The Ethics of Disposable Earbuds

 

Over the Christmas holidays, we stayed at a nice Texas motel that had an exercise room.  I usually take a daily bike ride for exercise, but as I didn't bring my bicycle with me, I did the next best thing and used a stationary bike.  The bike had a video screen connected to the cable-TV system of the motel, and for the convenience of exercisers, the motel provided free disposable earbuds, so if you wanted to watch Metallica music videos, you wouldn't disturb the lady next to you who was tuned to PBS.

 

The earbuds worked fine, but I had never come across an establishment which provided them free of charge.  It got me to thinking about how a thing which was once a high-tech piece of specialized and uncommon equipment has become a commodity so inexpensive that motels can afford to give them away.

 

The first device that transformed electrical impulses into audible speech was Bell's telephone receiver.  You have probably seen old movies in which characters use the "candlestick" phone, consisting of a vertical stand with a transmitter that the user spoke into, and a "potato-masher" receiver that was held to the ear.  The reason the potato-masher was as long as it was—several inches—wasn't for convenience in handling.  All electromagnetic transducers (the technical term for a device that converts electric waves into sound waves) need a magnetic field, and producing a strong enough magnetic field to make the device work efficiently has always been one of the defining challenges of making receivers, headphones, and earphones.

 

In the 1890s, the best magnetic materials were lousy by today's standards.  It took a U-shaped piece of iron about three or four inches long to make a strong enough magnetic field to work well as a telephone receiver, and so that was why the potato-masher was as long as it was. 

 

By the early 1900s, materials had improved to the extent that the magnet was small enough to fit into a round can, and thus the headphone came to be developed.  By 1930, you could buy a good pair of radio-quality headphones, the kind that fit over your head with a spring strap, for $1.09.  I have an Allied Radio catalog published in Chicago which describes them as "[u]nusually sensitive headphones carefully designed with aluminum shells and genuine moulded caps."  It's not clear why an imitation moulded cap would be a problem, but a certain amount of vivid writing was expected by the catalog reader of the day.

 

In 2024 dollars, those phones would cost $19.43, so how does a motel get by with giving their modern-day equivalent away?  Advances in manufacturing, of course, and the most significant advance has been in the technology of magnetic materials.

 

Around 1990, it became possible to make what are called neodymium-iron-boron (NdFeB) magnets, which produce the same magnetic field intensity as previous types but with a small fraction of the weight and size.  Magnets made of NdFeB are why we can have excellent sound quality in tiny packages, and also why we can have small battery-powered drones (one of the reasons, anyway—lithium batteries are the other).  And China, which bought the NdFeB technology from General Motors in the 1990s and ran with it, according to the economics website MacroPolo, makes the vast majority of all NdFeB magnetic materials today, although Japan and Germany still have toeholds in the high-end parts of the market.  The U. S. is no longer a significant player in the technology, although we are one of the largest consumers.

 

The reason why the motel didn't provide a single public set of earbuds, the way nineteenth-century railroads used to provide a single public brush and comb chained to the washroom wall, is sanitation.  I haven't seen any actual statistics on diseases known to be transmitted by reusing somebody else's earbuds, but I suppose it could happen.  And there's the yuck factor of just thinking that somebody else's earwax is getting into your ear.  Even if the motel provided more expensive non-ear-penetrating headphones with padding, there would still be skin-to-pad contact around the ear area, and so the easiest out is just to supply cheap disposable earbuds.

 

So what is the harm, if any, in using some inexpensive earbuds once and throwing them away?  

 

For one thing, that decision adds to the stream of waste electronics flooding our landfills daily.  As pollutants go, a pair of earbuds isn't that big a deal, but they are yet another example of the disposable society that is one of the driving themes of modernity.  Magnets aren't exactly biodegradable, but it turns out that one of the more significant growth industries in the U. S. is the enterprise of picking through garbage to find NdFeB magnet material to recycle.  An economic report by MacroPolo tells me that in the next few years, there may be a crunch in the NdFeB magnet supply chain.  China can't make the best ones, Japan and Germany are maxed out, and the demand for magnets to go in everything from electric cars and wind turbines to drones and earbuds is increasing rapidly.  So magnet material may become recycling gold if new sources of supply aren't found soon.

