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Tag: EPA

Trump’s EPA announces new plan to save the coal industry. Experts say it won’t.

Posted on by E.A. Crunden
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The Environmental Protection Agency (EPA) announced on Wednesday one of President Donald Trump’s biggest efforts yet to rescue coal, even as projections show the industry in a downward spiral largely due to market forces rather than policy.

The agency unveiled the long-awaited Affordable Clean Energy (ACE) rule, designed to repeal and replace the Obama-era Clean Power Plan (CPP), which aimed to curb climate change by lowering power plant carbon dioxide emissions. The Trump administration has repeatedly argued the CPP was a federal overreach, one the ACE rule seeks to correct.

The CPP sought to reduce the power sector’s greenhouse gas emissions 32% by 2030, using 2005 levels as a baseline, largely by shifting to natural gas and renewable energy in a blow to coal. By contrast, Trump’s new ACE rule moves power to the states, giving those governments broad authority over coal emissions on a plant-by-plant basis.

“ACE will continue our nation’s environmental progress and it will do so legally and with proper respect for the states,” EPA Administrator Andrew Wheeler said during a press conference Wednesday while touting the ACE rule’s boon to coal.

The new rule, Wheeler said, will “ensure coal plants will be part of our clean future.”

Opponents of the new plan took aim at such comments. “Instead of writing an invitation to clean energy producers, President Trump has written a love letter to King Coal,” said Sen. Ed Markey (D-MA) in a statement. “This new rule is nothing more than corporate welfare for the coal industry.”

The ACE rule’s introduction marks a major policy move for the Trump administration, which has actively sought to gut the CPP. In October 2017, former EPA Administrator Scott Pruitt announced the agency’s intent to repeal and replace the Obama-era plan. The CPP itself had been in limbo for several years after the Supreme Court halted its enforcement in 2016 while lower court lawsuits against it proceeded in an unprecedented legal move.

Experts have largely seen the ACE rule as a wide-scale effort by Trump to save coal; the president has repeatedly pushed to rescue the industry and campaigned on restoring it to its former prominence. But by virtually any measure, coal is dramatically on the decline, and few experts believe that the ACE rule will change that.

More coal plants shuttered during Trump’s first two years in office than during former President Barack Obama’s entire first term. While increased environmental requirements have played a role in coal’s decline, far more prevalent is the rise of cheaper — and often cleaner — alternatives, like renewable energy and natural gas. Overall improvements in batteries and efficiency have also been a factor.

A study released in March meanwhile found that it would be cheaper to replace most U.S. coal plants with renewable alternatives than to keep them open.

And that trajectory is only likely to continue, with national coal production set to hit a four-decade low this year and again in 2020, even as wind power emerges as an economic powerhouse.

Rather than saving the coal industry, environmental advocates and climate scientists agree that the larger threat is to efforts reigning in harmful pollution emissions: experts worry the ACE rule will hinder Obama-era climate targets.

“How we choose to power our nation will determine how serious we are about confronting climate change,” said Shannon Heyck-Williams, director of climate and energy policy at the National Wildlife Federation, in a statement. Heyck-Williams said the plan “does nothing to live up to these responsibilities.”

According to the International Energy Agency (IEA), the U.S. electricity sector needs to cut its emissions 74% by 2030 in order to avoid crossing the 2 degrees Celsius global warming threshold that the Paris climate agreement seeks to prevent. The ACE rule, experts said Wednesday, would fall far short of paving the way for such a reduction.

Independent analysis published in April found that the Trump plan would in fact increase emissions in 18 states compared to no plan at all.

EPA officials, however, insisted that emissions will still go down under the ACE rule. While the new rule will reduce emissions more than no regulation at all would, the EPA projects it will ultimately offer a reduction of 11 million tons by 2030. The agency had initially argued the ACE rule would see a drop of 13 to 30 million tons and did not explain the shift on Wednesday.

Officials also avoided any mention of the number of lives at risk from increased pollution that is likely to result from keeping coal plants open.

A leading emphasis of the CPP was the number of lives to be saved — the EPA estimated 2,700 to nearly 7,000 premature deaths would be prevented by 2030, due largely to lower pollution levels. Experts worry that the ACE rule could cause up to 1,400 more premature deaths by that time, a number obtained through a regulatory impact analysis using EPA’s own methodology.

But there was no acknowledgement of those numbers on Wednesday. Instead cost was emphasized: the administration says the new rule will save $120 million to $730 million over the next decade, a cost-benefit analysis critics argue has been stacked in favor of ACE.

“With this rule, the EPA is dodging its responsibility,” Richard Revesz, director of the Institute for Policy Integrity at New York University law school, said in a statement. “The agency is required to control greenhouse gas pollution with the ‘best system of emission reduction,’ but this approach is nowhere close, making the rule legally vulnerable.

“While Americans face mounting threats from climate change, the Trump administration is undermining environmental safeguards and manipulating its math to conceal the damage it is causing.”

The new rule is likely to face lengthy battles in court, with groups like the Center for Biological Diversity expressing optimism that “this attack on our lungs” would not survive a wave of lawsuits. Congressional Democrats similarly indicated that they would seek to fight the new policy.

This article was originally published at Think Progress on June 19, 2019. Reprinted with permission. 

About the Author: E.A. (Ev) Crunden covers climate policy and environmental issues at ThinkProgress. Originally from Texas, Ev has reported from many parts of the country and previously covered world issues for Muftah Magazine, with an emphasis on South Asia and Eastern Europe. Reach them at: ecrunden@thinkprogress.org.


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Court Orders EPA To Implement Chemical Plant Safety Rule

Posted on by Jordan Barab
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In a stinging rebuke to the Environmental Protection Agency, a federal court has called EPA’s delay in implementing the Obama administration’s chemical disaster rule “arbitrary and capricious” and told the agency to implement the rule.

EPA had argued that delaying the rule would reduce industry confusion while it figured out whether it wanted to modify or rescind the rule. The court, noting that the Clean Air Act clearly limits such delays to three months, rejected the EPA’s reasoning. The decision means that EPA can no longer delay enforcement of the rule. So far, only provisions regarding local emergency-response coordination requirements are in effect, while other provisions come into effect in 2021.

