Wednesday, December 2, 2015

Final review

The 8 Theories

I have a major stakeholder in regional environmental issues in We Energies. A powerful and controversial piece of legislation in the Clean Power Plan, and a voluntary network with big goals but no authority to get them there. Where do they fall within Evans final observations?

These are my thoughts and observations, an in no way are they meant to be objective.

Theory 1 Networks and markets are the best thing we have.
I think relying on market based governance and volunteer markets is a quick way to bring us to environmental catastrophe. We already know that companies who pollute will do the absolute bare minimum (with few exceptions) to meet environmental laws. When we allow We Energies greater leverage, they will use it to create more profits at the expense of the environment. It seems volunteer networks have some use, at least by bringing different stakeholders to the table, but are ineffective at exacting rel change, without the help of policy like the CPP.

Theory 2 Governance is about evolution, not revolution.
I like this idea, but some actors are so powerful, like We Energies, they can bully both local and national stakeholders. Otherwise the idea of appropriate levels of governance, according to scale, makes sense. This theory assumes that meta governance will always evolve slower or that the lower orders will be effected by it at a constant rate. With a changing world that is beginning to see increasingly larger environmental catastrophes, its hard to be rigid in finding the appropriate scale of government to deal with environmental issues. We have to be more flexible than that.

Theory 3 Getting the mix of approaches right is critical.
I think this theory works when you look at the full scope of environmental problems we have world wide. A one size fits all solution is impossible. We Energies does not need a myriad of solutions though. It needs clearly defined top down regulation and it needs to be enforced. Not every problem needs that. The CPP is one such piece of legislation attempting to do that. Wisconsin Partners for Clean Air is a different and largely ineffective approach.

Theory 4 Governance requires political vision
Unfortunately, this theory has been mostly successful in creating bad scenarios for our environment. Political leadership and corporate controlled media have partnered with large polluters and turned the general public against environmental stewardship. How many people even know about the Wisconsin Partners for Clean Air? I would wager not as many as there are people that have seen a pro Brad Schimel (WI Attorney General) ad using fear-mongering to manufacture support for his lawsuit against the CPP for the benefit of WE Energies. It is effective in creating support for the environment as well, and there will be a tipping point for global warming acceptance.

Theory 5 Governance is about learning
"The success of governance depends on the ability to adapt to changing contexts through a process of learning". I would attribute both the WPCA and the CPP to this idea. Networks were created as an idea to bring actors together, pool resources, share responsibilities, etc.. The top down hierarchical governance evolved into networks through experience and learning. We also learned the shortcomings of voluntary governance, thus the need for legislation like the CPP.

Theory 6 Duality of structure is critical
I think the CPP is a piece of legislation that allows small scale freedom to get to a common goal. We live in a capitalist society, and although I would prefer our utilities to be nationalized, since they are not, we must allow them room to come up with a cost effective way to meet emissions goals. The companies would prefer a network without enforcement capabilities, but usually get a mix of both. Participation within networks like WPCA seems to help them fall inline with regulatory bodies like the EPA.

Theory 7 Governments matter.
"Governments shape markets" Evans states the not so obvious. There is no such thing as a free market because it is always set by the government. The invisible hand of the market that so many market based environmentalists think can help solve problems, is really controlled by government policy. This is my favorite theory. Actors like WE Energies need a strong government with clear policy. Otherwise, they'll do as capitalists do. I agree that networks have a place, like the WPCA, but those are mostly just to get all the actors around the table. It's direct government action that can have the most impact at the meta level, and even below that as well, depending on the circumstance. I think federal environmental laws are at their best when they coerce states into following them. States are so full of anti-environmental cronyism!

Theory 8 Hybrid institutions are critical in coordinating action across sectors.
I think these are important for disseminating policy across actors and governments. This is one way in which I think networks find their niche. I think without the help of these institutions, we have no CPP.

I still think we need an evolved hierarchic form of governance. Giving companies some freedom is good, but we need gentle reminders to keep moving forward until the problem of global warming is solved. This won't happen without regulatory power. The political vision and political economy need also to be there as well to enact stricter governance, which I feel is why polluters have fought so hard to gain public support of a more relaxed regulatory environment.




Sutheastern Wisconsin Clean Air network



The Wisconsin Partners for Clean Air was created in 1996, when the EPA alerted Wisconsin that the  six county region in South-Eastern Wisconsin was found to have dangerously high ground level ozone levels.
 http://www.cleanairwisconsin.org/businesses/aboutus.phpconditions.

