Archive for Wednesday, July 1, 2009
EPA: State must conduct review, hold hearings on latest coal-plant proposal
July 1, 2009, 4:40 p.m. Updated July 2, 2009, 3:40 p.m.
Advertisement
Sunflower Electric coal plant
After months of debate and legislative battles, Sunflower Electric Power Corp. will be allowed to build a new, coal-fired power plant in Southwest Kansas. Trace the history of the disagreement and look back on how we got here.
Topeka The federal EPA has essentially told the state and Sunflower Electric Power Corp. to start over in considering a permit to build a coal-burning power plant in southwest Kansas.
Sunflower Electric must submit applications for the 895-megawatt plant, and the Kansas Department of Health and Environment must conduct a comprehensive review of the proposal and open up the process for public comment. Such a process can typically take up to 18 months.
The requirements were outlined in a letter sent Wednesday from EPA Regional Administrator William Rice to Gov. Mark Parkinson, KDHE and Sunflower.
“The redesign of this new unit, as well as public input on the new project, will need to be considered in determining the form and content of any final permit,” Rice said.
The EPA statement was the latest twist in an issue that has consumed much of Kansas politics over the past several years.
In 2007, KDHE Secretary Rod Bremby denied Sunflower’s permit to build two 700-megawatt coal-fired plants, citing concerns about the effect of carbon dioxide emissions on Kansans’ health and on climate change.
Former Gov. Kathleen Sebelius stood by the decision, vetoing several bills that would have required Bremby to issue the permits. Once Sebelius stepped down to become secretary of the U.S. Department of Health and Human Services, her lieutenant governor — Mark Parkinson — became governor.
Shortly after taking office, Parkinson negotiated a deal with Sunflower to allow construction of an 895-megawatt plant if the Legislature adopted a measure aimed at increasing renewable energy. The Legislature did just that.
Sunflower submitted a revised permit, but the EPA indicated more information was needed.
Since Sunflower filed its original application in 2006, much has changed in regulating air pollution and the project itself has gone through enough transformations to require a comprehensive analysis of the proposal, EPA said.
“Consistent with the approved regulations, KDHE must provide opportunity for a full 30-day public notice and comment period, making the results of KDHE’s analysis of the new project available for public review,” Rice said.
Last month, Earthjustice and Sierra Club called on the state to require a new permit process for the proposed plant, which would include public hearings.
The groups issued a statement praising EPA’s decision. “EPA is correct to require a new permitting process because this will bring out into the light of day the danger posed by this dirty coal plant which the governor and the coal power company sought to keep from the public,” said Amanda Goodin of Earthjustice.
But Parkinson’s office said he was OK with the EPA requirements.
Parkinson spokeswoman Beth Martino said the deal the governor made with Sunflower was not meant to circumvent the regulatory process.
“The governor has always known that the permit would have to conform to the Clean Air Act, and the standards in the permitting process,” Martino said. “He supports that process and would defer to the agencies that are responsible.”
And Sunflower spokeswoman Cindy Hertel said the company was prepared for EPA’s recommendations based on discussions with federal and state officials in a meeting in late May. She said Sunflower should have the information submitted to KDHE by early to mid-fall.
“This is an ongoing process,” she said.
More like this
- Sierra Club wants hearings on new coal-plant proposal 28 comments / June 22, 2009
- Timeline of coal-fired plants proposals May 5, 2009
- Sierra Club tries anew to block coal plant 12 comments / August 4, 2009
- KDHE: Coal plant permit 'most complex' 9 comments / October 6, 2007
- Power politics 10 comments / May 6, 2009
Top ads RSS
- LPN Baldwin Healthcare is currently accepting applications for a full ...
- KU Medical Center
- DERMATOLOGY Nurse Seeking LPN/MA for dermatology practice in Lawrence. Part-time ...
- Dishwasher The Merc is hiring! We’re looking for a high ...
- FUNERAL PLANNING ADVISORS An excellent career opportunity for men and ...
