Dec 26, 2007

LANL Major Player In Nuclear Shift

ABQ Journal


By John Fleck
Journal Staff Writer

They called it "the virtual sword."

In January 1990, as the Soviet Union collapsed, a pair of defense industry consultants wrote a paper outlining a new approach to meeting military needs in the post-Cold War world.

Rather than a pipeline constantly churning out new weapons, Ted Gold and Rich Wagner wrote, the United States should develop the industrial research and manufacturing capability to build weapons if needed.

We do not need a huge arsenal, they argued. Instead, we could deter future enemies merely by showing that we have the capability to build new weapons when we need them. The essay was titled "Long Shadows and Virtual Swords."

Fast-forward to Dec. 18.

In a Washington, D.C., news conference, the man in charge of the U.S. nuclear weapons design and manufacturing process seemed to be echoing Gold and Wagner.

"Because our nuclear weapons stockpile is decreasing, the United States' future deterrent cannot be based on the old Cold War model of the number of weapons," said Thomas D'Agostino, head of the National Nuclear Security Administration. "Rather, it must be based on the capability to respond to any national security situation, and make weapons only if necessary."

The proposal D'Agostino laid out, in the news conference and accompanying documents, calls for a modest U.S. nuclear weapons design and manufacturing complex.

For New Mexico, the implications of D'Agostino's vision are huge.

The critical "virtual sword" in the U.S. nuclear arsenal of the future will be Los Alamos National Laboratory's ability to manufacture plutonium "pits"— the highly radioactive cores at the heart of modern nuclear weapons.

Plutonium, a dull gray metal that looks much like lead, does not exist in nature. During the Manhattan Project, it was created in nuclear reactors and used to build the bombs detonated at Trinity and dropped on Nagasaki, the second Japanese city to be destroyed during World War II by the newly invented atomic bombs.

Squeezed by the detonation of high explosives, plutonium is rapidly compressed, starting a nuclear chain reaction that releases its lethal explosive energy in an instant.

During the Cold War, the Rocky Flats factory outside Denver churned out many thousands of pits. Rocky Flats stopped that work in 1989 amid radioactive contamination and safety concerns. It was shortly before Gold and Wagner described their "virtual swords."

For the weapons complex of the 21st century, D'Agostino would like to see Rocky Flats' old job turned over to a concrete, bunkerlike laboratory on a wooded mesa in Los Alamos.

There, if D'Agostino and his successors have their way, crews a fraction of the size of the old Rocky Flats work force will maintain the capability to build as many plutonium pits as the nation needs.

But instead of the thousands produced at Rocky Flats, the new plan calls for a capability, if needed, of just 50 to 80 pits per year.

"This is not your father's Rocky Flats," said Joe Martz, a plutonium scientist who is a project director in Los Alamos' nuclear weapons program.

The idea is to create and demonstrate the ability at Los Alamos to make nuclear weapons if needed, rather than to flex our military muscle through the manufacturing of a large nuclear arsenal. "My work becomes the deterrent, not so much the products of my work," said Martz, an advocate of the virtual swords concept.

The proposal to designate Los Alamos as the pit production center was more than 15 years in coming.

In the early 1990s, with Rocky Flats closed, the federal government launched the first of a series of efforts to build a replacement plutonium factory.

From the beginning, there was widespread speculation that Los Alamos would get the job. It had long worked with plutonium, and had long made pits used in nuclear test blasts.

In a February 1990 visit to Los Alamos, then-Energy Secretary James Watkins dismissed the suggestions that Los Alamos would become the new Rocky Flats as "nonsense."

"We have no such plans," he told reporters.

It was a refrain repeated often over the years, as Watkins and his successors launched one effort after another to replace Rocky Flats with a brand new factory. But in each case, the process foundered. Congress expressed repeated skepticism about the need and the cost, and successive political leadership kept reconsidering the idea and launching planning efforts anew.

The ground started to shift in 1997, when federal officials designated Los Alamos as an "interim pit production site." They still pursued construction of a new factory, but recognized the need for some way to make a few pits in the meantime.

