Skeptophilia (skep-to-fil-i-a) (n.) - the love of logical thought, skepticism, and thinking critically. Being an exploration of the applications of skeptical thinking to the world at large, with periodic excursions into linguistics, music, politics, cryptozoology, and why people keep seeing the face of Jesus on grilled cheese sandwiches.
Showing posts with label Crestwood Midstream. Show all posts
Showing posts with label Crestwood Midstream. Show all posts

Saturday, July 14, 2018

David 1, Goliath 0

There's been so much bad news lately that I've several times felt like I needed to avoid all forms of media not to go into a full-blown, crashing depression.

It's hard to escape the conclusion that we're in a downward spiral.  Our leadership is the most corrupt, dishonest, self-serving bunch of politicians that I can remember, and I'm 57 years old.  The driving force in our government at the moment is corporate interests über alles.  We're progressively alienating all of our allies, disregarding science, passing legislation that trashes the environment, and in general paying attention to nothing but short-term expediency and lining the pockets of the already-wealthy.

So today, I want to tell you about some good news.

Long-time readers of Skeptophilia might recall that over the last five years, I've become involved in a fight right here in my home county against storing liquified petroleum gas (LPG) in unstable salt caverns beneath Seneca Lake.  Salt cavern storage has been tried before, with disastrous consequences.  Explosions, collapses, and contamination of rivers and streams have been documented over and over, and here in New York, the county and state governments seemed bound and determined to ignore what the geologists were saying -- that the caverns underneath the lake were unstable on a huge scale, and that only fifty years ago there'd been a humongous ceiling collapse that, if the caverns had been filled with natural gas, would have caused a massive explosion, followed by the southern end of the lake becoming so saline that it would no longer be usable as a source of drinking and agricultural water.

We not only live in an area of great natural beauty, but the Seneca Lake wineries and farms are a huge money-maker for residents in the area.  Risking this for no good reason other than putting money in the pocket of Crestwood Midstream -- a Texas-based petroleum company -- makes no sense whatsoever.

So a lot of us began protesting.  At first, with letter-writing campaigns and often fiery debate in town, county, and state-level meetings.  Dr. Sandra Steingraber, a local resident and highly acclaimed ecologist, writer, and activist, became one of the most determined opponents of Crestwood's plan, and was tireless in her efforts to block the project.  The low-key methods had no effect, however, and so we were forced to kick it up a notch.  We organized blockades of Crestwood's Seneca Lake site -- resulting in hundreds of us being arrested, and a number were sent to jail.

I was one of the ones arrested -- although I was never jailed.  I had three court appearances, and the charges were eventually dropped.

[Photograph by Carol Bloomgarden; used with permission]

The protests and civil disobedience stretched out over years.  But eventually, people started to listen.

And just last week, the New York State Department of Environmental Conservation unanimously voted to kill Crestwood's plan to store LPG underneath Seneca Lake.

Basil Seggos, commissioner of the DEC, was unequivocal.  "The record is compelling that the permitting this proposed gas storage facility on the western side of Seneca Lake is inconsistent with the character of the local and regional Finger Lakes community," Seggos said, as part of his 29-page decision.

"This is truly a great day for our region,” said Yvonne Taylor, vice president of Gas Free Seneca, which formed seven years ago to combat the project.  "Don’t ever let anyone tell you that David can’t beat Goliath."

Look, I know we need energy, and that a switch to renewables can't happen overnight.  But continuing to support fossil fuels -- with its history of pollution and fostering climate change, not to mention spills, explosions, and fires -- is simply unconscionable.  We should be finding ways to cut back on fossil fuel use by becoming more efficient and looking for clean energy sources -- not foisting expanded storage on a community whose residents either didn't want the project or didn't understand its dangers.

So this is one win for the little guy, and a ray of hope in what has been a very, very dark time in our nation.  At least in our neighborhood, scientific research and plain good sense triumphed over corporate interests.

Which should be encouraging to others fighting in the hundreds of other David-versus-Goliath scenarios currently being played out.  You can win.  But only if you're determined to put yourself on the front lines -- and never, ever give up.

