On February 6, 2022 an article of mine was posted: New York Climate Act: Is Anyone Listening to the Experts? This post shows that the experts are saying now that there is a major problem with New York’s plan for a “zero-emissions” electric grid by 2040. Unfortunately, the message is buried in a technical analysis product and expressed in jargon so the warning will likely be ignored.
New York’s Climate Leadership and Community Protection Act was passed in 2019 and became effective on 1/1/2020. The Climate Action Council has been working since then to develop plans to implement the Act. Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”. Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.
My last post here described the New York Independent System Operator’s (NYISO) 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year. The difficulties raised in the report are so large that I raised the question whether any leader in New York listening to this expert opinion. This post highlights results shown in a draft presentation that all but admits meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.
I have discussed the ultimate problem before so will only sum up here. In their presentation to the Power Generation Advisory Panel on September 16, 2020 E3 included the following figure. The problem is that there are significant periods when winds are so low that wind generation output is negligible and, especially in the winter, solar output is also low: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”. The presentation notes: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits”. New York has substantial existing hydro resources but cannot be expected to develop much more. Nuclear is the obvious choice going forward but New York policies shut down 2,000 MW of nuclear capacity in the last couple of years so that is unlikely for the net-zero plan. The ultimate problem is what Dispatchable Emission Free Resource (DEFR) will be used to supply electricity during multi-day winter wind lulls. In the CRP NYISO stated: “While there are hundreds of projects in the NYISO interconnection queue, there are none that would be capable of providing dispatchable emission-free resources that could perform on a multi-day period to maintain bulk power system reliability. Such resources are not yet widely commercially available.”
A bit of background about the NYISO. It is the Regional Transmission Organization/Independent System Operator for New York State. Independent System Operators (ISO) grew out of the orders that enabled de-regulation of the electric system. The concept of an Independent System Operator was one way for existing tight power pools to satisfy the requirement of providing non-discriminatory access to transmission. The Federal Energy Regulatory Commission encouraged the voluntary formation of Regional Transmission Organizations (RTO) to administer the transmission grid on a regional basis throughout North America (including Canada).
The NYISO Electric System Planning Working Group (ESPWG) is the stakeholder group that provides Market Participant input on the NYISO’s comprehensive planning processes. On March 24, 2022 the NYISO Economic Planning Department made a presentation to the EPSWG on their System & Resource Outlook Update. The presentation itself is a draft – “for discussion purposes only” so the specific numbers are not finalized. The point of referencing this analysis is to show what the experts are saying now about the critical dispatchable emissions-free resource needed for the net-zero electric system transition. The purpose of the System & Resource Outlook analysis is to project what electric generating resources will be needed to maintain a reliable electric system in the future. The Economic Planning Department is collaborating with EPSWG and the presentation was to designed to solicit EPSWG and stakeholder input.
This type of capacity expansion modeling analysis develops a reference case that represents what is expected to happen to the system without any changes to “business as usual”. Then the analysis develops “Policy” case simulations and the model calculates an optimized projection of what capacity is needed as the Climate Act policy is implemented. The presentation described 27 different policy case scenarios that covered a wide range of different possible outlooks for the future. For example, they included two different low load projections for the future that, not surprisingly, were predicted to need much less future generation capacity. Scenarios to consider increased imports from Canada, different cost projections for wind and solar capacity, changes in nuclear retirements, and lower hydro output were also included. In addition, there were six scenarios that considered different future projections for DEFR were included.
In response to a request from the EPSWG three DEFR build types were addressed:
- High Capital, Low Operating (HcLo)
- Medium Capital, Medium Operating (McMo)
- Low Capital, High Operating (LcHo)
As has been the case for all the other analyses to date, these build types are only proxies for what could happen if a DEFR were to be developed with the identified characteristics. The authors chose three cost and operational profiles to show what kinds of DEFR would be built. These build types were included so that the capacity expansion model can provide solutions to load requirements and build resources if they are economic to build using the assumed characteristics.
