Within the late Sixties, pure gasoline utilities launched “Operation Assault,” a daring advertising marketing campaign to convey tons extra gasoline stoves into folks’s kitchens.
The gasoline utilities referred to as Operation Assault their “most formidable promoting and merchandising program ever.” However because it obtained underway, issues have been changing into public about indoor air pollution from gasoline stoves, together with family ranges of nitrogen dioxide.
Across the similar time, Dr. Carl Shy, a federal public well being researcher, was wanting into the well being results of nitrogen dioxide. In 1970, Shy printed a examine exhibiting that households uncovered to larger ranges of the air pollutant nitrogen dioxide outside had greater charges of respiratory sickness than households in less-polluted areas. The analysis caught the eye of the gasoline utility {industry}, they usually requested Shy for a gathering.
Cornell Watson for NPR
Once they met, Shy heard from the gasoline {industry} one thing Individuals at the moment are studying about, greater than 50 years later: the potential well being dangers from cooking with gasoline stoves. “They’re those who advised me that the gasoline stoves produce nitrogen dioxide due to their excessive temperature,” says Shy, now 91, at his dwelling close to Durham, N.C. “They stated the hoods above gasoline stoves have been actually not highly effective sufficient to drag out the nitrogen dioxide.”
However within the following many years, the gasoline {industry} argued the alternative, asserting that vary hoods may clear up this air pollution. And it has contended that fumes from cooking meals are extra of an issue than the fossil gas air pollution of nitrogen dioxide.
The narrative was a part of a prolonged marketing campaign by the gasoline utility {industry} to popularize gasoline stoves. But because it marketed the equipment, the {industry} additionally financed its personal analysis into the potential harms from cooking with gasoline. These industry-backed experiences confused customers and muddied the science that regulators relied on concerning the potential risks of cooking with gasoline, in keeping with an investigation by NPR and paperwork uncovered in a brand new report from the Local weather Investigations Heart (CIC), a analysis and watchdog group.
Together with materials collected by its personal reporting, NPR reviewed a whole lot of pages of publicly accessible paperwork gathered by CIC that embody scientific research, commerce journal articles and papers from the College of California, San Francisco’s tobacco {industry} archives.
The paperwork present that pure gasoline utilities and their highly effective commerce group, the American Fuel Affiliation (AGA), centered on convincing customers and regulators that cooking with gasoline is as risk-free as cooking with electrical energy. Because the scientific proof grew over time concerning the well being results from gasoline stoves, the {industry} used a playbook echoing the one which tobacco corporations employed for many years to fend off regulation. The gasoline utility {industry} relied on a number of the similar methods, researchers and public relations companies.
The paperwork present that AGA and utility corporations funded research that countered the rising analysis on well being dangers, typically with out disclosing their monetary assist. The industry-backed research centered on uncertainties within the well being analysis and magnified them, leaving the impression that the science shouldn’t be clear, at the same time as proof has collected a few hyperlink between utilizing gasoline stoves at dwelling and larger threat of respiratory diseases.
Analysis backed by the gasoline {industry} generated doubt and controversy over the well being results of stoves that affected policymaking round defending folks’s well being. It helped cease efforts to extra stringently regulate gasoline stoves in a minimum of one occasion below the Reagan administration. And paperwork present the analysis could have helped thwart efforts to strengthen federal nitrogen dioxide air pollution requirements outside, which impacts hundreds of thousands of Individuals.
These profitable ways are nonetheless related at present, as state and federal regulators as soon as once more study the well being dangers that come from cooking with gasoline, and as pure gasoline use turns into a flashpoint within the effort to cut back planet-heating emissions.
“I feel it is well past the time that we have been doing one thing about gasoline stoves,” says Dr. Bernard Goldstein, professor emeritus on the College of Pittsburgh Faculty of Public Well being. He researched gasoline stoves, nitrogen dioxide and indoor air high quality within the Seventies. “It has taken nearly 50 years for the reason that discovery of unfavorable results on youngsters of nitrogen dioxide from gasoline stoves to start preventive motion. We should always not wait any longer,” Goldstein says.
“Operation Assault” — a plan to promote extra gasoline stoves
Nitrogen dioxide is a reddish-brown gasoline and is a key component of smog. It could actually irritate airways and should contribute to the event of bronchial asthma, in accordance to the EPA. Publicity to greater concentrations over brief intervals can also worsen respiratory ailments, similar to bronchial asthma.
