The American environmental movement, and environmental politics in general, are in middle age.
So is a major environmental crisis that never seems to move toward resolution: Locating the nation's worst waste sites and polluting factories in or near poor and minority communities. Nearly 40 years after its debut as a national issue, will environmental justice finally get its due?
Environmental racism didn't begin in 1982 any more than racism itself began in 1982. But in the fall of that year, the state of North Carolina began the transfer of hundreds of truckloads of soil contaminated with carcinogenic PCB's to a new landfill in predominantly poor, Black Warren County.
Civil rights icons like Rev. Joseph Lowery, Warren County's own Floyd McKissick and Walter Fauntroy, Washington D.C.'s Congressional Delegate, helped lead mass protests in which 500 people were arrested for blocking the waste trucks. The PCB trucks eventually got through, but the protestors won a compromise ending further shipments to the site. And environmental justice drew national attention for the first time.
Delegate Fauntroy commissioned a General Accounting Office (GAO) report on racial and economic biases in siting hazardous waste facilities. Published in 1983, the GAO report determined that three-quarters of the hazardous waste dumps in eight Southeastern states are located in or near poor African-American or Latino communities.
In 1987, the United Church of Christ's Commission for Racial Justice (CRJ) issued a report, Toxic Wastes and Race in the United States, that affirmed such practices were both systemic and nationwide. In 1990, sociologist Robert Bullard published a book, Dumping in Dixie: Race, Class, and Environmental Quality, which told the stories of impacted communities throughout the South. And the Rev. Jesse Jackson pointed out what by now was obvious: While dangerous sites are commonplace in poor and minority communities, "there are no nuclear waste dumps in Beverly Hills."
Also in 1990, the CRJ sent a stinging letter to the heads of 10 of the nation's largest environmental groups, citing the overwhelmingly White makeup of the groups' boardrooms and executive suites. Environmental racism, the critics said, begins at home. And the Environmental Protection Agency under Republican appointee William Reilly, created what would become the Agency's environmental justice office.
The late Rep. John Lewis introduced the first environmental justice bill in Congress in 1992, with active support from Vice President Al Gore. It failed.
In 1994, President Clinton signed Executive Order 12898, mandating that all federal agencies and federally funded projects must consider the impacts of those projects on poor and minority communities.
Which is why it's stunning that 39 years after Warren County:
Louisiana's "Cancer Alley" --an 85-mile stretch of the Mississippi under the footprint of over 150 petrochemical plants—faces an onslaught of newer, bigger oil and gas facilities;
Uniontown, Alabama, is battling efforts to make it the final resting place for toxic coal ash from hundreds of miles away;
Aging inner-city drinking water systems in places like Flint, Michigan, and Newark, New Jersey, have imperiled residents;
Indigenous tribes consistently contend with pipeline construction and uranium mining.
And there are many more examples.
The Biden Administration has set the bar higher than any of its predecessors. His nominee for EPA Administrator, Michael Regan, would be the agency's second Black leader. He brings his experience as North Carolina's environmental chief. Since Warren County, environmental justice issues have been hard to ignore in the state: Just try driving down Interstate 95 on a summer day with the windows open and take in the aromas of massive industrial hog farming.
At the Department of the Interior—what a concept—Biden has nominated Deb Haaland as the first Indigenous leaders to serve as Interior Secretary. Both Regan and Haaland, if installed, inherit demoralized and reduced staffs and slashed budgets left behind by Trump appointees. But both have promised to extend environmental justice efforts to embrace climate change impacts on poor and minority communities.
Congresswoman Deb Haaland.
The Biden Administration is attaching some specifics to the rhetoric. One ambitious project would nationalize an ambitious California effort to inventory threats to disadvantaged communities—CalEnviroScreen, a screening tool that factors income, race, and pollution to identify the state's most at-risk cities and towns.
Environmental justice has never been a political top priority. In a year when COVID-19 and the economy have jumped the line and hogged the headlines, can Biden push beyond good intentions?
Houston’s fenceline communities welcome stricter federal rules on chemical plant emissions but worry about state compliance.
HOUSTON – Terri Blackwood, a Baytown resident living along the Houston Ship Channel, knows the smells of pollution well.
