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IRS: PTC Will Be Worth Slightly More In 2013

Wind developers have received a touch of good news, as the Internal Revenue Service (IRS) has announced that the federal production tax credit (PTC) for wind will be worth $0.023/kWh in 2013, up slightly from $0.022/kWh in 2012.

The PTC amount is adjusted each year for inflation. The IRS calculates the inflation adjustment and announces it each year on or around April 1. The adjustment also applies to other sources of generation, such as closed-loop biomass and geothermal.

The IRS previously adjusted the PTC in 2010, when it raised the tax incentive to $0.022/kWh. Before that, the IRS raised the PTC to $0.021/kWh from $0.020/kWh in 2008.

“This is good news for developers, as each hour of electricity generated by their qualified projects is slightly more valuable for tax credit purposes,” says David Burton, a partner at law firm Akin Gump Strauss Hauer & Feld.

Additionally, the statute is written in such a way that the tax incentive automatically begins to phase out when energy prices are raised to a level where the PTC is thought to be unnecessary.

“When the PTC was enacted, Congress wrote into the statute that the PTC would phase out automatically if electricity prices reach a high enough level that a subsidy is no longer needed,” explains Keith Martin, a partner at law firm Chadbourne & Parke.

According to Martin, the government looks at the average price at which contracted electricity from the same energy source was sold the year before.

“The IRS said the average price at which electricity was sold last year at contracted wind farms was $0.0453/kWh. The credits would have started to phase out if electricity prices had been significantly higher. The IRS said prices would have had to have reached $0.1205/kWh last year before the phaseout would have started.”

 

MWE Sells Portfolio;
Exits Development

Illinois-based Midwest Wind Energy (MWE) will no longer actively develop wind farms and has sold the majority of its project development portfolio to Minnesota-based Geronimo Energy.

Michael J. Donahue, executive vice president of MWE, tells NAW that the company began searching for an alternative source of funds about 18 months ago, after losing capital from long-time joint-development partner Edison Mission Energy.

“The hardest capital to come by today in the industry is the risk money that comes with developing projects from scratch,” he says. “We had partnered with Edison seven-and-a-half years ago to provide us with a development loan structure that funded all of our development activity. That aspect of the relationship changed when Edison had to curtail the development funding on its entire wind portfolio – not just Midwest Wind Energy – as a result of an internal financial situation.”

Donahue says his company’s relationship with Edison “continues to be excellent,” but MWE was left with two choices: find another joint-development partner to help fund and complete MWE’s portfolio, or sell the portfolio.

After exploring several options, the company set its sights on Geronimo Energy in fall 2012, and on March 26, 2013, the two parties announced that Geronimo would acquire substantially all of MWE’s portfolio.

“At the end of the day, Geronimo demonstrated a strong source of development funding and expertise,” Donahue explains. “Our primary objective was to keep our portfolio viable and moving forward.”

 

The acquisition

Through the deal, Geronimo purchased eight wind development projects representing a total potential capacity of over 1 GW. The portfolio includes the 400 MW Grand Prairie wind farm in Nebraska and the 210 MW Walnut Ridge wind farm in Illinois. Financial terms of the acquisition were not disclosed.

Blake Nixon, president of Geronimo Energy, says it was a strategic acquisition to help broaden the company’s portfolio and enter new markets, especially in Illinois.

“Illinois is a large market, not only from the utility side, but also from the commercial-customer perspective,” Nixon says. “There are a lot of great corporate headquarters in Illinois, Chicago in particular. We see a lot of attractiveness to the Illinois market.”

In addition, Nixon considers several of the portfolio’s projects construction-ready. “We think that the projects are very well developed,” he says. “Midwest Wind Energy selected good sites that are competitive and can offer real viable options for buyers.”

Geronimo has also hired “a substantial number” of employees from MWE. Nixon says having members from MWE’s development team on hand was necessary to continue with the portfolio’s progress and create a seamless transition.

“This was almost like a merger,” Donahue adds. “One of our top priorities was that if we were going to transfer the assets, we wanted to transfer the key staff along with the assets – that was one of our major objectives in finding a suitable purchaser.”

 

What’s next?

MWE has retained the 75 MW Broken Bow II project in Nebraska because of a current power purchase agreement, as well as a few minor assets that Donahue says will likely wind down over the next several months. However, now that MWE has sold most of its portfolio, the company will remain as an entity but not actively develop wind projects.

