To get your started, here’s some more information about each of our video topics.
Who needs the NED gas?
Currently Energy North/Liberty Utilities is the only NH local distribution company (“LDC”) to sign an agreement with TGP/KM for NED capacity. That agreement is for 115 dekatherms or 0.115 bcf/d. Therefore the current and future NH demand is currently 9% of what TGP/KM has proposed to supply.
Further, Liberty Utility’s agreement is not solely for new capacity. 0.05 bcf/d of their 0.115 bcf/d contract is to replace existing capacity from Dracut, MA. Therefore Liberty’s need falls to a mere 0.065 bcf/d or 5% of what TGP/KM has proposed to supply.
Does New England need every pipeline proposed? What will happen to our rates when we ultimately must pay for the construction of all of these projects?
The idea of a future “energy cost crisis” brought on by a failure to build enough infrastructure to keep up with power demand is a scary prospect indeed. But new information – quietly released by grid operator ISO New England – paints a vastly different, more optimistic picture of our energy situation. Demand for energy from our power grid is not going up. It is going down.
What is KM saying about the need for the NED gas?
Tennessee Gas Pipeline/Kinder Morgan (“TGP/KM”) claims there are pipeline constraints which limit the gas flow into New England and cause high electric rates. In fact they go so far as to use the term, “energy crisis”. This misleading information fails to mention that the pipeline constraints are not 24 hours a day or 365 days a year. Rather, they occur only for a few weeks during the coldest parts of winter. Therefore NED would deliver excessive yearly amounts of gas far beyond any current or future needs of New England.
TGP/KM claims the NED pipeline is in response to an “energy crisis” in New England and continues to say that New England pays some of the highest electricity rates in the country. Before falling for these misleading statements, recall from above that the only NH subscriber to the NED pipeline is Liberty Utilities. Liberty Utilities supplies heating fuel to homes and business. Despite two years of KM’s efforts, not a single contract has been signed under NED for the generation of electricity. One would assume that if there really was an “energy crisis” in New England, it would not be so difficult to find power plant subscribers.
What message do we want to convey?
There is no need for this pipeline to meet New England’s energy needs. Many other options are available that can provide cheaper solutions.
- A 30-inch pipe at 1,460 PSI delivers 1.3 billion cubic feet (BCF) of gas per day. Projected need is 0.6 BCF.
- The Maritimes and Northeast Pipeline currently runs southward from the Canadian provinces of Nova Scotia and New Brunswick to Dracut, Mass. Spectra Energy which owns this pipeline has asked for and been granted permission to reverse the direction of flow in this pipeline so that it travels northward from Dracut to Nova Scotia and New Brunswick. Terminals in New Brunswick and Nova Scotia have applied for and received export licenses for their terminals. The terminal in New Brunswick (Canaport LNG) alone can export 1.2 BCF per day. The price of natural gas in Europe is three times the US price and the price in Asia is five times the US price. If gas is exported, we will have to compete with higher European and Asian prices if we want any of the gas to stay here in New England.
It’s possible that the projected future need of 0.6 BCF/day could be met or eliminated without NED by:
- Further investment in energy efficiency to lower demand.
- Further investment in renewables such as solar and wind power.
- Plugging leaks in existing natural gas infrastructure (although loss from production and distribution systems is declining). Companies are responsible for monitoring and reporting their own leaks; no federal, state, or independent agency is involved.
- Imported liquefied natural gas (LNG) during peak-demand periods. Two or three tankers would be sufficient.
- Similar projects from KM competitors, especially Access Northeast from Spectra Energy.
None of these options has been thoroughly investigated or analyzed as an alternative to NED by KM, TGP, or FERC (the federal agency responsible for permitting the project) even though all these parties are required to do so by the National Environmental Policy Act (NEPA).
KM has said the project will yield about 3,000 jobs. Most are temporary and many will be staffed by workers from other parts of the country. About 50 permanent jobs will be created. In Massachusetts, spending what it will cost to build NED on alternative energy projects would create 24,000 permanent jobs, all local.
- “No Need For NED,” NH Pipeline Awareness Network.
- “Natural Gas Infrastructure And Electric Generation: Proposed Solutions For New England,” Black & Veatch, 2013.
- “Burden Of Proof,” No Fracked Gas In Mass.
