With new commissioners, Healey aims to reshape an agency seen as critical to climate reforms

They could seem the most bureaucratic of appointments, just a few of several that Governor Maura Healey has made since settling into office. But her administration is casting her two climate-friendly nominees to help lead the Department of Public Utilities as a first step toward overhauling a critical agency that she has lambasted as ineffectual and too cozy with natural gas interests.

The new appointments — Jamie Van Nostrand, a law professor and clean energy advocate from West Virginia, and Staci Rubin, a Boston-based environmental justice specialist at the Conservation Law Foundation — starkly contrast with the commissioners they replace.

People familiar with the department’s inner workings said the new commissioners will have exceptional power to quickly change the department’s priorities, in part because they effectively act as judges atop a bureaucracy organized by the principles of the judicial system.

“It’s like a court,” said Amy Boyd, vice president of Climate & Clean Energy Policy at the Acadia Center, which advocates for clean energy. “They can choose how to sequence their docket, and the commissioners decide what takes priority.”

You can read the complete article from The Boston Globe here.

The Clean Energy Cost of Green Hydrogen

Despite calls from environmental groups for the strategic decommissioning of the Massachusetts’ gas system over the coming decades, the state’s for-profit gas utilities have been pushing to keep the gas network running indefinitely on a mix of biomethane and green hydrogen. While the utilities argue that this would allow them to save costs by making use of existing gas infrastructure, environmental groups have brought up a litany of concerns related to cost, safety, climate impacts, and the overall viability of this path.

A new report from members of the nonprofit organization Gas Transition Allies highlights another major issue in the plans of gas utilities — the large amount of electricity needed to produce enough green hydrogen to heat the state. According to this report, blending hydrogen into the state’s gas supply would require about 120% of all the offshore wind energy slated to come online by 2030. To meet all of the state’s gas heating needs entirely with green hydrogen, this would require nearly all offshore wind energy planned for 2050.

The report’s authors argue that this could jeopardize the decarbonization of the state’s electrical grid and would be a far less efficient way to eliminate heating emissions compared to relying on electric heat pumps.

This report comes as several other studies have cast doubt on the efficiency of using green hydrogen for home heating, despite the hopes of investor-owned gas companies.

There’s also a planning process that we’re in favor of which was put forward by Acadia Center, which is called RESPECT. And we think that that’s a very nice outline for how an integrated statewide or countrywide planning process should be put together. So that’s one of the takeaways — we need an integrated planning process.

To read the full article, click here.

Correcting the record on decarbonization

A RECENT COMMENTARY,  Decarbonization road map has some gaping holes by Arnold J. Wallenstein, argues that Massachusetts must scale back its efforts to decarbonize its energy system. Unfortunately, the piece relies upon incomplete assumptions while making glaring omissions about the viability of clean energy. It glosses over the health, climate, and economic burdens imposed by our current outdated energy system, and it ignores that the transition to clean energy is well underway both regionally and nationally.

The energy system in Massachusetts is heavily dependent on fossil fuels. Nearly 50 percent of our electricity is produced by fossil gas. Over 80 percent of our homes and businesses are heated by fossil fuels. And fossil fuels do not produce a reliable system. Whenever a winter storm or a hot summer day arrives, we all cringe in anticipation of whether the power will stay on. Fossil fuels are expensive, too. Electricity rates just increased by 64% percent  in some areas of the state. Other states, such as New Hampshire, saw increases as high as 112 percent. Volatile energy prices come baked into the cake with fossil fuels, as anyone purchasing heating oil or propane this winter knows from seeing prices double.

Additionally, fossil fuels cause poor indoor air quality, damaging the health of the most vulnerable among us – children and the elderly – particularly those in lower income communities and communities of color. That’s not even counting their contribution to catastrophic climate change. And we’re shipping billions of dollars out of state each year for the privilege of unreliability, volatile prices, health problems, and climate destruction.

The good news is that clean energy technologies are market ready, cost-effective, local, healthier, cheaper to operate, and more reliable. For these reasons, the movement towards a wholesale turnover in power generation and heating and consumption technologies is well underway in our region.