Marketplace
Arts & Entertainment · Bars · Theatres · Restaurants · Coffeehouses · Libraries · Antiques · Services
- Blog: The Real Oscar November 7, 2009 · 2 comments
- CritiTech leader has stake in lab building November 7, 2009 · 30 comments
- Former House speaker has vital message for America November 7, 2009 · 26 comments
- FINAL: Daniel Thomas runs for 183 yards in KSU's 17-10 victory over KU November 7, 2009 · 43 comments
- Obama finding it harder to blame Bush for job woes November 7, 2009 · 46 comments
- Mass shooting worst ever at U.S. military base; 12 killed November 6, 2009 · 186 comments
- Poll: Would you vote the same way today as you did for president in 2008? November 6, 2009 · 54 comments
- City police welcome 6 graduates after 23-week ‘grueling academy’ November 7, 2009 · 9 comments
- Blog: I Am A Stripper. November 3, 2009 · 315 comments
- On the street: Do you have good penmanship? November 7, 2009 · 26 comments
- Tractor Supply Co. to open Lawrence store August 13, 2009
- Woman passes driver’s exam on 950th try November 7, 2009
- KU freshmen overcome first-game jitters November 7, 2009
- Sacred landmark: Capital campaign drives changes at ECM in its 50th year at KU November 7, 2009
- Conference on Kansas tourism slated for later this month October 5, 2009
- Former House speaker has vital message for America November 7, 2009
- Preserving penmanship in the Computer Age November 7, 2009
- City police welcome 6 graduates after 23-week ‘grueling academy’ November 7, 2009
- Regents Chairwoman asks legislators to put away the budget knife November 6, 2009
- Green pours in 17 in Colo. St. debut November 6, 2009



1 July 2009
at 4:50 p.m.
Suggest removal
Permalink
gccs14r (Anonymous) says…
Ha ha.
1 July 2009
at 5:07 p.m.
Suggest removal
Permalink
yankeelady (Anonymous) says…
This was somewhat predictable.
1 July 2009
at 5:16 p.m.
Suggest removal
Permalink
Akreed (Anonymous) says…
Bwwaaahhahahahah…the EPA telling another agency they must have a comprehensive review to allow for public input. Maybe they should practice what they preach and not hide their own scientists reports. Until then they should mind their own damn business.
1 July 2009
at 5:53 p.m.
Suggest removal
Permalink
a_flock_of_jayhawks (Anonymous) says…
Akreed (Anonymous) says…
“the EPA telling another agency they must have a comprehensive review to allow for public input.”
They have jurisdiction and legislation that would change the rules is making it's way through the US Congress. Sounds like a prudent step for that agency. If they didn't, they would have to take the heat for not doing so.
“Maybe they should practice what they preach and not hide their own scientists reports. Until then they should mind their own damn business.”
It's not hiding, it's called research, review, and vetting to make sure the public gets accurate information. If they didn't do that, an economist might put forth unfounded and possibly inaccurate information to the public, diluting the public and public entities reliance and confidence in the information published and making decisions on the local level based on policy guidance that could wildly fluctuate over time.
Oh wait, there's an EPA economist (not a scientist) doing this as a hobby that is complaining about just that at the moment. If that's the kind of input you desire from your tax dollars, then I think you'll be (even more) disappointed in the products that they produce resulting from that approach. Or, let's just politicize the scientific processes involved and use them as a pawn to support the initiatives of the party in power, like W did in his tenure. We wouldn't want any truth in the information furnished to stand in the way.
From your comment, you apparently don't have a problem with government doing whatever without any input from the public and concerned parties before they do it.
1 July 2009
at 7:02 p.m.
Suggest removal
Permalink
beobachter (Anonymous) says…
Glad to see someone is telling the Republican controlled legislature and the Republican bought and paid for governor they've got to follow the rules.
1 July 2009
at 7:19 p.m.
Suggest removal
Permalink
belexus73 (Anonymous) says…
It looks like they will be compelled to consider IGCC tecnology in their BACT application. That could be a tough road to hoe.
1 July 2009
at 7:51 p.m.
Suggest removal
Permalink
ukillaJJ (Anonymous) says…
Woohoooo!!! Thank you EPA!!!
1 July 2009
at 9:17 p.m.
Suggest removal
Permalink
rooster (Anonymous) says…
Best news all summer.
Maybe there really is a god.
1 July 2009
at 9:50 p.m.
Suggest removal
Permalink
riverat (Joe Hyde) says…
This is a reasonable development in the debate about whether to build this new coal-fired plant.
