Climate 411

The Mercury Standards, Post-Supreme Court – Still in Effect, Still Protecting Americans

By Tomas Carbonell / Published: July 2, 2015
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Supreme Court of the United States

The U.S. Environmental Protection Agency (EPA) first proposed the Mercury and Air Toxics Standards back in 2011, at a news conference at Children’s Hospital with cheering children and families surrounding the speakers.

They were cheering because the Mercury Standards were the single most important clean air measure of our generation – designed to protect Americans from some of the worst, most dangerous types of air pollution.

They still are.

This week’s disappointing Supreme Court decision, remanding the standards back to the D.C. Circuit Court for further analysis, has distracted from that fact.

But the fact remains – the Mercury and Air Toxics Standards are a suite of life-saving protections against some of the most health-harming substances emitted by coal and oil-fired power plants, including mercury, arsenic and other heavy metals, and acid gases.

Here’s What Happened

Coal- and oil-fired power plants are by far the largest emitters of these pollutants, which are dangerous to human health even in small doses. Mercury causes brain damage in children, metal toxics like chromium and nickel cause cancer, and acid gases cause respiratory problems.

This week, the Supreme Court held that EPA should have considered the costs of regulation when it made a threshold determination under section 112 of the Clean Air Act that it is “appropriate and necessary” to move forward with the first-ever national limits for these noxious emissions. It is now up to EPA to determine the best way to respond to the decision.

(The case was Michigan v. EPA. EDF was a party to the case. You can read the decision and the sharp dissent here.)

What does the Supreme Court ruling mean for the Mercury Air Toxics Standards?

Here are three important things you should know.

First — there is every reason to believe EPA can quickly amend its “appropriate and necessary” finding to address the Supreme Court’s decision, without affecting the substance of the Mercury and Air Toxics Standards themselves.

Importantly, the Court left it up to EPA to determine how to evaluate costs and how to weigh those costs against the benefits of regulation. As the Court’s opinion acknowledged, EPA has already conducted an extensive review of both the costs and benefits of the Mercury and Air Toxics Standards as part of the regulatory analyses most agencies carry out under Executive Order 12866. That analysis contains overwhelming evidence showing that the benefits of MATS far outweigh its costs.

According to EPA, the monetized benefits of the Mercury and Air Toxics are expected to be up to $90 billion per year.

That amount reflects the enormous health benefits Americans will get from the standards. EPA estimates that they will prevent 11,000 premature deaths, up to 4,700 heart attacks, and up to 130,000 asthma attacks each year.

There are substantial and additional non-monetized benefits associated with reduced exposure to mercury and other harmful pollutants regulated by the Mercury and Air Toxics Standards.

Moreover, in spite of the power industry’s claims, reducing these emissions has proven much less expensive than initially projected. Major power companies such as AEP, NRG, and FirstEnergy have been reporting to their investors that the costs of the Mercury and Air Toxics Standards are as much as 70 percent lower than they first estimated.

The bottom line is that the Mercury and Air Toxics Standards are an extraordinarily beneficial public health measure and are providing healthier, longer lives for millions of Americans at a fraction of the costs predicted.

Second — the Mercury and Air Toxics Standards can and should continue to be implemented while EPA amends its “appropriate and necessary finding.”

The Supreme Court’s opinion did not prohibit the implementation of the Mercury and Air Toxics Standards – and in the past, the appellate courts have often allowed Clean Air Act regulations to remain in place while EPA amends them to address technical or legal issues.  

In this case, a large majority of American power plants are already in compliance with the Mercury and Air Toxics Standards — in many instances because they have been upgrading pollution controls to comply with state emission standards or other Clean Air Act requirements.  M.J. Bradley & Associates recently estimated that about 70 percent of the U.S. coal fleet had installed pollution controls to comply with the standards by the April 2015 deadline. In addition, a substantial number of plants have received one-year extensions to this compliance deadline and are now working to install pollution controls by April 2016.

Given the importance of the Mercury and Air Toxics Standards to public health, and the overwhelming likelihood that EPA will be able to quickly address the Court’s decision, there is no reason that power plants should be allowed to delay installing pollution controls or cease operating already-installed pollution controls.

Third – the Supreme Court decision has no adverse implications for EPA’s Clean Power Plan – despite the wild claims being made by some opponents of these vital limits on carbon pollution from power plants.

