Gabriel Lafitte, January 2011
China’s 12th Five-Year Plan, for 2011 through 2015, is about to become public.
The ongoing massive infrastructure investments typical of a centrally planned economy will persist, and perhaps even accelerate, as China continues to finance its infrastructure construction by borrowing from future generations. China’s growth remains state-driven, and tightly focused on creating the necessary preconditions for the elite to get even richer, with the state picking up the tab for putting in place the expressways, railways, power stations, cities and ports needed to enable profitable businesses to follow.
While the overall amount to be spent on infrastructure construction contracts to be won by the well-connected may be as big, or bigger, than in the previous central plan, the focus will shift, from the coast to the inland, and from encouraging energy intensive heavy industries to encouraging heavy industries whose intensive energy use is supplied partly by “green” sources of power.
High on the list of construction programs, designed to distract attention from the massive program of building more coal fired power stations, is the increased use of nuclear power, solar power, wind power and hydropower. In order to maximise the impression that China is the world’s leader in renewable energy, the Party’s 12th Plan will result in maximum publicity presenting China as the global capital of hydropower and green energy. Although the 12th Plan will not be formally released until the 2011 session of the National People’s Congress in March 2011, already key media are publishing the core targets, and they are indeed ambitious, though hardly on the scale of the intensifying use of Chinese and imported coal, and the weekly commissioning of new coal fired power stations. China’s coal consumption is already around three thousand million tons and, even if every planned hydro dam and nuclear power station is built, will still rise to 3.8 billion tons as soon as 2015.
Since a high proportion of the new hydro dams are in Tibet, or on the edges of the Tibetan Plateau, how will China’s reinvigorated hydraulic economy impact on Tibet?
A GOLDEN DECADE FOR THE RED ENGINEERS
What is also becoming clear is that the Party leaders intend to sweep aside the growing strength of the environment movement in China, which in recent years grew in its ability to persuade Beijing to override local boosters of dams that would inundate areas of exceptional beauty or cultural significance. Not only is the party-state signalling its determination to vanquish the environment movement, but also the social unrest that frequently erupts when intensively farmed valleys are commandeered for inundation behind a dam wall, with farmers, sometimes hundreds of thousands of them, offered inadequate land and compensation in a country with no unused arable land left. The coming two Five-Year Plans taking China to 2020 are to be a “golden decade” for engineers. The rise and rise of the red engineers, who dominate the Politburo of the Communist Party to a remarkable degree, is not yet over, even if a new generation takes over in 2012.
Shanghai Daily reported on 6 January 2011: “WITH 2020 clean-energy targets to meet, China is set to accelerate the building of hydroelectric dams, reversing a long halt caused by environmental concerns and the social upheaval of relocating people living in the shadow of dam sites. The trend will create a “golden decade” for the nation’s hydropower sector, analysts say, as high fuel prices continue to squeeze margins of coal-fired power plants that comprise the bulk of China’s electricity-generating capacity. Renewable energy sources like solar power have been slow to come on line on a big scale because of high costs and grid-configuration problems.
“The Chinese government now aims to have 430 gigawatts of -hydropower capacity by 2020, increasing its earlier target of 380GW, the China Securities Journal reported last month. ‘That means each year, the equivalent of one new Three Gorges Dam will be added in China over the next decade,’ said Shao Minghui, an analyst at China Post Securities, using the 2020 target of 380GW as a base. ‘The market is really sizable.’ The 18.2GW Three Gorges Dam, which spans the Yangtze River, is the world’s largest.”
Shanghai will be a major beneficiary of this renewed investment in diversified energy sourcing. Not only will the industrial belts surrounding Shanghai be major users of hydropower transmitted from afar, there will be less reliance on coal hauled from Inner Mongolia and elsewhere in northern China, and fewer bottlenecks on a rail freight system overloaded with coal shipments. Shanghai will proclaim its green credentials as a city that directly emits less greenhouse gases, by sourcing its hydropower from as far away as the fringes of Tibet, where arrays of dams will cascade down the mountain rivers that pour from the Tibetan Plateau.
The Tibetan Plateau is increasingly divided geographically between two different purposes, in the minds of China’s planners. One land use, covering big areas on the map, is conservation and watershed protection for China’s downstream users, preserving landscapes often called pristine and unspoiled by Chinese economic and tourism industry planners. The other land use, concentrated narrowly in corridors of development, is concentrated urbanisation, industrialisation, minerals extraction and processing, and all the transport corridors that connect these zones of high productivity, high capital investment, and high immigrant population.
