courtesy of Jen Sorensen available at: http://jensorensen.com/2013/07/01/giving-gas-a-pass-fracking-cartoon/

A thoughtful New York Times opinion piece from an oil and gas engineer, Anthony R. Ingrafea, recently noted that:

“gas extracted from shale deposits is not a ‘bridge’ to a renewable energy future – it’s a gangplank to more warming and away from clean energy investments.”

This is a refreshing insight.

The leaks of methane from gas production and transportation “eviscerate” and advantage natural gas has over oil. Conservation Law Foundation provided a similar analysis last month regarding the Vermont Gas expansion in Addison County.

Even if natural gas burns cleaner it is still a fossil fuel. It still contributes to climate change. It still ties us to a dirty fuel at a time our climate demands we move toward cleaner sources.

It is disappointing to hear Vermont Gas and others tout claims that natural gas is clean and affordable. Glossing over the real impacts doesn’t eliminate them. As the cartoon says, it is time for a little honesty. Time for some real action toward clean energy as well.

A version of this article first appeared in the Sunday July 21 edition of the Rutland Herald /Times Argus.

Helping farms and Vermont businesses thrive while cleaning up the environment is a win all around.

Conservation Law Foundation is pleased to serve on the Executive Committee to help Vermont’s homegrown Green Mountain Power Cow Power program to pave the way for cleaner air, happier farm neighbors and more successful Vermont businesses.

The program works by turning farm manure into electricity. The average cow produces more than 30 gallons of manure a day. Multiply that amount by 1,000 — the numbers of cows on a typical Cow Power farm — and you have a lot of cow manure. That means there is also a lot of methane, which can be used to create electricity.

Here is how it works. The manure is placed in a digester at the farm that converts the waste into methane gas. The gas fuels an engine that runs an electric generator.

Gases that would otherwise create a nuisance and release harmful and very potent greenhouse gases are instead captured to produce electricity.

Farms have an additional revenue source, and the rest of us have cleaner air and renewable power.

Currently GMP Cow Power farms are producing electricity for nearly 3,000 Vermont homes and businesses. With the expansion of GMP Cow Power so that it is now available to any GMP customer, there are opportunities to grow the program even further. Customers can sign up and make a voluntary 4-cent-per-kilowatt-hour payment on all or a portion of their electric bill. The contribution goes directly to support Cow Power projects to reduce pollution and produce 100 percent renewable power that gets used in Vermont.

Methane is one of the most potent greenhouse gases. Its global warming impact over a 20-year horizon is nearly 75 times more potent than carbon dioxide because methane traps radiation much more effectively. But instead of simply being released into the air, farm methane can be used to produce electricity. This reduces pollution and makes the farm methane projects some of the best fighters of climate change.

These projects don’t just create renewable energy; they effectively capture some of the most potent global warming gasses.

Twelve GMP Cow Power farms remove the equivalent of over 40,000 metric tons of carbon dioxide from the atmosphere every year, in addition to replacing 6,800 tons of carbon from other electric sources. This is equivalent to removing more than 9,000 cars from the highway each year that would have burned 5.3 million gallons of gasoline. These are big numbers — and the biggest benefit comes from removing methane.

Removing farm-generated methane is great but it comes with some real challenges. The first is financial. The equipment is expensive and requires steadfast maintenance to operate smoothly. It is not like a refrigerator you plug in and forget about, and is mostly economically viable only for our larger farms at this stage of technological development.

To be a real success, we need to make this work for smaller farms as well. A few smaller-scale applications are underway that look promising. For instance, some simpler digesters are used in other parts of the world. The ingenuity of Vermont’s farmers and engineers will undoubtedly yield a product that works well on smaller farms within the next decade, but we don’t have it yet.

One way to improve the economics is to find a way to value and pay for the many real benefits of farm methane projects. They are counted now as renewable power, but offer additional advantages as well. One approach would involve credits or payments that recognize their value in reducing methane pollution. That could make it economically feasible to operate smaller-scale projects, or even applications that use digesters alone, without producing electricity.

Another opportunity – and challenge – is expanding the materials used in the digester. Some farms now use additional organic waste in their digesters, such as waste from ice cream manufacturing or fish production. Currently only pre-consumer waste can be used on farms, and off-farm substances cannot make up more than 49 percent of the total digested waste.