As gasoline utilities confronted rising scientific and regulatory pushback on the well being results of gasoline stoves, they’ve discovered themselves preventing on a brand new entrance. Pure gasoline is mainly made up of methane, a potent planet-heating gasoline. From the wellhead the place gasoline is produced, by pipelines and to the burner the place gasoline is combusted, the infrastructure leaks methane and worsens local weather change. Throughout the US, cities are passing legal guidelines to restrict new development of pure gasoline pipelines to houses and buildings, and in locations like Ithaca, N.Y., tearing out gasoline techniques utterly. Public concern concerning the well being and local weather results of gasoline stoves now threatens to intestine the gasoline {industry}.
The AGA maintains that gasoline stoves are a “minor supply” of nitrogen dioxide and it factors out that no federal businesses have chosen to control the home equipment for indoor air emissions. It downplays extensively accepted analysis exhibiting an elevated threat of bronchial asthma in youngsters who stay in houses with gasoline stoves. And the group promotes analysis it funded that finds no proof of well being issues.
Introduced with findings from NPR and CIC’s reporting, AGA Chief Govt Karen Harbert didn’t straight deny them. “The pure gasoline {industry} has collaborated with subject material specialists and analysis to develop evaluation and scientific research to tell and educate regulators concerning the security of gasoline cooking home equipment,” Harbert wrote in an e-mail to NPR. “The accessible physique of scientific analysis, together with high-quality analysis and consensus well being evaluations performed independently of {industry}, doesn’t present enough or constant proof demonstrating power well being hazards from pure gasoline ranges,” Harbert writes.
The gasoline range performs an outsized function within the gasoline utility enterprise. It would not use a lot pure gasoline, however home builders and actual property brokers say many patrons demand a gasoline range. That requires gasoline utility service to a house, which makes it extra seemingly clients can even use home equipment that eat extra gasoline, similar to a furnace, water heater and garments dryer. That is why some within the {industry} contemplate the range a “gateway equipment.”
The roots of this return to a almost century-old “cooking with gasoline” marketing campaign. Within the late Sixties, gasoline utilities sought to reverse a pattern towards electrical ranges. “For the primary time within the gasoline {industry}’s lengthy historical past, in 1968 the cargo of gasoline ranges to market fell beneath 50% of the overall vary shipments,” W. Morton Jacobs, then president of AGA, warned colleagues a 12 months later within the affiliation’s journal.
That prompted the AGA to launch “Operation Assault.” The objective of the $1.3 million marketing campaign (about $11 million, adjusted for inflation) was to spice up gasoline vary gross sales 15% within the first 12 months.
As Operation Assault was getting underway, issues about air pollution from gasoline cooking stoves have been rising amongst scientists and regulators.
A couple of years earlier, in 1962, on the Nationwide Convention on Air Air pollution, Dr. Theron Randolph had advised colleagues that the gasoline range was among the many indoor sources of air air pollution making his sufferers in poor health. Randolph, an allergist and researcher within the Chicago space, stated he helped sufferers initially by relocating them from their houses and later by changing 800 gasoline ranges “completely from the houses of extremely prone individuals.”
In 1970, air high quality and smog have been within the information and a authorities advisory committee of utility executives was feeling public strain “to indicate what they’re doing about air pollution.” Committee members recommended at a gathering that “the gasoline {industry} check out the NOx [nitrogen oxides] downside.”
Randolph’s claims, specifically, drew the curiosity of the highly effective public relations agency Hill and Knowlton. Within the Nineteen Fifties, the agency helped the tobacco {industry} manufacture controversy and doubt concerning the hyperlink between smoking and most cancers.
Notes
Fuel utilities have promoted “cooking with gasoline” for almost a century, whereas additionally funding analysis during the last 5 many years that forged doubt over well being dangers. The gasoline range performs an outsized function within the gasoline utility enterprise. It doesn’t use a lot pure gasoline, however home builders and actual property brokers say many patrons demand a gasoline range. That requires gasoline utility service to a house, which makes it extra seemingly clients can even use home equipment that eat extra gasoline.
