Protecting Communities & the Environment from Landfills, Transfer Stations, and Material Recovery (Recycling) Facilities
Among many other potential threats, CEDS helps people to stop bad waste projects to protect their home, community, and environment. We also help folks find ways of designing the harmful effects out of fundamentally sound waste projects. By waste projects we mean landfills, transfer station, composting, recycling-materials recovery (MRF), sludge disposal and related facilities. Whether you are faced with an existing or proposed facility, we can help you find the quickest, least expensive, yet highly-effective strategy to protect you, your community and the environment. Contact CEDS at 410-654-3021 or Rklein@ceds.org. Please don’t hesitate. Delay almost always decreases the likelihood of success in efforts to to stop bad waste projects.
WHAT IS A LANDFILL, TRANSFER STATION, RECYCLING-RECOVERY-PROCESSING FACILITY?
By solid waste we mean the trash, garbage and the other discards we generate in our homes and places of work. Following is background on landfills and transfer stations.
What is a landfill?
Landfills, which used to be called dumps, are essentially pits or mountains filled with waste and covered with earth. Modern landfills are encased in impermeable liners and caps to reduce, but don’t eliminate, the amount of contaminated liquid seeping from the landfill. These modern landfill are surrounding by a network of wells from which water samples are drawn. The samples are analyzed to detect pollutants that escaped from the lined landfill. Once detected, measures would then be taken to repair leaks and clean-up any resulting contamination.
What is the impact of a landfill?
First of all, landfilling is a waste of a valuable resource that could create jobs and bolster a local economy. Landfills can also pose a severe threat to the health of area residents, lowers the value of nearby homes, pollute ground and surface waters, increase heavy truck traffic on local roads, and create a drain on tax-dollars to minimize landfill impacts forever. For further detail on specific impacts click each of the following:
How to prevent landfill impacts
The best way to stop bad waste projects is not to build them. A number of U.S. towns, cities, counties, and states have set the goal of eliminating the need for landfills (and incinerators) over the next decade or two. This goal is achieved through measures set forth in a Zero Waste plan. This document spells out the steps that reduce the need for landfills by increasing waste recycling, reuse, recovery, and reduction.
Unfortunately, Zero Waste cannot entirely eliminate the need for landfills. Some waste will always remain. To accommodate this need, new landfills should be guided to sites where impacts can be minimized. Click on the following text to learn more about assessing potential landfill sites and minimizing impacts.
What is a transfer station?
As the name implies, a transfer station is a location where waste is transferred from the trucks that collect it from homes or businesses to larger vehicles for delivery to a landfill, incinerator or other facility. Potential transfer station impacts include:
What is a Recycling or Material Recovery Facility (MRF)?
As the name implies, the portion of the waste stream which is recyclable is separated from that which would otherwise go to a landfill or incinerator. While recycling or MRFs provide many essential benefits, all processing should occur within a building with very good air quality control measure and they should not operate near homes.
CEDS research indicated that a minimum 600-foot separation is needed to protect homes from the noise, dust, odors and other harm that can result from recycling or MRFs. For further detail on how to assess safe setback distances in your area see the CEDS Initial Strategy Analysis Project Frank Construction & Demolition Materials Recovery Facility.
How to Stop Bad Waste Projects?
Most waste projects require the approval of either a local or state legislative body, such as a Town Council, Board of Supervisors, County Commissioners, Legislature, General Assembly, and/or a chief executive like a Mayor or County Executive. The approvals may entail inclusion in a solid waste plan along with building, grading, discharge or other environmental permits. Most efforts to stop bad waste projects succeed in a political arena, where citizens have the advantage. While the applicant usually has the advantage in the courts, litigation may be necessary to prevent permits from being granted before the political effort produces victory.
CEDS employees a unique approach known as Politically Oriented Advocacy to win in the political arena. The CEDS Smart Legal Strategies approach can even the odds a bit in courts where citizens tend to be at a disadvantage.
If you wish, CEDS can prepare a strategy analysis to confirm that a waste facility should be defeated and to set forth the steps most likely to stop bad waste projects. An example can be seen by clicking the following title: Brownville Rubble Landfill – Strategy Analysis Example. Chapters 35 to 42 in our free, 300-page book How To Win Land Development Issues provide more detailed advice.
