I preface my comments on Xcel’s Integrated Resource Plan by echoing that this process is the one which Xcel Energy recently identified as “where we will be responsible for our progress”. On Thursday, January 21st, Xcel’s chief lobbyist Rick Evans spoke to State Lawmakers on the proposed 100% Clean Energy Standard on the basis that "legal mandates" were not as efficient and effective of a way toward meeting carbon free goals as “the resource planning process conducted by the MN Public Utilities Commission (PUC)”. Here is the exact quote which goes from 1:05:20 to 1:08:05 in this video listed online at: https://www.youtube.com/watch?v=tMt3gsGyK6A
“… In Minnesota we are very fortunate to have an active, transparent and open process of resource planning decisions that has been in place for many years and will continue going forward. It is conducted by the Public Utilities Commission. This is the process that is responsible for the progress we have made so far and will be responsible for the progress we make in the future….
…In our view this is the best, most efficient and most effective way to continue on this path which is gradually approaching consensus that we need to reduce carbon on our system. It recognizes the science and it recognizes the economics and gives the PUC the ability to examine those and move forward in an efficient and effective way.
We believe that legal mandates to achieve goals which come before we really understand the science and economics of the future may do more to inhibit some planning than advance it, and we encourage the committee to look in that direction.
I will just one word to say about the Renewable Energy Standard contained in this bill.
As Mr. Noble reported this morning there are 5 or 6 technologies, and in the future, there may be 7 or 8 or 9 technologies that could get us to a carbon free future.
The focus should be on carbon reduction. It is very unlikely that today we understand what the appropriate level and appropriate funding of adding resources like renewable energy and I would encourage the committee to focus on carbon reduction.”
NEW GAS PLANT IN APPARENT CONTRADICTION WITH XCEL’S STATED CARBON REDUCTION GOALS
The main problem with Evans’ line of reasoning is that Xcel is adding new fossil gas (commonly known as "natural" gas) generation in that same PUC process in which he claimed to be interested in meeting carbon reduction goals. As many are aware, Xcel’s 15-year energy plan (formally known as their Integrated Resource Plan or IRP) involves building a new Combined Cycle 835 MW gas-powered generator at the site of their soon-to-be-retired Sherco coal units near Becker Minnesota (henceforth referred to as the Sherco Gas Plant). The price tag for the new Sherco Gas is estimated to be around $1 Billion when the new pipeline that will be needed to supply Sherco with gas is added in.
The proposed Sherco gas plant is slated to begin operation in 2027 according to Page 25 of Xcel’s June 30th Supplemental Filing. It would have a 30-50 years proposed lifespan. This time period would extend well beyond Minnesota's existing 2050 carbon neutral goal. It is notably further beyond the 2040 goal the Walz Administration which they might have proposed at the same legislative hearing and is captured on this MPR Article: https://www.mprnews.org/story/2021/01/24/walz-calls-for-100-percent-carbonfree-electricity-by-2040 If the Sherco facility requires more than 23 years of operation to recover costs, then Xcel can’t reach its own goal of carbon neutrality 2050.
By committing to that 2050 target (in contrast to 2040), Xcel can be commended for is doing perhaps the bare minimum of what the science requires if only because the vast majority of fellow other investor-owned utilities around the nation do not make any such commitments on having carbon neutral goals.
In addition to the above stated contradiction between adding a new gas plant and while making carbon free goals, the statement from the Xcel lobbyist at the legislative hearing was essentially a clear case of pick-and-choose as to when the company wants to bear responsibility in the venue of the PUC. When Xcel didn't get its way at the PUC at the conclusion of the previous resource planning process in the fall of 2016 by not getting a certificate of need to build the Sherco gas plant rubber stamped by the PUC, the company helped draft a bill which pre-approved the Sherco gas plant. In February of 2017, the Minnesota Legislature passed this regulatory work-around (listed as SF85/HF113) into law, which allows Xcel to build the Sherco gas plant without having to go through the Certificate of Need process at the PUC.
