Education

Bailey Mine Expansion Recap and CRDA No.7 Reminder

Coal slurry and waste currently filling a Greene County valley

Coal slurry and waste currently filling a Greene County valley

The Pennsylvania Department of Environmental Protection held an informal public conference last Tuesday July 2 concerning the Consol Bailey Mine longwall expansion. In Richhill and Aleppo Townships, 2,510 acres will be longwall mined. According to the operator, there are no proposed stream impacts that will require stream mitigation. Few people attended due to the 1-3 p.m. meeting time on a Tuesday, but we collected useful information concerning the expansion if you are concerned or have questions.  

Also, as a reminder, there is an upcoming public hearing for the pending Coal Refuse Disposal Area (CRDA) No. 7 National Pollutant Discharge Elimination System (NPDES) water permit. It will take place Wednesday, July 17, 2019 from 1-3 P.M. at the Morris Township Community Center located at 1713 Browns Creek Road, Graysville, PA 15337. Consol Energy is seeking the permit to fill in another valley that will impact 900 acres and fill small headwater streams that are valuable components of downstream ecosystems. The proposed discharges associated with this valley fill further threaten those ecosystems.  The Center for Coalfield Justice will be preparing a technical review and comments and can help residents with providing  their comments to DEP as well.  

If you have any questions, comments, or need help preparing comments please contact Nick at nick@coalfieldjustice.org or 724-229-3550 extension 104.  


Why is equity important to discussions of climate change?

Screen Shot 2019-07-09 at 1.42.15 PM.png

This contribution to our What’s on your mind? blog was written by our Outreach Coordinator Lisa DePaoli, who has studied humans and ecology for quite a long time and earned her Ph.D. in ecological anthropology:

The ways that humans are being impacted by climate change include extreme weather events such as wildfires and flooding, stresses to food-producing systems, the spread of infectious diseases, and negative impacts on biodiversity and wildlife, security, migration, and public goods such as water. In short, climate change impacts people’s health, livelihoods, and homes and other forms of property.  

Furthermore, certain people are disproportionately affected by climate change, including low-income and minority populations and other vulnerable people who are at greater risk due to age, discrimination, health, and/or location. They may have less ability to move about, pay for damages, and rebound after setbacks. Communities of color and low-income communities face an increased vulnerability because of the compounded stresses of ongoing heat waves, poor air quality, flooding, and mental health stress.

People who are the most vulnerable to the effects of climate change are also those who are least responsible for causing it (for example, according to a study by Oxfam, the poorest 50 percent — about 3.5 billion people — contribute only 10 percent, while the richest 10 percent of people produce half of the planet’s individual-consumption-based fossil fuel emissions). Changes in weather patterns, sea level rise, and other impacts further exacerbate existing inequities. Therefore, we must integrate questions of justice in debates about the environment. Focusing on only one part of the problem, such as “jobs,” is like treating the symptom and ignoring the cause of this unequal effect (the underlying socio-economic factors of disadvantaged populations). Actions to address climate impacts and to reduce emissions should be considered in conjunction with broader equity issues involving livelihoods and a living wage, health, food security, and energy access. The wellbeing of people and communities must be at the core of climate action.

There is a lot of discussion of possible ways to address the problem of climate change. Unfortunately, many of the ideas that have been brought forward are top-down or trickle-down in approach (e.g., placing a tax on fossil fuels). With this approach, decisions are made by a few people in authority rather than by the people who are affected by those decisions, and solutions are framed by actions and policies that are initiated at the highest levels of government. However, it has been proven over and over again that top-down and trickle-down solutions do not work. This is especially true for systems-level problems like climate change, which involves the triple bottom line of sustainability: social and cultural factors, ecology/environment, and economics. We have to consider the effects of our actions, technologies, and livelihoods on the health of both people and the environment on which we depend.

Climate action and equity issues are integrally linked and can be mutually supportive. We need to ensure fair transitions for our workers, diversify our economy, and give power to frontline communities. Meaningful change will take an active and inclusive social movement, which will accelerate momentum for climate action. 


