Thursday, July 24, 2008

Grant $ Gets Green

This article, Grants Awarded to Help Protect Chesapeake Bay, in today's Washington Post is about school kids converting parking lots to rain gardens, grants for green roofs, and 32 other project grants intended to improve the Chesapeake bay.

Here in the city I heard just the slightest mention of the court house roof in the green gov't workshop, but nothing has been committed.

During discussions with Kalahari, I was the only one to bring up the acres of parking lots, or the lighting required to park all those cars.

Some leaders have privately expressed their concern, but so far all the work has been behind the scenes. What good is it to improve the watershed in one locality only to have the next runoff king being built somewhere nearby. I will concede that Kalahari is planning a water runoff containment design as required by ordinance, however, what these grants are doing is going above and beyond. The Kalahari resorts, for all of their good green designs inside, will still create quite a footprint of non-porous surfaces.

As the court house design and bonds come up, I hope that fellow citizens speak up for green development so that we can be leaders, not followers on this topic.

And FYI, the last major green development in the city of Fredericksburg has saved 100s of thousands over the last 10 yrs. So don't rely on 'it costs too much'. Let's at least discuss the options. I for one would like to see a proposal for a living roof on the 60M courts complex. Unfortunately I don't see a parking garage design coming for Kalahari.

25 comments:

Larry G said...

One of the things that we need is to know what the various options and costs are - including state-of-the-art.

I don't think we should assume what level will be built nor automatically advocate for "more" unless we know what "more/better" is and the costs.

For instance, porous pavement IS an option and while I don't know cost specifics, one can bet that it will be more.

But, the city could require it and then make it part of the CDA tax district that already exists for other infrastructure.

It's just that ...without an effective - knowledgeable advocacy that Kalahari..and most other businesses and local governments are probably not going to do any more than the law and regs require.

Since Silver Companies are involved, it IS possible that they will try to do a bit more ... LID - Low impact development.

but... bottom line... if citizens of this area want a better approach to storm water runoff - and I totally agree.. it should be a top priority - then we need to know what options to advocate for.

kudos.. for bringing the issue up

Bryan said...

To date, most of the LID examples around the area have been erecting erosion control during grading and construction, replanting trees, constructing landscaping around facilities.

Some of the other "Green" proposals are things that make good business sense, such as energy efficient design, treated windows (except in the Maury School project where they were required to leave the old drafty windows in the building), additional insulation. I group these things together because businesses will normally implement these without LID because of the added energy cost savings.

What I'm advocating is that on gov't facilities, where the taxpays are the owners, at least one innovative design be considered that goes beyond normal (green roof, solar assist, reclaimed building materials). Speaking of building materials, how about reclaimed coal ash from the power plant in KG:
http://www.sciencedaily.com/releases/2005/05/050504180858.htm

Larry G said...

There are building standards - LEED...even a platinum LEED.....

but energy efficiency is a way different concept than storm water runoff/LID....

:-)

aren't they recycling the ash to aggregate at the KG Plant?

kcw said...

Porous concrete is meant to attack water runoff from a flooding perspective, not a pollution one. Porous concrete allows some water to drain into the soil below. Some system even include big drainage pipes and tanks below to effectively grab all the rain water and slowly dissipate it into neighboring streams...thereby lessening flash flooding possibilities downstream.

Though I don't think the topic was explored the main issues with the Chesapeake is pollution DUE TO stormwater runoff...with the primary cause being agricultural but also including to a large extent non farming agricultural (by that I mean grass).

I'm less worried about impervious services than I am about an increase in manicured grasslands which inevitably end up gaining fun chemicals to ensure guests see only the best.

Being an African themed park I'd love to here african landscape designed being worked in (ie. desert-scape exteriors and low-water plants).

Green initiative? Take cars away. Create a walking government area. Bring all government into a certain area and ban cars. Tear up some asphalt and put in gardens and trees and picnic tables in a much bigger area than currently exists (ie. hurkamp park). Something I would love but would never happen (too difficult).

Larry G said...

I don't buy the farming angle.

There are far, far LESS farms now than there used to be.. and more, most of them using better buffering...and practices than ever before. How can we have MORE farm runoff with LESS farms?