The Mercury and Air Toxics Standards and the Clean Power Plan are based on entirely separate Clean Air Act authorities that reside in separate parts of the statute. The authority EPA is acting on to develop the Clean Power Plan expressly provides for the consideration of costs, and EPA has carefully taken costs into account in the Clean Power Plan in the manner required by the statute. Thus, claims that the ruling on the Mercury and Air Toxics Standards should somehow cast doubt on the legality of the Clean Power Plan are severely misguided.

Summing It Up

Marian Burton, president of the American Academy of Pediatrics, summed it up perfectly back in 2011, when the Mercury and Air Toxics Standards were first proposed:

Dirty air makes children sick … If you think it’s an expensive process to put a scrubber on a smokestack, you should see how much it costs over a lifetime to treat a child with a preventable birth defect.

That’s why hundreds of thousands of Americans sent comments to EPA in support of the Mercury and Air Toxics Standards.

It’s why EDF and so many other health, environmental, and social justice groups will go back to the D.C. Circuit Court to defend the standards.

We’ll keep fighting to make sure the Mercury and Air Toxics Standards are fully implemented so we can realize the promise of the Clean Air Act — and make sure all Americans have safe, healthy air to breathe.

Also posted in Clean Air Act, EPA litgation, News, Policy / Comments are closed

American Petroleum Institute Continues Its Long Campaign against Clean Air Standards

By Mandy Warner / Published: June 22, 2015

iStockphoto.com

I recently had the unfortunate experience of hearing a two-year-old suffer from an asthma attack. The nurses commented in passing how it was actually a great sign to hear the young child screaming, as it was more worrisome when children came in with asthma attacks and were unable to draw breath. As a mother of a two-year-old myself, hearing the terrified screams of this child was utterly heartbreaking.

This was the first time I’ve come face to face with a child suffering the effects of asthma – a terrible respiratory disease that is often exacerbated by air pollution. The thought of thousands of parents making preventable visits to the emergency room each year, desperate to get help for their children who are having asthma attacks triggered by smog or other air pollution, is gut wrenching. It’s also a poignant reminder of why we need to keep demanding more progress to clean our air.

Smog is primarily formed by emissions of nitrogen oxide (NOx) and volatile organic compounds (VOCs). The main sources of these emissions are power plants, oil and gas operations, and cars and trucks.

Setting smog limits to 60 ppb would, in the year 2025:

  • Prevent up to 7,900 premature deaths
  • Prevent up to 1.8 million asthma attacks among children
  • Prevent up to 4,100 cases of acute bronchitis among children
  • Prevent up to 1.9 million days when kids miss school
  • Provide up to $75 billion in public health benefits

Smog contributes to thousands of asthma attacks and other harmful health impacts every year – including early deaths. Pollution also blows into our national parks, harming wildlife and vegetation. EPA is required by law to re-evaluate each of our nation’s air quality standards every five years, ensuring our air standards are updated to reflect the latest scientific understanding of the impacts of pollution. Strengthening our nation’s outdated smog standards will help us continue the progress we’ve made in cleaning up our air, in line with what scientists and leading public health organizations have determined is needed to protect human health and the environment.

Unfortunately, the American Petroleum Institute (API), a trade association representing oil and natural gas industries, has launched a campaign against strengthened smog standards. In its ads, API claims our current standard is strict enough, despite the fact that an independent advisory committee of scientific experts concluded the opposite over seven years ago. Since that time, an even more extensive body of scientific research documents the harms of ozone to human health.

API is also claiming that strengthened smog standards will bring exorbitant costs to American families — this is based on an analysis roundly criticized by experts for its unrealistic assumptions and for the fact that it ignores the substantial economic benefits of reducing air pollution.

Sadly, this is nothing new from API. API has claimed time and again that clean air standards would be too costly and wouldn’t yield health or environmental benefits. For standards advancing low sulfur fuel and vehicles (Tier 3) API said:

The new EPA requirements could be devastating to consumers and communities across the nation  – Bob Greco, API Director of Downstream Operations, API press release, July 29, 2011.

