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Stimulus News Roundup By SGN Staff May 5, 2009 - 11:06:07 AM
President Obama pledges $467M to accelerate geothermal and solar. Newly promised funding will help deal with technical barriers, demonstrate new technologies, and support clean energy jobs. The critical areas sharing the geothermal funding are: demonstration projects ($140 million), R&D for Enhanced Geothermal Systems ($80 million), innovative exploration techniques ($100 million), and a National Geothermal Data System Resource Assessment and Classification System ($30 million). Solar funding is allocated for: photovoltaic technology development ($51.5 million), solar energy deployment ($40.5 million), and concentrating solar power R&D ($25.6 million). “We have a choice. We can remain the world's leading importer of oil, or we can become the world's leading exporter of clean energy," President Obama said during the announcement. Quick Take: The solar industry was hit hard by the economic meltdown, and this is the kind of recharge it was hoping for.
More DOE funding opportunities
U.S. industrial sector gets a slice of the pie for energy efficiency. Energy Secretary Steven Chu announced Monday that $256 million in ARRA funds will be allocated to energy efficiency improvements in manufacturing and IT. The secretary said the funding will generate jobs — quickly — in manufacturing, operating and maintaining the equipment. The funding focuses on three primary areas: Combined heat and power, district energy systems, waste energy recovery systems, and efficient industrial equipment: $156 million Improved energy efficiency for information and communication technology: $50 million Advanced materials in support of advanced clean energy technologies and energy-intensive processes: $50 million The secretary also noted that, in addition to creating jobs and reducing energy consumption, projects would reduce greenhouse gas emissions.
Tech vendors will benefit from rigorous reporting requirements. Tech companies are throwing their nets in the stimulus pond with new software to cope with the ARRA’s management and reporting requirements. Early entries include Microsoft and SAP. Observers note that development of the tailor-made software has been surprisingly fast, and that’s a good thing. The COO of San Francisco’s Department of Technology said that after reading the stimulus reporting requirements, he thought it would take 18 to 24 months for his IT people to build reporting software in-house. Quick Take: When you consider that states and municipalities are a collection of relatively independent agencies, it’s pretty clear that a reporting and management system must be coordinated, compatible, and fast. Considering that OMB's first deadline for stimulus reporting is Oct. 10, rapid deployment of the new software is essential.
Govtech.com story with more about the vendors
Industry and academia to team up on wind energy. DOE has issued a Funding Opportunity Announcement (FOA) for $24 million to for industry/university consortia to research solutions to the biggest challenges to efficient wind energy. Applicants will need to address two topics: partnerships for wind research and turbine reliability and wind energy research and development.
Nearly $50 million going to geothermal heat pump deployment. The funds will be used to support and advance commercial deployment of geothermal systems that provide both heating and cooling. The DOE announced projects in three primary areas: innovative technology demonstrations, life cycle cost tools, and a national certification and accreditation program. Geothermal heat pumps can be more efficient than the air-source pumps typically found in commercial and residential applications — and can significantly reduce electricity demand and maintenance costs.
DOE isn’t the only game in town for renewable funding. The Bureau of Land Management (BLM) will invest $41 million in ARRA funds to enhance development and transmission of renewable energy on public lands. The money will be used to whittle down the backlog of applications for solar and wind projects on land managed by BLM and will assist in siting and regional planning for future solar, wind, biomass, and geothermal projects. As part of this effort, BLM will open four Renewable Energy Coordination Offices in Nevada, California, Arizona, and Wyoming; and establish smaller offices in Utah, Idaho, Oregon, New Mexico, and Colorado.
Quick Take: Companies searching for renewable energy project stimulus funding can/should look beyond DOE for opportunities. Remember – if it involves renewable energy, it almost always involves the Smart Grid as well.
DOI/BLM news release on stimulus investment
Read It News report on new coordination offices
Smart Grid companies to DOE: It's still not quite right. Although DOE responded quickly to industry calls for a higher grant cap for ARRA-funded Smart Grid demonstration projects, some firms are lodging additional complaints. The Demand Response and Smart Grid Coalition (DRSG), Google, and others note that DOE's initial Notice of Intent didn’t assure that Smart Grid hardware would actually be delivered to end users. They also complained that interoperability requirements are a “work in progress.” Other issues include demand-response management and variable pricing.