What the Experts are Saying
The following two slides from the presentation are the focus of my claim that the experts are warning there are problems with the New York transition to net-zero. The first slide describes one of the policy case scenarios in the analysis described above. I have highlighted one of the caveats: Significant uncertainty related to cost / availability of DEFR technologies, as well as regulatory definition of “zero-emissions” compliant technologies.
Figure 1: NYISO System & Resource Outlook Update Dispatchable Emission Free Resource (DEFR) Scenario Description in March 24, 2022 Presentation to EPSWG.
The following DEFR capacity expansion scenarios slide describes the assumptions used for five different scenarios. I have highlighted the note: Assumption included in the scenarios are not an endorsement or estimate of the validity of the values modified. Some scenarios do not represent realistic system performance but are helpful in identifying directional impacts and sensitivity to key variables.
Experts from the NYISO, the organization primarily responsible for keeping the lights on, said there is “Significant uncertainty related to cost / availability of DEFR technologies, as well as regulatory definition of “zero-emissions” compliant technologies” and that “Some scenarios do not represent realistic system performance but are helpful in identifying directional impacts and sensitivity to key variables”. For people familiar with the jargon and the electric system these are red flags. Let me unpack the statements for everyone else.
Dispatchable emissions free resource technologies do not exist at this time to provide power for the long-duration periods when wind and solar resources are expected to provide minimal generation. This kind of technical report says “significant uncertainty” because they can’t flatly say “we don’t think this will occur”. Because they don’t think there is a resource that will be available, they certainly can’t guess a cost. A scenario that does not represent “realistic system performance” pretty clearly says that we cannot expect the system to perform as needed with the scenario’s resources. This is as close to telling the Climate Action Council that their “plan” to go to zero emissions by 2040 is not going to happen as it gets without actually explicitly saying that. In a perfect world an “independent” organization would just tell it like it is, but this is the state of New York so politics color everything including the future of the electric system.
Furthermore, during the presentation discussion the point was made that the capacity projected numbers indicate an enormous amount of generation is needed. That result was described as just “stunning”. Someone asked whether anyone on the Council is looking at what this means. These experts are clearly worried about the enormous resources that have to be built to meet to transition the New York electric grid to a net-zero. That concern is above and beyond my concern about DEFRs.
There is one other aspect of the first statement that needs to be addressed. The reference to the “regulatory definition of ‘zero-emissions’ compliant technologies” is included because the Climate Action Council has not defined what is meant by “zero-emissions”. Several of the most vocal members of the Council believe that zero-emissions means no combustion and are determined to impose that restriction. All of the New York analyses that have tried to project what types of generation and how much from each type will be needed for the future net-zero electric system have included combustion generation using hydrogen or renewable natural gas. The leaders of the Council have not had the courage to tell the members who have no reliability responsibilities and little relevant expertise “Sorry, even if we combust those arguably zero-emission fuels, there still are great risks to a feasible system that is reliable. If we don’t use them the feasibility risks are so high that the system will be unreliable”.
The NYISO capacity expansion modeling has been forced to be consistent with the Draft Scoping Plan by using DEFR technology and building enormous amounts of generating capacity. The capacity resource modeling is based on what is needed to keep the lights on rather than whether dispatchable emissions-free resources that provide those resources will actually be available. The authors of the report essentially say that they don’t think DEFR technologies will be available but I don’t think the message is blunt enough to force the Climate Action Council to respond.
Not so long ago the idea that natural gas could be used a bridge fuel until these aspirational dispatchable emission-free resources could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a rational approach. The analogy for skipping the need for a bridge fuel is that proponents want to jump out of a perfectly good airplane without a parachute because they assume that the concept of a parachute will be developed, proven technically and economically feasible, and then delivered in time to provide a soft landing. That cannot end well and this won’t either.
Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. More details on the Climate Leadership & Community Protection Act are available here. This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.
Without nuclear, dispatchable emissions free relies on unicorn farts, i. e. something one can describe but does not exist. Especially if they specify that the source be combustion free, which rules out CCS.
Most promoting this “transition” are against nuclear power. It seems they are leading us down this path that hides the fact that their policies lead to extremely high energy costs and reductions in the standard of living.
