Wednesday, November 28, 2012

Can citizen watchdogs effectively shape shale gas era? Dealing with global reality begins in our back yards

With declining government resources to police a growing shale gas industry, can activists armed with cameras and notebooks pick up the slack?

In a series of New York Times Dot Earth posts earlier this month, blogger Andrew Revkin examines the possibility of a Do It Yourself approach to shale gas oversight, using the Web as a primary tool to create “… unparalleled opportunities to foster transparency and awareness, point out best and worst practices and share and shape ideas.” Revkin cites success stories – and Skytruth – grass roots sites that have facilitated and informed the shale gas discussion by compiling and distilling relevant industry information by and for D.I.Y.ers. The scope of problems and problem-solving ambitions is broad, but Revkin focuses on methane leaks that are alarmingly visible when using infrared cameras pointed at wells, compressor stations, and other production areas.

The pros and cons of this call to action are expressed in subsequent posts by Walter Hang, an anti-fracking activist in Ithaca New York and owner of a firm that compiles environmental data for governments and engineers, and Frank O’Donnell, a clean-air campaigner in Washington. O’Donnell choses citizen action rather than “endure the long long wait” of a government regulatory revival to curb air emissions. He cites other precedent-setting examples of grass roots environmental oversight, encouraged by the Clean Water Act, including “watershed watchdogs” that spur government to address water pollution; and he raises the possibility that cash awards could be available for the work of volunteers that leads to convictions:

Similar watchdog patrols (“methane monitors?”) could be deployed with some financial incentives under the Clean Air Act. A little-known and, to my knowledge, never used, provision of the Act is designed to spur citizen action.

Hang is less optimistic. The complexity of the task invites quality control problems leading to bad analysis. “Citizen mapping efforts sound good, but they are plagued by serious limitations and spatial errors that advocates gloss over and the public does not know about… Citizens might review data that are mislabeled, mischaracterized, outdated or incomplete. This happens all the time.”

Having some experience with citizen activists, watchdogs, regulators, and industry, I offer my two cents. Spotting problems is one thing. Classing them as violations is another. Enforcing them is still another. For methane leaks, the first two of these three tasks will be somewhat more doable after the Obama administration passed the first federal regs for air emissions related to fracking operations earlier this year. Unsurprisingly, these were watered down in the face of industry resistance, and it will be at least two more years before they go into effect. Even then, expect continued resistance from the industry, as expressed by this quote by an American Petroleum Institute official in a Huffington Post report:

We don't need (the EPA) to come and tell our members we will save you money," said Howard Feldman, the institute's director of regulatory and scientific affairs. "Their business is natural gas. They get it that they are trying to capture as much gas as they can.

There are many compelling case studies of citizens attempting to enforce environmental laws and spur government to action, some of which I document in my book, Under the Surface. I count John Hanger, the former Pennsylvania DEP chief under the Rendell Administration, as a gauge on issues related to the effectiveness of regulatory enforcement of Big Oil. Hanger generally supports shale gas because he sees it as a practical alternative to coal. Yet he has not backed down from fights to hold operators accountable for pollution. Hanger was a main figure in a battle against Cabot Oil & Gas over methane migration that, according to his staff, permanently ruined an aquifer in Susquehanna County. Hanger demanded the company pay for an $11.4 million pipeline to bring fresh water to residents. Cabot fought back, and he ended up with a settlement that gave homeowners systems to treat the pollution in their homes and funds for the long-term maintenance of the devises The settlement cost the company a third of what the pipeline would cost.

Hanger has identified methane migration from abandoned wells as the most pressing problem with shale gas development, yet he also lost the fight for companies to post bonds to cover expenses of plugging and capping wells. This is a task that generally falls to government – or to no one in particular -- when companies go broke, walk away from problems, or the issue of legacy becomes mired in the complexity of multiple parties arguing over undocumented circumstances of past and present accountability.