Quick Take: While there's undoubtedly some self-interest here, the critics make some good points. There doesn't appear to be a defined plan for getting the 40 million smart meters installed, as the administration has apparently promised.
Ars technica: DOE gets an earful
Ars technica report on DOE's Notice of Intent
ZBB Energy Corp. wants (lots of) stimulus funds for higher-capacity flow battery. ZBB is asking for $47 million in stimulus funds for its existing zinc bromide flow battery factory and a new plant. ZBB said the funding would enable it to crank up its annual production capacity from 20 MW hours to 300 MW hours. Flow batteries send an electrolyte through a reactor which turns chemical energy into electricity, and reclaim the spent electrolyte for recharging. They have the potential to provide grid-scale storage.
Quick Take: The attraction is that flow batteries are relatively cheap. The downside is they're currently not very efficient, and lose more energy than other battery technologies. With additional research, that might change
New ARRA startup org targets transformational energy technologies. Where will tomorrow’s smart energy breakthroughs come from? Here’s one possibility: The Advanced Research Projects Agency-Energy (ARPA-E) deadline for its first announced funding opportunity is June 2. In this first call, ARPA-E wants concept papers for high-risk, high-payoff transformational energy technologies in energy production, transmission, use, and storage. Anything that builds on existing technologies won’t fly. Could be interesting; ARPA-E is modeled after the Defense Advanced Research Projects Agency, the defense agency that gave us the Internet, among other technological breakthroughs.
Quick Take: In a column on evolution of the Smart Grid (linked below), Jesse Berst talked about opening electric power to innovation and entrepreneurial ambition. Maybe this is a kick start.
SGN on Managing Smart Grid evolution
DOE takes criticism to heart, hikes grant cap. Energy Secretary Steven Chu announced Monday that the agency will raise the grant cap for the development of Smart Grid projects to $200 million, up substantially from the $20 million originally proposed. California Gov. Arnold Schwarzenegger recently criticized the lower cap; so has New Mexico Gov. Bill Richardson and a number of industry groups. SGN Managing Editor Philip Bane complained when the DOE guidelines were first announced that the low grant ceiling was biased against investor-owned utilities (IOUs).This latest move should remedy that and get big utilities back in the game. But they’d better hurry, because California, New England, and BPA are already ahead, as noted in the stories below.
Quick Take: Let’s see, we’ve got an Energy Secretary who listened to reasoned feedback and actually corrected a mistake. If this is an indication of Secretary Chu’s leadership style, we’re in luck.
Finance and Commerce report of Chu’s decision
SGN critique of stimulus bill bias
Greentech analysis of higher ceiling
Sixteen standards trotted out along with an urgent prod. At the same meeting with industry leaders where the elevated grant cap was announced, administration officials unveiled a set of 16 standards for the Smart Grid and characterized accelerated standards development an “urgent national priority.” The new standards deal with smart meters, cybersecurity, and distributed generation components, among others. True, these first standards have been in use for some time, but who expected the feds to mandate them so quickly? What’s more, they said in no uncertain terms that if parties cannot agree quickly on additional standards, the government will step in and impose them.
Quick Take: Raising the ceiling is a big deal for the short-term stimulus, but the aggressive standards announcements are a big deal for the long-term industry. In their own way, they are as momentous as the new CAFÉ standards for the auto industry.
Earth2Tech on Smart Grid standards progress
BPA to NW utilities: Let’s do this Smart Grid thing. The Bonneville Power Administration (BPA) issued a “request for information” for partners in its proposed Pacific Northwest Smart Grid Test Bed Project. BPA said it has committed to spend $10 million to initiate the project, which is intended to showcase how Smart Grid technologies can improve energy delivery reliability and efficiency on both regional and national levels. BPA wants to hear from utilities by May 26 or earlier. A joint effort between BPA and DOE’s Pacific Northwest National Lab (PNNL) on a GridWise Demonstration Project on the Olympic Peninsula in 2006 was widely regarded as a success.
Quick Take: If the Northwest utility giant can get its hands on the local commitments it needs, this should likely be a go. BPA was working in the Smart Grid arena years before it was called the Smart Grid.