Blackwood’s backyard is along the water shore where several oil and gas facilities and chemical plants cluster. She keeps a journal of more than 100 instances in which she smelled something “off,” felt ill, saw flares or noticed her house shaking. Depending on the severity and duration, she has filed reports to the Texas Commission on Environmental Quality (TCEQ) or called Exxon, the largest petrochemical complex in the area.
“I’m not anti-industry,” Blackwood told EHN. “I know they’re not moving. I’m not either. I’m just for the safety of the neighborhood.”
Soon Blackwood and her neighbors may get some relief: three facilities in ExxonMobil’s Baytown complex near her home are subject to the U.S. Environmental Protection Agency’s updated regulations released last week that aim to reduce cancer risk and air pollution at 200 chemical facilities. The agency is targeting six cancer-causing compounds including ethylene, chloroprene, benzene, 1,3- butadiene, vinyl chloride and ethylene dichloride. Nearly 40% of these facilities are in Texas and 14% are in Harris County — where Houston is located — alone.
“I’m not anti-industry. I know they’re not moving. I’m not either." - Terri Blackwood, a Baytown resident
These new regulations could mean relief for communities located along the fenceline, especially communities of color that are often disproportionately located near these facilities and often lacking adequate monitoring. While Harris County has nearly 20% of all of TCEQs air monitors, they are often spread out and far from facilities’ fencelines. Last year, the EPA granted the city of Houston $500,000 to increase air monitoring of benzene, 1-3 butadiene and ethylene via the Inflation Reduction Act. The new rule requires fenceline monitoring of the six targeted chemicals.
The rule will also more tightly regulate flaring and remove existing air pollution emissions exemptions from startups, shutdowns and malfunctions at plants. The EPA estimates the new rules will reduce the number of people with elevated cancer risk due to air pollution by 96%.
ExxonMobil did not respond to Environmental Health News’ request to comment about the new rules.
“It’s good that they’re making progress,” Juan Flores, Galena Park resident and community air monitoring director for the Houston-based nonprofit Air Alliance, told EHN. “I would like to see more progress to limit this even further, especially as a person who is dealing with health effects because of this stuff.”
Blackwood said keeping track of this new data will be “another thing” she will have to keep an eye on. In the last few months, Air Alliance monitored her house with different types of air monitors and she hopes the federal fenceline data will reflect what she “already knows.” The TCEQ only considers air quality data from a previously established network of federal and commercial air monitors.
While the federal changes are welcome, community concerns persist. The state of Texas and the TCEQ have historically challenged the EPA’s authority. In March, Texas’ Attorney General Ken Paxton challenged the EPA’s new national air quality standards in a lawsuit. Blackwood and Flores fear that Texas will prevent the new rule’s efficacy.
“I didn't realize I needed to pay more attention,” said Blackwood. “I definitely, naively, presumed EPA was a final authority for ensuring public safety."
Victoria Cann, media relations specialist for the TCEQ, told EHN the agency “will conduct investigations to evaluate compliance with applicable requirements as part of the compliance and enforcement program.”
Cann also said that the new requirements will be considered in the permitting process for facilities that are subject to the new standards.
Texas Environmental Justice Advocacy Services, or TEJAS, has advocated for decades for stronger chemical regulations like this one.
“We remember family, friends, and neighbors who we lost as a result of health-related issues because of highly hazardous air pollutants, including carcinogens like ethylene oxide and 1,3-butadiene,” TEJAS representative Deyadira Arellano told EHN. “We owe it to our loved ones to act on environmental justice and call for enhanced inspections and enforcement at facilities that repeatedly violate emissions rules.”
Depending on the type of chemical, facilities have between 90 days and two years to reach full EPA compliance. The full rule can be found here.
CAMERON PARISH, La. — Late into the night, John Allaire watches the facility next to his home shoot 300-foot flares from stacks.
He lives within eyesight of southwest Louisiana’s salty shores, where, for decades, he’s witnessed nearly 200 feet of land between it and his property line disappear into the sea. Two-thirds of the land was rebuilt to aid the oil and gas industry’s LNG expansion. LNG — shorthand for liquified natural gas – is natural gas that's cooled to liquid form for easier storage or transport; it equates to 1/600th the volume of natural gas in a gaseous state. It’s used to generate electricity, or fuel stove tops and home heaters, and in industrial processes like manufacturing fertilizer.
