HomeMy WebLinkAboutElectric Board - Minutes - 07/23/2008Fort Collins Utilities Electric Board Minutes
Wednesday, July 23, 2008
Electric Board Chairperson City Council Liaison
John Morris, 377-8221 Wade Troxell, 219-8940
Electric Board Vice Chairperson Staff Liaison
Dan Bihn, 218-1962 Robin Pierce, 221-6702
Roll Call
Board Present
Chairperson John Morris, Vice Chairperson Dan Bihn, Tom Barnish, John Graham, John
Harris, Steve Wolley
Board Absent
Jeff Lebesch
Staff Present
Brian Janonis, Patty Bigner, Steve Catanach, Tom Rock, Kraig Bader, John Phelan,
Norm Weaver, Eric Dahlgren, Jenny Lopez-Filkins and Robin Pierce
Guests
Council Liaison Wade Troxell; John Bleem, Mike Dahl and Joe Wilson, PRPA; Tony
Georgis, R. W. Beck, Inc.; Citizen Eric Sutherland
Meeting Convened
Chairperson John Morris called the meeting to order at 5:30 p.m.
Citizen Participation
Eric Sutherland recommends Fort Collins Utilities (Utilities) discontinue their
subscriptions to the wind power program. Mr. Sutherland noted lack of evidence
provided by Utilities to demonstrate the monetary investment by rate payers is producing
results. Mr. Sutherland requested no further Renewable Energy Credits (RECs) are
purchased due to lack of additionality and transparency which make them good
investments.
Approval of .Tune 18, 2008 Minutes
Board Member Steve Wolley motioned to approve the minutes from the June 18, 2008
meeting. Board Member John Graham seconded the motion, and it passed unanimously.
Climate Action Plan
Tony Georgis with R. W. Beck, Inc. consulting firm presented an analysis of the Climate
Task Force (CTF) Phase 2 recommendations on the City's carbon reduction goal.
Utilities was asked to review the recommendations, and weigh in on the initiatives
Utilities would endorse, recommend other initiatives to include and verify accuracy of the
figures. Figures cited in the task force report are aggregate in nature and do not represent
specific allocations to Utilities or any specific City department. The consultants focused
their analysis on the 8 CTF programs with impact to Utilities:
1) Residential rate structure;
2) Smart meters and automated metering infrastructure (AMI);
3) Low cost home energy assessments;
4) Time of sale energy conservation program;
5) Renewable energy program;
6) On the ground renewable energy program;
7) Local carbon offset fund, and
8) Increase to current energy efficiency programs.
Residential Rate Structure (recommended for adoption by Utilities):
The residential rate structure is a declining block (tiered) structure. A higher rate applies
as more energy is used. "Elasticity of demand" is the primary assumption driving a
declining block structure. The task force report assumed 20% elasticity of demand.
Consultants project a more conservative figure between 10-20%, translating to carbon
reductions of 9,000-18,000 tons compared to the task force's projection of 18,000 tons.
The cost impact for implementing a new rate structure is minimal, primarily involving
operations and maintenance costs for a rate study and implementation process.
Consultants are analyzing the impact of this type of rate structure on low income
customers. Board Member Wolley participated with the task force and noted the task
force based the information in the report on costs incurred by other cities to implement a
rate structure change.
Smart Meters/Automated Metering Infrastructure (AMI) (recommended for adoption by
Utilities):
Automated or "smart" metering refers to a solid state meter for both commercial and
residential use. A smart meter provides information on energy use in predetermined
increments. Other options exist with smart metering such as smart grid, integrating
appliances, two-way communication between the grid, and automated programming to
manage use. These options are not part of this program as represented in the report. This
is strictly for meters to display energy use and communicate real-time data to the
consumer. AMI technology would be implemented over 3-7 years and would not be fully
implemented in time to have a positive impact on the 2012 goal. Therefore, consultants
project zero tons reduction by 2012 from this program with the potential reduction of up
to 19,000 tons when fully implemented.
Consultants project a cost of $18- $26 million in initial capital costs based on a state-of-
the-art device which eliminates the need for meter readers, compared to a lower cost of
$9-12 million reflected in the task force report. The higher projection includes the cost to
install water and electric meters simultaneously, resulting in faster return.