GridWise Project Fast Facts (PDF)
New England tech firms feeling cocky about stimulus funds. While the details of Smart Grid stimulus funding and how to secure it are still murky, New England-based utilities and technology firms could get millions. EnerNOC Inc. is a good example. David Brewster, president of the Boston company, commented last week that New England has already established a reputation as a clean technology center. Some stimulus watchers have said it is likely that nonutilities such as EnerNOC will be able to apply directly for funds, rather than be obligated to partner with a utility to be eligible.
Massachusetts High Tech article on stimulus hopes
Massachusetts High Tech article on stimulus recipients
Power association wants all utilities to have a shot. The American Public Power Administration (APPA) called on the DOE to ensure that “small through large municipals, cooperatives, and investor- owned utilities and all other eligible entities are provided not just the opportunity, but successful applications” when they apply for Smart Grid investment grants. APPA also proposed dumping the $500,000 bottom limit for investment grants to allow worthy smaller projects to be eligible. While APPA commended DOE for promoting the Smart Grid, it also said the agency’s draft notices create “unnecessary obstacles” to implementing projects.
California utilities strut their Smart Grid progress. The state’s big utilities last week reported to the California Energy Commission (CEC) on their progress in incorporating Smart Grid technologies into their grids. Topics included digital communications, energy efficiency technologies, smart meter projects, and energy efficiency technologies. The state’s three largest utilities are spending a combined total of $11 billion in very large smart meter deployment projects. It is likely that state utilities will be seeking stimulus funds for a vast array of Smart Grid projects. The CEC estimates that it could receive upwards of $50 billion in stimulus funding.
Quick Take: We commend California for insisting that the utilities in its jurisdiction come up with stimulus concepts on an aggressive timeline
Greentech story on California utilities’ report
Southern California Edison’s presentation on Smart Grid strategy (PDF)
Big Blue tosses $2 billion into the stimulus ring. IBM will commit $2 billion to back start-ups and utilities working on Smart Grid and green technology. The company says it wants to give a boost to companies that will likely also qualify for stimulus money. As VentureBeat points out, the move gets IBM – already a maker of smart-meter components – even better positioned for a slice of the $13 billion global market.
Quick Take: Nice to see companies with strong balance sheets helping out for the greater good, but it’s not like IBM is writing a check for $2 billion. Much of it will apparently come from reduced-rate or deferred-payment loans and lines of credit. Still, it’s a smart competitive move on IBM’s part.
IBM pours $2 billion into Smart Grid in Venture Beat Clean Tech
IBM puts the smart (grid) money where its mouth is on BusinessGreen
IBM lubricates Obama's IT stimulus in The Register
Governors ask DOE to raise the stimulus ceiling. Last month in our analysis of the DOE’s preliminary guidelines for Smart Grid stimulus projects, we expressed our concern about the low ceilings on stimulus awards. We thought they clearly favored coops and municipalities over investor-owned utilities. Well, turns out we’re not the only ones who see it that way. In a letter to Energy Secretary Steven Chu, California Gov. Arnold Schwarzenegger asked to have the $20 million cap raised. As he put it: “The low cap places the nation's larger utilities, which serve the nation's largest cities, at a distinct disadvantage." He noted that the larger utilities have a better opportunity to maximize the cost-effectiveness of Smart Grid investments. Meanwhile, New Mexico Gov. Bill Richardson has made a similar complaint.
Quick Take: If it takes the Terminator to fix this, so be it.
California Gov Asks DOE To Raise $20 Million Smart-Grid Funding Cap on Dow Jones
On SGN: Smart Grid Stimulus Bill: DOE Snubs IOUs and Meters
On SGN: Smart Grid Stimulus Scorecard
10% of energy-related stimulus money pledged? See where it’s going. At a stimulus workshop in San Francisco earlier this week, Energy Secretary Stephen Chu’s special assistant Matt Rogers provided some spin on stimulus spending. According to Greentechmedia, the DOE has already pledged about 10 percent of the $90 billion in stimulus funds targeted for energy-related projects. Of that, there’s been a loan guarantee (which requires 20% matching) to Solyndra, a thin-film solar panel maker that wants to raise $535 million to build a factory. Some $500 million has gone to energy research and research programs and $93 million toward wind power. But lest you think this bus is moving slowly and you have time to ponder those applications, DOE wants to award half of the $90 billion by Labor Day, which pencils out to about $1.2 billion a week.
