Photo A hiker pauses to check the view on the shoulder of Storm King Mountain in the Hudson Highlands.Credit Andrew C. Revkin
On Sunday, I spent the afternoon accompanying my wife as she led a hike up Storm King Mountain, the imposing northern terminus of the ancient, history-rich and stunning Hudson Highlands.
As we ascended the 1,300-foot-high windswept knob, I was reminded continually of a remarkable gathering last December of environmentalists, lawyers and scholars who played critical roles in defeating a plan proposed by Consolidated Edison in 1962 to embed a pumped-storage hydroelectric plant in the mountain.
Photo Consolidated Edison's 1962 proposal for a pumped-storage power facility in Storm King Mountain was abandoned in 1979 over scenic and environmental concerns.Credit Marist Environmental History Project
It was the kind of facility that's much needed even today, able to store energy when electricity supplies are high and demand low, then pour it into the grid at peak times of day. But Storm King was absolutely the worst possible location. Opposition initially focused on the harm to the region's scenic splendor. (The fight gave birth to the group Scenic Hudson.) But as litigation and analysis proceeded, it became clear the turbines would threaten striped bass populations, as well. (This issue was brought to light in a 1965 Sports Illustrated article by Bob Boyle.)
Even a 1966 redesign that would have been hidden the facility deep in the granite was defeated. Eventually, shifts in electricity demand and the utility's business model, along with the sustained court challenges, killed the project.
But the story really only began at the end, given how the battle for Storm King established precedents that have since given environmental campaigners and communities far more influence on such projects. (For the full legal tale, read "Storm King Revisited: A View From the Mountaintop" — a Pace Environmental Law Review paper by Albert K. Butzel, a lawyer on the case for 15 years.)
The December gathering, just across the Hudson from the mountain, in Garrison, centered on a lecture by the University of Oklahoma historian Robert D. Lifset, laying out the observations in "Power on the Hudson: Storm King Mountain and the Emergence of Modern American Environmentalism," his rich new history of that event and how it shaped environmental activism and law ever since.
Lifset gave me permission to post his lecture. Take your time and read it below, and I hope you'll explore his book, as well. An excerpt is posted here. The book is as rich, nuanced and multi-dimensional as the complex challenges Americans face whenever weighing energy needs against environmental constraints.
Remembering Storm King
By Robert D. Lifset
In the time that I have I want to think about three questions.
First, why are we here? What precisely happened in the Hudson River valley in the 1960s and '70s? What was the nature of this environmental struggle?
Second, why did it happen? Why did this particular environmental struggle drag on for seventeen years? Why did the environmentalists prevail?
Third, why does any of this matter? Why should we care? What has been the impact of the struggle over Storm King Mountain? What is the meaning of this struggle?
First, as to the nature of the struggle over Storm King Mountain, the facts are fairly well known. In the fall of 1962 Consolidated Edison proposed to build a pumped- storage hydroelectric plant at Storm King Mountain. The company quickly gained the support of the Town and Village of Cornwall, as well as the established environmental organizations at the time: the Palisades Interstate Park Commission, the Hudson River Conservation Society. Con Ed applied for a license from the Federal Power Commission (FPC) in 1963 and expected the plant to be operational in 1965.
However, there soon developed a small opposition consisting of dissident members of the Hudson River Conservation Society and Leo Rothschild, the conservation chair of the New York-New Jersey Trail Conference. Together they began to plan a response resulting in the creation of the Scenic Hudson Preservation Conference in November 1963. Scenic Hudson was designed to serve as a clearing-house for information and base of operations for those opposed to Con Ed's plans. It was ad-hoc, temporary, a coalition of existing environmental groups and for its first several years not particularly effective.
Scenic Hudson was steamrolled in a series of hearings convened by the Federal Power Commission in 1964 and 1965. The arguments advanced by Scenic Hudson focused on the damage the plant would render to the historic, recreational and aesthetic values of the landscape. These arguments were noted and brushed aside by the FPC. The Commission issued a license in 1965.
At this point the story takes an interesting turn and the gentlemen sitting to my left each played a critical role in changing the fortunes of the environmental opposition.
