I have proof that Octopus knowingly makes this claim - whilst stating openly that they use REGOs- and yet states the blindingly obvious that they have to pay for back capacity fuelled by non intermittent fuel aka fossil fuels.Set this out in lengthy emails to Octopus who in the end admitted they lie but refused to give me the data - sent the whole email chain to Jackson by recorded post - have the “ signed for” evidence - response to date …..zilch. Lying corrupt …….
They point out that they were invented by the EU as a means of tracking renewables from generation to consumer, partly with the idea of promoting more renewables investment- a role for which they have been basically useless. Most of the noise about REGO reform has concentrated on the idea of hourly matching between generation and consumers of claims of renewables (much promoted by the tiny Good Energy) . As Cornwall point out, such a scheme would lead to extreme price volatility. Many of the other schemes for increases the matching frequency would tend to disadvantage solar, although looking at the hourly value of renewables (and subtracting curtailed values) I suspect wind might do less well in future.
Storage and hydrogen are set to add to complexity of the need for tracing renewables output. Strictly, hydrogen electrolysis should only take place using surpluses that would otherwise be curtailed - otherwise you are paying for other generation to power it, worst of all if you are burning hydrogen as H2P to produce less hydrogen than you burn. Simply showing that renewable output was purchased is insufficient, as the alternative generation must be fired up to meet other customer demand.
They do point out that were we ever to get to a net zero grid REGOs would be redundant. Nevertheless they anticipate that REGOs could account for up to 10% of the wholesale price. The lack of transparency in REGO markets means that most if us forget to include them in the register of subsidies. However the lack of clarity means that renewables investors are inclined to discount them when considering their economics.
I live in Oregon, USA. For about a year I've been trying to figure out how your system works and I still don't really understand it. It seems very complicated to me, and very like a con game.
Back in the summer Drax commented that REGOs were trading around £10-15/MWh, so that would imply current prices of around £5.50-8.00/MWh. Bear in mind that REGOs trade over a so called Compliance Period of a year to give plenty of elasticity in allocating them to supplied demand.
These prices are still way in excess of the EU equivalent GoO prices which have collapsed back to eurocents per MWh. Here's a recent EPEX auction
The UK disallowed the use of GoOs to meet REGO needs after Brexit (and vice versa). The question is will consumers demand a separate tariff that is REGO free if prices are adding significantly to bills? Would that come with security of supply when the wind doesn't blow, and would the REGO tariff include power cuts when renewables can't deliver? Would REGOs be made compulsory in much the same way as ROCs? (You get to pay whether you wanted them or not). Additional subsidy per MWh may not really be helpful when competition is eroding curtailment payments that are growing rapidly in volume: the new Clean Industry Bonus for AR7 is a backdoor Capacity Market payment, made regardless of generation.
I'm confused about the way the REGO system works. It says that the REGOs are produced when there is a surplus of renewables but surely there isn't ever any excess electricity because what is generated is always used. The system has to be balanced at all times. So how can it happen that there is a surplus of renewable electricity?
I'm with you, Steve. It makes no sense to me. It seems to me that any"surplus" electricity is imaginary, since, as you say, what is generated has to be used. Electricity that is generated but not used (or stored in batteries) disappears into thin air. It ceases to exist, since electricity cannot be saved or stored (except in batteries, which weren't mentioned in this discussion.) The REGOs have to be a magician's trick to try to fool us.
Generators report their monthly metered output to OFGEM who check it with Elexon (the outfit that handles all the metering records ). OFGEM then records this in a database of certificates. After registration, certificates can be traded with the new ownership recorded by OFGEM. Traders may take a speculative position, or even buy as private individuals.
The only legal obligation relates to Fuel Mix Disclosure, which operates in arrears. REGOs issued in a financial year can be traded up to July to secure the annual greenwash volume that is then included in the FMD published by October. All retailers must publish their historic FMD. It is supposed to be consistent with the total supply they claimed to their customers to be backed by renewables over the year. Note that companies now also have an interest because they are required to report on their emissions in annual reports: these depend on what their supplier claimed, and on any extra REGOs they bought for greenwashing.
The OFGEM database of REGOs and ROCs is publicly accessible, and is a relatively easy way to find out what your local wind or solar farm generated in the past.
