Bldg/Climate Solution: Train Uninformed Engineers/Engage Obstructionists by Net Zero Foundation+
Eliminate Carbon/GHG Emissions - Now Effectively-Free for all Buildings - Financing Ready -- #1o5C #ActOnClimate #AgeOfFreeEnergy #UpToUs
The Facts: Rapid Climate Action is obviously required (Fig 1 ), Net Zero Energy (NZE)/Zero Carbon Building technologies exist, and "Free" financing is available (savings>cost)! In our Winning 2016 Climate CoLab proposal, we showed "effectively free" NZ Carbon conversion/economic gain (Fig 2). NZE buildings are happening, some jurisdictions are mandating new NZE Buildings, and the U.S. DOE confirmed this new reality. "Green Financing" is now available and key leaders are promoting this new NZE Buildings/Economic Gain Reality.
Climate Solution: Technology/Financing for Climate Action could convert all Building Energy Systems to Zero Carbon in ~20 years - 5%/yr. Fully 37% of the entire U.S. GHG emissions can be eliminated. Combined with rapidly spreading EV's and PV/Wind Electricity, we can end over 60% GHG emissions in a very short time. The only GHG not easily eliminated is ~2% for commercial cooking. The net result (Fig 3) IS a 1.5°C Climate Solution if all Buildings are changed.
The Problem: The vast majority of building owners and engineers don't know Rapid Free Climate Action is available, including MIT!
The Solution: We bring turn-key "free" Building GHG Elimination projects to disrupt market stagnation. MIT's campus is a good corollary for buildings everywhere -- a collection of residential, office, food service, and light industry/"labs". Using MIT as a high profile Case Study, we show how to apply this breakthrough solution to drive rapid Climate Action.
We have communicated directly with MIT staff and faculty on this and discovered the same problems there as everywhere:
1) Uninformed Engineers, and
2) A Few Active Obstructionists.
Together, these cause Market Stagnation and lack of "interest". Saving Earth requires MIT and every campus/city to rapidly join in "Free" Climate Action via Buildings. Our fully financed plan is intended to break through these barriers.
Is this proposal for a practice or a project?
What actions do you propose?
We are in a New Age of Humanity where we can Effectively-Free transform our Buildings into Clean Energy Profit Centers with Zero GHG Emissions. To galvanize attention, this proposal includes a fully funded Zero Carbon Conversion for two Buildings at MIT to start them on this path -- an offer we are confident we can also bring to every College Campuses. This proposal is specifically meant to start the 20 year 100% GHG elimination from campus energy systems as in our 2016 proposal. Financing is offered by Generate Capital -- a clean energy infrastructure financing company co-founded by Climate Action Leader Jigar Shah, who also co-founded The Carbon War Room with Richard Branson "to immediately stop the business-as-usual systems and practices that proliferate carbon" and "stop global warming". This proposal is exactly that -- rapid 100% elimination of GHG Emissions from Building Systems other than cooking to help save our planet.
This is not a technology issue -- the technology is already proven and getting better. This "project" is to make sure Leaders in all our communities choose 'saving the planet' when there is also a profit for all. Zero Carbon Conversion creates profit as a 5-way Win for our communities by halting the flow of money for fossil fuels. The result: we all begin to enjoy Climate Stability and Economic Gain.
We use MIT as a case study for many reasons: it is a corollary for clusters of Buildings everywhere, a good example of what is blocking action, a location where significant public pressure can be brought to drive change, and an institution that could make a significant difference globally if they decide to Act. We first briefly explain 100% GHG elimination to catch all up on the latest Building Energy Systems Technologies. Then we will layout Who needs to act and what Actions they need to take. "Who", in the case of MIT/Boston, are the individuals and organizations listed in the box.
This is a Public Challenge for all to play their part in solving the "Uninformed Engineer/Active Obstructionist" problem and start rapid GHG elimination from all Buildings. We encourage everyone to engage the same individuals in your community so that we save our planet from serious Climate Change. It is #UpToUs!