Fortunately, Gov. Maura Healey understands the importance of addressing our existential climate threat – for instance, rising oceans and storm damage are a serious concern for Massachusetts – and seizing the economic opportunities presented by localizing our energy production sector, particularly for moderate- and low- income households. In her inauguration speech, she committed at least 1 percent of the state budget to environmental and energy agencies, and she has now followed through with $534 million in her first budget. She promised to triple the budget for the Massachusetts Clean Energy Center and to create a Green Bank to foster investment in resilient infrastructure. She has talked about an investment in the climate economy similar to the $1 billion investment former governor Deval Patrick once made in the growing biotech industry. Former governor Charlie Baker sought to make a similar investment during his final year in office.

Healey also pledged to double offshore wind and solar targets, quadruple energy storage deployment, and put a million electric vehicles on the road by 2030. Importantly, Massachusetts’ neighbors are, in some cases, making more aggressive commitments, like Rhode Island’s mandate to have 100 percent renewables by 2033, or New Jersey’s brand-new commitment to 100 percent clean electricity by 2035. Wallenstein fails to make reference to these goals – including, most importantly, the governor’s urgency to tackle these issues. Recycling 10-year-old talking points to turn the clock back 10 years is not a vision for the future.

Across the country, renewables accounted for 22 percent of the total electricity generation in 2022 and are projected to rise to 24 percent in 2023. From Q3 2020 through Q2 of 2022, the US added 63.2 gigawatts of new wind and solar power generating capacity against only 10.4 gigawatts for gas (and none for coal). And with the passage of the Inflation Reduction Act, tax incentives are now in place to drastically increase the pace of renewable energy adoption. In fact, it is now less expensive to operate solar and wind electricity generation than most fossil fuels.

This makes sense as wind and/or solar energy are already the cheapest power source for two-thirds of the people in the world, including the US (and New England), where solar is our cheapest power source. All grid-scale clean energy projects enter our power grid via a competitive bidding process, one in which clean energy generators are forced to increase their bid prices to keep fossil fuel operators competitive. There are no “undisclosed” costs. Once clean operators deliver their projects, they will supply electricity for fixed rates.

Wallenstein included numerous false statements about the Massachusetts 2050 Decarbonization Roadmap in his piece. While there are too many falsehoods to dissect each one in detail, one particularly egregious statement in his piece stood out: “Unbelievably, there is no cost analysis to be found in the 2050 Decarbonization Road Map.” In-depth cost analysis is actually one of the central pillars upon which the Roadmap was built. In fact, Section 5.6 of the Energy Pathways to Deep Decarbonization portion of the Roadmap is quite simply titled “Cost.”

The sophisticated modeling that is core to the Roadmap examined the costs of nine different paths, and specifically answers the question: “Under the most likely assumptions, what is the least-cost deployment of energy system technologies that achieves deep decarbonization?” The most cost-effective pathway shows that, by 2050, fossil fuel generation accounts for less than 1 percent of electricity supplied to Massachusetts while over 90 percent of building space and water heating utilize consumer and climate friendly electric heat pumps. Reading the Roadmap closely, for 0.25 percent of the state’s total annual economic output we can take the most cost-effective path to net zero emissions instead of just watching the world burn.

Massachusetts also has among the greatest offshore wind power potential of any state in the nation. According to the National Research Energy Laboratory, Massachusetts can produce 1,050 terawatt hours (TWh) per year of electricity. That far exceeds both Massachusetts’ current consumption of 56 TWh per year and the laboratory’s projection of future needs after widespread electrification of 140 TWh. The business case for embracing our most affordable and most plentiful local resources is fairly obvious.

Wallenstein’s piece also trotted out an old canard about how the sun doesn’t always shine or the wind doesn’t blow as an argument to hold on to our dirty fossil fuel system. However, his piece curiously ignores clean energy options that balance wind and solar, such as the increasing prevalence of battery storage. California increased its battery storage capacity from 0.25 gigawatts to 3.2 gigawatts from 2020 to 2022, and that new storage played a critical role in keeping the state’s power on during this past summer’s extreme heat waves. Massachusetts is seeing storage projects move forward: Eversource has installed a 25 megawatt battery in Provincetown, designed to improve power reliability for the Outer Cape.

Long-duration batteries are just around the corner. Somerville-based Form Energy is opening a factory space in West Virginia that in 2024 will start producing 100-hour, 500 megawatt batteries that rely on iron – the most abundant metal on earth. This doesn’t even touch on other options, like better coordinating our grid with clean energy from neighboring systems. There are clean energy answers for how to improve reliability that don’t require an endless reliance on climate-destroying fossil fuels.