**********************************

The Skeptophilia book-of-the-week for this week is Brian Greene's The Fabric of the Cosmos.  If you've always wondered about such abstruse topics as quantum mechanics and Schrödinger's Cat and the General Theory of Relativity, but have been put off by the difficulty of the topic, this book is for you.  Greene has written an eloquent, lucid, mind-blowing description of some of the most counterintuitive discoveries of modern physics -- and all at a level the average layperson can comprehend.  It's a wild ride -- and a fun read.





Wednesday, May 18, 2016

The price of precaution

There's a fundamental idea in ecology called the precautionary principle.  Put simply, the precautionary principle says that it's always easier and cheaper to prevent environmental damage than it is to clean up the mess afterwards.

Note that this is not saying we can predict and prevent every disaster.  Mother Nature has a mean curve ball.  But there are all too many instances of the powers-that-be hearing, acknowledging, and then ignoring the advice of the scientists and other experts, with devastating results.

Let's look at a quick example before I tell you what this post is really about.

The Everglades were once a sawgrass, cypress, mangrove, and palmetto wetland encompassing most of the southern tip of Florida.  Through this wetland flowed a 100 kilometer wide sheet of water slowly making its way to the Gulf of Mexico and the Atlantic Ocean.  The wetland acted as a natural filter, and the water entering the sea was remarkably pure and sediment-free.  The area was home to hundreds of native species, some found nowhere else on Earth, and hundreds more used it as a stopover point on migration.

The Everglades [image courtesy of the Wikimedia Commons]

The problem is, you can't raise cattle, grow oranges, or build houses in a wetland.  So in the first few decades of the 20th century, the Everglades were "improved" -- that is, turned into a patchwork of swamp with 2250 kilometers of canals, levees, and spillways designed to drain land for settlement.  The 160 kilometer long Kissimmee River was “straightened” by the Army Corps of Engineers for flood control; it’s now 84 kilometers long and has drained the wetlands north of Lake Okeechobee, which farmers turned into cow pastures.

In 1947, ecologists saw what was happening, and lobbied for protection.  In that year the founding of Everglades National Park attempted to conserve part of it, but you can't draw an arbitrary line around a piece of land and assume that what happens outside the line won't matter.  Continued development progressively cut off the water flow to the wetland, and in the following years between 75% and 90% of the park’s wildlife (depending on how you count the toll) disappeared.

Fast forward to 1990, when finally the Florida state government took notice -- prompted not by the recognition that Everglades National Park is one of the most damaged national parks in the United States, but because without the wetland, farmers and landowners were beginning to see problems.  The Everglades acted as a water catchment, and its reduced size caused a loss of fresh groundwater.  Not only did this compromise agriculture, it led to saline intrusion into wells, and the opening up of limestone sinkholes -- some big enough to swallow houses.  The sediment and fertilizer runoff that was once filtered by the marsh was now being ejected into the Gulf of Mexico and the Atlantic Ocean, killing fish, fouling coral reefs, and clouding the water.

The result was that in the late 1990s the government of Florida reluctantly agreed to the world’s largest ecological restoration project, to be carried out between 2000 and 2038.  It plans to restore the Kissimmee River to its original course, buying up farmland and creating new wetlands for both wildlife habitat and to filter agricultural runoff, and to create 18 large reservoirs to supply drinking water and slow down freshwater diversion.

At a cost to taxpayers of $7.8 billion.  To, if I haven't hammered in this point strongly enough, undo everything that we've done in the past eighty years, and return things back to where they would have been if we hadn't screwed them up royally in the first place.

This all comes up because two days ago, Crestwood Midstream, the company that is planning to expand natural gas storage in salt caverns underneath Seneca Lake, received a last-minute two year extension from the Federal Energy Regulatory Commission on their rights to use the site.  It had been hoped that FERC would come to their senses and deny the permit, but whether money talked or the officials at FERC simply shrugged and said, "Well, nothing bad has happened yet," they chose to allow the Texas-based company to continue in this reckless and irresponsible practice.

Seneca Lake [image courtesy of the Wikimedia Commons]

Just how reckless and irresponsible are we talking about, here?  All it should take is one statistic to convince you: salt cavern storage accounts for only 7% of the total underground storage of natural gas in the United States, but was responsible for 100% of the catastrophic accidents from natural gas storage that resulted in loss of life.  

A major accident here in the form of a cavern breach wouldn't just endanger the workers at Crestwood Midstream's facility in the Town of Reading; it would result in the salinization of the south end of Seneca Lake, one of the largest freshwater lakes in the Northeast, and the source of drinking water and water for irrigation for tens of thousands.  It would imperil the Finger Lakes wine industry, one of the biggest sources of revenue and tourism in the area.