But in taking the Xcel Lobbyist at his words, I offer the following comment as an opportunity to send a strong message to Xcel in this arena where they asked to be accountable toward. I have personally witnessed Xcel Energy formally oppose a Renewable Energy Ballot Measure which faced Colorado voters in 2004, known as Initiative 37. https://www.renewableenergyworld.com/baseload/colorado-voters-pass-renewable-energy-standard-17736/#gref I spoke with someone from Xcel who was tabling at a jobs fair who said the company opposed the standard based on how wind power is an intermittent energy source. But after voters passed Initiative 37, Xcel figured out the technical challenges and was able to meet the Renewable Energy targets apparently years ahead of schedule.
Fast forward 10 years into the future in 2014, and something interesting happens. That summer Xcel hosted an event on the front Plaza of their Nicollet Mall office in downtown Minneapolis specifically celebrating their 10 years as the nation’s #1 utility for wind energy. I noticed Xcel taking credit for the good things that happened as the result of policies their upper management had initially opposed.
Likewise, if the Public Utilities Commission holds Xcel accountable to deploying some combination renewables + storage as a viable alternative to the proposed Sherco gas plant, I have hope that Xcel in being responsible when required, will similarly be able to figure out a way forward. If that desirable scenario were to happen, then I predict that
Xcel will eventually take credit for delivering our clean energy future in a red box as they have done in many TV commercials.
REFERENCE TO EXISTING STATE STATUTES
Upon my understanding that the Commission is quasi-judicial, I must preface that this case before us is indeed rooted in existing Minnesota State Statute as it is and not just my personal positions on what a plausible new statute should be. Xcel Energy is obligated by Minnesota statute to consider renewable alternatives to the proposed Sherco combined cycle natural gas plant. But the company arguably has not done so in this IRP. Even if it were not in statute it would still be particularly important to consider because of the still falling of prices and growing technical feasibility of wind, solar, and energy storage.
According Minnesota Statutes section 216B.2422 Subdivision 4, “The commission shall not approve a new or refurbished nonrenewable energy facility in an integrated resource plan or a certificate of need, pursuant to section 216B.243, nor shall the commission allow rate recovery pursuant to section 216B.16 for such a nonrenewable energy facility, unless the utility has demonstrated that a renewable energy facility is not in the public interest.
Furthermore, Subdivision 7 of 216B.2422 states:
Energy storage systems assessment (a) Each public utility required to file a resource plan under subdivision 2 must include in the filing an assessment of energy storage systems that analyzes how the deployment of energy storage systems contributes to:
(1) meeting identified generation and capacity needs; and
(2) evaluating ancillary services.
(b) The assessment must employ appropriate modeling methods to enable the analysis required in paragraph (a).
Disappointingly, all the modeled scenarios for our energy future which Xcel considers in the IRP includes the proposed Sherco gas plant. In an exchange during Xcel’s May 20th, 2019 Stakeholder Engagement meeting on their IRP, captured on Twitter
https://twitter.com/MplsEnergyOpts/status/1130939661701013505/photo/1
Xcel performed quite a sleight-of-hand with their modeling to make sure that all scenarios discussed in the IRP include the proposed Sherco gas plant as a generation resource. Xcel presents 15 baseload scenarios, some High Distributed Solar and High Electrification sensitivity studies cases, a Hybrid Renewables + Storage sensitivity study, and a Sherco size sensitivities study. But none of these scenarios considered the feasibility of replacing Sherco with some combination of renewables plus storage, added energy efficiency (EE), and increased demand response (DR).
So, in sum, a billion-dollar facility which is not even built yet is a central assumption which the rest of their plan is crafted around.
THE LESSON OF THE MANKATO ENERGY CENTER DOCKET
We have a lesson from very recent history as to why it is unwise and unsustainable for Xcel to craft an entire IRP to revolve around such a central assumption. We just witnessed Xcel having to craft and release a new version of its IRP for 2020 because the 2019 version of their IRP had their sought-after acquisition of the Mankato Energy Center (MEC) Gas Plant as a given, with no alternatives. Xcel crafted the entire 2019 version of the IRP around an assumption the Commission would be a compliant rubber stamp for their petition to acquire Mankato Energy Center (Docket 18-702). But because it was not approved, the company had to craft a new version of the IRP, delaying this process for an entire year.
There are additional lessons to be learned from the hearings on that above-mentioned docket. Members of the Commission stated a concern about gas plants becoming stranded assets (which I will elaborate upon later). The Commission used that concern as an important part of their reasoning to unanimously deny the purchase of MEC by Xcel as a regulated utility.