And let’s be clear: our fossil fuel-based system is not exactly reliable. At the end of 2022, New England suffered a two-day cold snap that left hundreds of thousands without power, since dubbed “The Nightmare Before Christmas.” The cause of the outages was predominantly a failure of fossil fuel operators to fire on demand. New England’s own grid operator issues annual winter outage warnings and insists significant investment must be made to improve the reliability of its own system. At the most recent such proclamation, Rebecca Tepper, now Massachusetts’ secretary of energy and environmental affairs, said, We are overly dependent on natural gas. And the region is at risk any time that we have some kind of disruption on that system.”

Everyone involved agrees we will need to spend money to improve our energy system, particularly the grid that distributes that power. The question is where we are going to spend those citizen dollars. We can spend them on leveraging clean and affordable energy from local sources rather than subsidize expensive, unhealthy and not-too-reliable fossil fuel infrastructure. It seems like an easy choice.

It took decades to build our reliance on fossil fuels and it will take some time to wean off of it. Fully modernizing our system with clean electricity and converting our transportation and building heating/cooling systems to clean energy will not happen overnight. Eventually existing fossil fuel companies will need to find new ways to earn revenue. We invite them to join the momentum heading in that direction. Massachusetts’ most important goal now is to unite towards modernizing its energy system to benefit all the people of the state, not cling on to an increasingly outdated system that no longer can meet the needs of the public.

 

Joe Curtatone is the president of the Northeast Clean Energy Council, Daniel Sosland is president of Acadia Center, and Larry Chretien is executive director of the Green Energy Consumers Alliance. To read this article in Commonwealth Magazine, click here.

Heat Pump Challenges

One of the largest sources of greenhouse gas emissions in the US comes from heating buildings. The Biden administration is trying to change that by promoting efficient electric heat pumps. But as the Allegheny Front’s Reid Frazier reports, getting Americans to switch to heat pumps won’t be easy.

FRAZIER: When it comes to carbon dioxide pollution, the main cause of climate change. Heat pumps have two advantages over fossil fuels like natural gas, propane and heating oil. One is they use electricity, so it’s possible to run them on zero carbon sources like wind, solar and nuclear. The other is they’re very efficient. Amy Boyd is with the Acadia Center in Boston, which helps northeastern states meet climate targets. She says heat pumps work so well because they’re not generating heat like a furnace or stove. Instead, they rely on a clever piece of technology called a heat exchanger.

BOYD: The way that heat pumps work is they move heat. And so even if it seems cold to your eye, if it’s any warmer than the vacuum of space, then there is heat out there to be moved.

FRAZIER: Because it’s only moving heat around, not creating it. Heat pumps are up to four times more efficient than a standard furnace. In the summer, they can reverse themselves, doubling as air conditioners. Right now, about 10% of homes in the U.S. use heat pumps. That number will have to go up if the country is going to meet its climate goals.

BOYD: Eliminating the greenhouse gas emissions that are coming from our heat, particularly in the Northeast, is one of the biggest things that an individual consumer can do to fight climate change.

You can listen to the full exchange or read the entire transcript here.

The Nightmare Before Christmas

Have you looked at your electric bill lately? If you live in New England, your rates for this winter are likely to be higher than ever. In the past, Acadia Center has highlighted that this spike in prices is very likely due to our grid’s overreliance on fossil fuels like natural gas. And this week, there’s a report from Sierra Club and Strategen that confirms gas to be the culprit. What’s more, it shows that over the long term, the most effective way to protect customers from price spikes (and the climate and health damaging pollution fossil fuels create) is to transition New England’s generation to clean energy resources.

We have also seen a lot of recent information that pokes holes in the assumption that fossil fuels are more reliable than clean energy in the winter. One such example comes from Christmas Eve, 2022. As you may recall, our region was dealing with an arctic blast (itself an increasingly common phenomenon caused by climate change). Although the grid as a whole fared pretty well (the lights stayed on!), fossil fuel plants appear to have fared alarmingly poorly. And it’s not just New England – PJM, the power grid that runs from North Carolina to Chicago saw fossil fuel-fired plants fail to perform while wind provided three times as much power as planned.

