Thursday, July 2, 2015

The Supreme Court Looks at EPA’s Mercury Rule

On Monday, June 29th 2015 the U.S. Supreme Court ruled that the U.S. Environmental Protection Agency (EPA) must consider compliance costs as a part of its mandate to issue "appropriate and necessary" regulations under the Clean Air Act. In a 5-4 decision the court ruled that the EPA interpreted the Clean Air Act improperly in crafting the regulation because it did not consider the costs of emissions reductions. The Supreme Court remanded the regulation back to the D.C. Circuit, which must now decide how to proceed with the EPA.

The regulation in question was the Mercury and Air Toxics Standards (MATS) which is intended to regulate mercury, arsenic, acid gas, nickel, selenium, and cyanide from coal fired power plants. In 2011 EPA estimated that it would cost $9.6 billion annually to comply with the MATS regulations, the costliest regulation-ever. Industry analysts believed that 10% to 20% of U.S. coal-fired generating capacity would be shut down by 2016 and could impact electrical grid reliability. A coalition of states and industry groups lead by Michigan sued, arguing that the EPA did not properly consider the costs of compliance for the MATS regulations when crafting the rules. However, because the MATS regulation had a compliance deadline of April 16, 2015, most power companies have already largely chosen to retire or retrofit coal plants that would be impacted by the rule. The impact of the ruling, if any, will be on future regulations.

According to the EPA, MATS combined with another rule, the Cross-State Air Pollution Rule, (CSAPR), will prevent up to 46,000 premature deaths, 540,000 asthma attacks among children, 24,500 emergency room visits and hospital admissions. A 2011 press release stated: “The two programs are an investment in public health that will provide a total of up to $380 billion in return to American families in the form of longer, healthier lives and reduced health care costs.” The EPA did not give an estimated combined cost of the two rules; however, the Edison Electric Institute, an industry trade group, claimed the combined new rules would cost utilities up to $129 billion and eliminate one-fifth of America's coal electrical generating capacity. The regulation would slash emissions of these pollutants from coal fired electrical generation plants.

The Cross-State Air Pollution Rule, which requires reductions of sulfur-dioxide and nitrogen-oxide emissions in 23 Eastern and Midwestern states, as well as seasonal ozone reductions in 28 states has suffered delays from legal challenges. On December 30, 2011, CSAPR was stayed by the D.C. Circuit court prior to implementation. On April 29, 2014, the U.S. Supreme Court issued an opinion reversing an August 21, 2012 D.C. Circuit decision that had vacated CSAPR. Following the remand of the case to the D.C. Circuit who granted EPA’s requested that the court lift the CSAPR stay and roll the CSAPR compliance deadlines by three years. Thus, CSAPR Phase 1 implementation is now scheduled for 2015, with Phase 2 beginning in 2017 and MATS has already pretty much been implemented. Combined these two rules will have a significant impact on particulate pollution, the amount of power generated from coal and the future cost and availability of electrical power in the United States and should be part of a careful and well thought out and communicated environmental and energy plan for the nation.
data from EIA

Next up the challenges to the Clean Power Plan and EPA regulatory program announced in 2014 to cut carbon emissions from existing power plants and put the states on a “carbon diet.”

Monday, June 29, 2015

San Francisco Cut-Off with Senior Water Rights Holders

The drought in California continues. It is the dry season and there will be no rain until late fall or early winter. In an average year precipitation in California is about 23 inches. However, since 1960 almost 40% of years have been drought years. The evidence tree rings show that California has had alternating cycles of severe drought and heavy precipitation a dangerous pattern when water use is at its limit. Right now California is experiencing the most severe drought in the past century. This may be the result of a changing climate, the beginning of a long period of drought or just extreme weather. No one really knows how long this drought will last, but tree-ring studies indicate one 61 year drought from 1760-1820. Anything could happen-the next rainy year might be next year or in a half century.

Meanwhile, water reserves continue to dwindle down and so the California State Water Resources Control Board has issued “curtailment orders” to more than 100 senior water rights holders on the Merced and upper San Joaquin, Sacramento, Tuolumne and Scott rivers as well as the Antelope Creek. These curtailments have not just been to agricultural water districts and farmers, but also communities. San Francisco had their rights to divert water from the Tuolumne River to the Hetch Hetchy reservoir curtailed. San Francisco depends on water diversion from the Tuolumne River to fill its reservoirs and supply the city with water.