Vice Chairperson Dan Bihn asked about the fairness of allocating this figure solely to
carbon reduction when some of the expenditure may be part of a large investment to
benefit other Utilities projects. Mr. Georgis noted when analyzing costs and benefits, the
payback period is considered. The majority of the cost will be allocated to carbon
reduction if it's the main driver. Board Member Wolley noted the task force did not focus
on some available features and used historical costs from other cities. The cost for
additional functionality is minimal if Utilities opts to install other options with the meters.
Low Cost Home Energy Assessments (recommended for adoption by Utilities in
combination with the Time of Sale Energy Conservation Program).
Utilities would contract with a provider, subsidize a program or provide internal
resources to perform low cost energy audits for residential customers. The task force
projected 600 audits per year, a substantially higher number than Utilities is currently
managing. Consultants project zero tons in carbon reductions, and the task force projects
reduction of 15,000 tons. This program overlaps with the time of sale program, and the
programs are essentially different vehicles to accomplish the same result, so consultants
recommend adoption of one or the other program. Consultants also project zero tons
reduction with the time of sale program, as Utilities plans to bring both programs under
an existing program, Home Performance with Energy Star. Fifty audits per year is an
aggressive expectation under the Energy Star program. This is due to a shortage in the
number of contractors trained to perform audits in the area and lack of an implementation
strategy. Utilities would subsidize the audits, and the owner would be responsible for
100% of the upgrades. Upgrades projected at $1,000 in the task force report are
substantially lower than necessary to achieve significant savings.
The task force estimated 500 therms per year reduction for natural gas savings. The
average residential customer uses approximately 600-700 therms per year. The task force
figure implies the average residential customer will save up to 90% on natural gas
expenses by adding $1,000 in home upgrades.
Board Member Graham noted the assumption of combining this with the time of sale
program is conservative, and the projection of zero tons reduction is fairly negative and
essentially rejects the task force's efforts in this area. A real estimate with a footnote
stating Utilities will attempt to accomplish this in combination with another program
would be a clearer way to convey this. Board Member Wolley suggested a slide to
portray the result of combining these programs.
Increasing Current Energy Efficiency Programs (recommended for adoption by
Utilities):
This program looks for opportunities to increase current energy efficiency programs, such
as lighting retrofits. Consultants see the potential for more carbon reduction than
identified by the task force. Chairperson Morris pointed out the presentation lacks steps
for compliance and is concerned double counting may be an issue. Mr. Georgis noted
double counting is accounted for in a large deduction taken in the final analysis.
Time of Sale Energy Conservation (see Low Cost Home Energy Assessments section;
recommended for adoption by Utilities in combination with the program.)
Renewable Energy (recommended for adoption by Utilities):
This program is based on growth of the existing renewable energy policy, and
recommends a mix of RECs and purchases under the Purchase Power Renewable
Contract. The type of RECs purchased was not analyzed.
On the Ground Renewable Energy (not recommended for adoption by Utilities):
This is a small program on the task force list netting a reduction of 2,000 tons. However,
the consultants project zero tons reduction, because the program competes with the local
carbon offset program, and Utilities would endorse one or the other. A $1.8 million
surcharge across all customers would fund programs for both residential and commercial
customers (photovoltaic solar projects, ground source heat pumps, etc.) with a $65,000
administrative cost to Utilities. The carbon offset program also subsidizes installations,
and customers would pursue one or the other program.
Local Carbon Offset (not recommended for adoption by Utilities):
There was a substantial reduction with the local carbon offset program. The primary
assumption is based on a 5% adoption rate at $800 per year. There are important issues to
resolve with the Renewable Portfolio Standard (RPS) and carbon accounting. There is no
cost impact, as it is a customer funded program.
Summary of recommendations;
Mr. Georgis summarized the list of potential task force programs recommended for
adoption by Utilities. The list includes residential rate structure, smart meters (AMI),
combination of the time of sale energy conservation and low cost residential energy
assessments, increasing energy efficiency programs, and renewable energy. On the
ground renewable energy and local carbon offset programs may ultimately be adopted,
but Utilities does not plan to rely on them to meet the goals. The 21a` Century Utility
program has other programs in mind to meet the long-term goal more effectively.
Mr. Georgis presented additional programs Utilities would like to add to the action plan.