On the Road to Improving Our Economy

IMG_0026.jpg

The Center for Coalfield Justice launched an extensive Economic Justice Campaign at the beginning of May 2019. The campaign kicked off with a month-long on-foot door knocking canvass across Greene County. We knocked 1,374 doors and had 212 conversations with folks. The canvass was successful in helping spread the word to encourage the community to join us at two Economic Workshops in both Waynesburg and Carmichaels. In addition, we engaged with folks at their doors and over the phone around their experiences in Greene County and their ideas for the future. 

The workshops were a big success. Attendees forged an original conversation, with multiple points of view, in a civilized and productive manner. Discussions included hopes for the County’s future, the history of the county, the lives and experiences of attendees, and a deep dive into the declining mineral value tax revenue, made possible by of our research partnership with MIT (Massachusetts Institute of Technology). 

Due to positive feedback and a drive in the community for continued engagement around this issue, CCJ is planning to hold additional meetings to dive deeper and continue facilitating and uplifting civilized discourse around conversations concerning the future of Greene County. We are looking forward to encouraging residents to engage in active involvement and participation in forging the County’s economic future where everyone has access to good paying jobs. 

As the County Commissioners embark on creating Greene County’s 10-year Comprehensive Plan, it is imperative that the public has transparent access to not only the process but the content of this plan. That being said, the Comprehensive Plan public comment period should open in mid-July and CCJ is working to inform and educate the public on how to make comments and have their voices heard.  

CCJ will be facilitating and implementing a questionnaire/survey about our local economic needs for all candidates running for Greene County Commissioner. With the help of volunteers across the community (that means YOU!), we want you all to help us draft this questionnaire to candidates with your questions. CCJ will be at the Jacktown Fair, Rain Day, the Greene County Fair, and the Washington County Fair to discuss and receive feedback around Greene County’s current economic opportunities and what needs to improve for everyone to thrive in the community. We will be receiving comments and ideas for our candidate survey and we will be helping folks to navigate the Comprehensive Plan public comment process. Look for us in the tabling sections of the fairs- we would love to hear from you! 

For more information about CCJ’s Economic Justice Campaign, to make suggestions, volunteer, or if you have any ideas about research for us to work on through our partnership with MIT, contact Heaven Lee Sensky at heaven@coalfieldjustice.org or 724-229-3550 Ext. 103.

Fighting for Freedom from Plastics on this Independence Day

On July 4th, many Americans forget the history of the United States. July 4th, 1776 was the date that the Declaration of Independence was published, letting England know that the American colonies considered themselves free and were dissolving the “political bands” that tied the two together. Just as Cinco de Mayo is not Mexican Independence Day, July 4th is not the day that we won our independence (that’s September 3, 1783 when the Treaty of Paris was signed, ending the Revolutionary War).  

Internet meme inspired by  The Office

Internet meme inspired by The Office


To be fair, the first step in kicking any bad habit - be it a tax-crazy king or biting your nails - is to decide that the habit is no longer acceptable and to declare that its time is coming to an end. One of the biggest of our collective bad habits is plastics. 

This month is #PlasticFreeJuly, and people around the world are committing to reducing or eliminating their plastic use throughout the month, ditching coffee to-go cups and shampoo bottles in favor of cute, reusable travel mugs and shampoo bars. 

Don’t let getting down with the red-white-and-blue at holiday parties stop you from kicking your plastics habit! Here are some ways to go plastic-free (or reduced-plastic) on your holiday:

1) If you’re traveling, BYOR (bring your own reusables). If you, like so many, are the ultimate shopper and don’t have a to-go dinnerware kit already but it’s too late to order online, you can purchase almost everything you could need in portable sizes anywhere that camping supplies are sold. If you’re not so big on shopping, bring one of those Tupperware containers that you got from your grandmother that will still be around and in use by your own grandkids (you know what I’m talking about). Throw your container, utensils, and a cup into a bag - you’re all set! 

📸: Dianne Peterson,  Our Children Our Earth

📸: Dianne Peterson, Our Children Our Earth

2) If you’re hosting, offer reusables. You can ask people to scrape and rinse their own plates, cutting down on your cleanup later: I’m sure if Emily Post had known about our plastic crisis, she’d support this. If you don’t have enough reusables, encourage people to bring their own (see #1), buy paper/compostable products, and put out separate receptacles for refuse and composting. It’ll cut down on the cost of buying disposables if you ask people to keep their plate as long as possible, too. 