Like those pretending that KBJ gave a reasonable answer in being unable to define “woman” because she’s not a biologist, roughly the same people think that solar can produce electricity at night or wind turbines when it’s not blowing. They confuse capacity with actual power generation. Politicians take advantage of this ignorance.
Good article Mr. Caiazza.
It’s ironic to see fossil-fueled and nuclear power plants referred to as “back-up” for renewables when they are needed 60%-70% of the time.
That “Figure” is very telling…
It shows a typical 21 days in Winter (low Sun angle) indicating Wind and Solar supplies vs Load. Of the 21 days shown wind and solar met demand 7 days (1 in 3) and almost met it 3 other days. However, wind and solar cell flat on 11 days and spectacularly for 1 week straight.
Obviously, what is needed is priority research on how humans can hibernate for one to two weeks at a time.
While heat is important, many other aspects of adequate life other than just people keeping warm depend on constant power use.
One of the findings in the capacity modeling analysis is that for the high DEFR scenario it was cost-effective to build nuclear capacity. The attendees had a chuckle about the feasibility of that.
I would assume that the unicorn farts would need to be “combusted”, so I don’t see how they would be any better than any other source of energy.that can be described but does not exist.
When unicorn farts are oxidized (this occurs at very low temperatures) the carbon/unobtainium/nitrogen matrix acts a a catalyst and through a two step process forms N2, O2 & excess energy. The remaining dense carbon matrix is a resembles a diamond, but reflects differing colors from each facet due to the remaining interior filamentous unobtainium.
Somewhere along the line I began to wonder if the author was attempting to channel:
a. Mel Brooks
b. Jerry Seinfeld
c. Lewis Carroll
Perhaps it was an impossible task. To attempt to clarify or decipher the original article.
Then again I went to a state school. I settle on “a parody of a parody”?
“If you don’t know where you are going there are many ways to get there”
“Unfortunately, the message is buried in a technical analysis product and expressed in jargon so the warning will likely be ignored.”
Unfortunately? Or deliberately?
So, the implication is they will proceed with all haste until the idea hits the buffers. Then presumably it’s rationing.
Nuclear is in their terms green and because it is an obvious choice – if you buy into the idea that CO2 is a problem – it must be opposed.
The climate crisis requires a permanent state of crisis with NO solution.
The people doing this work don’t make the decision about the messaging. The problem is that there are people in every State agency, every generating company, and every load serving entity (aka the utility companies after de-regulation) who understand this problem and have undoubtedly informed their management. Those folks are the ones who deliberately are ignoring the implications.
“The people doing this work don’t make the decision about the messaging.”
And they all want to keep their jobs etc
Only when they retire or leave office do they pipe up.
Well, if you can’t dazzle them with brilliance,………….
“In response to a request from the EPSWG three DEFR build types were addressed:
How on earth, or anywhere else, is it possible to “analyze” these “build types” when there are no such machines of any sort that can do the job other than nuclear – which isn’t allowed. The issue is imbedded in bafflegab. The whole NYS green program is bafflegab with no roots in reality whatever. The only way for the State to provide emissions-free electricity is nuclear power with fleet of base load plants and perhaps some variable capacity plants if the base loads cannot be designed do the variation job. At least that is analyzable. The result could be debated among energy experts, environmentalists and others with at least a firm factual basis in reality.
And somewhere in New York, a large number of people are being paid to produce such nonsense. From your writings Mr. Caiazza, it seems you are not one of them. Perhaps you should switch sides and at least make a wage off the issue as so many others seem to do.
I am retired. Besides the vast fossil fuels conspiracy is paying me bundles of cash so I don’t need the work.
not sure if this is off topic or not, but since you are obviously familiar with the energy situation in NY, I was wondering if you had any thoughts or insight on whether they will ever allow fracking and development of natural gas in NY, or is that forever dead in the water?
In the reforming of a primitive civilization after the unavoidable total crash, who can say what might be possible?
Alas I think that won’t be on option unless everything goes badly and even then the zealots will probably not admit that fracking that works in adjoining Pennsylvania could work in New York.
My mom grew up in a small town in northern PA right on the NY state border. I spent a lot of time up in that area when I was a kid.
