Wetlands Destruction at Laurel Run Park

On Thursday morning I received an email from a concerned citizen from Kingsport, Tennessee, informing me of an article the Kingsport Times News had ran that day. Its headline, Hawkins County intends to fill in a swampy section of Laurel Run Park near the entrance gate at the far west end of the park (written by Jeff Bobo),  got my attention and I wanted to know what exactly was going down in Hawkins County.  I immediately called the news room and asked if someone could email me the article so that I could better assess the situation. Within an hour I received the message with the attached article.

© Jerry D Greer / EnviroStock Media

In the article, Alderman Joe McLain, a member of the Hawkins County Commission who serves on the Parks Committee, explained to the Board of Mayor and Alderman Monday that the county intends to fill in a swampy section of Laurel Run Park near the entrance gate at the far west end of the park. Laurel Run Park is located along the south bank of the Holston River just outside the Church Hill city limits. “It gets worse every year, and if it gets too bad they will eventually declare it a (protected) wetland and you can’t ever do anything with it,” McLain said. “Right now the state has said we can fill it in with dirt. We have to leave the drains in it, but we can fill it in with dirt and reclaim that property basically because right now you can’t even mow it.” After reading the entire piece I felt that I needed to make a call to the Tennessee Department of Environment and Conservation (TDEC). While waiting on a call back I did a little research. Here’s Tennessee’s definition and delineation of wetlands.

Wetlands definitions and delineation

The Tennessee Water Quality Control Act of 1977 defines “waters of the state” as:  any and all water, public or private, on or beneath the surface of the ground, which are contained within, flow through, or border upon Tennessee or any portion thereof except those bodies of water confined to and retained within the limits of private property in single ownership which do not combine or effect a junction with natural surface or underground waters. Wetlands are defined in the TDEC rules as “those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.”Tennessee relies on the delineation criteria in the Corps’ 1987 Wetland Delineation Manual.

Wetland related statutes and regulations

The Tennessee Water Quality Control Act of 1977 and the corresponding Aquatic Resources Alteration Rule establish the state’s Aquatic Resources Alteration Permit (ARAP) program that regulates wetlands and wetland activities apart from those covered by individual §404 permits. Physical alterations to waters of the state that require either an ARAP or a §401 water quality certification include: dredging, excavation, channel widening, or straightening; bank sloping; stabilization; channel relocation; water diversions or withdrawals; dams, weirs, dykes, levees or other similar structures; flooding, excavating, draining and/or filling a wetland; road and utility crossings; and structural fill.

§401 certification program

Tennessee uses §401 certification to protect wetlands by approving, conditioning, or denying federal §404 permits. In 2000, rules for implementation of the state’s §401 certification and the ARAP programs were formally adopted. The rules specifically define wetlands as a category of waters of the state and establish a “no net loss of water resource value” standard for permitting. Section 401 certification is required for any §404 permit approved by the Corps. However, if the Corps issues a Nationwide Permit (NWP) for a project, or doesn’t have jurisdiction over the impacted wetland, then the applicant must obtain a state ARAP permit. TDEC issues approximately 400 to 500 wetland permits per year, split about equally between ARAPs and §401 certification. These qualitative factors are described in TDEC’s Aquatic Resource Alteration Rules in relation to assessing water resource values and in the Tennessee Antidegradation Standard.

TDEC’s wetland assessment methodology is still evolving. The division is incorporating Tennessee’s antidegredation rules and tier evaluations into the permit assessment process. TDEC reviews all applications to assess the proposed impacts and determine if a tier assessment must be conducted. The antidegradation guidelines, which apply to all waters of the state, are more stringent for impacts to Tier 2 and 3 wetlands than those for Tier 1 wetlands. A field review is conducted for projects impacting all three tiers of wetlands; these are coordinated with TWRA, the Corps, the U.S. Fish and Wildlife Service (FWS), and occasionally the U.S Environmental Protection Agency (EPA). The department also has an EPA grant to develop a new assessment methodology for permitting purposes. TWRA reviews public notices for §401 certification and ARAP permits to ensure that the proposed impacts and mitigation comply with the Basic Minimum Compensatory Mitigation Requirements developed by TDEC, TWRA, EPA, Corps, and FWS. TWRA also ensures that permits follow the mitigation ratios laid out in the TDEC mitigation rules.

