webinar: proposed government–provided incentives to promote the capture and use of co2 for eor:...

Proposed government–provided incentives to promote the capture and use of CO2 for EOR: Options for incentivising large–scale CCS/CCUS projects in budget constrained times

Webinar – 26 June 2013, 0600 AEST

Judi Greenwald

Judi Greenwald is the Vice President for Technology and Innovation at the Center for Climate and Energy Solutions. She oversees the analysis and promotion of innovation in the major sectors that contribute to climate change, including transportation, electric power, buildings, and industry. Ms. Greenwald focuses on technology, business, state, regional, and federal innovation. She is a member of the Advisory Council of the Electric Power Research Institute and served on several National Academy of Sciences panels studying vehicles and fuels. She also served on the Resource Panel for the northeast Greenhouse Gas Initiative and the California Market Advisory Committee, and as a policy advisor to the Western Climate Initiative and the Midwest Greenhouse Gas Accord Advisory Group. She was previously the Vice President for Innovative Solutions at the Pew Center on Global Climate Change, C2ES’s predecessor organization.

Ms. Greenwald has over 30 years of experience working on energy and environmental policy. Prior to coming to the Pew Center, she worked as a consultant, focusing on innovative approaches to solving environmental problems, including climate change. She also served as a senior advisor on the White House Climate Change Task Force. As a member of the professional staff of the U.S. Congress Energy and Commerce Committee, she worked on the 1990 Clean Air Act Amendments, the 1992 Energy Policy Act, and a number of other energy and environmental statutes. She was also a Congressional Fellow with then-Senate Majority Leader Robert C. Byrd, an environmental scientist with the U.S. Nuclear Regulatory Commission, and an environmental engineer and policy analyst at the Environmental Protection Agency.

Ms. Greenwald has a Bachelor of Science in Engineering, cum laude, from Princeton University, and an M.A. in Science, Technology and Public Policy from George Washington University.

Patrick Falwell

Patrick Falwell is a Solutions Fellow for the Center for Climate and Energy Solutions, where he reports to the Vice President for Technology and Innovation. Mr. Falwell analyzes clean energy and climate change policy at the state and federal level. He also monitors nationwide clean energy market developments and identifies opportunities to support clean energy growth.

Mr. Falwell holds a Masters of Arts in International Economics and Energy, Resources, and the Environment from the Johns Hopkins School of Advanced International Studies and an undergraduate degree from Georgetown University. He previously worked as a research analyst for the U.S. Bureau of Labor Statistics (BLS) and the Consumer Price Index (CPI), where he conducted analysis of consumer expenditure behavior and national inflation data.

Ben Yamagata

Ben Yamagata is a Partner at the Van Ness Feldman Law Firm and the Executive Director of the Coal Utilization Research Council – a coalition of industry and educational institutions with an interest in promoting clean coal technology.

Mr. Yamagata’s practice encompasses federal and state legislative and administrative issues in the areas of energy, environment, natural resources, international trade (technology transfer and independent power project development), and transportation-related matters.

Mr. Yamagata represents clients before the Departments of Energy, Commerce, Transportation, Defense and State, as well as the Office of Management and Budget and the Environmental Protection Agency, on both project-specific and programmatic issues that relate particularly to technology research, development, demonstration, and deployment relating to the use of coal and other fossil and renewable energy resources. Mr. Yamagata has advised clients on energy and environmental technology projects as well as provided counsel and representation in the structuring and advocacy for government programs such as the Department of Energy’s clean coal technology development and demonstration programs and financial incentive programs (e.g., loan guarantees and clean coal tax credits) that were authorized as part of the Energy Policy Act of 2005.

Mr. Yamagata is a graduate of Harvard College and the George Washington University National Law Center University.

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A Diverse Coalition Recommends Incentives to Accelerate Commercial Deployment of EOR Using Captured CO2

Webinar for the Global Carbon Capture and Storage Institute

June 25, 2013

Presenter:Judi Greenwald, Vice President for Technology & Innovation Center for

Climate and Energy Solutions

Overview of presentation

• What is CO2-EOR?

• What is NEORI?

• What does NEORI recommend?

How does CO2-EOR work?

Commercial CO2 use in enhanced oil recovery is happening now, and it’s bigger than most people realize.

