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Back to School Special: Free Diesel Fumes in Class

2008-09-03T22:43:46Z

An important, new study just came out that addresses the effect of urban planning and road development on the health risk of students attending schools near major roadways.

Researchers at the University of Cincinnati looked at the proximity of public school students and major highways in nine large Metropolitan Statistical Areas (MSA) around the country. In sum, they found that more than 30 percent of the students in these MSAs went to schools that were within 400 meters of a major roadway and more than 10 percent went to schools that were less than 100 meters than a highway. For some MSAs, almost half of the student population attended schools near major roadways, resulting in a potentially increased risk for asthma and other chronic respiratory problems.

The authors concluded that proximity of major roadways should be an important factor in considering sites for new schools and developing policies for reducing the exposure in existing schools.

I think this is only half the story.

Sure, we need to do a better job coordinating future urban development, transportation and environmental policies. We must do this.

But we also have to speed up the replacement or retrofitting of the older, smoking diesel buses that service these schools and the trucks that pass by on all of those nearby highways.

Here’s why:

Despite one EPA rule that lowered smog-forming nitrogen oxides (NOx) by 40 percent in 2004 (and a consent decree that required most engine makers to start selling those engines in October 2002) and another EPA rule that reduced diesel NOx by another 40-50 percent and particulate soot by 90 percent in 2007, more than half of all of the trucks and buses on the roads predate both of these rules and the consent decree.

From the perspective of eliminating the diesel soot particles that can trigger asthma attacks and other emergencies, the picture is even worse. We don’t have bombproof data yet, but it’s safe to say that at least 80 percent of the trucks and buses on the roads today lack the particulate filters that became standard equipment in 2007, thanks to the latest EPA diesel rule. These filters are the only technology that removes almost all of the fine particulate soot from the tailpipes of today’s diesel engines.

And, here’s another important piece of information: According to EPA and other studies, every dollar spent to retrofit an existing diesel engine with a particulate filter yields $12-16 in health benefits. It’s hard to find an example of a more cost-effective pollution expenditure.

As we look to ensure that the diesel problem actually gets solved anytime soon (as compared to waiting 30 years or more for all of today's dirty-yet-durable diesels to die a natural death and be replaced by engines that meet the 2007 or upcoming 2010 standards), as we think about how to best spend transportation and air pollution-related moneys in the next transportation funding bill that Congress will consider next year, and as we think about how to incorporate what we know about diesel exhaust into what planners, governments and developers are doing with smart growth and related land use issues, accelerating the clean-up of the existing diesels should not fall off the radar screen.

Swim for your lives

2008-08-22T15:57:23Z

Today’s AP reports that aerial surveys conducted by the Minerals Management Service on August 16 recorded 9 polar bears swimming far from shore or any pack ice. As Arctic sea ice disappears, recording incidents of such long-distance swimming is becoming increasingly common.

Steven Amstrup, senior polar bear scientist for the U.S. Geological Survey in Anchorage, said the bears could have been on a patch of ice that broke up northwest of Alaska's coast.
"The bears that had been on that last bit of ice that remained over shallow shelf waters, are now swimming either toward land or toward the rest of the sea ice, which is a considerable distance north," he said in an e-mail response to questions.
It probably is not a big deal for a polar bear in good condition to swim 10 or 15 miles, Amstrup said, but swims of 50 to 100 miles could be exhausting.
"We have some observations of bears swimming into shore when the sea ice was not visible on the horizon," he said. "In some of these cases, the bears arrive so spent energetically, that they literally don't move for a couple days after hitting shore."

The risk of increased polar bear drownings is one of many affects of global warming and receding Arctic sea ice on polar bears about which biologists have long been concerned. These concerns first surfaced after a mass polar bear drowning off the coast of Alaska, where up to twenty-seven polar bears may have perished during a single storm. Writing about this (and other) incidents in its decision to list the polar bear as a threatened species, the U.S. Fish and Wildlife noted that

This suggests that drowning related deaths of polar bears may increase in the future if the observed trend of recession of pack ice with longer open-water periods continues.

What is the Bush Administration’s response? Why, new proposed regulations that attempt to foreclose any avenue to address global warming pollution through the Endangered Species Act, of course! Speaking of which, yesterday NRDC and over 100 other conservation groups, representing millions of Americans, requested that the Department of the Interior extend its comment period on the proposed regulations and hold public hearings on its proposed regulation. Let’s hope they listen.