Quick Take: As the article points out, Smart Grid awards may not move so quickly, since the rules are still being written. But if you want to win, you should have your application finished yesterday, just in case.
Stimulus money going, going… on Greentechmedia
Smart Grid News Stimulus Toolkit
How to get stimulus dollars on Greentechmedia
Khosla disses Smart Grid stimulus spending. Vinod Khosla has told Forbes that spending stimulus money on the Smart Grid is not the best use of that money. If he were doling out the cash he says he’d favor a transmission grid over a Smart Grid. He made similar comments in an interview earlier with the Wall Street Journal. Khosla, you may recall, got his 10 minutes of fame (and wealth) at Kleiner Perkins Caufield & Byers, the Silicon Valley venture firm that backed Google and Amazon. Now he has his own firm.
Quick Take: We’ve already weighed in on Khosla’s wrongheadedness. But you might enjoy Jesse’s characterization one more time. (See below.)
Khosla on Smart Grid Stimulus: Not the Best Use of Funds
Jesse Berst: How ‘Smart’ Is Vinod Khosla?
Summit targets renewable financing in a post-stimulus era. Bringing together renewable developers, investors, and lenders is the idea behind Infocast’s Post-Stimulus Renewable Finance Summit May 27-29 in New Orleans. Attendees will get the latest on the financial community’s response to the stimulus bill and more specifically, they’ll hear from lenders about any impact the bill is having on the flow of credit to the renewables sector. Sessions will also cover how the government is administering the provisions, how to structure deals to take advantage of the new incentives, and more.
Quick Take: If there’s a city in the country that understands economic stimulus, it’s New Orleans. And if you’re a renewables developer, this Summit could be your Big Easy–a chance to meet-and-greet with financial types who get your space.
Infocast Post-Stimulus Renewable Finance Summit website
Smart Grid News Stimulus Toolkit
Smart Grid News Energy Events Calendar
Previously published updates: April 8, 2009 Spending Smart Grid stimulus money in China could help the U.S., too. Wise use of stimulus funds and Smart Grid projects could be a win-win-win situation for the U.S., China, and the climate, according to Peggy Liu, chair of Joint U.S.-China Cooperation on Clean Energy (JUCCCE). In her editorial, Liu says that China spent $35 billion on power grid construction last year and that its two grid companies have the potential to create the world’s largest Smart Grid at a fast rate. Working with China on these technologies could mean jobs and money for both countries. She encourages the Obama administration to think outside U.S. borders to create green jobs that tap into the energy market of both countries. Peggy Liu piece in Huffington Post
Illinois is a top go-getter for Smart Grid funds; Missouri coming in last. When it comes to getting federal stimulus money for Smart Grid projects, Illinois is one of the leaders, while Missouri a serious laggard. That’s the conclusion of an article in the St. Louis Post-Dispatch this week. It cites California, Texas, New York, and Illinois as the most active states in grid modernization. All four states have high energy rates, which may be a motivating factor. Missouri, on the other hand, relies on coal for electricity and has one of the lowest electrical rates in the U.S. That could change if Obama’s carbon cap plan makes it into law. St. Louis Post-Dispatch story on Smart Grid leaders and laggards
DOE begins the complex process of doling out funds. Details are starting to emerge on the Department of Energy’s plan for distributing stimulus money for Smart-Grid related projects. According to a story in Renewable Energy World, the first grants to go out are likely to be block grants for state energy programs and weatherization aid to low-income individuals. DOE has made a spreadsheet showing money for those programs broken down by state. More complex research and development programs won’t see a check in the mail right away, in some cases as late as 2010. Similarly, applicants won’t see stimulus-related loan guarantees until the Treasury Department comes up with rules and criteria for the program. Renewable Energy Story on DOE process DOE’s block grant Excel spreadsheet
Stimulus starts high tech gold rush. The ARRA is breathing new life — or at least desire — into the tech sector, according to a story in USA Today. Tech firms ravaged by the recession are looking to the billions available through the stimulus package as a lifeline. Among the companies jockeying for money to fund Smart Grid projects are IBM, General Electric, and Cisco. USA Today story on the stimulus and the tech sector
