Time to grow up, AoCs. New blood needed.

Agents of Conscience, I'm not asking you to stop making friends and networking with people like yourselves. But I think we need more critical dialectic thinking.

The political system in the USA says the people who believe fervently in one thing (as opposed to being well rounded and open minded) invest earliest in the process to produce a candidate who must guarantee them what they want. These people are leaders, but I don't say "leader" with any capital L. They get candidates to commit early to a position (ethanol perhaps) the candidate has not had time to research. This produces perverted environmental legislation as well as bans on stem cell research and prayer in schools.

The more fervently you hold to your supposition, the more people who are AoC are attracted to learn from you, and you can quickly get a small posse to support your candidacy, and perhaps leverage the system.

But if you are not listening to critics, you risk the worst possible outcomes. EG:

1) ROHS "the restriction of the use of certain hazardous substances in electrical and electronic equipment". It means that you replace the toxic LEAD (Pb) in Solder circuitry with silver, gold and tin. Sounds great at first. Europe has done it, Japan is doing it, it has a lot of momentum. BUT the lifecycle of elements and production means we are mining Gold and Silver (one of the top producers of mercury is silver mining) from rain forests in developing countries to make less toxic (and less recyclable and less durable and less repairable and more greenhouse gas producing) circuit boards, which are going to be buried in a well regulated landfill in a developed country. The lead being replaced, incidentally, is one of the highest recycled (non mined) content metals on earth. SHAME!!!!

2) Mercury recycling: The USA has all these mercury recovery and recycling programs, sending environmentalists all over the place to hunt down mercury products and recover the mercury through recycling. The mercury is then (according to WSJ April 2006) primarily sold to alleuvial mining programs in rain forests. We are taking mercury out of well regulated western landfills and sending it into river basins in Africa and the Amazon. SHAME!!!!

I am a hard core environmentalist, and I don't mean to overstate the negative. Banning lead from gasoline was probably the best environmental law ever passed. But banning lead from solder may be the worst environmental law ever passed. I'm not saying to stop environmental laws. But I'm saying that the next generation of AoCs and environmentalists needs to study the entire lifecycle of product decisions. I read all kinds of insults hurled at environmentalists in engineer forums for solder, and I can't say I blame them.

(This turned into another "Alchemy must lead to western medecine" blog).

What I'm hunting for is environmentalist writing which is not back slapping emotional rib-punching self-righteous wreckless hogwash. The reason I need it is that I WANT OUR TEAM TO WIN. Some of our quarterbacks suck. There's no time to waste making non-toxic, biodegradeable packages out of baby seal pelts. The environmental answers must be rationally and logically researched. We have a limited number of enviro or eco-dollars to spare out to the M1 economy, and we need to spend them wisely.

Gold

Ok, it's getting through. It's going to be bigger than landfills. It hits endangered species, rain forest, toxicity/cancer, and it's driven by the most inane, dispensible purchasing decision we make.

4o years from now educated people will not buy gold. It will prove easier to change than vegetarianism or organic foods because not buying gold saves you money. Buying gold paves roads into rainforests and kills gorillas.

Duh.

Hollywood is getting it. Not that Hollywood is the best champion to look towards (see "the day after"... or actually, don't).

This is not like a boycott of coffee which would hurt poor farmers. The gold miners are poor, but they are being relocated to unnatural places where they buy/eat bushmeat.

I'm going to write more about this.

Evolution of Environmentalism 1: Agents of Conscience

I don't know about you, but I know when it started inside me. 10th grade, FHS Sophomore 1978, morning speech ("forensics") class. The long-term speech/debate coach (Dollarhide?) had gone into Jr High administration and they filled his position with some fraternity kid from Univ of Ark, Randall Oxford, who had been an FHS debater sometime before. At least that's the version I recall.

To make a long story short, the morning Foresnics/speech debate class was lightly attended by the teacher, who was out of office 2 years later. But those AMs had some smart kids in them, and we were talking all the time about big stuff. My mom had given me a bunch of wild reading, Bhagavad-Gita, Tao, Plato, and I was giving the New Testament its fair share. I really wanted to do something profoundly spiritual for the rest of my life.

I think extinction is a strong hook for environmentalists. You see rain forest disappearing, tigers going extinct, you acqaint that with your favorite animal (dinosaurs, duh) and realize your second favorite (gorilla, dolphin, tiger) is on the chopping block.