It took a decade, but last summer Los Alamos announced the production of the first "certified pit"— one that passed the exacting quality control standards necessary for the pit to be placed in a stockpiled U.S. nuclear warhead.

In the months since, the lab has completed nine more, a milestone that laid the groundwork for D'Agostino's announcement.

What has changed since the 1990s, when Watkins and his successors were so adamant that Los Alamos would not be the nation's plutonium production center?

The most important change is the slow realization that far fewer U.S. nuclear weapons are needed, said Raymond Jeanloz, a University of California professor who frequently serves as an advisory to the U.S. government on nuclear weapons issues.

A treaty signed in 2002 between the United States and Russia, its chief nuclear adversary, agreed to lower the U.S. stockpile to 1,700 to 2,200 nuclear weapons.

Global terrorism, not nuclear adversaries, has emerged since 2001 as the nation's primary security threat, Jeanloz noted.

Historic nuclear stockpile numbers are classified, but independent estimates put the Cold War peak at more than 30,000 and suggest we had as many as 15,000 nuclear weapons on hand when Rocky Flats stopped making new ones in 1989.

No new nuclear weapons have been built since then, and Congress last week killed the latest effort by the defense Establishment to design and build a new weapon to replace aging Cold War models.

That means the only plutonium manufacturing that will be needed is a small number of replacement parts for existing weapons, noted Sen. Jeff Bingaman, D-N.M. That fact led Bingaman to offer cautious support for the idea of designating Los Alamos as the nation's primary pit manufacturing site. That would be consistent with the lab's longtime small-scale pit-making role, Bingaman said.

Martz, in an interview after D'Agostino's announcement, said the simple small-scale demonstration that the United States could make new nuclear weapons if required should be sufficient in the future.

"That's all you need," he said.

31 comments:

Anonymous said...

Truth be told, Los Alamos gave birth to the atomic age and now, finally, must bear the full weight of the nightmare it unleashed on the world almost 70 years ago. As for science-based stockpile stewardship, it has now been exposed for what it is and always has been—a financial boondoggle made possible by snake-oil-slight-of-hand-smoke-and-mirror political backroom dealings of none other than our perennial patron saint for plutonium lovers, Senator Pete Domenici. Of course there will always be those who will never accept much less admit that the Los Alamos National Laboratory isn’t about science anymore, but rather about maintaining the most lethal destructive capability our planet has ever seen. And so denial, as always, must and will remain a core competency at Los Alamos. How else can such ridiculous self-serving notions as being the source of the world’s best science and home to the best and brightest take root? Such myths are used to mask the reality that the Lab has become little more than a glorified Pu pit production facility; a process that began in the early 1990's when the DOE held numerous town hall meetings to pretend it was giving communities a voice in determining the Lab's future. Instead what it did was plant the seeds that would mature into what you see today--a community so fearful of change and the economic uncertainties associated with change that it becomes a slave to those controlling the purse strings. A community without conscience is what the Potterville of It’s A Beautiful Life film lore is all about. In a sense, we have become at Potterville. The DOE needed a Rocky Flats successor, and that's precisely what UC, along with DOE operatives like Rich Marquez and others like him enabled the DOE to achieve. Never mind that this came at the expense of workers, their pensions and their communities. Never mind that in the process we lost our scientific soul.

Anonymous said...

I attended those town meetings in the 1990s, and I distinctly remember what the activists groups were asking for. Specifically, the Los Alamos Study Group submitted a letter and testified to the following. The said they would SUPPORT bringing pit manufacturing to Los Alamos if 2 conditions were met. 1) close Rocky Flats, and 2) ensure the manufacturing capacity at LANL would be no more than 5-10% of what Rocky could built. Guess what? NNSA only met 1 of the 2 conditions that LASG laid out. Indeed, they closed Rocky, but LANL isn't making enough pits to meet the target that LASG requested. So, from my perspective, NNSA did almost EXACTLY what the activists groups were requesting. It's simple, revisionist history to suggest otherwise. Indeed, read much of the public comment and opinion from the early 90s. The end result today is remarkably in-line with what some of the most progressive suggestions proposed. In my opinion, DOE (and later, NNSA), was exceptionally responsive on this issue. Any balanced analysis of the course of the NW program over the last 15 years shows a remarkable trend, enabled by science-based stewardship, to an arsenal size an order of magnitude lower than when the program began. I'd say a 90% reduction in our nuclear arsenal is a damn-good start.