So before you hire a lawyer or any other professionals, give CEDS call. We exist to assist folks who need more help then nonprofits can provide, but are not in a position to invest thousands of dollars in legal action. Our clients are presently winning 90% of their cases thanks to Politically Oriented Advocacy, an approach CEDS developed.
WASTE FACILITY IMPACT DETAILS
While landfills and transfer stations are essential and must exist somewhere, far too many unnecessarily impact neighborhoods and the environment. These impacts may extend several hundred feet to several miles. Following is a summary of the most common impacts prompting folks to seek to stop bad waste projects. Evaluating the potential impact of a proposed facility can be complex and frequently requires professional assistance. For further detail contact CEDS at 410-654-3021 or Rklein@ceds.org.
Landfill Air Pollution & Public Health
Most of the solid waste from our homes, businesses, schools, etc. goes to a municipal landfill. Highly toxic waste can go to a hazardous waste landfill. Debris from building projects and raising existing structures may go to a construction and demolition debris landfill. And incinerator or power plant residue will likely end up in fly ash landfill.
The potential public health effects of these and other landfill types differs. The focus of this webpage is the first category – the municipal landfill. Most of the adverse health effects are attributable to pollutants released to the air.
Many experts believe that 80% or more of wastes traditionally buried in a municipal landfill could be turned into marketable products via recycling, composting and other processes. In fact, a number of counties and cities have adopted Zero Waste plans for ending the need to bury or burn municipal waste over a decade or so into the future. Ironically, one of the factors holding back efforts to end the need for landfills are landfills themselves.
In a number of cases it’s cheaper to landfill waste then to set up the collection and processing facilities required to recycle and compost waste then deliver it to locations where these materials can be put to constructive use. A missing factor from waste management decision-making is the public health costs of landfills. The goal of this webpage is to provide a starting point for those concerned about landfills to demand factoring in this cost.
In the interest of full disclosure, the author of this webpage – CEDS president Richard Klein – is not an expert on landfills or public health. And some might say that I make money by helping those concerned about landfills.
Following are 14 scientific papers regarding the health effects of compounds released from landfills to the atmosphere. Each title is in blue because it links to the study. Following the title is our take on the key findings relevant to the public health effects of landfill emissions. A more detailed document posted at the following link contains the abstract from each paper so the reader can further judge the accuracy of our interpretation of the key relevant findings: https://ceds.org/wp-content/uploads/2020/10/Municipal-Landfill-Air-Pollution-Public-Health.pdf. Most papers include contact information for the researchers. You should feel free to contact the researchers about the relevancy of their findings to your situation.
- Relation between malodor, ambient hydrogen sulfide, and health in a community bordering a landfill: In this 2011 paper, researchers reported that odors from a North Carolina municipal landfill were strongly associated with alteration of daily activities like going outside, negative mood states, mucosal irritation, and upper respiratory symptoms. These adverse effects were experienced by those living at least 0.75 miles from the landfill. The researchers provided the following: “Although newer landfills may be better designed and operated than older facilities, communities near some Subtitle D landfills continue to report problems with noise, malodor, and animal pests. In the USA (Martuzzi et al., 2010) and North Carolina (Norton et al., 2007), landfills tend to be disproportionately located in areas with lower housing value and larger concentrations of people of color. Poorer housing, lack of air conditioning and clothes driers, and dependence on the local neighborhood for recreation, make low income communities more vulnerable to impacts of pollutants than communities with well-insulated homes where residents have the means to travel to other locations for exercise and entertainment at times when their homes and neighborhoods are affected by malodor.”
- Options for management of municipal solid waste in New York City: a preliminary comparison of health risks and policy implications: In this 2008 paper the researchers compared health risks of New York City Waste-To-Energy (WTE) incinerators to a regional, municipal landfill in Pennsylvania. The researchers also examined health risks among the population exposed to waste as it was transported to a regional landfill. They concluded: “The overall results indicate that the individual cancer risks for both options would be considered generally acceptable, although the risk from landfilling is approximately 5 times greater than from WTE treatment; the individual non-cancer health risks for both options would be considered generally unacceptable, although once again the risk from landfilling is approximately 5 times greater than from WTE treatment.”
- Systematic review of epidemiological studies on health effects associated with management of solid waste: In this 2009 paper, British and Italian researchers concluded that there was limited evidence that those living within two kilometers (1.2 miles) of old landfills were at higher risk for congenital anomalies and low birth weight based on peer-reviewed literature published between 1983 and 2008.