While these two kinds of land use pull in opposite directions, they could live side by side, if uneasily. But China has further decided that the nomads are to be sedentarised, emptying the land, leaving it officially designated only for conservation and watershed protection, with traditional pastoral use excluded. The displaced nomads are now becoming an urban fringe, dumped into high density concrete block settlements, with no skills, no livelihoods and few of the inhibitions essential to living in the urban crowd.
The land of Tibet is being pushed to contradictory extremes, with huge emptied areas badged to materialise China’s green credentials, while the engineering corridors and urban hubs monopolise almost all available investment. The existing corridors of highways, railways, optical fibre cables and oil pipelines across Tibet are to be joined by a new corridor, of hydro dams and high voltage power lines. The dams sometimes are to be in a cascade series, on Tibetan rivers, establishing the river system of Tibet, source of most of Asia’s great rivers, as a newly industrialised corridor comparable to the highways and railway. While there is little likelihood these mountain rivers will, in Tibet, be navigable, they can be made to generate enough electricity to see power pylons marching across Tibet, both to the new boom cities in Tibet, and far away to the east, to China’s major industrial cities.
The power of the hydropower engineers, far from waning as some have supposed, is reaching its peak. But the targets are, by any standard, ambitious; and will require massive injections of capital raised by issuing bonds to be repaid by future generations. Rather than encouraging domestic consumption, which would enable China’s factory workers to buy what they make, investment capital will, as usual, be primarily directed at massive projects that retiring leaders like to associate themselves with as their lasting fame.
But is it actually possible to add a Three Gorges dam once a year, for a decade? The reality is that Three Gorges, athwart China’s greatest river, the Yangtze, is unique, the world’s biggest hydro dam for good reason. There aren’t many rivers where a single dam of such wonder-of-the-world size could be contemplated. Instead, China will build an enormous number of smaller dams, and maps charting known sites on the Tibetan Plateau are now readily available online: http://tibetanplateau.blogspot.com/search?q=dams&updated-max=2010-01-21T13:06:00-08:00&max-results=20
DWARFING THE THREE GORGES
But there is one river, or to be more exact one stretch of a specific river, in a far corner of China, that has the potential to be another three gorges, in fact to generate double or even triple the power generated by the Three Gorges colossus. This is the great river of southern Tibet, the Yarlung Tsangpo, in its gorge in eastern Tibet, pinned beneath towering ranges on all sides, as it curves in a great bend before plunging south into northeast India and Bangladesh, known better to the world as the Brahmaputra. The great bend of the Yarlung Tsangpo is so remote and inaccessible it was charted only in the 1990s. On paper, its potential for generating hydropower is extraordinary. Over a 300 km stretch, it falls from 3000 meters to just over 500 meters at the point it leaves Tibet. The gorge it has cut through the rising Himalayas is itself a channel for laden monsoon clouds to penetrate Tibet more than anywhere else on the plateau, resulting in heavy rainfall. Hemmed in by glacial peaks above 5000 meters, with the highest mountain of eastern Tibet, Namche Barwa, at 7760 meters, the whole area not only attracts moist monsoon clouds, but captures almost all of them for the river. In the 300 kms of the great bend, the Yarlung Tsangpo’s flow more than doubles. China’s hydro engineers calculate that two great hydro projects could be built, Metok (in Chinese Motuo), with 38,000 megawatt generating capacity, more than double Three Gorges 18,600MW; and Daduo, which could generate even more, 43,800 MW. Either of these projects would add more to China’s electricity supply than all the dams planned for other Tibetan rivers put together.
The idea is quite simple. Both involve diverting water from the river through a man-made short-cut that avoids much of the great bend, sending huge volumes of water straight across from intercept points where the river is just below 3000 meters, rushing down to rejoin the river on the far side of the bend, where it is only at 850 meters (Metok/Motuo) or 560 meters, at Daduo, an even greater drop. This makes maximum use of a drop of more than 2000 meters -2 kilometres- to drive enormous turbines and produce electricity on a scale that dwarfs even the Three Gorges. Not only have Chinese hydro engineers sketched such plans, they have published proposed routes for the ultra high voltage cables that would then step across the deep gorges of nearby rivers in order to reach the core cities of western China, Chongqing and Chengdu. China’s Xinhua newsagency published a map in 2003 showing power lines heading east to the Sichuan basin.