In the U.S., at least 30 new LNG terminal facilities have been constructed or proposed since 2016, according to the
Oil and Gas Watch project. Louisiana and Texas’ Gulf Coast, where five facilities are already operating, will host roughly two-thirds of the new LNG terminals – meaning at least 22 Gulf Coast LNG facilities are currently under construction, were recently approved to break ground or are under further regulatory review.
Although the U.S. didn’t ship LNG until 2016, when a freight tanker left, a few miles from where Cameron Parish’s LNG plants are today, last year the country became the global leader in LNG production and export volume, leapfrogging exporters like Qatar and Australia. The
EIA’s most recent annual outlook estimated that between the current year and 2050, U.S. LNG exports will increase by 152%.
Allaire, 68, watches how saltwater collects where rainwater once fed the area’s diminishing coastal wetlands. “We still come down here with the kids and set out the fishing rods. It's not as nice as it used to be,” he told
Environmental Health News (EHN).
That intimacy with nature drew Allaire to the area when he purchased 311 acres in 1998. An environmental engineer and 30-year oil and gas industry veteran, he helped lead environmental assessments and manage clean-ups, and although retired, he still works part-time as an environmental consultant with major petroleum companies. With a lifetime of oil and gas industry expertise, he’s watched the industry's footprint spread across Louisiana and the Gulf of Mexico’s fragile shores and beyond. Now that the footprints are at the edge of his backyard, Allaire is among a cohort of organizers, residents and fisher-folk in the region mobilizing to stop LNG facility construction. For him, the industry’s expansion usurps the right-or-wrong ethics he carried across his consulting career. For anglers, oil and gas infrastructure has destroyed fishing grounds and prevented smaller vessels from accessing the seafood-rich waters of the Calcasieu River.
From the view of Allaire’s white pickup truck as he drives across his property to the ocean’s shore, he points to where a new LNG facility will replace marshlands. Commonwealth LNG intends to clear the land of trees and then backfill the remaining low-lying field.
“You see what’s happening with the environment,” Allaire said. “When the facts change, I got to change my mind about what we’re doing.”
Community bands together
John Allaire, left, purchased 311 acres in Cameron Parish in 1998, and has watched the oil and gas industry's footprint spread to his property.
Credit: John Allaire
During an Earth Day rally in April, community members gathered in the urban center of Lake Charles to demand local oil and gas industries help deliver a safer, healthier future for all. In between live acts by artists performing south Louisiana’s quintessential zydeco musical style, speakers like James Hiatt, a Calcasieu Parish native with ties to Cameron Parish and a Healthy Gulf organizer, and RISE St. James organizer Sharon Lavigne, who’s fighting against LNG development in rural Plaquemines Parish near the city of New Orleans, asked the nearly 100 in attendance to imagine a day in which the skyline isn’t dotted by oil and gas infrastructure.
Not long ago, it was hard to imagine an Earth Day rally in southwest Louisiana at all. For decades, the area has been decorated with fossil fuel infrastructure. Sunsets on some days are highlighted by the chemicals in the air; at night, thousands of facilities’ lights dot the dark sky.
“It takes a lot of balls for people to start speaking up,” Shreyas Vasudevan, a campaign researcher with the Louisiana Bucket Brigade, told EHN in the days after the rally. In a region with its history and economy intertwined with oil and gas production, “you can get a lot of social criticism – or ostracization, as well – even threats to your life.”
Many are involved in local, regional and national advocacy groups, including the Louisiana Bucket Brigade, Healthy Gulf, the Sierra Club, the Natural Resources Defense Council, the Turtle Island Restoration Network, the Center for Biological Diversity and the National Audubon Society.
“You see what’s happening with the environment,” Allaire said. “When the facts change, I got to change my mind about what we’re doing.” - John Allaire, environmental engineer and 30-year oil and gas industry veteran
But environmental organizers are fighting a multi-billion-dollar industry with federal and state winds at its back. And LNG’s federal support is coupled with existing state initiatives.
Under outgoing Louisiana Gov. John Bel Edwards — a term-limited Democrat — the state pledged a goal of reaching net-zero greenhouse emissions by 2050. Natural gas, which the LNG industry markets as a cleaner-burning alternative, is cited as one of the state’s solutions. Louisiana is the only state that produces a majority of its carbon emissions through fossil fuels refining industries, like LNG, rather than energy production or transportation. Governor Edwards’ office did not return EHN’s request for comment.
