FTC Comment Before the Environmental Protection Agency Concerning Proposed Rulemaking on Confidentiality Determinations for Greenhouse Gas Data (Docket No. EPA-HQ-OAR-2009-0924)

BEFORE THE UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
__________________________________________
)
Proposed Confidentiality Determinations for Data 	) 	Docket No. EPA-HQ-
Required Under the Mandatory Greenhouse Gas 	) 	OAR-2009-0924
Reporting Rule and Proposed Amendment to 	)
Special Rules Governing Certain Information 	)
Obtained Under the Clean Air Act 	)
__________________________________________)
COMMENT OF THE FEDERAL TRADE COMMISSION
September 30, 2010
Introduction
The Federal Trade Commission (FTC) appreciates the opportunity to submit this
comment to the Environmental Protection Agency (EPA) on its proposed rule concerning
confidentiality determinations for greenhouse gas (GHG) data.1 On October 30, 2009,
the EPA issued rules mandating that certain industries report data related to their GHG
emissions.2 The EPA now proposes to group that data into 22 categories and designate
the confidentiality status of each category through rulemaking.
Three categories of data that the EPA proposes to make public contain potentially
sensitive competitive business information: “inputs to emission equations,” “unit/process
‘static’ characteristics that are not inputs to emission equations,” and “unit/process
operating characteristics that are not inputs to emission equations.” These three
categories include data on production, throughput, raw material consumption, capacity,
and future operations. Public disclosure of such facility- and firm-specific sensitive
1 75 Fed Reg. 39094 (proposed July 7, 2010), available at http://edocket.access.gpo.gov/
2010/pdf/2010-16317.pdf.
2 Mandatory Greenhouse Gas Reporting Rule, 40 C.F.R. Part 98 (2009).

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business information may make it easier for reporting companies to either tacitly3 or
explicitly coordinate their pricing decisions. This is especially true when certain market
conditions are present, such as transparency, high concentration, impediments to entry,
homogeneous products, and low elasticity of demand. 4
Because many industries subject to the GHG reporting requirements share at least
some of these market conditions, making confidential business information (CBI) public
may lead to collusion that harms consumers through higher prices, decreased quality, and
decreased innovation. Therefore, the FTC recommends that the EPA treat data that is an
input to emission equations as confidential. The FTC also recommends that the EPA
delay publication of any reported data concerning plant or unit capacity or future
operating status until after reporting companies receive sufficient time to apply for
confidential treatment. The competitive sensitivity of this data can vary by industry,
which suggests that more information is needed to make a confidentiality determination.
Interest of the FTC
The Federal Trade Commission is an independent administrative agency charged
with maintaining competition and safeguarding the interests of consumers.5 As part of its
competition mission, the agency often provides input to federal and state policymakers on
3 Tacit coordination exists without any actual communication among competitors. See, e.g. In re
High Fructose Corn Syrup Antitrust Litigation, 295 F.3d. 651, 654 (7 th Cir. 2002) (a tacit
agreement to fix prices is, “an agreement made without any actual communication among the
parties to the agreement.”).
4 See U.S. DEPARTMENT OF JUSTICE AND F EDERAL T RADE COMMISSION, ANTITRUST
GUIDELINES FOR COLLABORATIONS A MONG COMPETITORS §3.31(b) (2000) available at
http://www.ftc.gov/os/2000/04 /ftcdojguidelines.pdf, [hereinafter FTC/DOJ GUIDELINES FOR
COLLABORATIONS AMONG COMPETITORS ].
5 Federal Trade Commission Act, 15 U.S.C. ' 45.

