333. Traisman cited energy independence, job creation, rural economic development, stable electric rates and environmental protection as reasons why environmentalists like the proposed legislation.
However, the preferred path toward more renewables/efficiency tends to diverge.
One significant fork in the road splits over the role of government.
Proponents of renewables/efficiency standards believe that the myriad gains for the state justify utility requirements for those energy resources. "It's an expression of public policy, the kind of energy future we want," policy director K.C. Golden of Climate Solutions told the TTE committee Jan. 20.
They also argue that Washingtonians largely favor efficiency and renewables. Ann Gravatt of Renewable Northwest Project told TTE members that a recent statewide poll found nearly two-thirds support for renewables/efficiency standards.
But others are hesitant or opposed to what they consider a state mandate. "We need to encourage power producers toward achieving a statewide goal on renewable energy," Nixon said. "If we take an approach that's all stick and no carrot, we're going to end up with nothing" passing the Legislature. "I think it's very important we get on the right road and be headed in the right direction, even if we don't manage to get as far as we'd like initially."
Some utility officials, meanwhile, are leery of the requirement approach. "We support one that is voluntary and rewards progress toward goals," said general manager Dave Clinton of Washington Rural Electric Cooperative Association, speaking at the HB 2477 hearing. Still, he suspected many and perhaps most rural utility managers would not sign up for voluntary standards. One bugaboo is the proposed 20-year planning horizon. "I believe [utility] managers will perceive this as an erosion of local control."
The Washington PUD Association and its members "have taken the position we oppose mandates, but nonetheless we are already building and operating and purchasing renewable energy for our ratepayers," said government relations director Dave Warren. Energy Northwest's Nine Canyon Wind Project and Last Mile Electric Cooperative's planned wind venture are prominent examples. The association prefers an approach tied to load growth, with incentives, he said.
Washington investor-owned utilities also are trending toward substantially increased renewables, through least-cost plans and requests for wind proposals, said IOU representatives. "We're planning to secure more renewables than the target" in HB 2333, said PacifiCorp representative Kathleen Collins; the utility also has a rate surcharge to fund conservation. "We support developing incentives for public and private entities to use for renewable energy and also for efficiency."
Efficiency/renewables proponents also like incentives, but they believe the HB 2477 strategy would generate insufficient development. "We do not opposed combining meaningful standards with incentives," said Danielle Dixon of the Northwest Energy Coalition. However, "Implementing this bill as written would cost the state substantially for minimal results," leading in 20 years to 1 percent non-hydro renewables for total retail loads, she said.
Golden said HB 2477 lacks a "significant engine" to "put us in a position to compete successfully for clean energy businesses and jobs and technologies." Utility aggregation of ratepayer dollars "is the money that will define whether we're clean energy leaders in the future."
Varying Economic Perspectives
Varying conomic perspectives also factor into the debate.
Utility rate impacts are one issue. "These eligible renewable resources are still relatively high cost by comparison to the market," said Tim Boyd of Industrial Customers of Northwest Utilities. Renewables acquisitions that would drive up electricity rates represent "our single greatest concern." Renewables costs are dropping, he said, but the marketplace should determine the role of renewables.
Washington rural cooperative officials worry about rate increases stemming from the "aggressive" conservation goals outlined in HB 2477 (0.85 percent of load from annual efficiency acquisitions in 10 years), WRECA's Clinton said. "Much of the low-hanging fruit has already been acquired."
Cost issues are addressed, said Robert Pregulman of Washington Public Interest Research Group. HB 2333 includes a cap of 4.5 cents per kilowatt-hour on renewables acquisitions, he said--a provision requested by utilities. The bill also would require cost-effective efficiency program portfolios for utilities.
Meanwhile, renewables/efficiency advocates are emphasizing potential economic advantages.
"At a time when Washington's economy is suffering, [standards legislation] would bring much needed economic development benefits--in the form of increased tax revenues and jobs--to our state," according to a document from the state's environmental community listing energy standards as one of its top four legislative priorities this session.
The state's utility-private sector collaboration on energy efficiency generates $900 million of annual economic activity in Washington, and the efficiency industry statewide supports 4,000 jobs, said Stan Price of the Northwest Energy Efficiency Council at a Jan. 8 forum in Olympia. Efficiency businesses want a stable marketplace, as opposed to the historical funding swings, he said.
Most of the money spent on natural gas plants goes for imported fuel, and only 5 percent covers in-state labor, said consulting economist Jim Lazar at the same forum. For wind energy investments, in-state labor is 20 percent, while efficiency spending is 50 percent in-state labor. Lazar also listed the marginal cost of new gas at the equivalent of 10 cents/KWh, above some renewables.
Rural Washingtonians are excited about renewables potential, said Randy Smith of Northwest Sustainable Energy for Economic Development. Biomass is available virtually everywhere in rural Washington, while wind power fits well in certain areas. "There are no silver bullets for farmers," said Smith, himself a Chelan County fruit farmer, at the Jan. 8 forum. "We're looking for tools that are building blocks for our economic future. Renewable energy really could be one of those."
Energy issues are yet another facet of the discussion.
On required standards, some point out that Washington utilities have considerably different load and resource situations, now and in the future.
HB 2477 recognizes that by basing the renewables targets on incremental load growth, said Collins Sprague of Avista Utilities. It also lets utilities choose when and whether they participate, which are "attractive" features, he said.