This is a voluntary network of businesses, community organizations,  government agencies, and schools that steer a committee which attempts to find simple and cost effective ideas to reduce emissions among its member organizations. Along with that, an educational component exists, to pass on useful information to the general public about ways to reduce emissions. 

This is an all volunteer organization, but one with lofty objectives:
  • Community leadership will be visibly supportive and personally engaged
  • There will be a true and equal partnership between government, businesses, and citizens
  • There will be sufficient resources to get the job done
  • The economic and health benefits of clean air will be quantified and communicated clearly
  • Voluntary emission reductions will be substituted for specific mandatory control measures to meet a portion of the requirements of the Clean Air Act
  • There will be significant broad-based public support and an understanding of the various roles of all stakeholders in achieving clean air
  • There will be a widely held belief that control of our own destiny through voluntary efforts is limitless in terms of what can be achieved
  • There will be a close and collaborative relationship with the media to enable effective communications
  • The youth of today will be involved to protect the air of today as well as tomorrow
  • Travel alternatives will be strongly supported and widely used
  • There will be learning resources to enable industry sharing of technical ideas
  • These voluntary efforts will challenge other regions to improve air quality
  • There is a vision and there are clear goals and annual recognition of success; focus and efforts will be renewed annually

The steering committee consists of these businesses and organizations:
American Lung Association of WisconsinCity of Milwaukee Health Department
Fight Asthma Milwaukee AlliesGeneral Mitchell International Airport
In-Sink-Erator DIV Emerson ElectricGodfrey & Kahn, S.C.
Milwaukee County Transit SystemMetropolitan Milwaukee Association of Commerce
Quad/Graphics, Inc.Milwaukee Journal Sentinel
Southeastern Wisconsin Regional Planning CommissionUniversity of Wisconsin-Milwaukee
WE EnergiesWisconsin Department of Natural Resources
Wisconsin Department of TransportationWisconsin Manufacturers and Commerce
Wisconsin Clean Cities - SE Area, Inc.



With that set of objectives and organizations that would be directly opposed to one another, what can we expect from this organization, that holds no political authority? 

Evans writes on page 119 that motivation to join these organizations is only for pure self interest. Why would WE Energies bother with an organization like this, considering the pro pollution (business) climate that exists in Wisconsin? The Fight Asthma Allies, what can they possibly gain over such powerful and well funded organizations like the MMAC? WE Energies gets to showcase its corporate responsibility, and the Fight Asthma Milwaukee Allies gets valuable input to help influence WE Energies self regulation. I mention these two because a prior post of mine mentioned a lawsuit both of these organizations were involved in. 
Evans writes that "The most common criticism of CSR is that companies will engage in order to improve their image, without stopping profitable but environmentally damaging activities". This would be called "greenwashing" and of some of these companies are extremely guilty of it.
I believe WPFCA is an organization that would fall under the CSA model of network governance.

I have a hard time finding what this organization actually asks of major polluters on its website. It does list simple ideas we can personally employ in our day to day lives to reduce emissions. Although useful, it does seem to push responsibility to individual consumers, which is odd, considering the massive amounts of pollution coming from some of the steering committee members. It seems like a greenwash, with many valid criticisms coming right from the Evans chapter on networks. Offering rideshare incentives are nice, but ineffective for real change in emissions.

The strengths I do see with this network is that it does broaden participation among actors. Even WE energies has to follow government regulation, and when it does, it can be useful to have community actors give input. 

It is also important to note that this organization is just one part of the state governments fight for cleaner air. It seems like this is the "ask nicely" part of its actions to regulate polluters. Everyone knows that it is poor form when seeking change, to not ask nicely first. So I feel it does have an important spot to fill.

Tuesday, December 1, 2015

Final Thoughts


I discussed a variety of actors, initiatives/regulations relating to air pollution and improvement on air quality. It ultimately comes down to the various types of governance discussed in lecture and which one is most effective. Like in the Valerie's post, all of these actors, initiatives/regulations and various forms of governance have their strengths ,but they also have their weaknesses.