Integrated Design Assistance Program:
The Integrated Design Assistance Program (IDAP) is a program developed to assist with
the construction of new buildings (primarily commercial) with a focus on orientation and
assistance with choosing equipment, windows, insulation and construction for energy
efficiency. Consultants recommend including IDAP in the action plan for the 2012 goal.
Projected reduction from adoption of this program is 7,000 tons at a cost of $1.25 million.
The cost includes incentivizing and subsidizing some upgrades. Vice Chairperson Bihn
asked whether the opportunity exists to double the investment for greater impact. Mr.
Georgis noted the issue lies with the number of larger building projects which can
reasonably be accomplished each year.
21" Century Utility Project:
The 21s` Century Utility project supports the Climate Task Force goals and the long-term
2020 goal. Utilities project a carbon reduction by 2012 of 117,000-146,000 tons and the
task force report projects a reduction of 239,000 tons. Cost projections are similar. The
project group is developing an overall sustainability strategy and action plan for Utilities.
Analysis shows the opportunity to not only meet, but exceed the 2020 goals.
Conclusion:
Utilities supports the goal and concepts outlined in the Climate Task Force
recommendations, but questions some of the assumptions, and will clarify them with
Lucinda Smith and the Brendle Group who served in a consulting role with the task force.
The 2012 goal is likely not feasible for Utilities to meet without purchasing RECs under
all the assumptions made by the Climate Task Force. Utilities will analyze the role RECs
will play in meeting the 2012 goal. The task force recommended the use of RECs at a
high level. There will also be impacts from potential carbon legislation and rate increases
of 8-10% with task force programs.
rd
The reduction programs touch on many areas in Utilities. At this time, the task force
report did not attempt to equally allocate the reduction across City departments.
Discussion and questions from the Board:
Board Member Bamish asked if any programs were on the list primarily for the purpose
of meeting the 2012 goal and is concerned with placing so much of the emphasis for
meeting the 2012 goal on Utilities along with the associated cost. Decisions made in
haste to implement programs for the short-term goal may not ultimately be the right
solution for the 2020 goal. Mr. Georgis noted the analysis ended with the 2012 goal,
although some programs recommended to meet the 2012 goal, such as smart meters, will
benefit the 2020 goal.
Board Member Wolley noted City Council asked the task force to define the impact of
relaxing the original 2010 goal. Council Member Wade Troxell noted the intention of
Council was to make investments for the short-term goal while not sacrificing the long-
term, more desirable goal.
Vice Chairperson Bihn asked for clarification as to how the task force arrived at the City
aggregate number and whether there will be non -Utilities strategies to meet the goal. Mr.
Georgis explained the formula used to arrive at Utilities' allocated portion. Utilities
accounts for approximately 40% of the City's carbon footprint. Utilities' allocated
portion is determined by multiplying the City aggregate by this percentage.
Vice Chairperson Bihn favors a sensible approach to address the entire system. For
example, it may be less expensive for Utilities to handle a higher percentage of
contribution to the goal than for other groups to handle their smaller contribution. Mr.
Janonis confirmed a collaborative process is underway across City departments to assess
and plan for their contribution to the goal. Information from this process is not available
to Utilities yet. The City will use the task force recommendations to develop a Climate
Action Plan, which will be presented to Council at the August 26 work session. Natural
Resources and Utilities will bring the Climate Action Plan and Electric Energy Policy to
Council together for action.
Council Member Troxell noted the level of contribution appears to be disproportionate
among departments at the outset, but investments in infrastructure will equalize the
benefit to Utilities and other departments as times goes on. This infrastructure will benefit
Utilities and in turn afford the opportunity to use some of their unique levers. Council
Member Troxell feels it would be beneficial to describe the FortZED/Department of
Energy project. FortZED provides an opportunity to aggregate and monetize items for the
first time. For example, if our system operates beyond carbon offset levels, the
opportunity exists to sell RECs. Many utilities are looking at revenue programs from
carbon. Light and Power Operations Manager Steve Catanach noted it's the intent of
Utilities to provide expandability, flexibility and communication capability with the
FortZED project. The communication realized from the FortZED project will become
critical to Utilities and will provide the ability to grow the system to meet our needs by
2020.
