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ARB Staff Publishes Concept Paper of ZEV Changes in Preparation for Public Workshop

In preparation for a public workshop next week, the staff of the California Air Resources Board (ARB) published a concept paper that further develops proposed changes to the California Zero Emission Vehicle (ZEV) regulations.

In a public board meeting in May, the Air Resources Board considered a status report on the ZEV program. Members of an Expert Review Panel commissioned by ARB to examine ZEV technologies presented a summary of their report (earlier post), and ARB staff made preliminary recommendations regarding the potential for modifying the ZEV program. (Earlier post.)

As an outcome of the May meeting, the Board instructed staff to examine possible changes to the regulation based on information provided by the Panel and from comments provided by the general public and effected stakeholders.

The new concept paper is a starting point for further discussions regarding possible amendments. ARB staff identified a number of goals for potential changes to the regulations:

  • Maintain the pure ZEV requirement in order to achieve long term public health goals.

  • Maintain requirements that accelerate ZEV technology development and deployment.

  • Provide support for near-term ZEV demonstration projects.

  • Take full advantage of technology options that are available today, to achieve air quality improvement and provide a bridge to ZEV commercialization.

  • Provide manufacturers flexibility with respect to ZEV fuels, technologies, and compliance pathways.

The paper outlines 10 potential areas for modification. The ones that will likely generate the most discussion are the proposed reductions in the volume requirements and lengthening of the implementation times for fuel cell vehicles; putting full-function battery electric vehicles on a more equal footing with fuel cell vehicles; and devising additional incentives to foster the development of plug-in hybrid electric vehicles (PHEVs)—both blended and all-electric range (AER) models.

Following the meeting next week, ARB staff will develop its Initial Statement of Reasons for changes to regulations, which it will deliver to California’s Office of Administrative Law on 9 October. The Board will hold a hearing on the specific changes 6-7 December 2007.




Why lower the volume requirements? Doesn't that conflict with their second goal to "Maintain requirements that accelerate ZEV technology development and deployment." ?

Also, if to "Provide manufacturers flexibility with respect to ZEV fuels, technologies, and compliance pathways" they simply mean counting flex fuel vehicles as ZEVs then this sounds like big trouble. In principle this is ok but only if when these vehicles are actually driven, they USE emission free biofuels (and what about non-CO2 pollutants?). Considering even just the difficulties in transporting ethanol from the Midwest to California (and hence lack of available ethanol) I think this is very unlikely.

Rafael Seidl

@ marcus:

The sentence regarding the volume requirement referred specifically to fuel cell vehicles. ZEV legislation currently permits two ways to comply with the "true ZEV" aspect: either a defined fraction of all vehicles sold by a high-volume manufacturer must be any type of "true ZEV" or, they must sell a specified number of FCVs.

As technology advances, CARB is obviously tinkering with the mandate to foster new R&D concepts that it feels are barking up the right tree wrt air quality and economic feasibility. FCVs remain ludicrously expensive.

There may also be an expectation of future CO2 regulation, which implies trading off R&D investment in traditional emissions technologies and a new, second focus on improving fuel economy.

Stan Peterson

The CARBite idiots are still at it.

Having marched up an impossible hill they are being forced to march back down again. Their demands for a set percentage of BEVs in 1990 couldn't and wouldn't fly; they were forced to back down that hill.

Now their "idee fixe" consists of a fuel cell fleet consuming Hydrogen created in inefficient and dirty plants and spewing out 100% of the worst GHG (H20) is beside the point. They want it, and these clowns are determined to demand the tide follows their dictates.

Still their is no realism to their demands.

Is CARB willing to encourage PHEVs?


They'll think about merely tolerating them, maybe.

Even though there is not a single electric generation coal plant in California, an electrical power crisis is brewing again, they are totally oblivious.

They insist that their vision is for prodigious amounts of hydrogen be created as the only acceptable fuel for the Fuel Cell vehicle fleet, to the exclusion of BEVs, PHEVs, and truly ICE ZEVs. (But gee, glorified golf carts are still OK and encouraged!)

These moronic true-believers want their FVCs and absolutely nothing else.

