Wild Wilderness believes that America's public recreation lands are a national treasure that must be financially supported by the American people and held in public ownership as a legacy for future generations
For those rugged outdoorsmen who need power while on the go there's now a green energy solution -- the portable Bourne hydroelectric generator (see appended article).
Would the use of this product be permitted within designated Wilderness without resorting to Presidential authorization as allowed for in the Special Provisions section of the Act? Presumably the answer comes down to whether this would be considered "motorized equipment" and whether it would be considered "an installation."
What do other think? Would land managers determine the use of this product to be illegal? If not, then might we someday be seeing such things as outfitters and packers having electrified streamside Wilderness base-camps? If so, would this be acceptable?
I don't know about you, but seeing the NPS shield share the same space with ARC's logo and watching the NPS partnering with a black-hat outfit such as this does not sit well.
Here's a link to a presentation available on the ARC's new Partners Outdoors blog.
The title slide appears above. The presentation itself is quite boring.
I encourage folks to zoom in on ARC's logo and note what it says. Then recall that these are the folks who introduced snowmobiling into Yellowstone National Park three decades ago and have fought to keep snowmobiles in the park ever since. You might reflect upon this "partnership" with that fact in mind.
To make it easier, here's a blow-up showing the ARC's byline:
In the interest of complete honestly, understand that the ARC did not yet exist as an organization when it's President, Derrick Crandall, worked with Yellowstone Superintendent Jack Anderson to open the park to recreational snowmobiling. Back then, Crandall was Director of Government Affairs for the International Snowmobile Industry Association.
Today "Privatization" is being presented as the solution to just about everything. No one should be surprised. Amongst the first words on this website's most visited page are these:
Access to public lands is deliberately being manipulated for the benefit of campground associations, private concessionaires, manufacturers and users of motorized sports vehicles, and giant tourist and recreation corporations.
Congressional budgetary cuts are intentionally creating a maintenance crisis for federally managed recreation lands and facilities.
The rescue of a badly decayed system of National Parks and recreational lands, through private corporate investment, is the planned outcome of this strategy.
Written in 1998, shortly after the passage of legislation that authorize the charging of fees to access federally-managed public lands, we explained where the new rec-fee program would end up. We described that final destination in additional bullet points within this same document, saying:
A highly influential business consortium called American Recreation Coalition (ARC) is PAYING to implement this trail fee program on your Public Lands and they are counting on enormous returns for their investment.
ARC's ultimate objective is to acquire for its corporate benefactors, 'rights' to develop and operate recreational facilities upon these Public Lands.
Well folks, that long anticipated end point is rapidly approaching.
Appended is an article from today's Salt Lake Tribune titled "Privatization a Red Ink remedy". Apparently lawmakers are now busily suggesting that parks be turned over to KOA -- which is precisely what KOA's President suggested in Congressional Testimony given in 1998.
I would add that when that testimony was given, the presenter served on the ARC's Board of Directors and his company was (as they remain today) a "Sustaining Member" of the ARC. And yes, we appreciate that this example deals with State Parks and not federal lands. We offer it to suggest that no public lands, whether federal or state owned, are safe.
Wilderness Unlimited offers private wilderness in Oregon and Washington States. They compete with publicly managed recreational venues and market themselves as an alternative for those who can afford something better. Interestingly enough "better" does not mean more developed. It means the opposite.
Here are two snippets selected from the two items which are appended.
For camping it has to be a big improvement on the Oregon State Parks Division privatization of camp grounds as fee access areas with their institutional ugliness.
There are not chain link fences with numbered spots where you pay for the day and open the door only to hit the neighbor! In fact, the only “improvements” most often added by W.U. are: an outhouse, for obvious reasons and in many areas, wooden picnic tables.
With land managers engaged in transforming public lands into pay-to-play Disney lands, the private sector has rushed in to fill the void. I don't know about you, but I much preferred public lands the way they were before recreation became the business of the land management agencies.
For those who can not quite recall when the US Forest Service actually took a wrong turn, here is a snippet quoted from a speech given by Undersecretary of Agriculture Jim Lyons in 1997. It is titled:
"VISIT US--COME AND ENJOY OUR BRAND OF OUTDOOR RECREATION" Recreation in the 21st Century: Increasing Demand, Increasing Recognition
We face some immediate and substantial challenges in this regard.