As Commissioner Schuerger stated in his closing remarks:
I do think the issue around stranded costs is a really important question…there are important questions in there for consumers around those future costs…2054 is a long way out, the world is changing rapidly [PUC Schuerger]
We have a good case before us as to why the Commission should apply the same skepticism toward any proposal Xcel has to get cost recovery on Sherco as the Commission did on Xcel’s proposal to get cost recovery on the MEC. While the MEC was already built, the proposed Sherco plant that won’t even be operational until 2027 at the earliest according to the preferred plan and will likely have to operate for at least 30 years to meet cost recovery without becoming stranded assets to some degree.
Perhaps the ability to get cost recovery was Xcel’s main interest in acquiring MEC, because the company sold it just a few short months after not being able to get cost recovery on it. That begs a question. Would Xcel be so insistent upon this Sherco gas plant, to the degree of not even studying any alternatives, if they were not able to get cost recovery on it? Even though the Certificate of need to build it was granted by the regulatory workaround at the State Capitol PUC approval will still be needed for Xcel to get cost recovery on the Sherco gas plant. Because it is a proposal that requires cost recovery from ratepayers it deserves to be rigorously evaluated by the Commission in an IRP proceedings.
Of important note, the Certificate of Need the State Legislature granted in 2017 for the proposed Sherco plant does not cover the gas pipeline that will be needed for the new Sherco plant to be operational. The 2017 statute does not allow Xcel to bypass the Certificate of Need process for the new pipeline. Because of Minnesota Statutes section 216B.2422 Subdivisions 4 and 7, the PUC still has a role in requiring Xcel to consider renewable alternatives to building Sherco.
CONCERNS FOR CLIMATE AND ENVIRONMENTAL JUSTICE ECHOED AT PUBLIC HEARING
The issue of which set of energy decision makers has the privilege of deciding which set of energy technologies get deployed has long been of interest to me.
I have organized a series of a few dozen Community Education events on our electric utility system based upon a shared excitement that we have some agency to chart the course of our energy future. But I have also attended many comparable events which other organizations took a lead role in.
Part of this interest included me personally attending 3 of the 5 in-person hearings on Xcel’s IRP back in October of 2019. I can attest that the proposed Sherco gas plant was the central overriding concern among those who showed up to speak, as what is likely for the comments received in recent months. Many of the remarks I heard at those hearings as well as information from a new website called “Energy We Can’t Afford” https://energywecantafford.org/ make the case that prolonging reliance on fossil gas would have a nearly as damaging of an impact on our climate as the coal it would be replacing and is not without environmental risk. Activists from this new Energy We Can’t Afford Coalition have made an impact by getting articles in neighborhood newspapers line the Longfellow Nokomis Messenger here: https://longfellownokomismessenger.com/stories/energy-we-cant-afford,1606
and the Park Bugle here https://www.parkbugle.org/do-you-want-fossil-free-electricity/
Although Hydraulic fracturing (aka fracking) to extract gas would not take place in Minnesota, it does harm human health and pollutes the air and contaminates groundwater with toxic chemicals that are considered secret and proprietary. In theory, it could be a safe practice. But drilling companies in the past have given gag orders against people near fracking wells speaking out in court on the health defects they have suffered through, in order to stop or at least delay the information from getting heard in court. One such story is documented here: https://stateimpact.npr.org/pennsylvania/2013/08/01/lifelong-gag-order-imposed-on-two-kids-in-fracking-case/
Air and water pollution do not know state boundaries though. By building new gas plants in Minnesota (Xcel is not the only utility proposing so), the health problems and other harms of fracking will be outsourced to communities near fossil gas extraction sites. It is likely to disproportionately harm people of color and residents in poverty. Specifically, black and indigenous people of color (BIPOC) and residents living in poverty are more vulnerable to the harms of outdoor air pollution, water contamination, and earthquake damage caused by fossil gas production and transport because fracked gas extraction sites are more likely to be permitted and constructed in their communities.
- Here are some figures for pollution exposure versus responsibility for caused pollution (labeled as production) among the US Population:
- Latino/ Latina - exposed to 63% more pollution than they produce
- Black Population - exposed to 56% more pollution than they produce
- White Population - exposed to 17% less pollution than they produce https://www.pnas.org/content/116/13/6001
Even if we get into the minutia where some degree of pollution is considered avoidable or acceptable, the environmental injustice of taking that too far makes it not worth locking in further long-term dependency on gas as a baseload level generation resource.