Worst still, it would be damn near impossible to clean up.  You think the bill for wrecking the Everglades was high?  That's nothing compared to what it would take to rectify a salt cavern collapse and the resulting explosion.  If it was remediable at all.

And how likely is this?  Is this simply a panicked overreaction?  Another fact might clarify: a mere fifty years ago, a 400,000 ton chunk of the roof of one of the very salt caverns Crestwood is proposing to use caved in.

Imagine what the result would have been had the cavern been filled with natural gas.

Put simply, the precautionary principle isn't alarmism.  Oddly enough, we have no problem with the idea with respect to our homes, health, and lives; why it's so hard for people to swallow with respect to the planet we live on is incomprehensible to me.

And for a government regulatory commission like FERC to give Crestwood carte blanche to proceed with this potentially devastating plan is the height of irresponsibility.

Friday, May 15, 2015

Ethical lawbreaking

One of the topics we discuss in my Critical Thinking class is when taking a stand on an ethical issue trumps law.

Civil disobedience, in other words, crossing the line into potential arrest and prosecution.

I ask this question because two days ago, I was arrested for being part of a blockade of Crestwood Midstream's natural gas and (proposed) liquefied petroleum gas storage facility alongside Seneca Lake.  As I have described in previous posts, the facility uses geologically unstable salt caverns for this storage, risking catastrophic failure that would result in environmental devastation of the region and almost certainly loss of life.  The plan is, to put it simply, reckless and dangerous, driven by the profit motive of an out-of-state corporation that could simply up stakes and move back to Texas if the unthinkable happens.

We, on the other hand, live here and would have to deal with the consequences.

Yours truly being loaded into the police van after arrest [image courtesy of photographer Carol Bloomgarden]

The fact that Crestwood's plan is wildly irresponsible is not just fanciful or alarmist.  Dr. Robert Howarth, professor of ecology and environmental biology at Cornell University, had the following cautionary words:
The stakes are high.  Industry and government march blithely ahead, ignoring the growing risks of extreme energy development: deep offshore oil and gas, Arctic oil and gas, tar sands, shale gas… and the risky storage of methane and propane proposed for the salt caverns below us here.  We hit 400 ppm carbon dioxide this winter, for the first time in the past few million years; and another greenhouse gas -- methane -- is also at its highest level in the last several million years.  We are near the point of no return, where a much warmer Earth will be with us for the next several thousand years.
Schneising et al. showed in 2011 that the methane in the atmosphere is largely from shale gas and shale oil drilling.  The methane signature they found from this human activity is so large that it was visible from data obtained from satellites.  And methane has a hundred-fold higher impact on global temperature than carbon dioxide does -- making this enterprise even more foolhardy. 
So the impact of what Crestwood is doing here goes far beyond the local damage that a catastrophic mishap would cause.  Simply put, the fossil fuels need to stay in the ground.
And it's not as if there aren't solutions, solutions that could be put in place now if there was the will and the farsightedness to do so.  Howarth writes:
We already have the ability to make the switch to electric vehicles, and electric heat pumps for heating and cooling.  Their efficiencies are far greater than gasoline and diesel driven vehicles, or furnaces and water heaters than run on natural gas or fuel oil.  This would result in a 30% reduction in total use of energy, just from this transformation.  And that electricity should come from renewable sources.  Crestwood is placing our lives and our homes at risk, and moving us closer to global ecological disaster, because of a determination to keep using an energy source that should have been phased out decades ago. 
Switching to energy primarily from wind and from solar has a lower cost today than using fossil fuels, if the health costs of fossil fuels are considered.  In NY, there are 4,000 deaths each year from air pollution caused by fossil fuels, at a cost of $33 billion per year.