New opportunities arise as Vermont moves to expand digesting for managing solid waste. Some organic wastes are very good fuel for digesters and can produce more methane per pound than manure, but the challenge is to make sure the waste is handled well from beginning to end. After digestion is complete and electricity is made, waste and nutrients still remain. We must be careful not to import or spread more nutrients than our land is capable of absorbing on our farm fields. Lake Champlain is already suffering from excess nutrients, and digesting our waste should not be allowed to make this problem worse.

Another new possibility includes expanding how the “products” made with farm digesters are used. Currently farms use the heat produced from the digesters to keep the digester warm. But this heat could also be used to support greenhouses or a new district heating project, among other possibilities. The challenge is to be as resourceful as possible and, like our farms, use as much of the output as possible. This will expand the reduce, reuse and recycle practice even further by adding “upcycling” — converting waste materials into products of better quality or with greater environmental value — while providing an additional revenue source.

Cow Power presents real, exciting opportunities and challenges. The leadership and innovation Vermont’s farms, businesses, utilities and customers have already shown are poised to take these efforts even further.  If you are a GMP customer, your participation in GMP Cow Power and your 4 cents per kilowatt-hour makes a huge difference. Sign up now at: http://www.greenmountainpower.com/renewable/cow/enroll/

(photo credit: flickr/Takashi H)

Like PSNH’s zombie talking points about the Northern Pass project, the company has once again repeated a baseless and misleading claim—this time in a vain hope of sustaining its failing coal-fired business model. Once again, the cold, hard facts belie PSNH’s claim of a $700 million savings to its customers over the last decade.  PSNH customers have lost hundreds of millions of dollars since 2003.

In early 2012, PSNH vigorously opposed a bill that would have required it to sell its power plants, where the market would be deciding their fates. It proclaimed, as it has for a decade, that divesting would be the wrong choice for PSNH customers and New Hampshire residents. A PSNH executive told legislators that “PSNH customers have saved more than $700 million over the last decade because our energy was priced below the market price for most of that time.”

PSNH has repeatedly touted this $700 million savings—most recently in a statement on its website last month—but it has never substantiated the figure. PSNH might have compared its rates to the average spot rates on the wholesale market, or it might have conducted some other irrelevant calculation. What is certain is that PSNH has never offered the most relevant and useful calculation, which is: How much would PSNH customers have paid for electricity if they had been served by a different New Hampshire utility for the past decade? The answer is, less. Hundreds of millions of dollars less.

Using data from PUC dockets, we compared the default service rates for small/residential customers of PSNH and those of Granite State Electric Company (GSEC). For PSNH, all figures were taken directly from PUC filings. For GSEC, figures from 2008 to 2013 were taken directly from PUC filings, and the average yearly rates from 2003-2008 were estimated based on a graph from the PUC Staff Report on Market Conditions, Default Service Rate, Generation Ownership and Impacts on the Competitive Electricity Market, which we explained here. By multiplying the cost differential of the PSNH and GSEC rates by the total kilowatts of electricity PSNH has delivered each year to its customers, we estimated that PSNH customers would have paid about $400 million less if they had been served by GSEC.

PSNH has already spent $40 million buying up land in the North Country for its Northern Pass route—the same amount its customers have lost on average every year. That average yearly loss has jumped to over $100 million/year since 2009.  That’s like buying a smartphone for every single residential PSNH electric supply customer every year, and then throwing them all in the Merrimack River.

PSNH could have purchased power competitively from the market like GSEC, and it could have had the same or even lower rates. As PUC Staff point out in their report: “If PSNH were to no longer own its generation fleet, and PSNH were then to procure its default service requirements as do the other New Hampshire distribution utilities . . . PSNH’s default service rate would more closely mirror prevailing market prices.” But instead it chose to continue running its inefficient fossil plants, forcing New Hampshire ratepayers to subsidize dirty, inefficient energy sources along with mounting costs for PSNH’s failed investments in its power plants, including the astoundingly costly $422 million scrubber project at Merrimack Station.

The good news is that every PSNH customer can choose to escape these costs and not to support these dirty, inefficient plants. 90,000 residential customers have already fled PSNH supply to competitive suppliers, who offer lower rates for cleaner power. This mass migration moves us closer every day to the clean, affordable energy future New Hampshire deserves.

