State sues U.S. over pole transformers

By San Francisco Chronicle


CSA Z462 Arc Flash Training - Electrical Safety Essentials

Our customized live online or in‑person group training can be delivered to your staff at your location.

  • Live Online
  • 6 hours Instructor-led
  • Group Training Available
Regular Price:
$249
Coupon Price:
$199
Reserve Your Seat Today
Environmental groups and state Attorney General Jerry Brown have sued the Bush administration over the U.S. Energy Department's new efficiency standards for the 40 million electric transformers on utility poles around the nation, saying the rules are too weak and would allow pollution that contributes to global warming.

"These standards allow a huge waste of energy to continue," said Tim Ballo, a lawyer with the environmental law firm Earthjustice, which filed appeals on behalf of the Sierra Club in San Francisco and the Natural Resources Defense Council in New York.

Brown's office filed an appeal with the Ninth U.S. Circuit Court of Appeals in San Francisco, where the cases are likely to be consolidated.

A 1992 law requires the Energy Department to set efficiency standards for electricity distribution transformers, most of which are owned by utility companies and transmit power to homes and businesses. The department took no action until this October, when it issued standards scheduled to take effect in 2010.

In a statement in the Federal Register, the department declared that its standards "will achieve the maximum improvements in energy efficiency that are technologically feasible and economically justified." More stringent standards, the department said, would cause economic harm to the nation without significant environmental benefits.

Environmental groups challenged those statements. Ballo said utility companies had joined environmental organizations in seeking stronger standards that would reduce energy waste - saving the companies $11.1 billion - and the need for more pollution-emitting power plants.

If the department simply required new transformers to be as efficient as the best equipment already on the market, environmental organizations said, enough energy would be saved to eliminate the need for nearly 20 large power plants by 2038.

That would also reduce the annual output of heat-trapping carbon dioxide by 700 million tons, more than the amount emitted by all U.S. cars, the groups said.

The Energy Department has said one reason it did not require greater efficiency was that there was no reliable way to measure the potential economic benefits from reducing carbon dioxide emissions.

State Deputy Attorney General Janill Richards, who filed the suit for Brown's office, noted that the Bush administration made the same argument in defense of its new miles-per-gallon standards for light trucks and SUVs.

An appeals court in San Francisco rejected those standards in November and said the administration must consider the effects of fuel consumption on global warming.

The court was "very clear - the federal government can't pretend any more that controlling emissions doesn't have value," Richards said.

She said California is also among the states that have filed a similar suit challenging new federal efficiency standards for commercial air conditioning and heating units.

Related News

US looks to decommission Alaskan military reactor

SM-1A Nuclear Plant Decommissioning details the US Army Corps of Engineers' removal of the Fort Greely reactor, Cold War facility dismantling, environmental monitoring, remote-site power history, and timeline to 2026 under a deactivated nuclear program.

 

Key Points

Army Corps plan to dismantle Fort Greely's SM-1A reactor and complete decommissioning of remaining systems by 2026.

✅ Built for remote Arctic radar support during the Cold War

✅ High costs beat diesel; program later deemed impractical

✅ Reactor parts removed; residuals monitored; removal by 2026

 

The US Army Corps of Engineers has begun decommissioning Alaska’s only nuclear power plant, SM-1A, which is located at Fort Greely, even as new US reactors continue to take shape nationwide. The $17m plant closed in 1972 after ten years of sporadic operation. It was out of commission from 1967 to 1969 for extensive repairs. Much of has already been dismantled and sent for disposal, and the rest, which is encased in concrete, is now to be removed.

The plant was built as part of an experimental programme to determine whether nuclear facilities, akin to next-generation nuclear concepts, could be built and operated at remote sites more cheaply than diesel-fuelled plants.

"The main approach was to reduce significant fuel-transportation costs by having a nuclear reactor that could operate for long terms, a concept echoed in the NuScale SMR safety evaluation process, with just one nuclear core," Brian Hearty said. Hearty manages the Army Corps of Engineers’ Deactivated Nuclear Power Plant Program.

