Telecommuting – Cole's Version

The Information Technology and Innovation Foundation (ITIF), a small but highly respected think tank in D.C., released a report by Wendell Cox two years ago called: “Improving Quality of Life Through Telecommuting”.

The report deserves your time.  There is much I am leaving out. In fact, after reading it, why not promote telework at your company?

Summary points about the current state of Telecommuting:
  1. It is growing rapidly
  2. Demographic trends favor its growth
  3. It appears likely to emerge as second only to SOV
  4. It emerged as a mainstream organization strategy
  5. It improves economic productivity
  6. It assists in achieving public policy goals
  7. It could reduce inner-city unemployment
  8. It needs to become a key transportation strategy
  9. There are barriers.

Summary of where Telecommuting could go:
  1. It is growing rapidly in U.S. and … is poised to become more popular than transit and non-household carpools as a means of accessing work.

  2. If encouraged by public policies, it could deliver enormous economic and environmental benefits and could even play an important role in creating new opportunities for employment for lower-income Americans. [I would add that since oil prices will rise before the eCar becomes affordable by lower-income carbon commuters, this is more than a little prescient. -bg]
  3. We can get a fourfold increase of telecommuters, to 19M by 2020, and there are two steps the U.S. Government could take this for telecommuting:
  • Congress should reform the current pre-tax commuter expense plan (Internal Revenue Code Section 132). This allows employees to exclude from gross income up to $220 per month for “qualified parking” (defined as parking provided to an employee on or near the business premises of the employer) or up to up to $115 per month for qualified mass transit expense to and from work. This system biases employee decisions toward driving and transit and away from telecommuting and other modes (e.g. walking and bicycling). From an economic perspective, the ideal policy would be to simply eliminate this provision completely.

  • The Obama Administration should initiate an interagency examination of the potential benefits as well as strategies for accelerating telecommuting. This should be a part of a national effort to reduce greenhouse gas emissions and create economic opportunities for lower-income Americans (especially in inner cities, where auto availability is limited) and rural communities.

CONSIDER THAT TDP charging would likely drive far more telecommuting than would any other program. -bg

    How IBM describes road pricing

    Look how cleverly IBM packages the less-than-perfectly-acceptable concept of road pricing.  Are they smart or devious?
    To make transport management more effective, several cities across the world are trying to build intelligence into existing systems. Transport management systems and software tools have been effective to curtail traffic woes around some mega cities of the world. A smart traffic system helped Stockholm cut gridlock by 20 per cent, reduce emissions by 12 per cent and increase public transportation use dramatically. In London, a congestion management system lowered traffic volume to the mid-1980s levels. The system in Singapore can predict traffic speeds with nearly 90 per cent accuracy. With future enhancements, the system will help predict—rather than merely monitor—other traffic conditions as well.


