Friends of the UNB Woodlot - 2nd Presentation to the Public Safety and Environment Committee, City of Fredericton (April 06, 2012)

Air Pollution from Shale Gas
Development “is a Certainty”
- the Evidence for a Ban
April 03, 2012
Mark D’Arcy, Friends of the UNB Woodlot

Presentation to the Public Safety & Environment Committee,
City of Fredericton

My
name
is
Mark
D’Arcy
and
I
am
with
the
group

Friends
of
the
UNB
Woodlot.

We
appreciate
this

opportunity
to
make
a
presentation
to
the
Public

Safety
&
Environment
Committee
on
the
dangers

poised
by
air
pollution
if
shale
gas
development
is

allowed
to
proceed
in
the
large
regions
outside

Fredericton.

We
have
been
active
on
the
University
of
New

Brunswick
Woodlot
issue
since
2007.

The
UNB

Woodlot
represents
a
microcosm
of
several
key

environmental
issues
facing
our
city
and
also
has

been
a
real
litmus
test
of
the
environmental

protection
policies
in
our
province.

Air Pollution is not just a Public Health issue but a
critical economic issue for Fredericton:

“Attracting investment, entrepreneurs, and talented
professionals and skilled trades people is based largely
on the quality of life and amenities a community has to
offer, and excellent healthcare is at the top of the list.
When potential newcomers to the community hear that
it can take 2-3 years to make a doctor’s patient list, we
start to look a lot less appealing.”

“Fredericton
Chamber
of
Commerce
Says
Doctor
Shortage
Still
a
Pressing
Issue”,
Andrew
Steeves,
President,
Fredericton
Chamber
of
Commerce,
March
23,
2012

http://www.frederictonchamber.ca/content/250205

Presentation Outline

1. Sources of air pollution from shale gas operations

2. Toxic chemicals identiﬁed to date in this air pollution

3. Emerging health effects from this air pollution

4. Obligations to the public - “precautionary principle”

5. Recommendations

6. Alternative economic development policies

1. Sources of air pollution from shale gas operations

Data
has
recently
come
out
from
government,
university

research,
and
municipalities
which
show
that
air
pollution

from
shale
gas
development
has
worse
health
effects
than

the
water
pollution.
Parts
of
once
pristine,
rural
Wyoming

have
smog
levels
equal
to
Los
Angeles.

Even
for
residents
that
live
far
away
from
shale
gas

operations,
the
following
has
become
a
common
statement

about
these
affected
communities:

"Water
pollution
is
a
possibility,

air
pollution
is
a
certainty."

(google
Dr.
Theo
Colburn)

Sources of air pollution associated with shale gas
operations
1. Intentional venting and flaring of natural gas

2. Diesel emissions from truck traffic

3. Diesel emissions from drilling pads

4. Gas processing at compressor stations

5. Spilled fluids

6. Storage tank emissions

A
major
source
of
air
pollution
is
certainly
all
the

activity
around
well
drilling,
hydraulic
fracturing,
and

completions
of
shale
gas
wells:

1.

Fracking
,luid
chemicals
2.

Drilling
,luid
chemicals
3.

Naturally
occurring
chemicals
(in
shale
formations)

-‐
benzene,
arsenic

-‐
heavy
metals
(e.g.
cadmium,
chromium,
lead)

-‐
radioactive
elements
(e.g.
barium,
lead-‐210,
radium,
strontium,

thorium,
uranium),
which
are
signatures
of
this
shale
rock
geology.

New
York
State
Department
of
Environmental
Conservation
(2011).
NYS
SGEIS
revised
draft,
Section
5
-‐

http://www.dec.ny.gov/energy/75370.html

Committee
on
Energy
and
Commerce,
U.S.
House
of
Representatives
(2011).
"Chemicals
used
in

Hydraulic
Fracturing",
April
2011
-‐
http://democrats.energycommerce.house.gov/index.php?
q=news/committee-‐democrats-‐release-‐new-‐report-‐detailing-‐hydraulic-‐fracturing-‐products

However,
the
processing
and
distribution
of
the

natural
gas
is
another
major
source
of
air
pollution.

Processing
plants
and
pipelines
often
contain
large

numbers
of
pneumatic
valves.

These
valves
are

under
pressure
and
leak
small
quantities
of
natural

gas.