Source: Scientific Atlas of Qinghai-Tibet Plateau, 1990, map 80
Such projects would forever be linked to their progenitors, the engineers who dominate the CCP Politburo Standing Committee, as Three Gorges is a lasting monument to its patron Li Peng, otherwise known as the driver of the Tiananmen massacre. Either of these great Yarlung Tsangpo dams would also showcase the technical mastery of Chinese engineers, whose worldwide work building railways, oil pipelines and refineries in Africa, or mines in Latin America, extend China’s global reach. Three Gorges relied on imported turbines from Siemens in Germany as the high precision heart of making electricity from water; but a new generation of turbines can now be made in China, after western manufacturers were induced to transfer their intellectual property to Chinese partners.
Source: Scientific Atlas of Qinghai-Tibet Plateau, Geographic Publishing House 1990, map 2
China’s mapping of routes for these hyper mega dams makes full use of existing river valleys feeding into the Yarlung Tsangpo gorge on the downstream side. Rather than having to channel diverted water all the way along a 50km shortcut, the plan is to utilise as much as possible the existing fall of water as it rushes down to join the Yarlung Tsangpo not far from where it reaches India’s Arunachal Pradesh state, a state still contested by China, which loses no opportunity to remind India that China’s armed forces occupied Arunachal in 1962.
But there are enormous obstacles facing the prospect of ever building these dams. Between the sides of the great bend is a major mountain range, peaking at 7760m, the highest mountain anywhere in eastern Tibet or western China. The spine of mountain ridges is mostly above 5000m, a full 2kms above the river bed; and it is underlain by a deep fault line, in a region subjected to enormous mountain building pressures and big earthquakes as pressures build and seek sudden release. The only way through would be to tunnel massive shafts on a down slope through the fault line, at a depth of 2kms or more, deep enough to be so naturally hot that water entering at close to freezing point might heat by as much as 50 degrees. No one really knows. So far it is all on paper, with little preliminary work done to test even the technical feasibility, let alone the financial cost/benefit case. Continuous tunnels would need to be up to 30kms long. In order to generate enough power, many parallel tunnels, each probably eight meters wide, would be needed. In addition, on a river that rages in the summer monsoon and slows greatly in winter, dams to regulate flow would be needed across the river. All this in an area so steep, jungled and inaccessible that the 1990s saw a Sino-American race to be first to actually traverse the full length. One result was a number of books, Ian Baker’s The Heart of the World: A Journey to Tibet’s Lost Paradise the best of them.
Source: Scientific Atlas of Qinghai Tibet Plateau 1990, map 138
The great bend occurs for a reason. This is the area of maximum thrust of the Indian subcontinent into the heart of Eurasia. What forces the river northeast, then east, and then southwest is a series of faults deep in the mantle of the planet, which are at right angles to each other. Across most of Tibet the fault lines run roughly parallel, trending from northwest towards the southeast, and it is these which force the Yarlung Tsangpo to turn south towards India and Bangladesh. But before reaching the walls of rock pushed up along these faults, the river must first find a path between other fault lines that are oriented southwest to northeast, resulting in parallel ranges trending the same way, that the river must squeeze between. This is a highly active seismic area, with deep-seated forces pushing in differing directions, not a secure environment for deep drilling on a massive scale. The risks are enormous.
Construction of the Three Gorges dam occurred in a highly populated area, with full urban services nearby, in fact the population that had to be removed as the dam filled was over one million people. From the perspective of the logistics of infrastructure construction the location was challenging, but workable, with ready access for the machinery needed to shift rock, blast and built the massive reinforced concrete walls. Everything needed, even huge and awkward items such as turbines, could be transported readily to the site, not least by large ships steaming upriver from Shanghai and China’s most industrialised belt.