Help Dan Save Traffic

2008-08-21T22:02:53Z

Sorry that I’ve been out of the Switchboard loop for awhile. While I was away, my friends at USPIRG held a “21st Century Transportation” video contest and you can watch the winner here. (Kudos to Streetsblog for highlighting this today, and for their continued great work covering the NYC sustainable transportation scene).

The video is about Dan. Dan loves “Sweet Lady Traffic,” loves everything about it. His greatest fear: in next year’s transportation funding bill, Congress will take money away from building highways and spend it on trains and buses. This will, according to the video, “suck the lifeblood out of traffic.”

Take a minute and 41 seconds and watch:

There is, of course, a serious side to this issue.

In response to high gas prices, Americans are turning to transit to get to work and school in numbers that have not been seen since the 1950s. Unfortunately, in too many cities, high diesel prices and transit funding cuts (in part due to lower gas tax receipts) are adding up to overcrowded buses and long delays at exactly the wrong time.

Here are just a few examples: In New York, the transit system faces its worst fiscal crisis since the 1970s, cutting services and facing a 5-year capital funding gap that could be as high as $20 billion; in California, there’s a proposal to cut $1.4 billion from the state’s transit fund for next year; in Cleveland, San Diego and many other cities, services are being cut to fill a budget holes despite record ridership levels. The list could go on and on – according to the American Public Transit Association, roughly one-fifth of the nation’s transit agencies cut services over the past year.

Responding to this transit funding crisis, the House of Representatives passed H.R. 6052, the Saving Energy Through Public Transportation Act, by a vote of 322 to 98 in June. The Act authorizes 1.7 billion dollars to transit agencies across America to expand services and reduce fares.

When the Senate returns to work in September, will it take up a similar effort? Thankfully, Senator Clinton has introduced a Senate version of H.R. 6052, but that’s a long way from passing a bill for the President’s signature.

The bottom line is that we cannot break our addiction to oil, we cannot solve our global warming problems, and we cannot give Americans clean, health air without investing in transit and other alternatives to driving. Support increased funding for transit.

"More protection, less red tape" . . . yeah, right.

2008-08-21T16:03:01Z

Secretary of the Interior Dirk Kempthorne has a wildly misleading op-ed in USA Today about his proposed regulatory changes to the Endangered Species Act. The Secretary makes it sound like his sole concern when proposing these changes was preventing the Endangered Species Act from being used to address greenhouse gas emissions (more about that later). He writes:

Congress, however, never intended this law to be the solution to global climate change. The law is already a complex source of red tape and litigation. The possibility of it becoming a tool for greenhouse-gas oversight — as a consequence of the polar bear listing in May — threatened to overwhelm agency experts and do more harm than good to the cause of conservation.
So the Interior Department recently proposed common-sense regulations that would prevent the law's consultation process from becoming a back-door mechanism to curb greenhouse gas emissions.

This is simply wrong. More than that, it is deliberately wrong.

As I’ve discussed before, the core of the new regulations is a provision that allows federal agencies to determine for themselves if their contemplated activities may negatively affect protected wildlife. And if they decide “no”? Well, then the agency can proceed with its plan without any outside review. These “self-consultations” would replace existing rules that require federal agencies to first consult with independent scientists at the U.S. Fish and Wildlife Service and the National Marine Fisheries Service if they conclude that any of their projects “may affect” a protected animal or plant.

Here’s the point: self-consultation is an idea that has been rattling around Washington, D.C. (promoted by industry groups) for years, certainly long before the polar bear ever shambled its way onto the list of endangered and threatened species. In fact, variations of self-consultation has been tried (often unsuccessfully) on the EPA’s regulation of pesticides and on Forest Service and Bureau of Land Management projects, such as logging and prescribed burns—none of which has thing one to do with global warming. If adopted, the self-consultation rule will apply to all federal agencies and to all listed species. Everything from road construction to off-road-vehicle use to dredging rivers will be impacted. Using the polar bear’s listing as an excuse for such mischief is like blaming a hospital patient for the high cost of healthcare.

USA Today understands the broader implications of such a massive abdication in oversight. In a parallel editorial that also ran today it writes:

But the plan to remove automatic review by fish and wildlife experts is truly alarming. It's one of several regulations the lame-duck Bush administration is trying to push through to reward its backers and tie the hands of its successors.