The Energy We Can’t Afford website also explains how fossil gas would have about the same net greenhouse gas impact as the coal it would replace due to expected methane leakage. Fossil gas only emits about 50% of the greenhouse gasses as coal when burned to generating electricity. But that other 50% is mostly reached due to significant amounts of unburned methane unintentionally leaked into the atmosphere during the process of extracting, transporting (e,g. pipelines), and storing fossil gas. To cite a specific figure, a Sierra Club analysis shows that the proposed plant would emit 3.6 million metric tons of carbon annually (including emissions from gas extraction and transportation).
https://energywecantafford.org/wp-content/uploads/2020/10/Gas-Brief_revisions4.pdf
For comparison, that is as much as putting 777,757 cars on the road, or as much as
building almost another full-sized coal plant. Many local governments, Including the City of Minneapolis in December of 2019, have issued a declaration of Climate Emergency. We cannot be building new fossil fuel infrastructure in a climate emergency. That message was by far the largest motivator among the public to show up to speak at the October 2019 hearings as the Administrative Law Judge probably noted.
ENERGY AFFORDABILITY AND ENVIRONMENTAL CONCERN UNITE AGAINST STRANDED ASSETS
In addition, I recall hearing many speakers calling for climate justice coupling their message with additional concerns about the rate impact a new Sherco gas plant would have on our monthly electric bills. Witnessing affordability and environment being on the same team was a fascinating reversal of the dynamics I saw during Xcel’s 2014 rate case hearing when the two concerns were in different camps among speakers who showed up. One set of speakers organized by the Sierra Club another who were on fixed income. Future executive and now NSP President Chris Clark was Xcel’s spokesperson at this hearing and may remember what it was like. He explained that it was still worth making efforts to save energy to community members who were upset Xcel was requesting higher rates to make up for their lowered revenue from load loss.
But now we see bill affordability and climate impact on the same team for a good reason. The Minnesota Solar Pathways project report finds the state could achieve a goal of ten percent solar by 2030, and 70 percent by 2050 at a cost that is comparable with fossil gas generation costs. http://mnsolarpathways.org/ 2018’s McKnight Foundation “Smarter Grid” study by GridLab showed that distributed renewables and efficiency together could save $1,200 per Minnesota household per year. https://www.mcknight.org/programs/midwest-climate-energy/mn-smarter-grid/ Why did Xcel not consider this study and instead consult E3 for their IRP to do studies that were much more limited in scope? Analysis done by Sierra Club shows customers would save $360 million if clean energy was built instead.
https://energywecantafford.org/wp-content/uploads/2020/10/Gas-Brief_revisions4.pdf
ACCELERATED ENERGY EFFICIENCY
I must state recognition that the ultimate measure of affordability is having lower bills rather than only considering lower rates than otherwise could have been. Lower bills though lowering avoidable overconsumption is where energy efficiency comes in. Xcel’s IRP is notably better than past utility plans in considering energy efficiency as a resource. From a system-wide perspective, energy efficiency is essentially a necessary prerequisite for approaching 100% renewables, so we could avoid the extra expenses associated with overbuilding capacity. Xcel doubled the minimum requirement for investment in traditional low-income energy efficiency programs in this IRP.
Xcel could improve its plan by supporting nontraditional equitable financing models for energy efficiency that would make it drastically easier for a far greater number of customers to save energy, such as Inclusive Financing under the Pay As You Save® (PAYS®) model.
I have not seen Xcel show any indication of considering Inclusive Financing, or any commitment to making the billing software updates needed to accommodate on bill repayment despite several years of being in discussion about it in the Minneapolis Clean Energy Partnership spaces. We will see how Xcel Responds to an effort to require them to offer PAYS® Inclusive Financing in Colorado https://www.coloradopays.org/ .
I am aware movement on Inclusive Financing is taking place on a separate docket before the Commission involving Centerpoint and the City of Minneapolis.
Regardless of the minutiae of the specific model used, we need exponential progress on saved energy rather than the incremental progress we have seen in order to meet the clean energy transition.