Vice Chairperson Bihn suggested a change to state the City can achieve the 2012 goal
without RECs, but it's going to be cost -prohibitive and not prudent. He questions the use
of the term "not feasible". Ms. Bigner stated Utilities will be challenged to ramp up
programs in time to meet the goal due to a variety of factors including capacity in the
community for assessments, putting programs on the ground and growing them to the
extent of needed return in the necessary time frame.
Board Member Wolley expressed concern with the projections represented in the
presentation. Within a year, Utilities can be buying and installing smart meters in
customer homes. On the ground renewable programs will provide $1.3 million dollars
each year to invest on something of value toward the goal.
Board Member Barnish expressed great confidence in staff. He would like to see some
programs initialized as pilots first, such as smart metering, to allow staff the time and
thought necessary to build and implement the right long-term solutions. Progress reports
on effectiveness and customer satisfaction would be beneficial to the Board.
Mr. Janonis and Ms. Bigner recognized the many challenges before staff in achieving the
short-term and long-term goals. Program implementation timelines, staffing issues and
budget cycle coordination are significant challenges. Mr. Catanach cited additional
challenges and tremendous pressure on Utilities related to energy costs, carbon tax, cap in
trade, pressures to implement renewables and extreme increases in the cost of materials.
Board Member Harris expressed concern for the impact o rate payers as a result of these
challenges.
In summary, the Board recommends the following items be revised or addressed in the
presentation:
• Correct the tone of the presentation, including "not feasible" language, and
address the passive approach reflected in the figures for anticipated targets.
• Present Utilities' plan without pointing out differences or conflicts with the task
force recommendations.
• Describe what attempts were made to reconcile gaps with the task force
recommendations, addressing the factor of two difference.
• Focus on the 2020 goal and define points Utilities can exceed in working toward
the goal with a checkpoint in 2012, and grade ourselves against the interim target
• Highlight anticipated accomplishments by 2012 in a different way.
• Add a statement that the City can achieve the 2012 goal without RECs, but it's
going to be cost -prohibitive and not prudent.
• Outline the cost of achieving the 2012 interim goal.
• Recommend some programs be initiated as pilots.
• Define a reporting mechanism/accountability from the City.
• Include a detailed description of the FortZED project and impacts.
• Suggestions for bullet point revisions:
o First bullet point: "Analysis suggests the task force recommendations will
not lead to the projected savings by 2012 without RECs and cannot
envision any other measures to achieve the goal (other than the purchase
of RECs.)"
o Last bullet point: Add "with reduced RECs usage" to "Utility for 2V'
Century Project underway includes a plan to meet 2020 goals."
Mr. Janonis noted staff would like to see the Electric Board make a recommendation to
Council to fully support the goal of 20% reduction by 2020, while allowing Utilities the
flexibility to select the best programs for achieving the long-term goal.
Motion for Recommendation:
Board Member Barnish moves to support the City-wide goal of 20% reduction in
greenhouse gas (GHG) emissions by 2020 with a revised, measurable Electric Utility
2012 milestone. The Board recommends the Electric Utility put forth an aggressive plan
to achieve the 2020 goal. Vice Chairperson Bihn seconded the motion.
There was no discussion following the motion. A vote was taken, and it passed
unanimously (6 for, 0 against.)
PRPA Organic Contract and Energy Supply Agreement
Mr. Catanach shared an update on the status of the Organic Contract and the Energy
Supply Agreement between Fort Collins Utilities (Utilities) and Platte River Power
Authority (PRPA). The Organic Contract is approximately 10 years old and lays out the
partnership structure between PRPA and four participant cities (Fort Collins, Loveland,
Longmont and Estes Park.) The document functions as a set of by-laws and an
intergovernmental agreement. The benefits favor the participant cities and include very
low rates and very high reliability. Other benefits include a local generation source, a
controllable fuel source, and input through Board involvement. Minor language changes
have been added to update some technicalities, including the process for handling a
vacancy in the PRPA General Manager position and allowing director participation by
teleconference. These items go before Council at the end of August.