3
the competitive implications of proposed laws and regulations.6 In its antitrust
enforcement role, the FTC reviews mergers and challenges anticompetitive conduct
across many industries that would be subject to the EPA’s proposed rule on
confidentiality, including petroleum refining, petrochemical production, natural gas
processing, and other manufacturing industries, such as industrial gases and titanium
dioxide production.7 In addition, FTC staff regularly studies and reports on competition
in the petroleum industry.8
In the course of this work, the FTC applies established legal and economic
principles as well as empirical analysis and recent developments in economic theory to
consider how market structure, transparency, and dynamics affect the ability of rivals to
explicitly or tacitly coordinate their competitive responses.9 In addition, the FTC has
6 See FTC Office of Policy Planning, Advocacy Filings, available at http://www.ftc.gov/opp
/advocacy_date.shtm.
7 See FTC Competition Enforcement Database, available at http://www.ftc.gov/bc/caselist/
industry/index.shtml.
8 Representative reviews in the petroleum industry in which FTC determined that a merger
presented a competitive problem, and significant structural relief was obtained, include In re
Valero L.P., FTC Docket No. C-4141 (July 26, 2005) (divestiture of Kaneb terminal and pipeline
assets in northern California, eastern Colorado, and greater Philadelphia area); In re Phillips
Petroleum Co., FTC Docket No. C-4058 (Feb. 14, 2003) (divestiture of Conoco refinery in
Denver, Phillips marketing assets in eastern Colorado, Phillips refinery in Salt Lake City, Phillips
marketing assets in northern Utah, Phillips terminal in Spokane, Phillips propane business at
Jefferson City and East St. Louis); In re Valero Energy Corp., FTC Docket No. C-4031 (Feb. 22,
2002) (divestiture of UDS refinery in Avon, California, and 70 retail outlets); In re Chevron
Corp., FTC Docket No. C-4023 (Jan. 4, 2002) (divestiture of Texaco’s interests in the Equilon
and Motiva joint ventures, including Equilon’s interests in the Explorer and Delta pipelines); In
re Exxon Corp., FTC Docket No. C-3907 (Jan. 30, 2001) (divestiture of all Northeast and Mid-
Atlantic marketing operations of the two parties and Exxon’s Benicia, California, refinery). A
listing of reports and other FTC activities involving the oil and gas industry is available at
http://www.ftc.gov/ftc/oilgas /index.html.
9 See, e.g., U.S. DEPARTMENT OF JUSTICE AND F EDERAL T RADE COMMISSION, HORIZONTAL
M ERGER GUIDELINES §7 (2010) (describing anticompetitive effects of coordination among
rivals), available at http://ftc.gov/os/2010/08/100819hmg.pdf [hereinafter FTC/DOJ
HORIZONTAL M ERGER GUIDELINES ].

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issued guidance addressing the harm to competition that can arise from collusion when
competitors share sensitive business information.10 The agency has raised these issues in
antitrust enforcement actions as well.11
The EPA’s Proposed Rule Regarding the Confidentiality of GHG Data
The EPA’s Mandatory Greenhouse Gas Reporting Rule requires certain industries
to submit data related to GHG emissions on an annual basis.12 This data must include
facility and unit identifier information, emissions, unit operating characteristics, unit and
facility production, unit and facility inputs and quantities, and unit capacity utilization.13
The EPA explains that these comprehensive, nationwide GHG data will provide a better
understanding of the sources of GHGs, and will guide development of policies and
programs to reduce GHG emissions. 14
The Clean Air Act requires the EPA to make this data public unless they
constitute confidential business information (CBI). The Clean Air Act also requires the
10 FTC/DOJ G UIDELINES FOR COLLABORATIONS AMONG COMPETITORS §3.31(b) (discussing
potential harms to competition when competitors exchange or disclose sensitive business
information); see also DEPARTMENT OF JUSTICE AND F EDERAL T RADE COMMISSION,
S TATEMENTS OF ANTITRUST E NFORCEMENT P OLICY IN HEALTH CARE , Statement 6 (Aug. 1996)
(same); available at http://www.ftc. gov/bc/healthcare/industryguide/policy/hlth3s.pdf; Letter
from FTC Staff to Sen. James L. Seward, New York Senate (Mar. 31, 2009) (disclosure of
sensitive business data in one market segment may chill competition in multiple market
segments); available at http://www.ftc.gov/os/2009/04/V090006newyorkpbm.pdf.
11 See, e.g., In re National Association of Music Merchants, FTC Docket No. C-4255 (Mar. 4,
2009) (prohibiting information exchanges among music merchant competitors), available at
http://www.ftc.gov/opa/2009/03/namm.shtml .
12 40 C.F.R. Part 98 (2009).
13 For a complete list of reported categories of data, see 75 Fed. Reg. at 39097.
14 See E NVIRONMENTAL P ROTECTION AGENCY, F ACT S HEET, M ANDATORY REPORTING OF
GREENHOUSE GASES (40 CFR PART 98), available at
http://www.epa.gov/climatechange/emissions/downloads09/FactSheet.pdf.