Regulators propose guidelines for choosing stimulus projects. A group jointly sponsored by the National Association of Regulatory Utility Commissioners (NARUC) and the Federal Energy Regulatory Commission (FERC) has proposed guidelines to the DOE for choosing which Smart Grid projects to fund. The Smart Grid Collaborative said the guidelines are “a consensus among 19 states and FERC” on the best way to fund projects. The criteria are broken down into eight categories, including preconditions, technologies, redesigns, and regulatory issues. Quick Take: As you might expect from a document designed by a committee of bureaucrats, the guidelines are frequently repetitive and hard to follow. If you plow through the cumbersome language, however, you’ll find a wealth of important considerations. For example, the Smart Grid Collaborative’s criteria offers a number of parallels to SGN’s own Stimulus Scorecard, including the emphasis on projects that are open, interoperable, and secure; scalable; and documented with progress reports (see items 6, 9, and 15 on our scorecard). But their list includes some differences, too, including a section on what the overall collection of funded projects should look like (for example, technological and geographical diversity) as well as protection for customer privacy and commercially sensitive data. We think the guidelines are a useful complement to SGN’s own scorecard. Collaborative guidelines (PDF) FERC/NARUC Collaborative Web page SGN Stimulus Scorecard article
Consumers may resist Smart Grid stimulus projects. The DOE’s official stimulus guidelines aren’t even out yet, and already we are hearing rumblings of consumer pushback. As pointed out in a recent editorial in The Oklahoman newspaper, “the real outlay will come at the local level and from ratepayers themselves.” When utilities ask regulators for more money to meet the federal 50% matching requirements, they may face opposition from those groups that The Oklahoman describes as “genetically predisposed to fighting rate increases.” Quick Take: As NARUC Chairman Fred Butler warned in an SGN interview, we must explain the consumer benefits of the Smart Grid before we can expect their support. The Oklahoman Smart Grid editorial
SGN interview with Fred Butler
KEMA offers ARRA analysis. Energy consulting firm KEMA has published an article that details the impact on the Smart Grid of the recently passed American Recovery and Reinvestment Act (ARRA) of 2009, commonly known as the stimulus package. In addition to noting the various pots of money that relate directly or indirectly to Smart Grid projects, the study, authored by Aaron Schneider, analyzes the amendments that the bill makes to the Energy Independence Security Act of 2007, reviews loan programs created by the bill, and lists some criteria that the Department of Energy will like use in approving funding requests. Kema article on “The Stimulus and the Smart Grid”
Duke expects hundreds of millions in stimulus dollars. Several of Duke Energy’s current Smart Grid and renewable energy pilots could qualify for stimulus dollars – at least according to the utility’s own analysis. For instance, the utility thinks its previously announced plan to spend $1 billion over the next five years to install smart meters could get stimulus funding. A team led by Duke VP Michael Schwartz expects to start submitting applications in the next few weeks. Quick Take: So let’s see. Duke would like stimulus money or tax credits for a host of projects, including a smart meter program, its commercial wind operations, a demonstration project in Charlotte, its coal-gasification plant, projects related to hybrid electric cars, energy-efficiency programs and more. All of which could add up to a sizable chunk of the stimulus bounty. And if you read California’s wish list in the article just below, it sounds like much of what’s left over may be heading straight to California. Charlotte Business Journal article
CA utilities lay out stimulus pitches. California’s largest utilities – PG&E, SCE, and SDG&E – were in front of the California PUC on March 27 to explain where they hope to gain stimulus dollars. The utilities will be looking to the CPUC to approve the money for the 50% match. For its part, the CPUC wants the utilities to have their plans ready within days to present to DOE. PG&E would like the following: SCE is promoting a three-pronged approach, including utility-specific projects, projects with business partners, and projects with university research partners. SCE is targeting several projects: For its part, SDG&E plans to pitch the following:
Previously published updates: March 15, 2009
Stimulus means $8.3B to grid, IDC predicts. Research firm IDC foresees a jump in technology sales owing to the Obama economic stimulus bill. High-tech provisions in the recently passed law could mean a $100B in revenue for technology companies. Money for Smart Grid and renewable energy will prime the pump for a total of $77B in spending, the report predicts (some of it from the required 50% match). The largest chunk, $66B, would go to renewable energy sources like solar and wind power. $8.6B could be spent on Smart Grid technology, such as smart meters. And another $3B could go to energy conservation technologies for commercial buildings, including programmable thermostats and other systems. Although Goldman Sachs has said that global technology spending could drop 9% this year, an IDC analyst expects the U.S. tech industry to expand by 0.1%. Quick Take: As we note in our Stimulus Tool Kit article (see link below), there are many pots of money for Smart Grid above and beyond the $4.5B labeled as such. Over the course of three years, we think the total flowing to Smart Grid-related project will easily be twice the amount projected by IDC.