“Although
some
processing
is
done
at
the

wellhead,
gas
processing
plants
miles
away

further
remove
any
liquids
from
the
gas
to
create

pipeline
quality
gas.

Gathering
systems
may
need

?ield
compressors
to
move
gas
to
processing

plants,
and
larger
compressor
stations
generally

are
sited
every
40
to
100
miles
to
move
gas
along

the
pipeline
and
generally
contain
some
type
of

liquid
separator.”

Text

Source:
based
on
[SUMI
2008])

Source:
based
on
[SUMI
2008])

Residents
near
fracking
operations
have
documented

strong
petroleum-‐like
odours,
diesel
and
chemical
smells.

These
smells
are
coming
from
the
toxic
air
pollution
from

shale
gas
operations
on
the
well
site,
1000s
of
truck
trips

to
and
from
each
well,
and
the
gas
distribution
system

moving
the
gas
through
the
pipelines.

Fredericton
is
in
a
valley
and
will
become
a
sink
for

heavier-‐than-‐air
toxins
that
travel
long
distances
from

shale
gas
wells
and
compressor
stations.

Summer
winds
are
longwise
SSW
to
NNE.

Winter

winds
are
longwise
ENE
to
SSW.
These
are
the
two
most

predominant
winds
in
NB.

“Smog
lines”
can
travel
for

up
to
300
kilometres.

http://www.gnb.ca/0078/Promo/NaturalGas/ObtainingOilGasRights-e.asp

The
Department
of
Natural
Resources
map
showing

shale
gas
test
drilling
licenses
speaks
for
itself.

These

licenses
cover
a
10-kilometre
radius
around

Fredericton,
and
includes
the
UNB
Woodlot
and
most

other
areas
of
the
City
of
Fredericton
and
surrounding

communities.

UNB
Woodlot

http://www.gnb.ca/0078/Promo/NaturalGas/ObtainingOilGasRights-e.asp

2. Toxic chemicals identiﬁed to date in this air pollution

Volatile Organic Compounds

1. Benzene, a known carcinogen

2. Acryloniltrile, a human carcinogen

3. Methylene chloride, a human carcinogen

4. Ethylbenzene, a human carcinogen

5. Xylene

Volatile Organic Compounds

6. 4-ethyltoluene

7. 1,3,5-trimethylbenzene

8. 1,2,4-trimethylbenzene

9. Ethylbenzene, a human carcinogen

Other Toxic Compounds in the Air

1. Carbon disulﬁde, neurotoxins

2. Naphthalene, a blood poison

3. Pyridines, potential carcinogens

Combustion products & ground-level ozone

1. Carbon monoxide

2. Nitrogen oxide

3. Sulfur dioxide

4. Volatile organic compounds (e.g. PAHs, BTEX, formaldehyde)

5. Small airborne particulates

6. Metals

Greenhouse Gases - Methane & CO2

1. Methane, 20X more potent GHG than CO2

2. Carbon dioxide (CO2)

Air Pollution from Trucks is one of worst impacts of
shale gas development:

Each well fracked equates to 1000s of truck trips to
and from the well.
“Each well = 1,800 to 2,600 truck drive-bys
8 well pad site = 14,400 to 20,800 drive-bys”

YouTube:

FRACK
TRUCK
CONVOYS

(Frack
truck
impacts
on
towns
and
roads,
and
includes
DEC
estimates
of
truckloads
per
well,

Jeffrey
Reynolds
and
James
“Chip”
Northrup,
uploaded
February
03,
2011)
http://www.youtube.com/watch?v=F93rDR3AOhw&feature=share

Ground-level
ozone
is
a
primary
ingredient
of
smog.
Higher

temperatures
increase
ground-level
ozone
production,
thus

climate
change
will
intensify
urban
smog.

“In
addition
to
the
land
and
water
contamination
issues,
at

each
stage
of
production
and
delivery,
tons
of
toxic
volatile

compounds,
including
benzene,
toluene,
ethylbenzene,
xylene,

etc.,
and
fugitive
natural
gas
(methane),
escape
and
mix
with

nitrogen
oxides
from
the
exhaust
of
diesel-driven,
mobile
and

stationary
equipment
to
produce
ground-level
ozone.

Ozone

combined
with
particulate
matter
less
than
2.5
microns

produces
smog
(haze).