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EPA to release “emission data” even if that data is CBI.15 The EPA thus explains that
GHG data will fall into one of three confidentiality classes:
 	“emission data” as defined by the EPA, which must be publicly released;
 	non-emission data that does not amount to CBI and thus must be
publicly released; and
 	non-emission data that is CBI, which must not be publicly released.
Historically, the EPA evaluated whether information qualified for confidential
treatment on a case-by-case basis, upon the request of the reporting company and subject
to considerations of whether the disclosure would subject the reporter to business harm. 16
The EPA believes, however, that the volume of GHG data to be reported makes a case-
by-case determination unduly burdensome for reporting companies and the agency.
Moreover, the EPA states that the amount of time required for the agency to evaluate
each confidentiality request would delay making the GHG data public and diminish its
usefulness.17 To address these concerns, the EPA’s proposed rule groups GHG data into
22 data categories and identifies the confidentiality status (emission data, non-CBI, or
CBI) of each category.18
Public Availability of Otherwise Confidential Business Information
15 42 U.S.C. §7414(c) (“Any records, reports or information obtained under [the Clean Air Act]
shall be available to the public, except that upon a showing satisfactory to the Administrator by
any person that records, reports, or information, or particular part thereof, (other than emission
data) . . . if made public, would divulge methods or processes entitled to protection as trade
secrets of such person, the Administrator shall consider such record, report, or information or
particular portion thereof confidential . . . .”).
16 See 75 Fed. Reg. at 39101.
17 Id. at 39102. Companies must annually report the previous year’s data to the EPA by March
31 st . The EPA plans to release public data after verifying it. Id. at 39106
18 Id. at 39094.

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The FTC commends the EPA’s thorough and careful analysis identifying data that
should be considered CBI or non-CBI. The FTC is concerned, however, that the proposal
may allow for the public release of competitively sensitive information. Specifically,
because of the potential risk to competition, we suggest that data reported under three
categories – “inputs to emission equations,” “unit/process ‘static’ characteristics that are
not inputs to emission equations,” and “unit/process operating characteristics that are not
inputs to emission equations,” – may warrant confidential protection.
Inputs to emission equations. The Mandatory Greenhouse Gas Reporting Rule
lists methods for calculating GHG emissions depending on the source of the emissions.
Many of these methods involve the use of specified emission equations requiring
particular data inputs.19 Inputs to emission equations include, for example, volume of
fuel combusted per year; production/throughput and raw material consumption, such as
petrochemical production; characteristics of raw materials, products, and by-products;
and facility operating information. 20
The EPA proposes to designate the data category “inputs to emission equations”
as “emission data” under the Clean Air Act21 even though the agency recognizes that
much of the data falling within this category would otherwise be CBI. For instance, the
19 40 CFR Part 98. See also 75 Fed. Reg. at 39108. Often, the rule provides more than one
calculation method and allows reporting facilities to select their preferred method. The EPA
notes that in many cases, use of a “continuous monitoring system” reduces the number of data
elements that a company must report compared to use of an emission equation. Id. at 39109.
20 See 75 Fed. Reg. at 39108-09 (describing types of data that would fall within the “inputs to
emission equations” data category).
21 EPA regulations define “emission data” as “information necessary to determine the identity,
amount, frequency, [and] concentration . . . of any emission which has been emitted by the source
. . . .” 40 CFR 2.301(a)(2). The EPA considers inputs to emission equations to be “information
necessary to determine . . . the amount” of any emission and, therefore, views such inputs as
“emission data.” 75 Fed. Reg. at 39109.

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EPA has designated data on production, throughput, and raw materials consumed as CBI
when not used as an input to an emission equation. 22 In doing so, the EPA recognized
that an individual company could be harmed if rivals obtained the reported data, which
could reveal strategic information on capacity, market position and costs.23 Nevertheless,
because “emission data” must be made public whether CBI or not, the EPA’s
classification of inputs to emission equations necessarily precludes protecting this
information.
Unit/process “static” characteristics and unit/process operating
characteristics that are not inputs to emission equations. By designating
“unit/process ‘static’ characteristics that are not inputs to emission equations” as non-
CBI, the proposed rule would make certain capacity information public. The EPA
explains that much capacity information is already publicly available through other
reporting programs, reference materials and industry publications, making its release here
not harmful. 24 Although that may be true in some industries, there are others in which
accurate capacity data is not publicly available. In those cases, capacity information can
be competitively sensitive.
By designating “unit/process operating characteristics that are not inputs to
emission equations” as non-CBI, the proposed rule could make future operating status
information public. For instance, companies must report anticipated dates and steps for
22 75 Fed. Reg. at 39106 (“[r]ecognizing that the Inputs to Emission Equations Data Category
may contain data elements that are considered sensitive by many businesses . . . .”).
23 Id. at 39115-16.
24 Id. at 39112.

