Category Archives: Rail routing

Forbes: comparing crude delivery by pipeline, rail, truck and boat

Repost from Forbes
[Editor: This lengthy analysis is worthwhile for its factual background and its many links to source material, even though the author seems unaware that fossil fuels are on their way out.  – RS]

Pick Your Poison For Crude — Pipeline, Rail, Truck Or Boat

By James Conca  |  4/26/14

Crude oil is moving around the world, around our country, around pristine wilderness, around our cities and towns. It’s going to keep moving, will undoubtedly increase during our new energy boom, so what is the safest way to move it?

The short answer is: truck worse than train worse than pipeline worse than boat (Oilprice.com). But that’s only for human death and property destruction. For the normalized amount of oil spilled, it’s truck worse than pipeline worse than rail worse than boat (Congressional Research Service). Different yet again is for environmental impact (dominated by impact to aquatic habitat), where it’s boat worse than pipeline worse than truck worse than rail.

In both the United States and Canada, more crude oil, petroleum products, and natural gas are transported in pipelines than by all other modes combined, using the unit of ton-mile which is the number of tons shipped over number of miles (The Fraser Institute).

In the U.S., 70% of crude oil and petroleum products are shipped by pipeline. 23% of oil shipments are on tankers and barges over water. Trucking only accounts for 4% of shipments, and rail for a mere 3%. In Canada, it’s even more lopsided. Almost all (97%) of natural gas and petroleum products are transported by pipelines (Canadian Energy Pipeline Association).

Amid a North American energy boom and a lack of pipeline capacity, crude oil shipping on rail is suddenly increasing. The trains are getting bigger and towing more and more tanker cars. From 1975 to 2012, trains were shorter and spills were rare and small, with about half of those years having no spills above a few gallons (EarthJustice.org). Then came 2013, in which more crude oil was spilled in U.S. rail incidents than was spilled in the previous thirty-seven years.

Crude is a nasty material, very destructive when it spills into the environment, and very toxic when it contacts humans or animals. It’s not even useful for energy, or anything else, until it’s chemically processed, or refined, into suitable products like naphtha, gasoline, heating oil, kerosene, asphaltics, mineral spirits, natural gas liquids, and a host of others.

U.S. Refinery Capacity by PADD (Petroleum Administration for Defense Districts) in 2012. Source: Congressional Research Service; Energy Information Administration U.S. Refinery Capacity by PADD (Petroleum Administration for Defense Districts) in 2012. Source: Congressional Research Service; Energy Information Administration 

Every crude oil has different properties, such as sulfur content (sweet to sour) or density (light to heavy), and requires a specific chemical processing facility to handle it (Permian Basin Oil&Gas). Different crudes produce different amounts and types of products, sometimes leading to a glut in one or more of them, like too much natural gas liquids that drops their price dramatically, or not enough heating oil that raises their price.

As an example, the second largest refinery in the United States, Marathon Oil’s GaryVille Louisiana facility, can handle over 520,000 barrels a day (bpd) of heavy sour crude from places like Mexico and Canada but can’t handle sweet domestic crude from New Mexico.

Thus the reason for the Keystone Pipeline or increased rail transport – to get heavy tar sand crude to refineries along the Gulf Coast than can handle it.

The last entirely new petroleum refinery in the United States opened in 1976 (Congressional Research Service). Since then, the number of refineries has steadily declined while refining capacity has concentrated in ever-larger facilities. 25% of U.S. capacity is found in only eleven refineries. Recently, Shell’s Baytown refinery in Texas, the largest in the nation, was expanded to 600,000 bpd. Most of the big refineries can handle heavy crude, but many smaller refineries can process only light to intermediate crude oil, most of which originates within the U.S.

Thirty-three states have refineries, and most refineries can handle tens-of-thousands to hundreds-of-thousands of barrels per day, but the largest capacity sits around the Gulf Coast and in California where the oil boom in America began. However, in the 1990s after production of sweet domestic crude had significantly declined from mid-century highs, the big companies like Exxon, Shell, CITCO and Valero spent billions upon billion of dollars to retool their refineries to handle foreign heavy crudes.