Background on CO2-EOR

• The CO2-EOR industry has 40 years of commercial operational experience (beginning at significant scale in West Texas in 1972).

• Today, CO2-EOR produces nearly 300,000 barrels of oil per day (100 million barrels annually), or about 6 percent of U.S. domestic production. Source: Melzer, 2012

10

Map of Current U.S. CO2-EOR Activity

Why is CO2-EOR so important?

• Energy SecurityoCan at least double U.S. reserves (20 billion barrels)o27 to 62 billion barrels with existing technology, 67 to 137

billion barrels with next generation techniques

• Economic Opportunityo Job creation, increased tax revenues, reduced U.S. trade

deficit (cumulatively) by $600 billion by 2030

• Environmental ProtectionoReduce U.S. GHG emissions by 10-20 billion tonsoDrive innovation in carbon capture and storage technologyoProduce oil with less environmental impact

Project Participants & Observers

Coal and Coal-Based Generation• Arch Coal• Basin Electric Power Cooperative• Summit Power Group• Tenaska Energy

Industrial Suppliers of CO2/Technology Vendors• Air Products• Alstom• Archer Daniels Midland• C12• GE Energy• Jupiter Oxygen• Linde• Praxair

Project Developers• Leucadia Energy

Environmental NGOs• Clean Air Task Force• Natural Resources Defense Council• Ohio Environmental Council• Wyoming Outdoor Council

Labor• AFL-CIO• United Transportation Union

State Officials• Illinois, Indiana, Michigan, Mississippi, Montana, New Mexico, Texas

and West Virginia

Academic Institutions• Enhanced Oil Recovery Institute (University of WY)

Observers• Oil and Gas

– Chaparral Energy– Core Energy– Tellus Operating Group

• Associations– Interstate Oil and Gas Compact Commission

1. Recommend and advocate for incentives and other policies to support commercial CO2-EOR deployment that are self-financing through revenues from additional incremental oil production.

2. Prepare key analyses to inform and support incentive policies for anthropogenic CO2-EOR

And…

NEORI’s Three-Part Agenda

3. Increase policy-maker, media, and public awareness of CO2-EOR, its benefits and the need for deployment incentives.

NEORI’s Three-Part Agenda

“We have endorsed, for example, the National Enhanced Oil Recovery Initiative’s recommendation that Congress create a production tax credit for power companies that capture CO2 from power plants and send it to oil companies to use to free trapped crude from underground rock formations.”

- October 17, 2012

Consensus recommendations released February 2012

• Incentives to use captured CO2 in EORo Federal

• Reform of existing Section 45Q tax credit

• Expanded 45Q program with added provisions

o State• Model state incentives

NEORI report available at: neori.org

– A bipartisan group of Members of Congress welcomed NEORI’s recommendations

– This translated into the Conrad (D-ND)-Enzi (R-WY)-Rockefeller (D-WV) bill incorporating NEORI’s 45Q reform recommendations

– Proposed improving functionality and transparency of existing program; helpful for obtaining private financing

– Renewed bipartisan interest in the new Congress

Conrad-Enzi-Rockefeller bill (S. 3581) introduced September 2012 on 45Q Reform

NEORI recommends an expansion of the 45Q program with new provisions

• Bridge the cost gap between what CO2-EOR operators are willing to pay and the cost of capture

• Credit goes to those who capture, but only once the CO2 is used for EOR

• More than pays for itself because: – CO2 captured with incentive incremental oil production

new sales revenue new tax revenue (under existing tax treatment)

• No change in existing tax treatment for oil

• Combine federal incentive with CO2 market price

Proposed 45Q expansion provisions

• Credits allocated for 10 years per project• $/ton of CO2 used in EOR • Two design objectives

– Minimize costs– Drive innovation

• Competitive bidding/reverse auction• Divided into tranches and sub-tranches for different CO2

sources• Provision to adjust annual tax credit value based on

changes in the price of oil

Tranche structure of 45Q expansion

• Tranches and sub-tranches– Pioneer (first mover)

• Power• Industrial

– Power– Industrial

• Low cost industrial• High cost industrial

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More anthropogenic CO2 can become available at higher prices . . .(Illustration with EIA 2011 data)

Power plant CO2 supply potentially larger

21

More anthropogenic CO2 can become available at higher prices . . .(Illustration with EIA 2011 data)

Power plant CO2 supply potentially larger

22

Incentives are needed to cover the “cost gap” between EOR operator willingness to pay and the cost to capture and transport CO2, especially for the larger man-made sources of CO2 . . .