Regarding active wells, there is an argument that companies are self-motivated to fix methane leaks. It’s simply a matter of good business sense because it prevents product from escaping. If this is true, why hasn’t it happened yet? Answer: because the cost of fixing often outweighs the return on investment, especially if gas remains cheap and plentiful. While some businesses can be counted on to serve public interest even when it runs counter to their bottom line, others cannot. Civic duty is not their charter, nor should we expect it to be. The it’s-good-business-to-be-a good-neighbor principal is applied as a matter of discretion, and many times it’s a public relations calculation. Regulators at the EPA and the Pennsylvania DEP (among other agencies) know through bruising defeats (example here) that enforcing environmental law can be a frustrating and difficult task when the industry digs in its heals. Past experience tells us the industry – by in large -- is ready to resist accountability for methane emissions and methane migration in the same way it is resisting mandates to make the chemicals it uses a matter of public record. (More on that here)

Before we can count on volunteer policing efforts to become a meaningful supplement to enforcement, a fundamental imbalance has to be addressed. It starts with this: The industry is dependent on policy that exempts it from federal laws to identify and track production, handling, and disposal of environmental hazardous. The uncontrolled, undocumented release of gases – in both the ground and the air -- accounts for one of three critical areas of concern. Others involve discharges of waste into the ground and water. For most industries, these discharges are regulated through the federal Resource Conservation and Recovery Act, which provides a cradle-to-grave accounting of toxic substances. The policy became relevant in the late 1970s - the era of the iconic Love Canal disaster caused by unregulated chemical dumping. Discharges are also controlled through the Safe Drinking Water Act, which regulates what can be injected into the ground. Exemptions from these restrictions are critical to the viability of shale gas development because hazardous waste is an expensive thing to dispose of, and because our government, with few exceptions, doesn’t allow the injection of poisonous chemicals into the earth.

In addition to providing operational advantages, the industry’s exemption from hazardous waste laws take care of another potential showstopper for drilling companies – Public Relations. Waste that includes glycols, acids, hydrocarbons, volatile organics, radio nuclides and hundreds of other additives or naturally occurring compounds deemed hazardous when produced by another industry are considered non-hazardous in the eyes of the government when flowing from oil and gas wells. Selling natural gas as a clean alternative would be a much taller order if that pitch were burdened with the PR nightmare of a hazardous waste label – the very thing that doomed the advancement of the nuclear power industry in this country.

The overriding issue, though, is that conforming to these laws would severely limit legal options for waste disposal for an industry that creates a lot of it. To date, shale gas developers have produced more than 1.5 billion gallons of liquid waste from Pennsylvania well fields alone, according to a recent study by researchers at Cornell University and Penn State. And while the paper notes that the industry has increased “reuse and reliance on industrial and on-site treatment,” recycling of shale gas waste remains a process that is unregulated, self-reported, and self-defined. The study, Wastewater Management and Marcellus Shale Gas Development: Trends, Drivers, and Planning Implications, found the state’s records were incomplete and prone to error, with the endpoint of 13.4 percent of waste volumes listed as “undetermined.” (Note. That figure was for 2008. Brian Rahm, one of the authors, noted after this post that "The database has arguably done a better job tracking waste in more recent years although ... there are still a variety of errors, as well as evidence of under-reporting." See Rehm's full response below.)

Meanwhile, the industry will continue to do what it can to discourage or refute independently produced science that suggests the possibility that this unregulated waste can end up in places over the near or long term where it causes harm. I have spoken to various researchers at universities who – proposing studies with their own funds — have been denied access to drill sites to conduct “before” and “after” water tests on their terms, rather than concede to industry stipulations. The EPA ran into similar problems in national study to evaluate the impact of fracking on groundwater. (More on that here) Without the “before” picture, it’s difficult to hold industry accountable for water pollution.

There is good reason for the resistance. Science that could encourage a regulatory crack-down on the oil and gas industry would likely threaten its economic viability, especially if gas prices remain low. This could happen in New York state, where the policy battle for access to world-class gas reserves, featuring both the Marcellus and Utica shales under the Southern portion of the state, has raged for more than four years, under two administrations, without resolution. In the meantime, permitting for shale gas wells remains on hold. The National Resources Defense Council is among an influential contingent of environmental groups looking for stronger regulations if not an outright ban. Specifically, the NRDC is urging Governor Andrew Cuomo’s administration to adopt hazardous waste rules spelled out in RCRA for shale wells operating within the state’s borders. In support of this, the agency has issued a report that includes a list of toxic substances found in samples from drilling wastewater. They include varying concentrations of benzene, toluene, xylene, volatile organic compounds, heavy metals, and radionuclides. The list is itemized in Table 1 of the report, titled “In Fracking’s Wake: New Rules are Needed to Protect Our Health and Environment from Contaminated Wastewater. “ (The report is one of several position papers the NRDC has published that characterize the agency’s regulatory approach to the fracking, including full disclosure of fracking chemicals.)