NZE Buildings combine highly efficient Building Energy Systems (HVAC/lighting/etc) with Clean Electric Energy production (PV/Wind/Hydro/etc) to achieve a Zero Net Annual Energy use. This generally means a combination of rooftop or nearby PV electric generation, good windows/insulation, and Advanced HVAC Systems chosen for cost-effectiveness. NZE Buildings have been deployed for over 5 years, and the DOE has now declared NZE Buildings using PV and GHP (Geothermal Heat Pump HVAC) as "feasible with cost-effective applications of current technologies..across..the 8 U.S. climate zones". We cited one of the oldest NZE schools in our 2016 Climate CoLab Proposal, and we have secured involvement in this project of that Advanced Building Energy Systems engineer who has also already done GHP work in Cambridge.
Briefly, conversion of MIT or any buildings to Zero Carbon involves these steps as explained in depth in our 2016 Climate CoLab Proposal:
1) Energy Efficiency such as new windows, insulation, vestibules
2) Elimination of Steam/conversion to Advanced Thermal (GHP + Thermal Batteries)
3) Addition of PV and contracting remote PV/Wind for electricity
4) Optionally, addition of Electric Batteries for power time shifting.
All of these items are well proven, and items 1-3 are already "effectively free" and still decreasing in cost. PV is exponentially advancing at a pace absolutely nobody predicted, with Clean Power on a Moore's Law like trajectory. Advancing from NZE Buildings to Zero Carbon Energy means ensuring your electric power is all Clean Energy, now widely available -- MIT announced that it has begun this too.
Batteries are a big part of Zero Carbon Energy Systems. GHP is highly efficient because it uses the earth as a giant Thermal Battery to achieve 350%-500% efficiency -- each unit of electricity effectively "mines" 3-4 units of earth supplied thermal energy to yield these very high efficiencies. Our 2016 MIT proposal took GHP even further to "Advanced Thermal Energy Systems" adding tuned phase change batteries and more. Cost effective application of these technologies is taught in the Certified GeoExchange Designer (CGD) course; new tools for Advanced Thermal design are under development.
Electric Batteries, too, are experiencing a Moore's Law like exponential growth/cost reduction thanks to exponential growing EV sales, new giant battery factories like Tesla's Gigafactory, and new utility adoptions such as by Duke Energy who just delayed a natural gas Peaker Plant for at least 4 more years due to Advanced HVAC and Batteries[18,21]. Large "Flow Batteries" are under development including at MIT.
Zero Carbon systems with Heat Pumps powered by PV have overall efficiency trending to infinity after the PV is paid for -- think about that! After 20 years, the PV will be paid for yet still retain >90% capacity and likely has another 30 years effective life. After paid off, these Building Energy Systems have an effectively "infinite" efficiency less typical maintenance which is lower than other systems. We propose even further advancements well beyond what anyone else has implemented. This is a big deal!
Rapid Effectively-Free 100% GHG Elimination from Building Energy Systems is now available where Owners Act themselves or give permission to firms like Generate Capital who are ready to take Buildings to Zero Carbon with no additional expense. The challenge becomes "How do we make sure Owners are properly informed and any Obstructionists from the fossil fuel industry are blocked?"
We identified the list of players in the box above, and we will address each one here. We will be engaging directly with these parties, and strongly encourage everyone to do the same, both in Boston and your local community. "Free" change may seem easy, but Leaders must still Act or we will never gain the Climate Action Acceleration necessary to save our planet.
We will start by focusing on the Engineers who hold a key position in this challenge -- one we can readily solve.
The key issue blocking Rapid Free 100% GHG Elimination from Building Energy Systems is Uninformed Engineers. To change this, some jurisdictions are setting future deadlines for NZE Buildings, mainly focusing on new Buildings. But, no mandate includes Immediate Action for existing Buildings, thus this will not provide the Climate Action necessary to avoid large Climate Mitigation expense. Mandates are also easily challenged except in a few jurisdictions.
An alternative and one directly in line with PE's responsibility "to safeguard the life, health, property and welfare of the public" (PE Rules of Conduct), we strongly recommend all state legislatures make the following single change to their Professional Engineering statute:
- All Engineers designing HVAC and DHW systems shall inform the Building Owner in writing of the availability of non-GHG emitting alternatives that enhance overall Public Safety from Climate Change.
With this appropriate change to the PE code to assure sharing of information, the Market will be able to force rapid Action. Remember, 5% of all Building Energy Systems are upgraded every year (20yr system life), and this simple change could have an immediate and profound effect. To provide this information, PE's will have to learn of the alternatives and their costs, enabling owners to make cost-effective decisions that also save the planet. The PE coursework for this is already available from the Association of Energy Engineers.