There is some question as to the date of the San Francisco’s claim on the Tuolumne River, it has been variously reported to be 1902 and 1903. Also, there is some question whether the most senior claims, and riparian claims, can be curtailed. The most senior of all water rights is the riparian right. The riparian right is a right to the natural flow of a watercourse- if the river runs through your land, you can use the water, but not store it. Riparian rights are senior to pre-1914 appropriative water rights, and are not lost by non-use. California created the State Water Resource Control Board to oversee the water rights in 1913 and began issuing permits for water claims in 1914. Prior to 1914, there was no comprehensive permit system to establish water rights in California. To establish an “appropriative right” right required simply posting and recording a notice of intended water diversion and use, and the construction of the system to divert and use the water. Claims going back to Gold Rush days are lumped together as pre-1914 rights.

Today the California Department of Water Resources (DWR) “owns” the California state-owned State Water Project (SWP) just as the U.S. Bureau of Reclamation “owns” the federally-owned Central Valley Project (CVP) water. Together they form the largest water storage and transportation system in the world with 1,200 miles of canals and nearly 50 reservoirs. Water is doled out based on the system of rights. There is hardly any water flowing naturally in California. Several lawsuits have already been filed by senior water rights holders who are challenging the California State Water Resources Control Board’s authority to cut their rights.

Water is wealth. Newer or junior water rights are the first to be cut back or curtailed when water supplies are inadequate. In this way, senior water rights holders can continue to get water deliveries in time of drought. In April of this year, the fourth year of the current drought, almost 9,000 junior water rights holders were ordered to stop using water this year. Now the California State Water Resources Control Board issued “curtailment orders” to Pre-1914 Claims of Right that Commenced During or After 1903.

While this is calamitous to the farmers who stand to lose $60-$100 million in crops already in the ground, San Francisco is not likely to run out of water any time soon. The city made sure that the Hetch Hetchy reservoir was over 90% full before the order was issued. The bigger issue for San Francisco is their rights to the water. The Hetch Hetchy Project supplies water to the City of San Francisco and surrounding Bay Area communities, and regulates stream flow in the Upper Tuolumne River, Cherry Creek, and Eleanor Creek. The Hetch Hechy system consist of the Hetch Hechy Reservoir, Cherry Reservoir and Eleanor Reservoir a portion of the New Don Pedro Reservoir as well as other small surface reservoirs of various size and significance and five groundwater basins. The stored water in the system is transported from the Tuolumne River to the cities, towns and farms supplied by the system via the Hetch Hetchy Aqueduct, the California Aqueduct, the Delta Mendota Canal, the South Bay Aqueduct, and the Pacheco Tunnel. The curtailment order challenges the City’s right to manage and regulate the Tuolumne River flow and sets precedence for the remaining city water rights.

It appears as if the courts will regulate water and determine water rights, too.

Thursday, June 25, 2015

Tighter Regulations for USTs

On Monday, the U.S. Environmental Protection (EPA) announced that they are strengthening the federal underground storage tank (UST) requirements. This is important because leaking underground storage tanks is the major source of groundwater contamination nationwide. Currently, there are approximately 569,000 active USTs in the U.S. that are regulated under UST regulations. The announced changes will expand the number of regulated tanks by eliminating some exemptions and deferrals. Improved equipment and leak detection will further prevent and detect releases from USTs protecting our precious groundwater supplies.

States and territories primarily implement the UST program- 38 states, plus the District of Columbia and Puerto Rico, have approved state programs the other 12 states implement the federal program. Many states already have some of these new requirements in place, but not all. Virginia began a program to register, regulate and cleanup USTs and their contamination in 1989 in compliance with the 1988 EPA regulations. The Virginia program has spent more than $67 million to cleanup contamination from USTs and had protective requirements to reduce the future contamination, but does not require secondary containment on all tanks and piping systems.

The EPA’s action will strengthen existing UST standards nationwide and help ensure a consistent level of higher standards on all USTs in the U.S. The new regulations will tighten the EPA’s original 1988 UST regulations by requiring secondary containment on tanks and piping systems, and focusing on properly operating and maintaining existing UST systems.