Making hydrogen is much more inefficient and requiring the consumption of prodigious amounts of fossil fuels. The only other realistic approach is un-designed, un-proven and unsafer High Temperature nuclear reactors, elctrolyzinf H20, where as the PHEVS or BEVs can be refueled in much cleaner and efficient electric generation. Well to wheel is much cleaner than FCVs would be.

These HTNR of Gen IV to make H2 are not even seriously proposed for commercial operation until the period of 2025-2030. No problem! Their mandates are for FCVs in 2008-2015 Mental disconnect! Not to them. (Is any brain between the ears of these true-believer imbeciles?)

There is still no serious discussion of accepting the ZEV ICE vehicle. Auto makers have offered a new true ICE ZEV but they don't even consider it. Why a T2B1 standard for ICE won't be accepted and rewarded, when the automakers say they can do it and almost immediately, is absolutely beyond me.

These morons want their FCVs and they don't care if the air is dirtier then it need be, for a couple of more decades; these children are throwing their temper tantrum and that's that.

Governor Arnold should do more than just fire the couple of clowns he has done so far in cooperation with the Democratsas clear obstinate fools; CARB needs a thorough house cleaning. Or better yet just thank them all, and send them home. The rest of the world has caught up,and surpassed them in pollution standards, and simply abolish the nest of idiots before they commit more mischief.


I agree with you Stan , it is just beyond belief !

Jim G

CARB is in a demoralized state right now, and the posts here reflect that. But it's such a tremendous lever of public power lying almost totally unused. We don't have one in Massachusetts. What if the actual (smog-breathing) Californians were broadly engaged in a renewed effort to evolve CARB into what it was originally envisioned to be? The ZEV mandate would never have been so successfully arm-wrestled down if ordinary Californians had been broadly involved at those critical points when it was being weakened.

What gives me hope is how even the slightest change in the environment around them seems to affect Detroit's behavior. They dragged their feet when the mandate was here, yet just four years after it was put to sleep, here we are with talk of PHEV's, series hybrids (Chevy Volt), LiOn batteries, etc. I don't know whether it was Toyota's jump into hybrids, or all the little EV entrepreneurs popping up which aren't making golf-carts (like Tesla). But I don't think it necessarily would take as much as we think it would. Why not start a campaign to enact the old ZEV mandate into state law? As a concerted single goal.

P Schager

If CARB were to put BEV's on an equal footing with fuel cells, they would not be doing what they're charged with, which now includes addressing CO2 as well as local, or criteria pollutants. Practical low CO2 sources of hydrogen remain largely hypothetical, whereas for electricity they are already on the roof. It seems to me that the direction is clear, that they must put BEV's on the front burner and leave FCEV's on the back.

Reality Czech

Stan Peterson writes:

Hydrogen created in inefficient and dirty plants and spewing out 100% of the worst GHG (H20) is beside the point.
Let's look at this assertion of "H2O is the worst GHG" for a moment.

A kilogram of hydrogen is the energy-equivalent of about a gallon of gasoline.  A commuter driving 50 miles round-trip in a car getting 25 mpkg would put 18 kg (18 liters, about a quart shy of 5 gallons) of water into the air every day.

Peterson appears to assert that this bodes disaster.  But 5 gallons is a fraction of what someone would sprinkle onto an average-sized lawn in an afternoon (and ultimately transpire into the air).  It's perhaps what a swimming pool might lose by evaporation on a hot day.  In other words, it's bogus.

The alternative is that Peterson is trying to cast doubt on climate change, using water as the falsely accused villian.  It's true that water is falsely accused, but not because GHG's are harmless; water is not an issue because it comes out of the atmosphere as rain.  Sulfur hexafluoride, nitrous oxide, methane and carbon dioxide do not do that.

Depending which way you read his diatribes, Peterson is either clueless or lying.  It is good that he's here as an object lesson, but I wish he would keep his trolling to the threads dealing directly with climate.

Stan Peterson

Reality Czech,

Nice try, but you can't ONLY count the re-oxidizing of hydrogen to hydrogen dioxide. You need to include in the calculation the energy and dirtiness of converting hydrogen dioxide first, back to hydrogen, to subsequently "burn" in your FCVs.

There are two ways of doing that. Through electrolysis of water, H20, at a a prodigiously expensive expenditure of electricity. That electricity that you need to generate somehow, either with fossil or High Temperature Nuclear for mild inefficiency of hydrogen production or regular Nukes for very poor overall hydrogen inefficiency.