MIT and many other campus/hospital sites get some of their electricity from a Combined Heat and Power (CHP) generator -- a fossil fuel turbine that costs a fortune, pollutes, and wastes a lot of energy. CHP was a great technology assuming no Climate Change, but now it is doomed to the dustbin of history to be replaced by exponentially advancing PV/Wind/Batteries and Advanced HVAC Systems that are over three times as efficient. Exponentially dropping Wind/PV/Battery costs will make CHP nearly obsolete in 20 years and fully obsolete by 2050. By incrementally changing from CHP/Steam to PV/Wind/Advanced HVAC over 20 years as proposed, the CHP plant will be used less and less extending its life. The proposed conversion of MIT's campus to Zero Carbon will maximally extend the new CHP plant's life so it can serve well after 20 years as a peaker-only plant, and will make its next replacement unnecessary. -- a major economic gain for all CHP sites. The CHP plant will also ease transition to Zero Carbon as we maximize its efficiency through Advance Heat Recovery.
To galvanize a focused response, we place the following specific proposal on the table for a near-term demonstration of Advanced Thermal/PV Systems, asking MIT to give us permission to:
1) Bring in expert financing and technical teams to initiate a full campus NZE System design,
2) Choose 1 or 2 target buildings (e.g., Bldg 1 on Mass Ave. and a dorm) which are ready for HVAC upgrades in high-visibility locations,
3) Complete a full Advanced Thermal and PV design for those buildings, and
4) Commence with conversion to Advanced Thermal HVAC and rooftop PV.
This proposal is explicitly focused to achieve a near term, high-profile demonstration. As above, Generate Capital has offered to finance this effort based on your existing energy cost structure. This proposal is specifically intended to help MIT and its engineers learn more about NZE/Zero Carbon system design and "effectively-free" economics. This is Step 1 for every campus ready to #ActOnClimate!
As the former U.S. Secretary of Energy, we are confident you know, or know the people who know, all the issues presented herein. ORNL's BTO has reported repeatedly on GHP and I'm sure you well know of NREL's SunShot and Zero Energy Buildings efforts. We have assembled a team of Advanced HVAC/GHP and DOE industry experts ready to help MIT and any campus take this step into the Energy Future, including Dr. Xiaobing Liu at ORNL who we are sure would confirm the veracity of this proposal. You might also find it interesting that, under our Geothermal Design Center firm, we just completed an SBV DOE funded effort with ORNL which resulted in new discoveries/cost reductions in the GHP field.
Please help MIT's administration recognize the accuracy and value of what we have presented! And, our congratulations on the amazing steps the DOE took under your leadership.
Who will take these actions?
(Continued from above)
Last year we discussed our proposed Zero Carbon conversion with you, and there was significant disbelief. Now the DOE, Bloomberg, and Generate Capital all confirm our claims.
We assembled a stellar expert team and financier, each key leaders in this field with way over 100 years combined experience so MIT can confidently move forward on Zero Carbon Systems.
MIT's Prof. Sterman well cited "pain before gain" as a barrier to taking transformative steps. But, this has "no pain" other than learning the about Advanced Building Energy Systems. "No pain" other than "having to learn" is not a legitimate excuse, certainly not at MIT where "learning” is the core principal. We hope you agree and MIT seeks to maintain its position as a Global Leader and help Boston and the whole planet not suffer damage from unchecked Climate Change. MIT should be a Leader on this and Act Now.
You hold powerful sway at MIT and may campuses with your generous financial contributions. However, the fossil fuel industry is now dying because of the natural progression of Technology where new and better is always the way. The Computer Industries have long seen this change at a pace you are just now facing. As Andrew Grove, co-founder of Intel, said in "Only the Paranoid Survive", you must change along with technology or fail. Let us strongly encourage you to realize this current and evolving reality, and to re-focus your interests to include Renewable Energy Technologies. This new field has a lot of room for financiers and technology developers, and you should make that move before the markets pass you by. Let us suggest that any effort to Actively Obstruct the Renewable Energy advances will only cause damage to your reputation and to those institutions, like MIT, that you may try to hold back.[23-29] As MIT alums, we hope you give this serious consideration for MIT's sake and heed Andy Grove's advise -- this is a true Win-Win for all once you realize change is inevitable.