On sample selection of offshore windmills they are only reporting ROC certificates issued not REGO. So does this mean those sites don't have any REGO surplus to trade?
All renewables generators are entitled to REGOs once accredited. Some retailers are looking even at aggregating domestic outputs - but bear in mind that certificates are only issued in units of 1 MWh, and are not worth a lot so small domestic outputs are not worth the admin cost: a 4KWp set of panels will produce less than 4MWh per year.
REGOs may be handled by an appointed agent, so may not show against a specific generator. Also, where a wind farm is owned by a retailer group who intends to simply keep the REGOs for their own FMD there is no financial reason to register the REGOs until the end of the financial year and trading deadline. for inclusion in FMD. You need to look at an historic year to see what was finally registered.
Your explanation isn't helping me understand anything about how there can be a surplus of electricity because if it doesn't get used, it disappears and is lost forever (unless stored in batteries, which you don't mention.)
Supply and demand have to remain closely matched at all times, otherwise the grid frequency will stray too far from its 50Hz target: that can cause serious damage to generators, grid equipment any many user appliances and result in blackouts.
However, when it's windy or very sunny we can now end up with more potential supply than demand. The extra must be curtailed.
Thanks, sorry to be so dim. Doesn't it mean that there's a discrepancy in the totals at the end of the year. If octopus has to buy 100 MWH/gas but buys the equivalent of 100 MWH in REGO so that he can claim that it was really renewable. Doesn't it mean that someone who has actually bought 100MWH/renewable must actually say it was really gas otherwise the totals generated and sold won't tie up.
It means they can only claim for the REGOs they have bought, and any bought implicitly through a traded purchase of electricity (rather than directly from a generator). The full regulations are here
I don't think there's much evidence that wind and solar are getting cheaper. What we actually pay for generation increases because of index linking, which has outweighed any other factor. The costs for new Offshore Wind farms have not declined for several years, remains at about £2.75m per MW installed according to company accounts.
On the other hand adding more renewables to the system has increased many other costs. We have to invest extensively in pylons, interconnectors, substations, batteries and other grid stabilisation aids: more if these are needed the higher the proportion of renewables on the system. Wind has effectively driven out low cost nuclear which cannot tolerate being flexed up and down with the wind or sun. The flex is provided by gas, which gets to operate less efficiently in consequence.
We are now at the point where renewables output exceeds demand on windy nights or sunny summer Sundays. The excess production has no value, and yet renewables need to maintain their income by either increasing prices and subsidies for what they do sell or being paid a full price for curtailment.
The result of all this is that our prices are increasing. The curtailment factor will become increasingly important as capacity is expanded, driving up the effective cost of extra renewables to a multiple of uncurtailed cost.
Agreed ... I was only looking at capability…production acquisition costs… which as you say are overridden by install and application costs let alone all the costs to support reliability and flexibility shortfall. We have people that just look at production acquisition reducing and have no clue how bad the other 2 factors are in the whole picture.
Bottom line… W&S certainly on the grid is a disaster and only mildly useful in off grid non strategic situations…. Then if we look at how much CO2 is used to make them it will make you cry.
It looks like the Advertising Standards Authority has received 3 complaints about Octopus Energy. However these were informally resolved and no rulings were published.
A quick calculation on an assumed 100TWh total of domestic supply per annum to 27 million households shows an average load (8760h/annum) of around 400W (3500kWh/annum) so for any dip below 11GW in renewables output the 100% supply isn’t possible and that would be even more impossible at peak times.
A trawl through DESNZ DUKES & OFGEM typical domestic consumption values would give a more accurate picture, and the half hour periods where renewables supply was below the threshold can’t be hard to crunch.
This ability to supply 100% renewable electricity at all times to iirc close to 7 million consumers is yet another issue where Greg Jackson of Octopus has been questioned on many occasions. The 11GW mentioned above would be somewhere around 2.8GW for 7 million octopus customers.
While ‘chatty Greg’ loves to talk about purple and pink heat pumps & locational pricing that reduces ‘energy costs for all’ neither he in a personal capacity, nor Octopus themselves has never yet had the decency to reply on this 100% renewables all of the time point.
Sales to the domestic market aren't the end of the story. Companies and public bodies must all publish their emissions in their accounts. Those will depend on what their suppliers claim, adjusted by any extra greenwashing they buy.