But, these challenges do afford us opportunities to explore new ways of doing business...
Opportunities to enhance partnerships with the private sector...
Opportunities to market our recreation products...
And make the Forest Service "BRAND NAME" stand for high quality outdoor recreation experiences, synonymous with our mission as an agency "Caring for the Land and Serving People", and equal--in the public's eye--to the kind of quality one comes to expect out of a...
Coleman stove, or an
REI parka, or a
day at Disneyworld, or a
run down one of the ski trails at Sun Valley
To me the opportunity is clear: we want to make the Forest Service into the Microsoft of outdoor recreation, and we've already got a good start at doing just that because, as I said earlier, the Forest Service is the world's largest supplier of outdoor recreation annually.
What follows are the first few words of the comment letter submitted today to the National Park Service. To read the entire document, click here.
Wild Wilderness is a 501(c)(3) non-profit based in Bend Oregon. Our mission is to preserve and protect opportunities for low impact recreational activities on public lands. Created in 1991, Wild Wilderness has since 1997 spoken consistently about the efforts of Federal Land managers to "commercialize, privatize and motorize recreational opportunities on America's Public lands." We have similarly, and consistently, warned of the ongoing efforts of land managers, working at the behest of, and in conjunction with, the recreation, travel and tourism industries to affect "The Corporate Takeover of Nature and the Disneyfication of the Wild."
It is our opinion that the decision-makers for Yosemite National Park have been amongst the worst offenders and, if left to their own devices would further transform Yosemite, a prime example of "America's Best Idea," into a mere Popcorn Playground", to use a favorite expression of our national's foremost living National Parks champion, Michael Frome....
The following is a coverletter recently sent to the US Forest Service. It is Wild Wilderness' response to proposed rule changes that relate to public land concessionaires, the National Parks and Federal Lands Pass, senior discounts, discounts for the disabled and the prevarication of management control of publicly owned recreation sites and facilities. Additional information is available from Western Slope NoFee Coalition.
The full comments of Wild Wilderness are available here.
To: Carolyn Holbrook (Recreation and Heritage Resources Staff)
cc: T. Tidwell, J. Holtrop, H. Kashdan, J. Bedwell
Dear Ms. Holbrook:
Wild Wilderness is a 501(c)(3) non-profit organization founded in 1991. We are located in Bend Oregon and have supporters in each of the 50 states. Our focus is outdoor recreation and public lands.
We are troubled by the direction the FS seeks to take with the proposed rule changes published in the Federal Register on December 1, 2009: "Proposed Directives for Forest Service Concession Campground Special Use Permits" (RIN 0596-AC91).
Our extensive comments are appended in PDF format. We ask that they be entered in the public record and request that your receipt of these comments be acknowledged via e-mail.
We appreciate that you, Ms. Holbrook, will carefully review the complete comment document. For the benefit of the Chief and others copied on this message I summarize here our key contentions.
It is the contention of Wild Wilderness that the proposed rule change is part and parcel of the commercialization and privatization of outdoor recreation that began with Chief F. Dale Robertson.
It is the contention of Wild Wilderness that at least portions of the proposed rule change are clearly illegal.
It is the contention of Wild Wilderness that the proposed rule change results from closed door meetings between the US Forest Service and various special interest organizations.
It is the contention of Wild Wilderness that the proposed rule change is a direct response to concessionaires whom the US Forest Service looks upon as "partners" and whose profitability the USFS seeks to increase.
It is the contention of Wild Wilderness that the Forest Service has greater allegiance to its partners than to the citizens of the United States of America and that when asked to choose between those competing interests as it has done with the proposed rule change, the Forest Services has chosen in favor of its commercial partners.
And finally, it is the contention of Wild Wilderness that the most important aspect of the proposed rule change is not the most obvious portion of the rule change. While we anticipate that the proposed changes to senior and disabled discounts will be the focus of most public comment, we believe that the proposed change regarding Standard Amenity Recreation Fees is vastly and profoundly more important. It is, in our estimation, so much more important that we might even speculate that this change was bundled with the senior and disabled discount issue so that it would effectively go unnoticed. We suggest that the most flagrantly illegal portions of the proposed rule change are associated with those provisions which deal with the charging of SARFs by concessionaires and with those provisions which permit concessionaires to NOT accept recreation passes legally authorized by the Federal Lands Recreation Enhancement Act (REA), as signed into law on December 8, 2004.