- “Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2013,” U.S. EPA.
- Mass. Executive Office of Energy and Environmental Affairs (EOEEA)
- “The Gas Will Be Exported,” The Beat News.
Topic: Property rights
What is eminent domain?
The Natural Gas Act (15 U.S. Code Chapter 15B – NATURAL GAS) section (h) states that
When any holder of a certificate of public convenience and necessity cannot acquire by contract, or is unable to agree with the owner of property to the compensation to be paid for, the necessary right-of-way to construct, operate, and maintain a pipe line or pipe lines for the transportation of natural gas, and the necessary land or other property, in addition to right-of-way, for the location of compressor stations, pressure apparatus, or other stations or equipment necessary to the proper operation of such pipe line or pipe lines, it may acquire the same by the exercise of the right of eminent domain in the district court of the United States for the district in which such property may be located, or in the State courts. The practice and procedure in any action or proceeding for that purpose in the district court of the United States shall conform as nearly as may be with the practice and procedure in similar action or proceeding in the courts of the State where the property is situated: Provided, That the United States district courts shall only have jurisdiction of cases when the amount claimed by the owner of the property to be condemned exceeds $3,000.
In other words, if a “certificate of public convenience” has been granted to a pipeline company like Kinder Morgan (KM), KM can grab the property of someone in the path of the pipeline by eminent domain, which is the power to take private property for “public use“. What does “public use” mean? The people who are fighting losing their property by eminent domain will try to define “public use” to be fairly restrictive, while a company like KM will find court cases, such as search the 2005 Supreme Court ruling in Kelo v. City of New London (CT) that found that a “…plan [that] will provide appreciable benefits to the community, including, but not limited to, new jobs and increased tax revenue” constitutes “public use”.
So, in short, it is possible for a government to transfer the authority to take private property to a private corporation that will generate profits from the ownership of the land.
What is the relationship between the pipeline and eminent domain?
Kinder Morgan is seeking a “Certificate of Necessity and Convenience” from the Federal Energy Regulatory Commission (FERC). Once FERC grants the certificate to TGP they will be able to use “Eminent Domain” to “take” the land of thousands of private landowners. FERC could issue the certificate as early as fall, 2016.
What is KM saying about taking land by eminent domain?
Eminent domain is business as usual for KM. When owners resist just having their land surveyed (let alone taken), KM files lawsuits to gain access to property, thus incurring further costs to landowners who, through no fault of their own, ended up in the path of the pipeline. KM is already working deals with landowners to buy easements to swaths of their properties to avoid the delay of court proceedings that could accompany the exercise of eminent domain.
What message do we want to convey?
Eminent domain should be reserved for true need and should have a higher level of scrutiny than it currently has using FERC’s interpretation when issuing the certificate of convenience.
Property owners who do not agree to sell a right of way to Kinder Morgan stand to have their property taken by Eminent Domain. This activity is legal. However, in the opinion of groups opposed to this pipeline, we offer that,
- The activities that will generate corporate profits by the taking of private property are not for “public use” as they will cause more harm to the public then be of benefit.
- The Natural Gas Act, which authorizes the use of eminent domain for natural gas pipelines, was written for a time long past (1938) and is no longer relevant.
- The Kelo v. City of New London decision is flawed and we agree with the dissenting opinion that:
- The fallout from this decision will not be random. The beneficiaries are likely to be those citizens with disproportionate influence and power in the political process, including large corporations and development firms.
- The decision eliminates “any distinction between private and public use of property—and thereby effectively delete[s] the words ‘for public use’ from the Takings Clause of the Fifth Amendment [of the United States Constitution]”.
- Areas that are to receive the pipeline will be subject to greater environmental damage and risk than the public will benefit.
- Since the size of this project is so much greater than the regional needs for natural gas, a large portion of this project is not for “public use” but for private profits.
- Kinder Morgan has the highest gross profit margin of any company in their industry, 46.5% (“The Street”).
Article 10a of the NH Bill of Rights prohibits taking of land for use by other than a public utility (which KM is not), but see “Condemnation Issues Under the Natural Gas Act” which seems to slam the door on state constitutional prohibitions that conflict with the Natural Gas Act.
“Condemnation Issues Under the Natural Gas Act,” 2008, John. C. Lemaster.
Topic: Environmental damage
What will be the impact of NED on the environment?
