Southern California faces summer power challenge: NERC

Hourly Electricity Emissions Tracking maps grid balancing areas, embodied emissions, and imports/exports, revealing carbon intensity shifts across PJM, ERCOT, and California ISO, and clarifying renewable energy versus coal impacts on health and climate.

Key Points

An hourly method tracing generation, flows, and embodied emissions to quantify carbon intensity across US balancing areas.

✅ Hourly traces of imports/exports and generation mix

✅ Consumption-based carbon intensity by balancing area

✅ Policy insights for renewables, coal, health costs

In the United States, electricity generation accounts for nearly 30% of our carbon emissions. Some states have responded to that by setting aggressive renewable energy standards; others are hoping to see coal propped up even as its economics get worse. Complicating matters further is the fact that many regional grids are integrated, and as America goes electric the stakes grow, meaning power generated in one location may be exported and used in a different state entirely.

Tracking these electricity exports is critical for understanding how to lower our national carbon emissions. In addition, power from a dirty source like coal has health and environment impacts where it's produced, and the costs of these aren't always paid by the parties using the electricity. Unfortunately, getting reliable figures on how electricity is produced and where it's used is challenging, even for consumers trying to find where their electricity comes from in the first place, leaving some of the best estimates with a time resolution of only a month.

Now, three Stanford researchers—Jacques A. de Chalendar, John Taggart, and Sally M. Benson—have greatly improved on that standard, and they have managed to track power generation and use on an hourly basis. The researchers found that, of the 66 grid balancing areas within the United States, only three have carbon emissions equivalent to our national average, and they have found that imports and exports of electricity have both seasonal and daily changes. de Chalendar et al. discovered that the net results can be substantial, with imported electricity increasing California's emissions/power by 20%.

Hour by hour
To figure out the US energy trading landscape, the researchers obtained 2016 data for grid features called balancing areas. The continental US has 66 of these, providing much better spatial resolution on the data than the larger grid subdivisions. This doesn't cover everything—several balancing areas in Canada and Mexico are tied in to the US grid—and some of these balancing areas are much larger than others. The PJM grid, serving Pennsylvania, New Jersey, and Maryland, for example, is more than twice as large as Texas' ERCOT, in a state that produces and consumes the most electricity in the US.

Despite these limitations, it's possible to get hourly figures on how much electricity was generated, what was used to produce it, and whether it was used locally or exported to another balancing area. Information on the generating sources allowed the researchers to attach an emissions figure to each unit of electricity produced. Coal, for example, produces double the emissions of natural gas, which in turn produces more than an order of magnitude more carbon dioxide than the manufacturing of solar, wind, or hydro facilities. These figures were turned into what the authors call "embodied emissions" that can be traced to where they're eventually used.

Similar figures were also generated for sulfur dioxide and nitrogen oxides. Released by the burning of fossil fuels, these can both influence the global climate and produce local health problems.

Huge variation
The results were striking. "The consumption-based carbon intensity of electricity varies by almost an order of magnitude across the different regions in the US electricity system," the authors conclude. The low is the Bonneville Power grid region, which is largely supplied by hydropower; it has typical emissions below 100kg of carbon dioxide per megawatt-hour. The highest emissions come in the Ohio Valley Electric region, where emissions clear 900kg/MW-hr. Only three regional grids match the overall grid emissions intensity, although that includes the very large PJM (where capacity auction payouts recently fell), ERCOT, and Southern Co balancing areas.

Most of the low-emissions power that's exported comes from the Pacific Northwest's abundant hydropower, while the Rocky Mountains area exports electricity with the highest associated emissions. That leads to some striking asymmetries. Local generation in the hydro-rich Idaho Power Company has embodied emissions of only 71kg/MW-hr, while its imports, coming primarily from Rocky Mountain states, have a carbon content of 625kg/MW-hr.

The reliance on hydropower also makes the asymmetry seasonal. Local generation is highest in the spring as snow melts, but imports become a larger source outside this time of year. As solar and wind can also have pronounced seasonal shifts, similar changes will likely be seen as these become larger contributors to many of these regional grids. Similar things occur daily, as both demand and solar production (and, to a lesser extent, wind) have distinct daily profiles.