So anyway a lot of us young folks (anyone sitting near me at least) were debating whether leaving society and becoming a hermit was preferable to riding along in a society which was pounding the daylights out of future generations' habitat. I came up with the concept that the hermit path was going to keep my conscience all shiny without changing anything. And that you had to do what is necessary to change society, and do what is necessary to get along in that society in order to change it.

I stuck with that. Some friends (some outside of HS, I also spent a lot of time at Univ of Ark student union, where i was a janitor in the evening) told me it was impossible, if I entered the machine I'd get chewed up by it.

Well, jump ahead a decade or two. I see that inside the machine there are a lot of us environmentalists, trying to pay off our college loans or buy a nice house or afford to buy at a coop instead of Wal-Mart. As is natural, whether you are a skinhead or a gangster or a fraternity drinker, we hang out with folks like ourselves and read one another's blogs and listen to one anothers songs, and get along with each other.

So how do we find a career path? We are kind of competing against each other for a limited number of eco-jobs, and all agreeing more funding is needed to raise the tide for all of our eco-jobs. We wind up adapting much of society's get-along, consensus-power, back-patting talk and accomodating and generally showing deference and agreements with each other. For example, how could we not be suspiciuos about a recent report (not enough data to confirm relevance or causality, but it's an example) that the icy poles or Mars are receding? That's kind of a shocking blow to "Global Warming", the current celebrity of environmental causes.

I find asking about it doesn't alarm friends as much as when I say I'm still open minded to how history will judge the Iraq War II. I won't get into that here, except to say that as a student of WWII I am a little concerned by how short term "proof" or certainty is measured, and I am relied we didn't have streaming embedded coverage of Iwo Jima or Normandy beach. I mean, who could have possibly believed those Japs could have formed a democracy when they were walking out and committing suicide bombing?

End of tangent...

What I'm exploring at this stage in life are 2 things. Entrepreneurism vs. Idealism and need for Dialectic in Environmentalist study. I will vomit if I attend another Middlebury College lecture where everyone nods in agreement and subtly underhands softball questions about environmental issues. It's disgusting to subject those students who have invested that much tuition to such vacant thinking. I'm sure there have been good fighting arguments at lectures I've missed, but I don't want to risk the stastical potential of my time spent watching the get-along-back-patting-political-consensus-more-money-so-we-don't-distastefully-compete-for-one-another's-jobs-so-lets-all-chuckle-and-applaud-at-taking-for-granted-we-all-vote-Bernie-Sanders drivel.

That kind of crap means we collect fluorescent bulbs to recycle the mercury, selling the mercury to alleuvial mining groups who dump it in rain forests to obtain gold. It means we change lead solder to silver-gold solder, increasing demand for that gold, increasing demand for that mercury. And feel good about ourselves.

My life and my determination to be an agent of conscience is too short for that. We must embrace truth.

But if we choose entrepreneuralsim and are trying to build a company and hire people and pull ourselves up by the bootstraps, how truthful can we be every single hour of every single day. I don't know what the crap on the floor an employee asked me about was. I'm sure it's not radioactive or poison, I'm sure it's oil. But if I call in a test squad, someone's going to lose their job. How sure can you be? I offered to clean it up myself and put it in a bag and bring it to hazwaste day (ca-ching), and I encourage the employees to ask me what the liquid on the floor is every day, and to come in and report every injury, cause you have to. But my clients have pushed my price down from 18 cents per pound to 12 cents. It's a cloudy sky overhead, prepare for rain.

to be continued...

2080 vision - new no-knee-jerk environmentalism

May 5, 2006. If you plan to live to 2080, please apply here:
(another blog on the theme of unintended consequences...)