#google#

He said the Army built SM-1A in 1962 hoping to provide power reliably at remote Arctic radar sites, where in similarly isolated regions today new US coal plants may still be considered, intended to detect incoming missiles from the Soviet Union at the height of the Cold War. He added that the programme worked but not as well as Pentagon officials had hoped. While SM-1A could be built and operated in a cold and remote location, its upfront costs were much higher than anticipated, and it costs more to maintain than a diesel power plant. Moreover, the programme became irrelevant because of advances in Soviet rocket science and the development of intercontinental ballistic missiles.

Hearty said the reactor was partially dismantled soon after it was shut down. “All of the fuel in the reactor core was removed and shipped back to the Atomic Energy Commission (AEC) for them to either reprocess or dispose of,” he noted. “The highly activated control and absorber rods were also removed and shipped back to the AEC.”

The SM-1A plant produced 1.8MWe and 20MWt, including steam, which was used to heat the post. Because that part of the system was still needed, Army officials removed most of the nuclear-power system and linked the heat and steam components to a diesel-fired boiler. However, several parts of the nuclear system remained, including the reactor pressure vessel and reactor coolant pumps. “Those were either kept in place, or they were cut off and laid down in the tall vapour-containment building there,” Hearty said. “And then they were grouted and concreted in place.” The Corps of Engineers wants to remove all that remains of the plant, but it is as yet unclear whether that will be feasible.

Meanwhile, monitoring for radioactivity around the facility shows that it remains at acceptable levels. “It would be safe to say there’s no threat to human health in the environment,” said Brenda Barber, project manager for the decommissioning. Work is still in its early stages and is due to be completed in 2026 at the earliest. Barber said the Corps awarded the $4.6m contract in December to a Virginia-based firm to develop a long-range plan for the project, similar in scope to large reactor refurbishment efforts elsewhere. Among other things, this will help officials determine how much of the SM-1A will remain after it’s decommissioned. “There will still be buildings there,” she said. “There will still be components of some of the old structure there that may likely remain.”

 

Related News

View more

Germany considers U-turn on nuclear phaseout

Germany Nuclear Power Extension debated as Olaf Scholz weighs energy crisis, gas shortages from Russia, slow grid expansion in Bavaria, and renewables delays; stress test results may guide policy alongside coal plant reactivations.

 

Key Points

A proposal to delay Germany's nuclear phaseout to stabilize power supply amid gas cuts and slow grid upgrades.

✅ Driven by Russia gas cuts and Nord Stream 1 curtailment

✅ Targets Bavaria grid bottlenecks; renewables deployment delays

✅ Decision awaits grid stress test; coalition parties remain split

 

The German chancellor on Wednesday said it might make sense to extend the lifetime of Germany's three remaining nuclear power plants.

Germany famously decided to stop using atomic energy in 2011, and the last remaining plants were set to close at the end of this year.

However, an increasing number of politicians have been arguing for the postponement of the closures amid energy concerns arising from Russia's invasion of Ukraine. The issue divides members of Scholz's ruling traffic-light coalition.

What did the chancellor say?
Visiting a factory in western Germany, where a vital gas turbine is being stored, Chancellor Olaf Scholz was responding to a question about extending the lifetime of the power stations.

He said the nuclear power plants in question were only relevant for a small proportion of electricity production. "Nevertheless, that can make sense," he said.

The German government has previously said that renewable energy alternatives are the key to solving the country's energy problems.

However, Scholz said this was not happening quickly enough in some parts of Germany, such as Bavaria.

"The expansion of power line capacities, of the transmission grid in the south, has not progressed as quickly as was planned," the chancellor said.

"We will act for the whole of Germany, we will support all regions of Germany in the best possible way so that the energy supply for all citizens and all companies can be guaranteed as best as possible."

The phaseout has been planned for a long time. Germany's Social Democrat government, under Merkel's predecessor Gerhard Schröder, had announced that Germany would stop using nuclear power by 2022 as planned.

Schröder's successor Angela Merkel — herself a former physicist — had initially sought to extend to life of existing nuclear plants to as late as 2037. She viewed nuclear power as a bridging technology to sustain the country until new alternatives could be found.

However, Merkel decided to ditch atomic energy in 2011, after the Fukushima nuclear disaster in Japan, setting Germany on a path to become the first major economy to phase out coal and nuclear in tandem.

Nuclear power accounted for 13.3% of German electricity supply in 2021. This was generated by six power plants, of which three were switched off at the end of 2021. The remaining three — Emsland, Isar and Neckarwestheim — were due to shut down at the end of 2022. 