Environmental effects come in many forms with gas pipelines, among them:
- Direct environmental damage during construction, and lasting adverse effects thereafter.
- Air, noise, and light pollution from compressor stations.
- Methane leaks at all stages of the gas transmission process.
- Environmental degradation from fracking, and
- Contribution to global climate change of increased dependence on natural gas.
NED is a massive construction project, requiring a 400-mile-long swath 150 feet wide. Within that path, all plants and topsoil will be removed, streams and rivers crossed, lakes and ponds traversed, wetlands ditched, and rock outcroppings blasted. The direct impact on the environment from this activity cannot be overstated.
And note that direct damage is not limited to private property. The pipeline route crosses many state and local conservations lands (supposedly protected permanently against such invasions) through all affected states.
Air pollution around compressor stations is an issue for the health of those living nearby. Numerous studies show marked adverse impact on the health of people living near compressor stations to a distance of two miles. Additionally, compressor stations operate 24 hours per day year round, generating noise and light pollution regularly as part of routine operation. See our Health and Safety topic for more about this subject.
All stages of natural gas processing, from wells to pipes to compressor stations, leak. Leaking pipelines are estimated to release between 8 and 12 billion cubic feet of methane annually in Massachusetts alone. What’s leaked is largely methane, an extremely potent greenhouse gas. Numerous other compounds, some known carcinogens, have also been detected in gas harvested by fracking, although the exact nature of these compounds is considered a trade secret (read about the “Halliburton Loophole” for more information on this point.) Yet, current state and federal policies actually provide disincentives for pipeline owners to aggressively find and fix these leaks.
Fracking, the source of the gas, raises it’s own special set of environmental concerns, including massive groundwater contamination and earthquakes (Oklahoma was recently named the earthquake capital of the U.S. with three earthquakes occurring every day on average, a fact considered by everyone but the gas industry to be a result of extensive fracking in that state.)
Finally, projects like NED make no sense because they increase our reliance on fossil fuels that 96% of scientists agree contribute directly to observed global climate change. Building this project now moves us in exactly the wrong direction. We should instead be investing our time, effort, and money in improved energy efficiency and in growing our use of renewable energy sources.
What is KM saying about the NED environmental impact?
KM and FERC routinely dismiss any claims of environmental degradation by any pipeline under its auspices. (FERC decided a year ago, in authorizing the Constitution Pipeline, that NED will have no significant environmental impact.) KM says they will comply with all relevant federal regulations, implying that doing so is sufficient. Sadly, current federal regulations are inadequate to address issues now surfacing about the environmental impacts of fracking in general, and gas transmission pipelines and compressor stations in particular.
What message do we want to convey?
- Fracking in general, and the associated pipelines and compressor stations, are environmentally unsound. That is, coupled with the lack of true need for NED (see our “Need” topic), the environmental destruction this project will cause is unacceptable.
- Natural gas production generates immediate, measurable, and ongoing adverse effects on the health of people living near these installations. People in the vicinity of compressor stations are particularly at risk.
- Natural gas (NG) is NOT a clean fuel. It burns cleaner than other fossil fuels, but when the effect of methane leaks is considered, NG shows negligible benefit relative to other fossil fuels. That is, NG is a fossil fuel that is continuing to emit greenhouse gas from the time it exits the ground to its time in transit to its time becoming compressed for export to its ultimate use.
- Fossil fuels in general are on the way out. Heavy investment in projects like NED makes no sense, especially considering the unavoidable environmental destruction it will cause.
Direct impacts from building the pipeline will include:
- Well contamination from nitrites or nitrates introduced during blasting.
- Well contamination from previously bound, naturally occurring pollutants (such as arsenic and radon) released by blasting.
- Loss or reduction of well output through changes in bedrock channels caused by blasting.
- Groundwater contamination through prolonged herbicide use to control vegetation in certain parts of the right-of-way (ROW).
- Groundwater contamination through fluids leaked from construction vehicles operating in wetlands and above aquifers, or fluids spilled during fueling or maintenance.
- Direct disruption of hydrology through soil disturbance (dig and fill), particularly in wetlands where necessary soil layering takes centuries to develop and is difficult to recreate once disturbed.
- Direct disruption of hydrology through changes in topology, affecting runoff patterns and rainwater accumulation needed to recharge aquifers.