The Golden State
California's CISO provides another instructive case. Imports represent less than 30% of its total electric use in 2016, yet California electricity imports provided 40% of its embodied emissions. Some of these, however, come internally from California, provided by the Los Angeles Department of Water and Power. The state itself, however, has only had limited tracking of imported emissions, lumping many of its sources as "other," and has been exporting its energy policies to Western states in ways that shape regional markets.

Overall, the 2016 inventory provides a narrow picture of the US grid, as plenty of trends are rapidly changing our country's emissions profile, including the rise of renewables and the widespread adoption of efficiency measures and other utility trends in 2017 that continue to evolve. The method developed here can, however, allow for annual updates, providing us with a much better picture of trends. That could be quite valuable to track things like how the rapid rise in solar power is altering the daily production of clean power.

More significantly, it provides a basis for more informed policymaking. States that wish to promote low-emissions power can use the information here to either alter the source of their imports or to encourage the sites where they're produced to adopt more renewable power. And those states that are exporting electricity produced primarily through fossil fuels could ensure that the locations where the power is used pay a price that includes the health costs of its production.

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Greengen Misfeasance Ruling details a B.C. Supreme Court decision awarding $10.125 million over wrongfully denied Crown land and water licence permits for a Fries Creek run-of-river hydro project under a BC Hydro contract.

Key Points

A B.C. Supreme Court ruling awarding $10.125M for wrongful denial of Crown land and water licences on Greengen's project.

✅ $10.125M damages for misfeasance in public office

✅ Denial of Crown land tenure and water licence permits

✅ Tied to Fries Creek run-of-river and BC Hydro EPA

A B.C. Supreme Court judge has ordered the provincial government to pay $10.125 million after it denied permits to a company that wanted to build a run-of-the river independent power project near Squamish.

In his Oct. 10 decision, Justice Kevin Loo said the plaintiff, Greengen Holdings Ltd., “lost an opportunity to achieve a completed and profitable hydro-electric project” after government representatives wrongfully exercised their legal authority, a transgression described in the ruling as “misfeasance,” with separate concerns reflected in an Ontario market gaming investigation reported elsewhere.

Between 2003 and 2009, the company sought to develop a hydro-electric project on and around Fries Creek, which sits opposite the Brackendale neighbourhood on the other side of the Squamish River. To do so, Greengen Holdings Ltd. required a water licence from the Minister of the Environment and tenure over Crown land from the Minister of Agriculture.

After a lengthy process involving extensive communications between Greengen and various provincial and other ministries and regulatory agencies, the permits were denied, according to Loo. Both decisions cited impacts on Squamish Nation cultural sites that could not be mitigated.

Elsewhere, an Indigenous-owned project in James Bay proceeded despite repeated denials, underscoring varied approaches to community participation.

40-year electricity plan relied on Crown land
The case dates back to December 2005, when BC Hydro issued an open call for power with Greengen. The company submitted a tender several months later.

On July 26, 2006, BC Hydro awarded Greengen an energy purchase agreement, amid evolving LNG electricity demand across the province, under which Greengen would be entitled to supply electricity at a fixed price for 40 years.

Unlike conventional hydroelectric projects, such as new BC generating stations recently commissioned, which store large volumes of water in reservoirs, and in so doing flood large tracts of land, a run of the river project often requires little or no water storage. Instead, from a high elevation, they divert water from a stream or river channel.

Water is then sent into a pressured pipeline known as a penstock, and later passed through turbines to generate electricity, Loo explained, as utilities pursue long-term plans like the Hydro-Québec strategy to reduce fossil fuel reliance. The system returns water to the original stream or river, or into another body of water. 

The project called for most of that infrastructure to be built on Crown land, according to the ruling.

All sides seemed to support the project
In early 2005, company principle Terry Sonderhoff discussed the Fries Creek project in a preliminary meeting with Squamish Nation Chief Ian Campbell.

“Mr. Sonderhoff testified that Chief Campbell seemed supportive of the project at the time,” Loo said.

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CO2 Tax for UK Offshore Energy Efficiency can accelerate adoption of aero-derivative gas turbines, flare gas recovery, and combined cycle power, reducing emissions on platforms like Equinor's Mariner and supporting net zero goals.

Key Points

A carbon price pushing operators to adopt efficient turbines, flare recovery, and combined cycle to cut emissions.