As the PUC Staff Report predicts, the cost of this lost opportunity for PSNH customers will likely grow exponentially in coming years as PSNH’s coal units become increasingly inefficient. No matter how PSNH spins the numbers, the truth blares louder every day: By holding on to its dirty coal plants, PSNH is sucking millions of dollars out of New Hampshire ratepayers and denying the state the clean energy, public health, and economic benefits of a post-coal Granite State.

I recently wrote a post commending and admiring the work that youth all over Massachusetts have done in order to shed light on climate change and to call for action to address it. When it comes to climate change action, the youth of Massachusetts are doing their part in spreading knowledge and creating a strong voice. Unfortunately, Massachusetts DEP does not seem interested in taking the opportunity to work with, or seriously respond to, the youth in their fight for climate action.

Students from the Boston Latin School who are members of Youth Climate Action Network recently spoke to the Massachusetts Department of Environmental Protection. These students, along with Boston College Law students, demonstrated their concern for our futures by creating a petition asking DEP to do more. Mass DEP was required to respond after the hearing. DEP said that they agree with the students’ statements and requests, and said that they were already working on the proposed actions. But the petition was created in order to get DEP to address global warming more aggressively, as needed and required. DEP, rather than admit what they could and should be working on, suggest that they are already doing enough – ignoring that the work they are doing falls short of what the students are asking and what DEP is required to do. DEP’s response embodies an attitude that needs to change in order to address climate change effectively.

It is very discouraging to see the Kids vs. Global Warming petition being taken lightly by the DEP. The Kids vs. Global Warming climate action in Massachusetts was an eye-opener, it allowed for me to see what some climate change fighters looked like.  It was discouraging that on the seldom recent occasion where youth have had the opportunity to speak directly to their government; Mass DEP chose to ignore their request for action. But this fight is not over. Please join CLF in making sure that youth voices are heard by Massachusetts DEP and other government officials in the fight for climate action.

Climate change has made many people concerned for their future. As we see more climate change impacts –such as intense storms, frequent flooding and extreme temperatures – more and more people want to take action to protect their future. There is no question that support for climate action has grown. And even more interesting is the age of many people involved in the growing climate action force.  In addition to the many environmental organizations and groups, many youth have taken a strong lead in the fight for climate change action.

I recently attended a Kids vs. Global Warming hearing at the Mass Department of Environmental Protection and got a good picture of what passionate youth concerned about climate change looked like. Thirteen and fourteen year olds concerned about their future put the climate change issue front and center. The students were well educated in climate change science and had a clear plan for what Mass DEP needs to do in order to protect their future.  As I wrote in an earlier post, the students are calling on DEP to issue regulations under the MA Global Warming Solutions Act. In particular, the petition calls on DEP to “Publish the delinquent rules expressly required by Mass. General Laws Chapter 21N Section 3(d) establishing declining levels of annual aggregate emissions rates as mandated by that law.”

And the “Kids” who brought a petition to Mass DEP are not alone. In addition to the Boston Latin School Youth Climate Action Network, which was involved in the DEP petition, many other Boston high schools have followed Boston Latin’s lead by creating Youth CAN groups in their schools. College students have joined the fight for climate action too. For example, Williams College and Massachusetts College of Liberal Arts students, among others, rallied in February in front of the White House to ask for action in addressing climate change. In addition, many youth are seizing the opportunity this summer to participate in a symbolic walk to call for a transition from coal to wind. Starting August 28,^th young adults will join Better Future Project to march from the Brayton Point coal plant to Cape Cod to bring attention to the opportunity to move away from dirty coal and replace it with clean energy like offshore wind.

As youth fight for their future, climate change takes on an additional profound meaning.  The youth understand all too well the huge impacts that climate change could have if not addressed. Youth all over Massachusetts have recognized the harm that comes from climate change and are asking government officials for action. They understand that what is at stake is their future, and ours. I am proud to be working alongside other motivated youth as we bring attention to climate change action. Committed youth fighting climate change give me hope for the future.

Vermont Gas’ proposed pipeline expansion is an ill-conceived pipe dream that would exacerbate Vermont’s contribution to climate change and fuel our continued reliance on non-renewable energy. Adding insult to injury, this fundamentally misguided expansion would pose both immediate and sustained threats to vital wetland ecosystems, state-significant natural communities, and threatened plant populations. The pipeline demands a full NEPA review and environmental impact statement, just as Governor Shumlin called for environmental review of the Portland Montreal Pipe Line reversal in a recent letter to Secretary Kerry.