Donahue says that he and partner Stefan Noe, president of MWE, still have some contractual rights to the projects purchased by Geronimo, as well as to other projects that the company has worked on over the years.

“We’re basically going to be maintaining our contractual relationships and deriving income,” he explains. “We will not be actively out prospecting for new sites. We will not be developing a new portfolio. We want to basically support the portfolio we transferred to Geronimo. If those projects are successful, Midwest Wind Energy will derive an economic benefit.”

Geronimo is already moving ahead with its newly purchased projects. “We have begun the transition and are continuing to develop the projects as is appropriate,” Nixon says. “We’re marketing the projects to customers for power sales, as we are the rest of our portfolio.”

He says Geronimo will continue to seek new opportunities for the company to grow.

 

Who Were 2012’s
Top Turbine OEMS?

Two research firms have released different takes on the wind turbine original equipment manufacturer (OEM) market, with MAKE Consulting placing Vestas at No. 1 in 2012 and Navigant Research assigning the top spot to GE.

According to MAKE Consulting, the top 10 turbine suppliers of 2012 were as follows:

 

1. Vestas

2. GE

3. Siemens

4. Gamesa

5. Enercon

6. Suzlon Group

7. Goldwind

8. United Power

9. Sinovel

10. Mingyang

 

MAKE Consulting says the No. 1 spot “went down to the wire,” but Vestas ultimately pulled ahead of GE by a narrow 0.9% margin: Vestas held 14.6% of the global market, and GE held 13.7%. If all of GE’s 2012 Brazil-based projects had been grid-connected, however, the firm says the OEM would have beat out Vestas.

Navigant Research’s top 10 list, meanwhile, includes the same big-name companies but gives the lead to GE, with GE holding 15.5% of the global market and Vestas holding 14%. (Other deviations from MAKE’s list include ranking Enercon, Suzlon and Gamesa fourth, fifth and sixth, respectively.)

Navigant says GE’s progress can be attributed to a rush to take advantage of the U.S.’ production tax credit, and MAKE adds that GE’s strong growth in markets emerging in Europe, the Middle East and Africa (EMEA) was also essential.

Regardless, both research firms seem to agree that Vestas still reigns as one of the largest OEMs and that 2012 was a huge year for GE.

Both reports also say that Chinese market leaders Goldwind and Sinovel slid down the rankings in 2012. According to Navigant, Sinovel “continues to drop in the rankings, narrowly maintaining its position in the top 10.” Perhaps most notable, though, is that Goldwind dropped on both lists from second place in 2011 to seventh place last year.

In part, MAKE says the declines are due to a 26% decrease in Chinese installations, while Navigant says “transmission bottlenecks and manufacturing overcapacity” in the Chinese OEMs’ home markets are to blame.

Both reports use the word “strong” when describing Siemens’ 2012 growth, landing the OEM its third-place ranking. Navigant says Siemens did well in both the U.S. and offshore markets. Regarding Gamesa’s fourth-place ranking, MAKE notes that the OEM’s performance in the Americas and the Asia-Pacific region compensated for a lower installation volume in the EMEA markets.

 

Duke Energy Jumps
Into Services Market

According to IHS Emerging Energy Research, annual expenditures of wind farm operations and maintenance (O&M) will exceed $5.6 billion by 2025 – more than double the total spent on O&M in 2011. In fact, IHS research shows that O&M services for wind energy are expected to account for more than one-third of total capital expenditures in the U.S. wind industry over the next decade.

With scores of wind turbines slated to come off of their original equipment manufacturer (OEM) warranties, Duke Energy Renewables is venturing into the third-party services arena as an independent service provider (ISP).

And to expand the company’s service capabilities, Duke Energy Renewables quietly acquired Canby, Minn.-based monitoring, maintenance and site management services provider Outland Energy Services late last year.

Duke Energy Renewables, which entered the wind market in 2007, owns and operates 15 wind farms in the U.S. representing more than 1.7 GW of capacity. Since its inception, the company has invested more than $2.5 billion to grow its renewable energy portfolio.

Greg Wolf, president of Duke Energy Renewables, says the acquisition of Outland, established in 2005, will help expand Duke’s capabilities with Outland’s knowledge and experience of eight wind turbine technologies.