We have written frequently here about how issuing standards and regulations designed to protect workers, consumers and the environment is a long and difficult process.  Rescinding or even delaying these legal protections is also difficult because an agency is required to justify its actions and provide evidence showing why the previous regulations are no longer needed. And despite all the fanfare that former EPA administrator Scott Pruitt received for being the deregulator-in-chief, the corners he cut have come back the haunt the Trump Administration’s efforts to undermine the laws that Congress passed to protect people from preventable workplace and environmental hazards.

According to Mike Wright, Director of Health, Safety and the Environment for the United Steelworkers union, who successfully sued the agency, “The decision clearly shows that EPA – and by implication OSHA and other federal agencies – can’t just delay a rule protecting the American people on a whim, or to do the bidding of some outside group.”

Background

Following a number of chemical plant disasters, including the 2013 explosion at West Fertilizer that killed 15 people and destroyed much of the town of West, Texas, President Obama issued an Executive Order that, in part, ordered EPA to reconsider its Risk Management Program (RMP). In January 2017, EPA issued a revised RMP regulation that enhanced requirements related to emergency response, provision of chemical hazard information, and requirements for facilities to consider inherently safer processes, as well as post-accident investigations, more rigorous safety audits and improved training.

“The decision clearly shows that EPA – and by implication OSHA and other federal agencies – can’t just delay a rule protecting the American people on a whim, or to do the bidding of some outside group.” — Mike Wright, USW Director of Health, Safety and the Environment

Provisions of the 2017 rule related to clarifying regulatory definitions were scheduled to come into effect on March 14, 2017. Other provisions, including most local emergency-response coordination requirements, were supposed to become effective on March 14, 2018. The requirements for emergency response exercises, public information-sharing and post-accident public meetings, third-party audits, more rigorous post-incident analyses, and safer technology requirements are not scheduled to become effective until March 15, 2021.

The Trump administration, under then EPA Administrator Scott Pruitt, delayed enforcement of the rule three times, the last time by issuing the “Delay Rule,” which delayed enforcement of the rule for 20 months while the agency decided whether to modify or rescind the Obama rule. (The EPA did, in fact, issue a proposal to rescind most provisions of the Obama rule last May. That process is not affected by this decision.) A number of organizations, including the United Steelworkers union, sued EPA, arguing that “The Clean Air Act (CAA) is explicit that reconsideration ‘shall not postpone the effectiveness of the rule,’ beyond a three-month period.” A number of other environmental and community groups joined in challenging the delay, along with a number of states.

A Mockery of the Statute

The court found that EPA’s delay rule “makes a mockery of the statute” because it  violates the paragraph in the Clean Air Act that requires EPA rules to “have an effective date, as determined by the Administrator, assuring compliance as expeditiously as practicable.” The court writes that “The Delay Rule does not have the purpose or effect of “assur[ing] compliance”; it is calculated to enable non-compliance.” And the EPA did not consider the delay’s effect on the requirement to “prevent accidental releases,” to “minimize . . . consequences of any such release,” to “protect human health and the environment,” and “to include procedures and measures for emergency response after an accidental release.”

The court criticizes EPA for basing the delay on a bunch of “alleged ‘security risks’ and other hypotheticals raised by industry” without actually explaining why the implementation delay was necessary.

The court also mocks EPA’s explanation that the delay is intended to avoid confusion among the regulated community and local responders who would have to comply with a rule that might later be changed, when it is actually EPA that’s causing confusion “by the almost two-years’ reconsideration it desires in order to decide what it wants to do.”

EPA is also ignoring the express interest of Congress Congress which expressly stated that it wants compliance with rules “as expeditiously as practicable” and therefore  provided “a strict limit of three months on stays of effective dates pending reconsideration” in order to keep any reconsideration from delaying a final rule.

Arbitrary and Capricious

The court found the EPA’s delay rule to be arbitrary and capricious first, because it didn’t explain why it couldn’t revise (or rescind) the rule while the rule was in effect. Second,the Delay Rule didn’t provide a “reasoned explanation” why the original effective date and compliance dates were unjustified, despite the fact that the EPA in the original Obama rule had gone to great lengths to justify the compliance dates and consider comments from the public. EPA also failed to explain “why the detailed factual findings [in the Obama rule] regarding the harm that would be prevented upon implementation of the Chemical Disaster Rule are now only ‘speculative.’”

The third reason the court found the Delay Rule to be arbitrary and capricious is a favorite of mine. The court found that the EPA’s justification of the delay on “‘the timing’ of a finding by the Bureau of Alcohol, Tobacco, and Firearms . . . that the West Fertilizer explosion was caused by arson’ rather than an accident…is not a reasoned basis for delaying the entire Chemical Disaster Rule.”

As readers of Confined Space are aware, in 2016 — days before the end of the RMP rule comment period — the Bureau of Alcohol, Tobacco and Firearms (BATF), found that the fire that led to the catastrophic explosion at West was intentionally set.  (The Bureau used a highly criticized investigative process to make that doubtful finding, but that wasn’t the reason for the Court’s decision.)

The EPA partially based the Delay Rule on arguments made in chemical industry petitions to the EPA stating that they did not have enough time to comment on the BATF finding and if the cause of the fire was actually arson, that might have affected their comments and the final outcome of the rule, especially in the area of emergency response and provision of chemical information to responders and the public.

But the court rejected EPA’s reasoning — particularly as the argument impacted the emergency-response and information-sharing provisions of the Obama regulation:

Even were the court to agree for purposes of argument that the cause of the West, Texas disaster being arson is relevant to some of the accident-prevention provisions of the Chemical Disaster Rule, it is irrelevant to the emergency-response and information-sharing provisions, including those that have indisputably been delayed from the original March 14, 2018 effective date. Given that twelve of the fifteen fatalities in the West, Texas disaster were local volunteer firefighters and other first responders, this would be a fairly weak explanation for delaying provisions that EPA previously determined would help keep first responders safe and informed about emergency-response planning. (emphasis added)

The court also noted that the West disaster was not the only chemical plant incident that EPA cited to justify the original regulation, citing incidents in Hawaii, Colorado, Washington, California, Louisiana and the 2005 BP refinery explosion in Texas City, Texas.

Standing

One other feature of the court decision was that it granted “standing” to the United Steelworkers Union, allowing the union to sue the agency on behalf of its members who work in chemical facilities and live in communities surrounding the plants. As Wright explained,

The Court’s decision on the USW’s standing is especially important. The ruling clearly shows that unions have the right to defend their members, not only in the workplace, but in the broader community. And that’s a right the labor movement should always be exercising.