I would posit that the "contributions" from 300,000 people in the Fredericksburg area via lawns, roads, parking lots, and sewage treatment is far, far higher than upstream farming.

what is increasing.. at the highest rate is land clearing and impervious surfaces - and it's what is on those impervious surfaces - oil, anti-freeze, pet feces, and other contaminates that - flush off of those surfaces every time it rains.

Take note the next time you use a parking lot as to what is on it - then go back during a rain storm and look or go look at what is in the storm ponds.

Porous paving... sorry to correct ... is not for flooding... instead designed to let water gradually soak in to the ground - get filtered on it's way back to the aquifer.

Heavy rain overwhelms porous paving.. and so storm ponds are still needed (but smaller)... unless there are also engineered swales...essentially medians and other areas that are depressed - (i.e. lower than the pavement surfaces) that receive and sequester and filter into the soil rather than feed it to storm water facilities...

check it out:

http://www.forester.net/sw_0305_porous.html

just GOGGLE "porous pavement"

You can see examples of engineered swales at the new Harrison Road shopping center - as well as some huge storm ponds behind the center... just drive around and look. These ponds are needed even though they are using good LID ..but not porous paving..

(compare these newer ponds to older development ponds which are much smaller).

Subdivisions (and city streets) contribute nitrogen/phosphorous but probably more important - pesticides and weed killers... which even in small quantities when washed into creeks, act like poisons in the waterways.

not to mention.. hormones and prescription drugs via the sewage treatment plant which does not remove those contaminates because there are no current rules requiring it.

It's this kind of thing that pretty much escapes the general public's attention...

they somehow believe that we are not dumping oil, anti-freeze, week and critter killing poisons, hormones and prescription drugs untreated into the waterways - but we are.

"we" - advocate for "green"..but without specifics - so local elected really are not hearing what exactly we'd like them to do... instead of current...

.. which is.. not very effective... advocacy in my view.

some would say ..that this is too much for average citizens.

to which I would say.. that we only get what we are serious about accomplishing... and if we leave it to others.. we get what others decide....

There ARE places that DO require porous paving...

and here's an example of where citizens DO make a difference:

"Green Common Sense"

here's an excerpt:

"Karen Forget leads the volunteer group known as Lynnhaven River Now, that's committed to cleaning up this historic body of water.

Virginia Beach is the state's most populated city. Thirty-five percent of the land surrounding the river is covered by hard surfaces like rooftops, driveways and roads.

"So on 35 percent of our watershed, when it rains the water goes directly into the storm water system, which goes directly back into the river and it carries with it whatever is on that surface," Forget explained.

Forget's group has rallied governmental agencies to address the problem.

http://www.cbn.com/CBNnews/404847.aspx

In our own area - do we know - what the pollutant levels are in the River just below Fredericksburg?

How can we know what to advocate for - if we don't know?

Bryan said...

KCW - Great Comments! Thanks for explaining to everyone the porous concrete thing, although parking lot runoff vs ground filtered runoff is a bit difference, the earth has a natural filtering capability. For anyone interested, here is an example of what we're talking about http://www.lakesuperiorstreams.org/stormwater/toolkit/paving.html

Pervious pavement is designed to allow percolation or infiltration of stormwater through the surface into the soil below where the water is naturally filtered and pollutants are removed. In contrast normal pavement is an impervious surface that sheds rainfall and associated surface pollutants forcing the water to run off paved surfaces directly into nearby storm drains and then into streams and lakes.


The state DEQ is just one organization measuring pollutants in the Rappahannock. There draft 2008 analysis is available here, specifically in this appendix. I like the suggestion of a desert/low water landscape for Kalahari, as long as it also adequately retains ground and prevents erosion. Desert scapes are notorious for moving around during gully washers.

On another note, I wouldn't say it's necessary impossible to green existing asphault. Check out this picture of downtown Charlottesville. This was once Main St, with parking and traffic. Now it is a popular shopping & dining area, with high rents and successful businesses.
Main Street Photo, they even went as far as to install these nice trash and recycle bins (click for picture).

Bryan said...

Larry,

Thanks for the link, I didn't realize there was porous asphault! Learn something new every day I guess.

