Environmental Law Blog

The federal Environmental Protection Agency reports that 290 million scrap tires are generated each year. Missourians alone generates approximately 5 million scrap tires each year.  A variety of pests, including mosquitoes capable of carrying the West Nile Virus, breed and live in old tires. Tires also take up much-needed landfill space. Tires release harmful pollutants into the environment, particularly if they catch fire. One passenger car tire may produce 2 gallons of oil when burned. And they mar the beauty of Missouri's rolling hills and blight our urban landscapes.  Its easy to see why we have to do something about waste tires.

Missouri law prohibits the dumping of solid waste. Section 260.270.1(1), RSMo. This includes scrap tires. Scrap tires may only be taken to or disposed of at facilities granted permits by the Missouri Department of Natural Resources. Scrap tire haulers and collection points also must have permits issued by DNR. Section 260.270.1, RSMo. Before being disposed of, scrap tires must first be cut, chipped or shredded. Section 260.270.1(6), RSMo. Violations of the tire law may be prosecuted as misdemeanors. Violators may also be ordered to pay civil penalties.

Missouri law imposes a fee of fifty cents for each new tire that is sold in Missouri. Section 260.273.2, RSMo. This tire fee is deposited in the Solid Waste Management Fund, which was established to provide a funding resource that could be directed to a variety of different projects, including cleanup activities and the elimination of illegal dumping operations in Missouri. Section 260.335, RSMo."

The Attorney General's Office has prosecuted numerous cases that lead to the cleanup of illegal scrap tire dumps.  We will continue to work with the Missouri Department of Natural Resources to address waste tire sites when they arise.  If you know about a waste tire site with more than 500 scrap tires, you can submit a complaint to us online by clicking here.

The Lewis and Clark State Office Building, which houses the Missouri Department of Natural Resources, was completed in Jefferson City in March of 2005. This was Missouri's first "green building" to receive the highest platinum ranking awarded by Leadership in Energy and Environmental Design (LEED). The building cost approximately $17 million to construct, but the average energy costs for the Lewis and Clark State Office Building are about half those for the average state building.

The U.S. Green Building Council founded the LEED Green Building Rating System, which is a nationally recognized third-party certification program that supports green building design, operation, and construction. The ratings consist of silver, gold, and platinum. More information about the LEED-certification program can be obtained at http://www.usgbc.org. 

In September of 2005, the Alberici Corporation headquarters in St. Louis became the state's second platinum LEED-certified building. In 2007, St. Louis was ranked #7 in the US for the most LEED-certified buildings. Kansas has received a gold rating for its EPA Region 7 Office located in Kansas City, KS. Illinois is not too far ahead with one gold and two platinum LEED-certified buildings.

Currently Portland, OR and Seattle, WA are tied for the most LEED-certified and registered projects. In 2000, Seattle became the first city in the US to adopt a city-wide sustainable building policy. The policy requires all city construction projects (both new construction and remodeling) over 5,000 square feet to obtain a silver LEED-certification. The city is also encouraging the private construction sector to incorporate sustainable materials and methods into future projects.

It is estimated that green buildings cost about 0.5 to 6.5 percent more to build than a non-green building. This increase in cost can be very significant when applied to large municipal projects, but the long-term savings in energy costs have always been emphasized as the selling point for these buildings. The New Building Institute and CoStar Group both recently released studies confirming that energy savings are significant in LEED-certified and ENERGY STAR buildings. For more details about the two studies, click here.

As we are entering into what some call an "energy crisis" and the price of oil continues to rise, the cost of heating and cooling homes and business is drastically rising as well. Should Missouri's state funded building projects be required to obtain LEED certification? Is Missouri ready to be a leader in sustainable living? How can Missouri government help encourage green building?

The U.S. Environmental Protection Agency strengthened its national ambient air quality standard for ground-level ozone, the primary component of smog. The new rule, which reduced the amount of allowable ground-level ozone from 0.080 parts per million to .075 parts per million took effect on March 12, 2008.

The Clean Air Scientific Advisory Committee, a panel of experts appointed by EPA to make recommendations for the new standard, recommended that EPA lower its standard to somewhere between .060 and .070 parts per million. In spite of the discrepancy between the Committee's recommendations and EPA's final rule, EPA estimates that the revised standards will yield health benefits valued between $2 billion and $17 billion.