Oil spill volume per billion-ton-miles compared among transportation modes. Source: the Congressional Research Service Oil spill volume per billion-ton-miles compared among transportation modes. Source: the Congressional Research Service 

With the number of refineries decreasing, and capacity concentrating in fewer places, crude usually has to be moved some distance. There are four ways to move it over long distances: by pipeline, by boat, by truck, or by rail. Each has its unique problems and none is without harm.

The question is: which is safest and which should we invest in most? Take two spills for comparison.

The Quebec train wreck last year killed 47 people and spilled 1.5 million gallons of crude onto land (Bloomberg.com). The Enbridge pipeline rupture in 2010 spilled over a million gallons of similar crude into the Kalamazoo River but did not kill anyone (Wikipedia).

Contamination of water is generally much worse for the environment than contamination of land as it spreads quickly over more area and impacts more species and habitat. But killing people makes a big difference. I don’t want to put a price tag on human life, but the Government has, and it’s about $8 million a person (NYTimes).

So the Quebec train derailment cost over $400 million in human life, and will cost another $150 million or so for clean-up and rebuilding the town. The Enbridge pipeline cost no human lives but will cost about a billion dollars to clean-up and, like the Exxon Valdez, will never really succeed.

Note: using this value of $8 million a person, we 300 million Americans are worth $2.4 quadrillion, hmm…maybe not a good number. If we use our net value for America as a whole, about $75 trillion, divide by 300 million people, then the average value of a human life in America would be $250,000. So the Quebec train derailment cost less than  $12 million in human life. Thus the danger of trying to gauge the value of a human life.

These are not easy questions and one’s vested interest has a great deal of sway in the answer. You really do need to pick your poison.

Like always, it will probably come down to money. And it won’t be about jobs (Pipeline Jobs), regardless of which end of the spectrum you believe, because there just isn’t enough jobs to matter compared to the value of the oil itself and the refinery capacity. It’s simply cheaper and quicker to transport by pipeline than by rail or by truck. The difference in cost is about $50 billion a year for shipping via the Keystone versus rail, totally eclipsing any economic effect of jobs in either direction.

A rail tank car carries about 30,000 gallons (÷ 42 gallons/barrel = about 700 barrels). A train of 100 cars carries about 3 million gallons (70,000 barrels) and takes over 3 days to travel from Alberta to the Gulf Coast, about a million gallons per day. The Keystone will carry about 35 million gallons per day (830,000 barrels). This puts pressure on rail transport to get bigger and bigger, and include more cars per train, the very reason that crude oil train wrecks have dramatically increased lately.

The Congressional Research Service estimates that transporting crude oil by pipeline is cheaper than rail, about $5/barrel versus $10 to $15/barrel (NYTimes.com).  But rail is more flexible and has 140,000 miles of track in the United States compared to 57,000 miles of crude oil pipelines. Building rail terminals to handle loading and unloading is a lot cheaper, and less of a hassle, than building and permitting pipelines.

It isn’t acceptable to just say we shouldn’t be moving oil, because we will for the next decade or more, no matter what. So, keeping in mind the difference between death/damage to humans and damage to the environment, which would you choose?

Like a few weeks ago, I would appreciate just one comment from each person for the first 24 hours after posting so we can get a tally before we get into the normal animated back and forth debates. Below is some more information on each transportation mode.

Rail

Two seemingly opposite facts –

1) from 1980 to 2012, the train accident rate in the United States fell 80 percent, the rail employee injury rate fell 85 percent and the RR crossing collision rate fell 82 percent, but

2) more crude oil was spilled in U.S. rail incidents in 2013 than was spilled in the previous thirty-seven years.

Huh?

Using data from the Pipeline and Hazardous Materials Safety Administration, 1.5 million gallons of crude oil were spilled from rail cars in 2013. On the other hand, from 1975 to 2012, railroads spilled a total of 800,000 gallons of crude oil (McClatchy; check out their great interactive map of spills over space and time).

Even worse, these data do not include rail accidents in Canada. 1.5 million gallons of crude oil spilled in a single day last year in Lac-Megantic, Quebec, and 47 people were killed. The shipment did originate in North Dakota so take your pick of provenance.

If crude oil shipping on rail is becoming a preferred mode for oil producers in our North American energy boom, this trend is very disturbing. In 2011, crude rail capacity between southern Alberta and the northern U.S. Great Plains tripled to about 300,000 barrels per day, about a third of the Keystone XL capacity. U.S. railroads delivered 7 million barrels of crude in 2008, 46 million in 2011, 163 million in 2012, and 262 million in 2013 (almost as much as that anticipated by the Keystone XL alone). To replace the Keystone XL with rail shipments would mean another doubling of rail capacity, but that would be just another couple of years given this trend.