Many Washington PUDs have plenty of power resources to serve their customers, Warren told the TTE committee. If they're required to add a certain amount of non-hydro renewables, "What they are faced with is having to buy an energy resource that may not be necessary," Warren said he supports renewables and believes wind can be very cost-effective, but he worries that fixed standards "may or may not mix with resource choices already made in the past."
He also described disparities in efficiency potential among utilities, depending on the nature of their customer base.
Pregulman said the HB 2333 renewables standards wouldn't kick in until 2010, allowing "ample planning time." He also said the efficiency cost-effectiveness requirement would guard against concerns over conservation potential.--Mark Ohrenschall
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The Northwest Energy Efficiency Alliance is seeking a five-year, $100 million extension.
The regional market transformation collaborative will formally solicit renewed money from Bonneville Power Administration and Northwest utility/public-purposes funders in the coming weeks, looking for signed commitments by mid-March for a total of $20.3 million annually from 2005 through 2009. These entities will be asked to continue their Alliance funding at historic proportional levels, based on retail power loads.
This quest for additional market transformation funding was unanimously approved by the Alliance board Jan. 21 in Portland.
Board members also approved a $3.8 million operations budget for 2004, part of a $19.4 million spending plan for this year.
And, the board endorsed a one-year $530,000 funding extension for the EnergyIdeas Clearinghouse, along with a pledge for a board committee to assess the EIC and make a recommendation to the full board on the Clearinghouse's future role with the Alliance.
The Alliance, which formed in late 1996, is nearing the end of its second regional funding period, which covered 2000 through 2004 with $100 million.
This quest for a third phase comes shortly after the release of an independent evaluation of the Alliance by two Colorado-based consulting firms.
They found the Alliance has made "substantive contributions to transforming regional markets for energy efficiency equipment and practices" since its inception. They also concluded benefits of the regional collaborative exceed its costs, and that "the reasons for establishing the Alliance are still valid and provide strong rationale for continuation." However, the report also substantially lowered the estimated energy savings attributable to Alliance programs--from 134 average megawatts, as the Alliance had reported, to 98 aMW (see Con.WEB, Nov. 26, 2003 for a story on the evaluation).
Now, the Alliance will ask its funders to sign memorandums of agreements for additional money to continue cost-effective regional market transformation. The goal is $20.3 million annually for five years starting in 2005, apportioned among BPA and utility/public-purposes funders.
The board's executive committee considered different ways of divvying up the funding, said Alliance board member Ken Keating, but concluded it was best to stick with historic shares based on approximate retail loads. He called it "not trivial to recompute equity" for Alliance contributions.
Total regional loads have dropped since the original computation, said Alliance executive director Margie Gardner. However, the relative percentage of loads is still roughly the same, said Alliance board chair Mat Northway. Keeping this formula creates predictability for utility budgets, he noted.
All the funding entities but one have supported this equation, according to Gardner. The exception is Tacoma Power, which believes it should pay about $50,000 less per year because its loads have fallen more than the average.
"We have no intention of Tacoma leaving the Alliance," said the utility's Alliance board member, Steve Hatcher. "My only concern is being able to justify to my management, my boss, what we're expending. I want to be in the best position to say, 'This is what it is, and here's the reason why.'"
This year, the Alliance plans to spend about $19.4 million altogether. That's a 7 percent decline from projected 2003 spending of $20.9 million, but a 3 percent increase from the 2000-2003 average of $19.1 million, reported board member Mark Kendall.
Most of the money, $15.6 million, is earmarked for project costs. That's down 10 percent from the $17.4 million estimated project spending for 2003, although project administration costs are forecast to rise from $2.1 million last year to $2.2 million this year, with more projects in progress.
|(Courtesy of Northwest Energy Efficiency Alliance)|
Under this spending plan, commercial sector activities are earmarked for $8.7 million, residential $5 million and industrial/agricultural/miscellaneous $3.8 million.
Meanwhile, the board-approved operations budget of $3.8 million is 7 percent higher than 2003. A big portion of this category is staff wages and expenses, which are up 13 percent--30 full-time-equivalent employees are included in this budget; the 2003 average was 26, said Kendall.
Non-project administrative costs are estimated at $1.5 million, slightly less than 8 percent of the total budget.
The Alliance projects annual budgets of about $20 million through 2008. "We're trying to go from a growth organization to a steady-state organization," said board member Fred Gordon.
Meanwhile, Gardner told the board about this year's major themes for the Alliance. They include partnerships with utilities and other stakeholders, securing renewed funding, residential new construction and clothes washer initiatives, launching commercial ventures targeting hospitals and grocery stores, adopting a unified industrial sector framework and implementing the distribution system efficiency initiative.
By a 14-3 vote, the Alliance board approved a $530,000 one-year extension of Alliance funding for the EnergyIdeas Clearinghouse, and decided to review the future role of EIC services with the Alliance.
Many Alliance board members from utilities praised the Clearinghouse as a valued regional informational resource. Bob Stolarski of Puget Sound Energy called it "a tremendous, successful infrastructure that supports the market of energy efficiency," while Deb Young of NorthWestern Energy said the Clearinghouse is used by her utility's staff, trade allies and customers. "I'm a little concerned we'd be reducing funding or not moving forward on one of our activities that really does have full regionwide acceptance and availability," she said.