How gasoline utilities adopted the tobacco technique
Hill and Knowlton has an extended historical past of working with oil and gasoline, relationship again to the Nineteen Fifties. On the time, it proposed a “long-range info program” for the {industry} that included many parts from the agency’s tobacco work, similar to funding its personal analysis after which selling it extensively.
Richard Darrow led Hill and Knowlton’s tobacco accounts, and he was additionally a key participant in its work for the gasoline {industry}, paperwork included within the Local weather Investigations Heart report present. In 1972, at an AGA convention at Disney World in Florida, Darrow defined that he had lengthy consulted for the {industry} and talked about Randolph’s claims that “gasoline home equipment are main indoor polluters.” Darrow advised utilities they wanted to reply. He advised them to “mount the large, constant, long-range public relations packages vital to deal with the issues.”
“Do we all know sufficient about air pollution inside the dwelling? And might we are saying one thing helpful about this downside that might be of assist to the patron?” Darrow requested, earlier than advising the gasoline {industry} to take the lead in explaining to the general public how it will deal with the air pollution challenge. “And we should always do that earlier than the critics take the ground and demand it.”
Darrow was chatting with an {industry} that was already adopting tobacco {industry} ways. Paperwork present the AGA was hiring researchers who beforehand accepted analysis funding from tobacco corporations.
Ralph Mitchell of Battelle Laboratories performed work for the tobacco {industry} and had sought funding for analysis from Philip Morris in 1964 and the Cigar Analysis Council in 1972. Mitchell and colleagues at Battelle and the Ohio State College reexamined earlier research that concluded there have been well being issues linked to make use of of gasoline stoves. Utilizing another, and in some instances controversial, evaluation method, Mitchell’s workforce discovered “no important distinction in reported respiratory sickness between the members of households cooking with gasoline and people cooking with electrical energy.”
Not one of the authors of the 1974 Battelle paper are alive at present to reply questions on their work.
“The analysis in query occurred almost 50 years in the past, and it will be inappropriate to take a position on the researchers’ strategies or conclusions,” stated Benjamin Johnson, spokesman for Ohio State, in an e-mail to NPR. A Battelle spokesman provided the same assertion and wrote that the group “conducts analysis that conforms to the strictest requirements of integrity.”
Figuring out uncertainty and highlighting it
One other technique deployed by the gasoline {industry} centered on uncertainties within the rising physique of indoor air analysis and amplified them. Uncertainty and questions are a part of analysis, however giving them disproportionate emphasis makes the science appear shakier than it’s.
The Fuel Analysis Institute, which funded analysis for the gasoline {industry}, employed the agency Arthur D. Little to provide this sort of materials. Arthur D. Little had a historical past of conducting comparable work for the tobacco {industry}. A 1981 paper accomplished by Arthur D. Little surveyed accessible analysis on the well being results of gasoline stoves however centered on questions the analysis didn’t reply and located the epidemiological information was “incomplete and conflicting.”
The corporate says it would not have entry to information for this venture, performed greater than 40 years in the past. “We’ve no purpose to consider that the GRI report wasn’t performed with the identical excessive requirements of rigor and objectivity with which Arthur D. Little approaches all shopper engagements,” Etienne Brumauld des Houlières, international advertising and communications director, wrote in an e-mail.
The {industry} additionally favored respected scientists who have been thought-about scientifically conservative, for usually desirous to see a bigger physique of proof than their friends earlier than reaching conclusions.
Amongst them is Dr. Jonathan Samet, dean of the Colorado Faculty of Public Well being, who has an extended historical past as an epidemiologist and researcher. A 1995 evaluate produced by tobacco firm Philip Morris concluded that his fame “as an authority in pulmonary medication and epidemiology” was “most likely due a minimum of partially to his scientific conservatism.”
Samet’s 1993 examine of infants dwelling in Albuquerque, N.M., houses discovered no connection between respiratory sickness and the presence of a gasoline range. It was funded by the Well being Results Institute, which acquired funding from all kinds of sources, together with the gasoline {industry}.
Samet says he by no means did analysis for the tobacco {industry} and that it set “a excessive water mark for egregious conduct and discrediting science.” He doesn’t see that very same conduct relating to the gasoline {industry} and well being results of cooking with gasoline.
“Over my profession, there are individuals who felt that I waited too lengthy earlier than maybe saying that X causes Y. However that is as a result of I do not assume we need to have false optimistic determinations,” Samet advised NPR. Scientists say carrying out that in epidemiology might be tough as a result of usually there are a number of components current that may very well be inflicting a well being downside.