The Association of American Railroads points out that over 11 billion gallons of crude were shipped in 2013, so these spills account for only one-hundredth of one percent. On the other hand, the environment and people’s health don’t care about what made it though OK, just what was spilled.

Our railroad infrastructure was not built to handle this mass of crude on its system and doesn’t use enough specialty cars. If this trend continues, major infrastructure investments need to occur on both sides of the border, as well as significant changes in protocol and regulation.

Like: big oil trains have to go slower, or oil tank cars have to be hazardous material cars.

It turns out that the rail industry recently modified its guidelines in response to the Quebec derailment (Congressional Research Service) as follows:

  • restrict train speeds to less than 50 mph
  • increase the frequency of track maintenance
  • install wayside defective equipment detectors, such as “hot box” detectors, that detect wheels with faulty bearings, every 40 miles, with specific protocols for conductors when defects are indicated
  • use only track in good condition to support speeds of 25 mph or higher.

Reducing train speed can reduce the number of cars that derail as well as the likelihood that oil will be released from those cars, or that explosions will result.

Truck

Although the news is filled with comparisons between pipelines and trains, the third vector is trucks. While we can compare relative risks, the issue with trucking is that it takes lots and lots of trucks to move billions of gallons of crude since a single tank trailer only holds about 9,000 gallons or 200 barrels, a little under a third of a rail car. Our present fleet only handles 4% of our needs, so shipping by truck instead of the Keystone XL would take another million-and-a-half tanker trucks. Trucking is the most risky form of transport from an accident standpoint (yes, driving is one of those things, like smoking, that will always be in the top four most risky things to doWhat’s Really Gonna Kill You?) and also from a spill standpoint. However, it is the least impactive from an environmental standpoint since each truck is small and is mainly on land, so large spills to waterways are less likely than any other mode of transport.

What is important to note, however, is that regardless of the long-hauling mode, most petroleum eventually gets onto a truck for the short moves. This limits the tons-mile risk but increases the incident number risk.

In a white paper about the dangers of transporting dangerous goods by truck, the Canadian Trucking Alliance repeats its long-standing position that “the federal government should introduce a universal mandate requiring all trucks, where the driver is currently required to carry a logbook under the federal hours of service regulations, to be equipped with an electronic recording device; and introduce a manufacturing standard (in lock-step with the United States) requiring all new heavy trucks to be equipped with a roll stability system” (Canadian Trucking Alliance). In addition, the Alliance wants all Canadian provinces and U.S. states to follow Ontario’s and Quebec’s lead by requiring truck speed limiters.

Boat

Ship transport is possible along coastal waters and along large rivers and is the method that is used for almost all foreign imports except from Canada. The thing about ships is that they carry a lot of oil per boat and many of the largest spills in history are from boats, such as the Exxon Valdez and the latest one from a collision in the Houston Ship Channel just last month (NOLA).

Five out of the ten largest oil spills in U.S. history were from boats (List of oil spills). Most important is that they have immediate impact on aquatic ecosystems both in the ocean, in rivers, or along shorelines that are usually sensitive habitats. I still don’t understand why these keep happening with modern technologies to detect water depth and nearby boats. Human error needs to be better removed from this equation.

Pipeline

The most controversial transport mode today is pipeline, mainly because of the Keystone XL debate and the recent Pegasus and Enbridge pipeline ruptures. The industry points to the generally good safety record in terms of percentages. Among oil pipeline workers, the rate hospitalization was 30 times lower compared to rail workers involved in transporting oil, and 37 times lower than for road transport, between 2005 and 2009, the latest period for which complete data exists (Intermodal Safety in the Transport of Oil).

But pipeline spills are inevitable. About 280 pipeline spills occur each year in the U.S. that are deemed significant (USDOT), that is, either there is a fatality or injury requiring in-patient hospitalization, it causes $50,000 or more in total costs (measured in 1984 dollars), there are highly volatile liquid releases of more than 5 barrels or other liquid releases of more than 50 barrels, or there are liquid releases that result in an unintentional fire or explosion.