Trying to assess Clean Wisconsin, this NGO has done substantial efforts in improving Wisconsin's atmosphere especially in terms of legislative action. The EPA, WI DNR, and WI Department of Transportation (in terms of emissions standards and testing) also have a very top-down traditional approach in terms of setting regulations for the country and the state. Whereas in my last post, the Wisconsin Clean Transportation Program including Wisconsin Clean Cities, Wisconsin State Energy Office and many other partners was more of a collaborative, network approach.

 Looking at various forms of governance when trying to improve air quality has given me an interesting point of view. We cannot forget about the forms that I nor my peers did not touch on.

The easiest way is to look at some of the hypothesis discussed by J.P Evans. Trying not to overlap too much, the first one I think is important is networks and markets are the best things we have. Networks are flexible and don't require a usual framework to operate in ,and markets do have a usual framework and can promote more supply & demand approaches like cap and trade. Evan says, "Although networks have been criticized for their voluntary basis, and markets for exacerbating existing inequalities, they are the best things that we currently have, so we should work with them" (215). The WCTP initiative is a perfect example of a network based approach in dealing with issues on air quality. I think more network based initiatives (more permanent ones) should be implemented throughout the state(s). especially due to the success of WCTP.

In terms of the emissions standards and testing, governance requires political action and governments matters hypotheses are crucial to consider. Having governance steer society in the right direction and implementing broad goals is a good start. EPA has started to do with emission standards even though their are wide variety of limitations to emissions testings across the states from cheating, loop holes in the regulations to some would say being completely inefficient. It is a pushing industries/companies, citizens, and society as a whole into the right direction of being aware of the emissions we put into the air and trying to regulate them. This leads to governments being important because it helps shape the structure. With the limitation of them being under-resourced, it can help by bringing together more partnerships and networks to achieve wide variety of strategic goals like improving air quality.

The last two hypotheses I would like to touch on are governance is about learning and getting the mix of approaches is critical. A successful governance is about having the ability to adapt to changing contexts through a process of learning, and I think we are learning that incorporating a diversity of approaches is the best way to such complex issues especially dealing with air quality regulations and overall improving our air quality. Its crucial to incorporate the different forms of governance (hierarchical, network, market, transition, adaptive) for it is beneficial and necessary.

Something that Evans states sums everything up, "Governance has the potential to link people, places and things together in radical new ways...Breaking with the existing status quo requires diversity, open-mindedness and the capacity to learn and change. In doing these things, governance can help forge new identities and visions for the world in which we want to live in" (219).

All these hypotheses presented apply to our issue of air quality, the actors and initiatives/regulations, and the forms of governance itself presented earlier have many strengths. Weaknesses mostly include rigidity for hierarchical and voluntary basis for network. I think it should be widely considered to incorporate more of transition and adaptive governance approaches to our problem of air quality. Especially, creating more laws and initiatives that have high rates of resilience.

Sources:
-Evans, J.P. Environmental Governance. New York: Routledge, 2012. Print.
-Images: Google

Monday, November 30, 2015

Regulations vs. Social Action

The two actors I have previously discussed, the Environmental Protection Agency (EPA) and Compost Crusaders, both approach air quality differently in Milwaukee. Despite their differences, the diversity of tactics is necessary for addressing such a widespread problem such as air pollution. Both actors do have strengths and limitations with their regulations and initiatives, such as any, but are able to cooperate with other actors in the area to implement action and address air quality issues.

In regards to the EPA and their air quality initiatives, they are regulatory by the nature of their governmental position. Although addressing problem
s through governmental regulation isn’t always praised, it deserves credit for initiating action against the depletion of the air quality. Regulations are a good starting point to draw attention to issues stemming from industry and corporations— areas that civilians have little power. In the case of the EPA’s involvement, it is important to consider one of the eight hypotheses presented in the concluding chapter, that governance requires political vision. In order to successfully govern, with regulatory action or social action, society absolutely needs attainable goals. By placing this role on politicians, not only will goals be created, but also a trustworthy figure is created to harness support and to legitimize governmental policy and regulatory decisions. Without a guiding hand, such as the EPA in regards to environmental protection, society does not have a structure to further elaborate and progress off of. Another applicable hypothesis provided by Evans is that governments matters. They shape markets, provide political visions, and legitimize through policies they enact. If the government isn’t addressing major issues, who is? Those who are talking about issues, do they have the power necessary to address such problems? The EPA provides a solid structure for further action.