Ex officio Board Members MA Governor Baker, MA Chief Justice, and Secretary of Education
The MIT alum on our team challenges the MIT Board to consider "why is MIT not involved in the planet-wide challenge to stop Global Warming?" Ex Officio Directors in leading government positions should strongly raise this question before asking the public to fund Climate Mitigation. It is wrong for the world's supposedly leading "engineering" university to not be fully involved in Global Climate Action. This avoidance will cause MIT to lose its global reputation, leave all coastal communities to suffer damage from Climate Change, and harm the reputation of all former MIT students.
It seem that as long as rich fossil fuel industry donors give to MIT it will take no Climate Action that may lead to elimination of fossil fuels. This issue is not limited to MIT as reports of other schools suggest similar fossil fuel industry influence.
Where will these actions be taken?
(Continued from above)
Advanced Electric and Thermal Building Energy Systems are important new technologies that researchers should embrace and implement before all the knowledge and patents are developed by others.
The Historic Energy Inflection Point we are at is a critically important story. We are transitioning from a society paying a small number of companies for all energy, to a society/planet mainly gathering energy from the sun and only "paying" for the machines that make it possible. It is a very far reaching change and deserves reporting to the public in a grand way. Bloomberg via BNEF.com is the only quasi mainstream outlet that seems to be addressing this. The Net Positive Wealth nature of NZE/Zero Carbon deserves much further analysis, forecasting, and reporting. We challenge all of you to take that step.
A few key facts: whole countries are now outlawing fossil fuels at a certain date; several automobile companies have already announced the end of fuel-based vehicle offerings. Add to that the historical note reported of the Easter Parade changing from horse and buggy to all automobiles in a very short 13-14 years.
We believe the "local communities" everywhere have a significant role to play in Climate Action. Significant funds are going to be spent on Climate Mitigation unless Rapid Climate Action/GHG Elimination occurs. MIT can and should be a significant global Climate Action Leader with effectively-free GHG elimination, but they appear to be uninterested. We suggest a loud voice from the local community would have a significant positive effect on MIT's Board and Administration. We all deserve to know whether MIT can be depended on to help solve our existential problems.
MIT Faculty and Staff
We were told directly that MIT could investigate 100% fossil fuel elimination only if the faculty and students created a "stampede" of interest. While it is not appropriate that this Leadership responsibility be put on your shoulders, it does show the power you have in your hands.
This Climate CoLab Proposal, in conjunction with our 2016 Proposal, is a roadmap to eliminate all GHG emissions from Buildings effectively for free, helping to end Damaging Climate Change, and building wealth locally in the process as we end the drain of the fossil fuel industry. Experts and financiers are ready to help every campus take this step. Get involved, and make sure our elected officials and non-profit leaders Act as well. With a few key Actions by our Leaders, we will have this Climate Problem solved.
Where will these actions be taken?
In the case of this specific proposal, the actions are for MIT's campus. However, the proposal is a guide for similar NZE/Zero Carbon Energy Buildings everywhere. DOE has confirmed feasibility of NZE buildings in all U.S. climate zones, and it is generally applicable everywhere.
In addition, specify the country or countries where these actions will be taken.
No country selected
No country selected
No country selected
No country selected
What impact will these actions have on greenhouse gas emissions and/or adapting to climate change?