Germany's energy mix 1st half of 2022
The need to fill an energy gap has emerged after Russia dramatically reduced gas deliveries to Germany through the Nord Stream 1 pipeline, though nuclear power would do little to solve the gas issue according to some officials. Officials in Berlin say the Kremlin is seeking to punish the country — which is heavily reliant on Moscow's gas — for its support of Ukraine and sanctions on Russia.

Germany has already said it will temporarily fire up mothballed coal and oil power plants in a bid to solve the looming power crisis.

Social Democrat Scholz and Germany's energy minister, Robert Habeck, from the Green Party, a junior partner in the three-way coalition government, had previously ruled out any postponement of the nuclear phasout, despite debate over a possible resurgence of nuclear energy among some lawmakers. The third member of Scholz's coalition, the neoliberal Free Democrats, has voiced support for the extension, as has the opposition conservative CDU-CSU bloc.

Berlin has said it will await the outcome of a new "stress test" of Germany's electric grid before deciding on the phaseout.

 

Related News

View more

Ontario's electricity operator kept quiet about phantom demand that cost customers millions

IESO Fictitious Demand Error inflated HOEP in the Ontario electricity market, after embedded generation was mis-modeled; the OEB says double-counted load lifted wholesale prices and shifted costs via the Global Adjustment.

 

Key Points

An IESO modeling flaw that double-counted load, inflating HOEP and charges in Ontario's wholesale market.

✅ Double-counted unmetered load from embedded generation

✅ Inflated HOEP; shifted costs via Global Adjustment

✅ OEB flagged transparency; exporters paid more

 

For almost a year, the operator of Ontario’s electricity system erroneously counted enough phantom demand to power a small city, causing prices to spike and hundreds of millions of dollars in extra charges to consumers, according to the provincial energy regulator.

The Independent Electricity System Operator (IESO) also failed to tell anyone about the error once it noticed and fixed it.

The error likely added between $450 million and $560 million to hourly rates and other charges before it was fixed in April 2017, according to a report released this month by the Ontario Energy Board’s Market Surveillance Panel.

It did this by adding as much as 220 MW of “fictitious demand” to the market starting in May 2016, when the IESO started paying consumers who reduced their demand for power during peak periods. This involved the integration of small-scale embedded generation (largely made up of solar) into its wholesale model for the first time.

The mistake assumed maximum consumption at such sites without meters, and double-counted that consumption.

The OEB said the mistake particularly hurt exporters and some end-users, who did not benefit from a related reduction of a global adjustment rate applicable to other customers.

“The most direct impact of the increase in HOEP (Hourly Ontario Energy Price) was felt by Ontario consumers and exporters of electricity, who paid an artificially high HOEP, to the benefit of generators and importers,” the OEB said.

The mix-up did not result in an equivalent increase in total system costs, because changes to the HOEP are offset by inverse changes to a electricity cost allocation mechanism such as the Global Adjustment rate, the OEB noted.


A chart from the OEB's report shows the time of day when fictitious demand was added to the system, and its influence on hourly rates.

Peak time spikes
The OEB said that the fictitious demand “regularly inflated” the hourly price of energy and other costs calculated as a direct function of it.

For almost a year, Ontario's electricity system operator @IESO_Tweets erroneously counted enough phantom demand to power a small city, causing price spikes and hundreds of millions in charges to consumers, @OntEnergyBoard says. @5thEstate reports.

It estimated the average increase to the HOEP was as much as $4.50/MWh, but that price spikes, compounded by scheduled OEB rate changes, would have been much higher during busier times, such as the mid-morning and early evening.

“In times of tight supply, the addition of fictitious demand often had a dramatic inflationary impact on the HOEP,” the report said.

That meant on one summer evening in 2016 the hourly rate jumped to $1,619/MWh, it said, which was the fourth highest in the history of the Ontario wholesale electricity market.

“Additional demand is met by scheduling increasingly expensive supply, thus increasing the market price. In instances where supply is tight and the supply stack is steep, small increases in demand can cause significant increases in the market price.

The OEB questioned why, as of September this year, the IESO had failed to notify its customers or the broader public, amid a broader auditor-regulator dispute that drew political attention, about the mistake and its effect on prices.

“It's time for greater transparency on where electricity costs are really coming from,” said Sarah Buchanan, clean energy program manager at Environmental Defence.