The revised requirements include:
  • requiring secondary containment requirements for new and replaced tanks and piping;
  • adding operator training requirements;
  • adding periodic operation and maintenance requirements for UST systems;
  • eliminating deferrals for emergency generator tanks, airport hydrant systems, and field-constructed tanks;
  • requiring new release prevention technologies and leak detection alarms.
You probably don’t remember, but leaking underground storage tanks were a huge problem in the 1980’s. By the 1980’s there were over 2 million fuel and chemical storage tanks that were buried underground. Many of those tanks had been in the ground for decades as gas stations covered the country. After World War II it became common practice to bury fuel tanks in the ground. No one thought about what would happen over time when these tanks rusted and began to leak creating a slow and steady source of contamination. By the 1980’s many of these tanks were leaking and contaminating soil and groundwater. To address the threat to groundwater from leaking underground storage tanks, Congress added Subtitle I to the Solid Waste Disposal Act (SWDA) and in 1986 created the Leaking Underground Storage Tank (LUST) Trust Fund that is financed by a 0.1 cent federal tax on each gallon of gas sold.

The trust fund was created to:
  • Enforce cleanups by recalcitrant parties
  • Pay for cleanups at sites where the owner or operator is unknown, unwilling, or unable to respond, or which require emergency action because drinking water supplies are threatened. 
The tax has generated far more money than has been used in the program. Since 2012 $3.4 billion of the LUST Trust Fund was transferred to the Department of Transportation’s Highway Trust Fund. In addition to the federal cleanup funds, 38 states have UST cleanup funds (funded by the tax) which pay for most UST cleanups and are separate from the federal LUST Trust Fund; collectively states raised and spent more than $1 billion annually on LUST cleanups.

Over the years the states have done a good job of addressing the historic backlog of UST problems. With the help of the various Trust Funds more than 1.8 million USTs have been properly closed, 525,095 fuel releases have been discovered of those 452,847 have been cleaned up and completed. However, it is time to tighten the UST regulations and try and cleanup the 72,248 cleanups have not yet been finished.

Over time all tanks and piping systems will grow old and fail. It is necessary to have a secondary containment system to capture the fuel when it leaks out of the tank or pipe, in addition to an alarm system to notify operators of the leak before the secondary system fails. Inspections and maintenance are necessary to ensure that systems are working properly and in good condition and workers are not just silencing alarms and ignoring problems.

Now that EPA has tightened the UST regulations, they need to think about regulations for above ground tanks (ASTs). The U.S. Environmental Protection Agency does not regulate most aboveground fuel storage tanks and there are no national standards for secondary containment and spill prevention. In addition, there are no regulations that limit the maximum life that a tank can continue to be used. This endangers our rivers, watershed and groundwater.

Monday, June 22, 2015

A Third of the Wold is Using Up their Groundwater

The Gravity Recovery and Climate Experiment (GRACE) satellite mission from the National Aeronautics Space Administration (NASA) has been collecting data for more than a decade. Two new papers from a group of researchers assembled from the University of California- Irvine, National Taiwan University, and National Center for Atmospheric Research, Boulder Colorado and the Hydrological Sciences Branch at NASA Goddard Space Flight Center have worked in partnership to apply 10 years of collected data to quantify groundwater use, resilience and stability.

The GRACE satellites measure monthly changes in total earth water storage by converting observed gravity anomalies measured from space into changes of equivalent water height this was a method developed by Matthew Rodell & James S. Famiglietti in 1999. The GRACE mission has collected more than ten years of data and the scientists have just completed their analysis of all the data from January 2003 to December 2013. While some preliminary reports have been published in the last couple of years, these two new reports represent a complete analysis of the first 10 years of data. The scientists raise the very real possibility of some groundwater basins running out of water in the near future.

The scientists found that more than one third of Earth's 37 largest groundwater basins are using up their groundwater faster than it is being replaced. Though the GRACE satellites can be used to see the rate of net water consumption, there is little accurate data about how much water actually remains stored in the earth for future us. Eight of the earth’s 37 major groundwater basins were classified as "overstressed," by the scientists. These basins have nearly no natural recharge of the groundwater to offset the ongoing and increasing consumption. Another five groundwater basins were found to be "extremely" or "highly" stressed by the scientists. Those aquifers were still being depleted but had some water flowing back into them. Management of the resource could restore groundwater resilience.