“Outland’s experience and excellence in the industry is a great fit for us as we focus on achieving efficiencies through scale and driving down our operating costs,” Wolf says.

Generally speaking, ISPs are free to point out any issues with a turbine’s operation without concern for the serial defect litigation that an OEM could face.

“As an independent service provider, we are unbiased advocates for the asset owner,” Wolf explains. “We have extensive operations and maintenance experience with a broad spectrum of turbines and know the strengths, issues and problems associated with them.”

Duke says Outland Energy Services and its 120 employees will continue to operate out of its present location, and Steve Scott will remain Outland’s CEO. In 2014, Duke says Outland will make the transition to become Duke Energy Renewable Services.

Dan Shreve, a principal at MAKE Consulting, says Duke’s acquisition of Outland “was a brilliant means to quickly elevate their in-house O&M capabilities. Duke has been extremely forward looking in its O&M approach and quick to evaluate new technologies and commercial business models.”

While Shreve expects other large asset owners to take the third-party O&M services plunge – as NextEra Energy Services and Iberdrola Renewables already have done – he expects additional, but limited, merger and acquisition opportunities involving ISPs as asset owners and component OEMs seek to enhance their positioning in the North American wind services market.

 

Name Change
For Juhl Wind

Minnesota-based Juhl Wind Inc. has announced its name change to Juhl Energy Inc., as well as launched a new website, juhlenergy.com.

The company says the new corporate name and supporting Web presence are intended to more clearly represent Juhl’s focus on its commitment to operate as a fully diversified clean energy company alongside its continuing dedication to community wind and small wind and solar.

“Over the past year, we have expanded into several important segments of the clean energy industry and, as such, wanted to re-establish our message to our respective market channels that we are not just community wind experts but experts across all areas of clean energy,” says Dan Juhl, CEO of Juhl Energy Inc.

Juhl will continue to handle all aspects of wind project development, such as feasibility studies, construction management and project financing, through its Juhl Energy Development Inc. subsidiary. Furthermore, the company has expanded its presence and services available in the renewable energy markets with the creation of the following operating divisions:

- Juhl Renewable Assets Inc. is an independent power producer subsidiary focused on ownership and acquisition of renewable energy assets, including wind farms, solar systems, biomass, cogeneration, coal to gas conversions and full-scale power engineering.

- Juhl Energy Consulting Services provides engineering and related services to the power and building systems industries. Juhl Consulting is primarily made up of wholly owned subsidiary, Power Engineers Collaborative, acquired in 2012.

- Juhl Energy Services Inc. provides a full range of wind farm operations, management, maintenance and warranty services. Through its newest subsidiary, Juhl Tower Services, Juhl now provides a full range of wind and cell tower services.

 

Sheffield Safe
For Water

Boston-based First Wind says that, for the second year in a row, the Vermont Agency of Natural Resources’ Biomonitoring and Aquatic Studies Program has issued a report showing that the Sheffield Wind project has not had an adverse impact on water quality and aquatic life of nearby cold-water streams.

The study spanned from 2006 to 2012 and looked at aquatic life forms as indicators of water quality in five streams adjacent to and downslope of the 40 MW Sheffield Wind project, located in Sheffield, Vt. First Wind says the report measured “biological integrity” – an index of ecological health based on the condition of aquatic life and fish populations – both before and after the construction of the wind farm.

The state conducted pre-construction tests in 2006, 2009 and 2010, during-construction tests in 2011 and post-construction tests in 2012, the company adds.

According to the new report, “Four of the five stream reaches sampled during and after construction (2011 and 2012) maintained an excellent to very good level of biological integrity in the primary biometrics ...” A fifth stream – which was rated “fair” in 2011, in part because of high water runoff due to Tropical Storm Irene – improved to “very good,” First Wind notes.

The company says the independent state study shows that water quality in the area potentially affected by the Sheffield Wind project has remained at very good and excellent levels.

“We’re proud of the measures we put in place to protect the water quality at the Sheffield Wind project,” says Josh Bagnato, First Wind’s environmental permitting and compliance manager. “For the second year in a row, these test results have proven that the things we did in planning and building this project have worked and worked well.

“With careful planning and construction, along with monitoring of natural resources, wind projects like this one can be built in a way that protects the surrounding environment while delivering clean wind energy with no pollution or emissions,” Bagnato adds.

