Thursday, December 31, 2015

42-Point Air Pollution Control Action Plan for Indian Cities



On Average, Everyday, 15% (~500) Buses are Not Utilized in Delhi


Even as the city grapples with the extra strain on public transport during the odd-even days, at least 400 to 500 buses lie unutilised at depots at any given point. The reasons range from poor maintenance to missed trips. This is, at times, equal to the total bus fleet in some of the smaller cities. According to an analysis by Centre for Science and Environment (CSE), the number of passengers availing the DTC bus service is stagnating. If DTC were to utilise its entire fleet, complete all scheduled trips and eliminate missed trips, it can carry at least 25 lakh additional passengers daily. More @ Times of India

Thursday, December 24, 2015

Delhi Government Initiatives.... Exemptions to Odd/Even Rule from January 1st, 2016


Delhi announced the Odd/Even restrictions to control pollution between January 1st, 2016 and January 15th, 2016. Here is the list of exemptions listed @ Times of India
  • CNG vehicles
  • 2-wheelers
  • Cars driven by women and those carrying the differently-abled
  • Cars being accompanied by children up to the age of 12
  • Cars being driven in case of medical emergencies would be treated on "basis of trust"
  • VIP vehicles
  • Vehicles bearing defence ministry number plates
  • Vehicles bearing Special Protection Group protectees (SPG) 
  • Emergency and enforcement vehicles such as ambulances, fire brigade, police vehicles, transport department

    Violators would attract a penalty of Rs 2,000

Tuesday, December 22, 2015

Delhi Government Initiatives....600 of the Quoted 6000 Buses Acquired for the Odd/Even Experiment


The government’s plan to ply 6,000 private buses during the implementation of the odd-even policy has, so far, generated little response from the intended participants. A little over 600 private buses, or one-tenth of what Chief Minister Arvind Kejriwal announced, have turned up for the odd-even initiative that aims to battle pollution. What’s more, the government has had to issue a circular to schools to offer their buses for the drive.

Read more @ Indian Express

We estimated the need for 13,000 buses for a smooth transition and operations during this experiment.

Human Fingerprint of Global Air Quality (NASA)

A Year in the Life of Earth's CO2 (NASA)

Monday, December 21, 2015

Kathmandu Choking

With air pollution hitting hazardous levels in Delhi and Beijing, the respective governments are scrambling to put in place desperate measures to control emissions. But in Nepal’s capital city Kathmandu, which also chokes beneath a blanket of pollution, there is neither data nor any proper information available regarding air quality. The government seems to be in a fog about the presence of harmful pollutants, including particulate matter (PM) and dust particles that could cause cancer, in the air that the Valley denizens are breathing. The level of exposure and extent of threat to public health due to the pollution largely remain unknown.

Kathmandu to Thrashmandu !!


“The winter concentrations of particulate matter, dust, dirt, soot and smoke, along with diesel exhausts, are high,” said Jagadish Bhakta Shrestha, Director General at the Department of Environment (DoE), the authority responsible to make public air pollution status. “However, at the moment, we are not in a position to say the status of air pollution and its effect on public health.”

“We are already overwhelmed with the programmes to implement and with limited human resources and funds, we are unable to priortise our activities,” he added. Various independent researches carried out at different intervals have stated that Kathmandu residents are already “choking”.

What is a Diesel Particle Filter (DPF)?

A diesel particulate filter (or DPF) is a device designed to remove diesel particulate matter or soot from the exhaust gas of a diesel engine. In Europe, the exhaust emissions standards for new cars have effectively required fitment of a DPF in the exhaust of all diesel cars since 2009, when the 'Euro 5' standard came into force. In fact, many cars registered before 2009 will have had one fitted too in anticipation of the change in standards. Standards aim to deliver an 80% reduction in diesel particulate (soot) emissions.




Can India adapt DPF's to control PM pollution from diesel vehicles?
An analysis was presented as part of the India-California Air Quality Management (ICAMP) program assessment report.

Road Ministry of India Proposes to Scrap all Trucks and Buses More Than 8 Years Old





Number of PM2.5 Monitors in China

China has gone from having monitors for small airborne particulate matter in only 47 cities in 2002 to monitors in 367 cities in 2015. This year, China also revised its air crisis policy, originally announced in 2013. It requires officials to raise the red alert whenever the air quality index is forecast to rise above 200 for 72 straight hours. The red alert allows for the suspension of industrial production and vehicle use. Read more NY Times


Friday, December 18, 2015

Monitor Your Air Quality - India Spend Breathe Program

India's first independent, streaming air quality monitoring network built on low cost devices.