Making entire state free of fossil fuels costs $570 Billion. The cost savings from reduced illness and death from fossil fuels over the next fifteen years is enough to pay for the entire cost of the transition to renewables.
The "natural gas is about jobs" argument is equally specious.  Crestwood's projection of the number of jobs created for locals is outweighed fivefold by the jobs available in renewable energy in our region.  Joe Sliker, president of Renovus Solar Energy, said:
The solar industry complements the existing, thriving, and growing winery and tourism industries.  Solar is cleaner, safer, and a more prosperous path forth for families and even for all of the Crestwood employees. 
So, I'm here today for all of the good men and women who risk their lives every single day for their jobs.  I'm here for the welders, the pipe fitters, the electricians, the truckers, and all of the hard working people who go to work every day to provide for their families.  I'm here for those people who lay their lives on the line every morning when they wake up, for those people whose hands bleed while they work, and for the families that love and worry about them. 
I'm here to offer them a choice.  I'm here to tell them that we don't have to support a dangerous facility and risk our lives and the lives of our loved ones in order to have good paying jobs. 
I'm here to offer all of those people a better job.  Today.  Right now.  Our Renovus HR manager is here with a stack of applications.  Come talk to us. 
Solar is rapidly expanding and Renovus is a thriving regional business. In contrast to the eight to ten permanent jobs promised by the gas storage facility, Renovus has added over 50 new permanent jobs just in the past year.
Add it all up.  Crestwood Midstream, and other companies like them, put the lives and livelihood of ordinary people at risk for one reason; to boost their profits and pay their stockholders.  The alternatives are real and affordable and viable.  What is being proposed amounts to reckless endangerment, yet our local and state governments refuse to step in and stop it.

So it was time for me to act.

I know that my arrest, by itself, will have little effect.  I'll appear at court, and likely face a fine, and that will be that.  But the symbolism of people who are willing to risk prosecution for a worthy cause has a far greater reach than that; it is the actions of individuals that make the difference.  And that means all of us who know enough to care about what is happening.  As the amazing Australian singer/songwriter Judy Small put it in her song about social activism, "One Voice in the Crowd," "In the end it's all the same; the buck stops where you are."  (Listen to the whole song at the link below.)


So it's not about the futility of a few people standing up to the actions of a huge corporation.  It's about doing the right thing, and as Kenyan environmentalist Wangari Maathai put it, "Keeping our feeling of empowerment ahead of our feeling of despair."  It's about being willing to put yourself at risk, because the alternative is to accept blindly a far worse risk, one whose consequences may still be felt a thousand years from now.

We all need to act, and the time is now.

*****************

To support what is happening here, please "like" the We Are Seneca Lake Facebook page, write your congressperson and/or Governor Andrew Cuomo (here's his contact information), and share this post around.  This message needs to move, and quickly.

Friday, February 27, 2015

Civil disobedience as a moral imperative

Let me just say at the outset that I'm a law-abiding sort.  With the exception of getting pulled over twice for driving too fast, I've never had a single unpleasant run-in with the cops.  And both times I got caught speeding, I was able to argue my way out of a ticket.

While I'd like to think that my history of clean living is because I have a respect for authority and the rule of law, some of it is due to the simple fact that I hate complications and conflict.  If I come up to a stop sign in broad daylight, and it's clear that no oncoming car on either side is within a quarter-mile of the intersection, I'd rather stop, look both ways, and then go rather than run the stop sign and risk having a third opportunity to explain my actions to a cop.

But my question of the day is: are there times when deliberately, knowingly breaking the law is the right thing to do?

I'm talking, of course, about civil disobedience.  And in my opinion, sometimes putting your own legal record, safety, or (perhaps) life at risk to make a higher point is not only the right thing, it comes close to a moral imperative.

A 2010 sit-in in Budapest protesting forced evictions of the poor [image courtesy of the Wikimedia Commons]

The whole idea of breaking the law to bring attention to a greater wrong has been much on my mind lately, for two entirely different causes, both of which will be immediately evident to regular readers of this blog.  The first one is the "opt-out" possibility for standardized testing, which is coming to a head in a lot of states, most recently New Mexico -- where state education officials are using combative language to make the point that exempting students from standardized tests is illegal, and districts that do not compel all children to sit for mandated exams risk losing their funding.  A number of districts are rebelling, some even providing pre-printed forms to parents to sign that exempt their children from the PARCC (Partnership for Assessment of Readiness for College and Careers) exams.

And none did it with such panache as the Las Cruces School District, where the forms were printed with the statements, "Federal and state laws require all students to participate in state accountability assessments," and "These laws do not offer an exemption or right of refusal to test."  One has to wonder how close they were to adding, "But this form allows parents to exempt their kids anyway," and "You can kiss the Las Cruces School District's rosy-red ass, policy wonks."