8
installing monitoring equipment.25 This information could be sensitive when it alerts
competitors that a production facility will be taken off-line.
The FTC is concerned that the EPA’s proposal to designate “inputs to emission
equations” data as public “emission data” and the EPA’s characterization of certain
capacity and operational status information as non-CBI could injure consumers by
harming market competition (not merely individual competitors).26 Sharing highly
sensitive data under the auspices of a government-mandated reporting program may be as
likely to lead to anticompetitive behavior as sharing that data by private agreement.
Competition Policy Concerns When Rivals Share Information
In some cases, sharing information among competitors may increase the
likelihood of collusion or coordination on matters such as price or output. 27 Coordinated
interaction among competitors includes collusive agreements, but it can also include
conduct not necessarily condemned by the antitrust laws.28 Firms that engage in
coordinated interaction are better able to predict, even absent explicit agreement, how
25 Id. at 39113.
26 FTC has recognized that information exchange facilitated by a merger in otherwise
concentrated petroleum markets can by itself lead to anticompetitive effects. See In re TC Group,
L.L.C., FTC Docket No. C-4183 (Jan. 25, 2007) (acquisition of partial interest in two of three
independent terminaling companies in the southwestern United States could cause
anticompetitive effects due to information exchange); In re Chevron Corp., FTC Docket No. C-
4144 (June 10, 2005) (Chevron’s acquisition of Unocal’s reformulated gasoline patents would
allow Chevron greater opportunity than Unocal would enjoy alone to coordinate with refining
competitors to raise the price for reformulated gasoline).
27 FTC/DOJ G UIDELINES FOR COLLABORATIONS AMONG COMPETITORS §3.31(b).
28 This includes parallel accommodating conduct by rivals in which “each rival’s response to
competitive moves made by others is individually rational, and not motivated by retaliation or
deterrence, nor intended to sustain an agreed-upon market outcome, but nevertheless emboldens
price increases and weakens competitive incentives to reduce prices or offer customers better
terms.” FTC/DOJ HORIZONTAL M ERGER GUIDELINES §7.

9
rivals will react to price changes.29 The antitrust agencies have explained how
coordinated interaction harms consumers: “[c]oordinated interaction involves conduct by
multiple firms that is profitable for each of them only as a result of the accommodating
reactions of the others. These reactions can blunt a firm’s incentive to offer customers
better deals by undercutting the extent to which such a move would win business away
from rivals. They also can enhance a firm’s incentive to raise prices by assuaging the
fear that such a move would lose customers to rivals.”30
The potential for information disclosure to harm competition will depend on the
structure of the affected market and the type of information disclosed.31 The ability of
rival firms to engage in coordinated conduct depends on the strength and predictability of
rivals’ responses to price change or other competitive initiative. Markets are more
vulnerable to coordinated conduct if each firm’s rivals can promptly and confidently
observe its behavior. Market factors that support this ability and increase the likelihood
of coordination include transparency, concentration, entry barriers, homogeneous
29 The FTC recognizes that rivals in the petroleum and other industries collect market intelligence
to anticipate and respond to rivals’ output and pricing decisions. See, e.g., In re Chevron Corp.,
FTC Docket No. C-4023, Analysis of Proposed Consent Order to Aid Public Comment (Sept. 7,
2001) (“Integrated refiner-marketers carefully monitor the prices charged by their competitors’
retail outlets, and therefore can readily identify firms that deviate from a coordinated or collusive
price.”).
30 FTC/DOJ H ORIZONTAL M ERGER GUIDELINES §7.
31 See Todd v. Exxon Corporation, 275 F.3d 191, 199 (2d. Cir. 2001) (quoting U.S. v. United
States Gypsum Co., 438 U.S. 422, 441 n. 16 (1978)) (“A number of factors including most
prominently the structure of the industry involved and the nature of the information exchanged
are generally considered in divining the procompetitive or anticompetitive effects of [the
information disclosed.]”); see also FTC/DOJ GUIDELINES FOR COLLABORATIONS AMONG
COMPETITORS §3.31(b).