Core Scenario + Transp. Costs

CO2 Market Price (*Starting 2013,

Willingness To Pay)

Representative EOR Incentive (for

illustration purpose) (A) (B) (A-B)

Power Plant Tranche ($/tonne) ($/tonne) ($/tonne)

Pioneer - First of a Kind Projects $70 $33 $37

Projects #2-#5 $60 $33 $27

Nth of a Kind (Projects #6-onward) $55 $33 $22

Industrial - Low Cost Tranche ($/tonne) ($/tonne) ($/tonne)

Pioneer- First of a Kind Projects $38 $33 $5

Projects #2-#5 $38 $33 $5


Industrial - High Cost Tranche ($/tonne) ($/tonne) ($/tonne)

Pioneer- First of a Kind Projects $65 $33 $32

Projects #2-#5 $55 $33 $22


Analytical Study

• “Cost gap” analysis– Determine difference between willingness to pay by EOR

operators and cost of carbon capture, storage and transportation• “Revenue neutrality” analysis

– Compare cost of new CO2-EOR incentives with new federal revenues directly resulting from incremental new CO2-EOR production in the form of royalties on Federal lands plus severance and corporate income taxes.

Analysis suggests “revenue neutrality” within 10-year window and significant net positive revenues over long term

Program revenues greatly exceed costs over time…

State-level Recommendations

Model complementary policies to federal incentives• Severance tax reduction and/or extension of existing severance tax

reduction for oil produced with CO2 from anthropogenic sources. • Cost recovery approval for regulated entities. • Off-take agreements. • Tax credits, exemptions, or abatements for CO2 capture

• State-level bonding of CO2 pipeline projects and/or capture and compression facilities.

• Inclusion of CCS with EOR in electricity portfolio standards.

See full report to see examples from specific states

Adjusting annual tax credit values based on oil price changes

• NEORI recently adopted a mechanism to adjust annual tax credit values based on oil price changes

• When oil prices rise, the tax credit value falls– Reduces the federal support when market conditions are more favorable

• When oil prices fall, the tax credit value rises– Ensures that a project developer receives a sufficient incentive when CO2

sales revenue falls

• If legislative scorekeepers assume oil prices will rise over time, this provision could help with scoring

Adjusting annual tax credit values based on oil price changes

• The 113th Congress could consider 45Q expansion in the context of tax reform

• Many states can act

• You can help

Prognosis

CONTACTS:

Judi Greenwald, C2ES(703) 516-4146

[email protected]

Brad Crabtree, GPI(701) 647-2041

[email protected]

www.neori.org

mailto:[email protected]


BACK-UP SLIDES

U.S. Department of Energy (2011), Improving Domestic Energy Security and Lowering CO2 Emissions with “Next Generation” CO2-Enhanced Oil Recovery (CO2-EOR), DOE/NETL-2011/1504, citing Advanced Resources International (2011). 31

Source Type (Location) CO2 Supply (Mt/year) Natural Anthropogenic

Colorado, New Mexico (Geologic) 33 - Texas (Gas Processing) - 6.4 Wyoming (Gas Processing) - 6.6 Mississippi (Geologic) 22 - Oklahoma (Fertilizer Plant) - 0.7 Michigan (Gas Processing) - 0.3 North Dakota (Coal Gasification) - 3

Total 55 17

Current CO2 Supply for EOR

• Some CO2 for EOR already comes from industrial sources

• Today, the U.S. EOR industry uses 72 million tonnes of CO2 per year — profitably and without serious reported injuries, accidents or environmental harm.

CO2-EOR production doubles within 20 years…

NEORI Analysis suggests significant oil production and revenues over time…

Time Phase

Cumulative Incremental CO2-EOR

Oil Production (Barrels)

Cumulative Net Present Value ($)

CumulativeCO2 Storage

(tonnes)

2013-2022 400 million $2 billion

~4 billion2023-2032 2.5 billion $31 billion

2033-2042 6 billion $73 billion

2043-2052 9 billion $100 billion

Oil production potential from CO2-EOR is vast…

Source: U.S. Department of Energy (2011), Improving Domestic Energy Security and Lowering CO2 Emissions with “Next Generation” CO2-Enhanced Oil Recovery (CO2-EOR), DOE/NETL-2011/1504.