As Conservation Law Foundation articulates in this letter to the Army Corps of Engineers, the pipeline expansion would have undue adverse impacts on aquatic resources and fails to meet the criteria established by federal law for a Section 404 individual wetland permit.

The proposed route impacts 25.16 acres of wetlands and streams, including 5.29 acres of Class II wetlands deemed “significant” under the Vermont Wetland Rules and an additional 6.22 acres of Class II wetland buffers. Testimony from Alan Quackenbush, Wetlands Program Manager for the Department of Environmental Conservation, says trenching poses permanent risks to wetland hydrology:

“If the hydrology changes or the soil layers are not removed and replaced in order, these impacts will be permanent.”

Vermont Gas plans to use open cut trenching throughout the majority of the pipeline route, even though horizontal directional drilling (HDD) is a far less environmentally damaging practicable alternative. Despite the availability of HDD, the invasive open trenching method will be used in areas up to 75 feet wide, including parts of state-significant natural communities.

Even testimony submitted by Vermont Gas recognizes the “permanent Project impacts” to state-significant natural communities. These permanent impacts extend to four areas, totaling 3.68 acres, of Pine-Oak-Heath Sandplain Forest designated by ANR as an S1 “extremely rare natural community.” Vermont Gas testimony acknowledges that this ecosystem is “appropriate to be considered RINA,” or a Rare and Irreplaceable Natural Area under 10 V.S.A. § 6086(a)(8).

Testimony from botanist Robert Popp adds that the pipeline construction and permanent removal of forest canopy pose risks to seven state-listed “Threatened” plant species, as well as an additional seven “Rare” species:

“There is concern about the pipeline acting in some areas as a conduit for invasive, exotic species to spread into the interior of what were formerly unfragmented forests and wetlands.”

We’ve been down this road before – the pipeline would rely in part on sections of the same wetland-rich right-of-way of the thwarted CIRC Highway project. The EPA came down hard on the CIRC’s wetland impacts:

“Even if the mitigation were fully implemented, the proposed project will cause or contribute to significant degradation of waters of the U.S. in violation” of federal law.

Vermont needs to maintain in tact wetland ecosystems and actively pursue forward-thinking climate solutions. Let’s wake up from this pipe dream before we get sucked down its slippery slope. 

(photo credit: flickr/macwagen)

With last month’s Northern Pass route announcement and last week’s filing of an amended application for a Presidential Permit, Northeast Utilities and PSNH have repackaged and repeated the very same arguments for the project that have filled air waves and op-ed pages throughout New England for nearly three years. We keep hearing the same sales pitch—cleaner air, a more reliable grid, economic prosperity, low-cost energy—with the same numbers: 5 million fewer tons of carbon pollution, 1,200 jobs, and millions in energy savings and tax revenue.

From a distance, the claims look real enough; on closer inspection, it becomes clear that they were born in a long-gone energy landscape and are aggressively deceptive. And they live not only in Northern Pass’s marketing materials, but in the disseminations of Northern Pass’s cadre of PSNH-aligned supporters, such as this recent op-ed by an avowed clean energy opponent who worked for a group that calls climate change “pseudo-science.”

CLF and others have been examining and debunking these talking points for a long time. But like zombies, they keep coming back. And there is perhaps no uglier member of Northern Pass’s living dead than the claim that Northern Pass will reduce carbon pollution by up to 5 million tons per year.

The number is an estimate of the carbon dioxide emissions from the typically natural gas power that Northern Pass imports would displace in our regional energy mix, based on a 2010 market modeling report by an economic consultant hired by Northern Pass—a report that, despite numerous references to it in the project’s amended application, no longer appears on Northern Pass’s website but is available here (25 MB PDF). The estimate assumes four things:

Assumption No. 1: Northern Pass power would not result in any carbon dioxide emissions. (See pp. 5 and 34 of the report.)