Thank you for giving our full comments careful consideration. I look forward to receiving confirmation that they have been entered into the record. We sincerely hope the FS will take no action prohibited by law or which is not in the public's best interest.
Years ago a RFID tag was mocked-up upon into a USFS Wilderness Permit. I reported upon it in a piece titled: "Digital Angel - Invasion of Privacy takes a hike."
...The "Digital Angel" is a tiny (about the size of a grain of rice) tracking device that works in conjunction with Global Positioning System (GPS) technology to allow continuous monitoring and remote tracking. It may be incorporated into identification tags/permits, inconspicuously hidden, or even implanted within the human body.
According to the manufacturer, the Digital Angel "can be used for a variety of purposes, such as providing a tamper-proof means of identification for enhanced e-business security, locating lost or missing individuals, tracking the location of valuable property and monitoring the medical conditions of at-risk patients."
One seriously proposed applications for the Digital Angel is to incorporate the device within USFS Hiking Permits. Used in conjunction with an Automatic Payment System, the Digital Angel could provide a precise method for accurately charging Wilderness Customers for the enjoyment they received. Similar versions would presumably be developed for rock climbers, ATVers, equestrians, mountain bikers and other recreational users of public lands if the Hiking Digital Angel proved to be a commercial success.
Well, that was back in 2000 and the technology is vastly "improved." Here's where the state of the art is today. It's now possible to track anything and anybody anywhere. Great stuff this technology!
Given current attitudes about Wilderness and Technology, I can see they day coming when just about all explorers of the so-called "Great Outdoors" are REQUIRED to be in possession of permits into which sophisticated tracking technology is embedded: hikers, climbers, mountain and dirtbikers alike.
Oh, who am I trying to kid suggesting that this threat is still in the future. It's upon us now, albeit not yet with its full panoply of refinements. I suppose some will feel comfortable allowing it to hide under the carpet until we trip on it, but I'm not content to do so.
Pasted below is an article from my local newspaper, published today and titled "A Beacon for All?" It ends with the words: "But the question remains: Does that technology help or hinder?"
A version of the appended news article appears following every death on Mount Hood. I fear that with every such article we get closer to the day when Wilderness hikers will be required to carry locator beacons. If and when that happens, it will only be a matter of time before more sophisticated electronic devises are required. Those devices will have the ability to track Wilderness users as if they were collared wolves and, even more ominously, direct those users to and from specific areas in order to "better manage the resource."
Even more ominously, many Wilderness organizations will support the use of such devices. Some Wilderness users will welcome them. Some will especially appreciate how those devices, employed in conjunction with Congestion Pricing, Reservations and similar tools, will provide solitude, safety and predictably wonderful Wilderness Experiences.
The first step is requiring the use of beacons. From there, all else follows naturally.
Written by Guest Tom Ribe, President of Caldera Action
Wednesday, 08 April 2009
With November’s election results, New Mexico moved into a new era of possibilities for achieving our common environmental goals. While the list of needed actions is long, the need to transform management of the Valles Caldera National Preserve in the Jemez Mountains is a high priority. As I write, the VCNP is taking a truly perilous course and it will take a strong coalition of organizations to protect this “Yellowstone of New Mexico” from commercialization and development. We hope you will actively join us.
Caldera Action is a 501(c)(3) organization founded in 2007 to advocate for the protection of the VCNP’s natural environment and to promote appropriate public access. We have a hard-working board that has studied the VCNP situation closely and we’ve drafted federal legislation to reform the VCNP. Naturally to succeed we need a full coalition of conservation, science and education groups to prevail upon a receptive Congress.
In 2000 when the federal government purchased the VCNP a compromise was struck between those who didn't want more public land in New Mexico and those who wanted the VCNP protected as federal land with high environmental standards. Rather than setting up the Preserve under an agency, a "Trust" was created to manage the Preserve. This Trust basically is a "government corporation "overseen by a board of mostly private-sector Trustees. These Trustees supervise a staff and together they struggle under a mandate to become "financially self-sufficient" by 2015. No other piece of wildland has this management structure and, frankly, it's not working.