However, customer representatives on the Alliance board questioned the EIC's reach. "I've gotten nothing out of this," said Richard Beam, corporate utility manager for Providence Health System. "I think there are better resources, readily available, all over the place."
The board's consideration of EIC also sparked a discussion--though no resolution--of the larger question of Alliance support for regionwide information/education/training services, such as the Lighting Design Lab, local government associations and this newsletter.
Kendall framed the issue as balancing "our responsibility funding market transformation measurable as megawatts, or whether infrastructure is part of that palette, necessary for making a fertile environment for other transformation efforts to go."--Mark Ohrenschall
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Bonneville Power Administration publicly unveiled in mid-January two new wind power integration services touted by the agency and others as a significant advance for intermittent wind energy.
A network wind integration service aimed at Northwest publicly owned utilities fills wind-generation gaps with hydropower; Cowlitz County PUD signed the first contract for this service for 2 megawatts from the Nine Canyon Wind Project.
Another new offering--intended for utilities outside BPA's control area, particularly investor-owned utilities--is a storage-and-shaping service that delivers flat power blocks a week after wind-generated electrons enter the Bonneville system.
For both, BPA takes in wind energy, delivers it when it's available and provides hydroelectric backup when it's not. The cost is 0.45 cents per kilowatt-hour for the network wind integration service and 0.6 cents/KWh for storage and shaping--both separate from energy and transmission charges.
"Integrating wind generation will be an important part of BPA's future strategy to encourage regional development of renewable energy resources," said administrator Steve Wright in a news release. "It is yet another example of how the flexibility of the Northwest hydropower system provides value to the people of this region."
Rachel Shimshak of Renewable Northwest Project called the new services "a very positive development" for wind energy, as they address a reluctance by many utility officials to invest in intermittent wind because of uncertainties on how to integrate it into their systems.
"BPA's services eliminate this problem because they help wind 'walk like a duck and talk like a duck,'" Shimshak told Con.WEB.
The federal power marketing agency wants to provide wind integration services for up to 450 MW of wind capacity through 2011; at least 200 MW of that has been earmarked for public-power customers.
Wind Integration Services
The network wind integration service provides load-following for participating utilities, even when no power is generated by a wind resource. This offering is targeted primarily at publicly owned utilities with loads inside BPA's control area.
Cowlitz County PUD last year signed the first contract for BPA network wind integration service. It covers power delivered from the PUD's 2-MW share of Energy Northwest's Nine Canyon wind farm in southeastern Washington. Cowlitz started taking the power Dec. 31.
"From my perspective," said Cowlitz general manager Denny Robinson, "it's a good agreement. It brings the wind power into our system in a reasonable manner for a reasonable fee."
BPA's news release said the 0.45 cents/KWh fee "is designed to cover the costs of providing the service while keeping wind affordable."
|(Courtesy of Bonneville Power Administration)|
The storage-and-shaping service takes wind project output and delivers an equivalent amount of energy a week later in flat blocks. This feature is "designed to serve the needs of utilities and other entities outside of the BPA Control Area who have chosen to purchase the output of a new wind resource but do not want to manage the hour-to-hour variability associated with the wind output," according to a BPA document.
It costs more than network wind integration because it involves transmitting power into and out of the Bonneville system, BPA's Cindy Custer told a Washington state legislative committee Jan. 21.
No utilities had signed up for storage/shaping as of late January, although investor-owned utilities are interested, said Elliot Mainzer, BPA manager for pricing and transaction analysis.
Costs for these services are in addition to transmission and wind energy prices. The latter runs approximately 3.5 cents/KWh, including the federal wind energy production tax credit, Mainzer said.
The week-long delay between taking in wind power and redelivering it in the storage-and-shaping service allows utility customers to eliminate the hour-to-hour uncertainty of wind generation. However, the delay could expose BPA to financial losses from sudden changes in power prices--a possibility that led to a cap on redelivered power of 50 percent of a wind resource's nameplate capacity.
"But the biggest single challenge in terms of transmission is getting the power into our system," Mainzer said. "This is nothing new, though--folks have grappled with it for some time. We're exploring a number of solutions on a transaction-by-transaction basis, because no two utilities have the same characteristics."
The program resembles services provided to BPA by PacifiCorp for Wyoming wind projects, and is comparable to a service BPA provides Portland General Electric for integrating output from the Vansycle Ridge Wind Farm in northeastern Oregon.
There are also similarities to PacifiCorp's integration of energy from the 41-MW-capacity Combine Hills wind farm, also in northeastern Oregon. "The product is a little different and the price slightly less" than BPA, according to renewable energy program manager Peter West of the Energy Trust of Oregon. He noted Combine Hills' output is absorbed within PacifiCorp's local distribution system, so there is no transmission element.
PPM Energy provides scheduling, forecasting, risk management and other products for its customers, including utilities buying wind power, spokeswoman Jan Johnson told Con.WEB. "We're very pleased that BPA is providing these services ... because they have unique capabilities with their hydro system to provide firming and shaping services for wind power. The Northwest has huge potential to grow wind power and multiple parties providing these types of services will facilitate the expected expansion of this renewable resource."--Rick Adair and Mark Ohrenschall
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The eyes have it.
A draft environmental impact statement for the proposed Kittitas Valley Wind Power Project in central Washington identifies visual effects as the most notable dilemma posed by the prospective wind farm of at least 181.5 megawatts capacity.