This is unequivocally wrong. Scientific research conducted by Hydro-Québec scientists and published in peer reviewed journals says just the opposite. The science confirms that, by flooding vast areas of boreal forests, new large-scale hydropower facilities have net greenhouse gas emissions (from the decomposition of flooded biological material, the elimination of forest carbon “sinks,” and other sources) that may initially exceed those of natural gas power plants and that, despite declining and producing fewer net greenhouse gas emissions than natural gas over time, may continue at meaningful levels even over the long term. Northern Pass’s continued “zero-carbon” assumption is dishonest and cynical, especially given the fact that Northeast Utilities has submitted summaries of the very same research findings on hydropower emissions to regulatory authorities and has steadfastly refused to change its marketing materials despite CLF’s effort to point out the error.

Assumption No. 2: Over the next ten years, New England’s energy market will look like government forecasts predicted in 2010. (See pp. 23-24 of the report.)

Northern Pass’s 5 million ton estimate is highly dependent on outdated modeling of an energy market that no longer exists. Its consultant report was prepared three years ago—in 2010—with U.S. Energy Information Administration forecasts of energy commodity prices, including natural gas prices approaching $7 per million cubic feet by 2022. The forecast price of natural gas is crucial to predicting how Northern Pass power will affect New England’s energy market because that price helps determine the market price of electricity in New England. Since 2010, domestic natural gas supplies have driven down prices, and the EIA’s forecast has changed dramatically, now estimating that average prices won’t crack $5 until 2026. (The spot natural gas price today is well below $4; the 2010 projection for 2013 was $6.13.) While CLF and many other stakeholders are deeply concerned about proposed long-term investments in natural gas (and their climate impacts), there is no denying that the fuel’s role in the region’s energy market is different than what was predicted in 2010.

In addition to lower power prices in New England, the report failed to account for the availability of an additional path for Hydro-Québec to export its power—the Champlain Hudson Power Express—which won approval from New York officials earlier this year and is in the process of obtaining federal permits.

All this means is that Hydro-Québec will likely sell less power into New England than previously estimated, replacing (by Northern Pass’s own logic) less natural gas power and its associated pollution.

Assumption No. 3: Hydro-Québec will continue to build more hydropower facilities, including the Romaine River dams that are under construction, which will facilitate additional exports to the United States. (See pp. 2 and 28 of the report)

The report on which Northern Pass’ claimed 5 million ton greenhouse gas reduction is based explains that “[i]n reality, the additional transmission capacity provided by [Northern Pass] could lead to additional development of resources to support exports from Québec….” In fact, the 5 million ton estimate is only that high because it includes emissions reductions (which are inflated for the reasons identified above) that will happen if Hydro-Québec develops new hydropower projects and as a result has more surplus energy available than it does today. (If not, the report itself predicts emissions reductions of only about half the 5 million ton estimate.) The assumption suggests that Hydro-Québec will rely on a succession of new projects –the Eastmain-Rupert River complex just completed, the Romaine River complex under construction, and the Magpie and Petit-Mécatina complexes that are in Hydro-Quebec’s strategic plan—to feed exports to New England.

With this context, the 5 million ton estimate is even more unrealistic because the short-term greenhouse gas emissions of new projects are worse than older facilities. The assumption of new projects in Canada is noteworthy as well because, while consistent with sworn testimony by a Northeast Utilities executive about the source of Northern Pass power, it is directly at odds with Northern Pass’s repeated refrain that Northern Pass power will merely be excess “system power” from Hydro-Québec and won’t require the construction of new hydropower facilities. (See p. 6, footnote 1 of the amended application.)

Assumption No. 4: There won’t be any greenhouse gas emissions associated with the energy that Québec’s other neighbors may need when Northern Pass comes online and more Hydro-Québec power flows to New England.

Where would Hydro-Québec sell its energy without Northern Pass, and what power sources other than Hydro-Québec power will those places use if Northern Pass is built? Whether Northern Pass has any climate benefit depends on the answers. The report’s estimate of increased Hydro-Québec power sales into New England predicts that New England will get power that would otherwise flow to New York and Ontario. (See p. 27 of the report.) In both markets, natural gas is the marginal fuel, meaning that it both sets energy prices and tends to be the power source that makes up for unavailable sources. In other words, it would be reasonable to assume that natural gas power plants in New York and Ontario will run more if Northern Pass is built and shifts Hydro-Quebec’s exports to New England. Northern Pass’s 5 million ton greenhouse gas reduction estimate wrongly assumes that other regions’ replacement power won’t have any carbon emissions—in fact, it doesn’t address this critical issue at all. Because climate change is a global phenomenon, what we have here looks like a shell game: the supposed climate benefits of Northern Pass from displacing natural gas power in New England could very well be cancelled out by power plants in other regions burning natural gas (or other fossil fuels).