I’ve heard this strategy called strangulation by regulation, and if successful in New York, it would be a victory for an anti-fracking movement that has flourished under the Empire State’s brand of celebrity-lead activism. But if shale gas development Is to be strangled, the act will require some urgent soul searching and rapid (some would argue unfeasible) practical adjustments by a public that has long enjoyed the benefits of cheap abundant energy without having to look too closely from where it comes.

Where energy comes from is the question of this century, and the on-shore drilling revolution taking place in America’s back yard is forcing us to take a good close look. Anybody eager to ban fracking in New York state, though, owes it to themselves to consider the global picture. John Cronin, Senior Fellow for Environmental Affairs at Pace Academy for Applied Environmental Studies, summed it up neatly in a recent email exchange. (Note, Cronin was responding to a query from Revkin about relying more on coal if Governor Cuomo is to eliminate shale gas and nuclear power production in New York. I find his point provides context for the fracking debate, and post it here with his blessing)

We are privileged to have the available time to debate a risk-free, domestic energy future. And whom do we owe for the breathing space to indulge our ruminations? The developing and war-torn nations to which we outsource the big risk, in return for boatloads of oil.

The energy tradeoff debate cannot be contained by the perimeter of the United States. Every megawatt provided us from out of country causes as much or more harm in those nations as domestic energy production causes at home. Our current energy policy has already made us complicit in and dependent upon significant environmental destruction outside our borders. The short-term campaign to dispatch with traditional energy sources in pursuit of a no-risk, long-term energy future for Americans is directly dependent upon a continuation of, even an increase in, some of the worst environmental problems on the planet, conveniently all in other nations. This is the crime of externalization we like to roll out when fighting domestic polluters -- only writ much larger.

Consider Nigeria, where Americans are a dominant oil customer, importing 40% or more of that nation's petroleum. Hundreds of billions of dollars of environmental damage to the Niger River Delta. Devastating human health consequences. Massive corruption. An unstable, almost bankrupt state government. A life expectancy of 51. Daily wages of $5 - $8. Loss of indigenous industries. Civil unrest. Environmental and political terrorism. Incursions by Al Qaeda. In brief, current American energy policy includes the environmental, political, economic and social destruction of Nigeria.

Call it the Law of Conservation of Risk. For the foreseeable future, we cannot destroy the risk inherent in energy consumption and production. If we eliminate it at home. it simply shows up elsewhere, in most cases in nations where laws are weaker, and citizens subservient to their governments.

Developing a globally sufficient and sustainable energy supply is one of the primary problems of our age, and it extends beyond ecological issues to human rights and environmental justice. And before we can address these problems, we first must be able to see them clearly and then be willing to take a hard look. That starts with buy-in on a grass roots level, whether it is thinking about whether you really need two cars, or that extra stuff you buy this Holiday season, or whether it involves getting out in the field with an infra-red camera to help advance the understanding methane leaks.

During visits to universities to talk about what I’ve learned as a reporter covering shale gas development in New York and Pennsylvania, I’ve been inspired by students and faculty taking D.I.Y. approaches to problems. One example: The Finger Lakes Institute at Hobart William and Smith coordinates outreach programs to enlist high school students to collect water samples in the Seneca Lake watershed – a prospective shale development zone that includes a project to warehouse gas and propane in reclaimed salt mines. Because of the changing dynamics of watersheds and the geographical expanse they tend to cover, tracking water conditions over hill and dale is an ambitious and painstaking job. Yet this is not a function that is likely to be covered by industry or government anytime soon. And without an accurate “before picture” of all the likely points of impact, it will be difficult to document environmental changes related to shale gas development and establish the groundwork for accountability.

Whether from a “neighborhood watch” approach outlined by Revkin, field work by students, or through watchdog journalism, bringing public pressure to bear on flagging problems where government falls short is never a bad idea. But neither is this: Embracing the vision of reformists who champion energy conservation while pushing with all their might against the technical and social inertia keeping this generation from advancing beyond the fossil fuel age. That’s a tall order, especially when accounting for developing countries aspiring to the standard of living and freedoms that U.S. citizens have enjoy for generations, but like D.I.Y. patrols, it’s a start, and it can start in our own back yards.