"For many viewers," the draft EIS reads, "the presence of the wind turbines represents a significant unavoidable adverse impact because it significantly alters the appearance of the rural landscape over a large area of the Kittitas Valley. Flashing of lights on the tops of turbines would similarly be considered a significant unavoidable adverse impact" from 82 to 150 commercial-scale wind turbines proposed for ridgetops northwest of Ellensburg.
The document adds: "How adverse these impacts become depends on the viewer's location and sensitivity and the impact on view quality."
From a regulatory perspective, "In Washington state, there is no standard or criteria for visual impacts from wind facilities," said Irina Makarow, siting manager for the state Energy Facility Site Evaluation Council. Her agency produced the draft EIS in its review of the Kittitas Valley proposal, for which it will make a recommended decision to the governor.
The draft EIS came out Dec. 12 and outlined a broad range of potential wind farm issues, including effects on birds, other wildlife, natural resources, human health and safety, land uses, transportation, and the local economy and community. Some issues are deemed insignificant by the draft EIS. Some others, such as bird deaths and fire risks, are noted but considered manageable. Cultural resources, specifically Yakama Indian Nation resources and a historic canal tunnel, could be indirectly affected for the worse, but those impacts could be avoided or mitigated.
"The EIS in large measure basically confirmed what we said over a year ago when we filed our application ... This project is not going to have any significant negative impacts on the environment locally and will have significant benefits regionally in terms of adding significant renewable generation," said project manager Chris Taylor of developer Zilkha Renewable Energy.
He acknowledged views as a "possible exception" to the lack of major concerns, but said Zilkha would design features to minimize visual impacts.
Meanwhile, an Ellensburg attorney opposed to the project criticized the draft EIS as "inadequate in so many ways." Steve Lathrop told Con.WEB the document is "nothing more than a regurgitation" of Zilkha's EFSEC application for site certification, instead of an independent evaluation.
Information and analysis in the draft EIS are "based primarily on information provided" by Zilkha, the document stated.
"We did the studies; these are the conclusions of [EFSEC] experts, who are not reporting to us," said Taylor, adding, "I never read this [draft EIS] until everybody else did."
Makarow said the proposed wind farm is subject to draft EIS public comments and upcoming adjudicative hearings. "We're very far from issuing a final EIS," she said.
Kittitas Valley Wind
The Kittitas Valley Wind Power Project was publicly announced in spring 2002, and has generated substantial local interest and controversy (see Con.WEB, March 27, 2003, for a column exploring different perspectives on the would-be wind farm).
A Jan. 13 Ellensburg meeting on the draft EIS illustrated the divisions over the project. Speakers were roughly split between supporters and opponents, according to Makarow.
"For the pro side, the main concern is support of renewable energy, and this is one of the means to get there," she reported. Another spoken point in favor was economic gain, to the county overall and to landowners leasing their property for turbines, she said.
Wind farm opponents generally said, "This really wasn't a great location for a wind power project," Makarow reported. Among specific concerns, "Obviously the most significant is the visual impact for residents in that area," she said. Also raised were health and safety concerns, including blade/tower catastrophes and shadow flicker, as well as prospective impacts on birds and other wildlife, she said.
A 58-page summary of the draft EIS outlines the proposed wind farm and its prospective impacts, along with mitigation measures.
Kittitas Valley would have a capacity somewhere between 181.5 MW and 246 MW, intended to "meet a portion of the projected growing regional demands for electricity produced from non-renewable and renewable resources," the draft EIS said.
The proposed wind farm would span about 7,000 acres along U.S. Highway 97 between Ellensburg and Cle Elum, although the permanent infrastructure would occupy an estimated 93 to 118 acres. In addition to turbines (the exact number and sizes are yet undetermined), the project would include 19 miles of new roads, 23 miles of underground electric lines, 2 miles of overhead lines, two substations, a 5,000-square-foot operations and maintenance facility, and up to nine meteorological towers.
Most of the proposed land area is private, although some is state-owned. Zilkha has agreements to use the properties, the draft EIS said.
The most notable irremediable effect of the Kittitas Valley Wind Power Project would be the sight of wind turbines, the draft EIS concludes.
From U.S. Highway 97 in the vicinity and from nearby residences, the wind farm "would be highly visible and would have a moderate to high visual impact," the document reads. "From more distant locations, the visual effects would be relatively minor and would have little or no impact on the quality of views."
The draft EIS lists Zilkha's proposed mitigations, such as gray paint on uniformly designed turbines and predominantly underground electrical collection systems. EFSEC suggests tree-planting to lessen impacts and Zilkha-purchased conservation easements "on land in important foreground views" to avoid further development. But neither the agency nor Zilkha mention any proposed changes to the wind farm's basic configuration.
Taylor said Zilkha has dropped some earlier planned turbines that would have been "quite visible" from points on Interstate 90, "for a variety of reasons, including visual effects." Zilkha also has created visual simulations of the proposed project, and made them widely and publicly available, he said.
Wind turbines are large and can't be hidden, Taylor acknowledged, but he said his company would incorporate known design methods of lessening visual impacts.
"Our position is and the reality is that visual and aesthetic impacts are inherently subjective," he said, and EFSEC should look at "the sum total of all impacts, positive and negative, across all areas of the environment," in making a decision on Kittitas Valley.