In New England, the electric grid is managed by ISO-New England (ISO-NE), which operates under a mandate to maintain reliable electric service in the six state region. On a ‘normal’ winter day, the real time energy market (which you can follow on the ISO to Go app) shows prices under $100/MWh. On December 24th, though, at the peak hour, the real time energy prices in the ISO-NE energy market spiked to over $2,800/MWh, a shocking sign that things weren’t normal. When a number of generators (who we now know to be fossil fuel-fired) that had committed to run instead no-showed, ISO-NE instituted some of its emergency procedures. Stopping short of asking consumers to voluntarily conserve energy, ISO-NE ordered all of the units that were capable of coming online quickly enough to meet the peak energy demand between 4 and 6 PM, to start running. They did, there was enough energy, and, most importantly, the power stayed on. The plants who “no-showed” have to pay penalties of around $39M, all of which goes to the plants who came to the rescue under ISO-NE’s Pay for Performance rules.

So what happened? And what can we learn from it for future winter storms? ISO-NE released a report on the Christmas Eve event that found that around 2,275 MW of generating capacity (over 1/8 of the peak load that day) that was expected to be available for the peak hour became unavailable for a number of reasons. The data released by ISO-NE so far show that at least 90% of these facilities burned fossil fuels – 33% were dual fuel generators (oil & gas); 29% residual fuel oil; 15% natural gas-only generators; and 13% were distillate fuel oil generators. ISO-NE reports that 65% of these reductions were due to mechanical problems like stuck valves and fuel pump failures – these mechanical issues could be coincidental, but the magnitude raises some questions about whether those facilities are prepared for the cold winter temperatures. Regardless of the reason these facilities weren’t online when needed, it drives a hole in ISO-NE’s conclusion that fossil fuel plants are always more reliable and need to be maintained through the rise of renewable energy.

In the past, ISO-NE’s warnings about potential issues in the winter called for needing more gas. Acadia Center has pointed out the fallacy of this argument – New England’s overreliance on gas for both the majority of our electricity generation and heating of buildings creates a risk of blackouts when there is not enough gas to go around or when international instability spikes prices. The solution to that is not doubling down on gas – it’s diversifying our resource mix, making better use of flexible demand and demand response, and adding more renewable energy, where the fuel is free.

In Acadia Center’s estimation, four reforms could help avoid crises like this in the future:

  • Diversify the resources and bulk up demand response programs: As Acadia Center and its partners outlined in our Winter Reliability white paper, residential, commercial and industrial, and energy efficiency programs provide controllable demand that can help keep the grid reliable in real time. A balanced portfolio of complementary renewables like wind and solar can displace fossil fuels, and adding battery storage in stacked form, can allow us to move way from our gas overreliance now, even while we wait for long-duration storage that can outlast a winter storm on one battery.
  • Coordinate to build the transmission needed to bring renewables: although the New England states have individually made commitments to decarbonizing their power and entering into procurements of renewables, the lack of a coordinated regional approach to building transmission is keeping these large scale hydro, wind, and offshore wind projects from coming online. Hopefully 2023 will bring more regional coordination (and, dare we wish, help from ISO-NE?) to work with affected communities to build the necessary transmission.
  • Make gas plants buy on firm contracts, or at least reflect their capacity rating to show they’re taking the risk of no fuel: in the past, ISO-NE has offered to pay certain generators to enter into firm contracts (which get first priority for the gas), rather than relying on the spot market. But such contracts are expensive, and many generators (particularly dual fuel) opt to only use gas when it’s most affordable. But, as Christmas Eve showed, such business decisions can affect the whole grid. The capacity rating for renewable energy is often lowered to reflect the intermittent nature – the risks of fossil fuels should be reflected, too.
  • Reform ISO-NE governance so consumers have more of a say in decisions that impact our air, our economy, and our family budgets: for the Northeast to achieve its climate goals and capture the many benefits of clean energy resources, the rules and priorities that govern the regional electricity system must change. Through analysis, public education, and coalition engagement like with our partners in Fix the Grid, Acadia Center is driving efforts to give consumers a voice within ISO-NE.

Acadia Center is working with our coalition partners to promote these reforms at ISO-NE and NEPOOL (the stakeholder body for ISO-NE) and in public engagement and bringing to consumers information about ISO-NE and how it impacts your life and wallet.