I whole heartedly agree that the biggest problem now is lawns (home and commercial). Although the farmers don't get off scott free. Farming practices have changed over the last 50 years to incrase per acre yields, particularly with the use of fertilizers. The one good thing is that the Gov't has been assisting farmers in contributing buffers between fields and water sources, unfortunately it still isn't a requirement everywhere. Recently I would say there has been a change in more organic farming, and lower impact methods, that was the easy part, farms are relatively easy to regulate and incentivize compared to residential lots. The only way to incentivize folks from fertilizing, might be to put a luxury tax on the stuff. But you would never hear the end of it. Would probably be as bad as the gas tax debate....

What a lively post this has turned out to be.

If I 'advocated' for a green living roof on the courthouse, might I be able to get a few more supporters out? That would cut the amount of runoff from the roof, and provide a cooling capacity which could result in lower a/c bills.

Larry G said...

Bryan - the 305(B)/303(D)report is... voluminous...but unhelpful IMHO.

For instance, we know that nitrogen and phosphorous are two big issues in the Chesapeake Bay ..and by inference - the rivers that feed into it.

But.. do we know .. how the Rappahannock COMPARES to other rivers in Virginia?

For that matter - on the Rappahannock itself, do we know which parts of the river have high levels of nitrogen/phosphorous and which places have lower levels - and from what sources?

For instance, we hear that farming is a big contributor..

How do these nitrogen/phosphorous level above Fredericksburg compare to below Fredericksburg?

What is the biggest contributor in the Fredericksburg Area?

Is it the sewage treatment plant, or subdivisions or the big box parking lots?

If area citizens wanted to advocate local government to concentrate on the highest priority pollutants... what would they be?

Should we tighten up subdivision runoff rules or require porous paving for new big box?

Without specific hard data in a form that helps everyone truly understand what the issue are - relative to each other.. we end up with a many people advocating different things.. that they personally believe in - without a collective understanding of the issues or an agreement about which ones are the ones that deserve the most attention.

complicated? yes.

but.. if we really want to address the issues.. we have to understand them.. much better... IMHO.

whose job is this?

well.. if you look through the DEQ report... you'll see they collect a crap-load of data but they apparently do not feel it is their job to distill that data down to citizen-understandable summaries.

They basically are doing precisely and exactly what the EPA requires - no more - no less.

And the City and Spotsy/Stafford?

they do exactly what the State regs call for - no more - no less.

and businesses - ditto...

with the exception of the Silver Companies - which have taken many hits form the locals.. but almost alone, they have actually voluntarily implemented some things that were/are over and above the regs.

Larry G said...

does any know and/or have a link to where...physically... Kalahari will be located in Celebrate?

TAT!

lcg

Larry G said...

On the impervious surface/runoff issue and standards... ordinances, etc... I found this in the paper this morning and found it enlightening and thought others might also:

Water plan angers builders
Tighter standard for Swift Creek pleases citizen group, though Swift Creek plan angers builders

A proposed new water-quality standard for Chesterfield County's Swift Creek Reservoir would make building in the lake's watershed significantly more difficult

rest of article at:

http://www.inrich.com/cva/ric/news.apx.-content-articles-RTD-2008-07-27-0161.html

Bryan said...

Larry,

Check out this article on the latest site plans for Kalahari:
http://burgnews.blogspot.com/2008/06/new-kalahari-site-drawings.html

Basically, if you are standing in the parking lot in front of the Expo Center, Kalahari will be to the left. The parking lot will continue in front and also across the road. It will probably go on for several hundred feet. Technically, the lot goes all the way to the field where there slavery museum is proposed.

One advantage of this location, is that the height of the buildings is hidden by the distance from the river, and the elevation change (there is a high bank near the river where the civil war trenches were located). This way the structures should be out of the site line from the river.

Larry G said...

Hey Thanks.. Brian!!!!

By the way.. there are some neat hiking trails between Celebrate and the River - and there are some runoff issues in that area around the Convention Center.

I understand that they are working on it....

one of those trails... goes through a large culvert underneath of I-95 ....!!!

you may actually already be aware of these trails since I believe it was on your site that I saw a map of them....(in the context of bike trails - both they double-duty).

lcg

kcw said...

Larry,

You definitely got the big issue right, upstream vs. downstream. The people upstream sometimes do things without regard to the people downstream.

This happens a lot. I moved down from PA where a borough may put industrial zoning right on their border...next to a neighboring township's park-open space zoning.

In just a handful of areas are people looking at this type of pollutant issue at a watershed level. This type of view is often very difficult to get buy-in..with everyone playing around with what to do with everyone's land. (no don't put that thing there, I have a great piece of land up here that is more suited for it..plus I'd love the taxes).