3) Look for plastic-free or reduced-plastic drink options. Drinks like water and lemonade are easy to serve in Pinterest-worthy coolers - don’t waste your money on bottled water. Pop/soda/sodapop is available in recyclable aluminum cans, both 8oz and 12oz sizes - grab the 8oz if you typically pick up a lot of half-full pop cans at the end of the party. 

4) Go for glass. Yes, that craft brewery may have great brews, but there may also be plastic on their aluminum cans! Cans are often wrapped in plastic shrink-wrap because smaller breweries order their cans in bulk but don’t need too many of one particular variety. Investing in a reusable growler can often save you money when you return to get refills - always a good option - and single-serve glass bottles can be recycled at most local recycling facilities. (Glass, unlike plastic, can be recycled repeatedly and still retain its integrity.) 

The plastic shrink wrap is particularly noticeable on the black can. Can you see it?  If you can’t do cans right, wine, keep to glass.  📸: Sarah Martik

The plastic shrink wrap is particularly noticeable on the black can. Can you see it?

If you can’t do cans right, wine, keep to glass.

📸: Sarah Martik


5) Decorate responsibly. Do you really need the plastic table confetti? Will anyone notice the plastic firework cupcake picks? Why go with a frilly plastic wreath that you’ll toss at the end of the day when you can get crafty and make one to use every year? There are plenty of ways to have a cute party without the plastic! 

6) No styrofoam. Your fork pokes through styrofoam plates, and styrofoam coolers don’t work, anyway. If your only option is single-use plastic disposables, for the love of all things frugal and environmentally-friendly, don’t go with styrofoam. 

As you’re declaring personal freedom from plastic, don’t forget that people won’t join in your revolution (like the French did for the colonies) if you don’t tell them about it! People are going to notice if you’re using bamboo utensils: a simple “I’m doing what I can to eliminate unnecessary plastic in my life,” is a great way to open a dialogue. If you want to be like the Marquis de Lafayette and turn the political tide in favor of Independence, consider moving beyond personal changes. Advocate at all levels of government, and add your voice to the movement to #BreakFreeFromPlastic













CCJ and allies plan trip to D.C. to lobby for black lung benefits for coal miners

images.jpg

The Center for Coalfield Justice along with the Alliance for Appalachia is planning a trip to Washington D.C. to talk with lawmakers about black lung benefits for coal miners.  We demand that these important benefits be secured. Here is a more in-depth look at the issues surrounding the Black Lung Trust Fund.

The trip will take place from July 22-24. Miners living with black lung have decided to take their issue to Washington, DC. A coalition of groups led by several local Black Lung Associations are working to support a large contingent to travel to Washington DC for a day of action. 

We expect to fill 1-3 charter buses to bring 80 or more miners and their loved ones from across Appalachia to take this issue directly to Congress. 

The goal of this trip is to pressure Congress to acknowledge and address the Black Lung epidemic and to restore the black lung excise tax so that the Black Lung Disability Trust Fund, which provides black lung benefits to coal miners and their surviving dependents in cases where the miner’s employer has gone bankrupt, can remain solvent in the face of unprecedented need.

Miners living with black lung, their families, their doctors, their neighbors and allies have been reaching out to legislators for over a year. We have delivered thousands of petitions, letters, and postcards. Extensive government reports and investigative journalism have been published to expose the severity of this issue. Miners have sat down and politely explained that they are dying, and that this epidemic is growing worse every day. And yet, Congress has done nothing.  

If you are concerned, please use your voice to help with this cause.  

If you would like to join or have any questions or comments please contact Nick Hood at nick@coalfieldjustice.org or 724-229-3550 ext. 104.  

In addition, right now the Senate Finance Committee is currently examining longer term solutions to temporary tax policy.  The Health Tax Task Force, established by the Committee and which both Senator Toomey and Senator Casey sit on, is looking at the black lung excise tax rate that supports the Black Lung Disability Trust Fund. This is an opportunity for stakeholders to make our case for a long-term extension of the tax rate that Congress allowed to lapse at the end of 2018.  In addition, we have heard that the coal industry is lobbying the Task Force aggressively to not extend the tax rate. 

Please send this letter to our Senators today advocating to extend the tax rate and support coal miners suffering from black lung.



Thanks for a Great DRYerson Festival!