According to the EPA, breathing air containing ozone can reduce lung function and increase respiratory symptoms. The increased stress on respiratory systems can aggravate asthma, some heart conditions, lung disease, and other respiratory conditions. Ozone exposure also has been associated with increased susceptibility to respiratory infections, medication used by asthmatics, doctor visits, emergency department visits and hospital admission for individuals with respiratory disease.

In addition to health effects, ozone exposure can cause damage to sensitive vegetation and trees due to reduced growth and productivity, increased susceptibility to disease and pests, and damaged foliage. Ozone exposure can also cause reduced or sub-standard crop yield.

EPA last reviewed the national ambient air quality standard for ground-level ozone in 1997. In light of the twelve-year gap between EPA's ozone studies, should EPA have adopted the stricter standard advocated by the Clean Air Scientific Advisory Committee? Should Missouri support the new standard?

According to the Centers for Disease Control and Prevention ("CDC"), the West Nile Virus is a potentially serious arbovirus (insect-borne virus) that infects the central nervous system. Approximately 150 people infected with West Nile Virus develop serious neurological symptoms from the disease. Approximately 20 percent of people infected with West Nile Virus develop mild symptoms, and the remaining 80 percent of people infected with West Nile Virus do not show any symptoms at all.

In 2007, 77 Missourians reported West Nile Virus illness, and 5 of those people died from the disease. West Nile Virus generally emerges in mid-to-late July, but due to this year's flooding, mosquitos are expected to carry the West Nile Virus starting in June. In fact, the St. Louis Post-Dispatch reported the first case of West Nile Virus in Illinois and Missouri today.

West Nile Virus is transmitted by the bite of an infected mosquito or, in rare cases, through transfusions, transplants or mother-to-child. Mosquitoes become infected when they bite infected birds.

To protect the public from the health threats associated with West Nile Virus, the CDC recommends the initiation of surveillance after mosquitoes become active in the Spring. An effective surveillance program includes bird morbidity/mortality surveillance, live bird surveillance, horse health surveillance, mosquito-based surveillance, and human case activity surveillance.

Are our state and federal health agencies doing enough to monitor for West Nile Virus?  In light of the current flooding and increased risk for infection, should Missouri take the threat of West Nile Virus more seriously and make an enhanced surveillance program an immediate priority?

As Missouri prepares to take on flood water from its northern neighbors, many are left wondering how a 500-year flood could happen twice in 15 years.

The terms "100-year" and "500-year" flood are used to describe the estimated probability of a flood event happening in any given year. Using historic weather and hydrograph data, experts can determine the estimated rate of flow or discharge of a river or creek. A 100-year flood has a 1 percent probability of occurring in any given year, and a 500-year flood has a .2% probability. Though unlikely, it is possible to have two 100- or even 500-year floods within years or months of each other. This is why we are hearing about the 100-year flood of 1993 and the 500-year flood of 2008, even though the floods are merely 15 years apart.

What does this have to do with environmental law, you ask? In 1944, Congress enacted the Flood Control Act, which charged the U.S. Army Corps of Engineers with the duty to provide quality, responsive engineering services to the nation including, among other things, planning, designing, building and operating massive civil works projects. Congress mandated the Corps to manage these projects to serve the dominant purposes of flood control and navigation, and to incidentally benefit a host of secondary purposes including fish & wildlife, water supply and recreation. Although the Corps must sereve many masters, the law is crystal clear that flood control is paramount when purposes collide. Everything else must yield.

Currently, the Corps is working with state and local levee districts to coordinate flood-fighting activities in Indiana, Minnesota, Wisconsin and Iowa. Immediately following the Floods of '93, the Corps planned and executed flood control strategies in all of the areas affected by the Floods of '93. Now we will find out if the Corps' work was sufficient.

The St. Louis Post Dispatch published an article this morning, highlighting Missouri's expected flood levels due to the extreme saturation and catastrophic flooding going on up North. As that water reaches Mississippi River towns, all Missourians can do is wait and hope the Corps's post-1993 flood improvements can withstand the pressure of all that water. Meanwhile, Missourians along the Missouri River and many other swollen tributaries are bracing for flooding, and hoping that this disaster doesn't spread any further.

The Attorney General's Office appeared before the EPA yesterday in order to provide comment on EPA's ongoing review of the National Ambient Air Quality Standards (NAAQS) for lead. (For a "primer" on the Missouri Air Conservation Law, see below).