✅ Aero-derivative turbines beat industrial units on efficiency

✅ Flare gas recovery cuts routine flaring and fuel waste

✅ Combined cycle raises efficiency and lowers emissions

By Tom Baxter

The recent Energy Voice article from the Equinor chairman concerning the Mariner project heralding a ‘significant point of reference’ for growth highlighted the energy efficiency achievements associated with the platform.

I view energy efficiency as a key enabler to net zero, and alongside this the UK must start large-scale storage to meet system needs; it is a topic I have been involved with for many years.

As part of my energy efficiency work, I investigated Norwegian practices and compared them with the UK.

There were many differences, here are three;

1. Power for offshore installations is usually supplied from gas turbines burning fuel from the oil and gas processing plant, and even as the UK's offshore wind supply accelerates, installations convert that to electricity or couple the gas turbine to a machine such as a gas compressor.

There are two main generic types of gas turbine – aero-derivative and industrial. As the name implies aero-derivatives are aviation engines used in a static environment. Aero-derivative turbines are designed to be energy efficient as that is very import for the aviation industry.

Not so with industrial type gas turbines; they are typically 5-10% less efficient than a comparable aero-derivative.

Industrial machines do have some advantages – they can be cheaper, require less frequent maintenance, they have a wide fuel composition tolerance and they can be procured within a shorter time frame.

My comparison showed that aero-derivative machines prevailed in Norway because of the energy efficiency advantages – not the case in the UK where there are many more offshore industrial gas turbines.

Tom Baxter is visiting professor of chemical engineering at Strathclyde University and a retired technical director at Genesis Oil and Gas Consultants

2. Offshore gas flaring is probably the most obvious source of inefficient use of energy with consequent greenhouse gas emissions.

On UK installations gas is always flared due to the design of the oil and gas processing plant.

Though not a large quantity of gas, a continuous flow of gas is routinely sent to flare from some of the process plant.

In addition the flare requires pilot flames to be maintained burning at all times and, while Europe explores electricity storage in gas pipes, a purge of hydrocarbon gas is introduced into the pipes to prevent unsafe air ingress that could lead to an explosive mixture.

On many Norwegian installations the flare system is designed differently. Flare gas recovery systems are deployed which results in no flaring during continuous operations.

Flare gas recovery systems improve energy efficiency but they are costly and add additional operational complexity.

3. Returning to gas turbines, all UK offshore gas turbines are open cycle – gas is burned to produce energy and the very hot exhaust gases are vented to the atmosphere. Around 60 -70% of the energy is lost in the exhaust gases.

Some UK fields use this hot gas as a heat source for some of the oil and gas treatment operations hence improving energy efficiency.

There is another option for gas turbines that will significantly improve energy efficiency – combined cycle, and in parallel plans for nuclear power under the green industrial revolution aim to decarbonise supply.

Here the exhaust gases from an open cycle machine are taken to a separate turbine. This additional turbine utilises exhaust heat to produce steam with the steam used to drive a second turbine to generate supplementary electricity. It is the system used in most UK power stations, even as UK low-carbon generation stalled in 2019 across the grid.

Open cycle gas turbines are around 30 – 40% efficient whereas combined cycle turbines are typically 50 – 60%. Clearly deploying a combined cycle will result in a huge greenhouse gas saving.

I have worked on the development of many UK oil and gas fields and combined cycle has rarely been considered.

The reason being is that, despite the clear energy saving, they are too costly and complex to justify deploying offshore.

However that is not the case in Norway where combined cycle is used on Oseberg, Snorre and Eldfisk.

What makes the improved Norwegian energy efficiency practices different from the UK – the answer is clear; the Norwegian CO2 tax.

A tax that makes CO2 a significant part of offshore operating costs.

The consequence being that deploying energy efficient technology is much easier to justify in Norway when compared to the UK.

Do we need a CO2 tax in the UK to meet net zero – I am convinced we do. I am in good company. BP, Shell, ExxonMobil and Total are supporting a carbon tax.

Not without justification there has been much criticism of Labour’s recent oil tax plans, alongside proposals for state-owned electricity generation that aim to reshape the power market.

To my mind Labour’s laudable aims to tackle the Climate Emergency would be much better served by supporting a CO2 tax that complements the UK's coal-free energy record by strengthening renewable investment.