On Saturday, June 22nd, the staff of the Center for Coalfield Justice held its 13th Annual DRYerson Festival at Ryerson Station State Park. About 100 community members attended the festival and enjoyed the park, the beautiful afternoon, conversation and community, food, door prizes, snow cones and cotton candy, and great music from Bree Otto! We enjoyed seeing each and every one of you! Thank you for coming out! 

fullsizeoutput_14.jpeg

The date of this DRYerson Festival marked the 25th anniversary of when Act 54 was passed. For 25 days leading up to the festival, we posted a fact each day on Facebook relating to Act 54. This Act was intended to protect water resources and structures against mine subsidence damage; extend the obligation of coal companies to pay for the damage they cause to homes, land, and businesses; and to enforce greater transparency regarding the impacts of mining. Under Act 54, the Department of Environmental Protection (DEP) must compile data and give it to a third-party source (researchers at the University of Pittsburgh) who produce a report every five years showing the effects of underground mining on land, structures, and water sources. The most recent report was released in August of 2014, regarding the years from 2008-2013. The report regarding 2013-2018 will be released at the end of August of 2019. Unfortunately, Senate Bill 763, which has been referred to the Environmental Resources and Energy Committee, would significantly weaken these protections. We are monitoring this bill and others and will share additional updates and send action alerts as needed.

We are also monitoring the streams in Ryerson (Kent Run, Polen Run, and North Fork Dunkard Fork) and are prepared to take any enforcement action if they experience significant damage that is not promptly restored. Two representatives of CCJ also serve on the Re-envision Ryerson Task Forces and have advocated for the state to be more clear about the timeline and process for improvement projects at the Park. There is another task force meeting scheduled for August and we will share an update afterwards.

Thanks to all of our members and supporters, who help us to continue the work that we do for environmental justice for our communities, and thank you to all of our volunteers for the hard work. We’ll look forward to doing this again next year!

Proposed Legislation Will Weaken Environmental Protections

Polen Run at Ryerson Station State Park

Polen Run at Ryerson Station State Park

The Pennsylvania Senate has been busy considering a series of bills that would reduce accountability and transparency regarding the impact of longwall mining operations in Pennsylvania, weaken water protections, and limit the ability for concerned individuals and organizations to challenge permits issued by the Pennsylvania Department of Environmental Protection (“DEP”).

Senate Bill 763

SB 763 introduced by Senator Bartolotta proposes amendments to the Bituminous Mine Subsidence and Land Conservation Act (“Act 54” or “Mine Subsidence Act”).  Currently, the Mine Subsidence Act requires DEP to compile, on an ongoing basis, information from mine permit applications, monitoring reports, and enforcement actions related to surface impacts of underground coal mining. It also requires DEP to report its findings regarding subsidence damage to homes and businesses, water supplies and streams at five-year intervals. A team from the University of Pittsburgh, which brings together expertise in mine engineering, hydrogeology, and ecology, is compiling the 5th five-year report. The 5th Act 54 report is scheduled to come out this year.

SB 763 would make compiling a report on subsidence damage to homes and other structures, water supplies and streams optional under the Mine Subsidence Act. The bill also eliminates the specific directive to the DEP to evaluate “the effects of deep mining on subsidence of surface structures and features and on water resources, including sources of public and private water supplies.” SB 763 replaces this specific directive with the generic phrase: “compliance with the requirements of this act.”

Assuming a report is compiled at all, SB 763 goes one step further and seeks to limit who would receive a copy of that report.  Under existing law, the five-year report compiled by DEP is submitted to the Governor, the General Assembly as a whole, and the DEP’s Citizens Advisory Council. Under SB 763, only the Governor and the Environmental Resources and Energy Committees in the Senate and House would receive a copy of the report.

The DEP’s Citizens Advisory Council (“CAC”) would no longer be entitled to receive a copy of the report. CAC held two public hearings on the report that was released in 2015, including one in Washington County. The Citizens Advisory Council used these public hearings to help it develop its comments and recommendations to improve Pennsylvania’s mining program. Those recommendations included a more qualitative review of water supplies, re-evaluating the 35-degree rebuttable presumption zone, and the general assembly make changes to ensure prompt replacement of water supplies.

SB 763 has been referred to the Environmental Resources and Energy  Committee.