On the subject of assessing science that may inform new insurance policies, Samet says it is uncommon that one examine is sufficient to attain a conclusion. “I have been concerned in sufficient of the event of authoritative experiences in numerous contexts to take the view that the fitting technique to perceive what the science exhibits is to place all of it collectively,” Samet says. “And typically, sadly, the reply is that we do not have sufficient. So if that is conservative, that is high-quality.”
As proof across the well being results of gasoline range use has collected, Samet’s views are altering. “If I had a baby who is likely to be notably prone due to bronchial asthma, for instance, then I’d most likely consider carefully about what I may do to make my dwelling safer and a gasoline range could be on that guidelines,” Samet says.
The controversy marketing campaign pays off
Because the gasoline {industry} funded extra analysis, typically with out disclosing that funding, the research grew to become a physique of labor that served as a counterbalance to impartial analysis on the subject. By the early Eighties, that industry-funded work helped shift the burden of the accumulating scientific proof that different researchers and regulators encountered within the {industry}’s favor.
The implications then went past the query of whether or not the usage of gasoline stoves must be extra strictly regulated. The physique of analysis was included in an analysis of whether or not the EPA ought to tighten outside nitrogen dioxide air pollution requirements, too.
A chart in a 1982 EPA evaluation concerning the well being results of nitrogen dioxide air pollution consists of 5 gasoline range research that confirmed “no important distinction” or “no proof” of issues. 4 of the 5 have been funded by the gasoline {industry}, although that went undisclosed in a scientific journal. The Local weather Investigations Heart tracked down {industry} funding for the analysis by references within the AGA’s month-to-month journal and thru a report printed by the Fuel Analysis Institute.
The EPA determined to retain the present normal with out strengthening it and referred to as for extra analysis to cut back “the uncertainties related to short-term well being results.”
Morton Lippmann chaired the EPA’s Clear Air Scientific Advisory Committee on the time, which reviewed the analysis the company used to achieve its conclusion. Lippmann, 91, is a professor emeritus of environmental medication on the New York College Faculty of Drugs and confirms that “the information have been too fragmentary” to achieve a sure conclusion. He says the EPA’s choice to maintain the present normal was a judgment name for the company.
Whereas industry-funded analysis was typical for such evaluations, Lippman tells NPR that not disclosing that funding ought to elevate questions concerning the analysis. “It could counsel that they have been hiding one thing,” Lippmann advised NPR in an interview.
Ultimately the outside nitrogen dioxide normal was tightened, almost 25 years later in 2010, with the promise that it “will enhance air high quality for hundreds of thousands.”‘
A client safety effort is stopped
With the burden of proof it had funded on its aspect, the gasoline {industry} grew to become extra vocal in arguing towards a connection between gasoline stoves and well being issues. A 1982 Fuel Analysis Institute article concludes that it is tough to achieve “dependable conclusions” and that the {industry} group “believes that in buildings with regular air flow charges, emissions from unvented gasoline home equipment don’t trigger any undesirable results.”
Additionally in 1982, the AGA printed an article, “Placing Fuel Vary Emissions in Perspective,” written by a gasoline firm government. It features a chart exhibiting AGA-funded research and no distinction between respiratory sickness charges in gasoline and electrical houses. A chart within the article really exhibits the next fee of respiratory sickness in houses with electrical stoves. The article ends with “it may be concluded that the gasoline vary’s emissions are usually not a supply of respiratory sickness within the indoor setting.”
In 1986, the federal Shopper Product Security Fee (CPSC) was investigating potential well being results from gasoline stoves and requested the EPA for recommendation on the state of science concerning the difficulty. The report by the EPA’s Clear Air Scientific Advisory Committee says, “Human epidemiologic research counsel that publicity could result in elevated respiratory sickness charges amongst youngsters.” However the report additionally included undisclosed, industry-funded research that spotlight uncertainty within the science.
These combined messages within the report discovered a receptive viewers on the Reagan administration’s CPSC, the place appointees have been proud to name themselves “deregulators,” in keeping with then-Chair Terrence Scanlon. He advised NPR he did not keep in mind the gasoline range inquiry however was all the time a “hesitant regulator.” NPR discovered no proof the difficulty was pursued additional on the fee.