First, Scenic Hudson hired Lloyd Garrison of the prominent Manhattan law firm Paul, Weiss, Rifkind, Wharton and Garrison to handle an appeal of the FPC decision. Al Butzel was a young associate at Paul Weiss in 1965 who gets drawn into a case that dramatically changed the direction of his legal career. Garrison and Butzel succeeded in persuading the 2nd Circuit Court of Appeals that the FPC had failed to build a full and complete record upon which to render a decision. The court overturned the FPC license and remanded the case back to the FPC. This bought the environmental opposition valuable time. This was the first time that an FPC license had been reversed on environmental grounds and the first time that environmental activists gained standing to sue in federal court.
Photo Richard Ottinger, a former congressman and Pace University law professor, and Robert Boyle, an environmentalist and author, at a meeting recalling the Storm King power plant fight, in December, 2014.Credit Andrew C. Revkin
In 1964, Richard Ottinger became the first Democrat elected to New York's 25th Congressional District since the Civil War. Representing a district that hugged the east bank of the Hudson River, he accomplished this feat by appealing to Republican suburbanites upset about the state of the river. Among other things, upon entering Congress he introduced the Hudson Highlands National Scenic Riverway bill which would create a compact between New Jersey, New York and the federal government so as to plan for changes to the river landscape on a regional as opposed to piece meal basis. The bill provided the opportunity to hold hearings, and create platforms that would allow opponents of the plant an opportunity to make their case. This was part of a sophisticated public relations strategy spearheaded by Mike Kitzmiller to attack both Con Ed and the company's primary political support: Gov. Nelson Rockefeller. When I say that the environmentalists seated before you are tough, they not only went after those engaged in environmentally destructive activities, they went after those who supported those who were engaged in such activities.
Speaking of tough, last but certainly not least there is Robert Boyle. In the early 1960s Boyle began writing stories for Sports Illustrated about the ecological diversity of the Hudson River and the fish kills caused by Con Ed's new nuclear power plant at Indian Point. Boyle did two things that altered the direction of the fight over Storm King. First, he introduced the issue of fish kills. Boyle's reportage revealed that the intake pipes for the Storm King plant were to rest on top of the spawning ground of the Hudson River striped bass with the likely impact of decimating the fish population.
To make maters worse, the company had put forward a scientist who clearly perjured himself at the 1964 FPC hearings when he testified that Con Ed's plant would have no impact on Hudson River fish. The fish issue, unlike a defense of the aesthetics of the Hudson River valley, injected a scientifically quantifiable issue into the arsenal of arguments of the environmental opposition. And unlike the previous questions raised about Con Ed's engineering studies or its calculations demonstrating the plant was necessary, it rested squarely within a field, ecology, where the company and the FPC had no expertise and were clearly uncomfortable. At the end of the day, more than any other, it was Con Ed's inability to successfully confront the fish issue that allowed the environmental opposition to prevail.
Photo Fishing organizations fought the Storm King power plant planCredit Marist College / Scenic Hudson
Second, in 1966 Boyle founded the Hudson River Fisherman's Association, the forerunner to Riverkeeper, which quickly began to identify and attack polluters up and down the river. But a special target were always Con Ed's Hudson River power plants whose thermal pollution attracted and killed large numbers of fish. When the Natural Resources Defense Council was created in 1970, its first client was the Hudson River Fisherman's Society and their first target was Con Ed's nuclear power plants at Indian Point. The pressure N.R.D.C. brought to bear on Con Ed's larger operations along the Hudson River would come to play an important role in how this story ends.
But before we get to that ending we should recognize that the fifteen years between the December 1965 2nd Circuit decision and the 1980 settlement consisted of a long hard struggle fought along legal, political and public fronts.
In 1966 the FPC convened a new round of hearings that resulted in a new license in 1970. These hearings were far more extensive because the commission did not want to repeat the embarrassment of being told by a federal appellate court that it had failed to develop an adequate record, and because there was now a much larger and better funded community of environmental activists intervening to oppose the plant. An additional factor was the success of Scenic Hudson in shaping the public perception of Con Ed's project. While in 1962 the larger public might be characterized as indifferent or mildly impressed with the engineering feat of a pumped-storage hydroelectric plant, by the late 1960s, the tide of opinion had begun to turn and a new conventional wisdom began to emerge. This new narrative held that the benefits of a plant at Storm King were outweighed by the environmental costs. This was reflected in many of the Hudson River valley and New York City newspapers, and it helps to explain how the City of New York and eventually even the Palisades Interstate Park Commission came to intervene in the FPC hearings in opposition to Con Ed.