    Creating a Market for Road User Charging

    The US Government and other governments in the developed and developing world have a problem: autonomous, motorized surface transportation (e.g., car, truck, bus and motorcycle) as it is currently powered and as its requisite infrastructure is currently funded, is unsustainable. Whether this is viewed from the perspective of demand management, environment, highway funding, or peak-oil the simple fact is that the fuel tax as a funding mechanism is grows more economically inefficient each day. As we look forward to increasingly efficient engines and alternative fuels, two of the problems (demand management and funding) will get rapidly worse.
    Some form of road-use charging, whether instead of or in addition to fuel taxes and other administration fees, is the solution most often proposed and defended. There are numerous proposals for collecting such charges using dedicated collection mechanisms.  None of these are cheap to provide or trivial to enforce. In many countries, the total cost of collecting such fees using dedicated methods range from 20 to 50% of the fees that are or could be levied.
    It can be argued that for commercial vehicles (buses, trucks) who directly use roads for profit that payment for use is not only justified, but that their operators likely have recourse to mitigating any incremental costs. It is harder to make this argument for private commuter vehicles. For this reason, acceptability of this impending tax shift requires that collection costs be arranged to be as close to zero as possible, so that such a shift can be expense neutral to the private commuter prepared to make slight adjustments in route, travel time or modality.
    We have a precedent for this in the cost of fuel tax collection – usually around 1% of revenue. The requirement to bring extreme cost control to the collection of road use charges is foreshadowed in the recent demand of the Dutch government that its now-delayed road use charging program cost no more than 5% of revenue – a demand that would have been challenging to meet.
    In the United States, where the level of fuel taxation is much lower than that in the Netherlands, the challenge will be far greater. A recent NCHRP study was designed to explore the type, scope, size and structure of system trials that policymakers might pursue. [1] One of the key questions examined was who should lead the deployment design of such a system.[2] Should the federal government plan a national system of VMT fees (federal framework)? Should the federal government help states help themselves (state framework)? Or should government foster a market for in-vehicle travel services (market framework)?
    The basis of the third idea has two components. First, it assumes that road use charging technology could be “just one application on” a telematics platform of the sophistication of a smart phone. Second, it assumes that such a telematics platform can support numerous useful and desirable applications, some of which would be payment services that support a profit, such as parking or pay as you drive insurance (PAYDI). Given these two factors, such payment services combined with the kinds of safety and traveler services proposed by other telematics programs such as Intellidrive in the US or CVIS as in the EU would comprise an attractive package that some drivers would voluntarily adopt and pay for.
    The attached ANNEX includes the full text of the description of the “market framework” as described in the NCHRP study by Sorensen (RAND). That description includes the proposal: “the federal government would let contracts with several firms (the initial “competitors” in the market) to provide metering devices and collection services and help enroll trial participants”. On reflection, it may make more sense to sell three or four automotive payment services licenses to significant telco providers. Such licenses would carry certification-level responsibility for protecting privacy, managing a high degree of charging performance, offering to state and federal government road-use metering and billing services at a pre-determined cost far below what would be expected from a dedicated road-use charging system.
    Such operating licenses, to be purchased by the telcos, would provide these firms with the market protection needed to invest significantly in telematics-based payment, safety, and other traveler apps in a market structured to deliver smart-metering apps in the same way smart phone apps are delivered today. The federal government should in turn use the revenues from these licenses to incent insurance companies to reform their insurance premium determination programs and municipalities to reform parking management.
    It is through fostering and initially protecting a market for telematics payment services that the United States can start building an attractive, for-profit, in-car payment service platform for a volunteer population. The telco providers of such a platform would be regulated for privacy protection and the protection of other consumer interests (fairness, equity, correct charge assessment, etc).
    The goals of reducing congestion and beginning the gradual shift from the way we now pay for roads, parking and insurance can begin immediately at far lower cost to the US taxpayer and with the promise of attractive services to volunteer motorists and a profit opportunity to telcos and their providers.
    (NCHRP study “System Trials to Demonstrate Mileage-Based Road Use Charges”. P.78-80)
     “6.2.3. Foster a Market for In-Vehicle Travel Services (Market Framework)
    This last framework, which represents the greatest departure from conventional thinking about how to accomplish a transition to VMT fees, is intended to address several goals in parallel: overcoming public acceptance challenges through voluntary adoption, implementing a fully operational (if initially voluntary) national system of VMT fees as quickly as possible, and reducing the cost to the government of collecting VMT fees.
    In essence, this framework envisions, and seeks to foster, the emergence of a market for in-vehicle metering devices and billing services that are capable of levying VMT fees and simultaneously supporting numerous value-added services, such as automated payment of parking fees, PAYD insurance, real-time traffic alerts, and routing suggestions based on current traffic conditions. Firms (e.g., device manufacturers, software developers, system integrators, telecommunications providers, toll road operators, and the like) would compete to provide these services, thereby driving down the cost of the required technology. Additionally, because firms would be able to collect payment for some of the additional services (e.g., a small percentage of parking fees or PAYD insurance premiums), the amount that they would need to charge the government for collecting VMT fees would be reduced. The main goal of the trials in this framework, then, would be to support and accelerate the development of this market. To do so, the federal government would let contracts with several firms (the initial “competitors” in the market) to provide metering devices and collection services and help enroll trial participants. In parallel, the federal government would fund or subsidize states that wished to examine VMT fees, cities or counties that wished to explore automated parking payment or local VMT fees, and insurance firms that wished to offer PAYD policies. These parties would then link up with one or more of the technology vendors to conduct the trials. After several years, the trials would evolve to full-scale implementation of an initially voluntary system. Trial participants that valued the additional services would become the initial adopters, and additional drivers would be able to adopt the in-vehicle equipment on a voluntary basis as well. After several more years, once it had been demonstrated that the system was operating successfully (i.e., that it was collecting fees, preventing evasion, and protecting privacy as planned), the government might then mandate the adoption of VMT fees for all vehicles. This approach to trials and implementation is described in greater detail by Grush (2010a)[3].
    Note that the role of private firms in providing metering devices, billing services, and other value-added offering would be possible in the other frameworks as well, but would not be the only approach that might be contemplated (e.g., a particular state might choose to examine the collection of VMT fees with registration in a publicly-administered system). In this framework, in contrast, the involvement of multiple competing firms in the provision of metering and billing services would be viewed as a critical component in achieving the goals of driving down costs and stimulating the development of value added services to promote voluntary adoption.
    Advantages. This framework offers several conceptually compelling advantages:
    • The opt-in period would allow time to demonstrate the effectiveness of privacy protection, fee collection, and enforcement strategies through the participation of voluntary adopters. This should reduce the current degree of public and political skepticism surrounding VMT fees, making it less difficult to mandate the adoption of VMT fees at a later date.
    • To gain market share, competing firms would be motivated to provide as many valuable add-on services as possible. This would help to maximize the benefits of the considerable social investment in in-vehicle metering technology.
    • Because the service and technology providers could collect revenue from a broader range of sources, the cost to the government for installing equipment and collecting VMT fees should be reduced.
    • On a related note, the cost to conduct the trials, on a per-participant basis, might be reduced in this framework. Provided that the government clearly signaled its intention to transition to a national system of VMT fees, firms might choose to cover some of the trial-related costs with their own resources in order to prepare a successful bid to participate in the trials, which would in turn position them as an early market leader. On the other hand, as expressed by one of the workshop participants, many firms have been “burned” by investing their own resources in European trials that did not lead to implementation and might therefore be less willing to do so again. This potential benefit is therefore far from certain.
    • The cost of installing equipment in vehicles would not be lost; rather, the same equipment would continue to be used when the trials phased directly into implementation and trial participants became early system adopters.