Since then, impartial scientists have continued to provide research that offered extra element and proof about how gasoline stoves have an effect on human well being.
A 1992 evaluation by Duke College and EPA researchers discovered that youngsters in a house with a gasoline range have a few 20% elevated threat of growing respiratory sickness. A 2022 evaluation confirmed 12.7% of childhood bronchial asthma instances within the U.S. might be attributed to gasoline range use in houses.
The load of proof is beginning to shift once more, away from the gasoline utility {industry}’s pursuits. Now, it is pushing again with a number of the similar ways that labored to forestall regulation previously.
Tobacco-style ways are nonetheless in use
In 2022, the well being division in Oregon’s Multnomah County reviewed the scientific proof and advisable towards utilizing gasoline stoves. County commissioners held a public remark listening to, and toxicologist Julie Goodman from the agency Gradient was the primary to talk. Gradient is an environmental well being consultancy that largely works for {industry} shoppers, and it has a documented historical past of casting doubt over science on behalf of shoppers dealing with stricter regulation or lawsuits.
Goodman echoed lots of the arguments gasoline utilities and the AGA have expressed, noting that one other “evaluate of the proof signifies that long run common NO2 concentrations in houses with gasoline cooking are usually not of potential well being concern.”
She argued that fumes from cooking meals additionally hurt air high quality and enough air flow can mitigate air pollution. She additionally questioned the worth of “dozens of epidemiology research which have evaluated gasoline cooking,” saying they “actually range by way of their outcomes and their high quality” and that almost all of them “have severe examine design limitations.”
What Goodman didn’t inform commissioners is that the native gasoline utility, NW Pure, employed her to testify. A utility spokesman advised NPR there was no effort to cover her connection to NW Pure and that she was requested to talk due to her broad vary of scientific expertise.
In an e-mail to NPR, Goodman says that whereas her “preparation time and time spent on the listening to was funded by NW Pure,” the views have been her personal. She disagrees that scientists are biased in favor of their funding supply. “All scientific work has a funding supply. This doesn’t imply that each one scientific work is biased or beholden to predetermined conclusions,” she writes. Goodman says she strives “for independence and scientific integrity in all my work” and that disagreement amongst scientists “is a crucial step within the strategy of advancing science.”
However companies like Gradient shouldn’t have a very good fame amongst public well being researchers.
“In my subject, we all know who these teams are, and we all know that work that is achieved by these teams shouldn’t be actually reliable as a result of they’ve by no means taken a stance on the aspect of public well being,” says Laura Vandenberg, professor of environmental well being sciences at College of Massachusetts Amherst. She co-authored a 2021 paper that lists the ways industries and teams use to fabricate doubt about “knowable details.”
Vandenberg says consulting teams similar to Gradient “just about have by no means seen a pollutant that they assume is that dangerous.”
Medical professionals don’t seem persuaded by arguments like Gradient’s. The buildup of research prompted the American Public Well being Affiliation to develop a 2022 coverage assertion that calls gasoline stoves “a Public Well being Concern,” and the American Medical Affiliation warned of an “affiliation between the usage of gasoline stoves, indoor nitrogen dioxide ranges and bronchial asthma.”
Throughout the final 12 months, the AGA continued funding analysis that focuses on and amplifies uncertainties. Gradient printed a examine in April, funded by AGA, that surveys accessible analysis and concludes it “doesn’t present enough proof concerning causal relationships between gasoline cooking or indoor NO2 and bronchial asthma or wheeze.”
Two days later, AGA President and CEO Karen Harbert touted that analysis as an effort “to make sure regulators and policymakers can confidently make selections based mostly on sound information developed utilizing dependable strategies as they method any points associated to pure gasoline.”
The gasoline utility {industry} is ramping up rhetoric and brazenly talks about preventing to avoid wasting its enterprise. In 2021, Harbert advised NPR that her {industry} desires to be a part of fixing the local weather downside and has developed a place assertion on the difficulty. “If the objective is to cut back emissions, we’re all in,” she advised NPR. “If the objective is to place us out of enterprise, not a lot.”
An existential query for gasoline utilities
Fuel utilities face one other sort of strain past well being issues, and it raises questions concerning the future viability of their enterprise: the numerous contributions pure gasoline makes to local weather change.