Nonetheless, Con Ed acquired another license for a plant at Storm King, a license that now stood up to judicial scrutiny. Construction of the plant began in 1974 only to be halted by an injunction from a federal judge on a suit filed by Al Butzel. The judge agreed that that the plant needed permits from the Army Corp of Engineers subject to the approval of the EPA to be in compliance with the Clean Water Act. At this point, Con Ed agreed to essentially freeze the license so as to have time to fund additional studies on the impact of the plant on the river's ecology. But for reasons I will discuss in a moment, Con Ed decided, in 1974, not to build the plant (this was a full six years before it formally relinquished the license in 1980).
All of this drew on the hard work and dedication of a large number of people who for the sake of brevity I can list only a few: Walter Boardman, Robert Burnap, Richard Pough, Stephen and Smokey Duggan, Ben Frazier, Alexander Saunders, Carl Carmer, Susan Reed, Nancy Mathews, Franny Reese, Richard deRham, Dave Sive, and Whitney North Seymour Jr. Many more discussed in the book and I am painfully aware of how even the book only begins to do justice to the contributions made by a very large and diverse number of people.
The fight formally ended with what The New York Times dubbed the "Hudson River Peace Treaty" (The Times took a strong editorial position against the plant in 1963 and closely followed this struggle for the next seventeen years). The treaty was the result of eighteen months of secret negotiations between Scenic Hudson, N.R.D.C., the Hudson River Fisherman's Association, Con Ed, Central Hudson Gas & Electric, Orange and Rockland Utilities, Inc., Niagara Mohawk Power Corporation, the Power Authority of the State of New York, the New York DEC, New York Attorney General's Office and the EPA. It was overseen by Russell Train; the nation's second EPA administrator, a former federal judge and president of the World Wildlife Fund.
Con Ed surrendered the license and agreed to fund the Hudson River Foundation: an organization created to support scientific research on the river. In return, the utility companies would not have to build cooling towers on their Hudson River power plants; they would instead regulate how the plants were operated so as to minimize the fish kills, they would not be forced to follow the strict letter of the Clean Water Act, to use the "best available technology" to mitigate the fish kills caused by their thermal pollution.
The environmentalists prevailed at Storm King in part because they gained leverage over Con Ed by attacking the environmental impacts of its remaining Hudson River plants. But they also created that leverage, by seeing to it that thermal pollution was included in the Clean Water Act as a form of pollution. Indeed the success of the Hudson River Fisherman's Association in finally finding a US Attorney willing to use the 1899 Refuse Act (a law rediscovered by Robert Boyle) to prosecute Hudson River polluters, and the spread of such prosecutions across the country produced a legal nightmare for industry which created the impetus for the Clean Water Act (1972) in the first place.
While these events are fairly well known, what is less well known is an understanding of why they unfolded as they did.
To answer this question I want to first focus on Con Ed. Consolidated Edison felt enormous pressure to expand its production capacity to meet an electrical demand that doubled every ten years. To be sure, Con Ed actively encouraged the increase in demand for it was a central part of the company's business plan, a plan widely followed throughout the American utility industry. The idea was that increasing demand created the business that could justify building new larger power plants. By taking advantage of economies of scale, and by building more efficient new plants, utility companies, in the first six decades of the 20th century, managed to meet expanding demand while simultaneously lowering prices. The lesson for Con Ed and its peers was that growth produced efficiency.
All of this fell apart in the 1960s and '70s for reasons I'll get to in a moment, suffice it to say the executives who ran Con Ed fervently believed that the inability to continually build new power plants would be a disaster for the company, the economy and the nation.
As energy production doubled every decade, its environmental footprint began to make an impact. Con Ed came under increasing pressure for its contribution to New York City's air pollution problem after a series of incidents in the 1950s and early '60s provided the issue greater visibility (no pun intended). With no formal announcement or debate, Con Ed decided to site as much future generating capacity as possible in the Hudson River valley. Between 1950 and 1976 five new power plants were constructed along a thirty-mile stretch of the Hudson River: Danskammer, Roseton, Indian Point, Lovett and Bowline. In 1969, Con Ed published a ten-year plan that called for six thousand new megawatts of generating capacity, five thousand of which would be located in the Hudson River valley.