Now operational in Delhi and Mumbai.

Monitor Your Air Quality - Laser Egg (Sold Out)



From Origins-China

Comparing Public Transport in Delhi, Bengaluru, and Chennai

In its efforts to get people off private transport and check air pollution, Delhi wants to increase the contribution of its public bus service. But the entity that operates this service, the Delhi Transport Corporation, is the worst-performing of the five city bus services in India whose fleet size exceeds 1,000. And it’s not the availability of buses or revenues that is killing DTC. It is fleet and cost management—areas in which it could learn a thing or two from its peers in Bengaluru and Chennai.

More @ Live Mint




Delhi Government Initiatives... Vacuum Cleaning to Start on April 1st, 2016



Thursday, December 17, 2015

Particulate Matter Pollution in Delhi - 2012 to 2014 (Average of DPCC sites)

For a copy of archived hourly monitoring data visit http://www.delhiairquality.info/monitoring-data 

In Gurgaon, Nearly 100,000 Suffer from Shortness of Breath Everyday

Authorities in the National Capital Region (NCR), despite various formulas like car-free day and the proposed odd-even formula have not been able to check the rising air pollution in the region leaving several people's lungs affected. Over one lakh cases of asthma and various other respiratory diseases emerged in Gurgaon from January to October 2015. These include over 53,000 cases registered in the out-patient department of the city civil hospital alone. Besides this, around 46,000 patients, who were suffering respiratory ailments, consulted different private hospitals.

More @ India Today

An alarming five per cent of the city's 20 lakh population suffers from shortness of breath, below par lung capacity and obstructive airway diseases like asthma. The quality of air in the Millennium City has deteriorated owing to the huge volume of vehicular movement and large number of industrial units that release toxic effluents into the air leading to a variety of respiration-related ailments. According to available data, in 2014, there were 26,149 respiratory patients who came to the civil hospital and this number rose sharply in the past 10 months to 27,291. There was a 25 per cent rise in the number of such patients in private hospitals.

"It has been observed that there is a 20 per cent increase of respiratory patients in last two months and with winter setting in and the fog intensifying, the frequency of patients is expected to rise in the next 40 days," said Kanta Goyal, PMO of Gurgaon civil hospital. She added that people will have to avoid morning walks as the quantity of smoke is much higher during the time in winters.

Air pollution or traffic-related air pollution and indoor air pollution caused by passive smoking and biomass fuel combustion is associated with the development of Chronic Obstructive Pulmonary Disease (COPD). The situation is particularly bad in NCR, where the recent pollution levels have been reported to be much higher than the acceptable limits on most days of the year, sometimes as high as 35 times the normal limits.

Though, the Gurgaon civil hospital is generally frequented by patients belonging to the lower income group and labourers for respiratory problems, the situation in people of the elite class is not different.

Real Time Air Quality Data Archive


http://www.openaq.org

For a copy of archived (since 2013) hourly monitoring data from Delhi's DPCC stations, visit http://www.delhiairquality.info/monitoring-data 

Wednesday, December 16, 2015

Cheapest Parking Space is in Mumbai and Delhi


A report on parking rates in Delhi @ CSE

Infographic - Restricting Vehicle Movement for Better Air Quality in Delhi


CSE's Body Burden 2015 Report

Air pollution is one of the top 10 killers in the world and is the fifth leading cause of death in India. It results in about 620,000 premature deaths which are caused by stroke, chronic obstructive pulmonary disease, ischemic heart disease, lower respiratory infections and trachea, bronchus and lung cancer, among others. The report highlights the heightened vulnerability of the poor. It calls for stringent actions on air pollution.

The report has gone into areas such as vehicular pollution, industrial pollution, polluting cook stoves that cause indoor pollution, and related issues. The report states: “Death toll due to uncontrolled air pollution-related illnesses alone has increased worldwide by a whopping 300 per cent in the last decade: from 800,000 in year 2000 to 3.2 million in 2012… In Delhi, which was named as the most polluted city of the world by WHO in 2014, air pollution is responsible for 10,000 to 30,000 annual deaths.”