The REGOs con meant that previously, energy suppliers could very cheaply offer '100% Green electricity' tariffs and not bother about how the electricity they were selling was actually generated. Now, with the rise in number of these tariffs, combined with the current worrying increase in winter wind droughts, the cost of REGOs has spiralled astronomically. It was £25 at the end of October. It must be even higher now, perhaps a lot higher. Supposedly, this extra cost will only be charged to customers currently on 100% renewables contracts. If you believe that, then I have a bridge to sell you. We're all going to be paying for this scam, basically driven by dishonest energy companies eager to parade their fake 'Green' credentials, plus idiotic, virtue-signalling customers also eager to parade their fake Green credentials no doubt by telling their fake Green soy latte sipping friends over dinner how clean, green and vegan their electricity is. Just like the Agile Octopus 'free energy' boasters who are now paying extortionate half hourly tariffs. Yes, they're paying for their stupidity, but pretty soon, all of us will be paying for their stupidity.
The fundamental requirement for a wind power system is reliable wind. I imagine that people planning irrigation schemes will check the water supply very carefully, including historical rainfall or snowfall records in the catchment area.
Meteorologists have long known that high pressure systems cause low winds.
Mariners at sea and millers on land must have known about prolonged low wind periods for centuriesl
Coal miners knew about them over a hundred years ago.
HG Wells wrote in 1901 ‘Wind was extremely inconvenient for the purpose of pumping [water from mines] because in these latitudes it is inconstant: it was costly, too, because “at any time the labourers might be obliged to sit at the pit’s mouth for weeks together whistling for a gale”.
So why did the recent Dunkelflautes come as a surprise?
Thank you David! I'd been dipping into gridwatch.co.uk this week with interest and seeing Dunkelflaute in action (or inaction). It showed very clearly that UK energy policy is now a belief system: between them, Santa Claus, the Easter Bunny and the Tooth Fairy will somehow contrive to keep the lights on.
For years the Dutch were buying pieces of paper from the Norwegians and saying they were green.
There was one significant event that increased pressure on the system on Thursday/Friday. The US allowed Ukraine to attack Russia with ATACMS, which resulted in Russia taking out most of what was left of the Ukrainian power system, including 5 out of 9 nuclear turbine output. As a consequence Ukraine called for emergency supplies from an already strained EU system with the resultant problems.
Demonstrating that there is no security of supply in the EU or UK. Trying the get out of a hole with a spade!
They were also firing up MPP3 with coal at Maasvlakte Rotterdam to feed the BritNed interconnector, which we pretended was supplying us with groene stroom. Put on the subtitles and have a laugh
I have proof that Octopus knowingly makes this claim - whilst stating openly that they use REGOs- and yet states the blindingly obvious that they have to pay for back capacity fuelled by non intermittent fuel aka fossil fuels.Set this out in lengthy emails to Octopus who in the end admitted they lie but refused to give me the data - sent the whole email chain to Jackson by recorded post - have the “ signed for” evidence - response to date …..zilch. Lying corrupt …….
Cornwall Insight has a very useful discussion of the evolution of REGOs here
https://www.cornwall-insight.com/thought-leadership/insight-papers/reviewing-the-future-of-regos-for-corporates/
They point out that they were invented by the EU as a means of tracking renewables from generation to consumer, partly with the idea of promoting more renewables investment- a role for which they have been basically useless. Most of the noise about REGO reform has concentrated on the idea of hourly matching between generation and consumers of claims of renewables (much promoted by the tiny Good Energy) . As Cornwall point out, such a scheme would lead to extreme price volatility. Many of the other schemes for increases the matching frequency would tend to disadvantage solar, although looking at the hourly value of renewables (and subtracting curtailed values) I suspect wind might do less well in future.
Storage and hydrogen are set to add to complexity of the need for tracing renewables output. Strictly, hydrogen electrolysis should only take place using surpluses that would otherwise be curtailed - otherwise you are paying for other generation to power it, worst of all if you are burning hydrogen as H2P to produce less hydrogen than you burn. Simply showing that renewable output was purchased is insufficient, as the alternative generation must be fired up to meet other customer demand.
They do point out that were we ever to get to a net zero grid REGOs would be redundant. Nevertheless they anticipate that REGOs could account for up to 10% of the wholesale price. The lack of transparency in REGO markets means that most if us forget to include them in the register of subsidies. However the lack of clarity means that renewables investors are inclined to discount them when considering their economics.