By comparison, Metok county is the very last of China’s 2000 counties to be accessible by any road at all. It was only in December 2010 that Chinese engineers blasted the last rocks separating tunnels coming from both ends of a 3.3km shaft which is to enable road traffic from Pome (in Chinese Bomi) county to get through to Metok. Then road making machinery will be able to enter, and construct a road to Metok town, the county capital on the Yarlung Tsangpo. The tunnel is not big enough to handle huge items such as hydropower turbines, nor can they be brought up a raging mountain river via Bangladesh and India. The news of the road tunnel connection was reported in Indian media as further evidence of China’s threat to Indian rivers. The last thing India would ever do is to facilitate the portage of heavy equipment enabling China to dam the Tibetan river relied upon by north-eastern India.
Metok is also the last of China’s 2000 counties to have any Chinese, Han Chinese, living there. The official 2000 Census lists Metok (Motuo) uniquely as having no Han at all, and only a small Tibetan population of 1300. Most of the people are neither Han nor Tibetan but are officially classified as Lhoba (Luoba in Chinese), an ethnicity that counts as one of China’s officially recognised 56 ethnicities constituting China. In Metok and nearby counties there are 2500 Lhoba, and about 4000 over the border in northeastern India, where they are more often known as Mishmi and Tani. They were classified by Chinese ethnographers as living in the evolutionary stage of “primitive communism”, an egalitarian tribalism which meant they were spared the compulsory class warfare China forced on Tibet. In China’s rigid social evolutionary ladder, which all people must pas through, primitive communism is the lowest of all, prior to the feudal slave owning stage of history which is where Chinese investigators fixed the Tibetans, necessitating compulsory struggle sessions in which educated Tibetans were denounced and liquidated.
The Lhoba were spared, partly because the official Chinese ethnologists who decided how everyone was classified, resisted the pressure on them to radically simplify reality and lump many peoples together, for the sake of administrative utility. Elsewhere, people’s own preferred identities were ignored, but the Lhoba got to be one of only 56 minority nationalities, down from over 400 in the early 1950s. Rather than colonising Metok county with Chinese cadres, Lhoba children were taken to schools in China’s interior to be taught how to be Chinese citizens, and become the cadres transmitting Beijing’s policies to these rugged borderland gorges.
The Lhoba have been further beyond the reach of the Chinese party-state than any minority, living in small villages close to raging rivers, hunting, trapping and trading with Tibetan farmers. Should the world’s biggest hydro dams twice or thrice the power of Three Gorges, come to Lhoba land, the Lhoba will have no way of even expressing their true feelings to the world.
Undeterred by the multiple impracticalities of this paper dream of a double sized Three Gorges on the Yarlung Tsangpo, Chinese armchair engineers have fancifully proposed the use of small nuclear explosions to blast the necessary tunnels. This wildly improbable fantasy has been seized upon by Indian hawks who enjoy ratcheting up Indian fears of China, and their Tibetan friends who take all opportunity to portray all Chinese speculation as fact, all Chinese plans as malevolent. Perhaps the most popular retelling of the nuclearisation of the Yarlung Tsangpo is in the film Meltdown in Tibet, by Canadian film maker Michael Buckley. No evidence is presented to back the assertion that these dams are to be built, and nuclear explosions are a key construction method. The fashion for nuclear explosions as a tool of civil engineering was popular in many countries, which faded as reality dawned that blasting is no substitute for digging and tunnelling. In Australia in the 1960s mining entrepreneurs with a penchant for simple solutions to complex problems proposed nuclear blasting of canals to take seawater to the dry salt lake beds of the inland, or to blast a canal from monsoon northwest Australia to the parched inland rangelands of West Australia a thousand or more kilometres south. Such ideas were quietly dismissed, as not worth a second look. In China such enthusiasms still surface. In 1996 Scientific American reported a macro-engineering plan involving peaceful nuclear explosions bruited during the December 1995 Beijing meeting of the Chinese Academy of Engineering Phy¬sics, to excavate a 20 km long canal through an intervening mountain range north of the Yarlung Tsangpo in order to convey irrigation-quality water on its way far to China’s arid north. Somehow a number of reports have muddled two Chinese plans which both begin on the Yarlung Tsangpo. One is an extraordinarily ambitious plan, of which nothing has been heard for years, to divert water far to the north, all the way to China’s over-used Yellow River, to replenish its depleted flow. The nuclear option was mentioned as a way of dealing with intervening mountain ranges which stand in the way. Some reports, based on hazy knowledge of Tibetan geography, assume nuclear explosions deep underground, are also proposed, not for blasting a canal but tunnels to link the Yarlung Tsangpo with itself further downstream across the sides of the great bend. While both of these massive projects based on extracting water and/or electricity from the Yarlung Tsangpo do have their supporters, they remain too big even for the red engineers in charge of today’s China, with no sign for several years that either plan is under serious consideration.