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Incremental Technically Recoverable Oil

(Billion Barrels)

Incremental Economically Recoverable Oil

(Billion Barrels)

Best Practices Next Generation Best Practices Next Generation

Lower 48 Onshore 55.7 104.4 24.3 60.3

Total 61.5 136.6 29.6 67.2

Projected CO2-EOR Resources:

• An additional 26-61 billion barrels of oil could economically be recovered with today’s EOR technologies, potentially more than doubling current U.S. proven reserves.

• Moreover, “next generation” EOR technology could yield substantially greater gains, potentially increasing recoverable domestic oil from EOR to 67-137 billion barrels, and storing 20-45 billion metric tons of CO2 that would otherwise be released into the atmosphere in the long term.

Enhancements to 45Q Tax Credit

To avoid stalling important commercial CO2 capture projects under development, there is an urgent need to improve the functionality and financial certainty of the 45Q federal incentive. Key Elements:

• Designate the owner of the CO2 capture facility as the primary taxpayer; • Establish a registration, credit allocation, and certification process; • Change the recapture provision to ensure that any regulations issued

after the disposal or use of CO2 shall not enable the federal government to recapture credits that were awarded based on regulations that existed at that time; and

• Authorize limited transferability of the credit within the CO2 chain of custody, from the primary taxpayer to the entity responsible for disposing of the CO2

Existing state-level policies to support CO2-EOR/CCS

Proposed Government-Provided Incentives to Promote the Capture and Use of CO2 for EOR

GCCS Institute Webinar - June 25, 2013

Ben YamagataCoal Utilization Research Council

(CURC)

ADA-Environmental SolutionsAir Products and ChemicalsAlpha Natural ResourcesAlstom Power, Inc.American Coal Council American Coalition for Clean Coal ElectricityAmerican Electric Power**Anglo American Thermal CoalArch Coal, Inc.*The Babcock & Wilcox CompanyBattelle/Pacific Northwest National Laboratory Caterpillar Global MiningCenter for Coal Technology Research Cloud Peak Energy**CONSOL Energy, Inc.Duke Energy ServicesEdison Electric Institute (EEI)Electric Power Research Institute (EPRI)Energy Industries of OhioFutureGen Industrial AllianceGlobal CCS InstituteGeneral Electric CompanyThe Greater Pittsburgh Chamber of CommerceIllinois Coal AssociationIllinois Department of Commerce and Economic OpportunityKentucky Coal AssociationKentucky Office of Energy Policy

LG&E Energy

Mitsubishi Heavy Industries AmericaLehigh UniversityThe Linde GroupNational Rural Electric Cooperative AssociationOhio State UniversityPeabody EnergyPennsylvania Coal AlliancePenn State UniversityPraxair, Inc.Pratt & Whitney RocketdyneSchlumberger Carbon ServicesSouthern Company*Southern Illinois UniversityState of Ohio, Air Quality Development AuthorityTenaska, Inc.Tri-State Generation & Transmission AssociationUnited Mine Workers of AmericaUniversity of KentuckyUniversity of North Dakota’s Energy & Environmental Research CenterUniversity of Texas @ AustinUniversity of UtahUniversity of WyomingWest Virginia Coal AssociationWest Virginia UniversityWestern Research InstituteWyoming Mining Association

Who Are CURC’s Members?

Companies in red indicate 2013 Steering Committee Members* CURC 2013 Co-chairs ** CURC 2013 Vice-Chairs

Over time the electricity mix shifts toward natural gas and renewables, but coal remains the largest fuel source

Realities --• Coal provides reliable, affordable power to the US population and economy• Abundant and inexpensive natural gas, stringent and expensive

environmental regulations, and projected tepid growth in demand is resulting in retirements/idling of coal and replacement, if any, with natural gas

• A requirement to reduce CO2 emissions from existing units may mean more retirements

Why the 3-Part Program --Coal – a primary energy resource -- is essential to the US economy. This proposal defines the application of technology as the way to insure the use of coal

Based on DOE/EIA AEO 2013er

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Address efficiency, reliability, flexibility of the existing coal

fleet; improve/apply CO2 & other criteria pollutant mitigation measures

Near term program –

Existing coal fleet

Financial incentives program to encourage coal-fueled facilities (CTL, SNG, chemicals, electricity) to capture and use CO2 to recover crude oil