One final note. The decision notes that Supreme Court nominee Judge Brett Kavanaugh was a member of the judicial panel at the time the case was argued but did not participate in this opinion.

This blog was originally published at Confined Space on August 17, 2018. Reprinted with permission. 

About the Author: Jordan Barab was Deputy Assistant Secretary of Labor at OSHA from 2009 to 2017, and spent 16 years running the safety and health program at the American Federation of State, County and Municipal Employees (AFSCME).


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EPA reportedly ‘distorted’ meeting notes and workers could be more vulnerable to pesticide exposure

Posted on by Esther Yu-Hsi Lee
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In November 2017, the U.S. Environmental Protection Agency met with several groups representing farmworkers to talk about three provisions of the worker protection rules to make farming safer. Organizers walked away feeling like there was some consensus between the groups, even though there was more work to be done on these issues.

But when the EPA made their two-day meeting notes public and summarized its notes to Sen. Tom Udall’s (D-NM) office a month later, organizers noticed major discrepancies and inaccuracies between their notes and those made by the agency.

In an early March letter addressed to the federal agency, organizers expressed concern that the agency had provided not only a “distorted account” of the meeting, but may have used their group’s participation “to validate or justify Agency actions which are completing at odds with both the EPA’s mission and our own goals of protecting the workers who grow our food, and the communities that surround them, from the harmful effects of pesticides.”

The concerns arose from the two-day November 1 and 2, 2017 meeting when EPA officials met with members of the Pesticide Program Dialogue Committee (PPDC) — comprised of farmworker and health organizations to discuss the Agricultural Worker Protection Final Rule. At the meeting, both sides discussed enforcing a minimum age of workers allowed to handle pesticides; requiring agricultural employers to provide pesticide application information and safety data sheets to a designated representative; and requirements to limit pesticide exposure for agricultural employers to keep workers and other people out of areas known as application exclusion zone (or “AEZ”).

Concerns have persisted since the EPA’s letter to Udall’s office, which appeared to “conflate” some feedback from PPDC members that actually came from those in the agency. Udall has an oversight role over EPA rulemaking.

The EPA’s assertions to Udall about the minimum age provisions were “not correct,” PPDC stakeholders wrote, explaining that the letter made it seem like the PPDC stakeholders agreed that the “family exemption” provision — in which immediate family are exempt from many worker protection standard requirements —  was “not flexible enough to accommodate family-owned and operated businesses of commercial applicators.” In a follow-up email sent from the agency to Udall’s office in January, it clarified that the input was not from PPDC members but rather from comments received as part of the Regulatory Reform docket.

On the issue of a designated representative provision, the PPDC criticized the EPA for telling Udall that “there was not agreement on a practical way to alleviate stakeholder concerns regarding who could qualify to be a designated representative and how the information could be used.”

“This is simply not correct,” the PPDC letter signers wrote, explaining that they agreed on addressing the concerns through the establishment of a short-term workgroup on the issue.

PPDC stakeholders had fewer issues on the discussion of the AEZ, but they said the EPA’s letter to Udall “fails to mention” the “overwhelming support for the provision and that the next step was to issue additional guidance.”

The PPDC members further wrote that they had expressed “serious concerns” about the EPA’s decision to overturn its proposed ban on chlorpyrifos, “[h]owever, this input is completely omitted from your letter [to Udall].” Last August, the agency rejected a ban on chlorpyrifos, a widely-used insecticide that has been linked to brain damage and other negative human health outcomes.

“We do not have an expectation that the EPA’s decisions will always correspond with our specific points of view, yet we do expect our views to be heard and we certainly do not expect them to be ignored or mischaracterized simply because they do not fit into a pre-determined political narrative,” the letter signers added.

The alleged troubling mischaracterization of EPA’s public releases of its interaction of stakeholders may perhaps be forgiven if this was a one-off occurrence. However,  pesticides like chlorpyrifos are manufactured by Dow Agrosciences, a division of Dow Chemical which donated $1 million to Trump’s inauguration. And under the leadership of EPA Administrator Scott Pruitt, the agency has appeared to take on stances that break from mainstream scientific consensus. Recently, the EPA released guidelines that “promote a message of uncertainty about climate science and gloss over proposed cuts to key adaptation programs,” the Huffington Post reported.

Moving beyond the EPA and PPDC’s war of words, the inconsistency in characterization and feedback ultimately affect one group the most: the 2.5 million farmworkers in the country. The National Agricultural Workers Survey estimated that about half of all farmworkers are undocumented. Under this presidency, they may be afraid to seek medical help if they’re exposed to pesticides out of deportation fears.

“We have to acknowledge that what we know about pesticide poisonings relies on the farmworker actually reporting the issue either via their employer at their worksite,” Andrea Delgado, the legislative director of the health communities program at EarthJustice, told ThinkProgress. “Or they actually went to a doctor to get taken care of and that the medical provider actually knows how to identify the signs of pesticide poisoning.”

“Think about all the things that have to be aligned  — that someone has to feel empowered enough to say I know enough about my rights when it comes to pesticide exposure,” Delgado reasoned.

This article was originally published at ThinkProgress on March 30, 2018. Reprinted with permission. 

About the Author: Esther Yu Hsi Lee is a reporter at ThinkProgress focusing on domestic and international migration policies. She has appeared on various television and radio shows to discuss immigration issues. Among other accolades, she was a White House Champion of Change.


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Corporate America’s Stealth Campaign to Stop Worker and Environmental Protections

Posted on by Jordan Barab
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Admit it. If they could, Trump and most Republicans would like to just get rid of OSHA, EPA the Consumer Product Safety Commission and any other agency — or law — that protects workers, consumers or the environment.

This is all part of Steve Bannon’s goal of “deconstructing the Administrative State” — making sure that corporate America’s quest for ever higher profits and control over our lives is not hindered by any of these damn government agencies that Congress created when the liberals ruled the earth.

But simply repealing the Occupational Safety and Health Act or the Clean Water Act probably wouldn’t play well even in Trump-America where people still like to come home alive at the end of the day and hate the idea of their kids drinking poisoned water.

So what to do, what to do?

How about just making sure the government can’t issue any new protections: the standards and regulations that put teeth into the laws?

The thriving New York Times has described two of their clever strategies that would do just that.

