Immoral Fire Contracting?

Today’s Idaho Statesman investigates the death of a 65-year-old dozer operator who was contracted to help fight a wildfire near Kamiah (click on “Satellite” in upper-right to get nice post-burn imagery of this 2013 fire).

Had the dozer operator been a BLM-employed firefighter, he would have to take and pass an annual fitness test and fill out a health questionnaire. He would also have to have been no more than 57 years old. [Note, as reported by the Statesman, early news reports on his death state he was in his young 50s -- slip of the tongue?].

What compelling reasons justify two different fitness & age criteria for wildland firefighters? Are we less concerned about the health and welfare of contracted firefighters?

I had my say in the Statesman article; now it’s your turn.

PS: Here’s the Idaho/BLM fire fatality investigation report.

Spirituality, Ethics and Natural Resources I

Vision of the Earth Hildegard of Bingen (1098-1179)

Vision of the Earth Hildegard of Bingen (1098-1179)

It’s hard to believe that I didn’t put Bob Berwyn up to this.. but Spirit moves in mysterious ways, especially where this blog is concerned.

Anyway, Bob sent me a message with three questions about this yesterday and wanted to hear from you all in NCFP-land.. I’m going to take each of questions and make a separate post since I think they build on each other. But this whole topic is fundamental to the discussions and perhaps the disagreements we have, and it should be fun to dive in and see where we go.

I’ll start with his first question and my thoughts to kick it off.

Question 1. Are there any spiritual values associated with natural resource management?
If not, should there be?

Yes, there are many spiritual values associated with natural resource management.

A major spiritual value is that we are all one.. connected and connected to a Higher Power (no, not the WTO). This is basic in our nature traditions, in many religions and certainly in Christianity. So I am Matthew and Matthew is Gil and that Best Ferret Forever, and the prairie dog it is eating, and the ticks on the prairie dog, and the viruses on the ticks on the prairie dog, and we are all a part of God and God is a part of all of us (this is a simplification, if you are interested in a theological morass, check out Wikipedia on panentheism here).

A second value, related to the first, is compassion and love. As mushy as this sounds. For people who want their homes protected from wildfires, for fish, for people working in fire suppression, for wolverines, for loggers. Natural resource management has tended to be run by a male-dominated culture (let’s be frank here) so this probably will not be articulated in quite the same way (love) in most of the natural resources literature ;).

There are others.. justice, for example. But take, Jesus for example, if we used KISS theology (thanks, Andy), it’s always about loving your neighbor. And your neighbor can include creatures other than humans.

Spiritual values slide over into ethics, so here are my Ethics and Natural Resource Management Helpful Hints (from when I taught Environmental Ethics at Virginia Tech).

1. Ethics is (are) not a sledgehammer to be used to attack people when you disagree with them. This violates the principle of compassion. I have seen this way too often as a drive-by attack. One reason I decided to learn about it was that, in my experience, people can use it to justify things that don’t make sense on any rational or other basis. And if they’re academics, they can wrap it in a cloak of impenetrable verbiage, but it still doesn’t make sense.

2. Ethical discussions about NRM need to take into account the environment AND people. At the same time. Otherwise, frankly, it’s not very helpful and separates (what Gaia has joined together, let no ethicist put asunder ;)). I think that’s one of the reasons that academic environmental ethics can make practitioners’ eyes glaze over.

3. If you look at the literature, you will find lots of talk about the below values in a) but very little about those in b) and c). I don’t know why. Except that perhaps people who spend their time analyzing can imagine outcomes ,but not so much the details of how these things come about.

a) There are spiritual values associated with outcomes on the land..positives and negatives for different species including humans.

b) There are spiritual values associated with how decisions are made (for example, whose voices are heard?)

c) There are values associated with treating people well who do the work on the land, people in the office, and people who use the land and care about it, and of course people who live in communities on the land.

So there is Bob’s first question and my responses.. your thoughts?

Precautionary Principle: Applications to Forest Management?