© Jerry D Greer / EnviroStock Media

Around 5:30 pm, the call came in from the TDEC field officer. I explained the situation and reviewed the article, and then emailed the entire article to the office so she could read it in its entirety. While on the call, she looked up Laurel Run Park in the TDEC database and found a 2009 permit issued for work on the east side of the Park, it was to help with water removal during flooding. It didn’t include any alteration to the documented wetlands. She also stated that they had not applied for any new permits for the wetland fill project that was mentioned in the article. Before we ended the call, I let the officer know that I would be visiting the Park the next morning to investigate and photograph the possible dredging of part of the protected wetlands.

Friday morning, I arrived at Laurel Run Park around 9am and found that someone had replaced the tile for the road that crossed the wetland and they had, in fact, started to dredge the west end of the wetland. I photographed the work that had been done, made a few notes, and decided that I had enough to make a report to the field officer. But before I could leave, the field officer pulled onto the road where I was parked. It was a great meeting, I was able to review the TDEC data and maps showing exactly where the documented wetlands are located, and we were able to confirm that the dredging was exactly where we suspected, right down the middle of the protected wetlands, on the west side of the property. At that moment, she confirmed that there were violations and that she was going to talk with the Park manager. I took a few more photos and made my way back to my office in Johnson City.

Late Friday evening, I received a followup email from the field officer detailing her meeting with the Park officials and how the violation would be handled.  She explained that the individual who had dredged the wetland and replaced the tile now understands that no one can place any fill material in the protected wetlands and how he would be restoring the wetlands with the material that had been removed while dredging.

I’m very happy to announce that currently, all is well and the Laurel Run Park wetlands are safe. We will be monitoring the situation by continued visits and also checking with TDEC to make certain that no new permits have been applied for. I am certain that this is not the end of the threat and at some point the county will apply for the ARAP permits. At that point we will do whatever it takes to insure that any permits to fill the wetlands be denied. So stay tuned!

The Southern Appalachian Beech Gap – Critically Imperiled!

At high elevations pure stands of American beech trees are know as beech gaps. Beech bark disease, a complex made up of the beech scale insect cryptococcus fagisuga and a closely associated fungus Nectria coccinea var. faginata poses a serious threat to this community. Most all of the beech gap communities in and around the Great Smokies have succumbed to the beech bark disease or a combination of the disease, pests and pollution.  This trend is being felt throughout the southern Appalachians, with the possible extinction of this forest community in the next few years. The beech gap community is assigned a Global Conservation Status Rank of G1. A G1 ranking translates to – Critically Imperiled—At very high risk of extinction due to extreme rarity (often 5 or fewer populations), very steep declines, or other factors.

During my Roan Highlands workshop this past weekend I found that one of my favorite locations to spend time studying and photographing in is sick, very sick. It looks to be a really tragic end to another huge beech gap. I’ve thought that this location was OK in terms of health with good leaf coverage and little tree kill. This year is drastically different. It looks like 70% to 80% of the beech trees have not leafed out and this is not good. It all happened in one years time. Not sure until the botanists get in to the location and study the trees. The way I see it is this, the trees will not survive if they do not leaf out and this was not a gradual die-off. It is real sad to see one of the largest beech gaps remaining in the southern Appalachians succumb to the disease. Over the next couple of years we will see this forest community make a dramatic shift and those beautiful flowing grasses will eventually die off as well. This was a very sad day for me and for those that have felt the same connection to such a unique ecosystem. I’ll be posting more images from this location over the coming months. My intent is to personally document, in stills and in motion, its transition, and to bring botanists, biologists, photographers and other scientists to this location as well. Maybe, just maybe, there is a slim chance that there could be a recovery but the cards are stacked against this notion.