API also claimed gas prices could rise up to 25 cents a gallon due to the standards. However, EPA and independent analysis by Mathpro projects that gasoline prices will increase by less than 1 penny per gallon due to the Tier 3 standards. EPA also found the standards would provide up to $13 in health benefits from every dollar invested. The Tier 3 Standards were finalized in 2014 with broad support from automakers and manufacturers, labor groups, health and environmental groups, environmental justice groups, moms groups, and numerous states.

Yet again with the smog standards, API is completely ignoring the fact that we have cost-effective tools at our disposal to meet strengthened smog standards. We also have policies underway that are already helping us get there, including tailpipe emissions reduction standards, and the proposed Clean Power Plan. We also know that there are emission reductions that are readily available right now. For example, some power plant units have installed advanced controls for NOx that have not been used consistently in recent years.

Nearly every step of the way to cleaner air in the past four decades, we have had to fight polluter interests that claim the costs will be too high, the economy will be ruined, or that our air is already clean enough. Time and again these claims have been disproven — our economy has grown as our air quality has improved due to clean air standards, and literally trillions of dollars in health and other benefits have accrued.

API’s latest campaign against much-needed, long overdue, cost-effective smog standards is a continuation of the decades-long battle we have faced. We ask you to urge API to cease its campaign against the ozone standards and instead constructively engage in the process to reduce the pollution that harms millions of American families. Please help the children across America – each child — breathe cleaner air for life.

Also posted in News / Comments are closed

New EPA Mapping Tool Sheds Light on Pollution Risk and Social Vulnerability

By Marcelo Norsworthy / Published: June 15, 2015

(This post originally appeared on EDF’s Texas Clean Air Matters blog)

EPA is getting into the mapping game in a big way.

Just this week, they launched an environmental justice (EJ) mapping and screening tool called EJSCREEN, an online, publicly accessible index of environmental indicators based on location. It will be a tremendously helpful resource for the EJ movement.EPA's new mapping and screening tool will help advance environmental justice.

In the past, concerned citizens, researchers, and advocates would access national databases individually without the ability to bring multiple sources of information together in one clear and consistent platform. EJSCREEN was created to address that issue. It’s a significant milestone that puts environmental and demographic data at your fingertips and empowers you to learn about your community.

One of the major advancements in EJSCREEN is the combination of environmental risk and social vulnerability information. This intersection defines a critical element of environmental justice: communities that are at elevated risk of exposure to harmful pollution are often home to the elderly, low-income families and other vulnerable populations. Much of EDF’s work focuses on this intersection, such as our environmental health efforts to improve air quality at and near ports and freight hubs. These areas can be pollution hotspots, and they are often close to communities of vulnerable populations.

EJSCREEN will help areas like port communities better understand how environmental and social issues overlap – and shows the information by map. The tool combines a set of demographic indicators and a set of environmental indicators into an “EJ Index.” There is one index per environmental indicator and the index for a particular area is compared to regional, state, and national averages. The tool produces a profile report and a map of a selected area that provides the comparative analysis of a community.

You can use EJSCREEN to visualize your neighborhood or city, or to develop a better understanding of a community that may be affected by environmental risks. Although EJSCREEN does feature a comparison of the selected area to the state and nation, the tool should not be used to define or qualify an environmental justice community. Rather, EJSCREEN is designed to promote a better understanding of the intersection between risk and vulnerability for potentially impacted communities.

Texas in particular will benefit from EJSCREEN as demographic shifts and significant industrial activity carry implications for environmental justice concerns. Houston, for example, is an incredibly diverse city with many sources of potential pollution hotspots. Area residents will be able to use the tool and better interpret environmental risks in the context of the local population.

EJSCREEN is a major advancement, but EPA is already thinking about what may come next for the tool. Right now, EPA wants you, the public, to use and explore this interim version and provide input ahead of the next release in early 2016. That version is set to include a vital dataset for understanding environmental risks: the National Air Toxics Assessment (NATA). The inclusion of this valuable dataset on some of the most hazardous air pollutants will greatly enhance the ability of EJSCREEN to characterize the environmental risk faced by many communities.

The tool comes at an important time for EJ at EPA, as they are preparing to finalize their “EJ 2020” framework that will establish their plan for advancing environmental justice over the next five years. EPA is accepting public input on the draft framework through July 14.

EPA is democratizing data with EJSCREEN. The ability to draw in nationally consistent datasets on demographics and environmental risks and present accessible maps and reports will be a major benefit to communities of all types. EDF is excited to share in the enthusiasm for the release of the interim version of the tool and is looking forward to seeing an even better tool in the future. EJSCREEN can be accessed publically and freely at http://www2.epa.gov/ejscreen.