Although the EPA is a great starting point for addressing air quality problems, it is not enough to get citizens on board to become concerned or inspired. furthermore, social activism is absolutely necessary to make a real impact on a problem such as air quality, stemming from so many sources. As I discussed in my previous post, Compost Crusaders is a network based social organization to expand the practice of composting. They work directly with the community to reach their goal and on the site they list their major customers; BelAir, Transfer Pizza, Beans and Barley, Café Corazon, the Riverwest Coop, Odd Duck, Lakefront Brewing, Outpost, Braise, and a few others. These businesses are often images of environmentally responsible entities, and have gained prestige in environmental awareness. Because they are able to construct a social appeal to composting, composting in a way becomes a business tactic, allowing other businesses to voluntarily step forward and hop on the composting bandwagon. With high hopes, people will see the number of compost bins within the community and will normalize it into their lives, maybe caring more or educating themselves about composting and its benefits.

It is a tricky subject to address, because when it comes down to it, air quality and the lack of action stems from ignorance. Not enough people are aware of the implications of industrial emissions, vehicle emissions, or landfill gases. Citizens are not aware that landfill gases have regulations and strict procedures in place by the EPA, or even know why this would be necessary (I know I didn’t!). Because of this, educational efforts, often associated with social organizations such as Compost Crusaders, is crucial. So, in the case of government regulations,they seem most successful with large corporations who do not deal with local impacts. But on a smaller scale, regulations are causes for resentment. On the local scale, social initiatives must take place by a voluntary participatory method, as well as education which is needed to ensure cooperation and commitment. 

Referring back to the eight hypotheses discussed by Evans, getting the mix of approach right is critical. One could argue air quality is a wicked problem, which in turns needs an extremely diverse set of methods to address it. As Evans says, « a single mode would be counter productive as problems are too complex and require a varied degree of solutions and methods ». This is exactly what we see in the issues encompassing air quality, where numerous and diverse actors are working to implement action. And most importantly, Evans mentions that Governance is about learning. A statement he made that really made me think was that «  both science and capitalism have problems dealing with non-linear changes ». This is clearly true, and supports the fact that a mix of approaches is needed to tackle this problem. 





Tuesday, November 17, 2015

Compost Crusaders

Air quality issues are seemingly difficult to rally support for. Maybe because it’s hard to visibly see the problem, difficult to witness improvements on the problem, or simply because there’s a lack of physicality that one could hold sentiment for. Because of this, NGO’s that strictly focus on air quality in Milwaukee are difficult to come by! But getting creative and thinking a little outside the box, while following the theme of my previous posts, I’ve come to realize that composting plays a large role in air quality!


So, I present to you Compost Crusaders, a Milwaukee NGO concerned with recycling of organic materials in a responsible fashion. Their goal is to divert 50-75% of organic material for the landfill waste stream. 


So the real question, how does reducing organic materials in landfills relate to air quality?

As the EPA says, 
« Organic waste in landfills generates methane, a potent greenhouse gas. By composting wasted food and other organics, methane emissions are significantly reduced. » (http://www2.epa.gov/sustainable-management-food/reducing-impact-wasted-food-feeding-soil-and-composting)


So, organizations like Compost Crusaders, despite not being directly related, works with the social aspects of air quality issues. Composting is an activity than can be advertised, branded, trended, sold to the public as an environmentally friendly initiative. It’s seems difficult to gather support for air quality, but composting has a side that appeals the public.

Like I discussed in my previous post, the Sierra Club is a huge advocate for composting to address landfill gas issues. The Sierra Club does not support burning of landfill gas, and emphasize that efforts should be devoted to reducing organic material in landfills instead. But, I do think both burning landfill gas and composting are important methods for handling landfill gas and the air pollution it causes. Landfill gas, specifically methane in this case, diminishes our air quality and contributes to global climate change, but is a widely complex issue that requires both government and social action. 


The Compost Crusaders’ efforts are drastically different than those of the EPA in targeting landfill gas issues. The Compost Crusaders are taking a collaborative approach, that could also be defined as a network mode of governance. They are community orientated, and their goal is to work with schools, restaurants, grocers, and municipalities to promote organic recycling. In addition to community collaboration, they also work with other organizations in Milwaukee to fulfill and promote their goals. Kompost Kids (another composting NGO), City of Milwaukee Recycling, US Composting Council, the EPA, and Natural Milwaukee are other organizations that also work towards composting efforts. This network of organizations has the scope to influence various sectors of society to join composting efforts. 