Bloomberg story on IDC analysis IDC report abstract (full report requires membership)
California takes early lead in race for stimulus bucks. The race is underway to secure stimulus dollars, with teams forming all over the country. California Governor Arnold Schwarzenegger has launched a Federal Energy Stimulus Team (FEST) to make California the “most competitive state in the nation” in contending for ARRA funding. A first Webinar was held March 13 (see link to the presentation below). Meanwhile, the California Public Utility Commission is already deciding what kind of projects it will approve, with plans to direct the state’s utilities so as to “maximize effectiveness and uptake of stimulus funds.” It is also teaming with the California Energy Commission, Cal-ISO and the major California utilities to “garner significant funding for California to demonstrate and deploy components of the Smart Grid.” It will hold a Smart Grid workshop on March 27 in San Francisco (see notice below). Quick Take: Other states are hard at work on stimulus plans, but none seem to be as focused on Smart Grid opportunities as California.
Download the California Stimulus Team presentation (PDF) CPUC Smart Grid workshop event notice
White house warns against wasting stimulus money. In a day-long conference on the stimulus package, the president and vice-president admonished state and local officials to spend stimulus money wisely. In his remarks, President Obama simultaneously expressed confidence (“I think you’re up to the task”) while admonishing leaders that “if we see money misspent, we’re going to put a stop to it.” Similarly, Vice-President Biden warned, “No swimming pools in this money.” Quick Take: No swimming pools, maybe, but plenty of bonuses for AIG executives.
Boston.com’s story on the White house stimulus conference
Battery manufacturers want some of the Smart Grid funding. Battery makers are also battling for stimulus funds intended for Smart Grids. One such hopeful is mPhase Technologies, developer of the Smart NanoBattery as part of the U.S. Army STTR program. Because a Smart Grid will require monitors and sensors throughout, batteries may provide a useful source of backup power for those sensors in the event of a power failure. Keeping a remote sensor powered could prevent a service interruption. The Smart NanoBattery is promoted as a good choice because it is programmable and has a shelf life of 20 years. And mPhase isn’t the only battery manufacturer who may come calling for funds. Alt Energy Stocks analyst John Peterson predicts a number of battery manufacturers will pursue Smart Grid stimulus grants. Quick Take: To the extent that the Smart Grid represents the convergence of IT with the electricity industry, we should not be surprised to see technologies once associated with computer and other high-tech industries move into the realm of electricity generation, transmission, and delivery. And that means more companies asking for DOE stimulus money as well.
Global Newswire story on mPhase and Smart Grid money mPhase Web site
Telvent gives adverts a stimulus spin. In a March 12 press release, global IT company Telvent (NASDAQ: TLVT) introduced a “Pilot-in-a-Box” – low-cost tools for studying advanced metering infrastructure (AMI). The program combines Echelon’s smart meters and data collectors with Telvent’s meter management software. Echelon Vice President Jim Andrus said the current availability of stimulus funds makes this a crucial time for utilities to evaluate AMI. Quick Take: Expect to see many if not most vendors promoting their offerings as “stimulus-ready” and offering special stimulus packages and promotions.
Telvent press release for Pilot-in-a-Box smart metering solution
Big Blue angles for smarter planet, stimulus dollars. While most of the world has been focusing on the Smart Grid, IBM has been taking a larger view, developing an ad campaign for smart infrastructure and creating a consulting service to advise governments around the globe. According to Times-Herald Record technology reporter Christine Young, IBM created a presentation for the Obama administration showing that smart infrastructure programs could create almost a million jobs and now stands to reap big rewards if it grab onto any of that stimulus money. Quick Take: We agree that Smart Grid is just the first step towards Smart Infrastructure. About a year ago, Global Smart Energy (the publisher of Smart Grid News) became a member of the Global Smart Infrastructures alliance, which designs, builds and operates the infrastructure for sustainable communities, ports and bases.
Times Herald-Record story on IBM and Smart Grid lobbying Global Smart Infrastructures Web page
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