The term “precautionary principle” has been kicked around a little here, but here’s another perspective. First, DellaSala’s quote that “With the precautionary principle, the agency has the burden of proof to demonstrate it’s not harmful” is not at all being “sloppy about science”, it’s exactly consistent with how the term is used in legal and policy contexts. The expression “first do no harm” (which comes from the physicians’ Hippocratic oath) is quite different from the precutionary principle. The quote that Jon found regarding “Despite U.S. acceptance of the precautionary principle in international treaties and other statements…” actually sugarcoats U.S. policy on the precautionary principle, especially in the arena where it has been most prominent, which is international regulation of biotechnology. The U.S. actively opposed the precautionary principle there, to the extent that we still are not parties to the Cartagena protocol where it arose.

Down below, though no one asked for it, is an excerpt from a law review article I wrote a couple years ago about the precautionary principle (and other things), in the context of pest control and biotechnology. Lots of good references in the footnotes.

But whether you wade through the article or not, I think it’s interesting how the PP, most commonly expressed as “Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation,” offers perspectives on forest policy. I would note that it’s not necessarily a so-called “enviro” perspective: for example, aggressive forest thinning in the hopes of reducing future risks of wildfires would be a very good example of the PP at work.

A common metaphor for the PP goes something like, if you’re driving down the road and you think the bridge may be out ahead, do you apply the brakes before you know for sure, or do you wait for proof (when it may be too late). The answer seems like common sense, but what if you’re delivering an urgent package and any delay would be very costly? Applying the brakes will cost you money. Then it becomes a value judgement that relates to how you handle risk. I think there are lots of interesting analogies in forest management.

From: Guy R. Knudsen, Where’s the Beef? How Science Informs GMO Regulation and Litigation, 48 IDAHO L. REV. 225 (2012)  

full text here:


International concerns about the transnational movement of the products of biotechnology, and possible adverse effects on biodiversity, were first addressed, although briefly, in the context of the Convention of Biological Diversity (CBD), adopted in Rio de Janeiro in 1992.102 The CBD requires Parties to “[e]stablish or maintain means to regulate, manage or control the risks associated with the use and release of living modified organisms resulting from biotechnology,” which pose the threat of adverse environmental impacts that could affect biological diversity or present risks to human health (the term “living modified organism” (LMO) is essentially synonymous with “GMO,” except that GMO is sometimes used to refer to nonliving bulk commodities of recombinant origin.103 Here, the two terms will be used interchangeably and restrict-ed to living organisms that are released into the environment and which are potentially capable of growth and reproduction).104 The CBD also requires that Parties consider the need and appropriate form of “protocol setting out appropriate procedures, including advance informed agreement, in the field of the safe transfer, handling, and use of any living modified organism resulting from biotechnology that may have ad-verse effect on the conservation and sustainable use of biological diversi-ty.”105

Thus, in the biodiversity protection context, the CBD distinguishes LMOs from other organisms on the basis of their origin in recombinant DNA technology, rather than on any potentially invasive or otherwise harmful characteristics of the organisms themselves. This focus on the recombinant nature of organisms, rather than more generally on their potential for invasiveness or other biodiversity-harmful traits, was carried forward into the Cartagena Protocol, which took effect on Septem-ber 11, 2003.106 The United States has signed, but not ratified the Convention on Biological Diversity, and thus is not a party to the Cartagena Protocol. Nonetheless, the United States played a significant role as an initial advocate of the latter instrument. The Cartagena Protocol’s objec-tive is to facilitate the safe importation and use of LMOs. Organisms that the Cartagena Protocol covers include genetically engineered plants, animals, and microorganisms that cross international borders.107

The primary goal of the Cartagena Protocol is to minimize adverse effects on biodiversity, including possible risks to human health, without unnecessarily disrupting world food trade.108 The Protocol imposes different levels of stringency depending on the intended use of a particu-lar LMO. For those that will be directly used as food or feed or for processing, only a relatively simple information procedure is required.109 For LMOs intended for introduction into the environment of the importing state, the Protocol requires an Advanced Informed Agreement (AIA) prior to the first transboundary movement of the organism. Components of the AIA include notification and an exchange of information between the exporting and importing countries.110

The Cartagena Protocol adheres to the precautionary principle or “precautionary approach” first delineated in the Rio Declaration on En-vironment and Development.111 The most commonly expressed version of the precautionary principle is: “Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”112 As applicable to the Cartagena Protocol, the precautionary principle provides that lack of scientific certainty about the extent of potential adverse effects shall not prevent a party, typically the importing State, from deciding not to allow LMO imports. Proponents of this approach included a number of developing nations who expressed fears that “a major loss of biodiversity” could result “from a replacement of traditional farming methods by genetically engineered crops.”113 Their views were echoed by environmental non-governmental organizations present at Cartagena including Greenpeace and the Worldwide Fund for Nature.114