The Trust is an “experiment” where the private sector was supposed to manage public lands better than federal agencies could. Despite a strong mandate from Congress to protect the environment at the VCNP, more and more the Preserve is being run like a business with little regard for the public interest. The new executive director has stated that his job is to commercialize the Preserve to achieve financial self sufficiency. Soon, there may be proposals for lodges, golf, full-hookup campgrounds, and new paved roads plus high public fees. Expect all this to be rushed with an aggressive PR campaign and minimal compliance with federal law.
Rather than entirely focusing on the actions of the VCNP Trustees, Caldera Action is taking a big picture view. We feel strongly that the whole Trust model is a failure and worse, it encourages privatization and the sort of commercial development on the VCNP that inspired the public to demand federal purchase back in 2000!
In response, Caldera Action has submitted a draft bill to our congressional delegation seeking to have the VCNP transferred to the National Park Service as a Preserve. The restoration of the damaged ecology would continue, protection of headwaters of the Jemez River would be an emphasis, and the VCNP would become an accessible place of rare quality where people could have exceptional outdoor experiences in a well-protected environment.
Our legislation would:
• Replace the experimental public-private Trust with professional management under the National Park Service. It will remove the unrealistic and unattainable financial self-sufficiency provision of the original Act.
• Guarantee the long-term protection of the Preserve’s natural and cultural heritage so that we can all experience the sense of wonder that comes from individual discovery of this unique and significant landscape.
• Mandate a Comprehensive Management Plan for the Preserve that will integrate resource protection, expanded public recreation, watershed restoration, scientific research and youth education, while maintaining the scientific adaptive management approach currently in place.
• Maintain and improve hunting and fishing opportunities offered on the property.
• Allow for limited domestic livestock grazing if consistent with the primary purposes of protecting natural and cultural resources, and educational, recreational, and scenic values. It will remove the mandate to operate the Preserve as a working ranch.
• Foster sustainable economic development in surrounding communities through increased visitation and provision of visitor facilities and services.
• Achieve management efficiency and cost savings by sharing administrative, law enforcement, and resource management staffs with neighboring Bandelier National Monument and incorporate the upper watersheds of Alamo, Capulin and Sanchez Canyons into the Preserve.
We feel strongly that the National Park Service is the best management agency for the VCNP given the Preserve’s national importance and the increasing demand for public access. The NPS manages 18 national preserves and a variety of other non-national park properties nation wide.
Caldera Action will call you soon to meet with you to get your ideas, discuss our proposal, and your involvement with it. We hope you will help your membership get involved as we did for the Valle Vidal so we can rescue the VCNP early in the Obama administration.
I was recently asked to review an unpublished article which delved into the
importance of fostering, preserving and garnering increased support for the
Wilderness Ethic enshrined within the 1964 Wilderness Act. I look forward to
reading that excellent article in print.
In the meanwhile, I'd like to draw attention to a very different and
disturbing article published in 2000 which enumerates the dramatic shift now
taking place with respect to the Wilderness Ethic. Rather than fostering,
preserving and garnering support for the ORIGINAL Wilderness Ethic, these
authors describe a radically altered Ethic -- one that bears no relationship to
the Wilderness Act or to the purposes for which the enduring resource of
Wilderness was originally established. The piece, which I view as presenting an extremely
probable future, is titled "Wilderness in the 21st Century". It could just as
appropriately been titled, "The End of Wilderness."
Selected text appears below with a link to the original and complete
This morning the Associated Press ran an article which has enjoyed widespread distribution. It is about the ongoing efforts of Senator Mark Udall to help the Ski Industry gain increased control over publicly owned mountains. It is about weakening the law which, since 1986, has given some measure of protection to these lands and about giving the go-ahead to forever transform Ski Areas into Four Season Mountain Resorts if not into privatized, commercialized and urbanized playgrounds. The headline given to this story by the Oregonian reads - "Environmentalists, ski industry clash over summer recreation". That's not the half of it!
Unfortunately, today's AP article was very weak. Fortunately, an excellent article was written when, then Congressman, Udall introduced this same legislation last year. That article appears below.
Pasted below is an item from the USFS' "FS Today" website. It begins with the words "A consortium of federal agencies and nonprofit organizations and the recreation industry..." and provides a link where you can "learn more."
Follow that link and you'll be taken directly to the American Recreation Coalition's website. Follow the link at the bottom of that page and you'll eventually find a list of event coordinators, sponsors and partners. Here is the direct link.