This accommodating attitude towards oil and gas industries has resulted in a workforce that’s trained to work in LNG refining facilities across much of the rural Gulf region, said Steven Miles, a lawyer at Baker Botts LLP and a fellow at the Baker Institute’s Center on Energy Studies. Simultaneously, anti-industrialization pushback is lacking. It’s good news for industries like LNG.
“The bad news,” Miles added. “[LNG facilities] are all being jammed in the same areas.”
One rallying cry for opponents is local health. The Environmental Integrity Project found that LNG export terminals emit chemicals like carbon monoxide –potentially deadly– and sulfur dioxide, of which the American Lung Association says long-term exposure can lead to heart disease, cancer, and damage to internal or female reproductive organs.
An analysis of emissions monitoring reports by the advocacy group the Louisiana Bucket Brigade found that Venture Global’s existing Calcasieu Pass facility had more than 2,000 permit violations.That includes exceeding the permit’s authorized air emissions limit to release nitrogen oxides, carbon monoxide, particulate matter and volatile organic compounds 286 out of its first 343 days of operation.
The Marvel Crane, the first liquid natural gas carrier to transport natural gas from the Southwest Louisiana LNG facility, transits a channel in Hackberry, Louisiana, May 28, 2019.
“This is just one facility,” at a time when three more facilities have been proposed in the region and state, Vasudevan said. Venture Global’s operational LNG facility — also known as Calcasieu Pass — “is much smaller than the other facility they’ve proposed.”
In an area that experienced 18 feet of storm surge during Hurricane Laura in 2020 — and just weeks later, struck by Hurricane Delta — Venture Global is planning to build a second export terminal Known as “CP2,” it’s the largest of the roughly two dozen proposed Gulf LNG export terminals, and a key focal point for the region’s local organizing effort.
Residents “don’t really want LNG as much as they want Cameron [Parish] from 1990 back,” Hiatt told EHN of locals’ nostalgia for a community before storms like Rita in 2005 brought up to 15 feet of storm surge, only for Laura to repeat the damage in 2020. Throughout that time, the parish’s population dipped from roughly 10,000 to 5,000. “But the wolf knocking at the door is LNG. Folks in Cameron think that's going to bring back community, bring back the schools, bring back this time before we had all these storms — when Cameron was pretty prosperous.”
“Clearly,” for the oil and gas industry, “the idea is to transform what was once the center of commercial fishing in Louisiana to gas exports,” Cindy Robertson, an environmental activist in southwest Louisiana, told EHN.
Helping fishers’ impacted by LNG is about “actual survival of this unique culture,” Cooke said.
In a measure of organizers’ success, she pointed to a recent permit hearing for Venture Global’s CP2 proposal. Regionally, it’s the only project that’s received an environmental permit, but not its export permit, which remains under federal review. At the meeting, some spoke on the company’s behalf. As an organizer, it was a moment of clarity, Cooke explained. Venture Global officials “had obviously done a lot of coaching and organizing and getting people together in Cameron to speak out on their behalf,” Cooke said. “So, in a way, that was bad. But in another way, it shows that we really had an impact.”
“It also shows that we have a lot to do,” Cooke added.
Environmental organizers like Alyssa Portaro describe a sense of fortitude among activists — she and her husband to the region’s nearby town of Vinton near the Texas-Louisiana border. Since the families’ relocation to their farm, Portaro has worked with Cameron Parish fisher-folk.
“I’ve not witnessed ‘community’ anywhere like there is in Louisiana,” Portaro told EHN. But a New Jersey native, she understands the toll environmental pollution has on low-income communities. “This environment, it’s so at risk — and it’s currently getting sacrificed to big industries.”
“People don’t know what we’d do without oil and gas. It comes at a big price,” she added.
Southwest Louisiana’s Cameron Parish is one of the state’s most rural localities. Marine economies were the area’s economic drivers until natural disasters and LNG facilities began pushing locals out, commercial fishers claim.
Credit: Xander Peters for Environmental Health News
Residents “don’t really want LNG as much as they want Cameron [Parish] from 1990 back,” James Hiatt , a Healthy Gulf organizer, told EHN. "But the wolf knocking at the door is LNG."