- Health hazards and waste management: In this 2003 literature review of 48 studies, a British researcher found there was insufficient information to assess the effect of new waste disposal technologies on mitigating health impacts.
- Analysis of odorous compounds at municipal landfill sites: In this 2009 paper, researchers reported that odorous compound concentrations from facilities in France and Poland were affected by “failures of the landfill gas collection system, heavy truck traffic, machinery operations and compacting fresh waste.”
- Health Effects of Residence Near Hazardous Waste Landfill Sites: A Review of Epidemiologic Literature: In this 2000 paper, a British researcher reviewed 76 epidemiologic studies and noted that a hazardous waste landfill can pose a greater threat to public health than one accepting only municipal waste. However, it is unclear whether the studies included in this literature review were focused on landfills in general or just those restricted to hazardous waste. While increased symptoms of adverse health effects – fatigue, sleepiness, headaches – were reported by those living near landfills, the researcher noted the need for more rigorous study.
- Influence of a municipal solid waste landfill in the surrounding environment: Toxicological risk and odor nuisance effects: In this 2014 paper, Italian researchers reviewed the findings from 61 other studies and noted the possibility that area residents would be exposed to potentially toxic compounds and nuisances such as odors. The researchers studied emissions from a landfill located in Italy. They found that risks for cancer and non-cancer were orders of magnitude below Word Health Organization acceptable levels.
- Environmental Stressors: The Mental Health Impacts of Living Near Industrial Activity: In this 2005 paper, researchers used U.S. Census and Toxic Release Inventory data to assess the mental health effects of living near a number of “industrial activities” including landfills. The researchers found that living close to industrial activities has a negative impact on mental health. They also found the impact is greater for minorities and the poor.
- Public perception of odour and environmental pollution attributed to MSW treatment and disposal facilities: A case study: In this 2013 paper, researchers reported that once an Italian landfill closed area residents reported fewer odors.
- Residential Proximity to Environmental Hazards and Adverse Health Outcomes: This 2011 paper, presented a review of the numerous environmental hazards – including landfills – that may adversely affect public health. The authors concluded: “Government agencies should consider these findings in establishing rules and permitting and enforcement procedures to reduce pollution from environmentally burdensome facilities and land uses.”
- Risk of adverse birth outcomes in populations living near landfill sites: In this 2001 paper, British researchers reported a small excess risk of congenital anomalies and low and very low birth weight in populations living with 2 kilometers (1.2 miles) of municipal landfills.
- Risk of congenital anomalies after the opening of landfill sites: In this 2005 paper, British researchers reported an increased risk of births with congenital malformations among those living within 4 kilometers (2.4 miles) of landfills. The researchers cautioned though: “Causal inferences are difficult because of possible biases from incomplete case ascertainment, lack of data on individual-level exposures, and other socioeconomic and lifestyle factors that may confound a relationship with area of residence.”
- Adverse pregnancy outcomes near landfill sites in Cumbria, northwest England, 1950-1993: In this 2003 paper, British researchers reported an increased risk of death from “other congenital anomalies of nervous system” for those living near a landfill.
- Incidence of cancer among persons living near a municipal solid waste landfill site in Montreal, Québec: In this 1995 paper, Canadian researchers reported an elevated risk of cancer among those living in the landfill vicinity.
A portion of the research addressed in the 14 papers was conducted at landfills that do not benefit from current protection measures like impermeable liners and caps, gas collection and treatment systems, and exclusion of toxic-hazardous waste. On the other hand, as liners and caps fail and collection-treatment system age, the impact of a modern landfill could come to resemble, over time, that of an older facility.
A 2003 paper noted the need to determine if, in fact, new control measures did resolve health impact concerns. It appears that the studies needed to make this determination have not been published. In a 2009 paper it was reported that odorous compounds concentrations emitted from facilities in France and Poland were affected by “failures of the landfill gas collection system, heavy truck traffic, machinery operations and compacting fresh waste.” Detection of odors has been linked to adverse health effects among those living near landfills.