The list is headed by the two event coordinators (the ARC and the USFS), followed by 92 supporters. I encourage you to check that list.
Knowing the ARC represents the narrow interests of commercialized, privatized and motorized recreation and having been informed that the ARC is the Get Outdoors Day co-coordinator, I'd like to ask -- is this event something the environmental community should actively support, publicly lambaste or simply ignore?
While I'm at it, perhaps I should ask -- "in the relationship between the ARC and the USFS, who is the senior partner?"
The Deschutes (DNF) and Ochoco National Forests of Central Oregon are co-managed and share a common budget. Numerous recreation sites on the DNF, including trailheads, boat ramps, campgrounds, picnic areas and more require the payment of a fee as authorized by the Federal Lands Recreation Enhancement Act (FLREA). These sites accept both the Northwest Forest and the national America the Beautiful Passes. No sites within the Ochoco NF accept either of these passes.
Walton Lake is a recreation site located on the Ochoco NF used by local fishermen, day-trippers and campers. Though publicly owned, access to this lake restricted to paying customers only. Walton Lake is managed by a company that describes itself in these words:
" Thousand Trails is the largest private system of RV camping and outdoor preserves in America."
It was recently reported that the Deschutes NF is considering spending $612,000 to upgrade the facilities at Walton Lake and is currently accepting public comment.
The annual budget for operation, maintenance and capital improvement for all of the developed recreation sites on the Deschutes and Ochoco National Forests is $149,828. Stated in a slightly different way, the cost of improvements proposed for Walton Lake, is more than four times the annual developed recreation budget for entire forest management unit.
One might reasonably ask "why would the Forest Service spend so much money improving a privatized facility -- a facility from which they receive almost no revenue?"
Written by Guest Kitty Benzar - Western Slope No Fee Coalition
Monday, 16 February 2009
All of the Forest Service and BLM Recreation Resource Advisory
Committee members have been selected and each committee has met at least once.
With very few exceptions, the members of these committees - hand selected by the
Forest Service and BLM - have become willing collaborators with the agencies in
turning our public lands into profit centers.
Known as RecRACS, they are mandated by the fee law to act as
representatives of the public, recommending for or against new fee areas and fee
increases. They are required by law to see documentation of general public
support before recommending fee proposals.
But instead of acting as the
public's firewall against ill-conceived, illegal, and poorly supported fee
proposals, time after time they have recommended approval even when there is
evidence of general public opposition, when the agencies have done no public
outreach at all, and/or in the face of evidence that many fee proposals do not
meet the requirements in the law.
Is snow-kiting within Designated Wilderness a legally permissible activity? That question was raised recently in a front page article within my local newspaper and the local Forest Service chose to punt rather than answer the question.
I am confident that snow-kiting it is absolutely prohibited by the Wilderness Act and the laws, rules and regulations promulgated to carry out the original intent of that Act. I am only somewhat less confident that land managers at both the local and national level will sooner, rather than later, declare snow-kiting to be a prohibited activity within Wilderness.
In 1962, the author of the Wilderness Act wrote:
“The purpose of the Wilderness Act is to preserve the wilderness character of the areas to be included in the wilderness system, not to establish any particular use.”
Today, America's leading advocates for proper Wilderness management, Wilderness Watch, writes:
The overarching legal mandate of the Wilderness Act is to preserve the Wilderness character of each area in the NWPS. Preserving Wilderness character is the essential key to keeping alive the very meaning of wilderness in America.
For those unfamiliar with the new and growing sport of snow kiting, I've pulled together five short videos. When viewed in the order presented, they show a progression from the basic to the extreme.
Here they are. Watch them and decide whether this activity is compatible with YOUR concept of "wilderness character."
Snowkiting. Club Overpower
Video shows the basics of snow kiting on flatland
Best Snowkiten 2008
Video shows a variety of kiting experiences
Video shows mountain kiting similar to that now taking place within the Three Sisters Wilderness, here in Central Oregon
Snow Kite Masters
Video shows kiting as paragliding
Extreme Kiting Skiing
Video shows examples of extreme big mountain kiting
I've drawn the connection between higher gate fees and lower attendance so many times that I won't do so when introducing the appended article. It makes the point well enough. I would, however, ask you to ponder the following.