So here we have the beginning of an understanding as to why Con Ed was so persistent in its desire to build a power plant at Storm King. The company felt it had no choice but to add new generating capacity; it was becoming increasingly difficult to add that capacity in New York City; and it needed to maintain the ability to add new capacity here in the Hudson River valley. Additionally, the pumped-storage plant itself effectively increased the company's efficiency (by pumping water to a holding pond at night thereby taking advantage of unused generating capacity) while improving its environmental credentials (the hydro plant emitted no air pollution).
So if this is why Con Ed dug in, why were the environmentalists so dogged in their opposition to a power plant at Storm King? In the book I suggest that stretching back to the mid-19th century, there have been two competing visions or conceptions of the Hudson River valley: one vision focused on the aesthetic and recreational possibilities of the valley, and the other on its commercial and industrial development. Indeed, this tension can be quite literally seen in many Hudson River school paintings that simultaneously depict both the landscape's aesthetic charms while noting the presence of industry.
The dogged determination of a rising environmental opposition can be traced to the growing belief that this balance between industry and aesthetics, between energy and the environment, had been lost and was deteriorating. This point was driven home when Con Ed published an artistic rendering of the Storm King plant in its 1963 Annual Shareholder Report. Environmental activists had long been fighting the trap-rock industry as it slowly dynamited sections of the palisades and Hudson Highlands. The Palisades Interstate Park Commission and Hudson River Conservation Society directly emerged from these struggles. Con Ed's image of Storm King arrived at a time when there existed the belief that much of the landscape had been effectively protected, and so the artistic rendering depicting a large gash in the mountain hit a nerve. At the same time, over a century of commercial and industrial development along the river, much of this development now in decline, had left an environmental impact that fostered the impression that the Hudson was a highly polluted wasteland.
But to those who had a closer relationship to the river, the working-class residents who could not afford to vacation in far-away places, or the recreational and commercial fisherman, the river was the depository of a tremendous ecological diversity and was in fact capable of being restored to a healthier state.
The eventual popularity of the opposition to Con Ed's plans for a power plant at Storm King then owes something to the relationship residents had toward the larger Hudson River and environment in general. The plant was viewed as the opening wedge in a new re-industrialization of the Hudson River valley, considering Con Ed's plans for the region this was not an unrealistic or paranoid view in the 1960s. This produced a sense of urgency and unwillingness to compromise.
All of this is to say, that the struggle over Storm King Mountain took on a meaning and importance for both Con Ed and the environmental community that eclipsed the details and importance of this particular plant.
Next question: why did the environmentalists win? The environmental opposition grew sufficiently strong and creative to delay the plant until the underlying economic conditions sufficiently changed so as to render the plant unnecessary. The strategy was always to kill the plant, not delay it indefinitely. Some of the delay owes something to the Federal Power Commission and its desire to build a complete record in light of being taken to the woodshed by the 2nd Circuit Court of Appeals in 1965; we might also point to the nature of the fish issue. What precisely would be the impact of this plant on the Hudson River striped bass? Could hatchery operations compensate for the destruction of the fish that might take place? Unlike questions about the aesthetics of the plant or its engineering, the fish issue required multi-year studies in the field. Without the 1965 decision, Con Ed might have been able to quickly build the plant and simply present the plant's ecological destruction as a fait accompli; but the '65 decision foreclosed that possible future. The plant was not being built, too much attention by the judiciary, the FPC and the public made it impossible to bury the fish issue under the advantages of the plant.
We should also take note that the opposition to the plant benefited from the strong tailwinds of a rising environmental movement. Scenic Hudson's case before the public was strong because a growing number of people were persuaded to view the issue as Scenic Hudson did. Even when it was framed in a manner that most benefited Con Ed: one of aesthetic beauty vs. needed power; a growing number of people, and most of the press found in favor of beauty. They did so because it was possible to see in one's everyday life, the toll exacted by a brand of industrial and commercial progress that took no account for environmental consequences. Howard Zahniser of the Wilderness Society reflected the feeling of many environmentalists in the 1960s when he wrote, about the struggle over the Grand Canyon, "We're not fighting progress, we're making it." From the pollution, derelict structures, and fish kills there emerged a powerful new consensus that something had to be done. Here in the Hudson River valley the then president of the Audubon Society expressed it best when he wrote in 1964 that the Storm King project became controversial "because it has brought home the truth that a line must be drawn somewhere if America is not to lose one of its great scenic treasures."