The GRACE data found that the Arabian Aquifer System, an essential water source for more than 60 million people in the Middle East, is the most overstressed aquifer on earth. The Indus Basin aquifer of northwestern India and Pakistan is the second-most overstressed, and the Murzuk-Djado Basin in northern Africa is third. Though California's Central Valley basin is used heavily for agriculture and suffering rapid depletion during the current drought it was found to be slightly better off, but highly stressed. The same was true for the North China Aquifer System and the Tarim Basin. The major stressors for these systems are irrigation and population. The Ganges, the Indus Basin, the Californian Central Valley Aquifer System, and the North China Aquifer System, have the four highest levels of irrigation demand and among the highest levels of population density.

Surface water has throughout history served as the principal freshwater supply used by mankind. However, the importance of groundwater has increased in recent decades as mankind’s demand for water has surpassed surface supplies and our ability to access groundwater has increased with technology. Fresh surface water can no longer support the needs of mankind. Accessing groundwater allowed populations to increase, and provide reliable water as surface water has become less reliable and predictable as weather patterns change and regions experience extended droughts. Regions of the earth have come to rely more heavily on groundwater as a dependable water supply source. Groundwater represents almost half of all drinking water worldwide, though a lesser proportion of irrigation water and is currently the primary source of freshwater for approximately two billion people [Famiglietti, 2015].

Groundwater is a renewable resource, but not in the way that sun light is. Groundwater recharges at various rates from precipitation. To recharge groundwater, it must rain (or snow) and the soil must absorb the water. Changes in rainfall patterns and the actions of man can impact the recharge rate of groundwater. It is known that some groundwater is quite ancient and other groundwater only days old. However, very little actual knowledge exists about global groundwater supplies. Groundwater storage estimates commonly cited in global groundwater assessments were traced to decades-old heuristic estimates. These largely uncertain estimates have been cited as fact so often in the global groundwater literature, and although they were originally only working speculative estimates or assumptions, they have become commonly accepted as fact.

Although there is no measured basis, it is commonly accepted that groundwater comprises 30% of global freshwater calculated from “the upper estimate of global groundwater storage” from a 1978 paper which assumed uniform groundwater supply across the entire global land area. This is not likely to be accurate, but has been used to estimate groundwater supplies in critical regions. Groundwater is an essential portion of the water supply and ecology-providing fresh water and stream baseflow in times of drought. For groundwater to be available to provide in times of drought indefinitely there must be a balance between the volume of water that enters a groundwater system and the volume that leaves the system over time.

The climate of the planet has continually changed over the millennia and some groundwater aquifers are legacies of an earlier climate and are not being recharged. There are some groundwater systems that have no natural recharge; unless they are artificially recharged they have a limited life span. The problem is we do not know how much water is available in the aquifer. If the water from a groundwater basin is used faster than it is recharged, it is being used up and ultimately it will run out. The scientists conclude that significant segments of Earth's population are consuming groundwater more quickly than it is recharging without knowing when it might run out.

Worldwide groundwater is largely unregulated and unmanaged. These two studies highlight regions that may be vulnerable to tipping points to higher ecological, economic and political stress. Potential consequence when an overused aquifer such as the Arabian Aquifer System can no longer supplement declining water supplies are starvation, war and death. Alexandra Richey is the lead author on both studies, conducted the research as a doctoral student and says: "We're trying to raise red flags now to pinpoint where active management today could protect future lives and livelihoods."

These studies highlight regions that may be vulnerable to tipping points toward higher levels of stress driven by a range of factors including conversion to intensified agriculture, or population pressures that increase the demand for water. The lack of ground-based measures of total groundwater availability will prevent a full characterization of aquifer stress and resilience, and the ability to predict critical water stress. To improve groundwater estimates would require a significant investment in regional monitoring and measuring systems to better characterize saturated thickness and soil properties within an aquifer. Water and water availability will drive the political and economic events of the next fifty years.

All this information is from a recently published articles “Quantifying Renewable Groundwater Stress with GRACE” and “Uncertainty in Global Groundwater Storage Estimates in a Total Groundwater Stress Framework” by Alexandra S. Richey, Brian F. Thomas, Min-Hui Lo, John T. Reager, James S. Famiglietti, Katalyn Voss, Sean Swenson, and Matthew Rodell, and published in Water Resources Research in 2015. Like all scholarly, peer reviewed articles this one took several years to go from data gathering to publication so the data collection was from January 2003 through December 2013. These are open access articles.