 

Vestas Investigates
V52 Turbine Collapse

Turbine manufacturer Vestas says a “thorough investigation” will begin to determine the factors that led to the collapse of its V52 850 kW wind turbine at the Loughderryduff wind farm, located in Donegal, Ireland. No one was injured in the March 22 incident.

Although Vestas is not speculating on the cause of the incident, the manufacturer indicates that wind gusts reaching 90 km/h – 25 m/sec. – played a major role in the incident, which occurred about 5 p.m. local time.

“Due to safety reasons, the other eight turbines at the wind power plant were shut down,” says Vestas in a statement, adding that company technicians responded at the site and the situation is under control. “The remaining turbines have now been restarted,” notes Vestas.

The 7.7 MW Loughderryduff wind farm, commissioned in 2010, was developed by Wind Prospect.

 

Former Sen. Bingaman
Heads To Stanford

Former Sen. Jeff Bingaman, D-N.M., will serve as a distinguished fellow for a Stanford University program focused on the development of renewable energy projects and the promotion of renewable portfolio standards (RPS).

According to a Stanford Law School News report, Bingaman – a five-term senator, former chairman of the Senate Energy and Natural Resources Committee and Stanford alumnus – will help the university’s Steyer-Taylor Center for Energy Policy and Finance assess states’ RPS mandates and develop strategies to improve the standards.

“I look forward to helping advance the Steyer-Taylor Center’s mission to find cost-effective solutions to advance clean energy,” said Bingaman. “I’m excited to work with Stanford faculty and students to develop approaches to policy and finance that make sense to the investment community, Congress and state legislatures.”

 

Reforms Needed On
Rare-Earth Potential

The U.S. must reform its mine permit process and safety regulations to get to the vast underground resources of rare-earth materials that could drive growth, add jobs and bring revenues to state budgets, according to a new study from the National Center for Policy Analysis (NCPA).

“Rare earths and rare-earth mining are crucial to modern life, providing critical components of everything from iPhones to computers, medical CAT scans, defense equipment, wind turbines and other forms of green energy,” says NCPA Adjunct Fellow Tom Tanton. “Yet, the United States depends on other countries, some of which are not very friendly, for these elements, importing more than 96 percent of its rare earths. This dependence on foreign sources such as China for our supplies of these critical elements must end, and it can.”

According to the NCPA, the study found that states with rare-earth resources could increase gross state product by almost $40 billion, add nearly 3,600 shovel-ready jobs and improve state revenues by $724 million by simplifying the approval process for rare-earth mining projects.

“Australia and Canada set good examples of how it should be done. Their permit approval time is dramatically shorter than the average seven years it takes in this country,” says Tanton. “The U.S. needs to combine redundant and multiple agencies into a single ‘one-stop-shopping’ authority.

“It is economically foolish to rely on other countries for such critical minerals when we have a bounty of them in the U.S. available for use,” Tanton adds.

 

BP To Sell
U.S. Wind Unit

Conglomerate BP says it will divest its U.S. wind portfolio – more than 2.6 GW of installed capacity – in order to focus on its core oil and gas business.

In a statement sent to NAW, the company writes, “BP has decided to market for sale our U.S. wind energy business as part of a continuing effort to become a more focused oil and gas company and reposition the company for sustainable growth into the future.”

BP is a leading developer and operator of wind projects in the U.S. and is a full or part owner of 16 wind farms in nine states. Some projects include the 141 MW Mehoopany wind farm, located in Wyoming County, Pa.; the 419 MW Flat Ridge II wind farm, located in South Central Kansas; and the 225 MW Trinity Hills wind farm, located in Texas.

According to a company spokesperson, the company’s portfolio also includes projects in various stages of development, including an additional 2 GW of projects “that are nearly shovel ready.”

BP – the second largest producer of oil and gas in the U.S. – says its decision to sell its wind business does not equate to an exit from alternative energy.

According to the spokesperson, BP supports commercial and academic research furthering alternative energy through its Global Technology Center in San Diego and its sponsorship of the Energy Biosciences Institute – a joint initiative between BP, the University of California-Berkeley and the University of Illinois.

Additionally, the spokesperson says that the developer continues to invest in “new, cutting-edge companies developing efficient energy technologies with applications in both renewable and conventional energy production.”