EPA issued an Advance Notice of Proposed Rulemaking (ANPR), inviting input from interested industry professionals, government officials, and concerned citizens on policy options and other issues related to the EPA's NAAQS for lead. Specifically, EPA asked us (the public) for help in informing the EPA's future decisions on the adequacy of the current lead NAAQS.

The Attorney General's Office responded to EPA's call by agreeing with the Clean Air Scientific Advisory Committee's recommendation to substantially lower the level of the primary (public-health based) lead NAAQS.

The Attorney General's Office further recommended that the EPA evaluate the lead NAAQS based on the highest monthly reading, rather than the second highest, as proposed by some industry groups. Missouri believes that, due to the increased concern in public health circles regarding the gravity of the health risks posed by lead contamination, why not take the most health-protective stance . . . particularly when all data shows that the most vulnerable to lead poisoning are our children?

Finally, the Attorney General's Office recommended that the EPA require current lead contaminant sources to immediately develop new State Implementation Plans (SIPs) if they are located in areas that have been classified as "nonattainment" under the current NAAQs. The EPA's current proposal allows those known sources to use the SIPs developed under the old NAAQs for lead during a grace period of 5 years. The Attorney General's Office argued that these air contaminant sources should be required to immediately start assembling plans to meet the lower standard.

Missouri is the only state in the nation with an ambient air quality region classified as nonattainment for lead. We, therefore, have a much stronger interest in how nonattainment areas are treated under the proposed rule. Do you agree with the Attorney General's position? Or, should the EPA allow all lead sources at least five years to control their emissions?

Environmental problems come in all shapes and sizes.  Some are easy to fix and can be corrected with a little hard work and a shovel.  Others take time, money and expertise--things not everyone has at their immediate "disposal." 

It is easy to say that the responsible person should pay whatever it takes to clean up his or her mess.  Sometimes that is simply not possible.  A penniless person can cause a significant environmental impact without spending a dime just as easily as person who has money but ignores the law.  The law deals with the latter and ultimately solves the problem much more easily than it does with the former.  The law appropriately considers ability to pay, through complex computer models that can examine an individual's finances and determine whether they can in fact pay what is required.  It all comes down to this: when a defendant doesn't have two nickels to rub together, he will not be able to hire an engineer or a contractor to fix the failing drinking water system or wastewater treatment facility.  Another surprisingly common example occurs when the responsible person dies without cleaning up the mess -- and leaves little or nothing in the bank.  Sites like these are known as "widows & orphans." 

Today, we aggressively and steadfastly pursue compliance.  We do the best we can to creatively solve these difficult problems when the opportunity arises, but some sites simply languish.  Missouri needs a "widows & orphans" fund to provide the resources in appropriate cases to solve intractable environmental problems and thereby protect the public.  Short of a dedicated fund established by the state and managed by the AGO, how can Missouri better protect the public from these environmental problems?  Would you support the creation of a "widows & orphans" fund in the state treasury? 

An interesting column appeared in the opinion section of the Columbia Tribune today. The commentator offers several reasons to oppose Concentrated Animal Feeding Operations (CAFOs). We talked about some of the reasons to support CAFOs in an earlier post. What would you say to Mr. Midkiff to rebut his opposition argument?

Across the nation and in Missouri, the improper disposal of pharmaceuticals and other emerging microbial contaminants has evolved into a significant concern.

According to the Missouri Department of Natural Resources, pharmaceuticals enter the environment when medication residues pass out of the body into sewer lines or the items are flushed down the drain and into our wastewater treatment facilities. Pharmaceuticals can include prescription and over-the-counter medicines, dietary aids, any other product consumed by individuals for health reasons. Domestic sewage is considered a major source of pharmaceuticals in the environment. For tips on how to dispose of pharmaceutical wastes without harming your water supply, check out the Missouri Department of Natural Resources fact sheet.

Microbial contaminants are microorganisms that are discharged into wastewater treatment systems after manufacturing, industrial, common household, agricultural or other activities. The United States Geological Survey (USGS) is researching the most common specific sources of these sometimes dangerous contaminants as well as the most common pathways for microbial contaminants to our rivers and streams.

Why are these new contaminants so bad for the environment? Both pharmaceutical and microbial contaminants harm the beneficial bacteria, or "good bugs," that break down waste in septic systems or wastewater treatment plants. These wastewater treatment facilities are not engineered for pharmaceutical or microbial contaminant removal, so the contaminants are then released into nearby lakes, rivers or groundwater.