However, I wish the the rules would be changed so that the public comment period were longer than 30 days. And not only for this power plant application but for all permit applications involving commercial activities that have the potential (or have already demonstrated their ability) to alter our environment in a lasting and fundamental way.
When a permit application is first publicized, this starts the clock ticking on the public's 30-day comment period. Many times concerned citizens do not hear news of the permit app., or even get a chance to read it, until it is too late to thoroughly consider the information contained in the application. The ramifications of approving or denying the application cannot thus be weighed and studied by the intended audience.
Indeed, depending on the application type and the timing of its Public Notice publication release, often citizens who are most concerned about the activity miss participating entirely, all due to the brief-ness of the public comment period.
Moreover, by the time many Public Notices come out, the company involved and specific government agencies have already worked together for months or even years, behind the scenes, out of the public eye, So it can be a deal where from out of nowhere comes a Public Notice that catches the public by surprise…if it catches anyone's attention at all.
Surely a permit application process that involves something as serious as a new coal-fired power plant needs to be reviewed more deliberately, so as to be respectful of the public's right to inspect and evaluate details of the proposed activity. After all, it's the public — in this case the Kansas public — who will have be living with the consequences of the industrial activity.
Why should this matter? Because in this case the wealthy main stockholders and management executives who own and operate this power plant won't be living in Holcomb or anywhere nearby downwind. No, boys and girls, they'll be living in homes and cities located far from the site. Mountain resorts in the Rockies most likely. How do I know? Well, it used to be called “tradition”; now the wording has been upgraded to “executive perk”.
1 July 2009
at 9:55 p.m.
Suggest removal
Permalink
ibroke (Anonymous) says…
well people i hope you are ready to see your electric bill jump…… you know that trees need co2 to live and when we exhale co2 comes out
1 July 2009
at 10:59 p.m.
Suggest removal
Permalink
logicsound09 (Anonymous) says…
This is good news. We can't continue on the reckless, consequences-be-damned course that we've been on regarding emissions and pollutants in the United States.
1 July 2009
at 11:08 p.m.
Suggest removal
Permalink
Marion (Marion Lynn) says…
The EPA has considered Kansas to be a “home rule” state on any number of other environmental issues, so it will be interesting to see where this goes.
1 July 2009
at 11:25 p.m.
Suggest removal
Permalink
Hoots (Anonymous) says…
They just got Obama'd. This is going to be part of Cap-n-Trade. Good luck on this one.
I didn't like the idea of these plants in the first place but this crack down scares me a little.
1 July 2009
at 11:27 p.m.
Suggest removal
Permalink
gccs14r (Anonymous) says…
Our atmosphere does well with a very small percentage of CO2. Adding more not only warms the planet, but also makes the oceans more acidic. One consequence of increased ocean acidity is the dissolving of shelled organisms.
1 July 2009
at 11:44 p.m.
Suggest removal
Permalink
straightforward (Anonymous) says…
Amanda Goodin of Earthjustice is flat out lying when she refers to this plant as a “dirty coal plant.” This plant's energy will be cleaner than any other coal plant in the state. And in case any of you environmentalists forgot, the President supports clean coal (or at least when he is speaking in coal mining states).
Hasn't the public had enough time to comment on this? I mean we debated this issue for the last two years. This is just a last ditch effort, by a powerful government bureaucracy, to delay construction so the President's Cap and Trade bill can come through and put a stop to it all together, killing any jobs this would have created and ultimately leading to higher energy costs.
2 July 2009
at 6:42 a.m.
Suggest removal
Permalink
belexus73 (Anonymous) says…
Ms. Goodin is not flat out lying. Her statement is backed up by the SCOTUS ruling that carbon dioxide should be regulated as a pollutant. Since CO2 is now a pollutant, Holcomb II would be emitting said pollutant and therefore be considered “dirty”-just as any other coal plant. The public has not had enough time to comment on this issue since (if you read the EPA ruling), we now have a totally different coal plant proposal and technological advances since the last permit application was submitted.
2 July 2009
at 8:44 a.m.
Suggest removal
Permalink
just_me (Anonymous) says…
This is GREAT news. Sunflower just keeps pounding away at Kansas on these plants, even though they've been rejected so many times, in so many different ways. Take this all as a sign. We DON”T want your dirty coal plants in Kansas!!!!!!
2 July 2009
at 9 a.m.