 

The libertarian economists among us would say, "Hey, if earbuds are cheap enough to throw away, don't worry about it.  If it gets to be a problem, the price will go up and we'll do something else, maybe rent them and sterilize them."  And they would have a point.  But just because something is cheap doesn't mean that it's fine to throw it away after one or a few uses.  Turns out that I kept my earbuds after we left the hotel, and now I have my own private set in my shaving kit if I ever come across another motel which isn't as generous with earbuds.  And if the coming NdFeB magnet crunch comes to pass, I may be glad I kept mine.

 

Sources:  I referred to a report "The Impermanence of Permanent Magnets:  A Case Study on Industry, Chinese Production, and Supply Constraints" at https://macropolo.org/analysis/permanent-magnets-case-study-industry-chinese-production-supply/, and an original Allied Radio catalog for 1930 in my collection of antique catalogs. 

Does Diversty Make United Less Safe?

 

Steve Kirby, CEO of United Airlines, drew a lot of flak this past week for two things.  One of them raises serious questions about the tradeoff between so-called diversity hiring practices and safety.  The other concerns one of Kirby's hobbies and can probably be dismissed as irrelevant, although it contributed to the overall attention level he's been receiving lately.

 

Some videos alleged to be showing Kirby—a 56-year-old married father of seven—performing as a drag queen went viral, amassing 2.7 million views in only a few days.  As I have no means of knowing whether these videos are authentic or when they were made, and I can't find any evidence that either confirms or denies their provenance, I fall back on a policy I once read which the manager of an ice-manufacturing plant told his employees in the 1920s:  "As long as you do your work well during the day, I don't care what you do at night."  While the CEO of a major multinational corporation may regret a time years ago when he dressed up in drag, I see no reason to draw any far-reaching conclusions from that fact, if indeed it is a fact. 

 

Its chief use by certain media organizations has been to serve as eye candy for the related story, which should be considered seriously:  whether United Airlines' stated diversity-hiring intents are so extreme as to cause their passengers unnecessary safety risks.

 

While I have not been able to locate the original June 2021 interview that is the basis of this charge, the closest I can find to a direct quote from Kirby is from something called "The Patriot Oasis" on X:  "We decided that 50% of the aviation academy students would be women or people of color.  Today, women and people of color make up only 19% of our pilots."     

 

The issue here is whether a prestigious and demanding profession—that of airline pilot in this case—should be allowed to compose and propagate itself according to criteria that are strictly professional-merit-based, or whether one should also consider what for the lack of another phrase I will call identity-based factors.  Questions like this are made clearer by extreme cases, so I will use an example to show what I mean.

 

In 1960, less than 5% of lawyers in the U. S. were female.  Many law firms would hire women only as secretaries and legal assistants, and many law schools either had a policy of not admitting women at all, or making it very difficult for a woman to obtain a law degree.   But things changed, and today, 38% of U. S. lawyers are women. 

 

Similar things can be said about the professions of medicine and engineering.  For a variety of reasons both historical and political, barring women from entering professions simply because they were women became something that was both frowned upon, and eventually made illegal by Federal and state laws.  What once seemed part of the nature of things now seems highly prejudicial and arbitrary.  In retrospect, the custom of banning women from the professions of law, medicine, and engineering seems to have few if any redeeming features, and undoubtedly lost the talents of many otherwise qualified women.

 

Lifting bans is one thing.  But setting numerical goals for percentages of various identity groups is a different thing.  Is it justifiable to arrange selection and admission processes to shift the percentage of various identity groups (women, ethnic and racial minorities, social classes, etc.) in directions that appear to be desirable, not for the intrinsic good of the profession itself, but for an extrinsic good such as distributing the benefits of highly-paid prestigious professions among identity groups who have previously not enjoyed them? 

 

If Steve Kirby's stated goal of his "aviation academy" students being 50% women or people of color is achieved, what are the consequences for the distribution of pilot quality among the graduates?  Qualitatively speaking, if the total number of slots in the academy is fixed, and the selection rules are changed so that the fraction of women and people of color rises from whatever it is under strictly professional-merit-based criteria (presumably less than 50%) to the stated goal, some people who would have otherwise been admitted can't get in.  I have no idea how hard it is to get into United Airlines' aviation academy, or what criteria one must meet in order to be admitted.  Presumably, it includes a track record of flying experience and education, and perhaps some tests of professional ability. 