Through accelerated permitting and regulatory clarification incentivize the construction of advanced coal power plants that will install CCS when commercially available

RD&D program to improve today’s coal-use technologies (“evolutionary” technologies)

Initiate R&D programs for transformational technologies (“revolutionary” technologies)

Long term program–

Technologies for the future

A 3-Part Technology Program to take Coal from 2013 to 2050 & Beyond

2013 2025 2050

Mid term program –

Encourage new coal builds using state-of-the-art technologies

CU

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Tech

nolo

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Address efficiency, reliability, flexibility of the existing coal

fleet; improve/apply CO2 & other criteria pollutant mitigation measures

Near term program –

Existing coal fleet

Financial incentives program to encourage coal-fueled facilities (CTL, SNG, chemicals, electricity) to capture and use CO2 to recover crude oil

Through accelerated permitting and regulatory clarification incentivize the construction of advanced coal power plants that will install CCS when commercially available

RD&D program to improve today’s coal-use technologies (“evolutionary” technologies)

Initiate R&D programs for transformational technologies (“revolutionary” technologies)

Long term program–

Technologies for the future

The Mid-term Program for CO2 recovery

2013 2025 2050

Mid term program –

Encourage new coal builds using state-of-the-art technologies

The CO2 Benefit from Improved Plant Efficiency

43

Each one percent Improvement yields two percent less CO2 emitted

Note: the “supercritical” units at 39% to 40% net efficiency up to 42% are also often defined as “ultra supercritical” units; A-USC are “advanced ultra supercritical”

Source of chart: Babcock Power

10 GW ultra supercritical program

10 GW Advanced Coal Power Plant Projects with Subsequent CO2 Capture Installation

Key Objectives of the Advanced Coal Power Plant Program:

• Facilitate the early construction and operation of advanced coal plants that achieve ultra supercritical temperature & pressure conditions (40+% conversion efficiency)

• Equip with advanced pollution controls to achieve near zero emissions (fitted with advanced clean coal technologies)

• Committed to installing carbon capture systems when such technology is deemed commercially available

Mechanisms that could be authorized to provide incentives for the construction of ultra supercritical power plants:• “safe harbor” for qualifying advanced

coal plants so that once constructed they are not subject to additional regulatory requirements

• accelerated permitting and mechanisms to minimize regulatory delays

• tax incentives granted if carbon capture system is installed on the new unit at time of initial construction

How Does the Program Work?

The tax receipts and other royalty revenues received by the federal government for the crude oil recovered by use of coal-derived CO2 is sufficient to help offset the financial incentive that would be provided to the CO2 capture entity participating in this program.

The CURC Accelerated CO2/EOR Program

What is the CO2-EOR Program? It is a coal-based demonstration program (5-10 GW(e)) that provides financial assistance for carbon dioxide capture from existing or new coal fueled facilities for sale and use in domestic enhanced oil recovery (EOR) operations.

Today – Capture Costs Greatly Exceed the Price Oil Producers Can Pay

46

Source: DOE/NETL CO2 Capture and Storage RD&D Roadmap, December 2010.

PROBLEM: $20-40/ton payment for CO2 by EOR producer does not cover $70-100 capture cost

Key Features of the Accelerated CO2/EOR Program

• 10 years and 5 to 10 GW(e) of facilities using coal

• Can be used to support on-going CCS demonstrations, next set of plants using current CCS technology & new technology from the CURC/ERPI Roadmap

• Focused only on new & existing coal (and pet coke) projects that capture CO2 for EOR

• Qualifying projects receive assistance for 15 years

• Limited to the CO2 capture system-only for retrofit or greenfield projects

• Injection wells classified as Class II EOR wells for purposes of a UIC permit under the SDWA

• Tax receipts/revenues and royalties identified to support (“pay for”) the CO2 subsidy – no added taxes o Cumulative federal taxes and royalties received

will “pay back” incentives provided in about 10 years for retrofit and 5-6 years for greenfield cases (initial federal funding required)

o Cumulative federal revenues are 3-5 times the cumulative subsidy in nominal dollars after 30 years

Captured CO2 Sold for EOR for Energy and Jobs

Domestic Oil Supplies and CO2 Demand (Storage) Volumes from “Next Generation” CO2-EOR Technology