The decision to follow the precautionary approach was conten-tious.115 During the development of the Cartagena Protocol, the U.S., although initially a state sponsor of the process, lobbied unsuccessfully for adoption of a less restrictive “scientific evidence standard,” alternatively known as the “sound scientific knowledge” basis.116 The scientific evidence standard is consistent with that found in the World Trade Organization Agreement on the Application of Sanitary and Phytosanitary Measures; the latter is relevant to alien species characterized as pests or pathogens, to the extent that measures to manage these species affect international trade.117 WTO member states may adopt national measures to protect human, animal, or plant health / life from risks arising from the entry, establishment or spread of pests, diseases, or disease-causing organisms and to “prevent or limit other damage” with-in its territory from these causes.118

The scientific evidence standard essentially requires that confirmed scientific evidence of harm be present prior to banning the import of a LMO. In this effort, the U.S. was joined by a number of other countries (the so-called “Miami Group,” whose other members were Argentina, Australia, Canada, Chile, China, and Uruguay), and was bolstered by support from the U.S. biotech industry. The motivation for the U.S. to first champion, but then abandon, the Cartagena Protocol has been de-bated. Keleman and Vogel pointed out that governments are more likely to support international environmental agreements when those agreements provide advantages to domestic producers in international com-petition, and tend to oppose such agreements when the costs of compliance put domestic firms at a competitive disadvantage.119 From this per-spective, early U.S. enthusiasm for a biotechnology protocol might be viewed as a preemptive attempt to occupy the regulatory field, in which a weak protocol would effectively codify a more laissez-faire approach to international regulation of biotechnology, to the advantage of U.S. producers. However, as a major biotech-exporting country with anti-biotech litigation an ongoing feature in its courts,120 the United States apparent-ly was concerned that inclusion of the precautionary principle as a fun-damental tenet of the Cartagena Protocol could have a chilling effect on exports. Some observers believed that the Miami Group’s strategy was to maintain exports of GMO commodities without the hindrance of in-formation, documentation, or a chance for informed decision-making by importing countries.121 Allegedly, “frustrated delegates from the develop-ing world” were heard to complain that “the negotiations at Cartagena were on ‘Biotrade’ not Biosafety.”122

Arguably, the term “scientific evidence standard” is misleading, since both the precautionary principle and the scientific evidence stand-ard involve risk management approaches in the face of uncertainty, and neither is fundamentally more “scientific” than the other. In one sense, the conflict involves differing approaches to the rate of technological transfer: the position of the United States favors a “rapid rate of technological transfer,” while Europe generally advocates a “slow[er] and [more] cautious rate.”123 These conflicting approaches may also be analyzed in the context of the burdens of proof that they require. The pre-cautionary principle places the burden of proving that GM products do not pose a threat to human health or the environment on the developers of the products,124 whereas the so-called scientific evidence standard places the burden of proving that the GM product presents a significant and quantifiable risk to health or the environment on those opposing the product’s introduction.

Ahteensuu observed that in quantitative risk assessment, which he considered “the prevailing institutionalized risk governance methodology,” conclusive scientific proof has generally been used as the “prerequisite for taking preventative measures.”125 However, in numerous instances there have been early indications of environmental damage be-fore it materialized or fulfilled the strict criteria for scientific acceptance, so that taking no precaution in the state of uncertainty resulted in serious adverse consequences.126 Conversely, the scientific evidence standard places the burden of proof on those who would oppose the in-troduction or deployment of GM crops or other GM organisms. Cranor notes that the scientific tradition (e.g., the use of statistical confidence limits) “strongly and asymmetrically” protects against false positive errors; for example, inferential procedures that show health or environ-mental risks when there are none.127 This standard contrasts with that used in tort law, where the prevailing view is that “legal false positives (i.e., mistakenly deciding for plaintiffs) should be approximately equal to legal false negatives (i.e., mistakenly deciding for defendants).”128

Thus, a cultural gap arises between science and law concerning the standards of proof required within each culture. Uncertainty raises “a substantial barrier for the party with the burden of proof,”129 so that it’s hardly surprising that proponents and opponents of GM crops each lobby for a different evaluation regime. The culture of science is not necessarily helpful at resolving these differences. As Cranor notes, science is open-ended, with even comparatively settled conclusions being open to revision, so that “scientists ordinarily assert their views with considerable uncertainty even [when] their personal beliefs may be stronger.”130

102. United Nations Conference on Environment and Development: Convention on Biological Diversity, opened for signature June 5, 1992, 31 I.L.M. 818.