“Ontario will be making big decisions in the coming years about whether to keep our electricity grid clean, or burn more fossil fuels to keep the lights on,” she added. “These decisions need to be informed by the best possible evidence, and that can't happen if critical information is hidden.”

In a response to the OEB report on Monday, the IESO said its own initial analysis found that the error likely pushed wholesale electricity payments up by $225 million. That calculation assumed that the higher prices would have changed consumer behaviour, while upcoming electricity auctions were cited as a way to lower costs, it said.

In response to questions, a spokesperson said residential and small commercial consumers would have saved $11 million in electricity costs over the 11-month period, even as a typical bill increase loomed province-wide, while larger consumers would have paid an extra $14 million.

That is because residential and small commercial customers pay some costs via time-of-use rates, including a temporary recovery rate framework, the IESO said, while larger customers pay them in a way that reflects their share of overall electricity use during the five highest demand hours of the year.

The IESO said it could not compensate those that had paid too much, given the complexity of the system, and that the modelling error did not have a significant impact on ratepayers.

While acknowledging the effects of the mistake would vary among its customers, the IESO said the net market impact was less than $10 million, amid ongoing legislation to lower electricity rates in Ontario.

It said it would improve testing of its processes prior to deployment and agreed to publicly disclose errors that significantly affect the wholesale market in the future.

 

Related News

View more

California Halts Energy Rebate Program Amid Trump Freeze

California energy rebate freeze disrupts heat pump incentives, HVAC upgrades, and climate funding, as federal uncertainty stalls Inflation Reduction Act support, delaying home electrification, energy efficiency gains, and greenhouse gas emissions reductions statewide.

 

Key Points

A statewide pause on $290M incentives for heat pumps and HVAC upgrades due to federal climate funding uncertainty.

✅ $290M program paused amid federal funding freeze

✅ Heat pump, HVAC, electrification upgrades delayed

✅ Previously approved rebates honored; new apps halted

 

California’s push for a more energy-efficient future has hit a significant roadblock as the state pauses a $290 million rebate program aimed at helping homeowners replace inefficient heating and cooling systems with more energy-efficient alternatives. The California Energy Commission announced the suspension of the program, citing uncertainty stemming from President Donald Trump’s decision to freeze funding for various climate-related initiatives.

The Halted Program

The energy rebate program, which utilizes federal funding to encourage the use of energy-efficient appliances such as heat pumps, was a crucial part of California’s efforts to reduce energy consumption and greenhouse gas emissions. By providing financial incentives for homeowners to upgrade to more efficient heating and cooling systems, the program aimed to make green energy solutions more accessible and affordable to residents. The rebate program had been popular, with many homeowners eager to participate in the initiative to lower their energy costs and improve the sustainability of their homes.

However, due to the uncertainty surrounding federal funding, the California Energy Commission announced on Monday that it would no longer be accepting new applications for the program. The agency did clarify that it would continue to honor rebates for applications that had already been approved. The pause will remain in effect until the Trump administration provides more clarity regarding the program's future funding.

The Trump Administration’s Role

This move highlights a broader issue regarding access to federal funding for state-level energy programs. The Trump administration’s decision to freeze funding for climate-related initiatives has left many states in limbo, as previously approved federal money has not been distributed as expected. Despite federal court rulings directing the Trump administration to restore these funds, states like California are still struggling to navigate the uncertainty of climate-related financial support from the federal government.

California’s decision to pause the rebate program comes after similar actions by other states. Arizona paused a similar program just a week prior, and Rhode Island had already paused new applications earlier this year. These states are all recipients of funding from a larger $4.3 billion initiative under the Inflation Reduction Act, which is designed to help homeowners purchase energy-efficient appliances like heat pumps, water heaters, and electric cooktops.

Impact of the Freeze

The pause of California's rebate program has serious implications for both consumers and the state’s energy goals. For residents, the halt means delays in the ability to upgrade to more energy-efficient home systems, which could lead to higher energy costs in the short term, a concern amid soaring electricity prices across the state.

The $290 million program was a significant step in encouraging homeowners to invest in energy efficiency, and its suspension leaves a gap in the availability of resources for those who were hoping to make energy-saving upgrades. Many of these upgrades are not just beneficial to homeowners, but they also contribute to the state’s overall energy efficiency goals, helping to reduce reliance on non-renewable energy sources, even as California's dependence on fossil fuels persists, and decrease greenhouse gas emissions.