THE GOLDEN DECADE OF DAMMING BEGINS
Perhaps these mega dams will be built one day, given that China’s modern hydraulic economy has, as a matter of revolutionary pride, built more dams than anywhere on earth in the past 50 years, displacing as many as ten million farmers in the way of progress. But that day is not soon. The Yarlung Tsangpo gorge does not go in a decade from being a heroic discovery of Chinese (or American) masculinity, to being an industrial worksite for a statist development project bigger even than Three Gorges.
Focussing on the impossibly over scale megaprojects distracts attention from the large number of smaller dams that are planned for Tibet. But even these are caught up in the chronic tension and suspicion in India about China’s intentions. The plan for a dam across the Yarlung Tsangpo, much upstream from the great bend, capable of generating electricity for nearby Tsethang town and the city of Lhasa, has been met in India with claims of Chinese malevolence. Supporters of India’s military establishment have even suggested that, in the event of hostilities, China could use the dam under construction at Zangmu as a weapon, opening the floodgates to inundate Indian towns downstream. The Zangmu dam will take a substantial portion of 12th Five-Year Plan funding, but it is not in any way designed as a water diversion dam, only as a generator of electricity, after which the water will be returned to the river. This does not reassure Indian critics, who depict the dam as massive, either depriving India of much needed water, or flooding it, or both.
Many dams will be built, and this is of great concern to the many southeast Asian downstream users of the waters of the Mekong, as well as Tibetan communities distressed at their powerlessness to in any way speak up for themselves or those downriver. The painstaking research pieced together by http://tibetanplateau.blogspot.com shows dozens of hydro dams under active consideration, or already under construction, around the eastern rim of the Tibetan Plateau, and deep in Tibet, where dams are the primary source of electricity to power China’s urbanisation strategy for Tibet. Some are modest in scale, yet still raise issues of displacement of farmers, interruption of fish migrations, and risks of siltation as rivers swell in monsoon months and erode their course, then dump their load when water is slowed by a dam. Many concerns are raised by these dams, especially the bigger ones on the faster flowing mountain rivers of Tibet as they begin their descent from the Plateau.
But no debate is possible in Tibet. All contributions from Tibetan civil society are quickly criminalised, declared to be an illegal discourse, part of the “splittist” plot to destroy China’s unity and stability. Although the wider world may soon know which of the many proposed hydro dams in Tibet are to be constructed as part of the 12th Five-Year Plan, the Tibetan villagers most affected are neither told what to expect, nor given any public space to participate in decision making. While there is limited freedom for Chinese environmental NGOs to speak up for protection of Tibet, Tibetans themselves must remain silent.
International organisations are sometimes caught up in this untenable situation. UNESCO was persuaded to declare the parallel gorges of three great rivers leaving Tibet to be the Three Parallel Rivers World Heritage UNESCO protected area, but UNESCO allowed China to exempt from the protected area boundaries the actual rivers, leaving China free to build dams, while proclaiming the gorges rising above the river beds to be a global tourist heritage wonder protected by UNESCO listing.
China is now determined to roll back the advances in recent years of the environmental movement, in order to ensure there are no obstacles to the coming “golden decade” of dam building. Popular resistance to being displaced by development, and environmental objections are to be swept aside, as dozens of new dams are constructed all along the flanks of the Tibetan Plateau, proclaiming China’s credentials as a “green energy” power. China’s next Party Secretary Li Keqiang says of the 12th Five-Year Plan: “In the coming five years, China will vigorously develop the green economy and low-carbon technologies to bring down significantly energy consumption and CO2 emission per unit of GDP.” (Financial Times 10 January 2011) This is a carefully crafted formula to raise energy efficiency and reduce energy intensity while accelerating total energy use as production continues to increase as fast as China can manage. What this formula masks is that coal use in China, dug domestically and increasingly also imported, is set to rise and rise over the 12th Five-Year Plan. Between 2007 and 2035 China’s use of coal to generate electricity will triple, even if China fulfils all its “green” plans for hydropower, wind power, solar power and nuclear power installation.