Credit: Xander Peters for Environmental Health News
For the most part, Cameron Parish’s life and economy has historically taken place at sea. As new LNG facilities are operational or in planning locally, locals claim the community they once knew is nearly unrecognizable.
Credit: Xander Peters for Environmental Health News
A disappearing parish
The stakes are seemingly higher for a region like southwest Louisiana, which is the epicenter of climate change impacts.
In nearly a century, the state has lost roughly 2,000 square miles of land to coastal erosion. In part driving the state’s erosion crisis is the compounding impacts of Mississippi River infrastructure and oil and gas industry activity, such as dredging canals for shipping purposes, according to a March study published in the journal Nature Sustainability. Louisiana’s Coastal Protection and Restoration Authority said Cameron Parish could lose more land than other coastal parishes over the next 50 years. A recent Climate Central report says the parish will be underwater within that time frame.
On top of erosion and sea level rise impacts, in August, 2023, marshland across southwest Louisiana’s Cameron Parish burned. The fires were among at least 600 across the Bayou State this year. Statewide, roughly 60,000 acres burned — a more than six-fold increase of the state’s average acres burned per year in the past decade alone.
But while the blaze avoided coastal Louisiana communities like Cameron Parish, the fires represented a warning coming from a growing chorus of locals across the region — one that’s echoes by the local commercial fishing population, who claimed to have experienced unusually low yields during the same time, according to a statement from a local environmental group. At the site of the Cameron Parish fires are locations for two proposed LNG expansion projects.
"The idea is to transform what was once the center of commercial fishing in Louisiana to gas exports.” - Cindy Robertson, an environmental activist in southwest Louisiana
It was an unusual occurrence for an area that’s more often itself underwater this time of year due to a storm surge from powerful storms. For LNG expansion’s local opposition, it was a red flag.
As the Louisiana Bucket Brigade has noted prior, the confluence of climate change’s raising of sea levels and the construction of LNG export terminals — some are proposed at the size of nearly 700 football fields — are wiping away the marshland folks like Allaire watched wither. Among their fears is that the future facilities won’t be able to withstand the power of another storm like Laura and its storm surge, which wiped away entire communities in 2020.
Amidst these regional climate impacts, LNG infrastructure has shown potential to exacerbate the accumulation of greenhouse gasses that cause global warming. For the most part, LNG is made up of methane — a greenhouse gas that’s more than 80 times more potent than carbon dioxide in the atmosphere. Among the 22 current LNG facility proposals, the advocacy group Sierra Club described a combined climate pollution output that would roughly equal to that of about 440 coal plants.
The climate impacts prompt some of the LNG industry’s uncertainty going forward. It isn’t clear if Asian countries, key importers of U.S. LNG, will “embrace these energy transition issues,” said David Dismuke, an energy consultant and the former executive director of Louisiana State University’s Center for Energy Studies. Likewise, European nations remain skeptical of embracing LNG as a future staple fuel source.
“They really don't want to have to pull the trigger,” Dismukes added, referring to Europe’s hesitation to commit more resources to exporting LNG from the American market. “They don't want to go down that road.”
While there will be a tapering down of natural gas supply, Miles explained, “we’re going to need natural gas for a long time,” as larger battery storage for renewables is still unavailable.
“I'm not one of these futurists that can tell you where we're going to be, but I just don't see everything being extreme,” Dismukes said. “I don't see what we've already built getting stranded and going away, either.”
For now, LNG seems here to stay. From 2012 to 2022,U.S. natural gas demand — the sum of both domestic consumption and gross exports — rose by a whopping 43%, reported the U.S. Energy Information Administration, or EIA. Meanwhile, in oil and gas hotbeds like Louisiana and Texas, natural gas demand grew by 116%.
Throughout 25 years, Allaire has witnessed southwest Louisiana’s land slowly fade, in part driven by the same industrial spread regionally. Near where the front door of his travel trailer sits underneath the aluminum awning, he points to a chenier ridge located near the end of the property. It’s disappearing, he said.
“See the sand washing over, in here?” Allaire says, as he points towards the stretches of his property. “This pond used to go down for a half mile. This is all that's left of it on this side.”
The U.S. has introduced stricter limits on silica dust in mines, affecting more than 250,000 workers in various sectors including coal and metal mining.
Despite support for the rule, there is controversy over its enforcement, with industry groups calling it costly and advocates worrying about self-monitoring by companies.