Another "significant unavoidable adverse impact" listed, though indirect, is the potential effect on tribal cultural resources, according to the draft EIS. Two prehistoric archaelogical sites are known at the site. The document notes "ongoing" consultation with the Yakama Indian Nation and suggests "appropriate mitigation measures should be devised" for any affected resources before construction begins.
On the issue of birds, the draft EIS predicts a "low" impact from the wind farm, not affecting overall population levels. However, raptor deaths would probably be "slightly higher compared to other wind projects with similar turbine types," the document said. Passerines are the most common bird seen in the vicinity and would likely be the most commonly killed by the wind farm. The draft EIS predicts "some bat fatalities" as well.
The wind farm would disturb up to 150 acres of lithosol habitat, which the document described as "unique and sensitive and difficult to restore." Invasive plant species also could colonize the area. Zilkha plans numerous project design features to limit impacts to flora and fauna, from the use of tubular towers to avoiding construction in sensitive areas to minimizing new road construction. A 550-acre replacement habitat parcel also is listed as a proposed mitigation measure by Zilkha.
The draft EIS also outlines several health/safety issues. Summer grass fires during project construction are an acknowledged risk, although Zilkha proposes an extensive mitigation plan to address potential fires and explosions. Tower collapse and blade parts detaching from turbines are listed as possibilities, though they are remote and could be mitigated by minimum setback requirements and compliance with engineering and manufacturing standards, the draft EIS said. Setbacks also would help address the potential of ice falling off blades, as would turbine shutdowns during icing conditions.
Rotating blades would cause flickering shadows in some nearby homes at certain times of low-angle sun, but this could be addressed by tree-planting and/or shade installations. Turbine noise "could ... exceed regulatory thresholds" at nearby structures and property lines. If acoustical analysis of the final planned turbines and layout shows a lack of compliance, EFSEC recommends moving or removing offending turbines.
Project construction would directly create 253 new temporary jobs and generate more than $5.7 million in total income (direct, indirect and induced) in the county, the draft EIS said. Project operations would result in almost $2 million annually in added income in the county, $1.3 million in additional property tax revenues and 12 to 14 full-time positions for a 181.5-MW-capacity wind farm.
Lathrop, an Ellensburg attorney and intervenor in the EFSEC Kittitas Valley process, believes the draft EIS largely echoes Zilkha's application--not an independent, objective evaluation to identify potential impacts and mitigations, to help inform decision-makers.
"On many key points, they simply said, to the effect, 'Well, we don't know what the impacts are going to be, but whatever they are the applicant will fix them after the fact.' Which of course is totally useless," he said.
EFSEC's conclusion about visual impacts is "probably one of the few accurate statements or analyses they've got in the whole document," he said, but it's still too general to provide guidance for EFSEC.
Cumulative impacts from other proposed Kittitas County wind projects should be better analyzed in the draft EIS, Lathrop said. So should effects on specific geographic sub areas from the Kittitas Valley project, which he called the worst possible wind farm site in the county. "It may be attractive from a wind standpoint, but that's a business decision; that's not an environmental decision or a cultural decision or what's the impact on the community."
Taylor disputed Lathrop's opinion on the EIS' objectivity, saying the document's findings came from independent experts.
"At the end of the day, it comes down to some people don't like to look at wind turbines. That's the only real argument against the turbines," Taylor said. He cited environmental and economic development benefits of Kittitas Valley, and reiterated the proposed site as one of Washington's best for a wind farm, with strong wind resources and close access to transmission and loads.
Public comments on the draft EIS closed Jan. 20, and will be reviewed and responded to by EFSEC. Adjudicative hearings on the proposed wind farm are planned sometime later this year, according to Makarow. "They would add more meat to the analysis ... presented in the draft EIS," she said. A final EIS will follow. EFSEC has no official timetable yet for its recommended decision to the governor, she said.--Mark Ohrenschall
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A large proposed landfill-gas-to-energy plant near Seattle passed a major milestone in late January, when the landfill owner and project developer finalized gas sales and development agreements.
King County and Energy Developments Inc. came to terms Jan. 20 on a planned 30-megawatt-capacity facility at the county's Cedar Hills Regional Landfill 20 miles southeast of Seattle. It would be the Northwest's biggest landfill-gas-to-energy plant, by far, and one of the biggest nationally. It also would become one of the larger biomass generators in the region.
First, however, EDI needs to complete permitting and arrange power sales for the project. With the gas sales and development contracts signed, the Texas-based firm plans to negotiate power purchase agreements in the coming months, EDI senior vice president of business development Dennis Bollinger told Con.WEB. His company has had "ongoing discussions" with Puget Sound-area entities and power marketers in the region. "We're specifically targeting people who are looking for renewable or green energy," he said. "I think that in the Northwest, there's a great opportunity for a green power renewable facility."
Bollinger anticipates the plant operating by late 2005 or early 2006, with three gas-fired turbines and a heat-recovery steam boiler generating about 30 MW altogether.
King County, meanwhile, expects to reap about $400,000 annually from selling Cedar Hills gas, which currently is flared. The county also would save $80,000 annually on electric bills for the landfill gas collection system. "This power plant ... will be developed on EDI's investment, while we are able to sell the waste gas for fuel," said King County project manager Mark Buscher. "It essentially results in a very strong public-private partnership."
Cedar Hills Landfill-Gas-to-Energy
Energy Developments operates nine U.S. landfill-gas-to-energy plants and another 54 worldwide through its parent company, Bollinger said. It was chosen to develop the Cedar Hills project through a King County Solid Waste Division request for proposals (see Con.WEB, Dec. 20, 2002).