The USGS first studied the effects of wastewater and combined sewer overflows on national water quality in the Blue River Basin, Kansas City Missouri and Kansas from July 1998 through October 2000. A team of scientists studied the contaminants indicative of wastewater, including antioxidants, caffeine, detergent, antimicrobials, and pharmaceuticals. The team discovered that water quality in the basin was affected by human wastewater during regular periods and heavy rainfall periods, alike, suggesting that wastewater discharges that result from heavy rainfalls do not necessarily increase the likelihood of these contaminants getting into our drinking water-they are already getting there.

The USGS conducted its second national study on the Upper Shoal Creek Basin in Southwest Missouri from 1999 trough 2000. Scientists discovered that concentrations of nitrogen were unusually large, which could be almost entirely attributed to discharge from wastewater treatment plants. Scientists further concluded that the trend of increasing fecal coliform densities corresponded with precipitation rises and consequential human wastewater treatment discharges, rather than changes in land use or animal operations.

Drinking these contaminants through our public drinking water systems can be harmful, but scientists have not yet collected enough data to understand the potential effect of pharmaceutical and microbial contaminants in water on human health. Certain studies have also indicated that fish and plant wildlife are being adversely affected by the presence of these emerging contaminants in their habitats.

Unfortunately, the improper disposal of pharmaceuticals escapes the restrictions on water pollution set forth in the Clean Water Act. According to the Clean Water Act, any entity that causes or permits the pollution of the waters of the United States with a water contaminant constitutes a point source. But, generally, point sources are limited to companies, organizations, or farm operations.

What do you think Missouri should do about this wide-spread, growing problem? Currently, neither state nor local law restrict human disposal of pharmaceutical or microbial contaminants into wastewater treatment systems in Missouri or any other state. However, Columbia has joined several cities around the nation in investigating the pharmaceutical presence in its drinking water. The Columbian Missourian details the investigative plan, according to local health officials, in an April 22, 2008, article. Can you think of a creative solution?

Friday, Yahoo! News posted an article on its homepage highlighting the new organizational trend of cutting workweeks to four days. The companies cited express their desire to reduce fuel consumption, and consequently carbon emissions, as their primary motivation. Secondary benefits include helping their employees make ends meet by reducing their commuting expenses 20 percent and increased employee morale. The Columbia Police Department recently switched to four-day work weeks.  Police Officers now work four days each week, ten hours per day--though law enfrocement continues around the clock. 

The Attorney General's Office is unlikely to benefit from a "four day work week."  Statistically, the AGO employee works longer days on average than her counterpart in any other state agency.  When duty calls, we answer the bell.  The AGO has worked to reduce energy use, however.  For example, we use some flex fuel vehicles in our fleet, reduced the air cooling in our computer server room, use a bulletin board on our intranet site to encourage and facilitate employee carpooling, and so forth. 

What do you think the State of Missouri should do? How would you feel if government office buildings were only open 4 or 5 days a week instead of 5 or 6 days? Would the benefits outweigh the costs or vice-versa? Are carbon-based workplace changes an over-reaction? 

According to the EPA, more than 40% of our assessed waters still do not meet the water quality standards that states, territories, and authorized tribes have set for them. This amounts to more than 20,000 impaired waterbodies, including individual river segments, lakes, and estuaries.

The Clean Water Act protects impaired waters through the TMDL and section 303(d) programs. Under section 303(d), states, territories, and authorized tribes are required to develop lists of impaired waters that do not meet water quality standards despite the implementation of minimum pollution control technologies. The law requires that these jurisdictions establish priority rankings for waters on the lists according to their beneficial uses and develop TMDLs for these waters.

Although someone may try to tell your that "TMDL" stands for "too many darn lawyers", TMDL actually means "Total Maximum Daily Load." A TMDL is a calculation of the maximum amount of a pollutant that a waterbody can receive and still meet water quality standards.  It can be compared to an apple pie.  A baker must follow a specific recipe to prepare and bake an apple pie like Grandma used to make.  And when the pie comes out of the oven, everyone wants a slice and the baker has to divvy the pie up fairly.  Not everyone will be happy with the size of his or her piece.  The same is true with a TMDL.