The rule revisits recommendations made back in 1974, finally implementing changes after decades of regulatory delays and rising health concerns.
Key quote:
"It should shock the conscience to know that there’s people in this country that do incredibly hard work that we all benefit from that are already disabled before they reach the age of 40."
— Chris Williamson, head of the Mine Safety and Health Administration.
Why this matters:
This regulation is important for improving health outcomes among miners, a workforce exposed to significant risks. As national attention focuses on workplace safety and health, this policy step exemplifies ongoing efforts to better protect those in high-risk industries. Read more: Coal miners are dying of black lung.
A new campaign, "Stop Polluting Politics," launched on Westminster Bridge, demands MPs to reject fossil fuel influence and donations.
The campaign criticizes the UK's Conservative Party for weakening climate commitments and continuing to accept substantial donations from polluters.
Ajaya Haikerwal, a spokesperson for Climate Resistance, emphasizes the conflict of interest in politicians accepting money from oil and gas lobbyists, impacting policy decisions.
Key quote:
"It’s frankly outrageous that in 2024, oil and gas lobbyists can quite freely cosy up to politicians, hand them fat stacks of cash, and see a favourable change in policy."
— Ajaya Haikerwal, spokesperson for Climate Resistance
Why this matters:
Activists view politicians' associations with fossil fuel companies as contradictory to addressing climate change effectively. Such relationships can lead to policies and decisions that prioritize the interests of these corporations over those of the public and the environment. Activists argue that politicians should represent the needs and concerns of their constituents rather than catering to the profit motives of fossil fuel companies.
As world delegates prepare for a crucial U.N. meeting in Canada, Arctic Indigenous communities emphasize the urgent need to address plastic pollution impacting their health and environment.
Delegates from nearly 180 countries will meet in Ottawa on April 23 to progress a treaty aimed at curbing plastic pollution, considering the lifecycle of plastics from production to disposal.
Arctic Indigenous representatives will present new scientific findings on the presence of harmful plastics in traditional foods like walruses and seals, highlighting the risks to their communities.
The negotiations, which have previously stalled, are seen as a critical opportunity to establish a comprehensive global agreement by year's end.
Key quote:
"To learn that these microplastics are ending up in our main foods, but also in our bodies, is yet another alarm for the decision makers."
— Vi Waghiyi, environmental health and justice director, Alaska Community Action on Toxics
The Biden administration has introduced new regulations to increase insurance bonds for offshore drilling cleanup, targeting companies deemed financial risks by the Bureau of Ocean Energy Management.
The new rule mandates supplemental insurance for costs related to decommissioning offshore oil and gas infrastructure.
It aims to protect taxpayers from bearing the financial burden if oil companies default on their cleanup responsibilities.
Estimates suggest the rule could generate $6.9 billion in new insurance bonds to cover potential bankruptcies of offshore operators.
Key quote:
"The American taxpayer should not be held responsible when oil and gas companies are unable to clean up after their own operations."
— Deb Haaland, Interior Secretary
Why this matters:
Offshore drilling carries inherent environmental risks, including oil spills and habitat destruction. In the past, the burden of cleaning up oil spills has often fallen on taxpayers when drilling companies lack the financial resources to cover the full extent of the damage. Increasing insurance bonds seeks to rectify this by shifting more of the financial responsibility back to the companies conducting the drilling operations.
California officials are poised to take unprecedented action against excessive groundwater pumping in Kings County, potentially imposing state control to combat the agricultural practices that threaten local water sustainability.
California may soon implement state control over groundwater in Kings County due to excessive pumping by agricultural interests.
This move could mark the first time the state enforces the Sustainable Groundwater Management Act, aiming to protect local water supplies and prevent land subsidence.
Major agricultural players in the region, influencing local groundwater policies, may face significant financial penalties.
Key quote:
"The stakes are extremely high, and the risk is extremely high."
— Jasmine Rivera, community development specialist at Self-Help Enterprises
Why this matters:
California's relationship with groundwater is a complex dance between necessity and sustainability.
Biodegradable food packaging is a step in the right direction, experts say, but when composted carries risks of microplastic and chemical contamination.
Oregon’s Regenyx plant announced its closing in late February, with those involved calling it a success, despite never reaching planned capacity and millions of dollars lost.