  1. As I said in a comment on one of Andrew Revkin's Dot Earth posts, it is neither realistic nor fair to expect unpaid, private citizens--who may or may not possess adequate training or equipment--to police a large and powerful industry. In reply to my comment, Mr. Revkin said that he views citizen participation not as a substitute for government regulation, but rather as a supplement to it. Fair enough, but how much of a "supplement" does he have in mind? Should private, volunteer labor be picking up 10% of the slack, 20%, 30%? Should we also start asking volunteers to inspect our meat and medications and automobiles?

    I have the GREATEST respect for the concerned citizens who travel around the gas fields, cameras in hand, searching for methane leaks and other dangers and violations. But I do not see their role as a "supplement" to the PA DEP or any other regulatory agency. Rather, I think these folks are watchdogs who are pointing out, with their courage and hard work, that the regulatory agencies are failing the citizens they are supposed to protect.

    Personally, I think that any policing that is needed should be paid for via fees and taxes on the gas industry and then reflected in the price of the shale gas--in other words, I want the externalities to be paid for by everyone who is using the gas, not just by those who have the misfortune to live on a gas field. Mr. Revkin, on the other hand, seems to want a lot of free labor and expensive equipment to be provided by the poor souls who have to live with the dangers of the shale gas industry every day: this hardly seems fair to me.

    It is also important to note that NE PA alone is VERY LARGE. It's a lot of territory to cover and some of these gas wells and compressor stations are on dirt roads, up in the hills. Further, methane leaks are just one problem in a long list of shale-gas-related problems, some of which are far beyond the detective powers of the average citizen.

    Frankly, I found Mr. Revkin's notion that the gas industry would want private citizens to search for methane leaks to be touchingly naive. There have been multiple videos of methane leaks posted on the internet for quite some time now, yet the leaks continue. If/when the day comes that it is in the gas industry's financial interest to find and fix the leaks, then the industry will do so. Until then I doubt the industry will welcome the help of citizens bearing FLIR cameras. Indeed, some of the citizens who have attempted to point out problems in the gas field have been vilified by the industry and its apologists.

  2. On a different note, I want to thank Tom Wilber for writing about the need to develop a globally sustainable energy supply that is obtained in ways that are environmentally just and respectful of human rights. I can honestly say that this is a high priority for most of the people I've encountered in the anti-fracking movement over the last four years. In fact, it's exactly what many of these folks were working on before the fracking issue surfaced. Many of them continue to work tirelessly on both issues at once.

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  4. Yes, thanks Tom. Great thoughts Mary....

    As I have expressed several times recently, it is my personal opinion that we should be working on renewable and sustainable energy policy as our #1 goal.

    This whole fracking nonsense which has distracted so many of us from the rest of our lives does, however, seem like an immediate threat to our well being which does need to be addressed now.

    Believe me, I love this movement, and all of the people volunteering, devoting their best efforts to it. I have never seen an environmental movement this large in my life before, nor imagined one could exist.

    YET-- if we Fractivists never get around to working on the root causes of Fracking -- outwardly: sustainable energy policy, and inwardly: greed, and our materialistic, dualistic, egoistic, disconnected worldview-- then I fear the worst possible outcomes...

  5. Thank you, Tom, for making it evident that there is no such thing as "safe fracking." The industry's refusal to allow accurate data collection and independent scientific analysis and their use of exemptions to re-classify hazardous waste as non-hazardous points out that this is inherently a polluting, harmful activity. As a society, we should not be exposing those in fossil fuel extraction zones to these dangers, domestically or in other countries.

    Most of the people working against unconventional fossil fuel production are also involved in efforts to conserve energy and move to non-fossil fuel energy as quickly as possible. James Hansen of NASA and Mark Jacobson of Stanford are two of the most prominent voices in the US; researchers in The Netherlands published this paper: this fall.

    At a minimum, we need to stop subsidizing the fossil fuel industry and hold them accountable for the same environmental and waste treatment protections to which other industries are held, with punitive penalties for cheating so that they won't continue to do it. There are various methods to help cushion the populace from the price shocks that would result, but we will all be in much worse shape if we don't do anything and allow the greenhouse gas emissions to continue to rise precipitously past the tipping point. We are already dealing with record droughts, flooding, and frequent severe storms world-wide, along with the shameful negative effects of fossil fuel exploitation that this post includes.