At least I did have the chance to spend the past few years working and bringing friends and colleagues into this wondrous location. And I can say for certain, every person that witnessed this community first-hand came home with a strong connection with this unique and beautiful place.
Canon EOS 5DmkII w/ TS-E 24mm f/3.5L II

Fern in summer beech gap, Roan Highlands, TN & NC

Roan Massif and the Race to Preserve it


Great Pyrenees tending to the flock, Baa-tany Goat Program, Roan Highlands 

The Roan Massif, which includes the longest continuous stretch of high-mountain grassy balds in the Southern Appalachians, sits along the borders of East Tennessee and Western North Carolina. Also Roan Massif contains in one of the most dense stands of coniferous forests in the southern Appalachians, and most notably, the world’s largest natural rhododendron garden. The combination of geology, topography and climate results in one of the most diverse displays of plant and animal species in the entire Southern Appalachian range. The Roan Massif is home to a host of threatened and endangered plants like the beautiful Gray’s lily, Roan Mountain bluet and spreading avens. Many other rare species, from the pygmy salamander, spruce-fir moss spider, and the northern saw-whet owl, add to its natural abundance. The Roan Massif is globally-rare, critically imperiled plant communities with a global rank of G1, the rarest ranking available. 

Angora wether, a castrated male sheep, Baa-tany Goat Program, restoring the Roan's western grassy bald corridors, Roan Highlands                             

 Over the past 100+ years the forests have been encroaching on the open grassy balds. Threatening to erase these wonderful sky islands from their very existence. Botanists like Jamey Donaldson, Project Coordinator and research botanist, believe that the decline of the balds is due to changes in soil and climate and the loss of large herbivores, all of these factors make them more welcoming to the woody plant incursions such as the main target, the Canada blackberry. Estimates suggest that more than 75% of Roan’s Grassy Balds have disappeared in less than 100 years with most of the loss occurring in the last 50 years.  

The Baa-tany Goat Project uses Angora goats as a surrogate for the absent herbivores and also offers the scientific study of the program. This experimental program is operating under a special use permit and volunteer agreement with the USDA Forest Service. Goats were chosen because they prefer to eat woody plants rather than the grasses. The goats are restoring a natural process that has been absent on the balds for decades. 

Angoras are a fiber goat (source of mohair) rather than a meat or dairy goat. More than half of the goats were donated by a northern Virginia woman who preferred giving her friends a retirement plan rather than sending them to market and ultimately being slaughter. Todd Eastin, a partner in this project, donated the remaining goats. All the goats that went up on the balds are guaranteed a retirement plan and will be taken care of for the rest of their lives. 

The success of this programs relies on good research and the funding to sustain the welfare of the main subjects, the Angoras. Oh, and we don’t want to forget the wonderful caretakers and security guards of the goats, brothers Ian and Baxter, the resident Great Pyrenees. Please feel free to visit the Angoras, Ian and Baxter, Todd and Jamey. Also, please visit www.friendsofroanmtn.org and adopt one or even more of the Angoras. Even though the program has sponsors and received grants it is not enough to ensure that the program will continue. The Baa-tany Goat Program needs your help so please visit the Friends of Roan website, download and fill out the adoption form, write a check and send it in. Lets insure the continuation of this great program to restore and maintain the wonderful Roan balds for generations to come.

 Angora kid on the job, Baa-tany Goat Program, restoring the Roan's western grassy bald corridors, Roan Highlands

You’re not going to believe this! TVA has done it (COAL SLUDGE RELEASE) for the third time in a month! What the HELL is their problem!!

This is a release sent to me by my friend Chris Joyell of Wild South:

Tennessee: State cites TVA for Ocoee sludge release at Olympic site

By: Ron Clayton

By: Pam Sohn
Included in this article
Audio      Video
TimesFreePress Audio
Jim Herrig
– Download MP3 –

OCOEE, Tenn. — A deliberate TVA sludge release last weekend on the Ocoee River killed fish and aquatic life in the once-dead but now-recuperating Ocoee River, prompting a state investigation that on Friday brought a citation and new cleanup order against the already embattled Tennessee Valley Authority.

Now state and Cherokee National Forest officials are awaiting lab results from sludge samples, fearing that the mud, piled for decades behind the dam that separated the Ocoee from copper mining residue, may contain toxins such as PCBs and heavy metals.

“It didn’t look like normal releases,” said Jim Herrig, a U.S. Forest Service biologist, adding that officials hope to get results on the samples next week.

Tennessee Department of Environment and Conservation spokeswoman Tisha Calabrese-Benton said state water regulators cited TVA with violations of the Tennessee Water Quality Control Act after bottom sediment from Ocoee Dam #3 was sluiced into the river.