To make electrolysis only mildly in-efficient, you must pre-heat the H20 up pretty high temperature like 900 degeree Centigrade, (1650 degree F) which is beyond the range of current nuclear plants to produce, (or most common steels as well).

Other than some concepts on paper, and military reactors making weapons grade materials that are not meant to be power producers either, High Temperature Nuclear power Reactors haven't been designed yet by the way.

So there is no HTNR yet as a plant for a California utility to just go out and buy. Call back in 2025. The CARBites demand FCVs and the hydrogen be available from 2008 to 2015. Like I said "What's wrong with this picture"?

When the Utilities call in 2025, I'll be there rejoining the principled fission opposition saying almost all, (save the pebble bed gas cooled reactor) of the designs for these HTNRs are dangerous, operating too close to the edge, and not needed.

That is NOT TRUE for the very safe, tested, lower temperature, Gen III+ plants that we are talking of and are in the process of building in large numbers now.

The other source of hydrogen is to use fossil fuels for the heat source; and natural gas or gasified coal to make the natural gas as a first step, before you make the Hydrogen, afterward. You also have to do something with the Carbon that you release from the hydrocarbon to which the hydrogen was originally attached, as well. Prodigious amount of fossil and prodigious amounts of pollution into the air to make the hydrogen that you can then "cleanly" re-oxidize in your FCV.

Net Net? You lose badly on the all fossil option; and like I said call back in post 2025 for a nuclear High Temp Nuclear option to electrolyze water into hydrogen and oxygen only fairly in-efficiently, rather than prodigiously in-efficiently so the FCVs can re-oxidize it back into water.

My comment regarding FCVs producing the worst GHG gas and 100% of it, is [satire] with a kernel of truth.

Water is some 20 times more powerful, molecule versus molecule as a GHG gas, and present in proportions 12,000 times higher in humid air then trace CO2. That should stop and make you think a bit about global warming.

If an altered solar wind merely changes the cloud cover by 1%, it is 100 times more than the effect of all the CO2 in the air. Then the IPCC TAR V will remove CO2 as the devil, as they promised to do so, in both IPCC TAR III. They alredy Did do that partially in IPCC TAR IV for the more intense light portion of the increased solar output. The IPCC will reassign it to water and cloud formation, modulated by an altered increased solar wind.

As to your comment about water doesn't count, because even though its there almost as a constant in the range of 1-4%;, specific molecules of it, fallout as rain and other H20 molecules replace it, is something that I have seen made by pseudo-scientists. While it is True that specific water molecules go into and out of the atmosphere rapidly. So what?? Ddoes its replacement act differntly?

Consider if your car is stopped at a RR crossing while a train is stopped on the tracks as well, and you can't proceed because a specific RR car blocks the way.

Does that mean if the train is moving and each car is in the intersection briefly for but a few seconds, do you really want to say that you can just drive right on because a single RR car that you identified as opposed to some other equivalent, won't collide with you?

Does that make any sense at all? Of course not. And if you think that changes anything, maybe I will give you a "Darwin Award" as you test your hypothesis, proceed right through an RR intersection with a moving train, since it can't hurt you.


What excatly does this report say that was not known before?

Reality Czech,

Don't you know, don't talk to trolls, its exactly what they want, just ignore them.


Though CARB may be demoralized now, it can still accomplish quite a bit if it aims at the right target.  But to do this, it has to learn from the mistakes of the past.

Recap:  In 1990, CARB settled on a ZEV mandate for car manufacturers, requiring a specified and rising percentage of vehicles in future years to be ZEVs.  At the time, the only feasible ZEV technology was batteries, and lead-acid was more or less the state of the art.  Matters were not helped by foot-dragging on the automakers' part.  CARB kept moving dates outward and numbers downward as original schedules failed, until the entire ZEV mandate was ultimately dropped.  The few EV's made available were leased instead of sold, and the majority of them were taken back at the end of the mandate and destroyed.  A few Toyota RAV4-EVs are now in private hands, but no GM EV1's.