The other area in my life in which civil disobedience is making some demands is in our area's attempts to block the storage of LPG (liquified petroleum gas) in unstable salt caverns beneath Seneca Lake.  Over 200 people, including my wife, have been arrested and charged with trespassing for blockading the gates of the facility, and I'm likely to be in the next round.  (Apparently they're not marching the protesters off in handcuffs, which I find kind of disappointing.  Such a missed opportunity for a photo-op.  But if someone can get a photograph of me being arrested, when it happens, I'll certainly find a way to post it here.)

Of course, what I'm talking about here is mild compared to the penalties you can incur in other countries.  Protesting against repressive governments in other countries can get you jailed and/or tortured, being that that's what repressive governments do.  Deliberately breaking the law to make a point reaches its pinnacle of risk in places like Saudi Arabia, where last week a young man was sentenced to death by public beheading for tearing up a qu'ran, hitting it with a shoe, and uttering curses against the prophet Muhammad.  Apparently the man is an atheist -- or, as they call them in that part of the world, an "apostate" -- and he was demonstrating his contempt for religion in general, and Islam in particular, by his actions.

And Saudi law being what it is, in a few weeks he'll almost certainly find himself kneeling in the city square of his home town of Hafr al-Batin, and his head will be severed with a sword.

Which brings up the question of when a cause is important enough to risk your own life.  Or, to put it another way, when is something legal, and at the same time so ethically wrong, that putting yourself in harm's way is the right thing to do?

Not easy questions to answer.  Human morality being the shaky thing it sometimes is, it's easy to conceive of someone breaking the law for his/her own selfish ends, and then justifying it by calling it civil disobedience.  It's also true that one person's civil disobedience is another person's immorality -- as in the parents who are putting other children at risk of disease by their insistence on their right not to vaccinate their own kids.

These are difficult things to sort out.  The best choice is to do a lot of soul-searching before you embark on such a course of action, not only to be certain you understand the risk, but to make sure that you're not engaging in equivocation to rationalize away something that you really shouldn't have done in the first place.  As we discuss at length in my Critical Thinking classes, morality is a deeply personal thing, and unfortunately the words "moral," "ethical," and "legal" don't always line up the way we might hope.  I'll end with a quote from that exemplar of the willingness to put one's life at risk for a higher cause, Martin Luther King, Jr., who wrote, in Letter from the Birmingham Jail:
There comes a time when the cup of endurance runs over, and men are no longer willing to be plunged into the abyss of despair.  I hope, sirs, you can understand our legitimate and unavoidable impatience.  You express a great deal of anxiety over our willingness to break laws.  This is certainly a legitimate concern.  Since we so diligently urge people to obey the Supreme Court's decision of 1954 outlawing segregation in the public schools, at first glance it may seem rather paradoxical for us consciously to break laws.  One may well ask: "How can you advocate breaking some laws and obeying others?"  The answer lies in the fact that there are two types of laws: just and unjust.  I would be the first to advocate obeying just laws.  One has not only a legal but a moral responsibility to obey just laws.  Conversely, one has a moral responsibility to disobey unjust laws. I would agree with St. Augustine that "an unjust law is no law at all."

Monday, January 26, 2015

A risk too far

Assessing risk is a complicated thing.  The technical definition of risk -- that it is equal to the statistical probability of exposure multiplied by the statistical probability of harm -- seems simple enough.  But in practice, calculating those probabilities is far from straightforward.  And when you throw in questions like, "Are the people exposed to the risk the same ones as the ones who are benefiting from it?" and "What if the people involved in the risk assessment are very likely to be lying to you?", it becomes damn near impossible to determine.

Such is the situation we find ourselves in, here in upstate New York.  The current controversy that is polarizing the region surrounds the benefits and risks of hydrofracking and storage of natural gas and liquified petroleum gas (LPG) in salt caverns underneath Seneca and Cayuga Lake.  You see signs in front of houses saying "Ban Fracking!" and "Friends of New York State Natural Gas" in almost equal numbers.

So let's roll out some facts, here, and see what you think.

Hydrofracking well in the Barnett Shale, near Alvarado, Texas [image courtesy of photographer David R. Tribble and the Wikimedia Commons]

Hydrofracking involves the use of sand, salt, and surfactant-laden water to blow open shale formations to release trapped natural gas.  The gas is pumped back up, along with a toxic slurry of "fracking fluid" that then has to be disposed of.  The gas itself is transported down a spider's web of pipelines, some of which pump the pressurized gas down into the abandoned salt mines that honeycomb our area.