The Chesapeake Bay Commission tries to do this for the entire Chesapeake but they meet the same hurdles.

Larry G said...

KCW -

closer to home.. how would citizens in Fredericksburg know what were the most important things to advocate for... if they don't even know what the pollutants are that Fredericksburg adds...

or even whether the river is already heavy with nutrients before it gets here (from upstream farms) or if it arrives here fairly low in nutrients but leaves here ..heavy with nutrients.

We simply lack information that I feel we need if we want to advocate for something...

For instance, if we KNEW that storm water runoff was a BIG problem in the Fredericksburg area, it could galvanize citizens to encourage local elected to require stricter run-off requirements for impervious surfaces.

but without that info.. we don't even know what to advocate for... we only assume.. but we don't know the data...

advocacy based on real data is much more powerful than ..what I call "feel good" advocacy...

kcw said...

Getting real nutrient runoff data would take a long time, to get valuable info I mean. Limited data could be, in reality, scientifically insignificant as it may be a one-time occurrence.

With the destruction of the dam historical data becomes iffy with such a significant change.

Bryan said...

I hear what you're saying on wanting pre/post event data, but I respectfully disagree with your stance on "feel good advocacy". Granted, you can't exactly go as far as creating very restrictive laws, but lets simplify it just a bit.

If we know that an event increases runoff/pollution source (parking lots w/oil & vehicle fluids), then regardless of whether or not we have before/after data in specific locations of the river, we can absolutly do something (anything) to improve it.

Doing nothing all but gaurantees that over time it's going to get worse. What you can't measure unless the sensors on in place already, is how bad each event is. But we can extrapolate that the combination of many events (ie. parking lot construction) has an overall effect.

Which is why I take a more middle-of-the-road when trying to argue this point. Let do what makes sense now, possibly as a smaller up-charge than some radical ideas, but that is better than doing nothing.

Realistically, probably not going to get a parking garage at Kalahari until they decide they need massively more parking. I accept that, plus the drainage design should include settling ponds. What I am interested in is if anyone is going to do a water quality report that includes the backwash of the park, along with Kalahari, Hampton Inn, and the other new hotels once we get decent room utilization.

On to the plans that I think the citizens can affect. The new courts building. If the residents of Fredericksburg are funding $60M in construction, what's the added cost of a green roof? What could we do to make the building energy independent? Lets take a look at what's possible, compare that to the costs, and see what we can do to prevent this building from adding to the carbon footprint of the City of Fredericksburg.

Back to my argument, we may have difficulty calculating the benefit, but doing nothing gaurantees that it's worse than before. It's worse because we are not removing the old courthouse from the footprint, instead we are doubling or tripling the size of the post office, plus removing some areas of landscaped porous ground. Back to the beginning article, what possibilites are there of getting grants to assist in any additional costs?

kcw said...

All initiatives have pros & cons beyond financial.

Settlings ponds are just a breeding ground for the fun mosquito. They may solve a water runoff-flooding problem but they create a couple more.

I honestly think drainage basins (retention or detention) should not be allowed and, in their place, porous concrete/asphalt with underground retention systems (for large parking lot projects).

I think dripping oil is less of an issue These types of maladies should be caught at vehicle inspection and taken out of the equation not compensated for. I think a better use of funds would be strict inspection standards and high penalties.

As far as other green initiatives again I like low maintenance landscaping (less water) and some level of power generation for 'large' projects (ie. solar on the roof).

LEED standards are more for the building owners to see the benefits in efficiency. Yes through association 'society' benefits but they aren't meant as building design standards, but building options.

Larry G said...

well.... if you want to make a compelling case - that will be hard for those opposed to more regulation to rebut - you need facts.

Any "special interest" group can and will advocate for what they feel is the "right thing" but in the end, an elected official is not going to vote for more restrictive regs because enviros support it -and the business community opposes it.

That's why I say you need facts - that cannot be disputed.

If your facts show that there is a problem - then even the business community will step up to the plate - not all of them - but enough of them so that you move away from he said -she said.

And really... for yourself... do you really want to make a difference??? meaningful changes in response to issues that need addressing....