    Potential Drawbacks. This framework also faces several risks and obstacles:
    • In a voluntary opt-in framework involving privately provided equipment and services, it is conceivable that drivers would choose to adopt the equipment for PAYD insurance, for the chance to automate the payment of parking fees, and to enjoy other services but then choose not to pay mileage-based fees. Assuming a relatively flat per-mile rate structure, drivers of highly fuel-efficient vehicles, in particular, would be better off paying current fuel taxes than mileage fees. In order to increase voluntary payment of federal road use fees, the government would likely need to create some form of incentives. For example, it might set federal fuel taxes somewhat higher than mileage fees and then rebate fuel taxes to adopters, or it might institute some form of federal registration fee (collected by states and remitted to the federal government) that would be rebated for VMT-fee system adopters.
    • Under this framework, since it is envisioned that the trials would evolve directly to full-scale implementation, it would be appropriate to develop an initial set of interoperability standards and corresponding certification process in advance of the trials. Though possible, this would be challenging to achieve within just a year or two.
    • As a corollary to the preceding point, it would be necessary to make certain system design decisions—for example, the decision that fee collection would be handled by multiple private firms operating in parallel, rather than by a single firm or by the public sector—in advance of the trials. There would not, therefore, be the opportunity to inform such decisions based on lessons learned during the trials themselves.
    • With independently funded technology and service providers, states, cities, MPOs, insurance providers, research institutions, and the like, it could prove more difficult to manage and coordinate the trials under this framework.
    • The success of an industry-led model would depend largely on voluntary consumer adoption. The assumption is that consumers would be willing to purchase devices to have access to the add-on services. However, it is not certain that a mass market will emerge for these devices. For example, while some drivers would undoubtedly find the prospect of paying for parking via an in-vehicle device appealing, a large share of drivers have free parking for most trips and would not be interested in this application. Moreover, many of the envisioned services, such as routing assistance or stranded driver assistance, are already available on other platforms. If relatively few consumers voluntarily chose to adopt the equipment in order to gain access to the value-added features, greater government subsidies or mandates could be required. Related to this point is the observation, offered by a private sector representative, that from the service provider perspective, the “base” business case has to make sense (i.e., the ability to earn some return on investment by charging for the collection of VMT fees); it cannot be assumed that firms would recoup all of their investment from value-added services.
    • An industry-led model would create not one but two enforcement challenges: the potential for tax evasion by drivers, as well as the possibility that the firms or consortia collecting the fees would not remit them in an accurate or timely fashion. Firms might be responsible for collecting billions of dollars annually, necessitating sufficient staff on the government side to carefully monitor contracts and audit accounts as well as a plan for penalizing firms found to be in breach of contract. The federal government would also need to either augment its own enforcement resources or rely on state support to help prevent driver attempts to evade fees.[4]