Suggest removal
Permalink
Ogallala_Kid (Anonymous) says…
Meanwhile, the self-appointed ecological umpires of Lawrence yelp with glee, as they suck in another big breathe of pollution created at their coal plant virtually at their city limits, as they point to someone else's activities hundreds of miles away.
2 July 2009
at 9 a.m.
Suggest removal
Permalink
ibroke (Anonymous) says…
well when your electric bill doubles you might feel better about how clean you think kansas and the usa is (it probably wont change a thing)but what is china doing about global warming?
2 July 2009
at 9:11 a.m.
Suggest removal
Permalink
rooster (Anonymous) says…
Ogallala: You start the petition to remove the local plant and probably 90% of lawrence will back you.
Ibroke: This aint china,
2 July 2009
at 9:42 a.m.
Suggest removal
Permalink
blue73harley (Anonymous) says…
Sounds like some former Lawrence City Commissioners now work for the EPA.
2 July 2009
at 9:44 a.m.
Suggest removal
Permalink
blue73harley (Anonymous) says…
rooster - Yes, this isn't China but that is where all the manufacturing jobs are going because of rulings like these.
2 July 2009
at 10:12 a.m.
Suggest removal
Permalink
rooster (Anonymous) says…
No blue73harley, There are subaru plants in mississippi. Toyota and honda plants in georgia. All these plants have zero or low impact.
2 July 2009
at 10:19 a.m.
Suggest removal
Permalink
blue73harley (Anonymous) says…
rooster - you clearly have no understanding at all of the extent of out-sourcing/off-shoring that is occuring. I am referring to the entire manufacturing sector, not a few piddly examples. Wake up.
2 July 2009
at 10:27 a.m.
Suggest removal
Permalink
logicsound09 (Anonymous) says…
“Amanda Goodin of Earthjustice is flat out lying when she refers to this plant as a “dirty coal plant.””
––––––-
It's not a lie, just a redundant statement.
*All* coal plants are dirty. Some are just less-so than others.
==========================
“Meanwhile, the self-appointed ecological umpires of Lawrence yelp with glee, as they suck in another big breathe of pollution created at their coal plant virtually at their city limits, as they point to someone else's activities hundreds of miles away.”
–––––-
Hyperbole much?
FYI, if the Holcomb project had been intended as a *replacement* for the plant outside Lawrence, I would have been in favor of it. A cleaner plant replacing an older, dirtier one would have been a good thing.
But this project wasn't about creating a cleaner energy solution—it was about generating more revenue for Sunflower Cooperative, benefitting a small group while contributing to the harm of everyone on the planet.
2 July 2009
at 10:32 a.m.
Suggest removal
Permalink
Ogallala_Kid (Anonymous) says…
Rooster: Not my job. Why didn't *you* protest when KDHE extended the Clean Air Permit for the Lawrence plant last year. oh yea.
If the ecological experts in Lawrence would devote 1/2 the time and energy focused on Sunflower to their own backyard, something could be accomplished.
2 July 2009
at 10:40 a.m.
Suggest removal
Permalink
gccs14r (Anonymous) says…
Besides, if our electric bill doubled, it would still be cheaper than either the water bill or my cell phone bill. Last month we used 7.5 kWh per day. That was with the A/C running.
2 July 2009
at 11:43 a.m.
Suggest removal
Permalink
ENGWOOD (Anonymous) says…
• U.S. unemployment rate climbs to 26-year high of 9.5 percent!!!
EPA hides evidence of global cooling!!!!!
http://cei.org/news-release/2009/06/2…
http://www.factcheck.org/politics/cap…
No thanks osa__ oops! Obama I think I will keep my change!
2 July 2009
at 2:04 p.m.
Suggest removal
Permalink
merrill (Anonymous) says…
Kansas will not use this juice so why build it in Kansas?
If Sunflower wants Colorado business they should build it in Colorado.
Not only that at a Home Energy Fair Westar reps told me if Kansas people would conserve instead of waste it is not likely that Kansas would need more electricity anytime soon thus saving on electricity.
What Kansas does need is not more power but cleaner power which is to say I would be happy for the opportunity to buy wind power from Western Kansas instead of coal power from Lawrence. OR hydropower from the Hill/Bowersock family.
2 July 2009
at 2:09 p.m.