A NGO such as Compost Crusaders that targets a social problem (the act of composting) is in some ways more effective than the EPA command-control regulations. Because they are a local organization, they have more opportunity to gather local support, as voluntary composting is more appealing than strict regulations such as ones the EPA must administer to achieve progress. In the case of the Compost Crusaders, participation is 100% voluntary. No one is forced to compost, adding a sense of social progress to involved community members. I think this is more successful and powerful in terms of changing social mindsets of the community. When people have the option to make change and do something good, support spreads a lot faster than legal obligations. 




Check out these links to find out more about Milwaukee composting efforts: 

http://www.milwaukeerecycles.com/

https://teamster.org/sites/teamster.org/files/6310GreenhouseGasReportrevisedlowres.pdf

Wisconsin Clean Transportation Program

Wisconsin Clean Transportation Program (WCTP) was a 4 year initiative to reduce petroleum consumption and to reduce emissions by increasing the amount of alternative fuel vehicles. WCTP was a program held from 2009 to 2013; it proved to hold great success with minor limitations. In terms of improving Wisconsin's air quality, implementing a program to help shift transportation methods would help greatly in reducing the amount of harmful emissions into the air and increase air quality and public health.
In 2009, U.S. Department of Energy's Clean Cities was awarded 300 million dollars in the American Recovery & Reinvestment Act to fund 25 cost-share projects around the country. Wisconsin State Energy Office (SEO) had the privilege of being awarded with 15 million dollars. SEO decided to partner with Wisconsin Clean Cities (WCC) and 53 businesses, companies, industries, or agencies around the state. All these actors volunteered to collaborate and join the program to shifting towards better means of transportation. 


So this program's goals was to reduce emissions and petroleum use, to increase alternative fuel uses, and it was aimed to maximize preservation and creation of jobs by investing in these alternative technologies. It allowed for increase in revenues and increase in the opportunities for growth in WI. 

The partners had the option to choose what kind of alternative fuels they wanted to expand on. They chose from bio-diesel, compressed natural gas, electric, ethanol to hybrid heavy duty class 8 trucks, hybrid & plug-in hybrid electric school buses or electric bucket trucks. The increased alternative technologies were manufactured in the U.S. and some of the manufacturers were located in Wisconsin. Some of them included: Cummins, ANGI Energy Systems, Odyne Systems, IMPCO, and General Motors. 

The partners included in this program were a wide range of actors. Milwaukee County, Marquette University, Go Riteaway Bus, Transit Express, University of Wisconsin-Madison, Milwaukee Metro Sewerage District (MMSD), and WE Energies just to name a few of them. WE energies was awarded with 1,262,291 dollars in funding; they bought 3 light-duty CNGs, and 3 transportation companies, allowing for them to purchase alternative fueling, too. MMSD was awarded with 95,371 dollars and purchased 9 light-duty CNG vehicles, 1 medium-duty, 6 light HEV and 6 HEVS. One more example is Milwaukee County purchased 4 PHEV utility trucks which turned out to be a huge cost saver. 

As a whole, MCTP turned about to be a great success. It displaced over 1.6 million gallons of petroleum by the year 2013.This program was featured at 163 events in WI throughout the 4 years. It allowed for 19 private alternative fuel stations and 3 public access alternative stations to be installed across the state ,and it deployed a total of 377 alternative vehicles on the road. It had small limitations throughout the initiative from a supply and demand problem to vehicle reliability and performance issues including some vehicles that were deemed inefficient in our cold winters. 
 
There was a consistency in the roles of SEO and MCC. SEO had important managing duties ,and WCC handled the outreach efforts. I think SEO, MCC, and the various partners worked collaboratively to significantly implement more alternative vehicles and have less impact on Wisconsin's air quality and environment. This program has had a great impact on all the actors and they all continue to be a part of programs and initiatives to improve air quality. One project MCC is currently working on is a Forwarding Wisconsin's Fuel Choice. 