    [1] Sorensen, P. (The RAND Corporation), “System Trials to Demonstrate Mileage-Based Road Use Charges”, National Cooperative Highway Research Program (TRB), October 2010, p.xv.
    [2] ibid, page 73-80
    [3] Grush, B. 2010a. http://grushhour.blogspot.com/2010/04/no-more-ruc-trials-please.html
    [4] As the author of this blog, I respectfully disagree. There are low-cost ways to set up metering and billing services to counteract both consumer and service-operator fraud. To the degree that payment via telematics can be maintained on a voluntary basis versus s fixed administrative fee that must be pre-paid to retain an vehicle license, fraud can be minimized at a cost lower than that of current enforcement systems.


    Gas tax, road pricing and the CAA

    Driving home from the Smart Transportation Summit (Toronto, 2010.12.07), I had a conversation with a colleague who had attended the Road Pricing & Smart Growth Conference in Toronto (2010.12.02).  While there, he was at a discussion table with "a young woman from the CAA" who said the CAA wants to see the Provincial (Ontario) and Federal fuel tax revenues shared in a way that might benefit the Greater Toronto and Hamilton Area (GTHA).

    My colleague asked:
    "What is the CAA's position as the gas tax dries up?"
    "What do you mean?"           
    "Well, people are buying more and more Priuses and Volts."
    "As cars become more and more electric, we won't have much fuel tax to share."
    "Oh, I never thought of that!"
    "Seriously? There are 100s of papers and government-funded studies concerned about what to do as the fuel tax dries up."
    "Huh! I didn't think the government thought that far ahead!"

    I know several automobile associations, and I have worked with a few of them. The Australian AA asked the government for road pricing schemes to relieve congestion.  The ANWB (Dutch) helped the Dutch government to design their (now iced) system.  The Royal Automobile Club Foundation (UK) has written extensively in favor of road pricing (its head, Professor Stephen Glaister, even starred in a documentary called Gridlock a few years ago to defend the now-hideous-in-hindsight London Congestion Charge.)
    The CAA is the only automobile club I know in the developed world that does not constructively engage with the road pricing conversation.  They are knee-jerk against it, and that is irresponsible to its constituents – Canada’s drivers – bordering on the criminal.

    The Canadian Automobile Association has a critical role to defend its constituency.  Our roads are inadequate, we cannot build to keep pace with congestion, and road pricing – the keystone of TDM – is critical to the solution needed to maximize performance of what we do have.

    The CAA should consider that they marginalize their voice and the interests of Canadian drivers by not coming to the table.  If you will accept that road pricing cannot be avoided forever:
    • Who, if not the CAA, is best suited to ensure that road pricing programs is deployed to keep the road under our cars, rather than to force cars off the road.
    • Who, if not the CAA, is best suited to ensure that road pricing not fund a “war on cars”.
    • Who, if not the CAA, is best suited to ensure all revenues are spent on roads, relieving congestion and making driving safer and more productive.
    • Who, if not the CAA, is best suited to insist that lower income drivers be protected with some form of progressive charging structure or rebate.
    • Who, if not the CAA, is best suited to ensure that if road-pricing revenue is spent on transit, then such transit needs to benefit the driver by significantly relieving congestion.
    • Who, if not the CAA, is best suited to ensure that road pricing is performance oriented and that only charges sufficient to manage congestion and fund roads be charged.
    • Who, if not the CAA, would have the strongest voice in the matter of privacy, i.e., that any road pricing technology must be absolutely private – preferably even more private than the devices and cameras used on the 407.
    • Who, if not the CAA, would have the strongest voice to demand that if GPS is to be used as part of the tolling system, then the guidelines regarding trip data that have been drawn up by the International Working Group on Data Protection in Telecommunications (IWGDPT), with input from the Ontario Privacy Commission must be followed.
    • Who, if not the CAA, is best suited to ensure that any payment service that a driver would use would conform to operating standards and would charge correctly.
    • Who, if not the CAA, is best suited to ensure that Canada not blindly follow the dominant America direction toward a simple mile-driven charge, which is a very expensive replacement for the fuel tax that would have no congestion abatement effect, as would a properly constituted system that considered time, place and vehicle-type, as well as distance traveled.
    Considering the earlier comment made by the CAA staffer regarding her surprise that the fuel tax is failing and her surprise that governments "thought that far ahead” perhaps we need an alternate automobile club prepared to understand the economic synergies between congestion and road-funding method, and prepared to understand that government, like a deer in the headlight, is unable to act to solve this problem because it is terrified of the massive number of uninformed and frustrated motorists so that we drivers who cannot or will not be accommodated by transit can drive at more that 9kph in the future.

