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How is the 10% law similar to the Law of Conservation of Energy?

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How is the 10% law similar to the Law of Conservation of Energy?

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10% law of energy transfer through trophic levels? I guess their similar in that energy is not destroyed. Only about 10% of the energy at one trophic level is passed on to the next. The rest is lost as heat (through metabolism) or decays. They are different in that usable energy is created in ecosystems (primary production by plants).

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