Image source: flickr/Cheryl

Also posted in News / Comments are closed

Déjà vu: Pushback to U.S. Clean Power Plan Reminiscent of 2011 Mercury Rule

By EDF Blogs / Published: May 15, 2015

By Susan Tierney,  Managing Principal, Analysis Group, Inc.

This post originally appeared on World Resources Institute’s Insights blog.

Did you notice the massive blackout on April 16th, 2015?Reversed-GoldBackground

Actually, I didn’t either. That’s because the electric system didn’t falter. The fact that April 16th came and went without a reliability glitch was both nothing unusual and also a really big deal. Because history has a habit of repeating itself, it’s worth understanding why April 16th was a remarkable (and remarkably dull) milestone in electric-industry history.

The Origins of the Mercury and Air Toxics Standard (MATS)

Back in 2010, just under a third of all U.S. power-plant capacity burned coal to produce electricity. Many of those plants were emitting unhealthy levels of toxic air pollution, which forthcoming regulations from the Environmental Protection Agency (EPA) would limit. Critics of EPA’s rule doubted that manufacturers and installers could get enough pollution-control equipment into the market and on to power plants fast enough to meet the deadline under the new Mercury and Air Toxics Standard (MATS) – and that taking so much of the nation’s generating capacity off line all at once would inevitably lead to an unreliable electric system.

Before the EPA finalized its MATS rule at the end of 2011, countless groups published estimates of how many coal plants would retire due to the EPA regulations. The North American Electric Reliability Corporation (NERC) warned that “with [the mercury rules] as the primary driver, the industry faces considerable operational challenges to complete, coordinate and schedule the necessary environmental retrofits.” Others, including opponents of the rule, argued that, in the name of reliability, the rule would need to be delayed.

In December 2011, EPA issued the final MATS rule, which gave owners of affected power plants until April 16, 2015, to either bring their plants into compliance with the new requirements or cease their operations.

That date passed two weeks ago without incident. The lights didn’t dim.

Why not? First, the EPA stood by its commitment (made in November 2011 by then-Assistant EPA Administrator Gina McCarthy in testimony to the Federal Energy Regulatory Commission, the agency with responsibility for electric system reliability) that “In the 40-year history of the Clean Air Act, EPA rules have never caused the lights to go out, and the lights will not go out in the future as a result of EPA rules.”

Part of the reason for that is that the EPA is nowhere near as rigid or anti-business as many observers like to portray it. The final EPA rule gave power-plant owners the ability to request an additional year of time to comply, and allowed yet another year in unusual cases where continued operation of a plant would be needed for reliability. According to the National Association of Clean Air Agencies, as of March 2015, owners of 38 percent of the 460 coal-fired power plants affected by the MATS rule had requested additional time to comply and, of those, the EPA granted an extension to 95 percent.

Kentucky power plant. Photo by Cindy Cornett Seigle/Flickr

Second, the electric industry is already transitioning to rely less on coal, even without the MATS rule. Between 2011 and the end of 2014, 21.5 gigawatts (GW) of coal-fired power plants retired. The fact that these retirements occurred before the MATS deadline indicates that something other than EPA’s regulations is driving the least-efficient and oldest coal plants into retirement.

Coal’s ardent supporters may prefer to point the finger at EPA, but the truth is that market conditions are responsible: relatively flat electricity demand, increased supply from power plants using other domestic energy sources (natural gas, wind and solar), and price competition between natural gas and coal. Another 14.6 GW of power plants have retired or will retire in 2015. This total amount of coal-plant retirements (36.1 GW) falls at the mid-point of estimates made during the 2010-2011 period.

Third, the electric industry is dynamic. The market has responded to signals that additional electric resources are needed to replace old ones. Many projects have come forward: new power plants, upgraded transmission facilities, rooftop solar panels, energy-efficiency measures and energy-management systems. These varied responses are the norm, collectively maintaining reliability and modernizing the power system along the way.

That’s why there were no blackouts on April 16th, despite all the dire warnings.