    Otherwise the automobile will only continue to suffer from its own marketing success.


    San Francisco, Enlightened Population, Thoughtful Leadership

    Part 1

    As of December 4, the San Francisco County Transportation Authority has released the Draft Final Report of its Mobility, Access and Pricing Study (MAPS). I will critique this report over my next few blogs.

    There is also a overview video here, whose cover frame is overlaid with the news-byte: “Private automobiles contribute over 45% of greenhouse gas emissions.” The number generally quoted for this is closer to 33% – i.e., transportation, of which the private automobile is only a fraction, contributes about a third of GHG emissions, so that I had always understood the private automobile to be responsible for between a sixth and a quarter (depending on several other factors).  In any case, in the interest of determining how this number became inflated, I note that on page 1-8 (figure 1-4) the combined contribution of the Intraregional Road Vehicles plus the San Francisco Road Vehicles is 47%.

    So the cover statement on the video should probably read: “Cars and trucks in the San Francisco area contribute over 45% of greenhouse gas emissions.” The misquote unnecessarily demonizes the automobile.

    Still… how did the more typical number quoted as 1/3 become nearly 1/2?  The reason is at least four-fold. First, the 47% number is from 20 years ago and engine efficiency has helped to slightly lower the relative contribution of the internal combustion engine of the private automobile since then. Second, the principle forms of commence in the Bay Area would tend to make the internal combustion engine a larger relative contributor than say would be the case with refinery-heavy New Jersey (which of course leaves some of San Francisco’s road-filth on the east cost and uncounted in the 47% figure, which means 47% might even be conservative!). Third, San Francisco has greater than average congestion (for the US), which would also raise the local relative contribution of vehicular GHGs. Fourth, San Francisco, due to its latitude, needn’t heat its homes as much as more northern mega-regions, hence lowering the relative contribution of buildings re GHG emissions in the case of San Francisco.

    So, the ‘over 45%’ number is indeed believable – and alarming – and says that the solutions proposed (including congestion-pricing) may be as important for San Francisco as for any US city.  It may be that the case for congestion pricing in San Francisco is stronger than it was for Manhattan.

    Next: Plan Details.


    Rethink or Obit?

    Here is a draft preface to Overcoming Global Gridlock, my 2011 book on why it is necessary to replace fuel taxes with universal road tolls and how to make them acceptable.

    We have reached a crisis point with cars and trucks. We face mounting congestion. We need to reduce both emissions and oil consumption pretty much everywhere. In many countries funding for road building and maintenance is becoming ever harder to sustain.  All the while, demand for personal mobility and goods movement continues to expand. And there is little to indicate many people are willing to give up the private vehicle.

    If the autonomous vehicle has so many problems stacked against it, but demand for it is increasing, you can see that something has to give. This is predicted for the coming decade or two.

    Cars are important to us. Judging by their use and abuse, the mile-for-mile preference we have for them over other forms of mobility, the growth in their numbers[i], the increasing number of vehicle miles traveled each year[ii] and a hundred other indicators, it is the car we are addicted to rather than oil[iii].  Oil is just one symptom. Most of the sustainability problem as it is now will survive the end of oil.

    We can list a lot of bad things about our cars, but there are also a lot of good things.  Perhaps the good outweighs the bad – I, for one, think that it does. There are a lot of reasons we have so many cars and there are many solutions offered to deal with their overwhelming ubiquity. We needn’t review those things here. You already have an opinion. You already like or dislike cars. I am probably unable to change your mind. You already have a car (or two) or wish you had one. Or perhaps you have even managed to get rid of yours. Or not yet.