Xcel did receive a question on energy efficiency in at their May 20th, 2019 IRP Stakeholder Engagement Meeting captured on Twitter:
https://twitter.com/MplsEnergyOpts/status/1130939788322844672/photo/1
Whether this applies to the current IRP before us, we can’t afford to have a duplicitousness where upper utility management privately and internally opposes ways to exponentially increase energy efficiency efforts out of fear of getting lower revenue due to load loss while publicly pretending to oppose the same efforts for a different trumped-up reason in order to avoid a public relations embarrassment that would undermine their public image as a green utility.
Accomplishing any system wide objective for saved energy would include Xcel becoming stronger at doing culturally competent community outreach on energy efficiency to lower income and communities of color.
THE SHERCO GAS PLANT IS HIGHLY PROBABLE FOR STRANDED ASSETS
I do not want to detract from the central affordability topic of the Integrated Resource Plan, which is how a new Sherco gas plant would affect rates. It has to do with what is perhaps the most dreaded two-word phrase in the utility industry: stranded assets.
This Sherco gas plant, if built, could get shut down in the early 2030’s after only a few years of operation due to the ever-decreasing cost of renewables plus energy storage. But under this decades old regulatory compact we still have, customers will still be considered legally on the hook to pay off its construction costs for years to come, even if we do not need the infrastructure anymore! The above consideration is basically a moot point because burning more fossil fuels than carbon neutrality would allow must stop well before the end of the Sherco gas plants’ expected 30 to 50-year lifespan.
For decades, we have seen various vested interests play a strategy of divide-and-conquer by trying to pit advocates for environmental sustainability and advocates voicing affordability for those in immediate need off against each other. Now we have a case where affordability and climate team up with each other facing off against claims from Xcel or elsewhere that this new Sherco gas plant is needed for energy reliability.
In trying to justify the Sherco gas plant, Xcel Energy brings up a legit energy reliability concern in needing to have firm dispatchable resources. But Xcel could easily run existing gas plants for a few hours to provide power during polar vortex blasts of arctic cold weather.
To the extent that the old saying is true about fossil gas (aka ‘natural’ gas) being “a bridge fuel” to full implementation of renewable power, Xcel could easily consider extending the life of existing gas resources instead of building Sherco. There are 918 Megawatts of Combined Cycle gas capacity due for retirement by 2034, either by decommissioning or by non-renewal of Power Purchase Agreements. Extending the lifetimes of these plants would be a better way to give Xcel the peak load flexibility it needs during the clean energy transition. Building a new Sherco gas plant on the other hand would at worst commit Minnesota to decades of fossil fuel dependency and at best have a strong likelihood that ratepayers would have to bear the brunt stranded assets.
There is abundant and compelling indication that Xcel’s proposed Sherco gas plant has a high probability of becoming a stranded asset. A new report from the Rocky Mountain Institute gives a 90% probability that a new gas plant would become a stranded asset.
Stranded assets in this case means that the technological feasibility as well as current and projected costs of renewable energy generation, energy storage, and demand side management (DSM) can feasibly eliminate the need for major new gas-powered generation infrastructure. Indeed, the 2020 NREL ATB database, which Xcel uses in their modeling, predicts that the cost of energy from gas will be twice that from solar and 60% higher than that from wind by 2034.
https://atb.nrel.gov/electricity/2019/
Xcel itself says in their 2017 Colorado Energy Plan Fact Sheet that “We are not building any new natural gas generation, reducing the risk of stranded costs”. Why wouldn’t this also apply in Minnesota?
Despite Xcel’s own assertion that “technological improvements will continue to drive the costs of renewables and storage down” [IPR pg 5], Xcel has not sufficiently explored non-fossil fuel options to Sherco. The alternatives for Sherco as a resource are at the very least rapidly maturing and are expected to be economically viable within a decade if not sooner.
Of interest to the founding purpose of the Public Utilities Commission, aside from our environment, the obligation Xcel customers have to provide cost recovery on stranded assets makes Xcel’s Sherco proposal very risky with regard to protecting customers. This is an also important social justice issue since it would disproportionately increase the energy burden of financially disadvantaged communities.
Again, this line of reasoning was a key consideration in the Commission’s decision to deny the Mankato Energy Center acquisition. It would make sense for the Commission to apply that same skepticism to the proposed Sherco gas plant, which won’t even begin operation until 2027 if built.