The Energy Supply Agreement is a unique agreement between PRPA and the City of Fort
Collins. It creates a symbiotic relationship by having a guaranteed customer and source,
and allows PRPA to maintain a very high bond rate and much lower interest rate which is
passed on to the City. In this update, language in the previous agreement regarding
allowance for and management of transmission projects has been addressed. Also, the
language to govern timelines has been streamlined, and the responsible party for the
maintenance of our substations has been clarified. There was a previous restriction on the
amount of self -generation the City could own. Joe Wilson, General Counsel with PRPA,
noted this defines the difference between a scenario where a customer can net meter and
when the customer would be required to sell power to PRPA under the tariffs. The
deminimous language allows Utilities to develop up to 3 megawatts of renewable
resources, an option previously prohibited by the all requirements feature. There is
essentially no limitation on customers developing generation sources for their own use,
unless generation reaches a level over 1 megawatt. A contract with the customer would
be needed if generation reaches over 1 megawatt. Limitations and requirements are
spelled out in the City's interconnection standards, and electric rules and regulations. For
example, if a customer generated more power than it used, the excess power would be
sold to PRPA rather than to Fort Collins Utilities.
Mr. Catanach noted the opportunity in the agreement for the City to work independently
and negotiate specific deals with PRPA. Council Member Troxell asked about purchasing
wind power from an entity other than PRPA. Mr. Wilson said if the other entity is
developed by an owner, and the wind is transferred between owners, it constitutes
customer generation via a third party power provider and violates the all requirements
7
nature of this agreement. Vice Chairperson Bihn asked whether the PRPA Board can
execute decisions on projects or exceptions to the agreement. Mr. Wilson responded the
Board can executive some decisions on a case by case basis, but bond holders would be
addressed for certain types of third party provider opportunities. The 3 megawatt limit
was developed to address a pattern of requests for small projects. PRPA has issued a
letter stating these projects are deminimous and present no issues for bond holders. PRPA
consulted with Sherman and Howard, bond counsel, to determine a sensible level that
would not be actionable on the part of those who have already purchased bonds based on
all agreements rights. The current power supply agreement runs through 2040; this will
extend the agreement by 10 years to 2050.
Electric Code Change
Light and Power Operations Manager Steve Catanach introduced a proposed change to
the electric code as defined in Sections 26-391 and 26-441 through 26-444 of the
Municipal Code. The Code contains sole provider language necessary to clarify the
City's position on obtaining and providing electricity within City limits. Fort Collins
Utilities entered into a sole provider agreement with Platte River Power Authority
(PRPA). However, the City also needs the option to accommodate distributed generation
projects. An example of such a project is a parking structure planned by Colorado State
University (CSU). CSU will potentially add solar panels to the structure in the future,
qualifying the structure as a distributed generation project. According to the way current
ordinances are written, due to the location of the parking structure and its relationship to
right-of-way, CSU would have to simply be a metered customer of the City.
The proposed language is designed to provide a new level of flexibility and allow parties
to petition Council for a permit to cross over right-of-way and interconnect with their
system, so long as the structure meets the "qualifying facility" criteria. It also recognizes
if a party is not entering right-of-way for distributed generation. It does, however, still
limit third party sales of electricity through appropriate restrictions in the Code. This
Code change will go before Council at the August 19 meeting and therefore requires
action by the Board.
Board members discussed various scenarios for applying this change.
• An owner of a solar panel cannot run a wire from their panel to a neighbor and
charge for the electricity.
• A distributed generation project that crosses ownership lines on the same premise
would be allowed if the party is the owner of the project under the interconnection
agreement. However, a third party financing and owning the project facilities
would not be allowed to sell only the kilowatt hours according to the Code.
• This practice is prevalent in some states as a very effective way for financing
solar projects. However, rates are much higher in those states, because these
practices are allowed.
Board Member Barnish noted our community has been successful in maintaining lower
rates, because this type of practice is not allowed.
Mr. Wilson noted the case of a third party solar developer in another city that wanted to
install panels and sell electricity directly to a building on the same property. Typically
under Colorado law, this would not be allowed. A customer can generate electricity for
their own use, but service territory protection protects utilities from third party retailing.
This guideline has eroded somewhat in light of solar development. As a solution, PRPA
offered to enter into a simultaneous buy -sell transaction where PRPA purchased the
solar -generated power at the price the customer was willing to pay and sold it at that price
to the city utility, so the utility could sell it for the same price to the customer. This was a
transparent transaction to the customer and would not go against contractual protections
or cause the utility to waive its territorial protections.
Board Member Harris added the importance of advancing solar projects while protecting
the interests of Utilities. Board Member Wolley added issues could arise if Utilities
anticipates cases where a party objects to selling through PRPA and wants to sell straight
to the customer.