 

The critical question is, does United Airlines maintain their professional-merit-based standards of admission and graduation and hiring while also managing to admit more women and people of color?  To answer this question in detail would require months or perhaps years of research and access to information which is probably proprietary.  But the answer is critical to our query. 

 

If United raises their fraction of discriminated-against minorities by admitting and hiring them with lower professional criteria than those applied to other applicants, it is clear that quality is being compromised.  But if they achieve their diversity goals only by extensive and intensified recruitment efforts, for example, and maintain the standards they held before the diversity initiative started, then there is nothing to worry about safety-wise.

 

There really is no other way to answer this question that I can see.  And of all the various places I've seen or heard this topic discussed, no one seems to have carried the inquiry to the depths it needs to go in order to answer it with fairness both to United Airlines and to the flying public.

 

Maybe some investigative reporter is busily digging into the records as we speak, but somehow I doubt it.  The drag-queen videos combined with a two-year-old interview quote have done their job of increasing Internet traffic to certain sites that are more interested in traffic than truth or objectivity. 

 

In order to remain professions and merit the respect and prestige they receive from the public at large, professions, including that of airline pilot, must maintain their professional standards, and must also be perceived as maintaining those standards in order to retain the public's trust.  This Internet-based kerfuffle about Steve Kirby has undoubtedly eroded that trust, but has left the real question of pilot quality unexamined.

 

Sources:  I referred to a Fox Business report at https://www.foxbusiness.com/media/pilots-hired-based-merit-not-diversity-safety-top-priority-aviation-expert-says, the quote from Patriot Oasis at https://twitter.com/ThePatriotOasis/status/1747584074175107488, and for statistics on women in law at https://www.census.gov/library/stories/2018/05/women-lawyers.html, in addition to the Wikipedia article on Steve Kirby, United Airlines CEO.

The Door Plug Blowout on a 737 Max 9: Another Headache for Boeing

 

When Alaska Airlines flight 1282 took off around 5 PM Friday, Jan. 5 from Portland, Oregon, few if any of the 171 passengers suspected that anything unusual was going to happen.  But at 5:11 PM, as the Boeing 737 Max 9 was climbing through 16,000 feet, passengers heard a loud bang followed by a roaring wind noise that made conversation impossible.  Where a normal porthole window had once been, a gaping two-by-four-foot hole had appeared next to a row of seats on the left side of the plane.   One passenger, Kelly Bartlett, didn't realize what had happened until a teenage boy moved into an empty seat next to her.  He was sitting in the row next to the hole, two empty seats away from the window, and the blast sucked the shirt off his back.  If he hadn't been wearing his seatbelt, he might have gone with it.

 

Oxygen masks deployed all over the plane, and the passengers remained calm amid the chaotic noise.  The pilot immediately returned to Portland and landed the plane safely.  No one other than the boy next to the hole was injured. 

 

The Boeing 737 Max 9 can be configured for various numbers of seats, and for more than 200, an emergency exit is required in the location where the hole appeared.  But for smaller capacities, the emergency exit is replaced by a panel, basically a plug the shape of the exit door, that blocks the exit opening.  From inside the plane, the window and trim make this plug almost invisible.  But all that was holding it against the differential pressure of over a ton as the plane rose through 16,000 feet were four bolts, at least if the plug had been installed correctly.  This particular Max 9 was delivered to Alaska Airlines only last October, so the problem may have existed since it was built.

 

A Portland high-school teacher found the door intact in his back yard, so investigators are looking at it closely to determine the cause of the failure. 

           

In the meantime, the U. S. Federal Aviation Administration (FAA) has grounded all Boeing 737 Max 9 planes, which affects some 171 aircraft.  It has ordered inspections of the bolts and other structures around the door plugs, and United Airlines has already found that some bolts on its door plugs are loose. 

 

Only last week, we described in this space how all passengers on a commercial flight involved in a runway collision in Japan survived with only minor injuries, and we can fortunately say the same about this accident in Portland.  But things could have been much worse.  In similar incidents involving sudden holes in fuselages, passengers or flight attendants have been sucked out bodily.  If the boy sitting next to the hole hadn't been wearing his seatbelt, that probably would have been his fate.  And if the plug had waited to fail at a higher altitude, the pressure differential would have been greater, possibly tearing a seat off its mounts. 