    We need political leaders to look at the science, look at the damage being done to people and the environment, and say "No more." Americans have taken on difficult tasks before. We have the technology to transform our energy profile to a sustainable one. What we need now are leaders with the political skill to marshall the political will to get it underway.

    Governor Cuomo and President Obama have the potential to become great international leaders on this issue. Will they step up and do it?

  6. The watch dog or watch wolf movement resulted, in my opinion, from the lack of a serious or credible regulatory agency and indifferent or worse "conflicted" officials. In the beginning, folks were just trying to protect their homes. Many have benefited from the grueling and tireless efforts of those early "watchers" who as you know did a lot more than just watch. I agree with Mary, we should not have to make up the slack yet, if we aren't or weren't there what would happen? Anyway, at this point, here in PA, I think everyone should be HOWLING for that hi tech green technology that the gas companies are bragging about. If they have it then PLEASE use it. We all know by now there is no reprieve for Penn's Woods.

    1. I agree with everything yoko said in her comment.

      The watchdogs (or watch wolves) have played and are playing a tremendously important role: When the regulatory agencies aren't doing their jobs, then watchdogs may be our last and best hope.

      But it seemed to me that what Mr. Revkin was suggesting was that we need a group of people who are not watchdogs, but rather citizen volunteers who can supplement the efforts of understaffed regulatory agencies and of the gas industry itself. It was as if he thought the main problem was that the industry has trouble finding methane leaks and needs some help, when in fact, the industry appears to have little interest in doing anything about the leaks, probably because it has decided that fixing the leaks will cost more than ignoring them (and possibly also because the leaks are bad PR and the industry wishes we would all just ignore them). It's also worth noting that some of these leaks are coming not from equipment, but from the ground itself, and are noticeable in cases in which the gas must move through water (e.g. in streams), thereby creating bubbling. (Watchdogs have posted footage of this type of leak online too.)

      Mr. Revkin also seemed to be under the impression that the public, the gas industry, and the regulatory agencies can all work together as one big, happy family to make the world a better place. The reality is that the public is deeply divided about the shale gas issue, the regulatory agencies are understaffed, underfunded, and subject to regulatory capture, and the gas industry exists not to make the world a better place or even to maximize the amount of gas that it delivers to the consumer, but rather to make a profit. (If wasting some of the methane they get out of the ground creates more profit than carefully capturing all of it, then the industry will waste the methane.)

      The situation is nightmarish, and my thanks go out to each and every watchdog--I think they are performing an invaluable function that requires far more grit and determination than it would if they were simply acting to supplement the regulatory agencies.

      The bottom line is that if our regulatory agencies need supplementation, that means that by definition they are not doing an adequate job, and that, in my opinion, is not acceptable.

    2. Thanks Yoko. No doubt you have heard this before, but NY has benefited from Pennsylvania’s misfortune, and the activism that began there is encouraging reform elsewhere. So we are left with some big questions: How substantial is the reform and how fast will it arrive? Is the Susquehanna County Watch Wolf an exceptional breed? Can everybody be expected to fight the consuming fight? If not, who can, and what motivates them to action? It’s pretty much a process of natural selection, and an altogether different animal than the bureaucratic process that produces government oversight; although the Dimock story is emblematic of how one influences the other through a venerable history of activism in this country. Michael Berndtson makes this point in his comment to this post, and I agree, although I would hesitate to place the blame at the feet of any particular party. There is an ideological divide, no doubt, between the far right and Ayn Rand faithful who feel government regulation is generally a harmful influence, and Great Society liberals and current day progressives who feel government is needed to serve the public good in ways that corporations and free markets simply cannot. (You can read my Pulitzer reference on the sidebar of my blog to see my worldviews, for what they are worth.)

      It’s hard to talk about the fracking story without talking about ideology, and it’s also necessary to push it aside or at least try to look around it in the interest of moving the discussion forward – a very tall task. Regardless, I agree with Michael and with Mary that your work, and the work of others in Dimock, is invaluable, and that’s why I took pains to document it thoroughly. I would also like to think the Susquehanna County story is extraordinary, because it’s a story that I’m personally tied to through Under the Surface. But the reason I think it resonates is because it’s everybody’s story, and people recognize many personal elements in it.

      Thanks again for your dedication and for checking in here.