With all these assumptions in the open, Northern Pass’s 5 million ton estimate is, in a word, indefensible. Northern Pass’s strategy of endlessly repeating this 5 million ton fabrication—to investors, to permitting agencies, and to the public— signals that Northern Pass version 2.0 will be pursued with exactly the same adversarial, greenwashing tactics that accompanied version 1.0. Worse, it reflects apparent contempt on the part of Northeast Utilities and PSNH for well-informed dialogue regarding a key supposed benefit of their project.

And we certainly need a rational, fact-based dialogue as the region embarks on what CLF hopes will be a productive and rigorous process for considering the merits of and best options for importing more large-scale hydropower from Canada. A clear-eyed regional approach requires real, well-grounded numbers addressing pollution and economic impacts. (The now-revived permitting process for Northern Pass needs them, too.)

Zombies need not apply.

A full environmental review is needed before Vermont Gas Systems digs up wetlands and pollutes the air.

Federal law requires a full review for major projects – like pipelines – that will have significant environmental impacts. The Vermont Gas project should not be exempt from this requirement.

The proposed gas pipeline planned for Addison County would use publicly owned rights of way. Land acquired with federal tax dollars. When federal land is used for a major project, the environmental impacts need to be fully evaluated. That’s the law. And it only makes sense that before we allow our tax dollars to support major projects, we know what the environmental impacts are.

In a letter to the Federal Highway Administration, Conservation Law Foundation is calling on the Agency to undertake this needed review.

The significant wetland, water resource, habitat and air pollution impacts have already been noted in testimony filed with the Public Service Board. Vermont Gas plans to use a right of way that was acquired for the Circ Highway and has already been shown to have significant and valuable wetlands. A full and new review is needed for the gas pipeline.

Before we blindly commit to a pipeline that will have far-reaching impacts for generations, we need a thorough and transparent understanding of what is at stake.

Read CLF’s letter here.

On July 8, 2013 the Governor of Connecticut, Dannel Malloy stepped up to the microphone and made a series of major announcements about the critical topic of energy.

Governor Malloy’s first task at the podium was to present the law he had just signed which set in place and partially implemented a Comprehensive Energy Strategy for the Nutmeg State. As CLF said in our press statement, this new law position Connecticut to take critical steps toward reaping the benefits of energy efficiency, our strongest, best and most widely available renewable resource.  The State can create the much-needed jobs and consumer savings it seeks by ramping up the state’s electricity and natural gas efficiency programs, rather than rushing to build costly and unnecessarynew natural gas infrastructure. Under its energy strategy Connecticut is moving to foster some great infrastructure, like charging stations for electric vehicles, but is also taking some very questionable steps towards building new natural gas pipes that will last for decades – long after we will have had to kick the fossil fuel habit if we are going to avert climate disaster.

The second subject of the announcement by Governor Malloy was the official launch of a large-scale purchase of energy from wind and solar power projects.  Thanks to this purchase, Connecticut residents will benefit from cleaner air, more stable energy prices and new, green jobs. This initiative allows Connecticut to join with Massachusetts to purchase energy ‘in bulk’ and have each state recognize the considerable economic benefits of regional collaboration. Connecticut’s purchase seeks to bring under contract wind power capable of producing over 500 Megawatts of electricity – which means that during peak wind conditions those wind farms will be producing more power than the mammoth and obsolete oil and coal power plants that blight the waterfronts of Bridgeport and Norwalk.  However, as we also noted in our statement, the renewable energy law which enables the purchase contains potential pitfalls alongside its promise of new wind and solar development, especially as regarding imports of large hydropower from Canada.  Butif implemented correctly, the renewable energy purchase will ensure that hydropower imports will complement rather than inhibit homegrown wind and solar development.

The Mars Hill Windfarm in Maine.

CLF is proud to have played a role in moving the renewable energy purchase forward and reducing the risk that imported hydropower will be used inappropriately. We look forward to working to ensure that this balance is maintained with imported hydropower playing an important supporting role behind wind and solar power while displacing fossil fuel fired power generation.