Fundamentally, this proposal is about maximal elimination of GHG from all Sectors and Systems. Much advancement is occurring at a rapidly accelerating pace. This last week, there was an announcement of Steel Mills in AU being converted to 100% RE. With only the progress of 100% elimination of GHG from Buildings as presented in this proposal and even without the full scale of Electric Vehicle advancement that we are now seeing possible, we can readily eliminate at least 55% of GHG emissions within 20-25 years as shown in this modification of the U.S. Total Emissions Graph:
(This part is directly copied from our 2016 Climate CoLab Proposal regard the secific GHG reduction amounts as presented in the Fig 2 in the Introduction)
To estimate the converted GHG load without more detailed data, we instead assume the following: 1) the thermal systems (GHP, etc) must provide 50% of the annual campus energy load (heating/cooling/DHW == electricity used), 2) a GHP system with minimum total system COP=3.2 annualized average will be implemented, and 3) an average CHP/purchased GHG rate for electricity. A COP of 3.2 is very conservative - we intend to design to a higher figure. Based on Groode (2003, relative conclusion assumed):
Total MIT MTCO2e = 192,247
Total Plant MTCO2e = 160,108
Total MTCO2e due to Steam = 106,220
Total MTCO2e due to CW = 25,752
Total MTCO2e due to Generated Electricity = 29,665
Total MTCO2e due to Purchased Electricity = 30,667
Electricity Generated = 124.4M kWh/yr = 124.4K MWh
Electricity Purchased = 45.0M kWh/yr = 45.0K MWh
Total Electricity = 169.4M kWh/yr = 169,400 MWh/yr
Electricity for Thermal Load at COP 3.2 = 169,400 MWh/yr * (1/3.2) = 52,938 MWh/yr
CHP electricity GHG/Wh = 29,665 MTCO2e / 124.4K MWh = 0.24 MTCO2e/MWh
Purchased GHG/Wh = 30,667 / 45.0K MWh = 0.68 MTCO2e/MWh
Weighted Average GHG/Wh = 0.36 MTCO2e/MWh (rounded)
GHG from Thermal Load = 52,938 MWh/yr * 0.36 MTCO2e/MWh = 18,840 MTCO2e
GHG Savings = Steam: 106,220 + CW: 25,752 - GHP: 18,840 = 113,132 MTCO2e
GHP GHG Savings Total = 113,132 / 192,247 = 58.8%
The net savings by conversion from Steam and CW to GHP is over 50% of the total campus GHG emissions. We modeled a 25 year implementation period, but much faster implementation is possible. Additional GHG savings may be possible with phase-change thermal storage -- left out of this analysis for simplicity (reduces GHEX sizing and provides energy storage for excess grid PV/Wind).
What are other key benefits?
The key benefits of NZE/Zero Carbon Buildings is combined Economic Gains and Environmental Gains. Beyond that, since the elimination of fossil fuel from our Buildings and cars will reduce the U.S. GHG emissions by over 50%, it will also reduce the associated air pollution and health issues, and save the planet from Damaging Climate Change.
What are the proposal’s projected costs?
There is no effective direct cost to the action items we have identified for specific individuals. The only "costs" associated with this project are those for hardware system and building envelope upgrades. On the whole, the incremental portion of these expenses over normal building expenses are now known to be zero or negative -- i.e., the upgrades are "effectively free" and make money for the owner.
Again, please see our 2016 technically detailed Climate CoLab proposal for the technical details -- this proposal is specifically about the missing Leadership needed to move Climate Action forward. There are no direct costs to Leadership!
Who will help MIT take these actions?
The team of 4 experts we assembled to bring to MIT is stellar -- The Mechanical Engineer who has completed multiple NZE schools and who has already been called in on systems in Cambridge, the foremost Standing Water Column GHP well designer/contractor who wrote the ANSI/CSA/IGSHPA C448 Standard's section on those wells and has done extensive work in Cambridge and has also already been on campus to discuss this proposal, the Advanced Thermal Systems designer/contractor/driller who has already taken another campus to Net Zero Energy/Zero Carbon, and the leading forensics expert in the Advanced Thermal Systems field. This team of experts, collectively with well over 100 years experience in this field and being 4 of the top 10 experts in the whole field, has also confirmed the bold "effectively free" claims we have made. MIT can confidently move forward with this team and learn a whole lot in the process.
Conversion of Building Energy Systems from fossil fuel based to NZE and Net Zero Carbon is a multi-aspect process including Energy Efficiency (new windows, insulation, vestibules, etc.), HVAC and DHW (potable hot water) Systems conversion to Advanced Thermal Systems, and addition of PV for electricity. These are each separate items which can be scheduled in general to match existing building maintenance and upgrade schedules. The longest of these normal building system cycles and the more difficult to budget is the periodic upgrading/replacement of HVAC systems. HVAC includes all of the heating and cooling and ventilation systems in a building, and they are very large consumers of energy. One basic fundamental about HVAC systems is that they are built with motors, fans, and compressors -- all components that wear out in about 20-25 years with normal maintenance.
Thus, about every 20 years or so every building owner expends a large amount of money to upgrade every HVAC system in every building. This purchasing is a huge ongoing expense for all buildings for which there are three (3) key parts:
1) The purchase cost of the equipment -- typically financed to spread it over many years,
2) Ongoing operation cost being the cost of the fuel or electricity being consumed for its operation,
3) Ongoing maintenance costs: maintenance department payroll, replacement parts, etc.