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Pickering nuclear refurbishment will modernize Ontario's Candu reactors at Pickering B, sustaining 2,000 MW of clean electricity, aiding net-zero goals, and aligning with Ontario Power Generation plans and Canadian Nuclear Safety Commission reviews.

Key Points

An 11-year overhaul of Pickering B Candu reactors to extend life, keep 2,000 MW online, and back Ontario net-zero grid.

✅ 11-year project; 11,000 annual jobs; $19.4B GDP impact.

✅ Refurbishes four Pickering B Candu units; maintains 2,000 MW.

✅ Requires Canadian Nuclear Safety Commission license approvals.

The Ontario government has announced its intention to pursue a Pickering refurbishment at the venerable nuclear power station, which has been operational for over fifty years. This move could extend the facility's life by another 30 years.

This decision is timely, as Ontario anticipates a significant surge in electricity demand and a growing electricity supply gap in the forthcoming years. Additionally, all provinces are grappling with new federal mandates for clean electricity, necessitating future power plants to achieve net-zero carbon emissions.

Todd Smith, the Energy Minister, is expected to endorse Ontario Power Generation's proposal for the plant's overhaul, as per a preliminary version of a government press release.

The renovation will focus on four Candu reactors, known collectively as Pickering B, which were originally commissioned in the early 1980s. This upgrade is projected to continue delivering 2,000 megawatts of power, equivalent to the current output of these units.

According to the press release, the project will span 11 years, create approximately 11,000 annual jobs, and contribute $19.4 billion to Ontario's GDP. However, the total budget for the project remains unspecified.

The project follows the ongoing refurbishment of four units at the nearby Darlington nuclear station, which is more than halfway completed with a budget of $12.8 billion.

The proposal awaits the Canadian Nuclear Safety Commission's approval, and officials face extension request timing considerations before key deadlines.

The Commission is also reviewing a prior request from OPG to extend the operational license of the existing Pickering B units until 2026. This extension would allow the plant to safely continue operating until the commencement of its renovation, pending approval.

Ontario's Ambitious Nuclear Strategy

The announcement regarding Pickering is part of Ontario's broader clean energy plan for an unprecedented expansion of nuclear power in Canada.

Last summer, the province announced its intention to nearly double the output at Bruce Power, currently the world's largest nuclear generating station.

Additionally, Ontario revealed SMR plans to construct three more alongside the existing project at Darlington. These reactors are expected to supply enough electricity to power around 1.2 million homes.

Discussions about revitalizing the Pickering facility began in 2022, after the station had been slated to close as planned amid debate, with Ontario Power Generation submitting a feasibility report to the government last summer.

The Ford government emphasized the necessity of this nuclear expansion to meet the increasing electricity demands anticipated from the auto sector's shift to electric vehicles, the steel industry's move away from coal-fired furnaces, and the growing population in Ontario.

Ontario's capability to attract major international car manufacturers like Volkswagen and Stellantis to produce electric vehicles and batteries is partly attributed to the fact that 90% of the province's electricity comes from non-fossil fuel sources.

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Alberta Lithium Brine can power EV batteries via direct lithium extraction, leveraging oilfield infrastructure and critical minerals policy to build a low-carbon supply chain with clean energy, lower emissions, and domestic manufacturing advantages.

Key Points

Alberta lithium brine is subsurface saline water rich in lithium, extracted via DLE to supply EV batteries.

✅ Uses direct lithium extraction from oilfield brines

✅ Leverages Alberta infrastructure and skilled workforce

✅ Supports EV battery supply chain with lower emissions

After a most difficult several months, Canadians are cautiously emerging from their COVID-19 isolation and confronting a struggling economy.
There’s a growing consensus that we need to build back better from COVID-19, and to position for the U.S. auto sector’s pivot to electric vehicles as supply chains evolve. Instead of shoring up the old economy as we did following the 2008 financial crisis, we need to make strategic investments today that will prepare Canada for tomorrow’s economy.

Tomorrow’s energy system will look very different from today’s — and that tomorrow is coming quickly. The assets of today’s energy economy can help build and launch the new industries required for a low-carbon future. And few opportunities are more intriguing than the growing lithium market.

The world needs lithium – and Alberta has plenty

It’s estimated that three billion tonnes of metals will be required to generate clean energy by 2050. One of those key metals – lithium, a light, highly conductive metal – is critical to the construction of battery electric vehicles (BEV). As global automobile manufacturers design hundreds of new BEVs, demand for lithium is expected to triple in the next five years alone, a trend sharpened by pandemic-related supply risks for automakers.