 

Although we can rejoice that nobody was seriously injured, the big question now is why the plug blew out.  The fact that at least one other plane has been found with loose bolts holding the plug says that this may not have been an isolated incident.  That is why the FAA has wisely grounded the Max 9s until a thorough investigation shows exactly what the problem was.

 

We can only speculate at this point, but already some things are fairly clear.  The fact that the plane suffering the accident was so new points to a possible manufacturing problem.  Nuts on airframes must be torqued to a specific tension, because the proper amount of torque represents a compromise between not enough tension on the bolt, which might leave it subject to vibration loosening or fatigue in some cases, and too much tension, which could lead to bolt failure.  Many bolts on aircraft have locking cables, cotter pins, or other means by which the nut on the bolt is prevented from turning.  It's not clear whether the four bolts that hold the door plug in place had such provisions, but even locking devices can fail, or be improperly installed.

 

Another 737 Max series, the Max 8, was the subject of an extensive and expensive investigation involving defective software that intentionally crashed the plane when it received faulty data from attitude sensors.  This problem cost Boeing billions of dollars and lost prestige, and the last thing the company needs right now is another expensive and embarrassing safety problem.

 

In a statement to employees that was also released to the public, Boeing CEO Dave Calhoun promised "100% and complete transparency every step of the way" during the investigation.  He can hardly promise less, because Boeing's reputation is on the line with every accident that points to a manufacturing cause. 

 

As airlines which own 737 Max 9s wait impatiently to begin using their millions of dollars of investment again, both the FAA and Boeing have big incentives to figure out why the plug blew out and how to make sure it doesn't happen again.  The recovery of the intact door will be very helpful in the investigation, and I expect we will know something definite within 60 to 90 days. 

 

In the meantime, air flight remains a safe mode of travel for the vast majority of passengers.  The incredible number of things that all have to work flawlessly for a typical flight to be completed goes completely unnoticed by most passengers, but it is the product of the efforts of thousands of engineers, technicians, service people, pilots, crew members, air traffic controllers, and others who do their jobs without public recognition. 

 

We are fortunate that the last two attention-grabbing commercial aircraft accidents have resulted in relatively few casualties.  But grounding the Max 9s was the right thing to do, and everyone looks forward to the time when we can know what happened, why it happened, and how to keep it from happening again.

 

Sources:  I referred to the FAA website at https://www.faa.gov/newsroom/updates-grounding-boeing-737-max-9-aircraft and the following news reports:  https://abcnews.go.com/US/alaska-airlines-emergency-fittings-top-door-plug-fractured/story?id=106218951, https://www.npr.org/2024/01/08/1223517098/door-plug-boeing-737-max-portland-ntsb-faa. and https://abc7ny.com/alaska-airlines-flight-emergency-boeing-door-plug/14298712/.

The Mostly Good News of the JAL Flight 516 Crash

 

Any air transportation fatality is tragic, and our sympathy is extended to the loved ones of the five crew members of the Japan Coast Guard plane who died in a collision with Japan Air Lines (JAL) flight 516 on Tuesday Jan. 2.  But considering that the JAL Airbus 350 had 367 passengers and 12 crew members on board, and every single one of them survived, this accident could have been so much worse.

 

Investigation of the crash will continue for months, but initially it appears that while the JAL flight was cleared to land on runway 34R at Haneda Airport, one of the two international airports in Tokyo, a much smaller Japan Coast Guard De Havilland turboprop was supposed to be waiting to enter the runway.  However, possibly due to a misunderstanding or communications error, the De Havilland was already on the runway as the JAL aircraft was landing.

 

The two aircraft collided, killing five of the six crew members on the Coast Guard plane and sending the Airbus 350 skidding down the runway.  It eventually ground to a stop with the right engine still running. Dramatic video footage of the wreck shows passengers escaping down inflatable ramps in the red glow of the engine's fiery exhaust.

 

The JAL flight crew were unable to use the plane's PA system, so they resorted to megaphones in order to direct the passengers to usable exits amid the smoke that quickly filled the cabin.  The wide-body carbon-fiber-composite A350 was designed for quick evacuation, but until now the evacuation procedure had only been tried out in drills.  Eyewitnesses say none of the passengers appeared to be carrying luggage, which probably helped evacuate the plane quickly.  The plane's captain was the last person to leave the aircraft.  Despite the presence of over 100 fire trucks and the efforts of firefighters, the A350's fire spread throughout the plane and completely destroyed it.  But other than bruises and minor injuries, all the passengers and crews made it out safely.