In this case, it's ludicrous to expect that federal agencies that build dams and roads will seriously search out impediments to their projects. Even small children can cite the fox-and-henhouse parable.

So what about that global warming argument? There is absolutely no reason that the Endangered Species Act, any more than the Clean Air Act, the National Environmental Protection Act, or any of America’s other bedrock environmental laws, shouldn’t be used to control global warming pollution providing, of course, that the situation warrants it and that law applies. If this is an issue that Secretary Kempthorne is truly concerned about, then that’s debate he should have in Congress. What he should not be doing is using the polar bear as an excuse to weaken the Endangered Species Act for all of America’s wildlife.

Court to EPA: “Read the Statute. Read the Statute. Read the Statute.”

2008-08-20T05:25:28Z

It’s that time of the month – for the U.S. Court of Appeals for the D.C. Circuit to issue yet another decision overturning a Bush EPA rule for violating the plain language of the Clean Air Act. Yesterday’s decision in Sierra Club v. EPA vacated an EPA rule that actually had prohibited state, local and EPA permitting officials from including adequate air pollution monitoring in the operating permits of approximately 18,000 industrial facilities, such as utilities, oil refineries, incinerators, cement plants and the like. NRDC was one of the prevailing plaintiffs in the suit, represented by extremely talented counsel at Earthjustice.

EPA’s rules previously had not only allowed permitting officials, but required them, to impose air pollution monitoring that was sufficient to “assure compliance” with all air pollution requirements included in industrial operating permits.

EPA stared that sensible requirement down and said, “Adequate monitoring? Assure compliance? Not so much our bag. We prefer letting polluters continue with monitoring that we fully acknowledge to be inadequate, and prohibiting states from doing something about it. We’ll get around to dealing with this our way, in our own sweet time.”

And when would that be? Well, never, based on EPA’s sorry track record of failing to correct monitoring that it knew to be deficient.

In a passage that reads like a hectoring haiku to incorrigible Bush EPA political officials, the court found EPA’s rule to “run counter to Justice Frankfurter’s timeless advice on statutory interpretation: ‘(1) Read the statute; (2) read the statute; (3) read the statute.’”

A waggish colleague of mine remarked that the EPA political officials responsible for this travesty should be forced to write those words on a blackboard 1,000 times. The problem is, those political officials have since left EPA to rejoin the private sector, where they are now representing the very same industry forces that cajoled EPA to issue this train wreck of a rule in the first place.

Oh and it gets even better (or worse). In 2002, EPA had issued a rule codifying its longstanding position that state and local permitting authorities were authorized and indeed required to improve inadequate air pollution monitoring in permits for industrial polluters. A coalition of utility companies called the Utility Air Regulatory Group (UARG) challenged that rule in court. (Could there be a better villainous acronym for polluting utility companies than “UARG”?)

At this point it’s worth quoting the court’s opinion, which flavors an otherwise dry recitation of events with a single italicized word that evokes an image of the judges’ eyebrows creeping up their foreheads, recoiling from EPA’s shamelessness:

Rather than defend the proposed rule, the agency settled the litigation by agreeing to adopt a final rule that would interpret [EPA’s existing rule] to prohibit state and local permitting authorities from supplementing inadequate monitoring requirements.

That’s right – EPA not only backed down in the face of the earlier utility industry lawsuit, the administration joined hands with UARG and issued a new rule that did the exact opposite of what EPA’s industry-challenged rule had done.

That new rule is the one the court struck down yesterday for squarely violating the Clean Air Act.

So much for the Bush administration’s claimed commitment to federalism; EPA threw state and local agencies under the bus faster than UARG lobbyists could ask EPA for a box of bon bons and a commitment ring to go with their sweetheart deal.

And where is one of the two former Bush EPA officials most responsible for this rule working now? At the private law firm that represents UARG, which intervened on EPA’s behalf in trying (unsuccessfully) to defend this illegal rule. (There is no indication that the former EPA official worked on the lawsuit itself for UARG.)

In fairness, EPA officials can read. I’m confident they even read the statute. The problem is they did not care to do what the statute commanded. EPA preferred to side with industrial polluters over states, the public and air quality. Industry foxes weren’t just guarding the henhouse; the foxes were invited in to have a house party.