Anonymous said...

Nice endorsement of D'Agostino's plans for LANL, Martz. I guess we know where you stand on the issue of pit production here.

You must have your eye on an AD position.

Anonymous said...

12/26/07 9:36 AM

What is your point? It just seems like a long incoherent ramble.

Joe Martz said...

I have supported a small-scale pit manufacturing capability enabling considerably smaller stockpiles since at least 1993. I am on the record in the press for the last 14 years as endorsing this concept. If you read my comments and many articles, you'll find I've been quite progressive in trying to find ways to lessen our reliance on large numbers of weapons in our arsenal. I've said more than once that I'd like to see a dramatic reduction (if not elimination) of nuclear weapons in my lifetime. I've devoted my career to finding practical ways to get there.

Personally, I think a capability-based deterrent is an excellent interim step that provides a win-win: we preserve security, have agility for future unknown threats, and downsize our aresnal and begin making progress toward Article 6 all at the same time. Several of us have recognized the benefits of this strategy, and have worked tirelessly to promote its merits at many levels. The fact that RRW enabled much of this was the key reason I agreed to lead the RRW team at LANL, and I'm still proud of our work, even if these benefits of RRW have been lost in the current debate.

Re: science and manufacturing. I also feel that properly managed, undertaking a small-scale manufacturing role can enable very good science at LANL. For example, the publication of actinide science papers in peer-reviewed journals has increased more than 2-fold since 1997, commensurate with the establishment of small-scale pit production. While not necessarily a direct result of this (the focus on Pu aging in this time frame is at least as important, though pit certification contributed a considerable number of these articles), it does demonstrate the ability to do both science and small-scale manufacturing in the same facility and institution. I have complete data on actinide science and overall publications going back yearly to 1970, it's very telling (including calibration data from Berkeley and LLNL).

This may not be a perfect solution, and there's much skepticism. But taken on the whole, recent developments from NNSA are very good news for LANL, and very progressive in finding ways to enable security at reduced arsenal sizes. As the Chinese proverb says, the best cure for a bad idea is a better one.

Joe Martz

Anonymous said...

Well, Joe, you should be as happy a a pig in tall clover. You've finally got your precious "officially approved" plutonium production mission. You've also managed to let everybody know how much you support NNSA and LANS' plan to narrow the lab's mission. With friends like you, LANL doesn't really need any more enemies. You should go far in the new corporate LANL environment.

Joe Martz said...

Where in my comments do you construe my endorsement of a "narrowing the labs mission"?

Quite the opposite, I fully endorse broadening the labs work into areas of relevance including energy and environmental security, climate change research, and increasing our technical productivity. I've championed these causes with influential policy makers on those occasions that I've spoken with them (including RRW dicussions).

This debate is about the weapons-program role and future at LANL. For better or worse, it is today our largest mission. Mine and other's thoughts are how to structure that mission to enable as many important national security objectives including a responsiveness to Article VI, support for a continued test moratorium, etc. while also providing the positive benefits of deterrence.

Don't misconstrue this discussion as stating the only future role for the lab is in weapons; far from it. A sustainable, supportable weapons program strategy can form a foundation from which to broaden the lab. Rather than complain, many of us are trying to do something concrete to further the lab's future.

In my opinion, better to have small-scale manufacturing at LANL that a green-field MPF somewhere else. Have you considered the implications for our budget (including science and diversification) in that scenario?

My thoughts here predate LANS and the corporate changes. Am I ashamed they align? Heaven's no! I'm proud that LANS, NNSA, and others see fit to support a remarkably progressive strategy that does answer the question of the future role for LANL, NNSA, and a win/win nuclear deterrent strategy.

Joe M.

Anonymous said...

Where in my comments do you construe my endorsement of a "narrowing the labs mission"?