History Repeats Itself

The reliability theme is re-emerging once again, as the states and the electric industry face the prospect of EPA finalizing its “Clean Power Plan” to control carbon pollution from the nation’s power plants. In anticipation of the final rules coming out this summer and of power plant owners having to comply with them by 2020, many observers are saying that the electric system’s reliability will be jeopardized if the EPA goes forward as planned. The latest warning came last month with a new assessment published by NERC, calling for more time to allow the industry and the states to respond to the forthcoming carbon-pollution rules.

Such warnings are common whenever there is major change in the industry, and they’re not without value: They play an important role in focusing the attention of the industry on taking the steps necessary to ensure reliable electric service.

But warnings lose their value when they are read as more than what they are. Notably, the reliability concerns currently being raised by some observers about EPA’s Clean Power Plan presume inflexible implementation, are based on worst-case scenarios, and assume that policy makers, regulators and market participants will stand on the sidelines until it is too late to act.

There is no historical basis for these assumptions. Reliability issues will be worked out by the dynamic interplay of actions by regulators, entities responsible for reliability, and market participants, all proceeding in parallel to find solutions.

EPA’s proposed carbon-pollution rule provides states and power plant owners with the means to prevent reliability problems by giving them a wide range of compliance options and plenty of operational discretion (including various market-based approaches, other means to allow emissions trading among power plants, and flexibility on deadlines to meet interim targets). And EPA Administrator McCarthy has stated repeatedly that her agency will write a final rule that reflects the importance of a reliable grid and provides the appropriate flexibility.

One of the best ways to assure electric reliability will be for states to actively avail themselves of the Clean Power Plan’s flexibility, rather than “just say no.” States that do not take advantage of this flexibility and then suggest that EPA’s regulations led to unreliable and uneconomic outcomes may be courting a self-fulfilling prophecy. The more states sit in the driver seat and figure out how to arrive at the emissions-reduction destination in a manner consistent with their goals and preferences, the more likely it is that they’ll accomplish them.

Also posted in Clean Power Plan, Energy, Greenhouse Gas Emissions / Comments are closed

Top policies to help Americans breathe easier, and what you can do

By Lucía Oliva Hennelly / Published: April 22, 2015

Source: Flickr/Kate Gardiner

A year ago, we joined our partners at the League of United Latin American Citizens on Twitter to ask U.S. Environmental Protection Agency Administrator Gina McCarthy about the impacts of air pollution on our health.

Many of the questions participants raised focused on the connection between air quality and asthma.

In a follow-up to the event, McCarthy reminded us that while there’s no known cure for asthma, “understanding how indoor and outdoor air pollutants can trigger an asthma attack or episode is an important step in managing this condition.”

Fortunately, decision-makers are now considering several new policies that would decrease the number of asthma attacks and the severity of symptoms.

Cutting climate and air pollution

As global temperatures rise, more ground-level ozone, a key component of smog, builds up. This, in turn, leads to more frequent and intense asthma attacks.

To address these problems, the EPA is working on several measures to limit the pollution that causes climate change, worsens air quality and threatens our health. The agency is:

  • finalizing a rule to reduce emissions from power plants, the largest source of climate pollution in the United States.
  • working on a rule to limit climate pollution from oil and gas production. It would also reduce toxic chemical releases during the energy extraction process.
  • proposing a stronger ozone standard to reduce smog pollution and restore healthy air.
Reducing the threat of toxic chemicals

Many chemicals found indoors are also known or suspected “asthmagens,” environmental agents that cause or exacerbate asthma. These chemicals can affect us in our homes – or in any of the indoor areas where Americans spend about 90 percent of their time.

Today, we’re exposed to chemicals in everyday household products in large part because of a 40-year old chemical safety law that has failed to protect us. The law is so weak, in fact, that EPA can’t even regulate chemicals known to cause cancer.

Congress is therefore considering reforming the Toxic Substances Control Act. If a new bill passes, we will have better safeguards against many asthmagens.

Get involved

Asthma affects nearly 26 million people in the U.S., including 1 in 10 Latino children who currently suffer from asthma. An even higher proportion of Latino kids, 14 percent, have been diagnosed with asthma at some point in their lives. Unfortunately, this illness presents a particular concern for Latinos in our country.

Studies have also shown that Latino-Americans are less likely than non-Latino whites to be diagnosed with asthma, have an asthma management plan, or use a controller medication. As a result, Latino children are 40 percent more likely than non-Latino white children to die from this condition.