In the future, the D.C. Circuit judges need to be a little more blunt with EPA, offering agency officials the following more timely advice on statutory interpretation of the Clean Air Act:

Read the statute. Follow the statute. Stop wasting our time.

What’s in a name?

2008-08-18T22:02:59Z

Andrew Sullivan links to a post by Professor Jonathan Adler at The Volokh Conspiracy about a poll that shows people are much less likely to describe themselves as “environmentalists” than they were 20 years ago.

Adler is correct, I think, when he writes: “Does this mean that Americans are less supportive of environmental protection than in the past? I doubt it.” Indeed, if you look at the poll itself, it’s pretty clear that there isn’t a whole lot of data to support that contention. In what strikes me as a bit of wishful thinking, however, Adler then surmises:

One possibility is that an increasing percentage of Americans reject the idea that the environmentalist movement has a monopoly on what it means to be "pro-environment." Americans who support environmental protection may feel uncomfortable with either the tactics or policy prescriptions embraced by establishment environmental groups. If so, it should not be much of a surprise.
A decade or so ago --back in my own activist/think tank days -- I commissioned polling work on what Americans believed it meant to be "pro-environment," finding that many Americans saw "conservative" approaches to environmental protection -- e.g. decentralization, protection of property rights, non-regulatory measures, etc. -- as "pro-environment." (See summaries here and here.)
I believed then -- and believe now -- that this and other polling data suggest that establishment environmentalist groups lack an enforceable monopoly on what it means to be "pro-environment." Insofar as conventional "greens" dominate the field, it is by default. Conservative and libertarian types generally -- and conservative politicians in particular -- have largely ceded the field. They either endorse conventional policies on the cheap, or oppose establishment environmentalist proposals outright without proposing a positive alternative.

As I’ve written about before, the fundamental problem with this line of reasoning is that it mistakes the environmental movement for one that can be easily assigned a place on the conservative-to-liberal spectrum. While that may well have been true at one time, I don’t think it’s nearly as true today as it once was. In fact, “establishment environmental groups” are far more pragmatic than most commentors give them credit for and are more than willing to embrace the kind policy prescriptions that Professor Adler mentions—if they work. Look at the mainstream environmental support for a cap-and-trade mechanism (which is, at its base, a market mechanism) to control global warming pollution. Or the support by some groups for individual fishing quotas (a property-rights approach to the tragedy of the commons).

But—and here’s the crucial difference with many of those who try to create “conservative” environmental agendas—environmental groups in my experience don’t reject or accept solutions to environmental problems based on how they fit into a predetermined ideological spectrum. Do many within the environmental movement have biases and preconceptions? Of course. And do some of those biases make them skeptical of things like “decentralization”? Mine certainly do. But if you have to ask whether an environmental policy is “conservative” or “protects property rights” in order to support it, then I would suggest that your agenda has more to do with something other than protecting the environment.

So why the poll result? As Frank Luntz famously pointed out in his 2003 memo to Republicans about how to communicate about the environment: “‘Environmentalism’ can have the connotation of extremism to many Americans, particularly outside of the Northeast.”

Such things do not happen by accident, of course. Just like the term “liberal” and “religious right” did not spontaneously acquire negative connotations, I believe there has been a concerted effort to brand “environmentalists” as extremists, self-righteous, nature worshippers, etc., by our political opponents. That effort is the more likely explanation for ABC’s poll results than a need for a “conservative” environmentalism.

Profiles of the edge

2008-08-17T19:36:13Z

Like a shipwrecked sailor clinging to the storm tossed cliffs of an angry sea, many plants and animals in Virginia and Maryland, such as the seabed amarath, cling to life as they pull against the swirling drain of extinction. Today the Washington Post begins its profile of 17 of the District of Columbia region’s endangered and threatened species, which will run over the next several weeks. The article starts off by recapping the Bush Administration’s recent proposed regulations to gut the Endangered Species Act’s consultation provisions, but then goes on to place that proposal in the context of specific species. It also includes a nice gallery of artwork. One of the dangers of the Bush Administration’s proposal is that it seems so abstract. But its consequences will be all too real, not just for imperiled wildlife in D.C., but across the United States. Hopefully, the Post’s profiles will remind legislators returning from their summer break what’s really at stake.