The black and foul-smelling sludge “overwhelmed the river and the Olympic whitewater area of the Ocoee in some places more than three feet deep,” Ms. Calabrese-Benton said.

PDF: TDEC’s notice of volation to TVA

Article: Polk County: Fish swimming again in Ocoee

The Ocoee River, devoid of life for nearly 100 years because of copper mining pollution, had begun show life again in the past five years after mining was halted and a Superfund cleanup had begun.

“We were just now documenting a very significant comeback,” Mr. Herrig said. “I’m disappointed. I’ve spoken to other biologist with TVA and they are concerned also. I think TVA will be doing some investigating of their own.”

TVA spokesmen Jim Allen and Barbara Martocci said they did not know why water was released from the bottom of Ocoee Dam #3 rather than the top, as is customary. Nor did they know how much water and sediment was released.

Ms. Martocci said TVA was drawing down the water behind the dam in preparation for repair work on the downstream Ocoee Dam #2 and in case of heavy rains. She said the move was for the safety of the crews working on Dam #2 and to give the workers time to get their equipment out if heavy rain came.

“We didn’t realize how much sediment was in it,” she said. “Some of the sediment was pulled with the water through the sluice gate.”

In the notice of violation, TDEC’s Chattanooga water pollution control manager, Richard Urban, said the state had received no permit requests or even inquiries about the “special operations” of the Ocoee series of dams and powerhouses.

“Due to the magnitude of the Ocoee, which flows to the Hiwassee and then to the Tennessee rivers, it was selected as the site for the 1996 Olympic whitewater events,” he wrote. “Thousands of people travel to the region each year to run the Ocoee rapids and swim. The river flows out of Georgia, and there it is called the Toccoa.

“Fish were killed and washed downstream or killed and buried in the mud/sludge/ooze,” he wrote. “No live fish were seen.”

Mr. Allen said TVA did not need permits for general maintenance work.

Mr. Herrig said some of the walkways were covered by the sludge, but the heavy rains Wednesday had eventually swept the material downstream. By Friday, the lower Ocoee appeared muddy, but Mr. Herrig said that was normal after so much rain.

Because of the clearing rains, he said Forest Service officials had not posted or roped off any areas of the Ocoee.

Ms. Martocci said TVA officials will determine what happened “to make sure it does not happen again, and we’ll respond accordingly to the notice (of violation).”

TDEC is giving TVA until Jan. 22 to submit a plan for restoring the river.


Christopher Joyell
Wild South, Strategy & Communications Director
16 Eagle St., Suite 200
Asheville, NC 28801
tel: 828.258.2667
email: chris@wildsouth.org

Senate boosts wilderness protection across US! Yes, now we can get some protection for our wildlands!

This is an awesome start! The great thing is we don’t even have our new President yet! Read the full story here!


Thanks Senators! We need to keep moving in the right direction.

Photos from the Kingston/Harriman, TN disaster site

Hey all,

I’ve quickly been getting these images processed and out to the groups that need them to help educate the public about this disaster. It really disturbing how some, even geologists, are taking the stance that coal fly ash is not toxic or even hazardous.  They are even saying that the enormous spill poses no threat to the environment. I really cannot understand these viewpoints. What about the 400+ acres of land and water that are now under millions of tons of coal fly ash sludge? Even if it was not toxic this land and the people that live here are now changed forever. The wildlife and aquatic life in and around the spill area will be affected  for generations.

Appalachian State University has released preliminary independent tests finding high levels of toxic chemicals in the Harriman/Kingston Fossil Plant fly ash deposits. According to the tests, arsenic levels from the Kingston power plant intake canal tested at close to 300 times the allowable amounts in drinking water, while a sample from two miles downstream still revealed arsenic at approximately 30 times the allowed limits. Lead was present at between twice to 21 times the legal drinking water limits, and thallium levels tested at three to four times the allowable amounts. All water samples were found to contain elevated levels of arsenic, barium, cadmium, chromium, lead, mercury, nickel and thallium. The samples were taken from the immediate area of the coal waste spill, in front of the Kingston Fossil plant intake canal just downstream from the spill site, and at a power line crossing two miles downstream from the spill. Dr. Carol Babyak, Assistant Professor of Chemistry at Appalachian State University stated, “I have never seen levels of arsenic, lead and copper this high in natural waters.”  These test findings should silence those that make those ridiculous statements of “coal fly ash is not toxic”!