Ekspurts? Ekspurts? We don’t need no damned ekspurts….
I’ll say it again — You have to build the replacement infrastructure before you tear down the existing infrastructure. But we’re going to eliminate fossil fuels first and then hope the new technology magically appears.
What’s amazing, is that “brilliant” politicians around the world are doing just this. From the US to Germany and Australia, they’re all in the fairy dust power business. Worse yet, the politicians either ignore or don’t bother to look at the experience of the “destroy first” countries.
Just like Brandon, it won’t be any of these people’s fault. It will be the engineers that screwed up the fine job of planning that the non-engineers did.
Been there, done that!
“You have to build the replacement infrastructure before you tear down the existing infrastructure”.
Sorta like you have to evacuate the people before you abandon Bagram air force base……
or: “We have to pass the bill so that you can find out what is in it”
Just like a stool sample.
What I found helpful is the math of trying to replace the 175,000 terawatt hours of energy that the world consumes each year to reach zero carbon emissions by 2050, the billions of people with little or no access to energy not withstanding. Two nuclear power plants per day every day until 2050. Or cover the entire USA one hundred times over with solar panels, with the sun shining 24/7.
‘The authors of the report essentially say that they don’t think DEFR technologies will be available but I don’t think the message is blunt enough to force the Climate Action Council to respond.’
Even if the message was sufficiently ‘blunt’, it would not get through the media filter that effectively protects the narrative from any real public scrutiny. This means that the CAC and Albany have free rein to impose their draconian plans on NYS’s largely clueless citizens.
As others have said, there are no ‘DEFR’ technologies outside of nuclear power, to which I might add NYISO could consider ‘darkening the skies’ with transmission lines up to Quebec.
They will never develop a plan: Any plan that meets the 2030 and 2050 politician-designed legislative goals will be so obviously insane that it cannot be papered over in the press. Not everybody can be bribed or bullied into silence. Elections will intervene; look what is happening with the anti-FF politicians now demanding more production (while blaming the companies for shortages). People will not put up with unnecessary privations.
Maybe GISS could loan their experienced data adjusters to NY electrical folk. One reason there is no definition of Net Zero, is they need a big manipulable fudge pot. It will become the repository for the goofy, dangerous ideas needed to tuft NY with windmills and glaze it with solar as has already been decided by the gray complected minions. They have their own experts.
It’s similar in UK. All these sensible people toiling away at these numbers yet nobody understands what Net Zero actually IS? Doesn’t anyone stop and say hey we can’t go further until we know what we are trying to do ? Irrespective of the total futility of the whole exercise.
We have this situation at present in the UK, with wind genrated power running at c3% of demand for the past 5 days.
Natural gas is making up the major part of demand, with solar by day, coal producing 5%, as is nuclear, and much of the rest being bought from overseas generators who use a variety of methods. Even the Drax woodchip burner is only producing 1% of demand.
As a result of the natural gas shortages, electricity prices are going through the roof.
The whole present system of generation in the UK is not fit for purpose, and is run like having a car but keepinng a taxi with the engine running in case your car runs out of fuel. I.e. a total waste of money.
What is the answer?
Allow the oil and gas companies to drill again to provide our own gas and oil instead of helping Putin pay for his war?
Roll out Small Modular Reactors?
Upgrade coal power stations to use the new increased efficiency systems?
Use wind and solar, when they are working, to produce hydrogen which might (could someone more knowledgeable provide the answer) be capable of being stored in the short term for blending with natural gas?
On the demand side it would seem to be better to improve the efficiency of existing systems rather than throwing them all out and starting from scratch, with the exorbitant costs involved, as well as problems with raw material availability and cost.
The only reasonable use for batteries would be to help stabilise the grid, although generators with built-in inertia should be able to provide this anyway.
By the way, the UK wind drought looks to be set to continue for another 5 days according to Metcheck.
“capacity expansion modeling has been forced to be consistent with the Draft Scoping Plan…”
IOW square peg, round hole and hammer. Some assembly required.
So New York State volunteers to be another crash test dummy.
The more, the merrier.