[This post is my entry into the NRDC Bulwer-Lytton © Environmental Blogging Competition]

Real Economic Stimulus with Energy Efficiency

2008-08-15T21:52:39Z

Oil prices are dropping to below $115 a barrel, so I guess the imperative to reduce our consumption soon will go away as well. That is what happened after the previous price spikes for oil in 1973, 1979, 1991, and 2004.

So we probably won’t do anything to prevent the next price spike: Congress recessed for August when prices were much higher than today without acting on consensus legislation that would have provided moderate-term tax incentives for energy efficiency in homes, appliances, and offices — incentives that would start us on the road to saving 4 times as much energy in the form of gas alone as the oil industry thinks could be found in the Alaska National Wildlife Refuge. These incentives, packaged with tax credits for renewable energy, had strong bipartisan support and were also backed by a broad coalition of business as well as environmental interests.

It seems that we can’t fix the leaky roof when it’s raining, but we don’t want to bother when it’s sunny.

We are especially lax on fixing it when the fix is invisible — when it is based on energy efficiency measures that literally cannot be seen.

Maybe we can take the right steps on energy by realizing that fixing our energy problems will also fix most of what’s wrong with the economy this summer.

And energy efficiency — the invisible but largest energy resource — is at the heart of the economic solution.

I will be blogging about this in the coming weeks. Some of the material in these blogs will appear in my new book, tentatively titled, Invisible Energy: How Efficiency Can Stabilize Global Climate and Fix the Economy, forthcoming from Bay Tree Publishing, which also brought out Saving Energy, Growing Jobs.

The fundamental problems facing the American economy are not broadly based concerns that can be addressed easily through conventional government interventions. Many economic slowdowns were due to broad problems such as weakening consumer demand or increasing general inflation. These could be dealt with by adjustments in fiscal and monetary policy. But most of the problems facing the American economy today relate to the weaknesses of specific sectors of the economy. These weaknesses are not random or accidental, but rather are the result, to a greater or lesser degree, of the failure to address the sorts of energy policies that I have described.

Conventional economic stimulus won’t work to address these problems, because it will worsen some of the problems at the same time that it helps solve some others. Because of faulty energy polices, the economic situation is like driving your car with the brakes on. Pressing harder on the gas pedal won’t solve the problem, it will just overheat the brakes.

This is an apt metaphor, because the brakes are the high cost of energy, much of which results in a flow of dollars away from the United States, and the failures of markets that thwart competition and innovation. I will show in Chapter 2 how energy is at the heart of several of the most important economic problems of the late decade of the 2000s.

But in brief, these problems are:

1. The risk of inflation

2. The large trade deficit

3. The mortgage crisis

4. The low savings rate

5. Productivity increases that are too low

6. Government deficits

7. Weak consumer spending

8. Too few jobs

All of these problems are created or exacerbated by inefficient uses of energy, and by the policy choices that enable inefficiency. So all of them can be ameliorated by reformed policy choices.

Perhaps you are wondering what the mortgage default crisis has to do with energy. Here’s the connection:

The mortgage credit crisis is not only due to subprime lending: even the giant government-sponsored enterprises Fannie Mae and Freddy Mac are seeing their portfolio values decimated by defaults. But these defaults are not random: they have a very clear pattern that has mysteriously been overlooked by the financial services sector. Mortgage defaults occur in places where the need to drive is very high — strolling suburbs with little or no transit service. Urban areas with compact, walkable neighborhoods and good transit services have been largely immune from the credit crisis. What date we have suggests that the lower the auto transportation cost associated with living in a certain neighborhood, the lower the probability of default. A rational energy policy would consider transportation expenses in underwriting loans, and could have avoided a substantial if not dominant portion of the risk that is now afflicting the economy. Concerning the low savings rate, for the past 35 years, since the energy crisis of 1973, median incomes of Americans have hardly changed, yet the trend of ever-increasing need to drive cars has continued unabated. At the same time, cities and suburbs were growing in ways that reduced compactness, walkability and transit access, apparently leading to this increased need to drive to maintain the same quality of life. Driving is expensive — it was 18% of household expenditures even when gas was $1.50/gallon. This compares to only 21% for housing itself (considering only paying for the house, not the utilities or furniture, etc.). So if expenses go up, it’s not surprising that savings would go down.