... or just advocate more or less blindly ... for the things that you believe in?

don't get me wrong.. or.. let me put it this way - don't let my words or the way I've said them be off putting... not my strong suite at times...

.. but ask yourself... if someone is advocating something.. and the have the facts.. are you not more receptive and more pursuaded?

The problem we have right now.. is that everyone chooses up sides and tries to get "their guys" into office.. with the idea that once they get into office..they'll just force the laws on folks even those that don't agree...


... and it don't work that way...

it might for one election cycle but in the end -you don't get the change unless you get strong support from more than just those environmentally supportive.

I just think it is no productive to argue about nutrient reductions if you don't even know the current status... and the advocacy is "fuzzy" ... AND expensive to developers...

they'll oppose it.. and for good reason.

they'll say... "why should we spend this extra money when we have no idea what the current problem is ..or if what we pay extra to do makes any difference"?

that's why I use the "feel good" phrase.

do we want to "feel good" about doing the "right thing" or do we want to make a difference that matters?

Bryan said...

Actually I would say that the data so far has shown that we ARE doing the right thing. This article from June (http://fredericksburg.com/News/FLS/2008/062008/06122008/386566) about the USGS sampling has shown a recent trend in reduction of Total Nutrients. The site is upstream from Fredericksburg, but reflects efforts in other localities upriver. I downloaded the data from the usgs website, and there is a lot more detail about various specific chemicals.

Although to Larry's point, is there a regular whitepaper with an experts summary on what all this means? The USGS does an annual water report, but I haven't been able to dig through to find something as specific as impact from the Fredericksburg area. I'll do some more checking.

There is also the issue of downstream reporting. The USGS's last Rappahannock reporting station is the just on the western boundary of the city. I can't locate an online source, but I believe Port Royal uses the Rappahannock as a water source, which would require the collection of similar, if not the same, data as the USGS station. Unfortunately, having data from different organizations often causes a disconnect in either collection/analysis methods, or in reporting formats.

I do believe that over the coming years, as more politions take interest, there will be better sources of data. Which of course will lead to more available research into the subject.

In the mean time, using Grants to encourage voluntary efforts seems to be a good step. Plus the use of some of these grants to foster projects at young ages will encourage the next generation of water experts.

Larry G said...

yes.. on the FLS article.. read my comments..

I've looked around also and there is data... USGS and DEQ and probably other data but none of it in a straight-forward format that answers the questions ....

and that's the problem,, IMHO

Before we can talk about runoff restrictions - we need to have some intelligent idea of the problem because without that, what level of restrictions should be advocated?

I just don't think it is effective to advocate for some level of restrictions without some nexus to the problem itself.

People could then argue about how much restriction and how much it might effect the current situation..at the least.. put some restrictions in place and then look at the effect it has on the data monitoring.

But without that data.. you wouldn't even know what effect the restrictions were having...

.. and business folks are not going to take kindly to spending gobs of money on a concept...

...that's why I believe you gotta put the data in a compelling form.. since the State and Feds are not....

..the only thing they will do is collect the data... and then not enough of it...

..the newspaper article that I posted earlier about the Lyndhaven River.. told of a group that did just that...

a small, short river that used to have oysters.. that became too contaminated by surface runoff to allow harvesting the oysters...

.. they cleaned it up.... still a work in progress.... but they basically showed that a group of citizens could accomplish that goal and that once the citizens demonstrated that they would - then the elected folks took them seriously... and businesses started going along also...

a very significant accomplishment as we all know..not an easy thing to accomplish...

Bryan said...

Hah, what? You mean you don't like spreadsheets with columns and rows with data by date and nutrient type? Sorry, it's the engineer in me, but I love the raw data format. The first thing I went to on the USGS site was the export as CSV file, then started chunking the data around to get the trend graphs I wanted... Ok, I'm odd, I think I just proved it. :)

Larry G said...

no .. I like the data chunking...but I'm a little slow at dealing with spreadsheets...

I have a DEQ database link also if you want it... I didn't have much luck extracting the nutrient data... there's a crapload of data... but it's not consistent...

What I'm amazed at... is (once again)... the heavy emphasis by the Chesapeake Bay (and other groups - local and state) ... emphasis on "cleaning up the Bay" but when we get down to the nitty gritty of the data... and Fredericksburg's situation... there is no straight forward data for citizens that they could use in advocating for better standards...

it's a real puzzler to me....

the primary advocacy.. is ..."get the Feds and the State to allocate more money"...