The ultimate underlying plan for NY and New England is importing power from Hydro Quebec with or without the locals in the way of power line development. Everything else is theatrics.
The Champlain Hudson Power Express project is an underground transmission line from Quebec to New York City that will deliver 1,250 MW of hydro generation. One small detail mentioned at the meeting was that there is no guarantee of delivery in the winter. When the grid turns into a winter peaking system because everything is electrified it will be worthless when needed most. Nuts is too kind a description.
And what happens when Canada goes down the same path as New York State and Canadians realize they need that hydro power to make up for their loss of power generation?
When everyone really starts shutting down natural gas, coal, and nuke plants en masse there won’t be any extra power left to export anywhere else.
This reads like The Emperor has no Clothes. Perhaps they should call it “The Empire State has no Current”.
Close relatives of mine who live on Long Island in New York State, in upper New York State near the Great Lakes, and in the Bay Area of California — and who are all anti-nuclear — cannot grasp the serious reliability issues that a transition into wind and solar present.
Referencing the closures of the Indian Point and the Diablo Canyon reactors, when I tell these people that within a decade’s time, they must become accustomed to using two-thirds or less as much electricity as they do today, they refuse to even consider the possibility that what I’m saying might be the truth.
They cannot believe that those responsible for making our power planning decisions would be so reckless as to follow a policy which guarantees that our supply of electricity will become far less reliable than it is today.
Concerning the future of nuclear power, the reality here in the US is that a decade of hard work is needed to demonstrate that a nuclear power plant can be built on cost and on schedule.
Forget the 1100 Mw AP1000 size unitary reactors. These will never be cost competitive in the US in comparison with the oncoming SMR designs whenever policy makers decide to include nuclear in their zero emission portfolios. IMHO, NuScale’s design will be the first SMR to reach commercial operation.
The Biden Administration’s carbon emission policies guarantee that much of our coal-fired and gas-fired generation capacity will be retired early and without replacement. When shortages of electricity become acute, my prediction remains that portable gas turbine peakers will be authorized on an emergency basis and will be deployed wherever needed to shore up the grid.
Some number of these portable units will be fueled by LNG and will deployed to the sites of shuttered coal-fired power plants, assuming the power transmission infrastructure has been retained onsite after their closure.
How will the LNG be transported if there isn’t a gas pipeline nearby? IMHO, the LNG will be delivered by railroad tank car over the same tracks that coal was being delivered while the coal-fired plant was operating.
When people realize that they have been lied to, and their standard of living has declined to unacceptable levels, there will be a reckoning — unless those in power have installed a foolproof method of rigging the elections that cannot be exposed. But to insure that they maintain unchallenged power, they will also have to disarm the public, in the name of public safety. I’m almost glad that I won’t live to see the day.
Some places, such as California and parts of Australia, are installing several hundred MW diesel powered generating stations in an attempt to prop up their stupidity. This is essentially the same as home owners installing back-up diesel powered generators in order to avoid freezing, having their food spoiled, etc., i.e. to escape the consequences of their beloved elected representatives stupidity. Of course, most said homeowners will continue to support said representatives.
Don’t bet on the railroad lines being there. Unused rail lines have been destroyed and returned to the land owners along the right-of-way for more than two decades here. I believe in Kansas at least, that is a requirement set forth by the state Corporation Commission. I’ll check on that further.
Or turned into bike paths…
In South Africa, the unused railway lines have been turned into ‘unofficial’ scrap. I.e. they’ve been stolen – along with rail power and signalling cables, and anything portable from the railway stations that have been left unused and unguarded over the last two years of lockdown!
This will be a problem — another reason why quickly deployable diesel engine peakers might be effective competitors for gas-fired peakers if emergency authorization is needed to shore up a failing wind & solar contaminated grid.
Concerning the future of nuclear power, the reality here in the US is that a decade of hard work is needed to demonstrate that a nuclear power plant can be built on cost and on schedule.