Federal and State Tensions

The freeze in funding is just one of many points of tension between the Trump administration and states like California, which have pursued aggressive environmental policies aimed at reducing emissions and combating climate change. California has often found itself at odds with the federal government on environmental issues, especially under the leadership of President Trump. The state’s ambitious environmental policies have sometimes clashed with the federal government's approach, including efforts to wind down its fossil fuel industry in line with climate goals.

In this case, the freeze on climate-related funding appears to be part of a broader strategy by the Trump administration to limit federal spending on environmental programs, and as regulators weigh whether the state may need more power plants, planning remains complex. While the freeze impacts states that are working to transition to clean energy, critics argue that such moves undermine efforts to tackle climate change and could slow down progress toward a greener future.

The Path Forward

For California, the next steps will depend heavily on the actions of the federal government. While the state can continue to push for climate funding in the courts, the lack of clarity around the release of federal funds creates uncertainty for state programs that rely on these resources. As California continues to navigate this funding freeze, it will need to explore alternative solutions to keep its energy efficiency programs on track, such as efforts to revamp electricity rates to clean the grid, even in the face of federal challenges.

In the meantime, California residents and homeowners who were hoping to take advantage of the rebate program may have to wait until further clarification from the federal government is provided, even as officials warn of a looming electricity shortage in coming years. Whether the program can be restored or expanded in the future remains to be seen, but for now, the pause serves as a reminder of the ongoing struggles that states face when dealing with shifting federal priorities.

As the issue unfolds, other states facing similar challenges may take cues from California’s actions, and with California exporting energy policies to Western states, broader conversations about how federal and state governments can collaborate to ensure that energy efficiency initiatives and climate goals are not sidelined due to political or budgetary differences.

California’s decision to pause its $290 million energy rebate program is a significant development in the ongoing struggle between state and federal governments over climate-related funding. The uncertainty created by the Trump administration’s freeze on energy efficiency programs has led to disruptions in state-level efforts to promote sustainability and reduce emissions. As the situation continues to evolve, both California and other states will need to consider how to move forward without relying on federal funding that may or may not be available in the future.

 

Related News

View more

Alberta Introduces New Electricity Rules

Alberta Rate of Last Resort streamlines electricity regulations to stabilize the default rate, curb price volatility, and protect rural communities, low-income households, and seniors while preserving competition in the province's energy market.

 

Key Points

Alberta's Rate of Last Resort sets biennial default electricity prices, curbing volatility and protecting customers.

✅ Biennial default rate to limit price spikes

✅ Focus on rural, senior, and low-income customers

✅ Encourages competitive contracts and market stability

 

The Alberta government is overhauling its electricity regulations as part of a market overhaul aimed at reducing spikes in electricity prices for consumers and businesses. The new rules, set to be introduced this spring, are intended to stabilize the default electricity rate paid by many Albertans.


Background on the Rate of Last Resort

Albertans currently have the option to sign up for competitive contracts with electricity providers. These contracts can sometimes offer lower rates than the default electricity rate, officially known as the Regulated Rate Option (RRO). However, these competitive rates can fluctuate significantly. Currently, those unable to secure these contracts or those who are on the default rate are experiencing rising electricity prices and high levels of price volatility.

To address this, the Alberta government is renaming the default rate as the Rate of Last Resort designation (RoLR) under the new framework. This aims to reduce the sense of security that some consumers might associate with the current name, which the government feels is misleading.


Key Changes Under New Regulations

The new regulations, which include proposed market changes that affect pricing, focus on:

  • Price Stabilization: Default electricity rates will be set every two years for each utility provider, providing greater predictability by enabling a consumer price cap and reducing the potential for extreme price swings.
  • Rural and Underserved Communities: The changes are intended to particularly benefit rural Albertans and those on the default rate, including low-income individuals and seniors. These groups often lack access to the competitive rates offered by some providers and have been disproportionately affected by recent price increases.
  • Promoting Economic Stability: The goal is to lower the cost of utilities for all Albertans, leading to overall lower costs of living and doing business. The government anticipates these changes will create a more attractive environment for investment and job creation.