Imagine the political pressure National Park concessioners could exert to reduce park entrance fees if they concluded that today's sky-high entrance fees have been cutting into sales of rubber tomahawks, slurpies and popcorn. They could exert as much pressure as they did when they lobbied Congress in support of giving the NPS authority to increase fees without limit.
Back then, concessionaires saw a opportunity to focus not upon the general admission crowd, but upon selling value-added experiences to those who could afford skybox prices. Back then, the generally accepted problem was that "we were loving our parks to death." Reducing visitation was a priority and many interest groups cried out for higher fees as a way to solve the visitation problem. Back then, the economy was booming and now it has gone bust. So what's next?
Will the Park Service and their tourism partners focus upon the skybox crowd or will they lower the price of admission in an effort to pack in the crowds more tightly and then sell them all the Bovrils and Pies they can consume? Or will they, after decades of mismanaging the National Park System, step back and try to determine where and how they went wrong? Will they use this opportunity to begin to put things right --- or is that asking too much?
On Monday and Tuesday, and from Thursday through Sunday, a walk in the Prescott National Forest costs five bucks. Same with a picnic by a lake or creek. Same with sitting and contemplating the universe. Six days a week, access to the forest is sold as a commodity. Wednesdays, however, are fee-free.
WHY? Why would any National Forest give one entire day each week for enjoying the Great Outdoors free of charge? Most National Forests provided only two, three or maybe four free days in an entire year. The Prescott provides one free day in seven. WHY?
My presumption is that the Prescott National Forest managers are either feeling generous or perhaps understand that there is a genuine equity issue with the fees. Perhaps they feel guilty knowing that the fees are exclusionary and discriminatory and that fees are keeping lower income persons from using the forests.
Or perhaps Prescott forest managers understand that the recreation fees they've been charging since the passage of the Federal Lands Recreation Enhancement Act in 2005 (as a result of being tacked onto the Omnibus Appropriations Bill by the felonious Senator Ted Stevens) are not merely unpopular, the fees themselves are responsible for reduced visitation.
Perhaps they've figured out that the fees are alienating the tax-paying public. The fees may not simply be responsible for reduced visitation, they could be reducing long-term support for adequately funding the forest recreation programs with tax dollars. Without such support, especially at with the economic crisis upon us, appropriated funding will likely be cut. If that happens, we can expect the closure of non-profitable facilities and/or the privatization of those facilities that can be operated profitably.
Or, perhaps the Prescott NF is merely trying to lure additional visitors on Wednesdays so that they can report to Congress that annual visitation is not plunging --- as it is on forests from coast to coast.
I don't know why the Prescott offers free public access to the National Forest one day each week. I'd love to hear your thoughts.
Read on to see what happens when forest managers imagine that the Federal Land Recreation Enhancement Act gave them the authority to turn tree cutting into a recreational activity. These FS managers have the most extraordinary imaginations --- and so very little regard for either the law and for the public ... or so it appears.
Several people have asked my reaction to the nomination of Senator Ken Salazar for the position of Interior Secretary. I am, in a word, 'disappointed'. Like much of the conservation community, Wild Wilderness favored the nomination of Representative Raul Grijalva. Unlike much of this community, we took a strongly negative stance against candidate John Berry and are now much relieved that Mr. Berry did not get the nod.
However, for taking such action, Wild Wilderness is coming under attack from Berry's supporters. We have been accused of incorrectly representing Mr. Berry's connections with the wise-use, anti-environmental American Recreation Coalition.
Luckily, the ARC's President, Derrick Crandall, has just issued his own post-Salazar update. In it he shared with his supporters, his reaction to this appointment and has provided behind the scenes background. More importantly, he has tipped us off as to who may soon be appointed Deputy Secretary.
Pasted below are the first paragraphs of Crandall's update and a link where the entire update can be read. To view the Crandall's previous six updates, click here.
According to recent news articles, the USFS and NPS are scratching their heads while publicly saying: we haven't a clue why visitation is down so much. They are likewise, and at every opportunity, claiming that today's youths are no longer playing in nature, because they are addicted to videos -- and similar statements.
Frankly I think the agency people are being remarkably disingenuous.
Pasted below is a short article about a town council in Canada that seems to understand why their local kids aren't playing outdoors. Is this relevant to our National Parks and Forests? You bet it is!
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