Most lithium today originates from either hard rock or salt flats in Australia and South America. Alberta’s oil fields hold abundant deposits of lithium in subsurface brine, but so far it’s been overlooked as industrial waste. With new processing technologies and growing concerns about the security of global supplies, this is set to change. In January, Canada and the U.S. finalized a Joint Action Plan on Critical Minerals to ensure supply security for critical minerals such as lithium and to promote supply chains closer to home, aligning with U.S. efforts to secure EV metals among allies worldwide.

This presents a major opportunity for Canada and Alberta. Lithium brine will be produced much like the oil that came before it. This lithium originates from many of the same reservoirs responsible for driving both Alberta’s economy and the broader transportation fuel sector for decades. The province now has extensive geological data and abundant infrastructure, including roads, power lines, rail and well sites. Most importantly, Alberta has a highly trained workforce. With very little retooling, the province could deliver significant volumes of newly strategic lithium.

Specialized technologies known as direct lithium extraction, or DLE, are being developed to unlock lithium-brine resources like those in Canada. In Alberta, E3 Metals* has formed a development partnership with U.S. lithium heavyweight Livent Corporation to advance and pilot its DLE technology. Prairie Lithium and LiEP Energy formed a joint venture to pilot lithium extraction in Saskatchewan. And Vancouver’s Standard Lithium is already piloting its own DLE process in southern Arkansas, where the geology is very similar to Alberta and Saskatchewan.

Heavy on quality, light on emissions

All lithium produced today has a carbon footprint, most of which can be tied back to energy-intensive processing. The purity of lithium is essential to battery safety and performance, but this comes at a cost when lithium is mined with trucks and shovels and then refined in coal-heavy China.

As automakers look to source more sustainable raw materials, battery recycling will complement responsible extraction, and Alberta’s experience with green technologies such as renewable electricity and carbon capture and storage can make it one of the world’s largest suppliers of zero-carbon lithium.

Beyond raw materials

The rewards would be considerable. E3 Metals’ Alberta project alone could generate annual revenues of US$1.8 billion by 2030, based on projected production and price forecasts. This would create thousands of direct jobs, as initiatives like a lithium-battery workforce initiative expand training, and many more indirectly.

To truly grow this industry, however, Canada needs to move beyond its comfort zone. Rather than produce lithium as yet another raw-commodity export, Canadians should be manufacturing end products, such as batteries, for the electrified economy, with recent EV assembly deals underscoring Canada’s momentum. With nickel and cobalt refining, graphite resources and abundant petrochemical infrastructure already in place, Canada must aim for a larger piece of the supply chain.

By 2030, the global battery market is expected to be worth $116 billion annually. The timing is right to invest in a strategic commodity and grow our manufacturing sector. This is why the Alberta-based Energy Futures Lab has called lithium one of the ‘Five big ideas for Alberta’s economic recovery.’  The assets of today’s energy economy can be used to help build and launch new resource industries like lithium, required for the low-carbon energy system of the future.

Industry needs support

To do this, however, governments will have to step up the way they did a generation ago. In 1975, the Alberta government kick-started oil-sands development by funding the Alberta Oil Sands Technology and Research Authority. AOSTRA developed a technology called SAGD (steam-assisted gravity drainage) that now accounts for 80% of Alberta’s in situ oil-sands production.

Canada’s lithium industry needs similar support. Despite the compelling long-term economics of lithium, some industry investors need help to balance the risks of pioneering such a new industry in Canada. The U.S. government has recognized a similar need, with the Department of Energy’s recent US$30 million earmarked for innovation in critical minerals processing and the California Energy Commission’s recent grants of US$7.8 million for geothermal-related lithium extraction.

To accelerate lithium development in Canada, this kind of leadership is needed. Government-assisted financing could help early-stage lithium-extraction technologies kick-start a whole new industry.

Aspiring lithium producers are also looking for government’s help to repurpose inactive oil and gas wells. The federal government has earmarked $1 billion for cleaning up inactive Alberta oil wells. Allocating a small percentage of that total for repurposing wells could help transform environmental liabilities into valuable clean-energy assets.