103. Id. at art. 8(g).

104. Id.

105. Id. at art. 19(3).

106. Cartagena Protocol on Biosafety to the Convention on Biological Diversity, adopted on Jan. 29, 2000, 39 I.L.M. 1027 (entered into force Sept. 11, 2003),

107. Id.

108. See generally id. at arts. 1, 2.

109. Id. at 1031–32.

110. Id. at 1030–33.

111. United Nations Conference on Environment and Development, Rio de Janiero, Braz., June 3–14, 1992, Rio Declaration on Environment and Development, U.N. Doc. A/CONF.151/26 (Vol. I), Annex I, Principle 15 (Aug. 12, 1992).

112. Id.

113. See Lavanya Rajamani, The Cartagena Protocol—A Battle Over Trade or Bi-osafety?, THIRD WORLD NETWORK, (last vis-ited on Nov. 3, 2011).

114. Id.


116. See Rafe Pomerance, The Biosafety Protocol: Cartagena and Beyond, 8 N.Y.U. ENVTL. L. J. 614, 618–20 (2000).

117. The WTO Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement), WORLD TRADE ORG., Article 2(2), (last visited Oct. 25, 2011); id. at Annex A.

118. Id. at Annex A.

119. R. Daniel Kelemen & David Vogel, Trading Places: The Role of the United States and the European Union in International Environmental Politics, 43 COMP. POL. STUD. 427, 444–50 (2009).

120. See Knudsen, supra note 69, at 5.

121. Rajamani, supra note 107.

122. Id.

123. See Dane Scott, Perspectives on Precaution: The Role of Policymakers in Deal-ing with the Uncertainties of Agricultural Biotechnology, 5 INT’L J. OF GLOBAL ENVTL. ISSUES 10 (2005).

124. Id. at 12, 23–25.

125. Marko Ahteensuu, Defending the Precautionary Principle Against Three Criticisms, 11 TRAMES 366, 378 (2007).


127. Carl F. Cranor, Daubert and the Acceptability of Legal Decisions, 5 J. PHIL., SCI., & LAW 1, 2, May 2005,

128. Id. (italics in original).

129. Id.

130. Id. at 2–3.


More Rim Fire Pictures

All too often, once a firestorm goes cold, a fickle public thinks the disaster is over with, as the skies clear of smoke. In the situation of the Rim Fire, the public hasn’t had much chance to see the real damages within the fire’s perimeter. All back roads have been closed since the fire was ignited. Besides Highway 120, only Evergreen Road has been opened to the public, within the Stanislaus National Forest.

From my April trip to Yosemite, and Evergreen Road, this unthinned stand burned pretty hot. This would have been a good one where merchantable logs could be traded for small tree removal and biomass. Notice the lack of organic matter in the soil.


Sometimes people say there is no proof that thinning mitigates fire behavior. It’s pretty clear to me that this stand was too dense and primed for a devastating crown fire. I’m guessing that its proximity to Yosemite National Park and Camp Mather, as well as the views from Evergreen Road have made this area into a “Park buffer”. Now, it becomes a “scenic burn zone”, for at least the next few decades.


There is some private land along Evergreen Road, which seem to have done OK, at least in this view. Those mountains are within Yosemite National Park. Sadly, the media likes to talk about “reduced burn intensities, due to different management techniques”, within Yosemite National Park. Only a very tiny percentage of the National Park lands within the Rim Fire have had ANY kind of management. Much of the southeastern boundary of the fire butts up against the Big Meadow Fire, generally along the Tioga Pass Road (Highway 120). Additionally, much of the burned Yosemite lands are higher in elevation, as well as having larger trees with thicker bark. You can also see that there will be no lack of snags for the blackbacked woodpecker. Can anyone say, with scientific sincerity, that over-providing six years of BBW habitat will result in a significant bump in birds populations? The question is really a moot point, since the Yosemite acreage, alone, does just that.