Another issue possibly affecting the applicability of these papers to conditions in the U.S. is that a number of the landfill studies were carried out in other countries. Waste composition and control measures may differ in those countries. Frankly, it is somewhat disconcerting that relatively few studies have been done in the U.S. Lastly, many of the researchers who noted adverse effects called for more thorough investigations to verify their findings. Unfortunately, it appears these more rigorous studies seldom occur.
Now that all the qualifications are covered, you’ll find that many of the papers listed above noted a small but statistically significant increased risk of adverse health effects among those living up to two-miles from municipal landfills. Adverse health effects may also be experienced by those living along the route travelled by trucks hauling waste to regional landfills.
Adverse effects range from nausea to low-birth weight to cancer.
The bottom line is that while we’ll need landfills for the next decade or two, it is imperative that we rapidly expand recycling, composting and other approaches that reduce the need to bury 80% or more of the waste we currently landfill. Otherwise we’ll simply be exposing more of our neighbors – who are likely to live in minority or low-income areas – to adverse health effects and a poorer quality of life.
Lastly, I have a favor to ask of you. Please forward any other research studies which should be added to list above.
Noise Impacts of Landfills, Transfer Stations, Etc.
Sound that disturbs the peacefulness of your home is an apt description of noise. Excessive noise from both landfills and transfer stations can make it difficult to relax, concentrate or share a conversation with others. Early morning or late-night noise can disrupt you sleep. With regard to landfills and transfer stations, the most common noises are from back-up beepers and the clang of tail gates slamming against heavy truck bodies. Public address systems are occasionally another source of noise.
You should insist on a detailed noise study to determine if sound levels will exceed those permitted in your state or locality. If a study is produced and you’d like a second opinion, then feel free to forward it to CEDS. But contact us first at 410-654-3021 or Rklein@ceds.org to let us know its coming. Following are a couple of steps for reducing the more common sources of landfill noise.
In a 2010 report, the National Academy of Engineering cited back-up beepers are one of the top six noise sources associated with behavioral and emotional consequences. Backup beepers and slamming tailgates top the federal Department of Transportation’s list of nighttime construction noise sources.
Alternatives are available to traditional back-up beepers, such as white-noise devices which may be even more effective but cause less disturbance to area residents. The Federal Highway Administration recommended four actions to reduce noise from slamming tailgates:
- Establish truck clean out staging areas;
- Use rubber gaskets;
- Decrease speed of closure; or
- Use bottom dump trucks.
Odor Impacts of Landfills, Transfer Stations, Etc.
Generally, odors from most municipal waste are not too bad. But when the odors are bad they can be offensive at a distance of up to four or five miles. Gypsum wallboard in construction and demolition can release hydrogen-sulfide which has an odor of rotten eggs if it becomes wet in a low-oxygen environment. This sulfurous odor has been smelled up to three miles away. Some industrial or other “putresible” wastes can be pretty horrendous, like those from food processing or sewage treatment plants.
Landfill operators are required to cover wastes with a layer of earth at the end of each day, Daily cover usually keeps odors down. Some of the worst odors occur when its necessary to dig into a landfill to repair liner leaks or gas collection piping.
Deodorants and odor neutralizers are used to reduce nauseating smells. But an active gas extraction system is the most reliable means of controlling landfill odors. Odor Control Blankets made of high density polyethylene (HDPE) liner material are another option. The Blankets are combined with fans to blow odor neutralizing agents across the area. Odorous water is treated with carbon scrubbers.
Property Value Impacts of Landfills, Transfer Stations, Etc.
If landfills and transfer stations can be seen, heard or smelled from a home then it probably lowers property value. Property value can also be depressed if landfills and transfer stations cannot be seen, heard or smelled but a large number of trucks travelling to the landfill pass by a home.
Most studies find that property value increases 5% for each additional mile separating a home from a landfill. A study of three Pennsylvania landfills found that adjacent homes sold for 13% less than comparable houses not located near a landfill. A study of five Ohio landfills concluded that property value is lowered by 3% to 7% in the vicinity of a landfill.
Truck Traffic Impacts of Landfills, Transfer Stations, Etc.
Landfills and transfer stations generate a tremendous amount of truck traffic. An increase in heavy truck traffic can lower property value and increase accidents as well as noise. The noise alone can substantially lower property value when truck traffic increases. The noise from heavy truck traffic lowers property value at a rate 30 to 50 times greater than cars. This is because at 50 feet heavy trucks emit noise 16 times louder than car traffic. With regard to accidents, a fatality is twice as likely when a car is involved in a crash with a truck vs. another car. In a 2008 study, researchers noted an increased cancer risk among those along the routes traveled by trucks hauling waste to a regional municipal landfill. However, the increase was one additional cancer case per 39 million people.