Beneath the Biden administration, the U.S. has set a objective of reaching net-zero emissions throughout the economic system by 2050. Web zero implies that any planet-warming air pollution is balanced out by efforts to cut back or take away it, like utilizing extra renewable power, for instance.
The AGA has developed a net-zero plan for gasoline utilities. However a rising listing of research, together with these from Princeton College, Lawrence Berkeley Nationwide Laboratory and the Nationwide Academy of Sciences, discover that assembly the net-zero objective would require electrifying buildings, making home equipment extra environment friendly, and powering them principally with emission-free sources like renewable power.
A 2021 report from the consulting agency Brattle Group paints a dire image of the monetary way forward for many gasoline utilities. As governments push to transform to electrical energy in buildings to satisfy local weather objectives, the agency warns of a “dying spiral” as clients migrate towards “electrification.”
Native governments are main the way in which towards electrification. Berkeley, Calif., was the primary within the nation to ban new gasoline hookups in houses and is now defending that in federal courtroom. The California Power Fee (CEC) permitted requirements that require further air flow for gasoline stoves over electrical ones. New York state is banning gasoline stoves and furnaces in most new buildings.
With the gasoline range being a “gateway equipment” for utilities, preserving its place in Individuals’ lives is a precedence for the {industry}. The AGA helps laws to get rid of power effectivity requirements that would scale back the number of gasoline stoves at the moment in the marketplace. And the {industry}’s angst concerning the future was on show at an occasion for contractors final March at Trump Worldwide Resort & Tower in Chicago. NPR obtained a recording of the shows.
“We prefer to say it is an all-of-government method and they’re coming after pure gasoline,” Sue Forrester, AGA’s vp of advocacy and outreach, advised {industry} colleagues. “So that they’re coming in to let you know what sort of range you possibly can have in your home, what measurement burners you possibly can have and what you should use it for.”
Whereas the gasoline {industry} claims it’s being focused by the Biden administration, others have criticized the president for not doing extra to section out fossil fuels, and as an alternative approving new drilling initiatives and boosting pure gasoline exports. The climate-focused Inflation Discount Act that Biden signed final 12 months consists of incentives to assist the oil and gasoline {industry} scale back its greenhouse gasoline emissions.
However the pure gasoline {industry} is the goal of environmentalists who’re pushing to cut back the nation’s reliance on fossil fuels. And advocates centered on kicking gasoline out of buildings to satisfy local weather objectives see alternative within the well being points surrounding gasoline stoves. Colorado-based RMI’s constructing electrification webpage prominently incorporates a report on gasoline stoves. And the group is amongst these pushing the CPSC to control gasoline stoves.
Earlier this 12 months, with the physique of science as soon as once more pointing to an issue, the CPSC launched an inquiry into hazards related to gasoline stoves and proposed options.
“I feel we must be speaking about regulating gasoline stoves, whether or not that is drastically bettering emissions or banning gasoline stoves fully,” Commissioner Richard Trumka Jr. stated in a December webinar. Per week later, 20 Democratic members of Congress wrote to the CPSC encouraging the commissioners to take motion.
Conservatives have latched onto the difficulty and pulled gasoline stoves into the nation’s tradition wars. Sen. Tom Cotton, R-Ark., tweeted “Democrats are coming to your kitchen home equipment,” and Sen. Ted Cruz, R-Texas, tweeted “COME AND TAKE IT.”
Trumka and CPSC Chair Alex Hoehn-Saric tried to tamp down the controversy by saying there was no plan to ban gasoline stoves. Whereas the CPSC inquiry continues, to date no plans to start drafting laws have been introduced. In the meantime, 11 attorneys basic referred to as on the fee to develop air flow and emission requirements for gasoline stoves.
Shy, now retired from the College of North Carolina at Chapel Hill, says latest research have reassured him that the results he noticed early in his profession have been right — that cooking with a gasoline range does include potential well being penalties. That is why he is all the time chosen to have an electrical range in his dwelling.
“I lately did have a selection. I needed to exchange my 40-year-old electrical range, and I changed it with one other electrical range. I would not even have thought-about a gasoline range,” Shy says. At 91 years outdated, Shy says he would not have any preexisting circumstances like bronchial asthma, however “I simply did not need to pose a threat in our dwelling to publicity to a dangerous air pollutant.”