Benefits of CO2-EOR

• Improves Balance of Trade$3.5 trillion over 60 years

• Promotes Energy SecurityReduces imports by 2 MMbpd1

• Increases Domestic Activity $60 Billion/year (wages, royalties, taxes, profits)1

• Creates Jobs622,000 new jobs1

1 Source : NETL Report, “Improving Domestic Energy Security and Lowering CO2 Emissions with “Next Generation” CO2 EOR,” June 2011

Alternative to a Fixed Subsidy or Tax related incentive: A Variable Subsidy

CO2 prices are linked contractually to oil prices

Uncertainty in future oil prices (and, thus, CO2 revenue) affects financing, increasing cost of capital for these capital-intensive projects

Fixed subsidy could over- or under-subsidize project depending on future oil prices

Variable subsidy reduces CO2 price risk and facilitates project financing, thus reducing capture cost and required subsidy

Potential for direct payment to government in addition to “income tax and royalty” revenue

CURC Accelerated CO2/EOR Program jointly developed by CURC and CONSOL Energy (Dr. Frank Burke)

Structure of Bid

Applicant bids on a subsidy for CO2 capture for EOR

Bid consists of two elements which are known to the project developer

• CO2 strike price based on the project’s revenue requirement for CO2 capture

• Rate (CO2 price as a function of oil price) used to calculate a CO2 market price based on a publicly available oil price index (e.g., West Texas Intermediate (WTI) crude)


Subsidy/Repayment Mechanism

At a calculated market CO2 price below the strike price, the project receives a subsidy based on the difference between the strike price and the market price

At a calculated market CO2 price above the strike price, the project pays the government an amount based on the difference between the market price and the strike price

Subsidy/repayment would be reconciled over some period (annually?) CURC Accelerated CO2/EOR Program jointly developed by CURC and CONSOL Energy (Dr. Frank Burke)

Conclude discussions within the CURC membership about the form and substance of the legislative provisions that could be considered to effectuate the 3 Part Program

Continue discussions with interested Members of Congress and staff to determine potential support for some, or all, of the

3 Part Program

Next Steps for the CURC 3 Part Program & the CO2/EOR programs

Thank you

Contact information:Ben Yamagata202-298-1800www.coal.org

Examples of how the Variable Subsidy would work

Attachments

Example: Case 1CO2 Strike Price Bid, $/tonne $60

CO2/Oil Price Rate Bid*, % 2.00%

Oil Price Index, $/bbl

Calculated CO2

market price, $/tonne

Subsidy / Repayment, $/tonne CO2

60 $23 $37

80 $30 $30

100 $38 $22

120 $45 $15

140 $53 $7

160 $61 ($1)

180 $68 ($8)

* In the CO2/Oil price ratio, the CO2 price is in units of $/MCF and the oil price is in units of $/bbl. If oil is $100/bbl, for example, the CO2 price in this example is $2/MCF, or $38/tonne.


Example: Case 2

CO2 Strike Price Bid, $/tonne $50 CO2/Oil Price Rate Bid, % 2.5%


Calculated CO2

market price, $/tonne


60 $28 $22

80 $38 $12

100 $47 $3

120 $57 ($7)

140 $66 ($16)

160 $76 ($26)

180 $85 ($35)


Example: Case 3

CO2 Strike Price Bid, $/tonne $60

CO2/Oil Price Rate Bid, % $0.5 + 2.5%


Calculated CO2 market price,

$/tonne


60 $38 $22

80 $47 $13

100 $57 $3

120 $66 ($6)

140 $76 ($16)

160 $85 ($25)

180 $95 ($35)


Comparison of Bids

Case 1 2 3CO2 Strike Price Bid, $/tonne $60 $50 $60

CO2/Oil Price Rate Bid, % 2.00% 2.50% $0.5 + 2.50%

Oil Price Index, $/bbl Subsidy / Repayment, $/tonne CO2

60 $37.27 $21.59 $22.12

80 $29.70 $12.12 $12.65

100 $22.12 $2.65 $3.18

120 $14.55 ($6.82) ($6.29)

140 $6.97 ($16.29) ($15.76)

160 ($0.61) ($25.76) ($25.23)

180 ($8.18) ($35.23) ($34.70)


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