In upstate New York, the permission to build the infrastructure for this massive project was granted by the Federal Energy Regulatory Commission last year, in a move that brushed aside objections from geologists and ecologists, and which appears to many of us to be a rubber-stamp approval of corporate interests over safety and clean drinking water.  Now, Crestwood Midstream, a Texas-based energy company, wants to expand the current salt-cavern storage to include LPG.

So let's see what we can do to consider the risks involved in this project.

The first piece, the risk of exposure, involves looking at the history of fracking and gas storage, to see if comparable facilities have experienced problems.  So here are a few accidents that have occurred in such sites:
What I haven't told you, however, is the time scale involved with these events.

All of them occurred within the past twelve months.

Kind of puts a new spin on the gas industry's claim that fracking is safe for humans and for the environment, doesn't it?

What seals the deal is the question of what happens after these accidents occur.  The answer is: not much.  The question is, honestly, not so much "what is done?" but "what could be done?"  And the answer is still: not much.  Such accidents are nearly impossible to remediate completely, and leave behind fouled ecosystems and contaminated drinking water that won't be useable for generations.

So as you can see from the above list, accidents really are more of a matter of "when," not "if."  This leaves it to the local residents to consider what the response would be if the unthinkable happens.  The result would be the salinization of a huge amount of water in the south end of Seneca Lake, which would likely be permanent as far as human lifetimes are concerned, given Seneca Lake's depth and slow rate of flushing.  Aquifers would become too saline to use for drinking water or agriculture, which would destroy not only local farms but the multi-million-dollar winery industry that has become a mainstay of the economy.

And whose responsibility would it be if a problem did occur?  The answer is, "Not Crestwood's."  They are not insured against accidents of this scale.  To quote directly from their own 10K report:
These risks could result in substantial losses due to breaches of contractual commitments, personal injury and/or loss of life, damage to and destruction of
property and equipment and pollution or other environmental damage. These risks may also result in curtailment or suspension of our operations. A natural
disaster or other hazard affecting the areas in which we operate could have a material adverse effect on our operations. We are not fully insured against all risks inherent in our business. In addition, we are not insured against all environmental accidents that might occur, some of which may result in toxic tort claims.
If there was a salt cavern collapse similar to one that happened in the 1960s, the result would be nothing short of a catastrophe for the local residents, because there would be no compensation forthcoming in the way of insurance money.  The only recourse would be a "toxic tort claim" against Crestwood, which would result in costly litigation that would be far too expensive for an average resident to pursue.

And Crestwood is planning on taking the same cavern that experienced a 400,000 ton roof collapse fifty years ago, and filling it with pressurized natural gas.

So if the whole thing blows up in our faces, literally and figuratively, Crestwood can cut their losses and go home to Texas.  We don't have that option.

This hasn't stopped the pro-gas voices from characterizing the risk as minimal, and the people who are speaking out against Crestwood as crazy tree-huggers who have "drunk the Kool-Aid" and who are the victims of "imaginary delusions."  These last phrases are direct quotes from one David Crea, an engineer for U.S. Salt, a company that is now owned by Crestwood.  Responsible, intelligent people, say Crea, couldn't possibly be against gas storage in salt caverns; and he points out that a lot of the people who have been protesting the Crestwood Expansion are from the eastern half of Schuyler County, not the western half, where the facility is located.

Because, apparently, you have to live right on top of a disaster before you're allowed to have an opinion about it.  This kind of illogic would claim that the objections of a woman in Oregon to the siting of a pesticide factory 400 yards away from an elementary school in Middleport, New York are irrelevant because "she doesn't live there."  (I didn't make that up; read about the situation here, which resulted in dozens of children suffering from permanent lung damage.)

So sorry, Mr. Crea; it's not the concerned locals who have "drunk the Kool-Aid."  There's not that much Kool-Aid in the world.  It's the citizens you and your ilk have hoodwinked, and who now sit on top of a site that has a ridiculously high likelihood of catastrophic failure.  And if you multiply all of those risk factors together, you come up with a figure so large that you would have to be on Crestwood's payroll to consider it acceptable.