Here are a few of the photographs that I took around the site one week ago.

I just returned from the Kingston Fossil Plant Disaster!

Well, the visit was a very educational one, to say the least! Police everywhere with no access permitted. I had to make my images from accross the lake with a 400mm lens. I’ll be posting them as I get them digitally processed. Here’s a 180-degree panoramic, made by stitching multiple images together in Photoshop.  I shot the images with my Canon Powershot G9, love this little camera! Also, here’s the latest information on the disaster.


A coal ash spill in eastern Tennessee that experts were already calling the largest environmental disaster of its kind in the United States is more than three times as large as initially estimated, according to an updated survey by the Tennessee Valley Authority.

Officials at the authority initially said that about 1.7 million cubic yards of wet coal ash had spilled when the earthen retaining wall of an ash pond at the Kingston Fossil Plant, about 40 miles west of Knoxville, gave way on Monday. But on Thursday they released the results of an aerial survey that showed the actual amount was 5.4 million cubic yards, or enough to flood more than 3,000 acres one foot deep.

The amount now said to have been spilled is larger than the amount the authority initially said was in the pond, 2.6 million cubic yards.

A test of river water near the spill showed elevated levels of lead and thallium, which can cause birth defects and nervous and reproductive system disorders, said John Moulton, a spokesman for the T.V.A., which owns the electrical generating plant, one of the authority’s largest.

Mr. Moulton said Friday that the levels exceeded safety limits for drinking water, but that both metals were filtered out by water treatment processes.

Mercury and arsenic, he said, were “barely detectable” in the samples.

The ash pond was adjacent to the Emory River and near a residential area, where three houses were destroyed by the tide of muddy ash. Water sampled several miles downstream from the spill was safe to drink, but its iron and manganese content exceeded the secondary drinking water standards set by the Environmental Protection Agency, which govern taste and odor but not potential health effects, Mr. Moulton said.

Neither the authority nor the E.P.A. has released the results of tests of soil or the ash itself. Authority officials have said that the ash is not harmful, and the authority has not warned residents of potential dangers, though federal studies show that coal ash can contain dangerous levels of heavy metals and carcinogens.

“You’re not going to be endangered by touching the ash material,” said Barbara Martocci, a spokeswoman for the T.V.A. “You’d have to eat it. You have to get it in your body.”

The Tennessee Department of Environment and Conservation also released a statement saying there was no indication of risk unless the ash was ingested.

But residents like Deanna Copeland were thinking further into the future.

“Our concern is, what happens if this liquid dries out?” Ms. Copeland said. “There are huge health concerns. It’s going to get in our house. We’re going to breathe it in. It would be like walking through a dust bowl, and we don’t know what’s in the dust.”

A round-the-clock cleanup effort continued on Friday, much of it clearing roads and railway tracks that were blocked by the sludge. Several booms, or skimmers, were installed on nearby rivers to catch floating cenospheres, a valuable component of the ash used to make bowling balls and other manufactured goods. A weir, or underwater dam, that would keep settled ash from moving downstream was about one-fifth completed,
T.V.A. officials said.

Some nearby residents said that the authority had done little to address their concerns.

“We’re terribly frustrated,” said Donald Smith, 58, a laboratory facilities manager who lives in the affected area. “It seems like T.V.A. is just throwing darts at the problem, and they don’t have a clue how to really fix it.

“It was nice that they came by to talk to us. They’re making an effort. But what upsets me is they didn’t have a plan in place. Why hadn’t anybody thought, `What happens if this thing bursts?’ ”

Residents said they were stunned by the new figure for the size of the spill.

“That’s scary to know that they can be off by that much,” said Angela Spurgeon, whose dock and yard are swamped with ash. “I don’t think it was intentional, but it upsets me to know that a number was given of what the pond could hold, and the number now is more than double.”

Authority officials offered little explanation for the discrepancy, saying the initial number was an estimate based on their information at the time.

Ms. Spurgeon said the scope of the disaster was difficult to fathom, even from photos.

“This is not a thin coating of ash,” she said. “These are boulders. There’s one in our cove that’s probably the size of our home.”

The spill has reignited a debate over whether coal ash should be federally regulated as a hazardous material.