Board Member Barnish asked whether PRPA would be left to hold a long term contract if
a current customer willing to pay the higher cost leaves and a new customer comes in that
does not want to pay the higher costs. Mr. Wilson clarified the customer chose to bear the
risk under any number of unforeseen possibilities that could develop, such as the solar
developer going out of business. PRPA would want protection in that case, since they are
still obligated to purchase the power.
Board Member Graham asked whether this Code change does well by our customers.
Staff responded that the proposed language is favorable in allowing the Utility to offer
customers more flexible options. Board Member Graham moved that the Board accept
the Code change language as written. Board Member Barnish seconded the motion. It
passed unanimously (5 for, 0 against. Note: Chairperson Morris was not presentfor this
vote.)
Electric Energy Policy
Customer and Employee Relations Manager Patty Bigner reviewed the last steps taken
with the Board on the Electric Energy Policy draft. Feedback gathered from the Board
previously has been incorporated. The Policy goes before Council in October, and staff is
following a specific timeline to share the policy with other boards (Air Quality Board and
Natural Resources Board.) Public outreach will also occur.
Energy Services Engineer John Phelan requested feedback on some new minor language
changes in the policy. No formal action is required from the Board at this time.
2050 Vision Statement:
The policy contains a mid-century vision and three goals. The policy goal reflects the
City's goal of 20% carbon reduction below 2005 levels by 2020 and 80% reduction
below 2005 levels by 2050. Board Member Barnish noted carbon neutral as referred to in
the vision means balance rather than zero carbon. Mr. Phelan notes future discussion
needs to occur on the vision and how it relates to specific goals. The term "responsible
management" appeared through the policy and has been added to the draft vision
statement.
Goal #1 — Provide highly reliable electric service. The year, 2005, was added as a
reference related to load management targets, replacing a percentage of load which varies
annually. Board Member Graham requested a wording change from reliability "statistics"
to reliability "performance." Discussion took place about the critical importance of
attracting and retaining skilled electric workers. Salaries, succession planning and
maintaining credentials are part of workforce management. A metric will be added
0
regarding recruitment and retention of skilled electric workers as referred to in the
summary.
Goal #2 — Support the community's carbon emissions goal of reducing the City's
carbon footprint 20% below 2005 levels by 2020 and 80% by 2050. A change was made
to reflect the goal as the community's goal rather than Utilities' goal. Mr. Phelan expects
changing the philosophy from 15% by 2017 to be the biggest topic of discussion in light
of the new minimum requirement from the State of 10% reduction by 2020. After all of
the voluntary programs and initiatives are implemented, renewable energy credits will
likely still be purchased to meet the goal. Board Member Barnish requests wording to
establish a cap on intermittent renewables on the system and allow only a certain level of
renewables on the system before a dispatching system is required. Intermittent
renewables of 20-30% are designed to work on system reliability. The point on
renewables in the summary document will be modified to read "renewables to reach
carbon goal without compromising reliability." A point will be added under bullet #3 to
state "include dispatchable renewables as part of the portfolio to maintain system stability
and reliability." This will reduce the need for future base load generation.
Goal #3 — Enhance local economic vitality. Points were added under bullet #1 to define
financial health metrics. For bullet #2, Board Member Barnish suggested emphasis on
comparison toward "like systems" (i.e., municipal utilities). A metric will be developed
in the future to reflect the affordability of electric bills for Fort Collins Utilities
customers.
The Board gave permission to share the policy with the Air Quality Board and Natural
Resources Board next month with the proposed changes. The Climate Action Plan will be
discussed at the August 26 Council work session, and Mr. Phelan anticipates discussion
of the Electric Energy Policy to occur at the same meeting.
Timeline:
An energy efficiency briefing will be given to Council to follow up on previous questions
at the September 9 work session. Staff will bring this back to the Electric Board at their
August 20 and September 17 meetings. The policy will be discussed at the September 23
Council work session and will go before Council with the Climate Action Plan at the
October 21 regular meeting.
Adiournment
The meeting was adjourned at 9:26 p.m. following a motion to adjourn by Board Member
Graham.
Submitted by Robin Pierce, Executive Administrative Assistant
Fort Collins Utilities
Approved by the Board on 2008
Signed
h
Robin Pierce
fwrlwa
DaTtc
10