Senate Bill 619

SB 619 introduced by Senator Yaw seeks to amend the Clean Streams Law to exclude from its definition of pollution any “accidental discharge, spill or release that does not cause a violation of any of the numeric water quality criteria under 25 Pa. Code Chapter 93 (relating to water quality standards).” SB 619 would also eliminate the need for reporting of accidental spills unless they meet this new limited definition of pollution.

Currently, the Clean Streams Law does not state that one can never place a pollutant into a stream. Instead, the Clean Streams Law and the NPDES permitting scheme allow for some amount of environmental impact because what is important is not that absolutely no environmental impact occurs, but that the impact does not impair the protected water uses listed in 25 Pa. Code §§ 93.3 and 93.4 (e.g. aquatic life, recreation, water supply).

SB 619 would add language narrowing the definition of pollution in the Clean Streams Law: “An accidental discharge, spill or release that does not cause a violation of any of the numeric water quality criteria under 25 Pa. Code Ch. 93 (relating to water quality standards) for the receiving water does not constitute pollution.” (emphasis added).

Chapter 93 protects water quality by protecting the designated water uses of streams and rivers such as for water supply, aquatic life, fishing, and recreation. The fundamental goal and purpose of the Clean Streams Law and the DEP’s water protection regulations is to protect and maintain uses. State water quality standards consist of three elements: designated uses that specify the intended uses or goal for each water body or segment of water in the state; criteria that are generally specific maximum numerical concentrations of pollutants in the water body that will not preclude attainment of the designated use; and an antidegradation policy that imposes limits on the issuance of permits that will impair designated and existing uses.

The problem with the revision proposed by SB 619 is that Chapter 93 contains few numeric water quality criteria. In fact, there are only 15 specifically named in Section 93.7 including alkalinity, ammonia nitrogen, bacteria, chloride, color, dissolved oxygen, fluoride, iron, manganese, nitrite plus nitrate, osmotic pressure, pH, Phenolics, sulfate and temperature. While the Chapter contains additional standards, they are not numeric because they are based on the designated use of the waterway. Section 93.7  acknowledges that the “list of specific  water quality criteria does not include all possible substances that could cause pollution.” It then adds the general requirement: “For substances not listed, the general criterion that these substances may not be inimical or injurious to the existing or designated water uses applies.” Further, Section 93.6 states: “Water may not contain substances attributable to point or nonpoint source discharges in concentration or amounts sufficient to be inimical or harmful to the water uses to be protected or to human, animal, plant or aquatic life…In addition to other substances listed within or addressed by this chapter, specific substances to be controlled include, but are not limited to, floating materials, oil, grease, scum and substances that produce color, tastes, odors, turbidity or settle to form deposits.” Again, these are not numeric water quality standards.

As written, if an accidental spill temporarily and irreparable harms aquatic life or temporarily or permanently prevented a stream or river from being used according to its designated use, without violating a numeric standard, DEP may not be able to take action to require cleanup and remediation because it would not be considered “pollution” under the Clean Streams Law. A company may not even be required to report the spill to DEP or downstream water users.

SB 619 was last referred to the appropriations committee.

Senate Bill 726

SB 726 introduced by Senator Bartolotta would create a new standard of review for appeals of DEP permitting actions before the Environmental Hearing Board (“EHB”). Currently, the EHB reviews actions of the DEP de novo, and is not limited to the record before the DEP at the time it took the appealed action. The EHB’s review extends to the issue of whether a continuation of the permitted activity is appropriate based upon up-to-date information and expert testimony presented to the EHB.

SB 726 seeks to limit parties appealing permit decisions to issues raised in and information contained in a record of decision of a permit prepared by DEP. Under this new standard of review, parties may be prohibited from calling experts or presenting information to rebut information in the record of decision if that information was not presented to DEP during the permit review process. This change would put additional burden on concerned residents and organizations to submit all possible grounds for appeal and all potentially relevant information during the public comment period. The public comment period is only 30 days long and applications are noticed for public comment before the DEP conducts its technical review. As a result, permit applications are often significantly revised after the public comment period has closed.

SB 726 has been sent to the Environmental Resources and Energy  Committee.

We are monitoring these bills and will share additional updates and send action alerts as needed.



Greene County’s Economy Must Work for Everyone

Photo of people at Washington, PA Peoples Climate, Jobs, and Justice March.

Photo of people at Washington, PA Peoples Climate, Jobs, and Justice March.