Gas
Eield
produced
ozone
has
created
a

serious
air
pollution
problem
similar
to
that
found
in
large

urban
areas,
and
can
spread
up
to
200
miles
beyond
the

immediate
region
where
gas
is
being
produced.
Ozone
not
only

causes
irreversible
damage
to
the
lungs,
it
is
equally
damaging

to
conifers,
aspen,
forage,
alfalfa,
and
other
crops
commonly

grown
in
the
West.”

Smog from oil and gas operations is now major
source in Dallas-Fort Worth, Texas:

Oil and gas operations in the Dallas-Fort Worth
region emit more smog-causing volatile organic
compounds (VOCs) than all cars, trucks, buses
and other mobile sources in the area combined.

Dallas-‐Fort
Worth
Attainment
Demonstration

SIP
Revision
for
the
1997
Eight-‐hour
Ozone
Standard
Nonattainment
Area

Project
Number
2010-‐022-‐SIP-‐NR
Texas
Commission
on
Environmental
Quality
(TCEQ)

December
7,
2011
http://m.tceq.texas.gov/airquality/sip/dfw_revisions.html

3. Emerging health effects from this air pollution

Only
recently
have
New
Brunswickers
learned
about

the
serious
threats
to
our
air
quality
from
shale
gas

development.

In
the
Fall
of
2011,
three
key
speakers

came
to
our
province:

-‐
Dr.
Anthony
Ingraffea
from
Cornell
University

spoke
in
Moncton
and
Fredericton;

-‐
Calvin
Tillman
(former
Mayor
of
Dish,
Texas)

spoke
in
Memramcook,
Richibucto,
Fredericton,

Minto/Chipman,
and
Woodstock;

and

-‐
Jessica
Ernst
(Rosebud,
Alberta)
spoke
in

Memramcook.

You
can
Google
their
presentations
on
YouTube.

They
painted
a
picture
of
a
very
new
technology
and

industry
that
is
under-‐regulated,
contaminates
air
and

water
with
human
carcinogens,
industrializes
our

farming,
hunting
&
nishing
areas,
ruins
our
roads
and

bridges,
and
does
not
deliver
on
promised
local
jobs.

In
fact,
their
concerns
are
supported
by
the
new

assessment
by
the
U.S.
Secretary
of
Energy.

Their
second

and
ninal
90-‐day
draft
report
was
issued
by
a
federal

panel
on
shale
gas
drilling:

The Ofﬁce of the U.S. Secretary of Energy issued this
report on November 18, 2011:

"current regulations are potentially insufficient
to protect health and the environment."

REPORT
-‐
SHALE
GAS
PRODUCTION
SUBCOMMITTEE
2nd
90-‐DAY
REPORT

(issued
by
a
federal
panel
on
shale
gas
drilling,

Secretary
of
Energy,
Nov.
18,
2011)
http://www.shalegas.energy.gov/resources/111011_90_day_report.pdf

Air
pollution
from
truck
trafnic
and
diesel
generators

can
cause
impaired
lung
function,
shortness
of

breath,
wheezing,
asthma
attacks
and
premature

death.

Children
and
the
elderly
are
especially

vulnerable.

Ozone is associated with premature death and
believed to promote cancer

"Ozone can travel up to 200 miles beyond the gas
production area (Colborn, et al., 2011). While not a
direct carcinogen, ozone exposure is strongly
associated with premature death and is believed to
promote the development of metastases, thus making
cancer more lethal (Breslin, 1995; Fann et al., 2011).
Exposure to traffic exhaust and petroleum fumes
further potentiates tumor formation and increase
cancer risk (Hanas et al., 2010)."