‘Green Hydrogen’ Would Squander Renewable Energy Resources in Massachusetts

Efforts by natural gas utilities in Massachusetts to replace 20 percent of their fossil gas supply with “green hydrogen” derived from renewable electricity would consume more clean energy than would be produced by the state’s ambitious offshore wind energy buildout in the coming years while yielding few climate benefits, according to a report published on Monday.

Using heat pumps powered by renewable energy to heat residential and commercial spaces would be a more effective use of limited clean energy resources, the report, from Gas Transition Allies, a coalition of clean energy advocacy organizations in the Bay State, concluded.

“If you were to use green hydrogen for heating, you would be using roughly three and a half times as much electricity as if you were providing the same amount of heat to buildings with heat pumps,” said Gordon Richardson, a technology and business consultant and co-author of the report.

Hydrogen, a clean fuel that does not release carbon dioxide when burned, is produced by splitting water into hydrogen and oxygen, an energy-intensive process. If the electricity used for this process comes from renewable energy sources such as wind or solar, the hydrogen it produces is considered “green.”

The report doesn’t compare the cost of green hydrogen to heat pumps. Ben Butterworth, a director with the Acadia Center, a clean energy advocacy organization based in Rockport, Maine, said costs associated with the additional renewable energy needed for green hydrogen would be tremendous.

“It’s expensive to build this renewable energy capacity at scale already, and if we’re using or requiring 3.6 times as much electricity, that really underscores the cost difference between the two,” Butterworth said.

Butterworth, who reviewed an early draft of the Gas Transition Allies report, said he sees building electrification paired with energy efficiency measures as being the “lynchpin strategy” for decarbonizing buildings in Massachusetts.

“We know this, and we have to focus on that and not be distracted by putting green hydrogen into the gas distribution system because it’s just an inferior option all around,” he said.

A utility plan to replace gas with climate-friendly fuels is deeply flawed, according to new report

Using so-called green hydrogen to heat homes and other buildings would require so much electricity to simply manufacture the gas that it would consume all the wind power Massachusetts expects to be generating by the end of the decade, a new report concludes.

The report’s authors said that would derail the state’s plans to rely on clean electricity as the main fuel driving a carbon-free economy and should cast doubt on any proposal to lean on green hydrogen as a fuel for home heat.

Hydrogen does not produce greenhouse gas emissions when burned, making it an attractive fuel of the future. But traditional manufacturing has commonly required large amounts of natural gas. Green hydrogen, on the other hand, is produced without fossil fuel, relying instead on water and carbon-free electricity.

But clean energy advocates disagree, noting that the state’s own climate plan calls for a majority of homes to use electric heat pumps for heating and cooling, which are far more efficient than gas.

“As the report highlights, pathways that rely on using local renewable electricity to generate hydrogen for heating buildings are going to require more than three times as much renewable electricity,” said Ben Butterworth, director of climate, energy and equity analysis for the advocacy group Acadia Center.

Moreover, he said, the utilities’ plans also call for a large amount of renewable natural gas, also known as biomethane, which he said is “extremely limited in quantity, expensive and better used in hard-to-electrify sectors of the economy.”

You can find the complete article here.

Massachusetts energy efficiency programs should shift focus to emissions, critics say

Massachusetts lawmakers and advocates are looking at ways to overhaul the state’s energy efficiency collaborative Mass Save, arguing that the longstanding, utility-run program isn’t up to tackling the present-day climate crisis.

A bill (SD 2346) filed in the state Senate calls for a wholesale reorganization of the program and the creation of a new leadership structure. At the same time, activists are pushing for an expanded mission that would focus more on accelerating the transition from fossil fuels by supporting electrification, battery storage and other clean energy investments.

Advocates would also like to see changes to the program’s funding. Currently, Mass Save is funded through a combination of sources, including a small fee on utility bills and proceeds from the Regional Greenhouse Gas Initiative. More — and more stable — sources of funding are needed for the program to make as much impact as necessary, advocates said.

“I have a dream that we can use tax dollars to fund climate as if it’s actually a priority of the state, not just one they claim is a priority,” said Amy Boyd, vice energy of clean energy and climate policy at the nonprofit Acadia Center.

You can read the rest of the article here.