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products, and low elasticity of demand. 32 Many of these market factors are present in
industries covered by the EPA’s rule.33
Information disclosures raise particular competitive concerns when the
information contains details about output, production capacity, production rates, current
price and cost data, and other business plans.34 Disclosure under the proposed rule of the
“inputs to emission equations,” which can reveal capacity and capabilities, other capacity
information, and forward-looking operational status would increase transparency in the
affected industries. In many instances, the actual output of a unit could be made public.
In other cases, the amount of feedstock used, the intermediate product produced, or the
32 FTC/DOJ H ORIZONTAL M ERGER GUIDELINES §7.
33 For instance, in relevant geographic markets with few players, the FTC has expressed concerns
about mergers or acquisitions in the petroleum industry that would reduce the number of
competitors necessary to engage in tacit or overt collusion. See, e.g., In re Dan Duncan, FTC
Docket No. C-4173, Consent Agreement and Order (2006) (in merger matter, consent agreement
ordering divestiture of certain pipeline assets related to salt dome storage for natural gas liquids in
Mont Belvieu, Texas – a concentrated market with high barriers to entry – in order to protect
competition in that region), available at http://www.ftc.gov/os/caselist/0510108/ 0510108.shtm;
In re Dow Chemical, FTC Docket No. C-4243 (2009) (consent agreement regarding Dow
Chemical’s acquisition of Rohm and Haas, which implicated glacial acrylic acid, butyl acid, ethyl
acrylate, acrylic latex polymers for traffic paint, and hollow sphere particles throughout North
America – all concentrated markets with high barriers to entry), available at
http://www.ftc.gov/os/ caselist/0810214/index.shtml; In re BASF, Inc., FTC Docket No. C-4253
(2009) (in a merger involving the production of pigments globally – a concentrated industry with
high barriers to entry – FTC ordered BASF to maintain the viability of certain assets so as to
preserve competition in the relevant market). Additional examples of FTC orders involving
industries subject to the GHG reporting requirements may be obtained through the FTC
Competition Enforcement Database, available at http://www.ftc.gov/bc/caselist/industry/
index.shtml.
34 See FTC/DOJ GUIDELINES FOR COLLABORATIONS AMONG COMPETITORS §3.31(b) (describing
potential harm to competition when firms disclose competitively sensitive data); see also Susan S.
DeSanti and Ernest A. Nagata, Competitor Communications: Facilitating Practices or Invitations
to Collude? An Application of Theories to Proposed Horizontal Agreements Submitted for
Antitrust Review, 63 ANTITRUST L.J. 93 (1994) (describing activities that make it easier for
parties to coordinate on price or engage in tacit collusion).

11
unit’s capacity would be made public. 35 As a result, collusion or coordination could
become more likely as firms are better able to predict one another’s behavior.
For example, improved information on the capacity and capabilities of a rival’s
facility can make it easier for a firm to anticipate how the rival will react to any strategic
changes it makes. More information about a rival’s output also will increase a firm’s
ability to detect when a rival deviates from the agreement, which need not be explicit. In
contrast, without output information, it would be difficult for a firm to determine whether
a price decrease is due to a fall in overall market demand or an increase in output from a
rival deviating from the agreement.
Improved information can lead to better coordination even when there is a gap in
time between the reported conditions and the availability of the information. Competitors
having capacity information that is one or two years old may be able to discern that
capacity has not changed significantly in that time. As a result, publishing capacity data
that is several years old could improve competitors’ estimates of current capacity. The
information on operating conditions, inputs, and outputs that would be made public
through disclosure of “inputs to emission equations” data could also give a firm added
insight into its rivals’ cost structures.
In addition to increasing the likelihood of collusion, this information can decrease
the competitiveness of a bidding process. In this case, the disclosed information can
allow a firm to better anticipate rivals’ bids, which may lead it to bid less aggressively,
resulting in increased prices. Therefore, disclosed information that would allow rivals to
35 See Memorandum, Data Category Assignments for Reporting Elements, EPA No. EPA-HQ-
OAR-2009-0924, available at http://www.epa.gov/climatechange/emissions/downloads
10/CBI_Data-Category.pdf.