There are a lot of people in charge, working hard, in government and business, etc. You've seen that. Some care a lot about things outside their own personal interest; we call these "good people". "Outside" could mean being a "company man", could mean worshipping your family, could mean caring about critters, you could be a patriot, or care about other aspects of the environment. But what I'm looking for is someone who cares about the year 2101, and it's likely going to be someone who will still be alive in 2080. Among those who will be around in 2080, those who care about things outside themselves will care about the year 2101. Also, they aren't yet distracted by other good things they'll one day care about, like the job or kids or status.
There are actually a lot folks who care about 2101, but most of us only have time to form opinion about the direction the world is headed based on cursory information. We learn about, and choose to care about, something outside our personal interest - say ice caps melting. We form an opinion about it. But most of us don't have enough expertise to do more than cast a vote and muster ourselves to agree or disagree with another person's opinion.
Both the young and the older tend to form opinions based on listening to people we trust. By trust, I mean we trust their motives and their facts, that they are a good source of information, smarter than us, or at least smart enough to know more than we are likely to learn in our spare time between now and the business trip or kids soccer game or taxes or box elder cutting or Mothers Day card or cassava pounding... At best, we are students who take a class on the issue and learn enough to write a paper during a semester.
So, let's call these people PTWs, Professionals We Trust, as gatekeepers for our opinion. Now let's pretend we work for the DEP or ANR or EPA, and we want to develop a policy, and we aren't experts in the field of, let's say, computer recycling. We want to get some PWTs together so we can have some informed policy that will improve the direction the world is spinning towards 2101. How about if we gather a big representative sample of these professionals, and see if they can arrive at a consensus.
All good so far.
Now we can't technically call this a "focus group". We may think we have a "focus group". But in actuality, a good focus group is designed to bring NEW BLOOD and fresh perspectives. Campaign Focus Groups disqualify anyone with a professional interest or knowledge, they are person-on-the-street consensus tools. We don't have a focus group, we have a set of people who may or may not be able to see outside their self interests. And of those looking outside their self interest, they may be well informed on just one thing, or have "patriotism" or something as their selfless goal.
You start with someone on the group who everyone can agree is unselfish, outwardly directed. One group of people is upset about photos of young kids standing on piles of garbage that were exported to their country from the USA. These people care a lot about others. They start to organize to drive business to people who share their concerns. That's a good thing! I don't like competitors who ship garbage to other countries! They undercut the costs I take on when I remove and properly manage the garbage. They have to be on the committee.
Other well meaning businesspeople, who have more facts, seem to agree there's a problem, and seem motivated to take resolve it. What could be a better business than helping improve the world? If you can earn a living, buy lacrosse equipment for your kids, and help these passionate folks improve the situation, that's great isn't it? We have me and another couple of ethical recyclers on the panel now, we are starting to form a real PWT group.
Now there's a third issue or fear - might be global warming, or national security, but it should be something relating to computers... I know! Privacy! There are a lot of stories about phishing scams and data. The beauty of this is that it can be a civil law issue - people are suing companies for losing or reusing confidential data. And who gets sued, usually? If you want bacon, you corner the fattest pig. Clients with money. Banks, hospitals, etc. These folks are concerned about their liabilities in both issues - seeing their garbage dumped overseas, and failing to safeguard client data, and they are certainly the victims of fraud as much or more than the rest of us.
Together, these people - the activists, the businesspersons, the EPA officials, and the bank/hospital clients, and other people like retailers and garbage haulers (who don't want to be involved in the policy but are afraid they'll get legislated at if they don't attend) agree that it's not ok to just send hard drives just anywhere, the information needs to be erased. A guy who sells hard drive shredding equipment will sponsor coffee at the conference, no one really pays attention to him but he's there for insurance.
Actually, everything I've written so far looks good.
Are these people enough to get legislation passed? NO. I'm telling you, from work in government, that this is a group which is "necessary but not sufficient" to create legislation which actually gets written and actually gets voted on, passed, and not vetoed.