    Here is what you cannot argue with – the relationship between our species and the car is in some trouble. Our roadways scar our planet and drain our treasuries. Our cars clog these roadways; they are ravenous for fuel and clean air, and for space to park. They directly kill more people every year than all the wars on the planet; they indirectly shorten the lives of many more. And sooner or later we will have to wean the entire fleet off of oil – likely 2 billion of them by the time that happens. If you have a car and you don’t think you are addicted to it, lend it to me for a month.

    How did it get to this? Where is it going? And how much longer can we let it play out before we engage in a concerted effort to rescue the beloved private vehicle?

    When my grandfathers were youths there were no cars. The streets of large cities like Paris, Moscow and Chicago teamed with horses. Manhattan had 5mph speed limits that were routinely ignored and 200 pedestrians were trampled to death each year.[iv] The London Strand was described with streets flooded “with churnings of ‘pea soup’ (a euphemism for a slurry of horseshit and urine) that at times collected in pools over-brimming the kerbs, and others covered the road surface as with axel grease or bran-laden dust to the distraction of the wayfarer.”[v] Horse-drawn vehicle congestion was a normal condition.
    Chicago, 19th Century
    By the time my mother’s father, a blacksmith who shoed horses, entered the Great Depression he had 13 children but no work thanks to the automobile. The decades leading up to the second war saw the end of the horse and the entrenchment of the autonomous vehicle. When my father’s father reached his middle years in the ‘20s, he owned a Model-T and maintained it himself. The congestion in our great cities switched from horse to car. We could fit more vehicles on the same streets and we breathed the pollution instead of walking in it.
    New York 1929
    After the Second War, the car entered our sex-lives and our song lexicon – spilling out of our radios.

    I'll buy you a Ford Mustang, I'll buy you a Ford Mustang,
    I'll buy you a Ford Mustang if you'll just give me some of your love now
    Yeah, give me some of your love girl, yeah, you know what I want.[vi]

    When I was 13 I knew I’d drive when I was 16.  Neither of my parents nor any of theirs thought that as a teenager. A new entitlement had locked in.

    The automobile has had a good ride since the 1950’s. Road building, urban form, transport policy and automotive innovation have deepened the entitlement to the point that we have now collectively forgotten what non-automotive transport and sex-before-cars was like. For many of us, not owning a car is little like being caught naked in public.

    This entitlement, if not the car itself, is endangered. The reputation of the private vehicle is tarnished and declining.  In some circles drivers are looked on as if they still smoked cigarettes. The utility of the private vehicle is diminished by congestion. Parking has turned from minor nuisance to dreaded chore. The gap between the promise of car ads and the experience of owning one widens more each year. My fourteen-year old daughter guffaws at car ads. She looks at me funny, when I say she will be driving soon.

    In the 2010s era of peak-oil, a century after peak-horse, most big cities have speed limits of 25-35 mph, and average speeds that are far lower. Pedestrians may be a little safer in these cities than they were under horses hoofs, but now we waste time and fuel. We pollute, text co-workers that we will be late, and use GPS to find alternative routes. In my city, Toronto, resigned complaints about congestion dominate morning greetings in place of innocuous comments about the weather. Our morning and afternoon rush-hours now bleed into a single 12-hour peak.

    This trend will not self-reverse.  Left as it is tending, the utility of the autonomous vehicle is threatened. And with it we will lose what remains of the convenience, effectiveness, autonomy, pleasure and sexiness of private commuting and travel.

    This book is not anti-car. In fact it is pro-car – but in a balanced way. It is true that many drivers continue to be rude to transit, aggressive toward bikes, and threatening toward pedestrians – and like blowing smoke in the face non-smokers, drivers do that to the detriment of the way of travel they prefer.  Unless we consider new ways of thinking about the use of fuel-powered, multi-thousand-pound, autonomous, private vehicles, we risk writing the obituary of freedom that the automobile came to symbolize in the last half of the twentieth century.

    This book describes the way out.

    [i] Sperling, Two Billion Cars
    [ii] FHWA, Our Nation’s Highways 2008.
    [iii] Quote from Bush.
    [iv] Vanderbilt, Traffic
    [v] Jacobs, Death and Life page 444
    [vi] The Animals