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learn more about the underlying costs of their competitors has the potential to harm
competition and consumers through higher prices. This can be true even when the
information is one or two years old in industries where firms do not regularly upgrade
their facilities. If a unit has not been upgraded, the underlying economics of the unit are
unlikely to change and therefore the public release of older data may still threaten
competition.
Designating Data as CBI
Because the disclosure of competitively sensitive business information can have
adverse consequences for consumers, the FTC urges the EPA to consider the implications
for competition when it decides what data should be publicly released under the proposed
rule. Specifically, the FTC urges the EPA to consider designating as CBI – at least
initially – “inputs to emission equations,” which can reveal capacity, capacity
information in the data category “unit/process ‘static’ characteristics,” and forward-
looking operational information in the data category “unit/process operational
characteristics.” The EPA can then determine the confidentiality status of those data
elements whose competitive sensitivity varies by industry.
The EPA may wish to consider an interpretation of “emission data,” as that term
is used in the Clean Air Act and defined by EPA regulation, that allows the agency to
classify inputs to emission equations as CBI. 36 EPA regulations define “emission data”
as “information necessary to determine the . . . amount . . . of any emission . . . .”37
36 The EPA is seeking comment on its proposed interpretation of the term “emission data” to
include data that are required to perform emission calculations specified in the Mandatory
Greenhouse Gas Reporting Rules. 75 Fed. Reg. at 39101, 39105.
37 40 C.F.R. 2.301(a)(2). The EPA proposes that the inputs to the equations are “necessary to
determine” the amount of emissions. 75 Fed. Reg. at 39105.

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Inputs to the emission equations may not be “necessary to determine” the amount of
emissions because EPA will be releasing the verified amounts to the public.38 Assuming
this interpretation of “emission data” is consistent with the Clean Air Act, classifying
inputs to emissions equations as CBI would be an effective way to balance the Act’s
policy goals of promoting transparency and protecting competition. Publicly releasing
the verified, total amount of emissions by unit would achieve the Act’s purpose regarding
public disclosure, while keeping sensitive business information confidential would
achieve the Act’s stated goal of protecting CBI. The Commission urges the EPA to
interpret the Clean Air Act and related regulations in a way that gives sufficient weight to
the Congressionally-authorized goal of protecting market competition for the benefit of
consumers. 39
Capacity and operational data are also potentially competitively sensitive, but the
EPA may need more specific information about how competitors might use such
information in a particular industry before determining whether it is CBI. For that
reason, the EPA may wish to consider delaying a decision on publication of these
categories until reporters can provide better information on the impact of making them
public and the need for confidentiality in particular industries. If the EPA were to treat
the capacity data as confidential, the information might be made publicly available in
38 See Natural Resources Defense Council v. Leavitt, Civ. No. 04-01295, 2006 WL 667327, at *4
(D.D.C. 2006) (“[S]trict interpretation of the ‘necessary to determine’ requirement [for emission
data] is warranted in order to ensure that the exception does not swallow the rule.”).
39 The Congressionally authorized goal of protecting competition can be seen in the Clean Air
Act’s protection of CBI and the federal antitrust laws’ prohibition against data sharing that
facilitates explicit or tacit collusion and harms consumers. See Todd, 275 F.3d at 198-99
(explaining that information exchange among competitors can constitute an antitrust violation
even absent an explicit agreement among them).

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nationally aggregated form. 40 Delaying release of the data for an extended period could
also alleviate competition concerns, but only if the historical data no longer reflected
current capacity or current plant capabilities.
40 It is important to keep in mind that there may be few firms in some geographic regions or in
some industries, which would raise the concern that publishing even aggregate data might
decrease competition. The Energy Information Administration developed rules to make the
public release of data less likely to lead to such undesirable results. See U.S. E NERGY
I NFORMATION ADMINISTRATION, DISCLOSURE P OLICY FOR EIA P OWER S URVEYS, (updated June
30, 2010) (explaining that certain firm-specific data will not be disclosed), available at
http://www.eia.doe.gov/electricity/forms/sselecpower98.html.