"A landfill of this size is unusual and it offers a great deal of potential and a great deal of opportunity," said Bollinger. Cedar Hills opened in 1962, and the 920-acre landfill holds about 27 million tons of accumulated garbage. The anaerobic decomposition of organic wastes in the trash creates landfill gas, which consists primarily of methane and carbon dioxide.
King County had long eyed the energy potential at Cedar Hills, according to a March 2001 study by consulting firm R.W. Beck. "Up to this point, however, project economics were unfavorable due to the relatively low price for electricity and natural gas in the region," the study said. "Recent run-up in energy prices and advances in technology have improved project feasibility."
After its selection by King County, EDI anticipated a final contract by early 2003, Bollinger told Con.WEB in late 2002. But this venture is large and complicated, and new to King County, he said in late January. Buscher said testing of landfill gas volume and composition took four to five months.
On Jan. 20, three separate agreements were signed by county and EDI officials.
King County will sell all the Cedar Hills landfill gas to EDI--an estimated 11 million cubic feet per day, according to Buscher. EDI will pay 15.4 cents per million British thermal units, subject to an inflation escalator. King County can adjust the purchase price after a year of commercial operation--one time only--"based on the actual real cost of developing the power plant and the real value of electricity in the open marketplace," Buscher said. The county and EDI will essentially share any added efficiencies or revenue increases.
The contract runs 15 years, with a potential 10-year extension.
The county and EDI also inked a project development agreement and a lease for the plant site, Buscher said.
On the company's part, "We will design, we will build, we will own, we will operate the facility," said Bollinger.
Although the proposed plant is not completely designed, Bollinger said EDI plans three gas-fired turbines, each 5 MW to 6 MW capacity. Heat-recovery steam boilers would produce another 12 MW to 13 MW, for a total capacity of about 30 MW. "Because of the size of the landfill, we are able to utilize combined-cycle technology," unlike with smaller landfill-gas-to-energy plants, he said. "We'll end up generating much more electricity with a lot less emissions per KW."
Cedar Hills is projected to close within a decade, and at some point diminishing landfill gas might lead EDI to shut down one of the turbines, but Bollinger called that possibility "many, many years out in the future."
The plant should have a capacity factor in the range of 93 percent to 95 percent, stopping only for routine maintenance and any transmission problems, Bollinger said. EDI won't build any new high-voltage lines; nearby Bonneville Power Administration wires offer grid access.
EDI doesn't yet know the exact cost of the plant or the generated electricity, but Bollinger offered a rule of thumb of $1 million per megawatt of capacity to build a landfill-gas-to-energy plant. "On paper it looks substantially higher on a per-megawatt basis than what a typical, utility-size combined-cycle facility would cost," he said. Landfill-gas-to-energy plants are smaller and lack economies of scale, while also facing added gas cleaning and maintenance costs.
Permitting, Power Buying
The proposed facility needs some regulatory approvals, including land-use permission from King County Department of Development and Environmental Services, air emissions permission from Puget Sound Clean Air Agency, and solid waste handling authority from the county.
"We expect that permitting process to take up most of the rest of this year, which coincides with EDI's final design for developing the project," said Buscher.
"Right now, we anticipate the plant operational sometime in late '05 or early '06," said Bollinger. "The permitting is the big variable we really have no control over," although he expects a "relatively uneventful permitting process."
After a community survey and several local meetings, Buscher described public reaction to the proposed landfill-gas-to-energy plant as "very positive." Some concern has been raised about noise and other potential impacts, but, "What we've been able to show is this is not a change, really, to the operation of the landfill. We're still burning gas." In addition, the power plant would be located in the middle of the landfill, while the existing flaring station--which would be kept as a backup--lies on the north end. "The potential for impact to the community, which right now is low, will decrease even more dramatically," he said.
Meanwhile, EDI now has a more definitive project with which to approach potential power buyers among utilities and marketers. "Until this time, it's been very difficult to really move forward with [power purchase agreement] negotiations," Bollinger said. "I could not demonstrate I had actual control of the site and actually had the gas under contract." With those resolved, "Our goal is to conclude those negotiations as quickly as possible, realistically probably something in the next 90 to 120 days."--Mark Ohrenschall
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Puget Sound Energy is in the market for energy efficiency ventures.
Washington's largest utility is scheduled to issue in early February a request for proposals for electric energy efficiency resources, to "supplement and enhance" its own recently expanded conservation offerings.
"PSE hopes companies with expertise in energy efficiency will propose ways of making conservation even more attractive and cost-effective for more PSE customers, and will identify energy-saving innovations currently unavailable to customers," according to a letter accompanying the initial draft RFP, filed Dec. 12 with the Washington Utilities and Transportation Commission.
Puget seeks efficiency resources from different customer sectors, with minimum average annual savings per proposal of 0.28 average megawatts for each of two years. Pilot proposals also are invited. Responses will be due April 28.
PSE plans to start chosen initiatives in January 2006, although it holds open the possibility of launching selected ventures in January 2005. This timing owes primarily to the utility's already established 2004-2005 conservation plans, and Puget's interest in meshing efficiency proposals with the scheduled May 2005 update of its least-cost plan, said PSE energy efficiency services director Cal Shirley.
The WUTC on Jan. 28 approved a slightly revised version of the efficiency RFP, which clarifies Puget's consideration of proposals to start in 2005.