CARB's error was to demand too much too soon.  The automakers had claimed hardship with the previous round of pollution controls, but had managed a near-miracle with the advent of the catalytic converter.  CARB appears to have thought it could force another miracle with batteries.  What CARB failed to take into account is that catalysts and electronic controls were new and rapidly improving, while storage batteries were over a century old and relatively well-optimized.  The possible improvements needed lots of capital to get to market, and without a proportionally large market the capital was not going to be there.

Note what we're seeing now.  The market for batteries is being driven by cell phones and other portable electronics.  The "bag phone" made do with lead-acid gel-cells, but NiMH made a smaller and lighter unit possible.  The shrinkage in hand-held units drives progress in lithium ion cells, as each improvement yields market advantage and offers large returns on investments in lab work and manufacturing.  The cheapest and most rapidly improving high-density cells are the 18650 lithium-ion units made for laptops.

This never happened with the ZEV.

CARB could have taken another course.  Even in 1990 (arguably, in 1980), the technology was available for a PHEV-20.  The batteries of the day were sufficient, and a smaller and more efficient sustainer engine running at a steady power level would have been far cleaner than a larger engine serving a rapidly-varying demand.  The energy of a traction battery would have allowed pre-heated catalytic converters and other pollution control measures, and the transfer of energy supply from petroleum to electricity would have eliminated a great many engine starts completely.

The effect of a PHEV-20 mandate on the market would have been to push motors, power electronics and traction batteries.  The volume of all these things would have been sufficient to get the R&D cycle going to push costs down and realize the remaining possibilities for improvement.  Developments like carbon-foam batteries (from Caterpillar spinoff Firefly Energy) would have been attractive much sooner.  We'd probably have PHEV-40's and PHEV-60's in showrooms today.  (I was musing about this publicly in 1992, and events have proved me right.)

Unfortunately, we're here 17 years later and CARB is still thinking about where to go.  A lot of time has been wasted, and the pollution problem has been joined by developing petroleum and climate crises.  What could CARB do about it?  Here are my suggestions:

  1. Speed and lane restrictions on all vehicles over 4500 lbs not operating on electricity.  Stick the Hummers and Durangos and Excursions in the right lane at 55 MPH, and ban them from HOV lanes 24/7.  Make them unattractive and uncool.
  2. Escalating tax on gasoline (this is way overdue).
  3. Escalating weight taxes on ICE-only vehicles.
  4. Incentives:  Tax credits for PHEV purchases.
  5. Infrastructure:  Tax credits for installations of charging connections (esp. for rental housing), meters, DSM systems, etc.
  6. Energy production:  Write bills to remove the legal obstacles to the replacement of the old wind turbines in the state with modern units and accelerate the installation of PV and solar thermal.  Send them to the legislature.  (Those PHEVs are going to need to be fed.)

Boondoggles like the hydrogen highway need to be terminated.  Neither california nor the USA have the money to waste on them any more.


Stan, stop this water vapor nonsense, it does not make any good. IR adsorbtion lines of water vapor in atmosphere are almost completely saturated, and additional amount of water vapor could increase GHG effect only at the wings of adsorption lines, and this addition is very small (although IPCC models incorporate highly speculative tripling of warming effect of CO2 by increased water vapor). In addition, water vapor in atmosphere is in equilibrium state, and it increase is possible only at increased air temperatures. No artificial addition of water vapor will influence global climate, thought local weather is influenced by, for example, massive irrigation. Most of adsorption lines of CO2 are same as water vapor, and no addition of CO2 will have GHG warming effect, except for two tiny adsorption lines different from water vapor. Exactly these two adsorption lines are attributed to CO2 GHG effect. Yes I agree that this effect is quite insignificant, but you can not compare CO2 and H2O as molecule per molecule. You also can not compare 390 ppm of CO2 and 30 000 ppm of water vapor, because IR adsorbtion is logarithmic function of concentration, and saturates quite quickly. You are physicist, for god’s sake…Do not play Al Gore.


Funny thing, ALL your propositions are irrelevant to CARB. They have no legal rights to set speed limits, traffic patterns, gasoline and vehicle taxation, tax incentives for vehicle purchases energy generation or infrastructure. Only state legislature can do such things. The only thing CARB can do is to regulate tailpipe emissions and fuel formulation.