 

Ontario Turbine
Catches Fire

A Vestas V-80 turbine caught fire at the Kingsbridge 1 wind farm, located north of Goderich, Ontario.

Alberta-based utility Capital Power, which owns the 40 MW wind farm, says no one was injured and no public property was damaged. The wind farm comprises 22 Vestas V-80 turbines, but the fire was contained to a single machine. The utility says Vestas is on-site and an investigation is under way.

This incident comes about a week after a Vestas V52 850 kW wind turbine collapsed at the Loughderryduff wind farm, located in Donegal, Ireland. Last year, a Vestas V112-3.0 MW caught fire at a German wind farm.

 

Latin America Poised
For Steady Growth

The Americas region will add nearly 92 GW of new wind power capacity from 2013 to 2020, but the rate of growth will be dramatically different between North America and Latin America, according to a new report from MAKE Consulting.

Despite macroeconomic headwinds in North America, the report says enough demand exists to support and build over 6 GW per year; however, the market is crowded. The real opportunity over the next eight years will be in Latin America, where MAKE forecasts a 20% compounded annual growth rate.

Opportunities in Latin America abound as market potential has yet to be fully realized, and only recently have regulatory frameworks been executed to spur growth in renewable energy, MAKE explains.

Unlike in North America, the emerging economies of Latin America and associated macroeconomic conditions support higher electricity consumption that creates opportunities for wind power development. Several markets in the region are also subject to seasonal and/or unsecure power sources, which drives an interest in harnessing domestic energy sources such as wind power, the report adds.

According to MAKE, growing pains caused by inadequate infrastructure, volatile political regimes and ineffective policies will influence a more sporadic growth trajectory than in more mature markets, but general demand is undeniable. Brazil highlights the region, becoming the second-largest market for new growth in the Americas with nearly 14 GW of wind capacity forecast to be installed through 2020.

MAKE says it believes the U.S. wind market is in the midst of the last production tax credit cycle. Given the expected stipulations of the program, MAKE predicts that installation numbers in the U.S. will rebound in 2014. A similar near-term growth is foreseen in Brazil on account of new capacity born from the 2009-2011 national power auctions and the delayed grid connection of 2012-2013 installations in 2014. Together, both the U.S. and Brazil markets will account for over 26 GW of installations from 2013 to 2016, with a bubble year expected in 2014.

Policy fulfillment, surplus power and competition from inexpensive gas and hydroelectricity will impact demand for wind power in North America over the next eight years, the report adds. Short-term policy support in the U.S., Ontario and Quebec will support growth from 2013 to 2016. In the longer term, MAKE says the industry will leverage a decreasing levelized cost of energy for onshore wind, increasing gas prices and opportunity born from coal retirements in the U.S. and Canada markets to sustain growth.

 

Mass. Lawmakers
Push Cape Wind

The entire Massachusetts congressional delegation, including the state’s nine U.S. representatives and two U.S. senators, has sent a joint letter to the U.S. Department of Energy (DOE) urging the department to approve the delayed loan guarantee for the Cape Wind offshore wind project.

Led by Rep. Bill Keating, the call for action comes two years after the DOE eliminated the Section 1705 loan-guarantee program and informed developer Cape Wind Associates that its application could not be processed by the program’s Sept. 30, 2011, deadline. The application has been on hold ever since.

The letter is addressed to former Energy Secretary Steven Chu and was also sent to Treasury Secretary Jack Lew and White House Office of Management and Budget Deputy Director Jeffrey Zients.

Within the letter, the Massachusetts legislators tout the potential economic and environmental benefits of Cape Wind, which is planned for Nantucket Sound.

“Cape Wind will create up to 1,000 jobs in Massachusetts during its construction and build a supply chain for the emerging offshore clean energy industry within the commonwealth that can serve as a model for future projects nationwide,” the letter says. “In this way, Cape Wind will help the nation achieve important public policy goals, such as greater energy independence and diversity, cleaner air and reduced greenhouse gas emissions.”

According to the legislators, the Cape Wind project is construction-ready and represents a new era for the U.S. wind industry.

“Cape Wind is the first U.S. offshore wind farm to secure all of its federal, state and local permits and to have received a commercial lease and approval of its construction and operations plan,” the letter says. “Further, Cape Wind’s 10-year regulatory review was one of the most comprehensive and thorough of any energy project on record. With your help, Cape Wind will enable the U.S. to tap into its vast offshore wind resource as Europe and China are now doing off their shores.