Source: International Energy Outlook 2010, International Energy Agency
Much of the new 12th Plan dams will be in the heartland of Tibet, to power the copper smelters, ore concentrators, rock crushers, urban infrastructure and glossy tourist hotels of central Tibet, the essential power supply enabling the 12th Plan’s “leaps-and-bounds” development of Tibet Autonomous Region (TAR) to be achieved. Even the great bend of the Yarlung Tsangpo and the several hydro dams well upstream of the great bend are all in TAR, where Tibetans are especially disempowered, under constant surveillance and suspicion of harbouring splittist tendencies the moment they speak up against dams or other environmental costs Tibet must pay. The harsh prison sentence given in 2010 to Karma Samdrup, a Tibetan businessman, environmentalist and community leader, indicates the price of speaking that questions Chinese governmental practice in Tibet.
GREEN TIBET, BROWN TIBET
Tibet has been offered to the world as a sacrifice for China’s greater good before. Tibetan nomads have been removed from their pasture lands, forced to lead idle lives in concrete block settlements, in order to grow more grass for protection of China’s upper watersheds in Tibet. These hundreds of thousands of “ecological migrants” are officially voluntary patriots sacrificing their lands and livelihoods for the greater good of China’s downstream. The creation of “paper park” protected areas covering large portions of Tibet’s alpine deserts has been engineered as a zero/sum game pitting wildlife conservation against the presence and life of nomads. Similarly, other official Chinese schemes for reforestation, converting sloping land to ecological plantations, “grain-to-green” and other slogan-led programs with international backing, invariably exclude Tibetan farmers and nomads from pursuing their livelihoods while also contributing to the conservation effort. Instead of enlisting local Tibetan communities as participants essential to the success of reforestation, degrading grassland rehabilitation and de-desertification, Tibetans are fenced out, declared redundant and are resettled elsewhere.
China makes much of its contribution to global campaigns to conserve biodiversity, mitigate climate change, step up investment in green energy, protect watersheds and reduce energy intensity and each time it is the Tibetan Plateau that is further disempowered, and divided into zones of exclusion, adjacent to zones of intensive investment in dams, highways, railways, mines and urban boom centres, all of which attract immigrants, adding to population pressure on a plateau the size of western Europe that has never sustained a human population of more than six million. China’s overall pattern of intervention in Tibet divides the plateau between areas developed intensively for production, and large areas mapped out of bounds for Tibetan use in the name of environmental issues. Excluded from the land use conversion zones and outnumbered in the urban production zones and dam construction sites, Tibetans increasingly have nowhere to live Tibetan lives, pursuing Tibetan livelihoods making extensive, mobile use of the whole plateau below the snow line of the Land of Snows.
China’s various slogan-driven “green” mass campaigns may each make sense taken in isolation, but what they add up to is an incoherent, deeply contradictory vision of Tibet as China’s salvation, providing China all at once with abundant clean water, minerals and hydropower, a mass tourism boom and green credentials globally. The new Tibet of the 12th Five-Year Plan is a patchwork landscape of intensive, exclusionary conservation; and intensive productivist development. China wants Tibet to be both pristine and unspoiled; and a productive supplier of hydropower, oil, gas and minerals to distant Chinese manufacturers and cities. It is this dual vision that has portioned Tibet into productivist brown and post-productivist green zones, chopping up a land which required no such interventions by state power until Chinese governmentality reached far into the rangelands in the 1950s, setting off a chain of policy failures that the 12th Plan golden decade of dam building greenwash is meant to correct.
Sweeping aside those displaced by hydro dam development, and dismissing the concerns of environmentalist objections to dams may not be as easy as the announcements in China’s official media suggest. Social unrest is growing, and rural Chinese are better aware of their legal rights. They are less willing to accept eviction from their farms, to make way for dams, when compensation for lost livelihoods and promises of better substitute land and higher incomes than ever prove yet again to be meaningless in practice. The rise of popular blogs exposing official expropriations of land is one sign of popular resistance among those most immediately displaced. But these days the environment movement in China attracts well-connected city dwellers, the sort of Chinese citizens who read the English-language Shanghai Daily and are not at all pleased to be informed that the state is about to end the “long halt caused by environmental concerns and the social upheaval of relocating people living in the shadow of dam site.
[OPINION-DISCLAIMER]