Sadly true of the West in general while China gets cracking with SMRs-
World’s First Small Modular Nuclear Reactor Starts Producing Energy in China (interestingengineering.com)
I‘ve mentioned this study ‘Metal Demands for Renewable Electricity Generation in the Netherlands‘ on a couple of other threads earlier this week. Here are some more excerpts
“The current global supply of several critical materials is insufficient for transition to a renewable energy system. Calculations for the Netherlands show that production of wind turbines and PV solar panels already requires a significant share of the annual global production of some critical metals.”
“Looking at the global scale , scenarios in line with the goals of the Paris Agreement require global production of some metals to grow at least 12 fold towards 2050 compared to today’s output. Specifically demand for neodymium, terbium, indium, dysprosium and praseodymium stand out. This calculation does not include demand for these specific metals in other applications, such as electric vehicles or consumer electronics.”
“Opening a new mine takes 10 – 20 years and large capital investment making it difficult to meet a rapid increase in global demand with a comparable increase in global supply.”
“A renewable energy system requires more than just renewable electricity production. The inherent intermittent nature of energy sources, such as PV and wind, means they require a significant buffer. The material requirements of the energy buffering infrastructure will be very significant. Additionally, the transport sector will have to move to zero emission vehicles. which also demands significant critical metal use. Finally a stronger and more resilient electricity grid is needed to ensure a stable power supply: for this critical metal demands increase as well.”
“If the rest of the world would develop renewable electricity capacity at a comparable pace with the Netherlands a considerable shortage would arise.”
Remember the population of the Netherlands is around 17.2m
It’s also important to remember that Local Law 97 comes into force in 2024.
This law requires all large buildings to reduce emissions.
It will be a bureaucratic nightmare.
The report bloviates: “zero emission resources, such as bioenergy”
I know a unicorn fart when I smell one.
Net zero is a fiction. The place to start solving this problem is to stop hiring these over educated fools to write the reports. If the reports were written at a high school level everybody could understand it and the net zero fiction would instantly become abundantly clear. Simplicity, clarity and truthfulness should be the bedrock for all reporting.
We can follow the German experience and convert to wood burning stoves and fireplaces. Until, like the Germans, the idiots are out and coal, gas, nuclear, oil, etc. are back on the table. “Experience keeps a dear school, but fools will learn in no other.” Ben Franklin
The chart is misleading. The peak wind and solar output exceeds the peak demand. That tells me it is modelled generation but there is no where to suggest that it is modelled.
New York is on a par with third world countries that rely on power barges to keep the lights on. Grid planning is non existent so they rely on expensive quick fixes instead of system planning.
New York currently gets less than 5% of its energy from wind and solar:
Loved this presentation as a rational and reasoned argument. But you’re obviously an engineer. Not know for writing prose. This could have been dramatically simplified by putting a draft in front of someone that does know how to write but not burdened by “EnGinEer SpeeK”.
All the logical connections exist within what you wrote. But are difficult to make without reading and then re-reading. Putting a period within a sentence, every once in a while, improves comprehension.
I know whereof I speak. My first job after leaving the Navy was as a Word Processor at a Naval Engineering firm. I was typing something written by an absolutely BRILLIANT engineer and discovered that I had typed an entire paragraph. It filled an entire page. The only period was at the end.
I re-wrote it. He thanked me profusely.
This is a critique, not a criticism. I find this contribution to be both well thought and worthy of consideration.
I can use all the critiques I can get. I will work on cutting down the length of the sentences. One problem in the current target rich environment is that I cannot keep up commenting on everything that needs to be called out. Consequently not enough time to review the draft well enough before posting.
Your parachute analogy is one I’ve also used. It’s spot on. Though in my version, its our “betters” that throw us out of the airplane, “confident” that our ingenuity will allow us to invent and deploy parachutes on the way down – while actually not caring one way or another whether that happens or not.
The acid test to establish if Green energy advocates are coming back down to earth or not, is to listen to what they say. If they mention hydrogen production, via electrolysis. If they claim using excess wind/solar energy to crack hydrogen needed to power motive needs and domestic heating in their future vision. Then you know, they are still away with the fairies somewhere over the rainbow,…. way up high..
I am wondering if that way up high condition is something that is driving the collective Green lunacy? They are addicted to a gas molecule to explain everything, but it clearly isn’t CO2……