I should add that Scenic Hudson effectively found ways to organize and channel this new emerging consensus toward an opposition to Con Ed's plans for Storm King. In addition to challenging Con Ed before the FPC and in court, Scenic Hudson organized highly publicized protests (one of which included a hike led by Justice William O. Douglas), and it played a role in creating venues, from the Bear Mountain hearings in November of 1964 to the Congressional hearings on Ottinger's bill in 1965 that provided a platform where the opposition could be heard and their views publicized. Scenic Hudson never allowed Con Ed to publicly make a case for the Storm King plant in the press without also hearing from the opposition. In my view Scenic Hudson's effectiveness can partially be traced to the fact that the dozen or so people who founded the organization in November 1963 did not feel they had the time to launch a grass-roots operation that relied upon volunteers. So they professionalized. Within a few months, Scenic Hudson had hired a law firm, public relations firm, fundraising firm, and a full-time executive director. Whereas the earliest efforts to oppose Con Ed consisted of writing letters to responsible officials, hiring professionals brought in people like Mike Kitzmiller who once declared to me that it was his job "to piss in Con Ed's soup, and I loved it."
However, even if Scenic Hudson employed professionals it was led by volunteers. This made a difference in that Scenic Hudson was never going to compromise or give up the fight. Their belief in the justice of their cause was absolute and they could take this position because while they worried about influencing public opinion, they could afford to make powerful enemies in industry and government for their activism was unconnected to their professional lives. Scenic Hudson existed for the sole purpose of opposing a power plant at Storm King. It did not matter that the plant was popular in Cornwall, it did not matter that the Hudson River Conservation Society and Palisades Interstate Park Commission endorsed the plant, it did not matter that the company began construction in 1974. There was no compromise Con Ed might make, no obstacle, no setback that would end the opposition.
Yet, as strong as the environmental opposition became it was never strong enough to actually kill the plant. This is highly speculative, but Con Ed might have been able to swallow cooling towers, or more effectively fight them, but in the end Con Ed decided not to build this plant because the business model it, like many of its peers, had followed since the early 20th century collapsed. And as a result of that collapse, the company (a publicly regulated monopoly guaranteed a rate of return) narrowly averted bankruptcy in the spring of 1974 only after the state of New York passed an $800 million bailout.
Increased oil and natural gas prices, resulting from the larger energy crisis played a role, as did increased interest rates and inflation. But Con Ed and the industry also hit a technological wall in the 1960s when it lost the physical ability to build larger more efficient plants. (Thomas Edison's first power plant built in 1882 had an efficiency rating of 2.5%; meaning that 2.5% of the energy potential in the fuel used was actually transformed into electricity. The laws of physics limit thermal power plants to a top efficiency rating of 48%. By the early 1960s the industry was running into technological and engineering difficulty with plants designed in the mid-30s). Con Ed's business model collapsed because the company lost the ability to meet new demand while lowering prices.
Additionally, lower rates of economic growth in the 1970s and higher prices for electricity served to reduce the rate of electrical demand growth thereby reducing the pressure to add new generating capacity. Higher interest rates and inflation also encouraged Con Ed to initiate conservation programs that further eroded demand growth. All of which is to say that the environmental community delayed the plant but it was killed by the energy crisis (the focus of my next book).
So, I've covered the basic events that defined this struggle and outlined why it was important to both Con Ed and the environmental community, and why the environmentalists in the end prevailed. Now I'd like to turn our attention to the meaning and importance of the struggle over Storm King.
The struggle over Storm King has had an enormous impact on the Hudson River, the region and even the larger American environmental movement. The Hudson River Peace Treaty continues to govern how the power plants that line its banks are regulated. The agreement itself became a landmark case in the emerging field of environmental mediation.
Con Ed never again attempted to build another power plant in the Hudson River valley. I would speculate that the experience of this struggle was so traumatic for the company that it played a role in its decision to divest itself of nearly all its generating assets when New York State's electric utility market was deregulated in 1994.