Water Pollution Impacts of Landfills, Transfer Stations, Etc.
When rain or snowmelt enters a landfill and mixes with decomposing waste a highly-contaminated liquid known as leachate can form. A 2002 review of 128 papers listed 133 chemicals detected in landfill leachate. These chemicals can be toxic to aquatic life and may pose a threat to human health including cancer. This literature review noted that the chemical composition of leachate changes over time. However, leachate may remain harmful indefinitely.
Modern landfills benefit from a series of measures to minimize the release of leachate into underlying groundwater or nearby waterways. The measures include a liner beneath and around the sides of the buried waste. A system of pipes at the bottom of the landfill to collect leachate for treatment. When a landfill cell is closed it is covered with an impermeable cap. Finally, the landfill is ringed with monitoring wells to detect significant increases in the release of leachate.
While all of these measures can reduce and delay leachate releases, they cannot prevent eventual water pollution. This is because water must be prevented from coming in contact with the buried waste for hundreds, even thousands of years. Liners have been in use for about 30 years, which is about the same duration as the warranty offered by most liner manufacturers. In the United States landfill owners are only required to monitor and maintain the landfill for 30 years. One study indicated that liner half-life is about 36 years. As holes develop in liners they can be repaired, but this requires excavating buried waste which can lead to severe odor problems. And eventual, catastrophic liner failure may be inevitable.
In the past, landfills designed solely for coal (fly) or other incineration ash were viewed as less of a water quality threat when compared to municipal waste landfills. However, a recent study by the Environmental Integrity Project noted groundwater contamination near 242 of the 265 U.S. coal-fired power plants. Most of the contamination came from coal-ash disposal ponds (92%) or landfills (76%).
GETTING THE BENEFITS OF LANDFILLS AND TRANSFER STATIONS WITH FEWER IMPACTS
In this section we’ll introduce options for minimizing impacts rather then just seeking to just stop bad waste projects. The key to minimizing impacts due to landfills and transfer stations is the minimize the amount and type of waste requiring transfer or disposal. According to EPA:
“In 2013, America recovered about 67 percent (5.7 million tons) of newspaper- mechanical paper and about 60 percent of yard trimmings.”
As of 2013, San Francisco diverted 80% of their waste from landfills while the national diversion rate was 35%. Advocating for aggressive waste reduction, reuse and recycling programs is the best way to minimize the size and number of transfer stations, landfills and waste processing facilities in your area.
In addition to waste minimization, the following measures will reduce waste facility impacts:
- Waste facilities should be located in industrial areas and away from homes;
- If a site is not available in an industrial area, then landfills, composting and related sites should be located at least 1500 feet from homes;
- Most waste facilities generate truck traffic so they should be located where direct access is available to a four-lane road or other major highways, never where trucks must travel residential streets;
- Waste processing and transfer should be done within a building fitted state-of-the-art equipment to control odors, dust, airborne pathogens and allergens;
- The building should have an impermeable floor to prevent groundwater contamination;
- Safety measures must be used that protect workers as well as area residents from excessive noise, such as white-noise backup alarms, rubber- gasketed or bottom-opening truck tailgates; and
- Waste facilities facilities posing a ground or surface water contamination potential should not be located in areas where drinking water would be threatened along with waters support uniquely sensitive aquatic communities.
ASSESSING POTENTIAL IMPACTS FROM LANDFILLS AND TRANSFER STATIONS
The first step is to assess the actual impact to determine if it’s necessary to stop bad waste projects. The process of assessing potential impacts from landfills and transfer stations is kind of the reverse of the criteria given above for Getting the Benefits With Fewer Impacts. Specifically, landfills and transfer stations should NOT be located:
In residential areas;
- Within 1500 feet if waste is handled, transferred, processed or landfilled in the open (not inside a building);
- Where truck traffic will travel residential streets or other roads where an increase in trucks may pose a threat to homes or other motorists;
- Where noise may exceed thresholds that harm quality of life for area residents;
- In areas with nearby wells or surface drinking water sources; or
- Where sensitive aquatic communities may be harmed.