XCEL NOT CONSIDERING ALTERNATIVES TO SHERCO GAS
I remember hearing about Xcel crafting its 2020-2034 Energy Plan as far back as Mid-2018 when the Sierra Club started hosting community events to mobilize involvement in the process.
After close to 3 years, and with no less than 4 delays in the comment deadline, the company has had ample time to do fair and transparent studies that compare different scenarios for our energy future that does not include this new Sherco Gas Plant.
Despite having had this extra year to study questions such as:
- Can energy requirements be readily met without Sherco?
- Can replacement of gas energy capacity by wind and solar be cost effective?
- Can grid storage help meet power and reliability requirements?
…The company has been reluctant to demonstrate whether some combination of renewables, storage, and demand side -management can be used to replace the proposed Sherco gas plant. Currently, the costs of wind, solar, and storage batteries are either low or continuing to go down. Normally a competitive business would look ahead to new renewable technologies that are rapidly maturing in recent years and continuing to drop in price, rather than backward to old ones with increasing prices.
But monopoly electric utilities are not like any other competitive business who would have an incentive to switch cost curves in this regard. That is where the MN PUC comes in.
Not only is Xcel’s Sherco proposal insufficiently justified in this IRP as required by Minnesota statute. It is also contrary to the PUC order of November 19, 2019 which required “Consideration of storage technology combined with generators powered by renewable sources of energy.” The clear intent of the directive was to determine whether or not some combination of renewables plus storage can be used to replace fossil fuel generation.
Instead of fulfilling the intent of that order, Xcel included the proposed Sherco gas plant in the modeled scenarios that included energy storage. Instead of replacing gas generation with renewables plus storage Xcel replaced renewable generation with storage.
At Xcel’s May 20th, 2019 Stakeholder Engagement Meeting on their IRP, they received a question referring to a similar earlier PUC order and gave no real answer with the exchange captured on twitter:
https://twitter.com/MplsEnergyOpts/status/1130936497853652992/photo/1
Unsurprisingly, there are no apparent plans to include energy storage in the current IRP. Meanwhile other utilities in the US are planning more than 16,000 MW of new energy storage by 2034.
In fact, Xcel Energy itself is already adding 275 MW of storage projects in Colorado, another one of their service areas through a different subsidiary. Xcel would best be served taking a leadership in the implementation of these modernization technologies, as opposed to signaling that they would be a reluctant follower.
We need Xcel to speed up this transition by making a commitment to large scale storage in this resource plan. Xcel would have to begin implementing storage anyway in order to meet their stated goals in this IRP that 2600 MW of ‘firm peaking’ resources be implemented by 2034.
Xcel’s IRP is admittingly agnostic on committing to any specific technologies needed to meet 2600 MW of firm peaking. For the purposes of the modeling in the 2020-2034 IRP these resources are included as Combined Cycle gas generation. For practical purposes, the actual addition of 2600 MW of Combined Cycle gas after 2030 would make it impossible for Xcel to achieve its admitted greenhouse gas reduction goals.
Therefore, energy storage along with Demand Side Management will be crucial for meeting this holy grail of carbon-free firm peaking resources. Xcel should thereby state in this IRP an anticipation of using renewables to implement this firm peaking goal, because the “wait and see” by 2030 approach is unsustainable.
An approach of deploying strategically sized and sited new renewable power that makes best use of existing infrastructure and with the assistance of Demand Response and energy storage would be an ideal path. Deploying renewable power in such a distributed manner at strategic scale could very well cancel out the intermittency of wind and solar enough to where the new fossil gas plant is not needed. It would be very disingenuous for Xcel's 15-Year Energy Plan to make a blanket claim that the scenario I describe is not feasible when they did not even give it a fair study. Having outdated software that is incapable of doing modeling at the distribution level is not a valid excuse. It appears the company has taken steps to rectify that issue in the most recent delay in the comment deadline.
However, the scenario plays out, there will be a transition period to replace fossil fuel electricity generation with renewables, storage, and demand side management. But building a new 835 MW gas plant that will not even become operational until 2027 is inconsistent with making a commitment to this transition instead of being a part of it. It is more of a gangplank rather than a bridge fuel.
The bottom line before I move onto the second main topic in the IRP is this. If the Commission agrees to what Xcel is asking for with this Sherco plant in this IRP, then it will lock Minnesota into 30 or more years of continued fossil fuel dependency with a high risk of stranded assets.