To develop a TMDL, the state must first classify a waterbody for its beneficial use, i.e., drinking water supply, recreation, or aquatic life support. Once the beneficial uses are established, a TMDL is calculated for particular pollutants according to the waterbody's beneficial uses and the assimilative or carrying capacity of the waterbody. The TMDL must include a margin of safety to ensure that the waterbody can be used for the purposes designated by the state. The state then allocates a percentage of the TMDL to each of the pollutant's sources along the waterbody through the permitting process.  It sounds like a neat and tidy process, but in reality it is very complicated and often challenged by both environmental groups and industry. 

EPA publishes TMDL reports by region and state online.

Until the early 1970s, states, territories, and authorized tribes virtually ignored the TMDL program. That changed when the EPA started to feel pressure from citizen groups and legislators. Now, EPA takes the TMDL program and impaired waters list more seriously. In your opinion, is the TMDL program enough? Should the EPA and states be doing more to protect Missourians from polluted waters? What if the scientists are wrong about the maximum concentrations allowable before harm will occur to human health and environment?

Missouri is known for its beautiful Ozark hills.  Unfortunately, those pastoral hills shelter some unsanitary and poorly-run dog breeding operations commonly called "puppy mills."

The Animal Care Facilities Act (ACFA), located at section 273 of the Revised Missouri Statutes, protects animals in the pet industry by requiring any animal shelter, pound or dog pound, boarding kennel, commercial kennel, contract kennel, pet shop, exhibition facility, dealer or commercial breeder to be licensed and inspected annually.

To work in the animal care industry, potential "dealers" must comply with the Missouri Department of Agriculture's (MDA) regulations that establish standards relating to adequate food water, shelter (including sanitation and ventilation), veterinary care, facility construction, handling, and transportation. The licensee must also keep records per shelters, pounds and dog pounds. Currently, 1,943 licensees are registered with the MDA statewide.

Last March, Attorney General Jay Nixon obtained a court order to stop the owner of a kennel in Gasconade County from selling or shipping any more dogs infected with parvovirus, a highly contagious viral disease. Nixon filed the lawsuit against Safe Haven Puppy Rescue and Rise-N-Shine Kennels, after inspectors from the Missouri Department of Agriculture (MDA) determined that the owner had recently sold and shipped three dogs that were diagnosed with parvovirus. This facility failed to meet minimum health and operating standards under the ACFA. The owner was ordered to rectify those deficiencies.

The Attorney General's Office is set to appear in Gasconade County Circuit Court today (Tuesday) to ask the judge to extend the injunction. If the injunction stands, the owner will not be able to sell any of her dogs in Missouri. And, any dogs already infected with parvovirus will remain quarantined in their kennels.

In this case, the ACFA effectively prevented the spread of a deadly, infectious disease. Can you think of any other measures the State should legally take when dealing with unlicensed dealers?  How can Missouri shake the mantle of being a"puppy mill" state? 

Some may say that all litigation is a nuisance, but that's not what this post is about.  Instead, this is about litigation related to land uses that amount to nuisances for neighboring landowners. 

Once upon a time, the Crown recognized that it was a "nuisance" for villagers to throw garbage and waste into the streets.  What was offensive in one man's house was just as offensive to all in the public streets and rivers.  So, in 1388, the Parliament passed the first known nuisance law. The "Dung Law" spoke in Olde English to today's problems,

"[f]or that so much Dung and Filth of the Garbage and Intrails as well as of Beasts killed, as of other Corruptions, be cast and put in Ditches, Rivers and other Waters, . . . that the Air there is greatly corrupt and infect, and many Maladies and other intolerable Diseases do daily happen, . . . to the great Annoyance, Damage and Peril of the Inhabitants, Dwellers, Repairers, and Travellers . . .; all they which do cast and lay all such Annoyances . . . in Waters . . . shall cause them utterly to be removed, avoided, and carried away . . . every one upon Pain to lose and to forfeit to our Lord the King . . ..

Missouri law largely embraces the ancient concept embodied in the Dung Law.  The Missouri Supreme Court ruled in 1971 that "an owner may use his property as he desires recognizing that same right in another." See Bower v. Hog Builders Inc., 461 S.W.2d 784, 793 (Mo. 1971).  Basically, a nuisance is a land use that unreasonably interferes with another's reasonable use of his or her land.  And this brings us back to another longstanding concept deeply rooted in British law -- and in Missouri law -- that "a man's home is his castle."  