One place you can turn is to Public Interest Groups (PIRGs). They have mainly been fueled by 2080s, college kids who care about something but don't have anything invested yet, who care and burn. Because lacrosse pants and home mortgages really do start to dilute your time spent thinking of things in the future (back to paragraph 1).
Where else can you turn?
How about a multi-billion dollar company which is working on another realm of the world - personal property rights vs. copyrights and copyrewrites. They for years have been involved in a slugfest with another group of individuals, technicians and folks who hate checking the End User License Agreement (EULA) which basically says that you can't make a copy of their software for your friend. That's fair. But they have also come up with OEM licenses and other things to keep you from passing on the software when YOU HAVE FINISHED USING IT. It is all about moving away from personal property, to a new system called LICENSING. It's based on the same concept as the Inheritance tax, that when a deceased person is "finished" with their things, that the government can take a slice. Again, probably fair. But this is digital... it is when you are finished with each individual piece of property, before you've died, that they take ALL OF IT.
"So when the company [Microsoft] announced late last year that it was favoring sweeping federal privacy legislation holding companies accountable for how they treat consumer data, one might be forgiven for wondering what the company had up its sleeve." (Wired News
http://www.wired.com/news/politics/privacy/0,70804-0.html?tw=wn_index_22
Well, some of us are exhausted, and willing to take any victory we can, so if we can do well on our issue (children perched on garbage overseas sent by competing businesspeople underpricing our services), and our friendly businesspeople who care can get more money from the banker and hospital, let's take this. The Linux guys will work out the other thing.
OEMs also jump in. HP makes 50% of all corporate profit from sale of toner cartridges, and has gone to great lengths to ban refilling and reselling toner cartridges. Too bad we can't scare people about privacy issues around toner cartridges. But we CAN scare them about their HARD DRIVES. Refurbished "white box" computers are 1/3 of all sales in the USA, much higher worldwide. For used monitors, white box PCs, and toner cartridges, there is another piece of legislation, a form of flow control called Manufacturer TakeBack, which I'm someday going to defeat in court. That's for another blog... let's finish the privacy issue. Privacy is good. Where is Robin's problem in all of this?
ONE, no one discussed the fact that the billions of dollars in software being wiped off the hard drives from this new legislation will cripple the secondary market, whose revenues other businesspeople (very small businesses, by the thousands) depend upon to make their own recycling collections work. Will the net effect be more recycling? Maybe it will, I'm just saying that I didn't bring it up because I didn't hear anyone else ask.
TWO, no one actually documented that hoards of Iranian students have upgraded the factory where they were taping back together all of the shredded paper (a big sales line in the fine paper shredder equipment market) and they are now booting up hard drives to get your personal information. WE NEED A VICTIM. In law, it's called Habeus Corpus. I have not seen any evidence other than BAN grabbing hard drives in Nigeria for their own purposes that there is a business booting up Pentium Is and getting data.
THREE, no one looked at the balance of harm. One of my clients used to donate their computers to schools. Now we take them and wipe all the drives, and the schools don't have software and we can't afford to donate the PCs because of the wages we paid wiping the drives. So I'm the winning businessman in the example above.
We need people who are experts in data security and information theft in the room. That doesn't mean people who sell fear or shredding equipment. We need statistical measures. If I put my P1 on a boat to China without wiping the hard drive, which do have have to fear more, data theft, or getting struck by lighting on the way home? How does hard drive skullduggery compare as a statistical risk against, say, avain flu?
My understanding from talking with writers on the subject is that the risk is real, but that Microsoft and other program sellers have much more to gain by wiping used equipment than any consumers have to lose. Most data theft (where there's habeus corpus, an actual, not theoretical, crime) happens where there is proximity to, knowledge of, or contact with, the victim. The thief has as some point been within 50 feet. In house, or a neighbor, somehow you want enough info about your victim that you don't do something dumb, like me claiming to be a 80 year old black woman. A distant second is theft from online hacking and phishing, where the data is at least very current and available in great volumes very quickly.