Get Rid of the Science: “Weaponized Transparency”

The Times reports that EPA Administrator Scott Pruitt is proposing to “no longer consider scientific research unless the underlying raw data can be made public for other scientists and industry groups to examine.” Pruitt is doing this in the name of “transparency.” After all, what could be wrong with only allowing science where the raw data is available for other scientists to critique?

Well, here’s the problem.

Opponents and supporters agree that the proposed new policy has its roots in the fossil fuel industry’s opposition to a groundbreaking 1993 Harvard University study that definitively linked polluted air to premature deaths. The “Six Cities” study, widely considered one of the most influential public health examinations ever conducted, tracked thousands of people for nearly two decades and ultimately formed the backbone of federal air pollution regulations.

The problem is that this study used the private medical and occupational histories of more than 22,000 individuals.  And if this private data were made available for public review, EPA “would have to spend hundreds of millions of dollars, according to a federal estimate, to redact private information.”

The bottom line, critics say, is that if the E.P.A. is limited to considering only studies in which the data is publicly available, the agency will have a narrower and incomplete body of research to draw on when considering regulations.

It’s not like no one has ever looked at this data critically. It’s all peer reviewed by other specialists in the field.

It’s “weaponized transparency,” according to Former OSHA head Dr. David Michaels, currently a professor at George Washington University and author of Doubt Is Their Product:  How Industry’s Assault on Science Threatens Your Health.

This is not just an academic debate. Not only would this policy chill scientific study and make it more difficult to protect workers and the environment, it would cost lives — thousands of lives:

Opponents of the proposed E.P.A. policy say the effort all comes back to the fossil fuel industry’s decades-long frustration over the Six Cities study and a related one sponsored by the American Cancer Society. Those studies, which have been independently evaluated and have had their findings confirmed, underpinned the first Clean Air Act regulations on fine particulate matter. Based on the research, the E.P.A. in 1997 estimated the rule would prevent 15,000 premature deaths annually and hundreds of thousands of cases of asthma and bronchitis.

So who’s behind this nefarious, and not so subtle plot? Who else but the Koch brothers, as well as Exxon Mobil, Peabody Energy and the American Chemistry Council.

Oh, and there’s also a bill in Congress that would mandate the same thing: The “Honest and Open New E.P.A. Science Treatment Act,” also known as the “Honest Act.”

Honestly.

Weaponizing the Judiciary

Just in case restricting the data that forms the basis of protective regulations doesn’t work, the Trump administration, Republicans in Congress and corporate American have another card up their sleeve: making sure the courts reject any regulations that manage to slip through.

One area that the Trump administration has seen great success has been in the selection and confirmation of conservative judges who have passed a critical “litmus test.” Usually, when we hear the words judicial “litmus test” it’s related to the debate over abortion.

But according to an article in this morning’s New York Times, the Trump administration is applying another litmus test: reining in what conservatives call “the administrative state” by limiting the discretion that agencies like OSHA or EPA have when they issue complex regulations.

What does that mean? When Congress passes a law like the Occupational Safety and Health Act, they give OSHA the authority to issue specific standards, and the law provides some guidance for the criteria the agency has to follow. For example, OSHA has to ensure that their standards are economically and technologically feasible.  But Congress doesn’t have the time or expertise to issue the specific standards — like those to protect workers against silica exposure, trench collapses or falls. They leave that lengthy and complex work to the agency.

When the new standards are inevitably challenged in court by the affected industries, the business associations argue that the agency didn’t evaluate the science properly, or didn’t ensure feasibility in the affected industries. The judges, who like your local Congresspersons, are not experts in toxicology or risk assessment, have traditionally deferred to the agencies’ expertise: “You’ve got some science here; you’ve got some science there. Congress says that the agencies have the expertise, so we defer to their decision.”

But not for much longer, if Trump and corporate America have their way. He is appointing federal judges who are “devoted to a legal doctrine that challenges the broad power federal agencies have to interpret laws and enforce regulations.”

Are you scared? If not, you should be:

This approach has shaped what could be one of Mr. Trump’s most enduring legacies, with the potential to dramatically shrink the body of federal regulations and programs that touch almost every aspect of American life — like workplace safety, environmental protection and health care.

If it is successful, the Trump administration could come closer than any Republican White House has to achieving a goal conservatives have longed for since the New Deal: curtailing the reach of a federal government they say has grown far too large and invasive.

According to Senator Richard Blumenthal (D-CT), these ideas have been around for a long time, “but have never been weaponized in the way that Trump is doing now with his judicial nominees.”

This blog was originally published at Confined Space on March 28, 2018. Reprinted with permission. 

About the Author: Jordan Barab was Deputy Assistant Secretary of Labor at OSHA from 2009 to 2017, and spent 16 years running the safety and health program at the American Federation of State, County and Municipal Employees (AFSCME). 


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Environmental groups sue EPA for failing to protect farmworkers from pesticide exposure

Posted on by Esther Yu-Hsi Lee
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The delay also prevents the agency from setting an age requirement prohibiting young farmworkers from applying such pesticides.

The lawsuit argues that the Trump administration’s decision to postpone the effective date for implementation of the Certification of Pesticide Applicators (CPA) rule could lead to adverse harmful health issues for farmworkers and other people. That revised CPA rule–originally published on January 4 with an implementation date of March 6–would have, in part, imposed strict standards that require pesticide applicators to be at least 18 years old, be able to read and write, and establish an annual applicator safety training. Currently, there is no minimum age limit for the roughly one million certified applicators nationwide.

The lawsuit also states that the EPA failed to provide the public “adequate notice” to comment on rules to delay the effective date of implementation; failed to consider the adverse effects the delay would cause to farmworkers and their families regularly exposed to restricted use pesticides; and failed to consult with other government agencies to review environmental health consequences.

The CPA training would provide in-language lessons for people on the potential dangers of pesticide exposure, how to use equipment properly, how to prevent environmental contamination like runoff and drift, and how to report pesticide safety violations to enforcement agencies. The rule would also require training for aerial spray applications, so applicators would lessen the impact of the off-target movement of pesticides on plants, animals, and bystanders. A 2008 longitudinal government study found anywhere between 37 percent and 68 percent of acute pesticide-related illnesses are caused by pesticide drift into local communities.

Earlier this year, EPA Administrator Scott Pruitt delayed a decision to ban the restricted-use insecticide chlorpyrifos primarily used to systemically kill pests on agricultural crops. At the time, Pruitt’s agency rejected calls to ban the use of chlorpyrifos, claiming “the science addressing neurodevelopmental effects remains unresolved.”