In addition, if a waste facility has been proposed for a site within four miles of your community or in the watershed of a stream, lake, or other aquatic resource you value, then we urge you to aggressively pursue the following quality of life protection measures:
- Ensure that strategies for minimizing the need for another landfill (reduce, recycle, and reuse) being aggressively pursued;
- Assuming full use of waste reduction strategies, is another landfill truly needed;
- Make certain that all reasonable sites have been considered and that the proposed location truly is the best; and
- Carefully scrutinize the design, operation plan, and long term care to ensure that the landfill causes the least impact possible.
HOW TO PROTECT A COMMUNITY FROM EXPANSIONS OF LANDFILLS AND TRANSFER STATIONS
Once landfills and transfer stations are in place they have a tendency to grow. Landfill owners are particularly prone to seek horizontal or vertical expansions as a facility nears capacity. Promises are often made during the initial permitting that a facility will never expand. While these promises may be sincere, the elected officials who make them may no longer be in office as a facility nears capacity.
One way to protect area residents from a never ending waste facility is a side agreement. The agreement is between the facility owners and individual citizens or a citizens group. Following are some of the important MUSTS:
- It must have enforcement mechanisms which do not drain you of funds, time or other resources;
- The attorneys for the waste facility owner should prepare the first draft of the agreement;
- The agreement must be reviewed by an attorney of your choosing, who is paid by you and who has extensive experience with this area of the law;
- The agreement must be notarized and recorded in the land records so it runs with the deed and binds on current as well as future owners of the facility site; and
- The waste facility owner must reimburse you for all expenses.
HOW CEDS CAN HELP
Following are the many ways in which CEDS can greatly increase the odds of winning a campaign to stop bad waste projects and protect you, your family and neighbors from the impact of landfills and transfer stations.
Free Advice By Phone
We’d be delighted to answer any specific questions you have regarding a waste facility. Just give us a call at 410-654-3021. Advice by phone is always available free of charge to those seeking to preserve their home and neighborhood from harm.
Free Plans Review
We can conduct an initial review of facility plans for obvious, potential impacts. We can then suggest possible technical solutions for each impact and suggest strategies for ensuring that the project is not approved until each solution is fully adopted. For those facilities where impacts cannot be resolved, we can suggest how you can research possible strategy options for preventing the facility from opening.
Detailed Analysis of Strategy Options
If you find you lack the time to research strategy options on your own, then we can carry out an Initial Strategy Analysis (ISA). Of course the purpose of the ISA is to determine the quickest, least expensive strategy for resolving your concerns. Generally, the ISA costs $750 to $1,500 and can be completed in two weeks. An example of an ISA can be viewed by clicking the following link: Brownville Rubble Landfill – Strategy Analysis Example.
Following is a bit more background on the CEDS philosophy and approach regarding waste facilities.
While we need a place to put materials which cannot be recycled or reused, the benefits of waste facilities can come at a tremendous cost to nearby residents and the environment. Though technological advances make the landfill of today safer than those of the past, the added safeguards are by no means foolproof much less universally applied.
The following two publications illustrate the approach advocated by CEDS to ensure that the preceding measures are achieved.
- Brownville Rubble Landfill – Strategy Analysis Example
- Citizen Perspectives on Siting Solid Waste Facilities
Additionally, the CEDS Project Evaluation Checklist allows you to assess the quality of life effects of many types of proposed development activities. A number of the impacts listed in the checklist are applicable to landfills, such as air quality, environmental justice, fire, groundwater degradation, historic places, light trespass, noise, odors, property value, traffic, and water pollution. Detail on how to review a project for these potential impacts can be found in our free 300-page book How To Win Land Development Issues. Strategies for defeating a poorly conceived landfill project can be found in Chapters 35 to 42.
CEDS is a nationwide network of attorneys, planners, environmental scientists, traffic engineers, political strategists, fundraisers, and other professionals. We help people with concerns about all types of landfills (municipal, construction-demolition debris, land clearing debris, stump dumps, rubble, etc). We also help those living near existing and closed landfills to reduce facility impacts.
To learn how we can help with the landfill of concern to you, just give us a call at 410-654-3021. Advice by phone is always available free of charge to those seeking to preserve their home and neighborhood from harm. You can also email us at Rklein@ceds.org.