Also, do not forget that ZEV mandate is highly modified, and includes incentives and mandates for ultra-low emission ICE vehicles (paving road to ultra-low emission technology to the rest of the world), hybrids, BEVs, and from now on – PHEVs. It is not only about hydrogen fuel cells. As an example, take a look at California/US model of Prius. Because of CARB PZEV incentives, Prius is equipped with expandable fuel tank bladder and has no fuel return lines, and as a result near zero evaporative emissions (and near zero probability of fuel tank explosion, for that matter). European Prius model use conventional gas tank and do produce evaporative emissions.


The list of 6 items by Engineer-Poet is great. Too bad we do not have anyone in DC with enough guts to do the righ thing for america.

Carb had the right idea in 1990. The only problem was they caved in to the auto companies too fast. Tesla and Pheonix will prove this year that we can do electric cars in quantity. The Tesla proves that EV's can be fun and clean.

Those cars cost too much for you, then build your own EV. It really is not that tough.

Whenever someone tells me that EV's are not practicle, I just open the door on my workshop and show them my EV that I drive to work 4 out of 5 days. See www.zevutah.com for details.

Whenever people tell me about air pollution from coal fired power plants, I show them the PV system on my roof that makes enough electricity to power my EV.

The power that runs my house is 100 % wind power. It only costs 10 cents a kWh and dirty coal electricity costs 8 cents. A small price to pay for clean power.

A carbon tax of just one penny a pound would clean up the auto industry and the electrical industry all in one fell swoop.

Like I said, Too bad we dont have any politicians with enough guts to do the right thing.


Andrey, CARB is the creation of the California legislature.  It can already do things like mandating afterburners on restaurant grills to cut organic emissions.  If it needs more authority, the legislature has the power to grant it or (as I suggested) implement its suggestions as separate laws.

Stan Peterson

Let me address your critique in two phases. First the Science, and then the Science Policy issues.

Yes, GHGs are logarithmic declining in effect. It is true that all the water and CO2 bands are virtually saturated, except for two tiny, exclusive CO2, bands that are approaching saturation, as well.

The effect of raising CO2 from 0 ppm to 20 ppm is the same driving force as the raise from 20 ppm to 280 ppm; and is the same driving effect as raising CO2 from 280 ppm to 9000 ppm. This illustrates the 'diminishing returns' effect of increased atmospheric CO2.

All that argues is that the GHG hysteria is just that, hysteria. Since all the other GHGs including CH4, NO2, halo-fluorocarbons and SOx, are now in control, stabilized, or outright declining. That leaves but H20 and CO2 in the list of GHGs.

H20 as you say is (sometimes)in equilibrium, but only when the air is in saturation. (It is not perpetually raining or ready to do so, everywhere, all the time.)

Meanwhile CO2 still rises but at a declining rate of increase. I suspect Ocean CO2 solubility, and the increasing plant flora worldwide, eating CO2, are doing more than Man's efforts. I will concede all the exhortation to reduce CO2 from Man's industry, has some rather small contribution, given the tiny anthropogenic contribution to the overall CO2 flux.

But cloud modulation has nothing to do with humidity and more to do with exposing the Earth to varying Solar Light radiation. And also to alterations in the world's net Albedo. Simply because we have had no way of measuring planetary cloud coverage, the GISS models, like Mr. Haansen works on so assiduously, have 'fudge factors' in them. That approach says it is invariant, and can be and is set by a parameter constant.

Now all Dr. Svensmark's science is saying is that planetary cloud cover is NOT a constant. It can vary, does so, and has an effect in the same order of magnitude as the very tiny augmented and logarithmically declining, CO2 effect.

The IPCC confirmed that explicitly in TAR III and by inference in TAR IV, for future action, as it reduced the TOTAL GHG effect by some 12-15% overall. Why anyone with any scientific training really thought worldwide daily precipitation or cloud cover is/was a constant, is the real question.

On to Science Policy discussions.
Please grant me the right to use satire and ironic mocking. As making fun of idiots is much better than any other approach to convince anyone of the hysteric's essential silliness. It was quite good as a technique used by Jonathan Swift and I prefer it too.

For the average layman, understanding what the Science is both explicitly saying for today, and pending further proof, implying for tomorrow, is not easy at all to discern.

I believe it is incumbent as both trained scientists and concerned citizens, to add to the general understanding. Further we should act to prevent the rather pointless expenditure of funds and efforts in rather sterile directions.