Pruitt’s agency also put industry economic interests ahead of farmworker health safety, arguing that the continued use of chlorpyrifos would provide “regulatory certainty” for thousands of farms reliant on the pesticide and that more research was needed. His decision superseded the scientific recommendation made by the Obama administration supporting a gradual ban of chlorpyrifos. Past scientific research found a correlation between the pesticide and human health problems for farmworkers and children.

A 2012 Columbia University study found links between chlorpyrifos exposure and brain development and cognition issues in children and fetuses, even at exposure levels below the EPA threshold for toxicity. The EPA also found adverse risks among threatened and endangered species due to the pesticide.

The latest lawsuit comes days after seven states and several health and labor organizations directly challenged Pruitt’s decision, arguing that the EPA violated the Food Quality Protection Act of 1996 which requires the protection of infants and children from harm by pesticides in food, water, and exposure to indoor pesticides.

The lawsuit was filed on behalf of the advocacy groups Farmworker Association of Florida, United Farm Workers, Pineros y Campesinos Unidos del Noroeste, California Rural Legal Assistance Foundation and Pesticide Action Network North America.

Health and labor organizations, represented by the advocacy groups EarthJustice and Farmworker Justice, have strongly pressured the EPA to act on implementing the rule.

“EPA’s mission is to protect all Americans from significant risks to human health and yet it’s delaying life-saving information and training for the workers who handle the most toxic pesticides in the country,” Eve C. Gartner, an attorney with Earthjustice, said in a statement. “This delay jeopardizes everyone’s health and safety.”

In December 2016, the EPA said the rule could prevent upwards of 1,000 acute illnesses every year. Farmworkers–especially the two million immigrant farmworker labor force?–?are at the greatest risk of health problems because they’re most directly exposed to insecticides. Applicators mix and apply pesticides and can be exposed because of spills, splashes, defective, missing, or inadequate protective equipment, direct spray, or drift, according to Farmworker Justice. Farmworker families are also at risk because farmworkers bring home pesticides in the form of residue on their hair, skin, and clothing, or when pesticides drift into homes and schools near fields.

Immigrant farmworkers in particular are the least likely to receive health treatments or to file complaints because of fear of retaliation by employers. In one case, a woman whose fingernails turned black and skin peeled off her hands and face after pesticide exposure in Florida went to the doctor and didn’t file a complaint because she feared retaliation on her and her undocumented husband, the Palm Beach Post reported in 2003. In a 10-year period, less than eight percent of 4,609 violations of pesticide regulations in Florida resulted in fines, according to the Southern Poverty Law Center. And in May, several sick farmworkers in California left the scene when chlorpyrifos drifted into their field because they were likely afraid to confront medical members who could turn them into federal immigration authorities.

This article originally appeared at ThinkProgress on June 14, 2017. Reprinted with permission.

About the Author: Esther Yu Hsi Lee is an immigration reporter at ThinkProgress interested in migration and refugees. Contact her at EYLEE@thinkprogress.org.


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Trump’s rollback of environmental rules will fail to bring back coal, report says

Posted on by Mark Hand
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“Can Coal Make a Comeback?” asks a new report by Columbia University researchers.

Spoiler alert: In its first few pages, the report states that President Donald Trump will almost certainly fail to bring jobs back to coal country or dramatically boost coal production.

Rolling back environmental regulations, as the Trump administration frantically sought to do during its first 100 days, will not “materially improve” economic conditions in the nation’s coal communities, according to the report.

During Trump’s presidential campaign, he repeatedly vowed to end a “war on coal” allegedly waged by the Obama administration. But as long as natural gas prices remain at or near current levels, U.S. coal consumption will continue to decline despite the Trump administration’s plans to roll back Obama-era regulations, the report says.

“Responsible policymakers should be honest about what’s going on in the coal sector?—?including the causes of coal’s decline and unlikeliness of its resurgence?—?rather than offer false hope that the glory days can be revived,” the report says.

The report was released by the Center on Global Energy Policy at Columbia University’s School of International and Public Affairs. It was authored by Jason Bordoff, the founding director of the Center on Global Energy Policy; Trevor Houser, a partner at consulting firm Rhodium Group; and Peter Marsters, a research analyst with Rhodium Group.

The report seeks to offer an empirical diagnosis of what caused the coal industry to collapse. It then examines the prospects for a recovery of coal production and employment by modeling the impact of Trump’s executive order directing agencies to review or rescind several Obama-era environmental regulations and assessing the global coal market outlook.

Even coal industry executives and coal country politicians have dialed down their rhetoric in recent months, according to the report. Robert Murray, CEO of Murray Energy and a Trump supporter, urged him to set more modest goals during the campaign and has warned post-election that there is little chance U.S. production can return to pre-recession levels.

Senate Majority Leader Mitch McConnell (R) also cautioned?—?after the election?—?that ending the “war on coal” might not bring jobs back to his home state of Kentucky.

The Columbia University report isn’t the first to rain on Trump’s coal parade. In a report released earlier this year, Bloomberg New Energy Finance emphasized U.S. coal’s main problem “has been cheap natural gas and renewable power, not a politically driven ‘war on coal.’”

But words of caution haven’t stopped Trump from waging a crusade for coal. Two weeks into his presidency, Trump signed a congressional joint resolution eliminating the Department of the Interior’s Stream Protection Rule finalized in 2016 by the Obama Administration that would have limited the amount of mining waste coal companies can dispose into streams and waterways. In late March, Trump signed the executive order that called on the EPA to “review” the Clean Power Plan, the agency’s carbon-reduction plan for new power plants.

“Many of these actions will take months for agencies to implement and will be challenged in the courts. But they are clearly designed to communicate Trump’s commitment to deliver on his campaign promises,” the Columbia University report said. “Indeed, he signed his March 28 [order] at the EPA in front of a group of coal miners, and after signing, turned to them and said, ‘C’mon fellas. You know what this is? You know what this says? You are going back to work.’”

In the report’s best-case scenario for coal that the authors modeled, U.S. production would see only a modest recovery to 2013 levels at just under 1 billion tons a year. In its worst-case scenario, consumption falls from 730 million short tons in 2016 to 688 million short tons in 2020 despite Trump’s aggressive rollback of Obama administration climate regulations.

Rather than bet on a recovery in coal production, coal communities, governments, and other private and public sector organizations should work together to “leverage the other assets” that exist in coal country to attract investment in new sources of job creation and economic growth, the study said.