Suggest removal
Permalink
logicsound09 (Anonymous) says…
Sorry engwood, but I have a hard time giving any credibility to a internal study done by CEI, a group that committed to the principles of free-enterprise and limited government—two principles which are threatened by the idea of the EPA having increased authority to impose taxes and regulations on private industry.
I'm also not sure why you included the link to FactCheck.org, as it has nothing to do with the idea that there is global cooling going on. Perhaps you were trying to mislead people into believing you had a credible source to support your use of the CEI website.
Some information on the motives of CEI:
http://www.sourcewatch.org/index.php?…
2 July 2009
at 2:24 p.m.
Suggest removal
Permalink
BigDog (Anonymous) says…
merrill (Anonymous) says…
Kansas will not use this juice so why build it in Kansas?
If Sunflower wants Colorado business they should build it in Colorado.
––––––––––––––––––-
This argument get used over and over and over ….
Why are Kansas farmers allowed to grow more crop than we need in the state ….. aren't the fertilizers and pesticides used in growing them polluting Kansas streams and rivers.
Why more cattle raised in Kansas than needed to just feed Kansans? As we know they cause pollution
Why more tires manufactured at Goodyear than is needed in Kansas? again there is pollution
And lets not forget about all of those extra airplanes built in Wichita
I could go on and on with this …. we create more than we need of alot of products …. so that people in Kansas have jobs.
2 July 2009
at 2:59 p.m.
Suggest removal
Permalink
logicsound09 (Anonymous) says…
“I could go on and on with this …. we create more than we need of alot of products …. so that people in Kansas have jobs.”
–––––-
And in each situation, a cost/benefit analysis must be done.
In the case of the coal plants, we are looking at 2 fundamental costs: the addition of megatonnes of CO2 into the atmosphere and the depletion of a finite resource—the Ogalalla Aquafer. The benefit is the hundred or so permanent jobs which may or may not be filled by Kansans (you need to be qualified to hold the job).
2 July 2009
at 7:32 p.m.
Suggest removal
Permalink
scott3460 (Anonymous) says…
“This is just a last ditch effort, by a powerful government bureaucracy, to delay construction so the President's Cap and Trade bill can come through and put a stop to it all together, killing any jobs this would have created and ultimately leading to higher energy costs.”
I forsee lots of employment for legal types. Not a bad thing, from my perspective.
2 July 2009
at 7:42 p.m.
Suggest removal
Permalink
RogueThrill (Anonymous) says…
Well, the good new is that this will accelerate the end of Hays, KS. I mean, one they completely run out of water they all have to move somewhere else.
3 July 2009
at 12:23 a.m.
Suggest removal
Permalink
9070811 (Anonymous) says…
Actually, Gov. Parkinson knew about the EPAs intervention before it happened. He only signed yes to allow them to run into a bigger road block.
3 July 2009
at 6:19 a.m.
Suggest removal
Permalink
merrill (Anonymous) says…
Wind Power,Solar Power,More hydro Power and Geo Thermal create more new jobs for longer term and in more parts of Kansas. Also helps farmers with payments from energy sources……
AND Kansas needs new clean power NOT more dirty and expensive coal power or Nuke power which is quite expensive and NOT clean.
3 July 2009
at 6:23 a.m.
Suggest removal
Permalink
merrill (Anonymous) says…
Nuclear Power Is Not Clean or Green!
The Real Dirt on “Clean” Nuclear Energy
* The mining, milling and enrichment of uranium into nuclear fuel are extremely energy-intensive and result in the emission of carbon dioxide into the atmosphere from the burning of fossil fuels.
* Estimated “energy recovery time” for a nuclear power plant is about 10 to 18 years, depending on the richness of uranium ores mined for fuel. This means that a nuclear power plant must operate for at least a decade before all the energy consumed to build and fuel the plant has been earned back and the power station begins to produce net energy. By comparison, wind power takes less than a year to yield net energy, and solar or photovoltaic power nets energy in less than three years.
* The Nuclear Regulatory Commission has calculated that collective radiation doses amounting to 12 cancer deaths can be expected for each 20-year term a reactor operates, as a result of radioactive emissions from the nuclear fuel cycle and routine reactor operations. This calculation assumes no unplanned accidents and does not consider radiation releases from high-level nuclear waste “disposal” activities. Nor are nonfatal health impacts related to radiation exposure counted in this tally.