Environmentalists have long argued that coal ash, which can contaminate groundwater and poison aquatic environments, should be stored in lined landfills. The ash ponds at Kingston were separated from the river only by earthen dikes. Coal plants around the country, most near rivers that supply the water they need to operate, store coal ash in unlined embankments and ponds, and in some areas coal ash is recycled as fill material.

The T.V.A. is still investigating the cause of the breach, but officials have suggested that unusually heavy rain and freezing temperatures may have been factors.

Sorry to post some bad news on Christmas but this is devistating! Environmental Spill Disaster Devastates Tennessee!

Not sure why I haven’t received this info sooner but I just received it by email. I hope to have so photos of this soon, I’m going to make a trip to the disaster this week!

Environmental Spill Disaster Devastates Tennessee; 48 Times the Size of Exxon Valdez

By Matthew McDermott, TreeHugger. Posted December 25, 2008.

An environmental disaster of epic proportions has occurred in Tennessee. Monday night, 2.6 million cubic yards (the equivalent of 525.2 million gallons, 48 times more than the Exxon Valdez spill by volume) of coal ash sludge broke through a dike of a 40-acre holding pond at TVA’s Kingston coal-fired power plant covering 400 acres up to six feet deep, damaging 12 homes and wrecking a train.

According to the EPA the cleanup will take at least several weeks, but could take years. Officials also said that the magnitude of this spill is such that the entire area could be declared a federal superfund site.

Toxic Sludge Got Into Tributary of Chattanooga Water Supply

Apart from the immediate physical damage, the issue is what toxic substances are in that sludge: Mercury, arsenic, lead, beryllium, cadmium. Though officials said the amounts of these poisons in the sludge could not be determined on Monday, they could (at the mild end) irritate skin or trigger allergies or (longer term) cause cancer or neurological problems.

This toxic sludge got into the Emory River, a tributary of the Clinch and Tennessee Rivers: The water supply for Chattanooga, Tennessee as well as millions of people living downstream in Alabama, Tennessee and Kentucky. TVA says that as yet the spill (which they are characterizing as a mudslide or landslide, but frankly it’s still toxic…) has not affected the water quality in the Emory River.

High Levels of Rain, Thaw Freeze Cycles May Have Weakened Pond Walls

On why the spill happened, the Tennessean speculated,

The area received almost 5 inches of rain this month, compared with the usual 2.8 inches. Freeze and thaw cycles may have undermined the sides of the pond. The last formal report on the condition of the 40-acre pond — an unlined, earthen structure — was issued in January and was unavailable Monday, officials said.

Greenpeace Calls for Criminal Investigation

In a press release issued yesterday, noting that spills of similar substances have resulted in felony charges, Greenpeace called for a criminal investigation into the spill:

“Every facility like this is supposed to have a spill contingency plan to prevent this kind of disaster,” said Rick Hind, Greenpeace Legislative Director. “The authorities need to get to the bottom of what went wrong and hold the responsible parties accountable.”

TVA Releases Official Statement

In an official statement, TVA president and CEO Tom Kilgore said,

Protecting the public, our employees, and the environment is TVA’s primary concern as we supply electric power for the people of Tennessee Valley region. We deeply regret that a retention wall for ash containment at our Kingston Fossil Plant failed, resulting in an ash slide and damage to nearby homes.We are grateful no injuries have been reported, and we will take all appropriate actions to assist those affected by this situation.

We appreciate the continuing efforts of local and state agencies, as well as TVA employees, to respond to this situation quickly and efficiently. Our intense effort to respond effectively will continue 24/7 for the foreseeable future with the safety of the public our top priority.

Clean Coal, Yeah Right

As many people in the blog world are noting, it’s this sort of thing that really makes the proposition of clean coal so absurd. Even if you can scrub all the CO2 out of it, you still have so many other toxic waste products associated with burning coal that have to be stored that carbon emissions are just a part of the problem. How many other holding ponds are out there waiting to burst?

Urban sprawl and development of farmland into subdivisions

I’m working on an assignment for a client on urban sprawl, including the development of farmland into subdivisions. I’m also looking at city infill projects and good development within the city limits. Here are a few of the images that I have so far. If you’d like to discuss these photos feel free to post. I’ll be working on this project for the next few weeks.