“What this new industry needs most is for the first offshore wind turbines to be installed off our shores to demonstrate the seriousness of our nation in moving forward,” the letter continues. “This is precisely what your timely approval of a DOE loan guarantee to Cape Wind will provide.”

In response to the letter, Cape Wind President Jim Gordon said in a statement, “I am grateful to Congressman Bill Keating and to the entire Massachusetts congressional delegation for their leadership and vision in pursuit of a cleaner and more prosperous energy future for Massachusetts and for helping launch the U.S. offshore wind industry.”

 

CAISO: Wind Energy
Sets Record

The California Independent System Operator (CAISO) says turbines spinning within its power grid combined to produce a new record of 4,196 MW of wind power at 6:44 p.m. PT on April 7.

On April 5, CAISO notes, total wind levels surpassed the 4,000 MW milestone when 4,095 MW helped to power California. Previously, the all-time record peak output for wind energy was 3,944 MW on March 3.

“With these impressive wind production levels, California is well positioned to meet the 33 percent by 2020 green power goal,” says CAISO President and CEO Steve Berberich. “Our control center operators are tracking a steady increase in renewable energy, and we are leveraging the latest forecasting technology as well as complementary flexible resources to capture and optimize this carbon-free power supply.”

 

Report: Reliability
Fears Unfounded

If the U.S. ceases to burn coal, shuts down a quarter of existing nuclear reactors and trims its use of natural gas by 2050, the resulting increased reliance on wind, solar and other renewables will not result in a less reliable electricity grid, according to a new report prepared by Synapse Energy Economics Inc. for the nonprofit Civil Society Institute.

The new study finds that in the envisioned 2050 with a heavy reliance on renewables, regional electricity generation supply could meet or exceed demand in 99.4% of hours, with load being met without imports from other regions and without turning to reserve storage. In addition, the report adds, surplus power would be available to export in 8.6% of all hours, providing an ample safety net where needed from one region of the U.S. to the next.

“Put simply, the message today is this: It is a myth to say that the United States cannot rely on renewables for the bulk of its electricity generation,” says Thomas Vitolo, analyst at Synapse Energy Economics Inc. and the report’s co-author. “This study finds that the projected mixes, based entirely on existing technology and operational practices, are capable of balancing projected load in 2030 and 2050 for each region – in nearly every hour of every season of the year.”

 

Xcel Is Top
U.S. Utility

Citing a newly released report from the American Wind Energy Association, Xcel Energy says it remained the No. 1 utility provider of wind energy in the U.S. in 2012. The Minneapolis-based utility says this is the ninth consecutive year it was rated No. 1.

At the end of 2012, Xcel Energy had nearly 4,900 MW of wind electricity generating capacity on its system, and wind power currently represents about 12% of the energy the company supplies to its customers.

“Our customers and communities are strong supporters of renewable energy, and wind energy plays a vital role in our strategy to meet customers’ energy needs with clean, reliable and affordable energy,” comments Ben Fowke, president, CEO and chairman of Xcel Energy.

 

Walmart Announces
New RE Goals

Walmart President and CEO Mike Duke has announced the company’s next step on the path to achieving its goal of being supplied 100% by renewable energy.

Unveiled at Walmart’s Global Sustainability Milestone Meeting, the company’s plan includes two major commitments to achieve by Dec. 31, 2020: driving the production or procurement of 7 GWh of renewable energy globally every year, a 600% increase over 2010 levels; and reducing the kilowatt-hour/square-foot energy intensity required to power Walmart’s buildings globally by 20% compared to 2010 levels.

Based on external estimates of projected energy costs and other factors, Walmart says the two new commitments will generate more than $1 billion annually in energy savings once fully implemented.

“When I look at the future, energy costs may grow as much as twice as fast as our anticipated store and club growth,” Duke said. “Finding cleaner and more affordable energy is important to our everyday low-cost business model, and that makes it important to our customers’ pocketbooks. Our leadership in this area is something our customers can feel good about because the result is a cleaner environment. And savings we can pass on to them.” w

New & Noteworthy

IRS: PTC Will Be Worth Slightly More In 2013

 

 

 

 

 

 

 

 

 

 

 

 

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