I'm sure there are opportunity crimes. You know what - Pentium IIIs an 4s need to be wiped. That's because someone will boot them up to see if they work, and that person is probably honest, but might not be. Generally, it's enough to erase the files, but you might want to go further and erase the whole hard drive. DON'T LEAVE YOUR P4 for curbside pickup, or in an unattended recycling shed until a data wiper can get to it, please. But a PII that's been sitting in your closet for 5 years?
On the scale of risk, where does booting up old Pentium Is, shipped halfway around the world, rank? I'd guess it's like leaving sales records of maintenance in the glove compartment of your car when you sell it. Someone COULD find out more about you through that paperwork. And wipe your DNA and fingerprints off the glove compartment while you are at it.
Can hard drives which are F-disked be reopened with special software? Yes. That's what DOD (Dept. of Defense) standards are about. If it's George Bush's red button laptop, DOD isn't enough, that thing's gotta be smashed. If you are already taking steps to secure data in house, like a hospital, you should be wiping hard drives yourself.
Don't get me wrong, I'll keep doing this, and keep charging for it. But we recyclers need to come to grips that there is a significant sector of our marketplace which ain't buying the fear we are selling. If I am a public library and I know all the data on the PCs has been publicly available to everyone since we got the P1, am I going to take money out of our book fund to pay Robin to wipe the drive? In the meantime, if I am a data thief, will I pay for an unseen/untested P1 laptop from that library and spend 20 minutes reformatting the F-disk hard drive?
The future: There will be a program installed in every PC which is a "Mission Impossible" cassette. IT departments will have a key to execute the program, which will spew 1s and 0s all over the drive. We want to work with colleges and other institutions so that the program also re-installs a "spare tire" program, like Linux, so that the PC can still be easily retested and resold.
Meanwhile, your privacy is already for sale by credit card companies. go to
www.abika.com and order your own info. It's worse than an FBI file. Legislation should be directed at ABIKA not at making Microsoft's EULA system easier to manage.
The anti-export folks need to look at where the piles of garbage are coming from. If it is a residue from a legitimate reuse practice, like spoiled apples from an apple store importing apples from America, how can fresher produce be sent? Who is sending the wormy apples? Don't just plunk a kid on the pile and say "don't export food!!!"
The PWT need to take stock in the "consensus" packages we are putting our names on. Too often, a focus group begins with a fair list of reps, and then the ones with less money stop flying to meetings, and it turns into "last man standing" model legislation, sponsored by a billion dollar anti-grey-market conglomerate.
Don't get me started on leadfree WEEE legislation today.
A lot of my friends say, this is good info, good points, but it's too much. If we try to consider all of the possibilities, no one will ever do anything. At least we are making progress. We may as well give up and follow the "free market".
This is where we need some 2080 folks. My generation takes "improvement" to mean next year will be better than yesterday, and we can't deal with a bigger scope of work than that. I say, suck it up, soldiers. You and I couldn't design an airplane either, but let's not give up on flight. Environmentalists have to be more like engineers and med school students. If we care enough about the planet to make legislation, we should care enough to work as hard as a doctor or software writer or a bridge architect. Fixing a problem today which sets the world on a path of powerlessness is wrong. I think people in 2101 should own personal property, stuff they can keep and maintain and resell and buy second hand and adapt and fix. A guy started collecting "disposable" cameras, the ones everyone was screaming about being wasteful 15 years ago, and started refilling and reselling them... Now he's a millionaire. And Fuji and Kodak are bringing suit against him all the way to the Supreme Court!! They say he isn't licensed to fix their disposable stuff.
If there is a simpler solution to the kid sitting on a pile of garbage that preserves our freedom, let's keep the freedom for now.
We are good people, we conference goers. But I think in 2080, we will be seen as the Alchemists who gave birth to modern medecine. The future environmentalists and ecologists will be less scatalogical and reactionary, and take time to measure all of the organs affected by legislation, and make the best choice. Maybe it will turn out to have been the privacy legislation after all. I'm just critiquing the sausage making process. I don't have time to actually answer the question, you see... I have to go to work.
If passion drives you, let reason hold the reins. - Benjamin Franklin
There is no poison on earth more potent, nor half so deadly, as a partial truth mixed with passion. -- Michael J. Tucker