Exciting Maine Offshore Wind Roadmap Released Today by Governor Mills’ Energy Office

Maine has announced  a plan to harness offshore wind is doubly exciting and promising, both for addressing climate change and taking advantage of an economic opportunity that only comes along once in a generation. The Roadmap is a result of the dedicated efforts of Maine’s Governor, the Maine Climate Council, the State Legislature, and many others. Offshore wind could become one of Maine’s leading industries, providing jobs to laborers, engineers, electricians, constructions experts and a host of other jobs yet to be developed. Maine is a world leader in developing offshore floating wind turbines, and the future is bright with promise.

But Maine’s Offshore Wind Map plan is not a gold rush toward wind power. Instead, it is designed to protect Maine’s existing fisheries and wildlife habitats. The roadmap won’t be accomplished behind closed doors, but out in the open as part of an effort to include all stakeholders. All of Maine’s people must rise on the tide of economic and environmental benefits: rural communities, labor, indigenous peoples, and those who are economically disadvantaged.

The Roadmap sets a specific timeline from 2023 and beyond to accomplish various tasks, from a procurement project to fulfill a percentage of Maine’s electricity needs to permitting and leasing. All to further and complete Maine’s offshore wind goals.

Acadia Center is dedicated to using its expertise to promote clean, efficient energy now and in the future, and we welcome the fantastic commitment Maine has made to climate matters generally, to promoting Maine’s abundant offshore wind resource, and for providing a Roadmap to achieving the goal of harnessing offshore wind.

Why a ‘temporary’ Portsmouth LNG site is expected to remain for another decade

PORTSMOUTH – Ever since a faulty valve in Weymouth, Massachusetts, caused Enbridge’s Algonquin natural gas pipeline to fail in January 2019 and threw Newport County residents into a heating crisis for a week, Portsmouth Town Councilor Keith Hamilton has been advocating for new natural gas infrastructure on Aquidneck Island.

Specifically, he wants a second pipeline connected to the island, both to serve as a redundancy for the existing line and to complete a loop system that would connect the island to the larger regional transmission network from two directions and address the potentially catastrophic issue of low pressure in the lines.

As Rhode Island begins the statewide process of working towards ambitious emissions reduction goals set forth in the 2021 Act on Climate (10% below 1990 levels by 2020; 45% below 1990 levels by 2030; 80% below 1990 levels by 2040; net-zero emissions by 2050) environmental and clean energy advocates such as the Acadia Center are calling for a complete moratorium on natural gas infrastructure, including a ban on residential and commercial hook-ups in new developments.

Hank Webster, senior policy advocate and Rhode Island director of the environmental policy non-profit Acadia Center, comes to a very different conclusion than Hamilton.

In a text message to the Daily News, Webster said, “We don’t think the (Old Mill Lane LNG storage) facility is necessary if (Rhode Island Energy) instead pursued investing in improvements that actually benefitted their customers, like weatherization, cleaner, safer appliances, and demand response programs. Proposals to build new infrastructure only benefit the companies building the project and the companies selling the gas.”

He continued, “Let’s not forget that the federal and state government found that the January 2019 outage only occurred because of an extraordinary coincidence of management failures and lack of attention to existing infrastructure like an upstream valve and backup power module. Without any one of those, the outage would not have occurred, and we would not be seeing these proposals for new long-lived infrastructure.”

Despite the state’s continued reliance on natural gas and local concern in both Middletown and Portsmouth about the siting of an industrial LNG storage facility in a residential neighborhood, there seems to be limited appetite at the state level for an infrastructure project of the magnitude Hamilton has in mind. This is not least because pushing for a second pipeline to the island would necessitate a huge political battle at a time when Acadia Center and other Act on Climate advocates in the state legislature and in the ranks of Rhode Island’s registered lobbyists are beginning to actively fight for a moratorium on natural gas infrastructure and eventually full abandonment of natural gas as an energy source.

Despite mounting public backlash from neighbors who have seen the facility in their backyards expand its capacity from one to five portable LNG tanks over the course of the past four winters, public documents submitted by Rhode Island Energy to the PUC and the state’s Energy Facility Siting Board indicate this “temporary situation” is likely to be in place for at least another decade to come, at an estimated cost of $31 million as opposed to $147 million for the construction of a second pipeline extending from the main line in southern Massachusetts. Webster and Acadia Center’s preferred solution, weatherization and electrification, is the most expensive option at $190 million.