  7. Excellent post. I can sum up the regulation of Oil and Gas Industry in two words: "special waste." And it is not waste with special needs - just the beauty of regulatory affairs, lobbyists and euphemisms.

    I'm a bit ambivalent on the citizen watchdog idea. On the one hand it's a great idea to get people interested and active in environmental concerns. On the other hand, no one should volunteer for this effort - unless they need a hobby. Environmental protection and remediation at all skill levels and professions should be paid for their goods and services. Its a cost of doing business, period. Just like operations labor, raw materials, utilities, transportation, maintenance and repairs - it needs to get done.

    Soap box time... The environmental business does not need App developers looking to make a buck off of volunteers doing the actual work. The environmental business needs policy consultants and lawyers working the halls and lobbies of Washington and State capitals to improve environmental protection and increase funding of these agencies - so they can monitor and set protection goals. Secondly, the environmental business needs more scientist, engineers doing science and engineering. Thirdly, the environmental business needs investigative journalist going after the craziness. Lastly,the environmental business DOES NOT need anymore fake green non-profit institutes with fake environmental consultants - promoting BS "client focused" and "free-market driven solutions" that do absolutely nothing for protection or remediation of the environment.... Off soap box.

    Having worked for years in the environmental biz - one thing about monitoring, sampling and analysis is that it is heavily tied to legal, i.e. can the data or information hold up in court. Environmental protection seems to be 95 percent consulting and legal and 5 percent prevention, treating and cleaning stuff up. That's an over exaggeration, but not necessarily entirely untrue. So I guess my gut feeling is that citizen watchdogs are a good idea, but the information will always get contested. And if there are no regulatory drivers, as Tom pointed out, nothing will get done.

    1. the watch wolf is not always ignored, or contested, right Tom?

    2. Yoko, sadly the concept of citizen watch dogs is after-the-fact and assumes shale gas development has primacy over air, land, water and residents. Environmental protection got its start through citizen watch dogs over 40 years ago, resulting in formation of the USEPA and State level agencies. Since then however,environmental protection has been systematically eroded in strength - by industry and Republicans (and blue dog Democrats). Culminating in what happened to Pennsylvania with the marriage of state politicians and industry in creating shale gas exploitation without any serious environmental regulation. The main problem is that once usable groundwater becomes contaminated - and depending on the extent of impact - it takes years and millions of dollars to cleanup. I can understand problems like this happening 40 or maybe 20 years ago. But in 2012, to have GW use restrictions put in place due to recent impact is inexcusable.

      Never the less, it took 21st century PA watch dogs to get the rest of us fired up with what is happening in PA and other States. So I agree with you, Yoko and commend you on your work.

    3. Yoko -- Some are harder to ignore than others.

    4. Michael --
      "Environmental protection and remediation at all skill levels and professions should be paid for their goods and services. It’s a cost of doing business, period. Just like operations labor, raw materials, utilities, transportation, maintenance and repairs - it needs to get done..."

      Interesting way to look at it. Citizens have a civic obligation to facilitate freedom and self-governance. That's clear on school boards and town meetings. How much should they be obligated to police private enterprise? On a practical level, I see it has healthy and necessary, like a neighborhood watch. But also like a neighborhood watch it has ethical and practical limits.

    5. Tom, nicely put. Based on appointments by the Republican congress to various science committees made public this week, maybe citizen watch dogs will be the only thing left standing between fossil fuel development and human health.

  8. Hi Tom,

    Thank you for your blog, and for highlighting some of the complexities of the issue. Regarding your reference to our work, "Wastewater Management and Marcellus Shale Gas Development: Trends, Drivers, and Planning Implications," I just wanted to offer a small clarification: the 13.4% of wastewater whose management was identified as "not-determined" was for 2008 only. These entries were also added retrospectively to a database only created in 2010. The database has arguably done a better job tracking waste in more recent years although, as you note, there are still a variety of errors, as well as evidence of under-reporting. So, it is still an imperfect tool.

    I bring this up only because these facts and figures get thrown around by both "sides" sometimes without much attention to important contextual details. This issue is already complicated, even if we could all agree on the facts. It is not possible to control how people interpret everything, but I feel it is important to try and be precise with how information is presented.

    Thanks again, and good luck with your work.

  9. Brian, Thanks for sharing your work. I have added a note in my post to reference the point you make here.