Another excellent analysis, thank you David, I've invested in yet more candles.
I live in Oregon, USA. For about a year I've been trying to figure out how your system works and I still don't really understand it. It seems very complicated to me, and very like a con game.
Yes, it's very difficult to understand and most of it is a con.
For £400 a month you can get a weekly update on REGO prices from this crew: pity their chart lacks a y-axis
https://renewable.exchange/blog/uk-rego-prices-drop-45-between-august-and-november-2024/
Back in the summer Drax commented that REGOs were trading around £10-15/MWh, so that would imply current prices of around £5.50-8.00/MWh. Bear in mind that REGOs trade over a so called Compliance Period of a year to give plenty of elasticity in allocating them to supplied demand.
These prices are still way in excess of the EU equivalent GoO prices which have collapsed back to eurocents per MWh. Here's a recent EPEX auction
https://www.epexspot.com/en/market-results?market_area=&auction=&trading_date=2024-11-27&delivery_date=&underlying_year=&modality=Mgo&sub_modality=&technology=&data_mode=table&period=&production_period=
The UK disallowed the use of GoOs to meet REGO needs after Brexit (and vice versa). The question is will consumers demand a separate tariff that is REGO free if prices are adding significantly to bills? Would that come with security of supply when the wind doesn't blow, and would the REGO tariff include power cuts when renewables can't deliver? Would REGOs be made compulsory in much the same way as ROCs? (You get to pay whether you wanted them or not). Additional subsidy per MWh may not really be helpful when competition is eroding curtailment payments that are growing rapidly in volume: the new Clean Industry Bonus for AR7 is a backdoor Capacity Market payment, made regardless of generation.
I want to buy my electricity from a supplier who will give me cheap electricity regardless of it’s origin.
So do I
I'm confused about the way the REGO system works. It says that the REGOs are produced when there is a surplus of renewables but surely there isn't ever any excess electricity because what is generated is always used. The system has to be balanced at all times. So how can it happen that there is a surplus of renewable electricity?
For clarity REGOs apply to every MWh of actual renewables generation aside from small domestic installations.
I'm with you, Steve. It makes no sense to me. It seems to me that any"surplus" electricity is imaginary, since, as you say, what is generated has to be used. Electricity that is generated but not used (or stored in batteries) disappears into thin air. It ceases to exist, since electricity cannot be saved or stored (except in batteries, which weren't mentioned in this discussion.) The REGOs have to be a magician's trick to try to fool us.
Generators report their monthly metered output to OFGEM who check it with Elexon (the outfit that handles all the metering records ). OFGEM then records this in a database of certificates. After registration, certificates can be traded with the new ownership recorded by OFGEM. Traders may take a speculative position, or even buy as private individuals.
https://www.ofgem.gov.uk/environmental-and-social-schemes/renewable-energy-guarantees-origin-rego
The only legal obligation relates to Fuel Mix Disclosure, which operates in arrears. REGOs issued in a financial year can be traded up to July to secure the annual greenwash volume that is then included in the FMD published by October. All retailers must publish their historic FMD. It is supposed to be consistent with the total supply they claimed to their customers to be backed by renewables over the year. Note that companies now also have an interest because they are required to report on their emissions in annual reports: these depend on what their supplier claimed, and on any extra REGOs they bought for greenwashing.
The OFGEM database of REGOs and ROCs is publicly accessible, and is a relatively easy way to find out what your local wind or solar farm generated in the past.
On sample selection of offshore windmills they are only reporting ROC certificates issued not REGO. So does this mean those sites don't have any REGO surplus to trade?
So who are the main source of REGOs?
All renewables generators are entitled to REGOs once accredited. Some retailers are looking even at aggregating domestic outputs - but bear in mind that certificates are only issued in units of 1 MWh, and are not worth a lot so small domestic outputs are not worth the admin cost: a 4KWp set of panels will produce less than 4MWh per year.
REGOs may be handled by an appointed agent, so may not show against a specific generator. Also, where a wind farm is owned by a retailer group who intends to simply keep the REGOs for their own FMD there is no financial reason to register the REGOs until the end of the financial year and trading deadline. for inclusion in FMD. You need to look at an historic year to see what was finally registered.
https://www.ofgem.gov.uk/sites/default/files/2023-04/REGO%20Guidance%20for%20generators%2C%20agents%20and%20suppliers.pdf
Arghh i think i get it now and thus in 100% renewable grid you wouldn't need them anymore!!