No need to construe, it's a given. NNSA itself has stated that the only WFO it will tolerate at its laboratories is WFO that supports the core mission. In LANL's case, the core mission is now pit production. You, like Anastasio, can pretend to support the concept of WFO in other areas such as energy and environmental security, climate change research, and so on, but it will not happen.

DOE has long disapproved of WFO at LANL, and now they have finally succeeded providing an environment at that will completely purge it. How long do you think WFO sponsors will pay LANL's bloated FTE costs and accept the inefficiencies of LANL's massive workplace dysfunction?

By endorsing pit production at LANL, you endorse DOE and NNSA's plans to have a "pure" NNSA lab that prohibits non-Pu WFO. What is truly pathetic, Joe, is that you know this to be true, and yet you still pretend to be supportive of the concept non-NNSA WFO being performed at LANL.

That makes you a hypocrite.

Anonymous said...

Regardless of what Joe Martz has just said, you won't be seeing LANL turn into a well diversified science lab that expands its base of national security work outside of nuclear weapons. NNSA has made it very clear that LANL is to concentrate on plutonium work and the cost for doing the work will come out of the existing LANL budgets.

The outcome of this will be the following. Expect labor rates at LANL to go up, available funding for diversified science to go down, and the remaining dinosaurs that walk the hallways at LANL to take full control over the direction of a quickly shrinking lab. It's not a pleasant outcome.

Joe Martz will do well in this new world with its strong emphasis on plutonium science. Bechtel and BWXT will also like the direction that LANS and NNSA have choosen. Many of the others on LANL's scientific staff will not fair nearly as well.

There are much better places to do non-weapons related national security work than LANL. These others places will give you greater job security and more favorable labor rates. Good scientists like Roger Johnston finally came to this conclusion over the last year. More will certainly follow.

RIP, LANL. The well diversified science lab I once knew is, sadly, about to disappear.

Anonymous said...

As expected, a thoughtful signed post is attracting the usual blog diatribes.

Doug Roberts said...

Well, here's another signed one.

I don't know Joe, although I have exchanged a few emails with him. I must say that I do not understand his contention that non-NNSA WFO can continue to exist at LANL in the future. NNSA has been quite explicit on this point: the only WFO that they would consider allowing at one of their labs is WFO that was in support of the lab's core mission -- Pu pit fab in LANL's case.

I agree with at least part of 3:05's statement -- even without NNSA's stated stricture on what kinds of WFO they would allow at LANL, the FTE costs and general workplace inefficiencies at LANL will prevent programmatic WFO growth in those areas that Joe suggested.

Hypocrisy is, I suppose, one possible explanation for Joe's stated position. As is ignorance regarding NNSA's stated new policy regarding WFO at NNSA labs.

Being a proponent of scaled up pit fabrication operations at LANL is Joe's right, but acknowledging the consequences of this future mission at LANL is everybody's responsibility.

Doug Roberts
LANL, Retired 2005

Joe Martz said...

Doug,

I do respect your comments and opinion, and we have exchanged useful e-mails in the past. I share the concerns here about the difficulty and pricing of WFO at LANL. I've attracted some WFO dollars to the lab, and indeed, our pricing makes this more difficult than need be.

I would suggest one possible solution is to have Congress authorize and allow DOE to charge on a cost-plus basis for WFO, rather than the full cost recovery model now used. It's my understanding that DOE (policy? law?) requires them to charge for full cost-recovery on WFO projects. Obviously, this prices LANL out of the market for a lot of work. The simple fact is our security and facility costs are prohibitive, and frankly, don't add much value in WFO proposals.

We do have a valid model, authorized by Congress: LDRD. LDRD is both authorized by Congress and exempt from overhead. This makes LDRD dollars very competitive, and I would suggest that Congress could do the same for WFO work. Acknowledge the base cost for enabling the weapons work at LANL, have DOE pay the bill, and allow us to bid on WFO in-line with other institutions. It think this simple step would help considerably in opening up WFO work and diversifying the lab.

I have written Congressman Udall with this suggestion, and mentioned it to Bingaman. If those representatives are serious about helping LANL diversify, then this is a concrete step they can take to help us, at no additional cost to the government. I know their staff read the blog, and perhaps they can act on this suggestion.