* Thermal pollution from nuclear power plants adversely affects marine ecosystems. “Once-through” cooling systems in use at half the U.S. nuclear reactors discharge billions of gallons of water per day at temperatures up to 25 degrees Fahrenheit hotter than the water into which it flows.
The Waste Problem
* A typical reactor will generate 20 to 30 tons of high-level nuclear waste annually. There is no known way to safely dispose of this waste, which remains dangerously radioactive for a quarter of a million years.
* The nuclear power industry has amassed hundreds of thousands of tons of “low-level” radioactive waste (or, in industry and regulatory parlance, “slightly radioactive solid materials”), which has created an enormous disposition problem. The industry hopes to absolve itself from liability for this waste through the insane practice of “releasing” it from regulatory control, whereupon it could be sent to recycling facilities and ultimately end up in common consumer products!
* Isolating nuclear waste from people and the environment requires significant energy and resources.
And Expensive Too!
* The Department of Energy admits that “Economic viability for a nuclear plant is difficult to demonstrate.” Since the inception of commercial nuclear power in the United States 50 years ago, this industry has been propped up by huge government subsidies.
http://www.citizen.org/cmep/energy_en…
3 July 2009
at 6:33 a.m.
Suggest removal
Permalink
merrill (Anonymous) says…
January 23, 2007
King Coal's Latest Con Job
Clean Coal is Not Clean
By john blair
Proponents of Integrated Gasification Combined Cycle (IGCC) technology like that Duke and Vectren desire to use at Edwardsport, Indiana, loudly proclaim that IGCC is the answer to global warming since the technology makes its easier to capture carbon dioxide. Once captured, their pitch is that it can be “sequestered” for thousands of years in deep geological formations. Out of sight, out of mind.
In December 2006, the US Department of Energy finally admitted in a supplement to an Environmental Impact Statement (EIS) for an IGCC plant in Pennsylvania that, “DOE has considered the potential to reduce project CO2 emissions using geologic sequestration. This is not a reasonable option because sequestration technology is not sufficiently mature to be implemented at production scale during the demonstration period for the proposed facilities.”
This admission is consistent with most recent research done by government and private sources as it relates to sequestration. In fact, most recent research tells a story that makes the whole idea of sequestration questionable, at best, and perhaps even dangerous for those who may live near the areas where CO2 is dumped underground.
Three areas of concern have emerged in recent studies.
1. CO2 injected near earthquake faults like the region of SW Indiana which is in the New Madrid fault zone, may actually increase the potential for earthquakes due to CO2's ability to lubricate geologic plates, making it easier for them to move when subjected to pressure from beneath the earth's surface.
2. Injection of CO2 can ultimately damage groundwater used for drinking by a chemical conversion when the CO2 is injected causing an increase in acidity which leaches dangerous chemicals like metals out of the formation. Those contaminants often find their way to groundwater. Such a chemical conversion could render entire aquifers unusable as drinking water which people depend upon.
3. Huge financial and energy investment in sequestration. Most of the debate about IGCC has evolved around whether it is possible to convert coal to a synthesis gas in a manner that can be used to generate electricity more cleanly than conventional technology called pulverized coal. The real reason utilities are seeking to build these plants is to capture enormous federal and state taxpayer funded subsidies. For instance, Duke and Vectren were recently awarded more than $133 million in federal tax credits to build their costly and dirty plant.
Con't
http://www.counterpunch.org/blair0123…
P.S. Bush admin pulled the plug on the FutureGen project due to high dollar costs the plant was
generating
P.S. 2 Coal and Nuke plants are financed and insured by taxpayers because no other source will accept the costs or extremely high risks associated with these two toxic sources of electricity.
23 July 2009
at 12:05 p.m.
Suggest removal
Permalink
swku (Anonymous) says…
I'm sorry but I must have missed something. It's my understanding that 'clean coal' does not mean 100% clean. It simply means a cleaner substitute for the older coal fired plants that are not as efficient.
If Wind Farms are so great than why do the residents of Lawrence protest their installment outside of Lawrence city limits. It's convenient for the people of Lawrence to protest the Sunflower plants and insisting wind turbines should be a part of the prerequisites…yet they won't let them be built in Douglas County because it blocks the scenic view. Really people get a life.
Oh yeah…I think its funny how someone is posing as Chris Merrill.