“The way forward would be to reduce the source of air pollution—mainly revamping our transportation systems and forcing the industry to come up with cleaner technologies. But people are not aware of these linkages and continue to junk public transport,” said Narain.

Violations of Air Quality Standards in Indian Cities


Sucking Pollution for Better Air Quality... Is that Really Possible?


Best option is to cut the emissions at the source, not at our nose

Monitor Your Air Quality - One of Many DIY Kits

Monday, December 14, 2015

Delhi Government Initiatives... Don't Burn Garbage


Fighting Climate and Air Pollution Together

Actions to help climate change do not always help air pollution. One conflict area is wood heating. This is becoming increasingly popular across Europe as a low carbon fuel but it produces a lot of air pollution. This is especially true of open fires where most of the heat is wasted too. Modern stoves and wood chip burners perform better but it is difficult for any wood burner to match the low pollution from gas heating.

Article from the Guardian

Diesels cars are sold, and taxed, on the basis of lower carbon dioxide (CO2) emissions when compared with petrol cars. But diesel car owners are not getting the fuel economy shown in tests. This means more CO2 than expected, and diesels also produce sooty sunlight-absorbing exhaust. We are paying a huge public health cost for the diesel cars in Europe and it is unclear if they are helping climate change at all.

Improved energy efficiency helps climate, air pollution and fuel poverty. Swapping car trips for public transport, walking or cycling works well and also produces massive health benefits from increased every-day exercise. Coal, heavy and unconventional oils are worst-case fuels for both air pollution and climate, due to carbon intensity and black carbon soot particles. Renewable energy and smart grids are therefore win-wins. Methane from agriculture, landfills, coal mines, gas leaks and fracking isoverlooked as a climate-warming gas and for the dangerous ground-level ozone that it creates.

Post Paris, we have a great opportunity to control climate change and reduce the global health burden from air pollution, but only if the right choices are made.

Car Restrictions in Mexico City and Bogota


Several cities around the world, including Mexico City, Bogota, Sao Paulo and Santiago, have implemented licence-plate restrictions in various forms. Mexico City’s story resembles Delhi, where car restriction was started to counter the extremely high pollution levels in winter. The idea originated when air pollution levels were seen to drop significantly on car-free days, similar to Delhi’s Raahgiri initiative, where small sections of roads are car-free on Sundays. Vehicle restrictions in Mexico City began in 1987 as a voluntary initiative led by an environmental group. By 1989, the metropolitan area of Mexico City was faced with such high levels of atmospheric ozone that the government implemented a programme that banned the circulation of 20 per cent of all private vehicles on each weekday between 5 am and 10 pm. The ban was based on the last digit of the vehicle’s licence plate. Early results were good, with reduced fuel consumption, faster road speeds, etc. However, these gains were shortlived, as by 1995, about 22 per cent people had bought second cars. These second cars became notorious as “chocolate cars” for the colour of their exhaust, as they were cheaper, older, poorly maintained vehicles, bought with the purpose of circumventing the car restriction by those who could afford it.

Interview with Dr. Lucas Davis, Associate Professor at the Haas School of Business at the University of California-Berkeley, on Reuters

Vehicle restrictions were first introduced in Bogota in 1998. Here, 40 per cent of private vehicles were prevented from operating in the city each day between 7 and 9 am and between 5.30 and 7.30 pm. Vehicles having any of four digits as the last digit of their number plate are restricted each day. Over the years, the programme has helped significantly reduce peak-hour congestion in Bogota. While congestion has reportedly worsened in the hours before and after the restriction period, peak-hour travel times have reduced by 40-50 per cent and car users have managed to change their schedules, organise car pools or use taxis. The reason Bogota succeeded where Mexico City struggled was that the initiative in Bogota was accompanied with implementation of the bus rapid transit (BRT) and cycling infrastructure. This ensured that public transport was boosted to deal with the added influx of people and did not choke with the additional pressure.

Impact of Bus and Rickshaw Strike in Delhi

This was observed on April 30th, 2015. Below is the variation in daily PM2.5 concentrations at one of the monitoring sites in Delhi. More news on NDTV


One conclusion is that the role of bus and rickshaw emissions on ambient air quality is small.