Joe Martz

Anonymous said...

"LDRD is both authorized by Congress and exempt from overhead. This makes LDRD dollars very competitive" (Martz)

Wrongo, Joe! That you would make such a silly statement clues me in on how little you may really know about the non-weapons world at LANL.

LDRD work use to have low overhead rates, pre-FY06. However, today it is almost fully burdened with an FTE cost that places it just barely below the cost of weapons and WFO related work.

The reason that the LDRD tax on all incoming program funds was raised from 6% to 8% several years ago was largely to help minimize the hit that LDRD researchers would feel when their LDRD FTE rates were more fully burdened.

LDRD work is no longer cheap at LANL.

Anonymous said...

The point is still valid that LDRD for most of its history was lightly burdened, and if Congress and DOE wished, they could authorize this for WFO. And I'm pretty sure the 6 to 8% increase in LDRD was authorized by Congress. Was it in response to plans by DOE to burden LDRD? I'm not so certain the increase from 6 to 8% and the decision to burden LDRD were related. One may have canceled the other.

Anonymous said...

I don't agree with everything Joe and Doug post, but I do appreciate them raising the level of discussion. The current path LANL is on is one where WFO projects do not exist and very little if any science is done. Hopefully congress will realize what a National Laboratory could do if directed to other missions, mainly national security missions at Los Alamos.

Anonymous said...

Just My $0.02 worth:

1. A lot of what Joe Martz says makes sense to me.

2. I detest that "Win/Win" teminology...it's at best a compromise, a less than perfect solution, and only the long convoluting road of history will tell us the facts.

3. I agree, as do many others,that charging on a cost-plus basis for WFO is a viable solution to the current full cost recovery model.

4. I'll leave the discussion of the RRW to the experts but for security reasons, it makes no sense to me to leave HMX based HE Systems in the stockpile.

5. As for 12/26/07 9:36 AM...well I guess everyone has an opinion.

Anonymous said...

Anyone familiar with the cost structures of the labs understands there are many ways to distribute costs. If WFO is important, there are ways to minimize the burdens (taxes) associated with that type of work.

Of course, reducing a cost on one type of work increases costs on others, and that is the nature of the debate.

Anonymous said...

The point that all of you all seem to be missing is that NNSA and DOE don't want WFO at LANL. They view it as a nuisance and a distraction from what they want LANL to focus on.

If they wanted to encourage WFO, there are ways they could do so, such as changing the WFO charge rate. They haven't. They won't.

As Doug indicated, NNSA will decide what, if any WFO is allowed at their NNSA labs. Any WFO accepted at LANL will will be work that supports pit production.

This is the way it will be at LANL now. You should get used to the idea because moaning about it will not change a thing.

Anonymous said...

Joe-

Thanks for being willing to post the detailed comments. For once this is actually an interesting thread to read.

Anonymous said...

8:57 a.m.

"If they wanted to encourage WFO, there are ways they could do so, such as changing the WFO charge rate. They haven't. They won't."

Do you understand how WFO rates are determined? Apparently not. The role of DOE/NNSA in that process is small compared to the knobs lab management can turn. DOE/NNSA does not set the G&A rate (one of the biggest burdens) nor a slew of other internally generated burdens.

Anonymous said...

11:40,

I'm afraid that you are the one who doesn't get it regarding LDRD *and* WFO at LANL.

The point is: DOE and NNSA can mandate policy in both of these areas. DOE and NNSA could, for example, tell LANS to develop a customer-friendly WFO charge rate, if they felt like it.

The point is, neither DOE nor NNSA have *any* desire to encourage WFO at their NNSA labs, nor do they much care how much mileage LANL gets out of its LDRD 8% appropriation. LANS, therefore, is similarly disinterested.

DOE and NNSA are interested in one aspect of operations at LANL these days: pit production.

It really doesn't matter how things used to be, this is the current reality.

Eric said...

Joe and Doug,
Thanks for discussion with real people and credible facts attached to it.

I had mostly stopped reading comments because they usually consisted of blogorhea - anonymous emotional comments with few facts. I would like real facts from real people, whether I agree with them or not. Then we can have productive discussion.