If you’d like to hear more about these topics, you can join us for our Latino Health and the Environment Twitter Town Hall Series.

First up is an Earth Day Twitter Town Hall, where McCarthy will be answering questions about environmental issues and human health, why the Latino community is disproportionately affected by climate change, and what we can all do to protect ourselves.

Then stay tuned in May for our second Twitter Town Hall, which will focus on the health impacts of toxic chemicals.

This post originally appeared on our EDF Voices blog.

Also posted in Latino partnerships, News, Policy / Comments are closed

Half a Million People across America Support Stronger Protections against Smog Pollution

By Mandy Warner / Published: April 2, 2015

Our friends at Moms Clean Air Force dropping off their smog comments at EPA

The comment period has now closed for the Environmental Protection Agency’s (EPA) proposal to strengthen our national health-based smog standards, and we know one thing already:

Support for cleaning up our air has been tremendous and far-reaching.

More than half a million people from across our nation sent comments urging EPA to strengthen America’s health-based smog protections. And we’re so grateful to our dedicated members and activists for helping EDF collect more than 130,000 of those comments.

EDF strongly supports strengthening our public health standards for ground-level ozone—more commonly known as smog.

Smog contributes to a variety of health problems, including increased risk for asthma attacks, long-term lung damage, other heart and lung diseases, and even premature death. The most susceptible groups are young children and elderly adults.

But it isn’t just EDF – and it isn’t only environmental organizations — calling for cleaner air.

Leading medical associations, states, moms, and environmental justice organizations have highlighted the challenges their constituencies face from this pollution — and have voiced their support for tighter smog protections.

Here are just a few examples:

WE ACT for Environmental Justice said improved smog standards are urgently needed to protect the children in Harlem afflicted by smog pollution:

According to the New York Department of Health and Mental Hygiene, in 2012, children aged 0 to 4 in the Harlem [sic] visited the emergency room 280 times because of asthma. There is no doubt that children in Northern Manhattan are suffering disproportionately from asthma, which is exacerbated by the formation of Ozone and other social stressors.

Mom’s Clean Air Force also weighed in:

Parents have a right to know the truth about whether the air is safe to breathe… Smog standards that reflect current science will protect children from harmful air pollution.

The American Academy of Pediatrics said smog standards must be improved for the sake of children:

Simply put, children are different. They breathe faster. They spend more time outdoors, playing and being physically active. These combined differences mean that, at a given concentration of air pollution, children will be exposed to a higher dose. But their lungs are not fully developed until about 18 years of age. Children are thus at greatest risk from air pollution, because their increased physical activity, plus greater time spent outdoors, means that they are exposed to a higher dose of air pollutants.

In a 2014 joint letter to the White House Office of Management and Budget, Attorneys General  from New York, Maryland, New Hampshire, New Mexico and Rhode Island all expressed support for strengthening our nation’s smog standards, stating that smog pollution has been a persistent problem for their states:

The States [listed above] have been battling ozone pollution (smog) for decades… Although we have made strides to reduce smog levels that harm public health in areas such as New York City and that harm our natural resources in areas such as the Adirondacks, smog remains a persistent threat. Much of this pollution is generated in upwind states and carried by prevailing winds into our States.

Dozens of organizations, including EDF, submitted a letter urging EPA to issue strong standards:

EPA must protect the health of children, people with asthma and other lung diseases, older Americans and other sensitive and vulnerable populations.

The American Lung Association and the March of Dimes wrote an op-ed for CNN that discussed the serious health issues at stake and voiced support for strengthened smog standards:

Over the past several years, a number of studies have indicated a likely link between higher levels of maternal ozone exposure and poor health outcomes in infants, including changes in lung structure and function, low birth weight and neuro-behavioral abnormalities. Many of these health effects can be expected to have lifelong consequences… ​Strengthening the ozone standard to reflect the best current science will help save lives and protect our families, including pregnant women and their babies.

This broad support for stronger smog standards shows how much is at stake for all of us.

Our nation has proven time and again that, by working together, we can achieve pollution reductions in a cost-effective manner. Strengthening these life-saving standards now will help us continue, and build on, progress made in the past that has provided healthier and longer lives for millions of Americans.

Also posted in Clean Air Act, Partners for Change, Policy, Smog / Comments are closed