Thursday, June 18, 2015

Muir Woods a Mere 777 Years Old

Muir Woods is a coastal redwood forest that was designated a national monument in 1908. Muir Woods is located 12 miles north of San Francisco in Marin County in Redwood Canyon two miles inland from the Pacific Ocean. The canyon forms a wetter and cooler micro climate with the moisture from the heavy summer fogs that roll in from the Pacific provide the moisture that has allowed the Coastal Redwoods to grow.

The woods is a beautiful place; silent and majestic on an early spring week day when most tourists are home. It is a place I dragged all my relatives to walk in the woods, picnic and hug a tree when they visited us in San Francisco. Sometimes I would go to the woods to hike the trails and just be alone. I walked the pathway and read the placards several times a year until I knew by heart that the oldest and largest tree in Muir Woods was believed to be more than 1,500 years old. That turns out not to be true.

The age of trees is determined by the counting of tree rings. The science of studying tree ring patterns is called dendrochronology and was created by A.E. Douglas at the beginning of the 20th century. In 1922 he used the methods to date the Giant Sequoias (cousins to the coastal redwoods). In general, each year a tree is alive and grows is marked by a growth ring; the tree gains a little bit of girth though there can be years where rings are absent. The width of the ring added to the outside of the tree is in part dependent on the amount of moisture available to the tree thus trees in the same area add thin rings during dry years and thick rings during wet years. In this way, by examining the rings of a group of trees, the scientists can study the history of the climate and weather in a region.

Researchers from Humboldt State University, University of California at Berkeley and Natureserve were studying the impacts of climate change on redwood growth, carbon storage and forest biodiversity through the Redwoods and Climate Change Initiative (RCCI) one of the many climate change impact funded studies. As part of the study scientists took pencil-thin cross sections from trees to count their growth rings. As mentioned, tree rings vary in width and tell a story of the tree’s growth history and what was happening in the forest during a particular year. Together the tree rings over a region form a catalogue of regional climate.

When Allyson Carroll of Humboldt State University analyzed the data she found that the oldest tree in Muir Woods, the giant 249 foot tall “Tree 76”, is not some 1,500 years old as previously assumed, but a mere 777 years old. The samples were taken in March of 2014 and I was surprised to hear represent the first significant scientific study of the tree canopy at Muir Woods. Besides Tree 76, Ms. Carroll determined the ages of two fallen trees in the forest; the Vortex Tree was 693 years old, and the Solstice Tree, was 536 years old. This leads to the theory that the entire grove is probably younger than previously thought.
From Allyson Carroll Presentation

The new theory of Muir Woods is that some catastrophe likely struck the area; a fire perhaps suggested by burn record, forcing the forest to start again from scratch. Scientists will attempt to use the reconstruction of the past climate to learn how redwoods have responded historically to climate change and assess how the trees are adapting currently.
The Ward Cousins Hugging a Redwood Tree

Monday, June 15, 2015

Ivanpah Solar Thermal Generating Station

The Ivanpah Solar Thermal Plant rises 450 feet above the Mohave Dessert and "power towers" shine with sunlight reflected by 350,000 software controlled mirrors that follow the sun (heliostats) spread across an area of about 3,500 acres. Receivers atop the towers heat to nearly 1,000 degrees Fahrenheit, boiling water to turn turbines that crank out power. At 392 megawatts, the Ivanpah solar thermal plant cost $2.2 billion (or $5,612 per kilowatt) and was intended to produce 940,000 megawatt hours of energy a year. In its first year of operation it produced about 40% of that amount of energy and has been plagued by other problems including massive kills of birds.

Solar thermal creates electricity by using mirrors to direct intense amounts of heat at a centralized collector, which is used to heat a substance like water to create steam and drive a conventional steam power turbine. Solar photovoltaic, meanwhile, directly converts solar energy into electricity through semiconductors. Solar thermal is looking like an Edsel in the dessert and the investors in the solar utility scale photovoltaic systems (who include Warren Buffet) are looking like the smarter investors.