.... for what? specifically?

to help build better storm ponds?

better sewage treatment plants...

tougher impervious surfaces standards?

what should citizens advocate for in the Fredericksburg Area?

What should we hold the feet of our elected officials to?

anyhow.. without data.. understanding the problem.. is a tough deal...

kcw said...

People are committing to hybrids without data. Everyone just 'assumes' it makes sense because it impacts their wallet. Do they really know the environmental impact? No.

Think beyond cars, think battery production & recycling...do you think the big truck coming to haul the batteries away is a super efficient? No but in reality those logistics, beyond just materials, contribute to the environmental impact of a system.

The energy companies say the grid can handle plug-ins. Sure when everything is fine. I'd love to see California after an earthquake with no power to move their vehicles around...hell during a fun heat wave with rolling blackouts. I get enough power outages from storms to convince me to never buy an electric vehicle.

Total picture is never looked at.

You can't look at downstream nutrient data from the past as the dam used to be there. It isn't. That changes the dynamics of the river and the flow of water/chemicals/etc. Now if your looking for just data with little reality, just to sway people who aren't experts, then go ahead...but I'd stop digging for info that isn't scientific.

I honestly think you don't need data beyond cost savings. Porous concrete/asphalt may result in smaller drainage basins...increasing usable land to build taxable buildings. Perhaps? Take the environment out of the equation.

Bryan said...

KCW - you hit on a topic that I've actually done a fair amount of research on - Hybrid Vehicles. See my posts here, here, and here.

The Hybrid industry is doing it's part for recycling those batteries. And the current generation of hybrids is developing a demand that will drive research into more efficient and environmentally friendly lithium-ion batteries (need to fix the fire problem known to laptop users - that should come with better mfg tech, and safety interlocks in the design).
http://www.hybridcars.com/battery-toxicity.html

I was in the market for a NEW vehicle to replace a close to dead Durango. I eventually ended on the Ford Escape (Mercury Mariner). Look at what they have done - a hybrid SUV that gets 29-35 mpg, while using soy foam, and purchasing carbon credits to offset manufacturing. In return, I get a hybrid vehicle that gets better gas mileage than any other SUV, while being a "Super Ultra Low Emission Vehicle" according to the EPA.

Costs? I didn't pay any more than a normal SUV in the same class after negotiating with the dealer and applying the tax credit. What about without the tax credit? Look at what I'll save in fuel in a year. What about battery replacement? My Durango had 136k and needed serious engine and trans seal work done, in addition to other mechanical wear, probably competitive at least.

Batteries will be recycled, and hopefully better tech will be available by then.

Plus the hybrid market today is driving demand for higher economy vehicles - hybrid or not.

Hm - this would be a good post. I'll think about putting it in a better more detailed article.

Larry G said...

doing the "numbers" on hybrids is the same as doing the "numbers" on nutrients.

In both cases, you need some basic data in order to make some intelligent judgments.

but I think we have a misunderstanding about dams.

A dam does not hold back nutrients.

Nutrients are water-soluble and actually it is this fact that makes them a problem.

yes... there are nutrients in sediment... but they are not the ones that cause the problems downstream.

besides... if you actually had the historical data UPSTREAM of Fredericksburg and DOWNSTREAM of Fredericksburg - you'd know this anyhow.

it's the LACK of data.. combined with the idea of making decisions about what to do (or not do) that is the problem.

we ought not to be making decisions, especially ones that involve a lot of money (whether it be for nutrients or hybrids) unless we know the data.

Bryan.. demonstrated this.. by doing the research necessary to support his decision...for the SUV.

How do we make similarly intelligent decisions about nutrients and storm water?

I'm not opposed to trying to do "more" for the environment but I think it is enormously better if we know what we are talking about.

For instance, what would be the difference in runoff from a normal 5 acre asphalt parking lot than a 5 acre porous paving lot?

what would be the nutrient load of the asphalt lot and what would be the nutrient load of the porous paving lot?

It is information/data/facts like this - that could make a difference at a public hearing.. say for Kalahari.. where folks were advocating for higher parking lot standards....to reduce runoff.

and .. this could be the start of stricter standards across the region - supported by citizens.. who then knew.. that meaningful reductions would be the result of stricter standards.

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