From an overall standpoint, there are preferred courses of action, and non-preferred course of action, and each has their consequences for Man.

Consumption of fossil fuels for the transport application virtually exclusively, produces problems for society and Mankind as a whole. In order of importance, I rate them as follows:

a) There is simply not enough fossil to take the entire World population to a high standard of living;
b) The overall efficiency of fossil based transport is just too low and overall human progress is based on increasing efficiency.
c) Increased efficiency liberates surplus that then raises human living standards.
d) Fossil is concentrated in the hands of totalitarians and unstable political economies implying War and economic disruption.
e) Creating analogues by manufacturing fossil fuels is ultimately self-defeating; as it impacts food levels ands is a carbon de-sequestration process, all hyperbole aside.
f) Fossil is too valuable as feedstock to burn;
g) Pollution effects, while now essentially controlled, still requires diversion of resources.
h) As a corollary to better human living standards, through Man's concern, the living standards of the Planet's flora and fauna rise as well.

I assert wealthy humans help the worldwide flora and fauna. I know this will prompt sputtering attacks of hysterical over reaction. As proof, an example: Only a wealthy USA with a significant social surplus, could afford to set aside a large area for Parks and Wilderness.

That large area happens to be greater than the sum of all the area of the original thirteen colonies at the time of the American Revolution. (I'll leave to any observer to verify this astounding but true tidbit for the next time someone complains of dwindling wildlife habitat.) Only wealthy humans will take action to protect endangered species, and give them an area equal to or greater than: New Hampshire, Vermont, Rhode Island, Connecticut, New York, New Jersey, Delaware, Maryland, Virginia, North Carolina, South Carolina and Georgia.

For all those reasons, we as scientists and citizens should be fostering substitutes for the transport applications. Dr Frank's theories and Mr. Kramer's efforts, who posts here occasionally, contribute by their work.

The least that we should expect from those appointed to help conquer the air pollution problem, is that they do not march us down self-defeating avenues.

The CARBite true-believers have done that on at least three occasions. They have wasted resources better devoted elsewhere; delayed the development of applicable technology, to follow their pet whims; and now outright delay the cleaning of the air that is their supposed Prime Directive and "raison d'etre".

Please do not compare me to a rather dumb, Elmer Gantry wannabe, who is using the hysteria of a well-executed propaganda campaign. Mr. Gore is using the Big Lie technique, to re-promote his bid for political power.official or otherwise. I can't imagine a worse insult.


1. CARB does NOT require fuel cells. Type III ZEV requires 100 mile range and 10 minute refill. FCVs are most easily able to meet this requirement, but the category does not exclude BEVs, air-cars, or whatever. In fact, Phoenix Motorcars' entire business plan is built around use of AltairNanosystems lithium titanate cells to meet the requirement and earn valuable Type III ZEV credits with a $200k BEV instead of a $1m FCV.

2. Water vapor is NOT a 20x more powerful GHG than CO2, and it is NOT 12,000 more plentiful than CO2. It's about 100x more plentiful in the tropics (380 ppm vs. up to 40,000 ppm) and actually less than 1x near the poles. On average water vapor is around 30x more plentiful than CO2.

3. Practical PHEV-20s were NOT possible in 1990. The Volt's 160 kg battery pack is already too heavy, but a lead-acid pack would weigh even more. Such a lead-acid pack would also be power deficient and fall well short of the cycle life spec. A PHEV-20 typically gets two full charges per day (home and office). That's 700+ full cycles per year, a workload that would quickly kill even deep-cycle lead-acids (and deep-cycles have notoriously poor burst power). The numbers just don't work.

Lots of people say we should start with PHEV-20 (or PHEV-10) and work our way up to PHEV-40. But you actually need BETTER battery technology for a PHEV-20 than a PHEV-40.

4. A penny-per-pound carbon tax would not "clean up the auto industry and electrical industry". A penny per pound of carbon would add less than 6 cents per gallon to the pump price of gasoline. A penny per pound of CO2 would add about 20 cents/gallon. We've seen almost $2/gallon of cost increase lately and yet US gasoline consumption continues to increase. Likewise, a penny tax per pound of carbon would raise electric costs a fraction of a cent per kWh. A penny per pound of CO2 would be 1-2 cents/kWh. We already subsidize wind and other non-CO2 sources by that much.

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