Acute symptoms of residents associated with odors
from shale gas operations

1. Severe headaches

2. Nosebleeds, persistent and heavy, much different than
the average nose bleed a human carcinogen

3. Full body rash

Childhood cancers linked to air pollution from
combustion processes

"Childhood cancers/leukemia births are closely
associated with high atmospheric emissions from
combustion processes, mainly oil based, and from
organic evaporation. Demonstrated associations with
1,3 - butadiene, dioxins, and benz(a)pyrene, but
possibly others as well, are probably causal. Such
toxic emissions may account for a majority of all
cases. "
Knox, E.G. 2005. “Childhood cancers and atmospheric carcinogens,” Journal of
Epidemio. Community Health. 2005:59:101-105. p. 101,

http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1733004/

Lung, breast, and bladder cancers linked to air
pollution

“Fracking pollutes the air with known and suspected
human carcinogens. Air pollutants from fracking take the
form of diesel exhaust (from trucks, pumps, condensers,
earthmoving machines, and other heavy equipment) along
with volatile organic compounds, including benzene
(released from the wellheads themselves) and formaldehyde
(produced by compressor station engines). Exposure to
these air pollutants have been demonstrably linked to lung,
breast, and bladder cancers (Brody et al., 2007; Liu et al.,
2009).

We now know that shale gas development blankets
distant communities downwind with known carcinogens
& asthma-causing smog.

Childhood asthma associated with shale gas sites
in the U.S. State of Texas

Texas
hospital
records

in
six
counties
with
some
of
the

I

heaviest
shale
gas
drilling,
including
the
Barnett
Shale

region,
found
that
"children
in
the
community
ages
6-9

are
three
times
more
likely
to
have
asthma
than
the

average
for
that
age
group
in
the
State
of
Texas."

Baylor
University’s
results
published
in
2009
showed

that
childhood
asthma
rates
in
the
Tarrant
County
area

of
the
Barnett
Shale
were
more
than
double
the
national

average.

Cancers associated with oil and gas sites
in the U.S. State of Colorado

“Using
US
EPA
risk
assessment
tools
to
examine

carcinogenic
effects
of
air
quality
at
oil
and
gas
sites,

researchers
in
Colorado
found
excess
cancer
risks
from

air
pollution
alone
(from
5
to
58
additional
cancers
per

million).
At
86
percent
of
these
sites,
the
human

carcinogen
benzene
was
found
at
hazardous
levels.

Airborne
concentrations
of
other
carcinogens
were

also
elevated
(Witter
et
al.,
2008).”

One
canary
in
the
coalmine
for
shale
gas
development

may
be
breast
cancer.

Although
the
breast
cancer
rate
is

dropping

in
many
parts
of
Texas,
the
incidence
of
breast

cancer
is
rising
in
parts
where
the
shale
gas
industry

exists.

“According
to
the
Texas
Commission
on
Environmental

Quality's
2010
inventory
of
gas
production
equipment
in

the
24
counties
of
the
Barnett
Shale,
the
same
six
counties

with
rising
rates
of
invasive
breast
cancer
also
have
the

highest
count
of
compressors,
separators,
tanks
and
other

above-ground
points
of
emissions.”

Looking
at
the
map
of
254
counties
in
Texas,
“You
will

notice
that
the
counties
in
which
you
have
heavier
drilling

activity
perfectly
matches
the
jump
in
breast
cancer
rates.”

http://www.damascuscitizensforsustainability.org/2011/09/breast-cancer-rates-jump-in-the-barnett-shale/
Breast Cancer Rates Jump in the Barnett Shale
September 3, 2011

And
new
research
out
in
March
2012
shows
that
a
dose

response
which
is
signinicant
because
it
is
associated
with

a
high
correlation
of
the
health
effect
to
the
source
of
the

toxin.

Their
report
includes
health
data
of
those
living

about
a
half-‐mile
from
the
shale
gas
wells,
together
with

air
pollution
data
collected
for
three
(3)
years:

Colorado School of Public Health released results
from their 3-year study on March 19, 2012:

"We also calculated higher cancer risks for residents
living nearer to the wells as compared to those residing
further [away]. Benzene is the major contributor to
lifetime excess cancer risk from both scenarios."

(in
an
upcoming
edition
of
Science
of
the
Total
Environment,

Dr.
Lisa
McKenzie,
lead
author)
http://ecowatch.org/2012/study-‐shows-‐air-‐emissions-‐near-‐fracking-‐sites-‐may-‐impact-‐health/

The
ninal
and
the
single-‐largest
health
threat
is

climate
change.

Our
atmosphere
is
now
moving
past

400ppm
and
our
children
will
see
CO2
levels
move

past
550ppm
by
2050.

The
latest
climate
models

(March
2012)
predict
that
temperatures
could
rise

by
3*C
by
2050,
and
6*C
by
2010,
based
on
mid-‐
range
emissions.