 

According to a BBC report on the crash, after a 1985 accident in which a JAL aircraft collided with a mountain and killed 520 people the company pledged that they would "never again allow such a tragic accident to occur."  And a look at commercial aircraft fatalities over the years shows a generally declining trend since the 1970s, with a low of 59 deaths worldwide in 2017, for example. 

 

This is the first total loss of a carbon-fiber-airframe A350, and the Airbus designers should be justifiably proud of the way the plane took the punishment of a crash landing without coming apart.  Carbon does burn, after all, while aluminum doesn't burn as easily, and one might be concerned that a carbon-fiber plane would be more dangerous in terms of flammability.  But the JAL 516 crash proved that under the particular circumstances of this accident, the Airbus managed to protect every human being inside from a fiery death.

 

Turning to the causes of the crash itself, increasing aspects of commercial flying have been computerized and automated.  But the processes of taxiing, takeoff, and landing are mostly still done manually by the pilots and copilots. 

 

Decades ago, railroads devised a system called "interlock" which helps prevent settings of switches that would put a train on a track occupied by another train.  Planes aren't trains, but it seems that with modern GPS systems installed on every commercial plane, some sort of coordinated alarm process could be designed to inform pilots when they are straying onto a runway that they have not yet been authorized to enter. 

 

Of course, such a system could cause more trouble than it's worth.  And cockpits are already overflowing with alarms, flashing indicators, and other distractions that sometimes encumber pilots more than helping them. 

 

But when you look into any multiple-fatality accident, regardless of the engineering field, you will typically find that there were precursors:  less serious non-fatal incidents that nevertheless resembled the big awful one, but for some reason turned out to be either harmless or only slightly harmful.  These near-misses are full of information about how to avoid the big awful accident, if only engineers and safety people will pay attention to them.

 

In the JAL-Coast Guard plane crash, five people died, but that was only a small fraction of the number who could have perished, had it not been for the excellent safety procedures and obedience of the passengers who evacuated Flight 516 so quickly.  So in terms of what could have happened, this crash was more of a warning than a full-fledged tragedy. 

 

If the cause does turn out to be due to pilot error, I think it's time to consider some sort of automated system that at a minimum, warns a pilot when he is about to stray onto a runway for which he hasn't been authorized.  Not being a commercial pilot, I may be speaking out of ignorance and there may be such a system in place already.  But it seems like if there was, we would have heard about it.  Warning systems can only do so much, but if a light or voice had warned the Japan Coast Guard pilot that he didn't belong on the runway yet, his crew members might not have died, and 379 other people might not have had to run for their lives before their plane burned up. 

 

It's good to know that those inflatable ramps are actually good for something, and that the practice evacuations in aircraft manufacturers' test facilities that some people make fun of ("Sure, try doing that with smoke in the cabin and screaming people everywhere") can actually be realized in a real-life emergency.  But what would be even better is if this accident encourages new safety features that would keep the precipitating cause from happening anywhere, ever again.

 

Sources:    I thank my wife for alerting me to the BBC article on this crash at https://www.bbc.com/news/world-asia-67870119.  I also referred to statistics at https://www.statista.com/statistics/263443/worldwide-air-traffic-fatalities/

and https://ourworldindata.org/grapher/aviation-fatalities-per-million-passengers, and the Wikipedia article "2024 Haneda airport runway collision." 

California Cracks Down on Warehouse Pollution—Or Does It?

 

As the retail economy transitions from big-box stores to big-box warehouses supporting home delivery, the U. S. has experienced something of a warehouse building boom.  And the South Coast Air Quality Management District (SCAQMD) in Southern California is going to make sure that those warehouses don't pollute the air.

 

How does a warehouse pollute the air?  Good question.  A warehouse itself is just a big room full of stuff.  But getting the stuff in and out of the warehouse requires trucks and forklifts.  Never mind that those trucks are going to be going somewhere else and emitting pollution anyway if that particular warehouse isn't built.  The brilliant minds of the California regulators have determined that warehouse owners and operators are liable for the air pollution caused by any truck that delivers or picks up stuff at the warehouse. 