“This certainly isn’t easy,” the authors wrote. “Coal communities in particular are often geographically remote and lack the infrastructure necessary to attract large-scale investment. Miners and others in the local labor market often lack the skills necessary for jobs that offer the kind of compensation available in coal mining.”

The federal government could offer plenty of help to accelerate locally driven economic diversification efforts, according to the report. Infrastructure investment, tax credits, and re-purposing of abandoned mine land that has other economic use can attract new investment and job creation, it says.

“But this all requires a clear-eyed assessment of the outlook for the coal industry and a commitment to put sustainable solutions ahead of politically expedient talking points,” the report says.

This article originally appeared at ThinkProgress.org on May 15, 2017. Reprinted with permission.

About the Author: Mark Hand is a climate reporter for Think Progress. Contact him at mhand@americanprogress.org.


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Unionized Scientists March in Protest of Attacks on Science and Jobs

Posted on by Carly Ebben Eaton and Kathy Setian
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Of all the attacks on our civil society, the attacks on evidence-based science pose perhaps the greatest existential threat. Decisions being made about climate science and environmental protection at this critical time will shape the future of our planet.

Advances in research are produced by the twin pillars of dedicated scientists and an activated citizenry who demand that the best science be applied to today’s most pressing problems. Because scientists produce the facts that expose the lies currently being purveyed, the tip of the spear is pointed at the heart of science-based policy and research.

But the imminent threat also presents an extraordinary opportunity for the scientific community to unify around a message of resistance, one in which organized labor has a critical role to play. Unionized scientists are well-positioned to fight back against the false narratives being pushed by the administration and to advocate collectively for continued funding of crucial basic research. Science professionals need a workplace free from fear of corporate power and political malfeasance influencing their results. We are the protectors of truth and facts, and in that way we all are in service to the public. With scientific integrity, we speak truth to power.

Budget cuts are the beginning of the attack. For example, the Donald Trump administration is proposing a 31% cut in funding and 21% cut in workforce at the U.S. Environmental Protection Agency on top of less-heralded budget cuts over the past three years. Such low funding levels have not been seen since the 1970s, prior to the enactment of most of our national environmental laws. Enforcement is also targeted, crippling the EPA’s ability to protect human health.

Is this a good way to save money? Investments in environmental protection pay huge dividends for the country. For example, air pollution reductions will avoid 230,000 premature deaths and produce total benefits valued at $2 trillion in 2020, according to a 2011 study. This benefit exceeds costs by more than 30-to-1, to say nothing of the human suffering.

Scientists have long held the view that with enough data and evidence we will be able to convince skeptics that climate change is real, that humans are responsible and that immediate action must be taken. It is increasingly clear that this approach has not worked.

For the nearly 7,000 postdoctoral researchers at the University of California and Lawrence Berkeley National Lab represented by UAW Local 5810, having a union ensures strong workplace protections as well as a powerful, nationwide platform for advocacy when research comes under threat. And the collective power of the union is not limited to the workplace.

Kathy Setian and other members of IFPTE Local 20 march at the Inauguration protest on January 20th in San Francisco.

With a diverse membership that includes both higher education and the manufacturing sector, the UAW has been a leading advocate for climate change policies that both create healthy communities and address economic and racial inequities. And at the EPA, the International Federation of Professional and Technical Engineers (IFPTE) Local 20/Engineers and Scientists of California (ESC) has rallied in opposition to the cuts and will continue to speak out, including in San Francisco at the March for Science.

Make no mistake. As organized scientists, we are in solidarity with our union brothers and sisters who have lost jobs and real income steadily over the past several decades. We support the creation of jobs in clean energy sectors and in green infrastructure projects.

It is time for scientists and the citizenry who depend on science to embrace our responsibility to advocate for sound policies. Our very lives and livelihood are now dependent on stepping collectively forward into the realm of political advocacy and action.

Together we will March for Science on April 22, in opposition to the damage that the current administration seeks to do to research and in solidarity with scientists, researchers, and concerned citizens who remain resolved, undeterred, and organized in the face of these threats.

This blog was originally posted on aflcio.org on April 18, 2017. Reprinted with permission.

Carly Ebben Eaton is a postdoctoral scholar and executive board member of UAW Local 5810.

Kathy Setian was a project manager at the U.S. Environmental Protection Agency and a steward of IFPTE Local 20, Engineers and Scientists of California. She will be a speaker at the April 22 March for Science in San Francisco.


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Leaked Trump administration plan to close Chicago EPA office puts 1,000 jobs at risk

Posted on by Mark Hand
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President Donald Trump’s proposed cutbacks to the Environmental Protection Agency may include the closure of the agency’s regional office in Chicago, a move that could undermine the agency’s ability to monitor pollution in the Great Lakes and curtail its ability to implement enforcement actions against coal-fired power plant owners in the six-state region.

The workforce for the Chicago Region 5 office would be consolidated with the EPA office in Kansas, the Chicago Sun-Times reported, citing anonymous sources. Trump’s budget chief Mick Mulvaney singled out the EPA as a target for budget cuts and the agency, under the leadership of former Oklahoma attorney general Scott Pruitt, was tasked with choosing two regional office for closure by June 15. The identity of the other regional office has yet to be disclosed.

“This decision doesn’t make sense from an efficiency standpoint. Instead, this decision makes sense from an ideological standpoint,” Nicole Cantello, the head of the union representing agency employees in the region, told ThinkProgress. She received leaked information about the possible closure of the regional office and believes it accurately represents the intentions of the Trump administration.

Cantello, who also works as a lawyer in the EPA Region 5 office, added: “If you wanted to drive a stake through the heart of EPA enforcement and EPA’s ability to protect the country, this would be one way of doing it.”

News about the Trump administration’s plans to close the Chicago EPA office leaked the same week the agency discovered a potentially carcinogenic chemical had spilled from a U.S. Steel facility in Indiana into a tributary of Lake Michigan. U.S. Steel reported last Tuesday that it leaked an unknown amount of wastewater containing hexavalent chromium into a waterway in Portage, Indiana, within 100 yards of the lake.

The Region 5 office oversees environmental protection in six states surrounding the Great Lakes: Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin. “It would be devastating to environmental protection in Region 5, the office that is the steward of the Great Lakes,” Cantello insisted.