People have, and will continue to compare the Yosemite portion of the Rim Fire to the Stanislaus National Forest portion, pointing at management techniques and burn intensities. IMHO, very little of those comparisons are really valid. Apples versus oranges. Most of the Forest Service portion of the fire is re-burn, and there is no valid Yosemite comparison (other than the 2007 Big Meadow Fire). It has been a few months since I have been up there, and I expect that there are plenty of bark beetles flying, and the trees around here have no defense against them, with this persistent drought. Everything is in motion and “whatever happens” is happening.

Scientist vs. Scientist: Compassionate Conservation


Well, it didn’t take too long to find an article where scientists seem to be disagreeing. I was surprised to find this point of view stated as fact (of course it is an op-ed) by a scientist from the Western U.S. Here is a link to the article in New Scientist. If you can’t see the article as a non-subscriber, make a comment below to that effect, and I will copy it.

Biologists are also re-evaluating the merits of reintroduction projects. The reintroduction of wolves into Yellowstone National Park, for example, resulted in numerous wolves dying or being killed “for the good of other wolves”. The surviving wolves also lack protection, especially when they leave the park. As a result, scientists are concerned that the project is failing.

Other reintroduction projects are being similarly reappraised. A team at the University of Oxford assessed 199 such programmes and found potential welfare issues in two-thirds of them, the most common being mortality, disease and conflict with humans.

Hmm. “scientists are concerned that the project is failing?”

But this one made me wonder..

Compassionate conservation is also changing the way researchers tag animals. This is an integral part of conservation as it enables scientists to identify individuals and estimate population sizes. But it is often harmful or painful and can reduce the animals’ fitness, which compromises the usefulness of the data collected. More researchers are now using methods that don’t stress animals or alter their behaviour, such as unobtrusive tags or remote camera traps.

Compassion for animals isn’t incompatible with preserving biodiversity and doing the best science possible. In fact, it is a must. Mistreatment of animals often produces poor conservation outcomes and bad science. It is also immoral.

I always find it fascinating when people say “you should believe what I tell you because I’m an expert (scientist)” and then move on to a field that they’re not an expert in, in this case, morality. I think reasonable people could disagree that wolf reintroduction was “immoral.”

Given our discussion of the precautionary principle, maybe people should stop studying endangered species until they can prove their methodologies don’t reduce the fitness of individuals ;)..of course to study that you’d have to risk hurting them..complicated, no?

Conservation Biologists Urged to Get More Political

Thanks to a Montanan who sent this link to a Missoulian article entitled “Conservation biologists must take message to politicians, experts say at UM.”

The weeklong gathering has brought scientists, policymakers and journalists from around the world to the University of Montana. While much of the gathering is focused on the latest scientific discipline discoveries, this year’s agenda also features many discussions about getting more science to the general public.

Dominick DellaSala, president and chief scientist of the Geos Institute in Ashland, Oregon, argued that even different political camps can end up following the same policy aims. He said that while the George W. Bush administration caught fire for recommending logging and thinning in spotted owl habitat with little evidence that would help the bird, the Obama administration has pursued a very similar policy.

“The thinning goes forward even though the science says, ‘Wait a minute,’ ” DellaSala said. “With the precautionary principle, the agency has the burden of proof to demonstrate it’s not harmful.”

Based on these quotes, the folks there seem to be pretty sloppy about what is “science.” For example, the precautionary principle is not science, it’s an idea or value. I don’t believe that particular idea is enshrined in law but others can help with that.

Here are some more:

But that’s going to take a higher level of commitment and organization than most scientists are willing to assume, said David Johns, a professor of politics and law at Portland State University and co-founder of the Yellowstone-to-Yukon Conservation Initiative.

“Conservationists have abandoned grassroots organizing,” Johns said. “It’s mostly check-writers supporting professional staff. But when you’re only playing the inside game, you can’t match the resources of our opponents.”

U.S. Fish and Wildlife Service Director Dan Ashe said managing people is much harder than managing wildlife, especially where science is involved. When people “stack facts based on beliefs,” to make political decisions, it becomes extremely hard for scientific evidence to persuade someone to change an opinion.