Sunday, December 13, 2015

Car Sharing Increasing in Chinese Cities

Car-sharing has been one of the most attention-grabbing trends in urban transport in recent years, as commercial car-sharing clubs like Autolib' in Paris have taken off. But the habit has yet to catch on in Chinese cities.

Yet that may be set to change, as efforts to control toxic air quality have spawned increasingly-restrictive number plate lotteries, no-driving days, and higher parking fees to tackle gridlock and pollution. The steady increase in such measures could make car-sharing more appealing and commonplace in China.

Greater use of car-sharing could also help to popularise electric vehicles (known as EVs) if car-sharing companies choose them for their vehicle fleets, as has happened in Paris. So far, battery-operated cars have struggled to attract significant numbers of buyers in China, the world’s biggest car market, partly because of lack of charging stations and preferences for cheaper, petrol-fuelled models.


Hangzhou, south of Shanghai, is arguably China's most progressive city in terms of experimenting with car-sharing; it has five competing companies where the cost of car-sharing is US$3.25 per hour, more than a taxi, but giving greater comfort and mobility, as well as cutting down on the waiting time to hail a cab at busy times of day. Hangzhou's city government wants to see 100,000 car-sharing vehicles on its roads by 2018.

Read more @ China Dialogue

Time to Attack Pollution from All Sides

Read more @ Economic Times

NGT says, HELP the Farmers in Punjab to Dispose Agricultural Waste Cleanly

Pollution levels in the national capital has seen an upswing with the onset of winter that also sees weak winds. This means that particulate matter in the air lingers for much longer. Burning of crop stubble is seen as a major contributor to Delhi’s pollution woes. Punjab farmers, reportedly, burn almost 15 metric tonnes of paddy straw every year. The National Green Tribunal (NGT) has directed the Punjab government to ensure that agricultural residue is not burnt and help farmers with machinery and mechanism to dispose the waste materials without polluting the environment.
Open fire emissions estimated based from area burnt (satellite data) on a daily basis 

NGT Chairperson Justice Swatanter Kumar in his order (a copy of which is with The Indian Express) said that equipment should be provided free of cost to small farmers having less than 2 acres. For farmers having less than five acres but more than two acres, the price should be Rs 5000 and for the rest, it to be Rs 15,000, the order added.

“Farmers must be educated of how crop residue burning is injurious to human health, causes serious air pollution and is now banned or prohibited by law. They shall also be educated that the agriculture residue can be extracted and utilised for various purposes including manufacturing of boards, fodder, rough paper manufacturing and as a raw material for power generation etc,” mentioned in the NGT order.

Read more @ Indian Express

Saturday, December 12, 2015

NGT says STOP Registering Diesel Vehicles in NCT


Irked with the Centre and the Delhi government for seeking more time to address the issue of phasing out diesel vehicles, the National Green Tribunal Friday directed that no diesel vehicles be registered in the capital till January 6. “In view of the serious contribution of vehicular pollution to the air quality of NCT, Delhi, it is important that the government should take a serious view and a decision (on) whether any vehicle — particularly diesel vehicle (old or new) — should be registered… As an interim measure till next date of posting subject to hearing of all concerned parties, we direct that diesel vehicles of more than 10 years of age as already directed, as well as new diesel vehicles, would not be registered in NCT, Delhi,” directed the bench headed by Justice Swatanter Kumar.

Read more @ Indian Express

Air Pollution in Delhi (BBC)

Friday, December 11, 2015

Delhi Government to Launch 4000 Additional Buses in January 1st, 2016

In the wake of restricted private vehicle movement, 4000 buses will be pressed into service by the state government, as part of its efforts to strengthen the public transport, beginning 2016, when the odd-even scheme for plying of cars and bikes comes into force. The Delhi government has tied up with the Delhi Contract Bus Association (DCBA), an apex body of contract carriage and tourist bus operators in Delhi. Read more @ Business Today

Our estimate is 13,000 additional buses for a smooth transition.


Viewing Pollution from a Hot Air Balloon in Paris


The air quality is officially “good”, 400ft above Paris in a balloon at rush hour. From that height you can see the ring road and many of the city’s 37 bridges blocked with traffic, the commuting trains coming in, and – on the first cold day of winter – water vapour rising from several power stations as thousands of central heating systems fire up. A yellowish haze has formed on the horizon as air pressure builds, but the pollution from Paris’s transport, construction sites and power stations is minimal compared to that of Beijing or New Delhi at this time of year.