The North American lithium-battery supply chain will soon be looking for local sources of supply, and there is room for Canada-U.S. collaboration as companies turn to electric cars, strengthening regional resilience.
 

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Duke Energy zero-coal 2050 plan outlines a decarbonized energy mix, aligning with Paris goals, cutting greenhouse gas emissions, driven by investor pressure, shifting to natural gas, extending nuclear power, and phasing out coal.

Key Points

An investor-driven scenario to end coal by 2050, shift to natural gas, extend nuclear plants, and manage climate risk.

✅ Eliminates coal from the generation mix by 2050

✅ Prioritizes natural gas transitions without CCS breakthroughs

✅ Extends nuclear plant licenses to limit carbon emissions

One of America’s largest utility companies, Duke Energy, is set to release a report later this month that sketches a drastically changed electricity mix in a carbon-constrained future.

The big picture: Duke is the latest energy company to commit to releasing a report about climate change in response to investor pressure, echoing shifts such as Europe's oil majors going electric across the sector, conveyed by non-binding but symbolically important shareholder resolutions. Duke provides electricity to more than seven million customers in the Carolinas, the Midwest and Florida.

Gritty details: The report is expected to find that coal, currently 33% of Duke’s mix, gone entirely from its portfolio by 2050 in a future scenario where the world has taken steps to cut greenhouse gas emissions, and where global coal-fired electricity use is falling markedly, to a level consistent with keeping global temperatures from rising two degrees Celsius. That’s the big ambition of the 2015 Paris climate deal, but the current commitments aren’t close to reaching that.

What they're saying: “What’s difficult about this is we are trying to overlay what we understand currently about technology,” Lynn Good, Duke CEO, told Axios in an interview on the sidelines of a major energy conference here.

She went on to say that this scenario of zero coal by 2050 doesn’t assume any breakthroughs in technology that captures carbon emissions from coal-fired power plants. “We don’t see that technology today, and we need to make economic decisions to get those units moving and replacing them with natural gas.”

Good also stressed the benefits of its several nuclear power plants, highlighting the role of sustaining U.S. nuclear power in decarbonization, which emit no carbon emissions. She said Duke isn’t considering investing in new nuclear plants, but plans to seek federal relicensing of current plants.

“If I turn them off, the resource that would replace them today is natural gas, so carbon will go up,” Good said. “Our objective is to continue to keep those plants as long as possible.”

What’s next: A spokesman said the other details of their 2050 scenario estimates will be available when the report is officially released by month’s end.

Axios reports that Duke Energy will release a report later this month that detail the utility's efforts to mitigate climate change risks and plan carbon-free electricity investments across its operations. The report includes a scenario that eliminates coal entirely from the company's power mix by 2050. Coal currently makes up about a third of Duke's generation.

Duke CEO Lynn Good told the news outlet the scenario ending coal-fired generation assumes no technological advances in emissions capture, seemingly leaving open the possibility.

Last year, a report by the Union of Concerned Scientists concluded one in four of the remaining operating coal-fired plants in the U.S. are slated for closure or conversion to natural gas, amid falling power-sector carbon emissions across the country. Duke's report is expected to be released by the end of the month.

Duke's report on its carbon plans comes at the behest of shareholders, a trend utility companies have seen growing among investors who are increasingly concerned about companies' sustainability and their financial exposure to climate policy.

Last year, a majority of shareholders of Pennsylvania utility PPL Corp. called on company management to publish a report on how climate change policies and technological innovations will affect the company's bottom line. Almost 60% of shareholders voted in favor of the non-binding proposal.

The vote, reportedly a first for the power sector, followed a similar decision by shareholders of Occidental Petroleum, which was supported by about 66% of shareholders.

Duke's Good told Axios that right now the utility does not see the coal technology on the horizon that would keep it operating plants. “We don't see that technology today, and we need to make economic decisions to get those units moving and replacing them with natural gas," Good said. However, it does not mean the utility is making near-term efforts to erase coal from its power mix. However, some utilities are taking those steps as they prepare for en energy landscape with more carbon regulations.

In addition to the 25% of coal plants heading for closure or conversion, the UCS report also said that another 17% of the nation’s operating coal plants are uneconomic compared with natural gas-fired generation, and could face retirement soon. But there is plenty of ongoing research into "clean coal" possibilities, and the federal government has expressed an interest in smaller, modular coal units.

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