Again, you’ll notice that these measures are in human health and property damage, not environmental effects. Environmental impacts are very difficult to estimate and, in almost all cases, are not even attempted.

In the end, all of these transportation modes can be made safer if stricter regulatory controls and modern technologies are emplaced, but the questions remain – can we make the industry comply and which ones do we want to invest in?

Finally, what brave reader wants to calculate the value of an acre of land destroyed by an oil spill? The EU recently allotted $100 per acre for removing pristine land for energy use, but this seems way too low. My muse suggests you start with Sierra Club, NRDC and EDF.

More Trains equal More Train Crashes with cars and trucks; trend reversal

Repost from The Milwaukee Wisconsin Sentinel Journal
[Editor: Note that references here to Wisconsin’s “frac sand mining” are NOT describing tar-sands mining of bitumen.  Rather, there is a boom in Wisconsin for “SILICA SAND, which is mined and exported to states like North Dakota, Pennsylvania and Texas where it is used in hydraulic fracturing, or fracking. The tough, crystallized sand, unique to the Wisconsin-Minnesota area, is hard enough to break through rock and release natural gas.”  Source: The Cap Times.  – RS]

More trains lead to more crashes with vehicles in Wisconsin

Recent booms in sand mining in Wisconsin and crude oil from shale in North Dakota.

By Lydia Mulvany of the Journal Sentinel  |  April 26, 2014 3:49 p.m.

Laurel Norlander grew up down the road from train tracks that trace the edge of Lake Wissota outside Chippewa Falls.

She’d been crossing those tracks her whole life, but that didn’t help the night of Jan. 3, 2013. The 60-year-old was returning to town after a visit to her parents’ home. She stopped at the stop sign before the tracks, but didn’t see or hear an oncoming Canadian National train. The train conductor told investigators he blew the whistle, but Norlander says she’s sure the train never did. They collided, leaving her with a totaled car and a bruised leg.

“It was very bizarre, and I’m grateful to be alive,” she said. “But at an uncontrolled intersection, it would sure be nice if they would blow the horn.”

Norlander’s crash was the first of 60 crashes between trains and highway users in 2013, the highest number Wisconsin has seen in five years. Injuries are at a six-year high, at 21. In addition, there were three deaths.

One possible factor in the rise is increased train traffic in the state, a result of recent booms in sand mining in Wisconsin and crude oil from shale in North Dakota.

Products of the state’s sand mining operations, which have grown from a handful in 2010 to well over 100, are used in hydraulic fracturing, or fracking, a process for extracting oil and natural gas. Crude oil, some of which passes by rail through Wisconsin, has similarly exploded. According to the American Association of Railroads, railroads nationwide transported 9,500 carloads of crude in 2008. In 2012, that number jumped to 234,000, and the most recent estimates for 2013 are around 400,000.

Trains on the tracks where Norlander was struck used to be few and far between, Norlander said, but a new sand plant in town has changed that.

“There’s been quite an increase in train traffic,” she said.

Jeff Plale, the state’s commissioner of railroads, said it seemed as if trains and cars were crashing every time he turns around.

“We have more trains going through the state, they’re heavier, they’re longer. Stop playing with the trains,” he said. “I’m just tired of it, because these (accidents) are so preventable.”

Plale said that besides increased train traffic, some railroads that weren’t in use have been revived, so people aren’t accustomed to seeing the trains.

“All of a sudden you’ve gone from having no trains or very few, and now you have a whole bunch of them. It’s a matter of being cognizant and safe,” he said.

Much of the sand mining activity in Wisconsin has occurred in the region governed by the Western Central Wisconsin Regional Planning Commission, which includes Chippewa County. Train-highway incidents there are at their highest in more than a decade.

According to a Milwaukee Journal Sentinel analysis, there were 11 crashes with trains at highway crossings in Barron, Chippewa, Clark, Dunn, Eau Claire and St. Croix counties. It hasn’t been that high since 2001, a year when the state saw more than 100 rail-highway incidents.

Rail accidents at road crossings have been steadily declining since a peak in the late 1970s, when the annual totals for Wisconsin were 450 and higher. In contrast, there were just 33 crashes in 2010.

Federal Rail Administration spokesman Michael England said reasons for the decline are stepped-up enforcement, advances in technology and a large increase in crossings with lights and gates.