In April 2011, the Department of Energy issued three loan guarantees for BrightSource Energy, NRG Energy and Google totaling $1.6 billion to finance the construction of Ivanpah. BrightSource is a privately held company backed by $615 million in equity from investors including VantagePoint Capital Partners,, California State Teachers' Retirement System, Morgan Stanley and others. BrightSource began developing Ivanpah and then sold the majority stake in the project to NRG and Google which used the operation to off-set their conventionally generated power used in their data centers.

Though it is difficult to tell from government reports, it appears as if BrightSource Energy Inc. has been able to delayed repaying hundreds of millions of dollars of the project's federal loans for about a year. As of September 2014, the DOE financed projects have repaid nearly $3.5 billion of principal, as well as more than $810 million in interest payments to the U.S. Treasury, which issued the loans guaranteed by DOE through the Federal Financing Bank. In the five years since DOE began financing projects, actual and estimated loan losses are $780 million or approximately 2% of the program’s loans or 3.6% of funds disbursed to date. Not a great performance for a loan portfolio that has not aged, but better than the approximately 5% SBA (Small Business Administration) loan portfolio.

Nonetheless, the Ivanpah loans will be repaid. BrightSource locked in a 20-year power purchase agreements with local utilities that includes fixed pricing, and the vast majority of costs were borne up front, so even with significantly reduced production of power, the marginal cost of that power is very low. That means that the Department of Energy should get its money back as well as interest. It is the rate payers in California that will pay the bill in the end. It is unlikely; however, that there will be further Solar Thermal Installations built. This appears to be a failed technology.

Thursday, June 11, 2015

The G-7 on Climate- Do They Matter?

The annual summit of the Group of Seven (G-7) industrialized countries was held this past week in a resort town in Germany. At the close of the G-7 Summit there seemed to be few areas of clear agreement, but the Leaders of the G-7 nations made a joint statement that deep cuts in carbon dioxide (CO2) emissions were needed this century. They said that the world nations should hold to the upper limit of the United Nations recommendation calling for a 40% to 70% reduction in greenhouse gas emissions by 2050.

German Chancellor Angela Merkel emphasized in her statement that the G-7 leaders had agreed on the need for binding global rules to be developed later this year in Paris. That is a nice sentiment, but the G-7 probably does not have the ability to accomplish that goal or anything close to it. Though the G-7 remains influential, that influence is waning. As the wealth and power of the developing countries grows, the G-7 needs to recognize that it is being eclipsed as the world marches towards multiple and polarized point of power. To reach any world agreement now requires increasing participation of developing countries instead of G-7 authoritarian rule.

The G-7 summit, established in the 1970s to handle the oil crisis, has returned to its original seven members. The G-7 nations are: Canada, France, Germany, Italy, Japan, the United Kingdom and the United States. Together they represent less than 28% of the World’s 2012 CO2 equivalent emissions from fuel and even less in 2015 as China and the emerging nations have continued to grow. In 2012 the Middle East , Russia, Eastern Europe, China, the rest of Asia, Africa and Latin America accounted for 58% of global emissions and an even larger share of the world’s population.

Total CO2 emissions per country is far from the total picture. The picture would change significantly when moving from total CO2 emissions to looking at CO2 emissions per capita or per dollar of GDP (gross domestic product). The charts below show the problem. The CO2 emissions per capita are both an indication of standard of living and energy efficiency. There is some progress that can be made in reducing CO2 emissions by changes in behaviors in the United States without sacrificing the future quality of life of our children and grandchildren. However, life in a a less CO2 emitting United States will look vastly different from today.

World CO2 emissions have grown at an alarming pace over the past fifty years. With tremendous effort and cooperation the nations may be able to halt the growth in CO2 emissions and possibly reduce that slightly, but cutting emissions by 70% in 55 years is unfathomable. While the latest preliminary data on emissions have shown a slowdown in growth, there remain more than 1.2 billion people without access to electricity, or adequate sanitation. If everyone on earth were to have access to electricity and adequate sanitation, CO2 emissions would jump, not fall by 70%.
The International Energy Agency, IEA, will release its 2014 full report on world CO2 emissions from fossil fuel combustion on June 15, 2015. The report will include an analysis of the plans nations have submitted to reduce CO2 emissions, Though the United States and European Union have submitted plans (the European Union's plan is the most ambitious) many nations, including China, have not submitted plans. The current commitments alone can't do it- contain the global temperature rise to 2 degrees Celsius. Stay tuned.