Your explanation isn't helping me understand anything about how there can be a surplus of electricity because if it doesn't get used, it disappears and is lost forever (unless stored in batteries, which you don't mention.)
Supply and demand have to remain closely matched at all times, otherwise the grid frequency will stray too far from its 50Hz target: that can cause serious damage to generators, grid equipment any many user appliances and result in blackouts.
However, when it's windy or very sunny we can now end up with more potential supply than demand. The extra must be curtailed.
Thanks, sorry to be so dim. Doesn't it mean that there's a discrepancy in the totals at the end of the year. If octopus has to buy 100 MWH/gas but buys the equivalent of 100 MWH in REGO so that he can claim that it was really renewable. Doesn't it mean that someone who has actually bought 100MWH/renewable must actually say it was really gas otherwise the totals generated and sold won't tie up.
It means they can only claim for the REGOs they have bought, and any bought implicitly through a traded purchase of electricity (rather than directly from a generator). The full regulations are here
https://www.gov.uk/government/publications/the-electricity-fuel-mix-disclosure-regulations-2005
If you're dim, I'm even dimmer. It kind of sounds to me like the imaginary surplus is being paid for twice.
It amazes me that we are still talking about and experiencing the disaster of W&S.
It’s the definition of insanity. …. doing the same things and expecting better results.
Process performance theory says you need 3 things for a high-performance process (to do anything.)
Capability, Flexibility and Reliability
Here is the W&S score card..
High capability… OK…W&S has got less expensive per unit of full load output.
High Flexibility…. Poor… Has no controllable relationship to real demand
High reliability…. Very Poor … only when the wind blows and the sun shines.
So 2 out of these 3 factors will never improve.. forget this technology other than very narrow uses.
Think…There are solid reasons why we went from sailing ships to steam and from washing tubs and lines to washing machines and dryers!
I don't think there's much evidence that wind and solar are getting cheaper. What we actually pay for generation increases because of index linking, which has outweighed any other factor. The costs for new Offshore Wind farms have not declined for several years, remains at about £2.75m per MW installed according to company accounts.
On the other hand adding more renewables to the system has increased many other costs. We have to invest extensively in pylons, interconnectors, substations, batteries and other grid stabilisation aids: more if these are needed the higher the proportion of renewables on the system. Wind has effectively driven out low cost nuclear which cannot tolerate being flexed up and down with the wind or sun. The flex is provided by gas, which gets to operate less efficiently in consequence.
We are now at the point where renewables output exceeds demand on windy nights or sunny summer Sundays. The excess production has no value, and yet renewables need to maintain their income by either increasing prices and subsidies for what they do sell or being paid a full price for curtailment.
The result of all this is that our prices are increasing. The curtailment factor will become increasingly important as capacity is expanded, driving up the effective cost of extra renewables to a multiple of uncurtailed cost.
Agreed ... I was only looking at capability…production acquisition costs… which as you say are overridden by install and application costs let alone all the costs to support reliability and flexibility shortfall. We have people that just look at production acquisition reducing and have no clue how bad the other 2 factors are in the whole picture.
Bottom line… W&S certainly on the grid is a disaster and only mildly useful in off grid non strategic situations…. Then if we look at how much CO2 is used to make them it will make you cry.
It looks like the Advertising Standards Authority has received 3 complaints about Octopus Energy. However these were informally resolved and no rulings were published.
https://www.asa.org.uk/codes-and-rulings/rulings.html?q=Octopus#informally-resolved
A quick calculation on an assumed 100TWh total of domestic supply per annum to 27 million households shows an average load (8760h/annum) of around 400W (3500kWh/annum) so for any dip below 11GW in renewables output the 100% supply isn’t possible and that would be even more impossible at peak times.
A trawl through DESNZ DUKES & OFGEM typical domestic consumption values would give a more accurate picture, and the half hour periods where renewables supply was below the threshold can’t be hard to crunch.
This ability to supply 100% renewable electricity at all times to iirc close to 7 million consumers is yet another issue where Greg Jackson of Octopus has been questioned on many occasions. The 11GW mentioned above would be somewhere around 2.8GW for 7 million octopus customers.