There are more than 4,000 rail-highway crossings in Wisconsin. Of these, about 800 have both flashing lights and gates, a thousand have flashing lights, and 2,200 have only crossbucks. The average cost of installing gates is around $200,000, and the Office of the Commissioner of Railroads spends $4.4 million a year upgrading crossings.

Whatever the signage, crossings can be deadly. In many of the 2013 accidents, drivers went around gates or failed to stop. But cars also got stuck on the rails, in snow, or slid on ice into a train’s path.

Clarence Drewa, 87, a Palmyra resident, was driving Nov. 7 on Benson Ave. in Vernon when his tire got stuck in the railroad tracks. When he saw a train coming, he exited the car, his daughter, Sandra Stefanski, said. But the train struck the car and sent it hurling toward him. Among other injuries, his ribs were marred by fractures, and he died a week and a half later, she said.

The most tragic part was when two of his grandchildren, ages 5 and 6, were looking for their grandpa to come home.

“He was in all of our lives daily, and he was a very healthy man,” his daughter said.

Oregon Department of Transportation serving rail companies rather than public

Repost from The Oregonian
[Editor: QUESTION: has anyone asked the California DOT for similar information?  Here is a simpler version of this article from Grist: Oregon Tells oil companies to keep oil deliveries secret.   – RS]

ODOT acts to limit disclosure of oil train shipments after The Oregonian won its release

By Rob Davis | April 22, 2014
oil train report redactions
Heavily redacted forms released by ODOT show where oil moves by rail in Oregon and the specific volume. The agency plans to no longer seek the reports.

The Oregon Department of Transportation, the state’s rail safety overseer, says it will no longer ask railroads for reports detailing where crude oil moves through the state after The Oregonian successfully sought to have them made public.

Railroads “provided us courtesy copies with the understanding we wouldn’t share it — believing it might be protected,” ODOT spokesman David Thompson said in an email. “We now know that the info is NOT protected; so do the railroads.”

The result? At a time of heightened public concern about increasing volumes of crude oil moving by rail in Oregon, ODOT is reducing the flow of information that has benefited not only the public but its own employees.

State law requires railroads to annually submit detailed reports saying what dangerous substances they’ve moved, where and in what volume. They’re due to emergency responders across the state by March 1 of each year. That hasn’t been happening.

The reports have been sent to ODOT instead, which historically acted as a central hub, providing the information on request to firefighters across the state.

ODOT officials say that process needs reform. But as ODOT begins working to change those disclosure rules, its officials say they no longer need any reports.

“The exact quantity of those specific shipments doesn’t impact our work,” said Shelley Snow, another ODOT spokeswoman. “Our focus is on any and all shipments traveling through the state.”

If ODOT safety inspectors need to know anything about hazardous material trends, Snow said, they can call railroads to ask.

The reports ODOT has received are the public’s only way to know how much oil moves by rail through specific corridors in Oregon. They provide the most comprehensive view of the volumes hauled through Portland, Salem, Bend, Eugene and Klamath Falls.

oil train.JPG
Trains in Oregon carry the same type of flammable North Dakota oil involved in three high-profile explosions last year, including one that killed 47 people and leveled part of a Canadian town.  Rob Davis/The Oregonian

They’ve also been valuable for ODOT’s employees. Michael Eyer, a retired ODOT rail safety inspector, said he used the annual reports to do his job. The reports helped Eyer spot trends, see whether new hazards were moving and decide where to target his field inspections.

“It was our only institutional memory,” Eyer said. “There’s no other place to get the data, no other way to have this information.”

Railroads won’t tell the public how much hazardous material such as crude oil they move, saying it’s a security risk, even though the tank cars move openly in labeled containers.

The Oregonian in March obtained an order from the state Department of Justice that required ODOT to release the reports. Not disclosing them “could infringe on the public’s ability to assess the local and statewide risks” posed by crude oil rail shipments, a Justice Department attorney said.

The heavily redacted forms showed exactly where oil moved in the state through 2012. But ODOT said it did not have reports for 2013, a year in which oil-by-rail shipments increased 250 percent in Oregon.

The Oregonian requested 2013 records on April 14, more than a month after they were due. ODOT said it still didn’t have them and didn’t plan to seek them from railroads.