- Direct drawdown of aquifers due to hydrostatic testing that might require more water than many of these aquifers normally produce.
- Erosion and sedimentation during construction of water crossings affecting fish and stream life.
- Wildlife habitat destruction. (Pipeline maintenance requires a 50-foot right-of-way maintained in nothing but grasses and similar herbaceous plants for the life of the pipeline.)
- Removal of biological material along the ROW leaving bare mineral soil, a habitat conducive to establishing invasive species.
- Introduction of invasive plants through plant materials inadvertently brought to the site on construction equipment or within fill material.
- Fugitive dust and diesel exhaust from trucks and heavy equipment on roadways.
- Long-term yield reduction in farmland crossed by the pipeline
- “Into Thin Air: Time to Replace and Repair Leaking Natural Gas Pipelines,” Conservation Law Foundation.
- “Why are natural gas leaks a problem?,” Environmental Defense Fund.
- “The Climate Risks of Natural Gas,” Union of Concerned Scientists.
- “Environmental Impacts of Natural Gas,” Union of Concerned Scientists.
- “Oil and Gas: What We Know is Concerning, but What We Don’t is Worse,” ,” Union of Concerned Scientists.
- “Natural gas may be harmful to your health,” Allergy and Environmental Health Association.
- “Potential Environmental and Human Health Impacts Associated with the Minisink Compressor Station, ” Dr. Wilma Subra.
Topic: Exporting America’s resources
What is the situation with exporting NED gas?
The NED pipeline begins in Pennsylvania and ends in Dracut, MA. Spectra Energy’s Maritimes & Northeast Pipeline (M&NP) is a transmission pipeline from Nova Scotia to Dracut MA. The owner of the M&NP has announced plans to reverse its transmission pipeline to carry natural gas north towards Canada. The Goldboro Nova Scotia LNG project is in development to export US gas to higher profit markets overseas, presumably gas from the M&NP pipeline, presumably US gas from the NED pipeline. Plans are underway for five LNG export stations in eastern Canada.
KM is justifying the NED pipeline by citing New England’s regional “energy crisis” and the need for more gas in New England. At the same time, export facilities are being developed, and the NED pipeline will transport significantly more gas than New England can possibly use.
What will become of the excess gas? It is widely understood that the gas is intended for export. Exporting the gas will reduce the supply in the U.S. and force U.S. consumers to compete on the world market, thereby raising the domestic cost of gas. The price of gas in Europe and Asia is currently 3-5 times the cost in the US.
What are the issues with exporting the NED gas?
- US citizens will be allowed to use only a small portion of the gas flowing through the NED pipeline (and through the cities, towns, farms, lakes and streams, sugar bushes, wells and septic systems, and barns and farmhouses of New Hampshire). The bulk of the gas will be sold overseas at an enormous profit for KM.
- Export will result in competition for gas on the world market, raising the cost of gas to American consumers.
- We are giving up our nation’s energy independence for get-rich schemes of a big pipeline company. If the pipeline is so good for NH, then
- Why did KM directors pay $124,000 to NH politicians in 2014–2015?
- Why did KM directors pay $449,000 to MA politicians in 2014–2015?
What is KM saying about exporting the NED gas?
KM has told its shareholders that exporting the NED gas is one way they will profit from investing in KM (Slide 9, “Natural Gas Pipelines”, Tom Martin). At the same time, KM tells FERC and landowners that the NED pipeline will supply gas to New England and reduce energy costs. Furthermore, when pressed on these points, KM representatives routinely say that KM is only a transport company; they have no control over what their customers do with the gas.
These statements cannot all be true.
What message do we want to convey?
- NED will supply much more gas than New England needs. It is clear the bulk is intended for export.
- Because of competition, selling gas on the world market will raise the price of gas in New England.
- Exporting limited American resources jeopardizes long-term U.S. energy independence.
- The Maritimes and Northeast Pipeline
- The Goldboro Liquified Natural Gas Project
- “Natural Gas Pipelines,” Tom Martin, New Hampshire Union Leader, December 10, 2015.
- “As Fossil Fuel Industry Staggers, a Massive Gas Pipeline Project Endures in Texas,” TruthOut.
Topic: Cost to citizens
What are the issues with cost?