While ‘chatty Greg’ loves to talk about purple and pink heat pumps & locational pricing that reduces ‘energy costs for all’ neither he in a personal capacity, nor Octopus themselves has never yet had the decency to reply on this 100% renewables all of the time point.
Sales to the domestic market aren't the end of the story. Companies and public bodies must all publish their emissions in their accounts. Those will depend on what their suppliers claim, adjusted by any extra greenwashing they buy.
Correction, 2023 total demand was 316.8TWh, domestic consumption was 92.6TWh so a little bit lower than I stated above.
The REGOs con meant that previously, energy suppliers could very cheaply offer '100% Green electricity' tariffs and not bother about how the electricity they were selling was actually generated. Now, with the rise in number of these tariffs, combined with the current worrying increase in winter wind droughts, the cost of REGOs has spiralled astronomically. It was £25 at the end of October. It must be even higher now, perhaps a lot higher. Supposedly, this extra cost will only be charged to customers currently on 100% renewables contracts. If you believe that, then I have a bridge to sell you. We're all going to be paying for this scam, basically driven by dishonest energy companies eager to parade their fake 'Green' credentials, plus idiotic, virtue-signalling customers also eager to parade their fake Green credentials no doubt by telling their fake Green soy latte sipping friends over dinner how clean, green and vegan their electricity is. Just like the Agile Octopus 'free energy' boasters who are now paying extortionate half hourly tariffs. Yes, they're paying for their stupidity, but pretty soon, all of us will be paying for their stupidity.
The October was 2023. Prices have crashed since.
Not me, my electricity is 100% Buddhist.
Ohm Mani Padmi Ohm.
I chant it every time I plug something in.
The fundamental requirement for a wind power system is reliable wind. I imagine that people planning irrigation schemes will check the water supply very carefully, including historical rainfall or snowfall records in the catchment area.
Meteorologists have long known that high pressure systems cause low winds.
Mariners at sea and millers on land must have known about prolonged low wind periods for centuriesl
https://www.flickerpower.com/images/The_endless_wind_drought_crippling_renewables___The_Spectator_Australia.pdf
Coal miners knew about them over a hundred years ago.
HG Wells wrote in 1901 ‘Wind was extremely inconvenient for the purpose of pumping [water from mines] because in these latitudes it is inconstant: it was costly, too, because “at any time the labourers might be obliged to sit at the pit’s mouth for weeks together whistling for a gale”.
So why did the recent Dunkelflautes come as a surprise?
Thank you David! I'd been dipping into gridwatch.co.uk this week with interest and seeing Dunkelflaute in action (or inaction). It showed very clearly that UK energy policy is now a belief system: between them, Santa Claus, the Easter Bunny and the Tooth Fairy will somehow contrive to keep the lights on.
With Ed Miliband as Tinkerbell.....
For years the Dutch were buying pieces of paper from the Norwegians and saying they were green.
There was one significant event that increased pressure on the system on Thursday/Friday. The US allowed Ukraine to attack Russia with ATACMS, which resulted in Russia taking out most of what was left of the Ukrainian power system, including 5 out of 9 nuclear turbine output. As a consequence Ukraine called for emergency supplies from an already strained EU system with the resultant problems.
Demonstrating that there is no security of supply in the EU or UK. Trying the get out of a hole with a spade!
They were also firing up MPP3 with coal at Maasvlakte Rotterdam to feed the BritNed interconnector, which we pretended was supplying us with groene stroom. Put on the subtitles and have a laugh
https://www.youtube.com/watch?v=xW-VLPyxqAM
Zondag met Lubach - Groene Stroom
I dont know what you mean by 'glory'," Alice said.
Humpty Dumpty smiled contemptuously. "Of course you don't- till I tell you. I meant 'there's a nice knock-down argument for you!'"
"But 'glory' doesn't mean 'a nice knock-down argument'," Alice objected.
"When I use a word," Humpty Dumpty said, in rather a scornful tone, "it means just what I choose it to mean- neither more nor less."
"The question is," said Alice, "whether you can make words mean so many different things."
"The question is," said Humpty Dumpty, "which is to be master-that's all."
Yep, Lewis Carroll nailed this. We are living in Alice in Wonderland...
Subsidy = not subsidy, not really...