Ah.. it sounds like conservation “ists” and “biologists” are the same folks.. but “science” is supposed to be objective (or not..). Even Director Ashe as quoted seems to believe that “science” should drive political decisions.

The curious thing about this is that everyone knows that scientists in the real world do have different values and do disagree about things.. in fact, science is supposed to be open and transparent. Plus our government if supposed to be “of the people” not “of the scientists.”

And politicians get that .. that’s why you see scientists of all persuasions testifying at hearings.

Active Management


Yesterday was my annual pilgrimage to speak at the Siuslaw Watershed Council’s summer camp for middle and higher school-age kids. I was to meet the group at the Forest Service’s Fivemile-Bell project, about which I’d read a lot but never seen.

It looked simple enough to find, tucked just east of Tahkenitch Lake near the Pacific Ocean. I’m geographically-challenged in the woods and the directions were a bit vague (“After you turn left from hwy 101 on Five Mile Road (I forget the actual mileage), you will go past Thakenitch Lake. You’ll get to the bottom of a valley, go past a house and small wetlands on your left and before you go back up the hill, there will be a white fence and then a gate on your right. That’s us.“). It didn’t help matters that I blithely went “back up the hill,” (30% grades) for several miles before realizing my error and backtracking. Having given myself an extra half-hour, I was more-or-less on time. The kids and I chatted about owls, salmon and national forest tree thinning.

About ten years ago, the Forest Service bought the 640-acre cattle and hay homestead along Fivemile and Bell creeks to restore coho habitat. Its plans are ambitious. Some old dikes have been removed. Invasive plants are being treated with Glyphosate, mowing and excavation (canary reed grass makes a deep mat that is a bitch to remove). While there, I saw a log loader putting some alder and fir logs into a small tributary creek.

The general landscape is intensively managed and drop-dead gorgeous.

The Deer Decline in Colorado

mule deer
Given that I moved from the east coast where there are too many deer, who seem to be getting along with housing development, I thought this Denver Post article was interesting.

Below is an excerpt:

In Colorado, the latest CPW population estimates, provided in response to Denver Post queries, show a statewide decline in mule deer — the main deer in the West — down to 390,600 in 2013 from 614,100 in 2005.

Some of the decline may be because of changes in methods for estimating deer populations.

Across western states, deer decreased by about 10 percent overall between 2003 and 2009, said Arizona-based wildlife biologist Jim Heffelfinger, who chairs the Western Association of Fish and Wildlife Agencies’ Mule Deer Working Group, which draws expertise from 23 states and Canadian provinces.

Deer aren’t likely to join polar bears facing extinction, but the sharp downward trend requires concerted human action, Heffelfinger said.

“We certainly cannot have it all. We need to be smart about our wildlife habitat, especially our mule deer habitat and how we manage the population,” Heffelfinger said. “There are so many different things that are stressing mule deer around the West. Fire suppression has closed the forest canopies, and that has reduced the amount of shrubs and weeds that deer rely on.

“You don’t really like big, catastrophic fires — certainly where human structures are damaged. But we really need to open up the canopies for deer.”

It’s interesting the lengthy list that they came up with for possible causes..

Colorado-based wildlife biologists have pinpointed multiple factors driving deer declines:

• a one-two punch of hard winters followed by drought;

• commercial and residential development in the mountains;
Mule deer make their way across the fencing in an area of the Rocky Mountain Arsenal.
Mule deer make their way across the fencing in an area of the Rocky Mountain Arsenal. (Kathryn Scott Osler, Denver Post file)

• chronic wasting disease;

• aggressive fire suppression that leads to overly thick forests;

• coyote and mountain lion predation;

• more than 2,000 vehicle collisions a year in western Colorado;

• energy development that disrupts deer habitat and migration.

In response to the multi-year decline, Colorado wildlife managers have reduced the number of deer hunting licenses they offer from 130,106 in 2007 to about 80,000 for this year.

Hunters in Colorado kill 35,000 to 40,000 deer a year, said Chad Bishop, CPW assistant director for wildlife natural resources.

As well as the “change in method of estimation.” I’d be interested in hearing what other states think. Seems like if the reduction is westwide, all the possible factors would have different levels of occurrence in different states.