A bipartisan group of lawmakers from the region are pushing back against the Trump administration’s proposal to eliminate the Great Lakes Restoration Initiative. In a March 30 letter to House appropriations committee leaders, the members of Congress explained the initiative “is showing real and measurable results, but there is still a great deal of work to do.”

EPA employees and environmental activists gather in Chicago on Feb. 6, 2017, to protest Scott Pruitt’s nomination as EPA administrator. CREDIT: AP Photo/Carla K. Johnson

Consolidating the two regions would make EPA Region 7, located in Kansas City, Kansas, the largest regional office in the nation, covering 10 states. Region 5 has expertise in dealing with the states in the upper Midwest and a deep knowledge of Great Lakes protection. “That expertise would be completely lost,” Cantello said.

Region 5 has only 500 employees, while Region 7 employs 1,000 staffers. “You could imagine how 500 people would be able to handle all the issues going on in 10 states,” she said. “It would be virtually impossible. Therefore, it would put people’s lives at stake. For the people who live in the six states, there won’t be an environmental cop on the beat.”

Under the administration’s plan, 3,000 EPA employees nationwide would lose their jobs. Closing the Chicago office, and eliminating its 1,000 positions, would help accomplish that goal. Whether any employees would be transferred to the Kansas office is unknown. But the EPA regional office in Kansas does not have adequate space to accommodate hundreds of new employees, Cantello said.

Rep. Dan Kildee (D-MI), whose congressional district includes the city of Flint, called reports of the proposed closure of EPA’s Chicago a “misguided” move that would jeopardize federal resources to help Flint recover from its water crisis.

“If true, the closure of the EPA’s Region 5 office —which serves Michigan and other states in the Great Lakes region—is very concerning,” Kildee said in an emailed statement. “EPA efforts to protect the Great Lakes through the successful Great Lakes Restoration Initiative are also critical to reduce pollution run-off and combat the threat of invasive species like Asian carp.”

EPA employees rallied in early February against the impending confirmation Pruitt as EPA Administrator, in what was the first protest by federal workers against the Trump administration. Roughly 300 people—a third of whom work for the agency—took to the street outside the agency’s Chicago regional office.

With the latest leaked information about the possible closure of the Region 5 office, Cantello said her union plans to work with members of Congress from the six states to fight back against the closure of the Chicago office.

The Trump administration plans to focus on regional offices for job cuts, not the EPA’s headquarters in Washington, D.C. Along with Chicago, employees housed in other regional offices are fighting back against the administration’s plans to gut the agency. In the EPA Region 3 office, the mood “is fear, dread,” Marie Owens Powell, an EPA enforcement officer and a local union leader, told National Public Radio’s Morning Edition.

The Philadelphia office employees hope they can persuade their representatives to save the EPA and convince friends and family to speak out in defense of the agency’s work, the union leader said. A recent poll by Quinnipiac University showed a large majority of U.S. voters oppose cutting EPA’s budget.

The proposed budget cuts are like nothing Cantello has seen in her 27-year career at the EPA. “I’ve been through many presidential transitions and have never seen this type of animosity toward our staff and animosity toward our mission,” she said. “George W. Bush, even though there were some things around the edges he wanted to do that were from a conservative bent, generally supported our mission.”

The Trump administration wants to let the states take over many of the duties of the EPA. “This idea that the states do the same work of the folks in the region is a fallacy supported by some Republicans but is not something that is a reality on the ground,” Cantello said. “The notion that there is duplication between what we do and what the states do is not reflected in reality. All the enforcement we do is requested by the states because they can’t do the work we do.”

In the six-state Midwest region, where coal-fired power plant capacity retains a sizable share of the electric power generating mix, the EPA Region 5 office has pending cases against coal plants for violations. “We don’t know if we will be allowed to follow through with those cases,” she explained. “We already have some cases on the docket against coal-fired power plants. We may not be able to get the cuts in environmental pollution that we would get under a regular course of business.”

This article was originally posted at Thinkprogress.org on April 17, 2017. Reprinted with permission.

Mark Hand is a climate reporter for Think Progress. Contact him at mhand@americanprogress.org.


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New EPA head takes action—delaying a mining clean-up rule

Posted on by Samantha Page
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In one of his first acts of business, Environmental Protection Agency Administrator Scott Pruitt directed his new staff to delay a initiative that would require mining companies to prove they can clean up after themselves.

The order would require companies to prove they will be able to clean up the damage caused by routine mining activities. The order is an effort to reduce liability to taxpayers and improve environmental practices at mines.

But mining interests?—?such as coal companies?—?have fiercely objected to the Obama-era proposal, which was developed after environmental groups sued for better enforcement of Superfund regulations. Pruitt on Friday delayed consideration of the order for an additional four months.

“It appears the new EPA administrator is already favoring industry over public interest with this delay,” Earthworks’ Bonnie Gestring told the Associated Press.

Republican Environment and Public Works chair Sen. John Barrasso (WY) requested the delay in a letter to the EPA last month so that states and businesses would have more time to comment. Per court order, the rule must be finalized by December 1.

Mining companies have historically left a mountain of cleanup costs to state and federal governments. Before the days of environmental responsibility, mining companies would just walk away from their destruction. In more recent years, some companies have declared bankruptcy before they get around to cleaning up.

A 2015 report from the Center for Western Priorities found that cleaning up mines in Western states could cost taxpayers up to $21 billion. Under the Superfund law, the report notes, federal and state governments can be held accountable for mining clean up on public lands, where much of U.S. mining takes place.

“The hardrock mining industry, the nation’s largest toxic polluter, has already burdened taxpayers with a $20 [billion]-[$]54 billion cleanup bill and left communities with widespread water pollution,” Gestring said earlier this year.

Gestring’s statements echoes environmentalists’ primary concern about Pruitt, who, in his third tweet as administrator?—?after saying he was honored to lead and looked forward to working with staff—characterized the agency’s stakeholders as “industry, farmers, ranchers, [and] business owners.”

Traditionally, the EPA’s stakeholders have also included the U.S. public and environmental groups.

Pruitt also has deep ties to industry groups. His confirmation was marked by allegations of working on behalf of fossil fuel companies as Oklahoma attorney general, and there is an ongoing court case to force the release of emails between Pruitt’s office and oil and gas companies.

A 2014 New York Times investigation revealed that lawyers for Oklahoma-based Devon Energy had drafted a letter Pruitt sent on state letterhead to the EPA. Earlier this month, a judge ordered the AG’s office to comply with a two-year-old Open Records Act request, and a first tranche of emails was released last week, just days after Pruitt was confirmed.