In the case of MIT, this cycle is currently heavily dominated by the need to replace the CHP (Combined Heat and Power) turbine every 20 years -- it is already being replaced now at the cost of many millions of dollars and will have to be replaced again in about 21 years unless something is done to end this cycle.
Cost-Effective Timing Desired
Implementation of Net Zero/Zero Carbon Energy Systems is most cost-effective when synchronized with the normal building HVAC equipment upgrade cycle. Thus the "normal" upgrade expense is not a part of the incremental cost associated with the more advanced technologies, and thus does not affect the cost-effectiveness calculation for choosing the advanced approach over a regular required upgrade.
About the author(s)
This proposal was written by the MIT/Purdue alum co-founders of Net Zero Foundation, a 501c3 nonprofit dedicated to Scientific understanding and Education regarding how to eliminate enough GHG producing emissions from Energy to solve our Climate Change problem. We are also owners of a licensed Professional Engineering firm, a licensed Mechanical Contracting firm (HVAC), and a Product Engineering firm. Our focus has always been successful deployment of Renewable Energy (RE) which we have intuitively realized is a multi-faceted economic and climatologic solution -- recent findings by many others as shown herein have proven we are correct about RE.
The power of the current RE Technology Market is significant. We have been creating RE products since the 1980's when we built an early east-west tracking parabolic trough solar collector meant to be a hybrid thermal/electric system. Along the way, we have watched the RE market take a rollercoaster ride up and down, with the actions of various presidents significantly making the up/down difference. It is exciting to now see RE move past politics to the strong point where even withdrawing from the Paris Accords will not stop the RE industries - PV, Wind, Batteries, GHP, etc.
For those interested in getting involved in our RE product developments, we will post all public investment offerings on our Intelli-Products Inc. website. We are co-inventors of an Advanced Robotic PV Array Assembly System which includes solutions for fixed mount tracking PV and tracking solutions for floating arrays as well. We see PV and GHP as two of the key planet-saving technologies, and we are proud to be doing our part to accelerate their deployment.
Our 2016 Judge's Choice MIT Climate Mitigation Solutions 2016 proposal showed how MIT could go carbon-free and become a Global Climate Action Leader by implementing a simple and "free" set of engineering solutions to MIT's campus Buildings, and advancing the Curriculum and General Knowledge on Campus in specific ways. As said above, it seemed we were saying things that almost no one even believed were true. Thankfully, now others including NREL, New Buildings Institute, Bloomberg have figured out NZE is exactly as we showed. The only difference between NZE as others have grasped and Zero Carbon is you must use only non-fossil based Clean Electricity Power. And now, you can readily contract all your electric power to be from PV, just as MIT has already partially done.
The key difference between our 2016 proposal plus this one and what every else it attempting involves two significant advances. First is the Whole Campus nature of the Zero Carbon solution at the front edge the Advanced Thermal Technologies field. The Advanced "chiller-loop overbuild" we proposed has not been tried, as far as we know, except by one small school in Utah. This is a breakthrough concept that needs maturing and development of associated design tools for use elsewhere. We have proposed this to the DOE, but now expect no support there. Instead, we are proceeding with this current fully-funded proposal under the hope we can use the MA Clean Energy Center "rebate" funds ($250K-$500K per year) to get MIT's "Whole Campus" system rough designed plus develop the tools to replicate that level of design everywhere else.
The second key advancement we presented in 2016 and are now researching under Geothermal Design Center (in cooperation with ORNL) is the use of thermally tuned modular thermal batteries. The point is that one can gain significant reduction in GHEX and other infrastructure size and thus lower cost if you can handle all short-term thermal demand spikes locally, at or near the Building level. Our goal is to bury small, probably salt-based, thermal batteries under sidewalks and around Buildings to achieve a level of efficiency never before achieved. This is another reason we are approaching MIT as our idea target because we know MIT will take such advances as opportunities for further research and even possible breakthrough.
With a floor goal of eliminating 37% of all GHG emissions just from Buildings as cost-effectively as possible so it is "free" and accelerating, we need to find all the efficiencies possible.
19 See #2 above
40 NASA: CO2