The nearly-two-year gap between proposal deadline and launch of selected projects had been criticized by some stakeholders, including the Northwest Energy Efficiency Council. NEEC and the Northwest Energy Coalition also argued for a more targeted solicitation, but Puget, with the WUTC's blessing, kept the open approach.
Renewed Conservation Push
Puget's energy efficiency RFP follows, and complements, the utility's renewed push for energy conservation.
The Bellevue, WA-based investor-owned utility has saved more energy since 1978 than any other Northwest utility outside of Bonneville Power Administration, but its programmatic conservation efforts dropped sharply in the late 1990s before rising anew earlier this decade.
For 2004-2005, Puget is pursuing 39.2 aMW of electric savings and more than 5 million therms of natural gas efficiencies, on planned combined spending of about $62 million. Those targets derived from an integrated resource planning process that included an assessment of conservation potential in the utility's service territory--1,106 aMW of technical potential over 20 years and 328.3 aMW of achievable potential over the same period. Puget set a 2004-2013 conservation target of 203 aMW; most of its new resources in the coming decade are expected to come from natural gas- and coal-fired power, with some renewables as well. (See Con.WEB, Nov. 26, 2003, for more on Puget's 2004-2005 conservation plans).
Meanwhile, Puget on Nov. 25 filed with the WUTC a draft all-source RFP, which didn't include an efficiency component as the commission had previously ordered. Puget misunderstood this directive, according to the letter accompanying the draft efficiency RFP. The utility and stakeholders subsequently "reached the consensus that pursuit of a parallel RFP targeting conservation resources could present new opportunities and incremental value to PSE's resource acquisition efforts," the letter said.
The all-source RFP also received WUTC approval Jan. 28.
The draft RFP expresses a general intent "to supplement and enhance PSE's ongoing energy efficiency efforts."
Shirley, in a Jan. 5 informational meeting, outlined Puget's three areas of interest with this solicitation. "One has to do with programs incremental to whatever we're doing, above and beyond," he said. Another is "better, cheaper, faster, better customer service" approaches for existing Puget initiatives. Pilot ventures are the other category.
The draft RFP seeks proposals that "involve installation of equipment and technologies for any of a wide variety of electricity end-uses," at sites of PSE retail customers. "PSE intends to choose a variety of proposals such that all customer classes are included."
In addition to minimum annual average energy savings of 0.28 aMW, proposals must generate efficiencies for at least five years and "produce savings that can be reliably measured or estimated with accepted engineering methods," the draft RFP said.
"We're not looking for new, experimental kinds of projects," said Puget's Mary Smith. Likewise, bidders must have experience operating or contracting on utility programs.
The RFP specifically excludes proposals for fuel switching from electricity to gas, education/information and operations/maintenance. It also puts off-limits bids involving low-income retrofits, Northwest Energy Efficiency Alliance efforts, self-directed programs by large power users, middle school energy education and resource conservation managers.
Pilot proposals are invited for "viable energy efficiency measures which are not yet widely available or adopted in PSE's service territory, and/or demonstrate effective, sustainable program delivery to market segments in which, historically, customers have infrequently undertaken energy efficiency investments," the RFP said. Proven technologies are required, but pilot proposals don't have to meet the minimum savings requirement, Smith said. They also will be assessed separately from other bids.
Submitted proposals will initially be judged on cost and cost-effectiveness, from both utility and total resource cost perspectives. Other primary criteria include the amount and duration of energy savings, a proposer's demonstrated abilities to do the job, plans for savings verification, marketing and customer service, potential PSE resource commitments, and public benefits such as environmental, economic and community impacts.
"We're not weighing any of these factors one over the other," said Puget's Bill Hopkins. "It really is truly a balancing act we're trying to accomplish here."
Schedule, Other Issues
The timetable for selecting and implementing proposals was questioned by NEEC executive director Stan Price, at the informational meeting and in the organization's December newsletter. Though he praised Puget's strong commitment to conservation, he wondered in writing whether the RFP would unintentionally create "18 months of marketplace uncertainty about the nature of and process for efficiency program participation in PSE service territory?"
Shirley said the RFP schedule was designed to synchronize with the scheduled May 2005 unveiling of Puget's revised least-cost plan, which in turn will influence Puget's conservation plans for 2006-2007. "One reason this whole process is protracted is that successful bidders will have the same review and analysis process our other programs are going through," he said.
The final draft RFP makes an allowance for ventures before 2006, declaring the utility "may, at its option, select projects for early implementation," beginning "no later than January, 2005. The contract period for these projects will be negotiated, and based on the proposal, but cannot go beyond 12/31/2007."
The RFP schedule calls for shortlist proposal selections by June 30, contract negotiations this fall, and, for non-early ventures, finalist selections by September 2005 and contract awards in December 2005.
Another issue was the general nature of this solicitation. NEEC, in formal comments to the commission, suggested a design "targeted to specific end use sub-sectors and/or specifically targeted program design approaches where PSE needs additional support to achieve conservation goals in the near term."
But WUTC staffers preferred the broad approach, "to identify what the market has to offer without discretionary constraints," and to furnish "market information on price and program design that will supplement the supply curves" for Puget's least-cost plan, according to a commission staff memo.