Of course, all of the attention and energy channeled into opposing Con Ed's plans for Storm King did not remain focused on the mountain itself. Indeed, the opposition to the plant had always been successful in attracting people with a diverse range of interests. These interests eventually found expression in a range of new environmental organizations all of which I argue can be traced back to Storm King. They include Scenic Hudson, the Hudson River Fisherman's Association (Riverkeeper), Clearwater, the short-lived Hudson River valley Commission, the Hudson River Foundation, and the Natural Resources Defense Council (It might surprise some to know that N.R.D.C. was founded by Scenic Hudson board members on the losing end of an internal struggle over an effort to push Scenic Hudson to focus on more than Storm King).
Its clear that the struggle over Storm King played a powerful role in focusing attention on much more than the aesthetic character of the region; that the lasting legacy of this fight has been a sustained and long-lasting effort to clean up the Hudson River.
Finally, I want to address the biggest claim that has long been made about the struggle over Storm King, that this fight is the beginning of the environmental movement in America.
This is an interpretation that cannot be defended. There is a growing consensus among environmental historians that there were forms of environmental activism in the late 19th and early 20th century. And so even if the term environmentalism was only coined around 1970, it is inappropriate to dismiss these earlier forms of environmentalism as something else. In other words, the idea that pre-World War II conservationism evolved into environmentalism in the decades after World War II has effectively been dismantled by a wave of scholarship that found a concern for pollution and its impact on public health in the late 19th and early 20th century.
So if Storm King is not the beginning of environmentalism in America what is its relationship to the larger movement? I argue that Storm King is the moment environmentalism becomes modern. That is, this story provides a window that allows us to see a moment in time where the larger environmental movement is transformed. The heart of this transformation is the manner in which environmentalism embraces ecology. This might sound strange, for environmentalism and the ecology movement were terms that were practically interchangeable in the 1960s. But it is instructive for us to remember the original arguments and motivation for much of the opposition to Con Ed's plans. They rested on the damage that would be done to the aesthetic, recreational and historic character of the landscape.
These arguments were the same types of arguments deployed by environmentalists earlier in the century defending some corner of the national park system or attempting to preserve a beautiful landscape. To be sure, these activists sometimes deployed ecology but it was always a relatively minor part of the larger struggle (environmentalists fighting pollution in the early 20th century typically made arguments about public health or efficiency, they did not rely on ecology). This begins to change in the 1960s, as ecology becomes increasingly useful in its ability to quantify environmental impacts. Indeed, it is for this reason that ecology becomes labeled the "subversive science."
This usefulness owes something to changes within the discipline of ecology, but a big part of this story is how the venue of many environmental struggles shifts from the purely political realm toward political and legal fronts. That shift was made possible by the 1965 2nd Circuit Court of Appeals decision, which, for the first time, granted environmental litigants standing to sue in federal court. This access was later enshrined in the form of citizen suit provisions written into many of the environmental laws passed in the 1970s (legal scholars have long disagreed as to the whether and to what extent the '65 decision influenced the crafting of the National Environmental Policy Act of 1969).
In other words, the kinds of arguments environmentalists deployed, the nature of environmental conflict, shifted and became more ecology-focused in part because as a quantifiable science ecological arguments were more persuasive in court. And it was the struggle over Storm King that first cracked open those courtroom doors.
All of this encouraged and accelerated the growing professionalization of the American environmental movement. Scholars have largely seen this development as beneficial if not somewhat unavoidable. But we should recognize that this development was contingent on changes in the nature of environmental conflict, changes that can be traced right back to Storm King.
However, more important than the professionalization is the fact that, for all the reasons described above, the fight over Storm King fashioned a new set of tools, new forms of environmental conflict and resolution that would allow people in other communities, in other times, the means to fight for a better environment.
Thank You.
Photo Storm King Mountain draped in low clouds.Credit Jack Revkin
Postscripts | Stephen Bocking, chairman of the Environmental and Resource Science/Studies Program at Trent University, has written a fascinating related piece. Here's his key point building on Lifset's analysis:
[T]here's another point to be made here: that it wasn't just ecology, but a particular way of doing ecology, that became so useful. It's a long story, but the summary is that this controversy marked a shift from relying on ecosystem ecology to support environmental claims, to instead using population ecology (like models of striped bass populations) to make predictions of impacts. These predictions, focused on a single species, could be far more precise than vague claims about impacts on entire ecosystems. And as a result, ecosystem ecology had to often take a back seat whenever environmentalists used science to support their claims.