Thank you Lynn Scarlett - Mining Subsidies


Thank you in advance, Lynn Scarlett
"Industry-friendly interior chief quits...[Gale] Norton leaves office at a time when her agency was increasingly tied to disgraced lobbyist Jack Abramoff....Until Bush appoints a successor, Deputy Interior Secretary Lynn Scarlett will take the helm of the Interior Department. A Santa Barbara resident, Scarlett is former president of the Reason Foundation, a Los Angeles think tank with libertarian leanings. She has worked to promote free-market solutions to environmental problems." San Jose Mercury News 3/11/06
http://www.mercurynews.com/mld/mercurynews/news/14074802.htm
March 11, 2006: Starting soon, Lynn Scarlett, former executive of the Reason Foundation, will become Acting Secretary of the USA Interior Dept., replacing Gale Norton. http://www.mercurynews.com/mld/mercurynews/news/14074802.htm. Scarlett wrote reports on recycling and solid waste in the 1990s, and was a source for the mid 1990's diatribe, "Recycling is Garbage" by NYTimes' John Tierney. In a 1997 editorial in Reason Magazine, Scarlett wrote, ``Environmentalism is a coherent ideology that rivals Marxism in its challenge to the classic liberal view of government as protector of individual rights.''
Lynn Scarlett's criticism of recycling was best summed up in her quote from Tierney's article: "In a purely market-driven situation, people would still recycle according to what makes sense in their area."
It will be wonderful to finally have this free market, level playing field advocate finally in charge of the federal agency responsible for collecting fees on federal land mining and forestry projects. The agency is arguably the de facto administrator of the Superfund (technically overseen by EPA, but bankrupted by cleanup costs at federal copper and gold mining sites on federally "leased" land).
Ms. Scarlett has already been in charge of the Bureau of Land Management for several years. The BLM administers land leases to mining companies under USA's 1872 General Mining Act, at a rate unchanged from the $5/acre set during the 1872 Apache Indian wars. Her failure thus far to reform extraction subsidies may be explained by the cozy relationship between lobbyist Jack Abramoff and former Interior Secretary Gale Norton ties (a possible explanation for Norton's early retirement).
If the cost of recycling and waste disposal were still administered in 1872 dollars, the former Reason Foundation president would be outraged. Now Ms. Scarlett is completely in charge of the federal mining and forestry land lease and cleanup enforcement. What can we expect?
Implicit in her 1995 article "Solid Waste Recycling Cost"
http://www.reason.org/ps193.html is a criticism of government interference in raw material commodity supply and demand. The article made valid points about exaggerated landfill closure rates.
Now, under Ms. Scarlett's tenure, we should expect the price of copper, gold, aluminum, silver, palladium and other metals used in electronics manufacture to be unshackled from the 1872 GMA / Superfund subsidy system. As mining and refining bear an increasing share of their true costs, we can expect electronics recycling to achieve a great leap forward, as it has already in countries without federal mining subsidies. The “wild, wild east” has a truly free market for raw materials, making it a magnet for recycled metal.
The subsidies by the Interior Department were a major focus of the GAO's recent report to Congress on the underachievement of electronics recycling in the USA. It is easier, more energy efficient, and cleaner to get a pound of copper out of used electronics than out of a mountain in Montana. With reform of the BLM, it can be a less expensive source of copper as well.
Even free market environmentalists shouldn't demand complete reform of the BLM subsidy programs in the first year. Perhaps, as a starter, the Interior Department can implement a "user fee" for mining companies obtaining federal land leases. Added to the $5/acre, 0% royalty system, the User Fee can cover the salaries of the federal workers who actually administer mining and forestry land leases. Afterwards, these "user fees" might even cover the overhead of these federal agencies, or to pay for the development of access roads put in by the federal government to provide access to the mining and timber industry.
We shouldn't expect a profit from leases or "user fees" on federal lands any more than we demand a profit from public recycling programs. But perhaps primary smelting and mining may one day pay enough into the system to cover its own Superfund costs, as recycled smelters are forced to do. Seven of seven of America’s secondary copper smelters have been closed, with the biggest factor being failure to pay their cleanup and remediation costs.
China, which has no BLM subsidies, has been more than happy to take over the secondary copper market. America is left with mining and primary smelting. If you owe Superfund ten million dollars, like recycled smelters, Superfund can go after you. If you owe Superfund ten billion dollars, like a virgin smelter, BLM takes over the "leased" site.
The simple fact is that hard rock mining on federal lands accounts for 45% of all toxics pollution released by all USA industries. If we could dump all of America's raw municipal solid waste straight onto the ground on federal land, it would generate less pollution, and would generate more than $5 per acre in revenues. Or another “modest proposal” might be to dump MSW onto an existing mining Superfund site, effectively "sub-letting" the land lease for the fraction of a cost of a regulated lined landfill, a win-win scenario for both extraction and disposal.
The 1872 mining laws have been around so long, that the recycling community doesn't even discuss them any more. But the fact is, reform works.
Canada's small revisions to its 1977 mining cleanup laws are credited with mining-giant Noranda's multi-million dollar investment into electronics recycling the following year. A few months after the reforms, which were opposed by the mining company, Noranda’s president made a major speech on “sustainability” as the future of the industry, and Noranda soon made the largest electronics recycling investments in history. Micrometallics of California is now owned by Noranda.
http://www.retroworks.com/easiest_solution_to_electronics.htm
We eagerly await the anticipated effects of similar small doses of free market reforms to the 1872 General Mining Act and Superfund implementation. Go to it, Lynn Scarlett.
Robin Ingenthron March 11, 2006