This problem could have been avoided — and a repeat of it could be avoided without crushing new housing construction — if the lending industry started to consider transportation and energy costs along with the mortgage payments in deciding if a borrower can afford the house. This is not hard to do: there have already been small scale testing of Energy Efficient Mortgages and Location Efficient™ mortgages. The Location Efficient™ mortgage test was a complete success — not a single borrower has defaulted.

UPDATE: Comment Period on the Bush Administration’s Proposal to Gut the Endangered Species Act Begins Today

2008-08-15T20:13:11Z

The Bush Administrations’ last-minute proposal to dramatically weaken Endangered Species Act protections for fish, wildlife, and plants has now been officially published in the Federal Register. Because the Fish and Wildlife Service is refusing to accept any comments by e-mail, the NRDC Action Fund will be collecting comments and submitting them directly to the federal government at the close of the comment period.

If you would like to learn more about the regulations or comment on them, click here to do so simply and efficiently. If you would like to submit comments directly to the agency, you can also use the federal government’s web portal, here.

P.S. I'll be debating the proposed regulations with Kaursh Arha, Deputy Assistant Secretary for Fish and Wildlife and Parks, on Planet Green's Focus Earth, hosted by ABC's Bob Woodruff this Saturday at 6:00 p.m.

Creatures from the Deep Are Invading!

2008-08-14T14:41:11Z

We are slowly being infiltrated. Creepy, crawly, slimy little creatures are invading. Aliens are taking over.

This isn’t a sci-fi movie. It’s the Great Lakes and it is happening now. But just like in all the scary flicks, bringing the army, navy, coast guard or marines into the fray is not going to solve the problem…

The Great Lakes ecosystem, which holds one-fifth of the world’s fresh water supply, is continually threatened by invasive species---a new organism finds its way into the lakes every six months. Sea lampreys decimated fish stocks. And now the giant Asian carp, threatens to devour all remaining fish species if it can find a way out of the Sanitary Ship Canal. The zebra mussel played havoc with our water intake systems in the 80’s. The quagga mussel is now one of the most plentiful animal species in the lakes and is fundamentally changing the ecosystem.

Fundamentally changing the ecosystem? It sounds overblown, I know… But this is not alarmist hyperbole. The Chicago Tribune’s article last week “Underwater, A Disturbing New World” was…well, yeah, disturbing.

Lake Michigan’s formerly dark and rocky floor is rapidly transforming. In less than five years, the murky waters have been cleared of the plankton and microscopic critters that are central to the food chain by the ceaseless and voracious filtering by some of the new lake residents.

The quagga mussels have become so prevalent, and are such efficient filterers, that the lake water is crystal clear. Admittedly, that sounds good---the crystal clear waters and sandy beaches of Lake Michigan. But this is no tourism pitch; and while our beaches on the third coast have always been great this is not an improvement.

For the first time, sunlight can now make it all the way to the lake bottom. As a result, algae has exploded covering everything at on the floor. Now, gobies, another invasive species, that feed on the algae are the most plentiful fish species in the lake; beaches are fouled by stinking layers of muck (dead algae); and there is some indication that this contributes to the high levels of E. coli noted in our recent Testing the Waters report.

The Mother Ship

Ballast water dumped from ocean-going vessels is the number one source of new species entering the Great Lakes. The big ships expel the water they use to stabilize their loads, often dumping foreign plants, animals, and viruses with it. The problem is not new. In fact, Michigan, has aggressive laws in place to address the problem already and other states are considering legislation.

But a new federal bill is attempting to streamline the legal landscape around this issue by putting enforcement into the hands of the Department of Homeland Security via the U.S. Coast Guard.

Despite the good intentions, this bill will make it harder to tame the rogue’s gallery of foreign species that have taken up homes in our inland waters. By shifting responsibility away from the EPA and states, the bill puts enforcement in the wrong hands, eliminates states' abilities to ratchet up protections, takes the Clean Water Act out of the picture, and creates a three-to-nine year delay in ending the procedures that are largely responsible for opening the lakes up to invasive species in the first place. That’s too little, and too long to wait.

With multimillion dollar industries, not to mention the quality of life and drinking water of 60 million at stake, this is not the time to toss the baby out with the ballast water and start with a new oversight regime. Let’s let the Coast Guard protect our shores. But leave the mussels with the folks who know them best at the EPA.