At the informational meeting Price also raised the issue of financial penalties linked to performance. The final draft RFP describes Puget's intent "to assign to each accepted proposal an energy savings target for the 2006-2007 period with reduction in compensation proportionate to the penalties for which PSE is at risk if the respondent fails to perform as agreed." A smaller penalty would apply if a proposer's work "impedes or undermines PSE's ability to achieve energy efficiency with the same set of customers."
Shirley called these provisions a "sharing of the risk" between bidders and Puget, which will be forced to pay anywhere from $250,000 to $750,000 if it fails to reach energy-saving goals for its controllable 2004-2005 programs. The utility's 2006-2007 liability is yet unknown.
Price asked whether Puget would offer "commensurate financial incentives for performance" by proposers, but Shirley said no, since Puget lacks any such arrangement for itself. "There should probably be more of that," Shirley said, "but right now there isn't."--Mark Ohrenschall
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The vast opportunities for energy efficiency improvements in commercial buildings are often hindered by various misunderstandings, but energy-saving economics can be favorable for owners as well as tenants.
An East Coast-based consultant addressed this theme Dec. 10 at the Lighting Design Lab's annual open house in Seattle.
"Our goal is nothing short of changing the way commercial real estate uses energy," Mark Jewell, head of RealWinWin Inc., told a sizable crowd at the Lab. "The goal is to try to make people see things through a different lens."
(Courtesy of RealWinWin Inc.)
In addition to outlining "myths" that can thwart commercial building efficiency ventures, Jewell discussed strategies for pursuing efficiency upgrades in leased buildings, including careful analysis of costs and benefits.
Simple paybacks from energy savings are less relevant to property owners than net operating income, which Jewell termed "the mother's milk of commercial real estate." Energy efficiencies can boost NOI and increase appraised value, he said.
Real Estate Investment
Energy efficiency can offer financial benefits to real estate investors, especially in the current business climate, according to Jewell, whose background covers 20-plus years in real estate and a decade in energy efficiency.
"[E]xternal growth" real estate strategies such as buying and building commercial properties are hampered by high vacancy rates that reduce rental income and low interest rates that make it difficult to buy buildings at good prices, he wrote in a November 2003 Energy User News article. "Now, internal growth is the more sensible strategy to pursue: lower operating expenses, improve tenant attraction and retention, and do anything else that improves the profitability of assets," wrote Jewell.
"The smart money is reallocating dollars that had been reserved for increasing the size of the portfolio to initiatives that upgrade the infrastructure (and profitability) of properties already there."
With utility costs accounting for about 30 percent of a typical office building's operating expenses--higher than any other category, according to an April 2002 EUN article by Jewell--energy efficiency is thus a promising approach.
"However," he wrote in a January 2003 article in HPAC Engineering, "too many income properties continue to have very inefficient building systems for a variety of reasons: 'lowest-first-cost' decision-making, dysfunctional owner/tenant dynamics, and popular myths that lead owners and managers to ignore or reject worthwhile energy upgrades."
In his Lighting Lab talk, Jewell cited a number of leading myths that deter commercial efficiency projects.
One is the mistaken belief that buildings already are energy efficient, and in any case that building managers and employees are well-versed on efficiency opportunities.
Another major barrier is the erroneous idea that landlords are economically disadvantaged by improving the efficiency of tenant spaces, since tenants pay energy bills. Jewell said landlord/tenant energy responsibilities actually vary depending on the type of lease. For example, under so-called "fixed-base leases" owners typically pay a certain amount for energy above a predetermined baseline--and thus they have an incentive for efficiency.
Jewell offered a specific example in HPAC Engineering. If energy costs shrink from $2 per square foot to $1.60 per square foot from one year to the next, the tenant saves 10 cents per square foot in the subsequent year under a fixed-base lease requiring the tenant to pay energy costs above $1.90 per square foot, while the landlord saves 30 cents per square foot.
Energy efficiencies can boost a property's net operating income and enhance appraised value, he wrote.
"When you're dealing with commercial real estate, it's very important to get all the costs and benefits on the table" for both owners and tenants, Jewell said.
A simple payback benchmark for efficiency projects is "irrelevant if you don't know whether the owner, the tenant, or both will capture the savings," he wrote in EUN in April 2002.
Jewell also disputed the notion that energy-saving initiatives such as re-lamping should await tenant departures, supposedly because mid-lease upgrades don't benefit property owners.
"The largest opportunity to create value in real estate is to do what's called internal growth," he told the Seattle audience. "It's better to spend $1 per square feet increasing energy efficiency in buildings you own than spend $10 million on another building. The rate of improvements give you far more value."
And it's "crazy" to think speculative building is more profitable than efficiency upgrades, given today's high vacancy rates and construction and economic risks, he said.
Making Projects Happen
Jewell also offered some thoughts on making efficiency ventures happen in leased buildings: seek a wide range of opportunities; use metrics that speak the language of building owners (such as internal rate of return, net present value and discounted cash flow); conduct a detailed investment-grade analysis of payments and benefits to the parties; improve communications between different people in real estate organizations; and have an internal champion to support a project through to fruition.
In addition to setting efficiency priorities on a "triage" basis and careful evaluation and design of projects, Jewell encouraged pursuit of rebates, which in a typical year amount to $1.5 billion for energy- and water-saving ventures nationwide. "There are lots of rebates out there for building improvements, not just lighting retrofits," he said, mentioning as examples emergency equipment replacements, feasibility studies and building commissioning.--Mark Ohrenschall
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