It is clear that our economy and communities are changing in Greene County. At the Center for Coalfield Justice, we acknowledge that the only way these changes will include everyone is if we are all working together. As a result, CCJ has launched a canvass in Waynesburg and Carmichaels, where we are going door to door in these two towns to talk to as many residents as we can about what they need to thrive in Greene County in the next 5-10 years. Do people need access to better-paying jobs? Do we need more investment in our children’s education? Are there adequate protections for our air, water, and public health?

The past has shown that we cannot always count on elected officials to ensure that proposed solutions address people’s needs. Through our launching of this campaign, we plan to build an avenue for everyone to participate in visioning our economic future. We believe that this will help ensure that our County Commissioners, State, and Federal Legislators know what our needs are and will allow us to better hold them accountable.

In addition to the canvass, we are hosting community conversations about what we need to support our families in the coming years. Join us for one of three workshops across the county to provide input on what types of jobs we need and how we can all act together to improve our communities. Here is the workshop schedule:

  • June 11th 6:30-8:30 in Waynesburg at the Corner Cupboard Food Bank (881 Rolling Meadows Rd, Waynesburg, PA)

  • June 12th 6:30-8:30 in Wind Ridge at the Richhill Firehall (120 Ferrell Ave, Wind Ridge, PA)

  • June 13th 6:30-8:30 in Carmichaels at the American Legion (205 E George Street, Carmichaels, PA)

During these conversations, we hope people will share their experience of living in Greene County, how they view the current local economy and access to jobs, and discuss what people need to support their families and thrive in our area. If you have any questions please call our office at 724-229-3550 or email Heaven at heaven@coalfieldjustice.org

Dinner will be served at the meetings starting at 6:00 PM and the program will start at 6:30 PM. There is space for 25 people at each workshop but if there is more interest than we have space, we will host additional meetings. We can provide childcare, travel support, and meet other access needs by request. Please note any needs in the registration form:

In addition, CCJ has been working with the Massachusetts Institute for Technology to research the status of our economy in relation to fossil fuel extraction. We have also worked with FracTracker to map the energy company-owned land in Greene County and will be publishing these results soon.

Join Us for CCJ's May Open House

IMG_1562.jpeg

Each month, the staff of the Center for Coalfield Justice looks forward to hosting our CCJ Community Open House because you - our members and supporters - are the heart of our organization. You are why CCJ exist, and you help to guide our plans and actions.

At last month’s meeting, Veronica Coptis, our Executive Director, presented on the history of CCJ and how we approach working with communities. This month, Nick Hood, one of our community organizers, is going to present our new Fracking in the Coalfields Virtual Tour! This tour has been quite a while in the making, and we look forward to watching it with you and hearing your thoughts and comments.

CCJ’s Community Open House is held on the last Tuesday of each month in our office from 6-8 p.m. This month, the date is May 28th, and CCJ will be providing sandwiches and drinks. Any other contributions of food or drink are welcome!

For the month of May, we are making an additional ask of our members and supporters: please bring some nonperishables for the Waynesburg Food Bank, the Corner Cupboard, who has generously agreed to host one of our Economic Workshops in Greene County on June 11th.

If you’re able to join us, please let us know by emailing or calling Lisa DePaoli, our Outreach Coordinator, at lisa@coalfieldjustice.org or 724-229-3550 ext 101 or commenting on the Facebook event page. As always, our meetings are held in our office at 14 E. Beau Street, Washington, PA.

We look forward to seeing you!


Remember Today and All Days to Care for Our Environment

Earth-day1-712x1024 (1).jpeg

Earth Day is the most celebrated secular holiday in the world.  We all live, work, play, love and depend on this planet. Today is a day to celebrate our planet and perhaps find a way to replenish it and clean it up.

You might consider some of these ideas for you on Earth Day: plant trees or flowers, clean up a roadside or park, go for a walk at a stream, make a rain barrel, make a recycling bin, make bird feeders and/or share your knowledge!

Let Earth Day activities inspire you to make permanent changes in your life. Decide on new, eco-friendly habits and try your best to implement them throughout the year. While Earth Day is one day out of the year to focus on the environment, it takes daily dedication to create long-lasting positive change.  Every little bit counts, and these little things can add up to massive changes.

Today we urge you to soak in the beauty of this planet and to think about how we want to leave it for the generations that follow.