Paris measures its air pollution from 20 official sites, one of which is a large helium-filled balloon tethered to the ground with a small measuring device strapped to its base. At 9am at ground level, it registers 66,500 particles in a single litre of air; 400ft up, however, it reads 78,000. The most it has recorded is more than 6m in November 2013 when the city’s fumes were trapped for days in a particular weather pattern.

Read more @ the Guardian

Still a Lot to Learn About India’s Deadly Air Pollution

What exactly is the relationship between exposure to air pollution and its effect on human health? How much cleaner would the air have to be to reduce the health burden of dirty air? Can cities be designed so as to minimize the flow of air pollution? More @ EIN News


There is still a lot that scientists don’t know about air pollution, but the severe pollution common in much of India offers scientists an opportunity to better understand its causes and effects. The Department of Energy’s Lawrence Berkeley National Laboratory researcher Josh Apte is developing some unique approaches to studying air pollution in India and hopes to apply what he learns to developing global strategies for combating it.

Nature of Air Pollution, Sources, and Management in Indian Cities.

Although India uses the same air monitoring techniques that are standard throughout the world to measure ambient air pollution in major cities, such techniques don’t give residents or scientists enough actionable information, in Apte’s judgment. “A big limitation with ambient monitoring is it doesn’t tell you what people actually breathe,” he said. “It gives you some indication of the overall level of air pollution in a city, but it doesn’t tell you where the hot spots are, and it doesn’t tell you the locations where people are getting the bulk of air pollution exposure.”

Air pollution is the number five risk factor for premature death in India, causing three times as many deaths as AIDS and malaria combined. “One thing we can say with quite a bit of certainty is that air pollution is a major risk for premature death in India,” Apte said. “Air pollution now kills more people than poor water and sanitation, which historically has been a major cause of death in India.”

Specifically, the pollutant that is most harmful to human health is fine particulate matter, or PM2.5, for particles that are less than 2.5 micrometers in diameter. These particles are not visible to the naked eye and can be inhaled deeply into the lungs. The U.S. Environmental Protection Agency considers an annual average concentration in excess of 12 micrograms per cubic meter of PM2.5 to be a health concern, whereas average annual levels in India are on the order of 50 to 150 micrograms per cubic meter, according to Apte.

The primary sources of PM2.5 in India are similar to those of other countries—vehicle tailpipes, power plants, and certain industrial processes. Indian cities and rural areas also have significant unregulated sources, including brick kilns, diesel backup generators, trash burning, and wood-burning cookstoves.


To better measure the types and levels of pollutants that people are breathing, Apte hired an auto-rickshaw and drove it around the roads and highways of New Delhi for four months. The vehicle was outfitted with sensors placed at face height to more precisely measure what a person would inhale. He took two- to three-hour trips every day during the morning and evening rush hours.

Apte collected more than 200 hours of real-time measurements of three types of pollutants: PM2.5, black carbon, and ultrafine particles. “The levels of air pollution are truly astounding,” he said. “These are some of the highest levels of air pollution that have ever been measured in traffic anywhere in the world.”


Concentrations of PM2.5 were 50 percent higher on the road than in the ambient air. Concentrations of black carbon and ultrafine particles were 3.6 and 8.4 times higher, respectively. Videos he made while driving through traffic clearly show how a large polluting truck passing by can immediately cause sensors to spike. “Fifty percent is a big increase when you consider that the baseline is already very high,” he said.

The results from the auto-rickshaw study were previously published in Atmospheric Environment. Since then he and other Berkeley Lab researchers have been working on creating a global map showing mortality caused by ambient air pollution and what happens to mortality rates when air pollution is dramatically reduced. “If we have the goal of ultimately removing the burden of disease from ambient air pollution, we need to know how much cleaner we will need to be and what areas of world should be areas of focus,” Apte said.


Eventually he hopes to have a real-time map of pollution in Indian cities to decipher how spatial patterns of air pollution vary around cities. “There’s a lot we don’t know when just looking at air pollution at single points of space,” he said.

Real time air quality index for Delhi

Apte believes that understanding how urban form is related to air pollution can be a promising way to ultimately design cities of the future to minimize both sources of air pollution and exposure to it. “If we can engineer strategies for ‘smart cities’ to protect public health, I think it’s a tremendous opportunity when we think about the growing cities in Asia,” he said.