- As if the taking of private and conservation land through eminent domain is not payment enough, New Englanders will also be charged a tariff on their energy bills to pay for the construction of this $6 to $8 BILLION dollar pipeline.
- The NH Municipal Pipeline Coalition (a group of 15 towns that have come together to fight the proposed NED) has issued warnings that the long-term costs of this project counter any savings pipeline proponents are promising, further stating that in NH the average cost to ratepayers could be an added $600 per year. If this project is contracted for the two decades, as proposed, costs could total $12,000 per customer.
- Study after study proves that our so-called “energy constraints” are limited to a few weeks in winter, and that we have a “winter reliability” issue, NOT a gas shortage in the region. Even the MA Attorney General has determined that NED is not needed and is more costly than alternatives like LNG, energy efficiency, upgrading existing pipelines, clean energy options, etc. since the additional costs are likely to be significantly greater than the gas commodity cost savings.
What is KM saying about cost?
KM says that The Northeast Energy Direct project, if approved, will add millions of dollars to the local economy and generate $16.8 million in revenue to local governments plus cut residential heating bills by 40-percent.
What message do we want to convey?
The adverse financial impacts of this project outweigh any benefits. Increasing gas pipeline capacity would not ensure energy savings or address our widespread carbon emissions, but it would certainly line the pockets of Kinder Morgan.
- Studies show that existing infrastructure provides more than enough capacity except for a few peak days each year. KM’s proposed pipeline would increase New England’s pipeline capacity by more than 50 percent. This excess capacity would leave us paying unnecessarily for at least an extra 300 days each year.
- These peak days can be better addressed by fixing leaks; better utilizing the liquefied natural gas (LNG) and gas storage already available, and building out renewable power alternatives. A study by the Conservation Law Foundation (CLF) concludes that this approach can meet our gas needs through 2030 and save consumers $340 million a year, $4.4 billion over 20 years.
- New England will foot the bill for this project. In MA, Kinder Morgan and Spectra Energy are insisting that the electric consumers pay for 75 percent of the bill, and in NH the Public Utilities Commission has decided it will take applications from Eversource to purchase long-term contracts for space on natural gas pipelines and blend the cost into electric rates.
- Opponents find it significant that in MA and NH, the local gas companies that are interested in the project have parent companies that are hugely invested in the project. UIL Holdings, parent company to Massachusetts’ Berkshire Gas, has an $80 million investment and Algonquin Power, parent company to NH Liberty Utilities, has an investment opportunity of up to $400 million in this project.
- “Coalition of NH towns says NED pipeline will cost ratepayers,” SentinelSource.
- “Customers may have to pay for new pipelines,” New Hampshire Union Leader.
- “NH Towns Warn of Costs Associated with Kinder Morgan Pipeline,” Milford, N.H.
- “Motion to Intervene and Protest of the New Hampshire Pipeline Coalition,” Federal Energy Regulatory Commission.
- “AG Study: Increased Gas Capacity Not Needed to Meet State’s Electric Reliability Needs,” Maura Healey, Massachussetts Attorney General.
- “Algonquin Power & Utilities Corp. to Partner with Kinder Morgan,” PR Newswire.
Topic: Health and safety
What are the health and safety issues with the pipeline?
Health issues arise primarily near compressor stations. These installations routinely leak gas, and intentionally expel gas from time to time (known as “blow downs”). Numerous studies show marked adverse impact on the health of people living near compressor stations to a distance of two miles. Acute health impacts include respiratory complaints, sinus problems, allergic reactions, and a variety of other problems. These issues arise not so much from the methane, but from other chemicals infused in the gas from the fracking process, and from particulates expelled at compressor stations.
Additionally, compressor stations operate 24 hours a day year round, generating noise and light pollution regularly as part of routine operation. Both can interfere with sleep, and sleep deprivation is associated with a host of health problems. Also of concern are ailments caused by low-frequency sound (called “infrasonics”) caused by the diesel engines and pumps operating at compressor stations.
A key safety risk arises from KM’s plan to co-locate the NED 30-inch high-pressure pipeline with a 345kV three-phase high-voltage AC (HVAC) power line. This “co-location” proposal is problematic in regards to pipeline longevity. The proposal has the NED pipeline running adjacent and parallel to the existing HVAC power lines for many miles. The existing right-of-way was never intended for a buried pipeline.