Interestingly enough, a nuisance lawsuit is about preserving and protecting a landowner's property rights.  The law precludes one from using his land in such a way that it unreasonably interferes with another's right to the peaceful use and quiet enjoyment of her property. 

Should this centuries-old rule still be the law of the land?  Can you think of examples where the public good should trump one landowner's right to the peaceful and quiet enjoyment of her property?  More on our property rights later.

Do you know that you can calculate your carbon footprint online? Just go to the Nature Conservancy's website at http://www.nature.organd follow the "Carbon Calculator" link. Whether you agree with the science supporting or weakening the argument for global warming, everyone can agree that Missourians should work to reduce air pollution. Air pollution causes health problems, such as respiratory disease, asthma, lung cancer, and irritation of the eyes, to name a few. Most, if not all, industrial and individual sources of carbon emit additional air pollutants. In fact, electric power plants are the single largest industrial source of some of the worst air pollutants, including sulfur dioxide and nitrogen oxides. Both of these pollutants can cause severe damage to a person's respiratory system, sometimes resulting in death, and both pollutants cause acid rain.

Several states have taken steps to reduce their carbon emissions. In May 2007, Missouri Representatives Beth Lowe and Jenee M. Low referred proposed legislative bill HB 1268, or the Missouri Global Warming Solutions Act of 2007, to the Special Committee on Energy and Environment for research and review. The bill would amend the Missouir Air Conservation Law, located at chapter 643, RSMo., to include eight new sections relating to the reduction of carbon dioxide emissions, with penalty provisions. The bill is still with the Committee, but its drafters clearly had the reduction of Missouri's carbon footprint in mind.

In addition to state measures, individual citizens have taken notice of the carbon emission problem on a national level. To reduce your carbon footprint (and consequently reduce emissions of other harmful pollutants) you can follow these easy tips:

1. Walk or bike instead of driving a car or taking the bus. Cars and trucks run on fossil fuels, which release carbon dioxide into the atmosphere. Automobiles account for more than 20% of the total carbon emissions in the United States.
2. Host a telephone or video conference instead of traveling to a work-related meeting. The burning of jet fuel causes the release of carbon monoxide, which can have cardiovascular effects; nitrogen oxides, a powerful lung irritant; and volatile organic compounds, which can cause eye and respiratory tract irritation, visual disorders and memory impairment.
3. Switch to compact fluorescent light bulbs. Each fluorescent light bulb that replaces an incandescent bulb saves 100 pounds of carbon emissions over the life of the bulb.
4. Recycle, recycle, recycle. And, support the recycling industry by using recycled products as often as you can. Recycled glass, metal, paper and plastic use less energy to manufacture than products made from raw materials. Furthermore, recycled paper saves trees and, consequently, wildlife habitat.
5. Eat locally. Shipping food across the nation results in excessive air pollution emissions. If you eat foods grown locally, much less energy is needed for your groceries to go from the source to your dinner table.

What do you currently do to reduce your carbon footprint? Do you agree with the science supporting or weakening the argument for global warming? Should the Missouri General Assembly more enthusiastically support the Missouri Global Warming Solutions Act of 2007, or should the proposed bill stay in the Committee?

Last Tuesday, the St. Louis Business Journal announced that the Doe Run Co. recently completed the State Implementation Plan (SIP) for its Herculaneum lead smelter. The SIP was designed to improve air quality and meet the National Air Quality Standard for lead on an ongoing, consistent basis. As we discussed earlier, SIPs are state plans designed to meet federal ambient air quality standards by air quality region.

Jefferson County, where Herculaneum is located, is one of two counties nationwide classified as a non-attainment area for lead. The other county is located in Montana. For a map of the various attainment classifications across the country for all criteria pollutants, check out the EPA's online Green Book.

Lead mining and smeltering is an important economic industry in Missouri. However, lead can cause serious neurological problems in children and can even interfere with growth, lessen intelligence, harm hearing, and affect behavior, possibly making the child more excitable and less able to concentrate. In addition, lead can adversely affect reproduction in men and women and can cause kidney problems, high blood pressure, and memory and concentration problems. Renewed efforts to meet SIP requirements definitely bode well for Missouri in our quest to reach attainment classification, improve public health, and protect the environment.

But, do you think it will be enough? What else should Missouri do to ensure that Jefferson County is eventually classified as attainment for lead?