Going on a tangent, on a current agenda, another program on reducing emissions I found that I wanted to mention was the California Environmental Protection Agency. They have the California Air Resources Board (ARB) have a significant vehicle emissions research program that leads multi-agency research programs to characterizing vehicle emissions. Their goals are to understand the real-world effects of the current regulations and to inform the development of new regulations. Part of their research includes remote sensing devices that are capable of measuring real-world vehicle emissions and their impact on the air quality. From my eyes, this research program is working on some really neat stuff, hopefully in the near future, it will have success in improving emissions testing, emissions regulations and reducing amount being released into the atmosphere. And, too, I hope more programs and initiatives occur in Wisconsin to improve our emissions tests and regulations to overall keep working on and implementing programs to better the air quality.  


Sources:


Wednesday, November 4, 2015

The Clean Air act and the Clean Power Plan

“the Super Bowl of climate politics.”
Coalbot 27, an industry lobbyist, who also moonlights as Fox Sports official Football Robot






 The Clean Air Act was originally passed in 1963, and then had major amendments in 1970, 1977, and 1990. It is a US federal law created to regulate air pollution and the effects it has on our communities and the surrounding environment. The 1970 amendments are considered the most important, granting enforcement powers and regulations against industrial air pollution, in conjunction with the creation of the EPA.

Why is the Super Bowl of climate politics coming to a court room near you?

Justices Alito and Scalia






 In 2007 a group of states sued the EPA( Massachusetts vs. EPA), claiming that it was abdicating its responsibility under the Clean Air Act by not regulating greenhouse gas emissions from new automobiles. http://www.supremecourt.gov/opinions/06pdf/05-1120.pdf

The Supreme Court agreed, and ordered the EPA to "ground its actions or inaction within the statue" (Clean Air Act) which led to the 2009 endangerment finding.

It was a landmark decision and a giant rebuke for President Bush at the time. Shortly after that decision another ruling was given on Environmental Defense v. Duke Energy Corp, which helped create even more precedent for what we are seeing now. http://www.supremecourt.gov/opinions/06pdf/05-848.pdf

In some of my favorite language from the former ruling, the EPA claims that any harm to the state of of Massachusetts would be small and incremental. The justices then proclaimed that rarely do regulations solve a problem in one fell swoop. It is indeed the incrementalism of regulation that closes in on the problem.

The Duke ruling also has the EPA joining forces with non governmental actors against the power company.

Fast forward to now, and the CAA showdown for these new rulings. The new rulings are part of the Clean Power Plan.
http://www.ncsl.org/research/energy/states-reactions-to-proposed-epa-greenhouse-gas-emissions-standards635333237.aspx

There has been a policy explosion in regards to these new rules. The state bills and state resolutions being passed are mostly in opposition to the new rules. See the link above.
If you want to laugh at the Texans, note that one of their state resolutions states that they refuse to recognize EPA regulations without congressional legislation, even though the Clean Air Act is congressional legislation. It failed.

These states have joined together in a lawsuit against the new rules:
Alabama, Arizona, Arkansas, Colorado, Florida, Georgia, Indiana, Kansas, Kentucky, Louisiana, Michigan, Missouri, Montana, Nebraska, New Jersey, North Carolina, Ohio, South Carolina, South Dakota, Texas, Utah, West Virginia, Wisconsin and Wyoming.

It is important to note that the Supreme Court has ruled in favor of the cross state contaminant rule, the rule mentioned in the NYT article. http://www.supremecourt.gov/opinions/13pdf/12-1182_553a.pdf
  
 
The sheer amount of legislators, lobbyists, environmental groups, government agencies, and other actors are building this battle to be "the Super Bowl" of climate politics.
Because the projected cost for compliance has been estimated in the billions of dollars. Many jobs are expected to go up in smoke. Rolling blackouts are predicted. It's as if these normally cornucopia style neo-liberal economic environmentalists are taking their devil horns off and wearing the the old saggy trousers of the neo-malthuesian. They present a doom and gloom scenario. Environmentalists hail this plan as a landmark ruling in the fight to slow down the effects of climate change. Even though this plan has global implications, health and air quality will be greatly affected at local levels due to the reduction of the 6 pollutants mentioned by the EPA.
The reason for the large cost is the requirement of sharp reductions of those 6 pollutants by power plant companies. The goal is to reduce emissions of these by 30% (of 2005 levels) by 2030.
For more information: http://www.gpo.gov/fdsys/pkg/FR-2015-10-23/pdf/2015-22842.pdf





Map above us: A quick glance at the 24 states involved in the lawsuit and where they are at with compliance policy. Note the grey states. I bet one could have some fun finding parallels with other extreme positions or policy within the same borders.