Opposition Views

Critics argue that limiting the flexibility of prices for the default electricity rate could interfere with market dynamics and stifle market competition among providers. Some worry it could ultimately lead to higher prices in the long term. Others advocate directly subsidizing low-income households rather than introducing broad price controls.


Balancing Affordability and the Market

The Alberta government maintains that the proposed changes will strike a balance between ensuring affordable electricity for vulnerable Albertans and preserving a competitive energy market. Provincial officials emphasize that the new regulations should not deter consumers from seeking out competitive rates if they choose to.


The Path Ahead

The new electricity regulations are part of the Alberta government's broader Affordable Utilities Program, alongside electricity policy changes across the province. The legislation is expected to be introduced and debated in the provincial legislature this spring with the potential of coming into effect later in the year. Experts expect these changes will significantly impact the Alberta electricity market and ignite further discussion about how best to manage rising utility costs for consumers and businesses.

 

Related News

View more

KHNP is being considered for Bulgarian Nuclear Power Plant Project

KHNP Shortlisted for Belene Nuclear Power Plant, named by the Bulgarian Energy Ministry alongside Rosatom and CNNC; highlights APR1400 reactor expertise, EPC credentials, and expansion into the European nuclear energy market.

 

Key Points

KHNP is a strategic investor candidate for Bulgaria's Belene NPP, leveraging APR1400 and European market entry.

✅ Selected with Rosatom and CNNC by Bulgarian Energy Ministry

✅ Builds on APR1400 reactor design and EPC track record

✅ Positions KHNP for EU nuclear projects and O&M services

 

Korea Hydro & Nuclear Power (KHNP) has been selected as one of the three strategic investor candidates for a Bulgarian nuclear power plant project amid global nuclear project milestones worldwide.

The Bulgarian Energy Ministry selected KHNP of Korea, RosAtom of Russia and CNNC of China as strategic investor candidates for the construction of the Belene Nuclear Power Plant, KHNP said on Dec. 20. The Belene Nuclear Power Plant is the second nuclear power plant that Bulgaria plans to build following the 2,000-megawatt Kozloduy Nuclear Power Plant built in 1991 during the Soviet Union era. The project budget is estimated at 10 billion euros.

By being included in the shortlist for the Bulgarian project, KHNP has boosted the possibility of making a foray into the European nuclear power plant market, as India takes steps to get nuclear back on track worldwide. KHNP began to export nuclear power plants in 2009 by winning the UAE Barakah Nuclear Power Plant Project, with Barakah Unit 1 reaching 100% power as it moves toward commercial operations. The UAE plant will be based on the APR1400, a next-generation Korean nuclear reactor that is used in Shin Kori Units 3 and 4 in Korea.

The ARP1400 is a Korean nuclear reactor developed by KHNP with investment of about 230 billion won for 10 years from 1992. The nuclear reactor became the first non-U.S. type reactor to receive a design certificate (DC) from the U.S. Nuclear Regulatory Commission (NRC), as China's nuclear energy program continues on a steady development track globally. By receiving the DC, its safety was internationally recognized. In June, the company also won the maintenance project for the Barakah Nuclear Power Plant, completing the entire cycle from the construction of the nuclear power plant to its design, operation and maintenance. However, U.S. and U.K. companies took part of the maintenance project for the nuclear power plant.

In July, KHNP officials visited Turkey and contacted local energy officials to prepare for nuclear power plant projects to be launched in that country, as Bangladesh develops nuclear power with IAEA assistance in the region. Earlier in May, the company also submitted a proposal to participate in the construction of a new nuclear power plant in Kazakhstan, while Kenya moves forward with plans for a $5 billion plant.

 

Related News

View more

Sign Up for Electricity Forum’s Newsletter

Stay informed with our FREE Newsletter — get the latest news, breakthrough technologies, and expert insights, delivered straight to your inbox.

Electricity Today T&D Magazine Subscribe for FREE

Stay informed with the latest T&D policies and technologies.
  • Timely insights from industry experts
  • Practical solutions T&D engineers
  • Free access to every issue

Live Online & In-person Group Training

Advantages To Instructor-Led Training – Instructor-Led Course, Customized Training, Multiple Locations, Economical, CEU Credits, Course Discounts.

Request For Quotation

Whether you would prefer Live Online or In-Person instruction, our electrical training courses can be tailored to meet your company's specific requirements and delivered to your employees in one location or at various locations.