Federal guidelines allow pipeline companies to use thinner-walled pipe in areas of low population density. Most of the planned route in NH is classified in this way. Thin-walled pipe is more susceptible to corrosion and rupture than thicker-walled pipe.
Throughout the U.S. since 2003, KM and its subsidiaries’ pipelines (of all kinds) have been responsible for more than 400 spills, evacuations, explosions (some due to corrosion of pipes), fires, and fatalities in 24 states, incurring more than 110 federal enforcement actions. KM’s natural gas transmission pipeline accidents caused more than $224 million in property damage. Further, the ratio of federal inspectors to pipeline length is about 1 inspector for every 2,600 miles of pipeline. Further, newer pipelines have been experiencing greater fault incidences than older pipelines.
What is KM saying about pipeline safety?
KM states regularly that it has a nearly flawless safety record in NH for 60 years. Notably, Kinder Morgan as a company was created in 1997.
What message do we want to convey?
- Fracking in general, and compressor stations in particular, create significant and well-documented health risks for people unfortunate enough to live nearby. Air pollution around compressor stations is proven to cause many health issues. Noise pollution at compressor stations is a problem that cannot be addressed by local noise ordinances because of federal preemption (see “Condemnation Issues Under the Natural Gas Act” by John. C. Lemaster).
- Natural gas pipelines are inherently risky, and the cost-cutting that is planned (at least because the NED pipeline is traveling through rural areas) places the people along the route at even higher risk.
- Solid granite. The right-of-way (ROW) crosses Kidder Mountain in New Ipswich, Fletcher Granite quarry in Mason, and historical quarries in Milford. The rocky terrain here is not conducive to burying a pipeline safely below the frost line. The route also traverses numerous ledges and outcroppings with very steep pitches, and crosses a steep gorge over the Souhegan River. These slopes will be difficult to cover with fill that will not wash away without using hard fill that will damage the pipeline coating designed to protect it from corrosion. Federal regulations do not require burying the pipeline below the frost line anywhere and standard practice is to set the top of the pipeline at 18-36″ below the surface.
- Anti-corrosion methods complicated. Pipelines will corrode due to metal ionizing in the soil and the resulting electrical current flowing from the pipe into the ground. This corrosion will occur anywhere the pipeline coating allows metal contact with the soil. Pipeline corrosion is mitigated with DC cathodic protection electrical circuitry that reverses the direction of electrical current such that it flows from the ground into the pipe. This protection system requires constant monitoring for effectiveness and maintenance for proper operation.
- HVAC interferes with anti-corrosion. The close proximity of and running parallel to the 345kV power transmission lines will induce AC currents which will interfere with the DC cathodic mitigation systems and create its own AC current flow to corrode pipes. Again, this affect can be mitigated with additional electrical circuits and monitored for induced AC voltages, but this also requires constant monitoring and maintenance. Lightning strikes to the power lines and phase-to-ground faults from electrical power disruptions can induce very high currents in nearby buried pipelines, can degrade pipeline protective coatings, and can cause severe corrosion in the pipe.
- Thinner-walled pipes in rural areas. Kinder Morgan representatives have stated, at public hearings in NH, that less expensive, thinner walled pipes are used in rural areas. This will reduce the expected lifetime of this gas pipeline due to corrosion. This increases the need for constant monitoring and maintenance. But NH is not set up for such required monitoring.
- Poor maintenance record. Master Limited Partnerships (MLPs) like Kinder Morgan Energy Partners are skimping on crucial maintenance spending. They do not pay corporate income taxes. Instead, they distribute almost all their free cash flow to their investors. See Wikipedia.
- “Pipeline leak statistics should give pause to pipeline supporters,” OnLineAthens, Athens Banner-Herald.
- Kinder Morgan’s safety record, Wikipedia.
- “Mitigating AC Corrosion on Cathodically Protected Pipelines,” Pipeline & Gas Journal.
- “Transmission Line EMF Interference with Buried Pipeline: Essential & Cautions,” Electrical Engineering Department at King Fahd University of Petroleum and Minerals.
- “Williams Transco Central Penn Line South: A Citizen’s Guide -Risk,” LancasterPipeline.org.
- “Potential Environmental and Human Health Impacts Associated with the Minisink Compressor Station, ” Dr. Wilma Subra.