Apte’s work has been supported by a Fulbright-Nehru fellowship to India from the US-India Educational Foundation, a US EPA STAR graduate research fellowship, and an ITRI-Rosenfeld Postdoctoral Fellowship from Berkeley Lab’s Environmental Energy Technologies Division.

Thursday, December 10, 2015

Bonus for Controlling Emissions @ Coal Power Plants in China

Getting China's cash-strapped coal-fired power industry to comply with tough emissions rules and tackle choking smog that has recently blanketed the capital and other major cities will take incentives as well as fines. 

In a change in tack after years of fining rule-breaking firms, the government said on Wednesday it will pay bonuses from Jan. 1 to those meeting coal efficiency standards. The measures reflect increasing pressure on the world's biggest consumer of energy as leaders meet in Paris to hammer out a global climate deal and a new push to encourage companies to invest in clean, efficient technology to curb air pollution. "It will help to cut coal use and emissions from the sector. And some outdated facilities will be phased out that will ease the power oversupply," said Lin Boqiang, energy researcher with Xiamen University.

Plants that open after Jan. 1 and meet the government's environmental requirements will get an 0.005 yuan per kilowatt hour on top of the basic grid tariff. Those already in operation will get an extra 0.01 yuan per kilowatt hour, which would equate to about 42 million yuan ($6.5 million) if all thermal power output last year had been produced at plants meeting the coal efficiency standards. The higher tariffs will take effect in January and last until the end of 2017, when the government will reassess the rate, the NDRC said.

Read more @ Reuters

Infographic - Coal and Gas based Thermal Power Plants in the Greater Delhi Region


Controlling Ship Emissions

The shipping industry is not only a major contributor to the air pollution choking many port cities, but also, as explained in a front page article in today's New York Times, one of the fastest growing sources of transport greenhouse gas emissions.Shipping is currently responsible for almost 3 percent of global CO2 emissions and over 2 percent of global black carbon emissions, the second most potent climate pollutant behind CO2. Shipping emissions are predicted to grow by 50% to 250% by 2050 depending on future economic and energy developments. A new study by a European Parliament research committee found that shipping could be responsible for 17% of global CO2 emissions in 2050 if left unregulated. In Paris the European Union, the Danish Shipowners Association and many environmental NGOs are calling for an international climate agreement that includes an ambitious CO2 emission reduction goal for the shipping sector in order to help keep warming below dangerous levels. Others are calling for fast action to regulate black carbon and other short-lived but very harmful climate pollutants. Read more @ Huffington Post

Saturday, December 05, 2015

Banning Odd and Even Numbered Vehicles in Delhi for Better Air Quality

Lets be clear that this is a good idea, but an implementation nightmare, if checks and alternate options are not put in place by January 1st, 2016.

When we talk of emissions from road transport, we are looking at three contributing factors

1. number of vehicles (NV)
2. number of vehicle km traveled (in a day or year) (VKT)
3. emission rates per vehicle (EF)

The odd/even rule comes under (1) - cutting the number of vehicles on the road. You cut 50% of the vehicles, you get 50% of reduction in the emissions, assuming that the other two parameters are not changing. But, it is likely that (2) will go up. On a day odd car is banned, the even car could be doing double the number of km, which could bring the reductions back to zero. The best seal proof option is (3). You introduce better fuel, the overall fleet emission rate improves, and achieve complimenting emission and pollution reductions.

This is not to say that technology is the only or the main option. We do need a change in the on-road travel behavior. We want sustained emission and pollution reductions in the city. We need people to not use their car or motorcycle and instead walk, cycle, or go by bus - assuming that all these facilities are in place, to accommodate the transition. 

So, in numbers

50% reduction in NV, 0% change in VKT, 0% change in EF = 50% reduction in emissions
50% reduction in NV, 100% increase in VKT, 0% change EF = 0% change in emissions
50% reduction in NV, 0% change in VKT, 50% reduction in EF = 75% reduction in emissions
50% reduction in NV, 50% reduction in VKT, 50% reduction in EF = 87.5% reduction in emissions

I hope that this rule applies to all the vehicles - cars, motorcycles, light duty trucks, and heavy duty trucks. Otherwise, exceptions (I am sure there will be) will only cut into any possible benefits.