 

In order to be absolved of these sins, warehouses must either pay a fee that allegedly goes toward the air district's anti-pollution initiatives, or must install electric vehicle chargers or rooftop solar panels.  If the warehouse doesn't comply by the deadline (which varies from now till 2025, depending on the warehouse's size), the SCAQMD can assess fines of $11,700 a day.  And according to an LA Times article, only about half of the warehouses included in current regulations have complied so far.  In order to shame the noncompliant ones, the paper published a 109-line table of the warehouses that haven't complied.  The article noted that the regulators made warehouses in disadvantaged communities a special priority for enforcement. 

 

Nobody in their right mind is in favor of air pollution, other things being equal.  But other things are hardly ever equal, and this attempt on the part of California regulators to reduce pollution that is loosely associated with warehouses shows that the regulatory process has reached the outer limits of feasibility in this case.

 

Let's see if we can analyze the logic of the regulations, such as it is.  Californians need stuff that is typically shipped by truck.  Currently, that stuff is moving less through retail stores and more through warehouses owned by retailers, shippers, and manufacturers, and a lot of truck traffic is going to and from the warehouses. 

 

So far, electric trucks are not much of a thing, although in other regulations California is threatening to ban diesel trucks from the state altogether.  (That would certainly fix the truck-pollution problem, but would deprive most Californians of their stuff.)  The people building warehouses clearly have money to spend on building them, so they can certainly afford to pay either fees the regulators assess—so many dollars per truck coming and going—or they can afford to install lots of charging stations for the electric trucks which will surely materialize ("If you build it, they will come"), or force the warehouses to install solar panels on those nice flat roofs of theirs. 

 

Now suppose you're a poor person living in one of those disadvantaged neighborhoods near which a big new warehouse has been built, and you open your door to diesel fumes emitted by the many trucks that drive past your house on the way to the warehouse.  How is any aspect of these new regulations going to make your life better? 

 

If the warehouse is paying a fee per truck and that goes to the SCAQMD, that isn't going to help you directly unless you get a job at the SCAQMD.

 

If the warehouse installs hordes of electric-truck charging stations, that isn't going to help you until the electric trucks come along, which may be many years from now, if ever.

 

If the warehouse installs solar panels on their roof, there's just as many trucks going by your house as there were before. 

 

Unless you have the particular mindset that rejoices when any polluter is made to pay a penalty for their crime, and derive enough satisfaction from knowing that the warehouse operator is doing daily penance for attracting all those trucks that drive by your door, and that warm glow of vengeance or whatever it is outweighs the problem of all those trucks passing your house, you are no better off with these regulations than without them, at least for the foreseeable future. 

 

Yes, perhaps the regulations move us incrementally closer to the fossil-fuel-free utopia envisioned by many in our elite classes, in which the roar of diesel engines is replaced by the almost imperceptible hum of electric motors—except for the occasional boom of exploding transformers overloaded by too much demand on an outmoded power grid. 

 

I put the regulations in terms of sin and penance rather than in more objective or scientific terms, because that is what they amount to:  a secular version of the religious concepts of sin and salvation.  As I have shown, the warehouse anti-pollution regulations are not going to reduce the diesel emissions from trucks going to and from the warehouse, at least not until most of the California truck fleet becomes electric.  But they punish people who have had the economic initiative to build warehouses in order to meet California's insatiable desire for stuff. 

 

It would make more sense to assess fines on the trucks each time they make a delivery.  But the regulators know they have pushed truckers about as far as they can stand, and so instead they go for large warehouse-owning corporations, which are richer and easier to shake down than individual truckers.  I use the term "shakedown" intentionally, because in some ways, these environmental regulations are taking on the look of the Mafia henchman who comes into a dime store and says to the owner, "Nice little place you got here—a shame if anything happened to it."  Because air quality has become such a sacred cow in California, almost anything can be done in its name, including the slapping of ineffective regulations that don't get at the root of the problem, but appease the gods of air quality. 

 

Perhaps these regulations are just rough spots on the road to a diesel-free future, but in the meantime, I'm glad I don't run a warehouse in California.

 

Sources:  The article "Crackdown on warehouse pollution results in more than 100 violation notices" appeared on the LA Times website at https://www.latimes.com/environment/story/2023-12-22/warehouse-crackdown-results-in-over-100-pollution-violations.