For
the
future
health
and
security
of
our
children
and

grandchildren,
the
data
from
climate
change

scientists,
including
NASA’s
James
Hansen,
prove
that

we
must
leave
coal
and
unconventionals
such
as

shale
gas
in
the
ground.

Faith Birol, Chief Economist for the International
Energy Agency (IEA):

“When I look at this data, the trend is perfectly in line
with a temperature increase of 6 degrees Celsius [11°F],
which would have devastating consequences for the
planet.”

“Even school children know this will have catastrophic
implications for all of us.”

4. Obligations to the public - “precautionary principle”

Public health and safety

“Home
Rules”

Two
higher
court
decisions
in
the
United
States
have

recently
ruled
that
municipalities
have
the
right
to

ban
high-‐impact
industrial
activity
such
as
shale
gas

operations.

To
date,
154
municipalities
in
New
York
State

have
passed
a
ban
or
moratorium(or
in
the
process

of
doing
so).

90%
of
these
cities
and
towns
are

located
on
the
Marcellus
Shale.

Fundamental obligations to follow
the precautionary principle

The Physicians, Scientists and Engineers for Healthy
Energy recommended a U.S. national moratorium
on fracking until human health impacts are
researched.

Physicians
Scientists
&
Engineers
for
Healthy
Energy
http://www.psehealthyenergy.org/

Under the Municipalities Act, it clearly states
their obligations:

“36(2.1)

A
councillor
of
a
municipality
shall

(a)
consider
the
welfare
and
interests
of
the

entire
municipality
when
making
decisions

(b)
bring
to
the
attention
of
council
matters

thatmay
promote
the
welfare
or
interests
of

the
municipality,”

(page
65)

http://www.canlii.org/en/nb/laws/stat/rsnb-‐1973-‐c-‐m-‐22/
latest/rsnb-‐1973-‐c-‐m-‐22.html

Fundamental obligations to protect
public health and safety

- duty to protect citizens from unnecessary &
easily avoidable health risks

- duty to protect our air from contamination

- duty to start a monitoring program for volatile
organic compounds (VOCs) in Fredericton

5. Recommendations:

Ban Shale Gas Development in UNB Woodlot and City;
Resolution for a Ban to UMNB and Province;
Implement Air Monitoring of VOCs.

Recommendations:
To ask our individual Councillors for a public
debate and vote by Council:

(1) to ban high-impact industrial land use, including shale
gas development, from the Fredericton city limits;

Cities in New Brunswick have the power to regulate their
own zoning by-law. Each city have their own unique land
use controls, which makes sense when you consider that
cities actually look different from one another. The
Province of New Brunswick does not take a cookie-cutter
approach to controlling land use. My own house is in a
residential block zoned 'TP-3A', a zone unique to
Fredericton and not found elsewhere in New Brunswick.

Fredericton updated its own Municipal Plan in 2007 and
this plan was approved by the Province. Under the
Community Planning Act, our city has the autonomy to
make their plan work using various land use instruments.
In addition to the Zoning By-law, Fredericton has control
over its subdivision by-law, building by-law, deferred
widening by-law, & controlled access street by-law.

Recommendations:


(2) to adopt resolution asking the Union of the
Municipalities of New Brunswick (UMNB), and the
Provincial Government, to ban shale gas development
from the province; and

Recommendations:


(2) to adopt resolution asking the Union of the
Municipalities of New Brunswick (UMNB), and the
Provincial Government, to ban shale gas development
from the province; and

(3) to implement air monitoring of volatile
organic compounds (VOCs) in Fredericton.

BASELINE
&
ONGOING
AIR
MONITORING
OF
VOCs

Sampling:

VOCs
are
monitored
using
a
6
L
stainless

steel
electropolished
(SUMMA)
canister.
Air
samples

are
collected
by
drawing
air
into
the
canister
at
a

constant
rate
(10
to
15
mL/min)
for
a
24-‐hour
time

period.

Analysis:

The
SUMMA
canisters
are
sent
to
Ottawa

and
tested
for
over
150
hydrocarbon
species
(e.g.

Environment
Canada
Environmental
Technology

Centre).

6. Alternative economic development strategies

Recommendations:
These initiatives will create substantially more long-term
jobs AND improve our quality of life:

1.

Invest
in
a
strong
education
system
(early
learning
to
trade
colleges
and
universities).