The decision typifies the unusual lengths to which ODOT goes to accommodate the railroads it regulates. Though it is supposed to be an independent safety watchdog, ODOT’s rail division treats the companies it oversees as cooperative stakeholders.

“I’m certainly concerned by what I hear and want to find out about that,” said state Rep. Barbara Smith Warner, a Portland Democrat who’s taken an interest in oil train safety.

Eyer and another retired ODOT rail official said the agency’s move is a bad idea that could threaten public safety.

“Because of your records request, they’re trying to bail out,” Eyer said. “I don’t think for safety it’s the wisest decision. It puts us in a situation where no one knows the overall picture. Things will fall through the cracks.”

If the reports aren’t collected, new rail inspectors hired by ODOT won’t have any background material to know what’s historically moved around the state, Eyer said. “Any new inspector coming in will be dependent on the kindness of strangers,” he said.

Claudia Howells, a former ODOT rail administrator, said forcing the state’s lone hazardous materials inspector to make phone calls to determine what dangerous substances were moving around the state would only add to the workload of someone already responsible for overseeing tens of thousands of shipments statewide.

“Part of the function of government regulatory systems is to act as a referee and provide assurance to the public that things are as they should be,” Howells said. “Right now, I have a higher level of confidence in the railroads than their regulator.”

Outgoing chair of NTSB: U.S. not prepared, not enough NTSB investigators

Repost from Bloomberg News

Communities Not Prepared for Worst-Case Rail Accidents: NTSB

By Patrick Ambrosio Apr 22, 2014 7:38 AM

Bloomberg BNA — Deborah Hersman, the outgoing chairman of the National Transportation Safety Board, said April 21 that U.S. communities are not prepared to respond adequately to worst-case accidents involving trains carrying crude oil and ethanol.

Answering questions following her farewell address at the National Press Club in Washington, Hersman said U.S. regulators are behind the curve in addressing the transport of hazardous liquids by rail. She said federal regulations have not been revised to address the increase in rail transport of crude oil and other flammable liquids—an increase of over 440 percent since 2005.

Hersman, who is leaving her post at NTSB April 25 to serve as president of the National Safety Council, said the petroleum industry and first responders don’t have provisions in place to address a worst-case scenario event involving a train carrying crude oil or ethanol. She said several catastrophic accidents have involved crude oil, including a July 2013 train derailment in Lac-Mégantic, Quebec, that resulted in 47 fatalities.

The NTSB, in conjunction with the Transportation Safety Board of Canada, identified regulatory steps that could be taken by the Transportation Department to address safety risks, including expanded route planning requirements for crude oil shipments, the addition of a requirement for carriers to develop response plans for incidents involving crude oil shipments and increased audits of shippers and carriers to ensure that hazardous liquids are properly classified.

Hersman said the NTSB scheduled a two-day forum to hear from first responders and the petroleum and rail industries on safety issues. The forum, which will be held on April 22-23 in Washington, will include discussions on tank car design, emergency response to releases of flammable liquids and federal oversight of crude oil and ethanol transport, according to an agenda posted on the NTSB’s website.

Tank Car Safety

When asked about the adequacy of the DOT-111 rail tank car to carry crude oil, Hersman reiterated the NTSB’s position that the tank cars are not safe to carry hazardous liquids.

The NTSB recommended in 2009 that all new and existing tank cars in crude oil and ethanol service be equipped with additional safety design features, including enhanced tank head and shell puncture resistance systems, top fittings protection and bottom outlet valves that remain closed during accidents.

“We have said that they are not safe enough to carry hazardous liquids,” Hersman said about the DOT-111 legacy cars. “Carrying corn oil is fine, carrying crude oil is not.”

The Pipeline and Hazardous Materials Safety Administration and the Federal Railroad Administration is working on a proposed rule to update the federal design standards for DOT-111 rail tank cars used to transport hazardous liquids. The consensus among industry and regulators is that new design standards are needed, but there is disagreement over whether the new safety requirements should be more stringent than the CPC-1232 standard, a voluntary industry standard adopted for all new tank cars ordered after Oct. 1, 2011.

Staffing Limitations Said to Delay Work

NTSB staff needs support from Congress to fulfill their mission, Hersman said. At present, she said the NTSB is involved in more than 20 rail accident investigations but only has “about 10 rail investigators.”

“We’re going to have to turn down accidents that occur in the future because we have too much on our plate.”