The emails, requested by the Center for Media and Democracy in January 2015, show a friendly, close relationship, marked by happy hours and exchanged favors, between Pruitt’s office and a number of oil and gas executives.

But the release of a second tranche of emails has been delayed, and Pruitt’s successor has requested a stay of the judge’s order to release them. A hearing on the stay is scheduled for Tuesday in Oklahoma City.

“This maneuver is just more stonewalling by Team Pruitt to prevent the American people from seeing public records of national interest that should have been turned over prior to Pruitt’s confirmation as head of the EPA,” said Lisa Graves, CMD’s executive director. “Pruitt’s office had many months to provide his emails with corporate polluters, but is now complaining they don’t have enough time.”

Pending dismissal of the stay, the next set of emails is set to be released March 3.

This post appeared originally in Think Progress on February 27, 2017. Reprinted with permission.

Samantha Page is a Climate Reporter at @ThinkProgress. Contact her at spage@thinkprogress.org


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New Congress on Track to Block Long-Sought Workplace and Public Health Protections

Posted on by Elizabeth Grossman
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An estimated 10,000 Americans die from asbestos-caused diseases each year, a figure that’s considered conservative. Asbestos is no longer mined in the United States but it still exists in products here, perpetuating exposure, especially for workers in construction and other heavy industries. In June 2016, after years of debate, the country’s major chemical regulation law was updated for the first time in 40 years, removing a major obstacle to banning asbestos.

Exposure to beryllium, a metal used in aerospace, defense, and communications industry manufacturing, to which about 62,000 U.S. workers are exposed annually, can cause a severe, chronic lung disease. On January 6, the Occupational Health and Safety Administration (OSHA) issued a rule—more than 15 years in the making—that dramatically lowers allowable workplace exposure to beryllium. OSHA says this will prevent 94 premature deaths and prevent 46 new cases of beryllium-related disease per year.

On April 17, 2013, an explosion and fire at the West Fertilizer Company plant in West, Texas, killed 15 people and injured hundreds. In late December—after a four-year process involving public, business, governments and non-profit input—the Environmental Protection Agency (EPA) issued a rule designed to prevent such accidents, improve community response to and preparedness for such disasters.

Those three examples are among the occupational and public health protective policies finalized by the Obama administration now jeopardized by antiregulatory legislation already passed by the 115th Congress. It remains to be seen if this legislation will become law and actually used. But, says University of Texas School of Law professor Thomas McGarity, the likely outcome is “that this will make people sick and unsafe.”

“Landscape is grim as it is”

In addition to having the ability to pass antiregulatory legislation, Congress has at its disposal the Congressional Review Act (CRA). Passed in 1996 by the Newt Gingrich-led House, it allows Congress to overturn a regulation passed during the last 60 legislative working days of an outgoing administration. What’s more, it prevents the creation of a substantially similar regulation. It’s only been used once, in 2001, to overturn the ergonomics regulation passed by OSHA under President Bill Clinton.

Add to this the Midnight Rules Relief Act, passed by the House on January 4. It amends the CRA, allowing Congress to overturn multiple regulations promulgated during the previous administration’s last six months, rather than individually as the CRA requires. “This allows the House to pick and choose rules that industry doesn’t like and do it all at once,” McGarity explains.

Also already passed by the House is the Regulatory Accountability Act. It includes a provision that could threaten the change made to the Toxic Substances Control Act (TSCA) eliminating the provision that prevented the EPA from banning asbestos. As Natural Resources Defense Council director of government affairs, David Goldston explains, “This bill has a provision that says notwithstanding any other provision of law, costs and benefits have to be considered when writing a rule.” Goldston calls this phrase “dangerous,” as it means putting economic costs to industry ahead of costs to human health as TSCA previously required—a requirement the revised bill eliminated.

And, as if these laws weren’t enough to threaten existing regulations, there’s the REINS Act (Regulations from the Executive In Need of Scrutiny Act), also already passed by the House. This law essentially says that an agency rule can’t go into effect unless Congress approves it. Or, as University of Maryland Carey School of Law professor Rena Steinzor explained in the American Prospect, “In a drastic power grab, the House has approved a measure that would strip executive agencies of the authority to issue significant new regulations.”

“If the REINS Act becomes law, then Congressional inaction will supersede previous Congressional action on fundamental bedrock popular health, safety and environmental protection laws,” says Public Citizen regulatory policy advocate Amit Narang.

He also points out that if the administration of Donald Trump declines to defend regulations now under legal challenge, they could also be undone. Among the rules now being challenged is OSHA’s long sought updated restriction on occupational silica exposure.

“The landscape is grim as it is,” says Emily Gardner, worker health and safety advocate at the non-profit citizens’ rights advocacy group Public Citizen, referring to OSHA’s limited resources. “There are nearly 5,000 workers dying on the job every year and OSHA’s not able to respond to threats as they’re happening.” Now, she says, “I’m looking at a Congress that would nearly paralyze rulemaking.”

“Designed to smash the system not reform it”

These laws effectively knock the foundation out from under how agencies like OSHA, the Department of Labor and EPA go about creating the network of regulations needed to implement the intent of laws that protect workplace and public health.

“This is designed to smash the system not reform it,” says Goldston of this antiregulatory legislation.

Not surprisingly, the historically pro-big business U.S. Chamber of Commerce supports antiregulatory legislation, as does the American Chemistry Council and National Association of Manufacturers. On the other hand, it’s opposed by American Sustainable Business Council, which represents more than 250,000 business owners and says the regulations these laws aim to undo are needed to support healthy, thriving workplaces and the economy.

Apart from the CRA, all of this legislation still needs to pass the Senate and be signed by the president to become law. But with a Republicans in the majority and Trump in the White House, vetoes seem highly unlikely.

This article originally appeared at Inthesetimes.com on January 27, 2017. Reprinted with permission.

Elizabeth Grossman is the author of Chasing Molecules: Poisonous Products, Human Health, and the Promise of Green Chemistry, High Tech Trash: Digital Devices, Hidden Toxics, and Human Health, and other books. Her work has appeared in a variety of publications including Scientific American, Yale e360, Environmental Health Perspectives, Mother Jones, Ensia, Time, Civil Eats, The Guardian, The Washington Post, Salon and The Nation.


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