2.

Establish
Low-‐Carbon
Infrastructure
Investment
Funds
owned
by
Pension
Funds.

3.

Community
forest
ownership.

4.

Implement
policies
for
the
manufacture
of
community
value-‐added
forest
products
for

NBer's
first
(e.g.
wood
fibre
insulation
for
energy-‐saving
building
retrofits
and
construction).
5.
Implement
a
strong
industrialization
policy
across
all
levels
of
government.

6.
Implement
community
economic
development
investment
funds
(e.g.
CEDIFs).

7.
Reverse
personal
and
corporate
tax
reductions.

8.
Establish
ninancial
instruments
for
renewable
energy
in
cities.

9.
Develop
an
international
tourist
industry
-‐
biking,
cross-‐county
skiing,
river
tours
etc.

Make
New
Brunswick
the
“Costa
Rica
of
the
North”.
10.

Implement
strong
policies
to
encourage
local
food
production.
11.

Phase
out
subsidies
to
oil
and
gas
companies.

12.

Implement
a
modest
carbon
tax
(e.g.
$10/ton
CO2).

Some recommended presentations:

(1)
Jan.
10
Statehouse
Fracking
Protest
Part
2.mov
(powerful
&
moving
10-‐
minute
speech
by
Ohio
woman
on
shale
gas
and
her
serious
health
problems)
http://www.youtube.com/watch?feature=player_embedded&v=6hB33D105ak

(2)
Dr
Anthony
Ingraffea
in
Moncton
NB
Part
1
of
3
(Dr.
Ingraffea
is
an

engineering
professor/researcher
at
Cornell
University,
one
of
the
founding
fathers
of

hydraulic
fracturing
technology,
and
an
expert
on
well
casing
integrity.)
http://www.youtube.com/watch?v=sD7koag4QqE&feature=related

(3)
"Finishing"
a
gas
well
in
Dimock,
PA
(huge
air
emissions
coming
from
well)

http://www.youtube.com/watch?
v=DRkEmyofXwM&list=UU7Eph33czawYR2ZKZrexS0Q&index=11&feature=plcp

(4)
Be...
Without
Water?
(New
Brunswick
documentary
about
how
local

communities
are
treated
by
gas
industry,
42:58)
http://www.youtube.com/watch?NR=1&v=aK0NMTMXHSw

Some important quotations:
“If
you
were
looking
for
a
way
to
poison
the
drinking
water
supply,
you
couldn’t

?ind
a
more
chillingly
effective
and
thorough
method
of
doing
so
than
with

Hydraulic
Fracturing”

(Dr.
Paul
Hetzler,
NY
Dept
of
Environmental
Conservation)

“We
can’t
afford
multi-million-dollar
water
pollution
cleanups
or
earthquakes

that
could
pose
risks
to
homes
and
health.”
(Dusty
Horwitt,
Senior
Counsel
and

chief
natural
resources
analyst
at
Environmental
Working
Group,
U.S.
Geological

Survey,
in
April
2012
study,
published
by
the
Seismological
Society
of
America)

"The
situation
we're
creating
for
young
people
and
future
generations
is
that

we're
handing
them
a
climate
system
which
is
potentially
out
of
their
control.

We're
in
an
emergency:
you
can
see
what's
on
the
horizon
over
the
next
few

decades
with
the
effects
it
will
have
on
ecosystems,
sea
level
and
species

extinction."
(Dr.
James
Hansen,
Director
of
NASA's
Goddard
Institute
for
Space

Studies,
April
2012
lecture
at
Edinburgh
International
Science
Festival
)

Friends of the UNB Woodlot
unbwoodlot.org
Brochures & Form Letters:

http://www.slideshare.net/friendsoftheunbwoodlot
(or simply Google ‘slideshare’ ‘unb woodlot’)

Contact Information:

E-mail: friendsoftheUNBwoodlot@gmail.com

Website maintained by Fredericton Chapter of Conservation Council: www.unbwoodlot.org

Facebook: "I don't want the UNB woodlot turned into Big-Box Strip Malls"

YouTube: search for "UNB Woodlot"

Website: www.smartgrowthUNB.ca

Friends of the UNB Woodlot - 2nd Presentation to the Public Safety and Environment Committee, City of Fredericton (April 06, 2012)

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