Grazie.

Anonymous said...

11:52 AM

Okay, so you don't know how rates are set.

Ask any of your financial types to generate the chain calculation of burdens associated with WFO. Then look at those and decide which ones are driven by DOE/NNSA Order. The only one I am aware of is the Safeguard & Security recharge, which is scheduled to be phased out in FY09.

As you point out, DOE/NNSA are actually quite silent on this. And believe me, you do not want them coming in and setting all your rates; they have already done enough damage.

Anonymous said...

12:03,

It is proving surprisingly difficult to get you to see the big picture, or to even recognize that there is one.

But, for the record: I have 20 painful years of experience in seeing my WFO and (lately) my LDRD budgets taxed into insignificance. I've brought in WFO; I've been P/I on LDRD proposals that I won. I know how the system works.

The point that you seem unwilling to recognize is that it doesn't have to work that way.

If DOE and NNSA wanted to create WFO and LDRD-friendly environments at their labs, they could.

That's the point.

To get us back on topic: DOE and NNSA could tell LANS to change how they charge for WFO.

They have not done so.

They will not do so.

Because they have no interest in encouraging WFO at LANL.

Point made, again.

Feel free to ignore it, again.

Anonymous said...

"The point that you seem unwilling to recognize is that it doesn't have to work that way."

I clearly recognize it doesn't have to work that way. My point is that lab management's hands on the financial knobs have a far greater impact on WFO and LDRD cost structures than DOE/NNSA.

If you believe that inviting in DOE/NNSA to set your rate structures is going to be helpful, then you haven't appreciated all the damage done by ending Contracts 36 and 48. That is the big picture, and it is a sorry one indeed.

Anonymous said...

All of the staff members in my division who have bailed out of LANL during this last year have been those working on WFO projects. They heard the implied message very clearly. LANS and NNSA may give lip service to this issue but won't offer much more.

Just look at the comments made by Mike Anastascio about this subject over this last year. It's clear that these folks will never make the changes necessary to grow LANL into a more diversified 'SNL mode' of operation. In fact, they'll do just the opposite.

We are headed to being a much smaller lab that circles our wagons around the jobs or pit production and plutonium science. Heck, LANS even tells you this on their web page. What's not to understand here?

Anonymous said...

Here's my personal perspective. Four years ago I cost my sponsors about $280 K per year. Today, I'm running about $420 K per year. During this time, my salary has gone up only about 8%. In the future, I can probably expect this FTE rate to rise even higher.

That's the reality at LANL. It's killing WFO work. It's eating into the weapons research budget. It's bringing a slow death to LDRD science at LANL. And it's of no serious concern to LANS from what I've been able to gather.

Safety and security is all that LANS is really concerned about going forward over the next few years. If they at least create a perception of success in those two areas, then LANS will make a good profit and the bonuses will flow freely at the top.

Long term, LANS is mainly concerned about getting the pit production facility up and running at a level that satisfies NNSA.

Safety, security, and pit production now appear to be the main missions. Some scientific research will be kept around for good measure to be used as window dressing as needed. I hope I'm wrong with this assessment, but I doubt it. Joe talks a good talk, but I see no one in LANL management walking a good walk.

Anonymous said...

Fascinating, 1:23.

We are approaching convergence on agreement as to what the big picture is, although with different perspectives.

You say that things will never get better wrt WFO labor costs, because LANS management has their hands on the financial knobs (with DOE's blessing) and even if DOE wanted to improve our situation, they'd just screw it up worse than it already is.

I say that things will never get better wrt WFO because DOE has screwed things up to the point that we are in the exact position they want us to be in. Meaning, even if DOE/NNSA would let us try to bring in WFO, we couldn't get any meaningful amounts of it because we cost too much (thanks to LANS management having their hands on the financial knobs).

Anonymous said...

I'm from a different lab and "WFO" might have different meaning. In my terms, it means research for an entity other than DOE.

You do realize that there are parts of DOE not included in NNSA, correct? Many other labs make a good living with funding from NE, EERE, FE, SC, etc... Is NNSA discouraging that type of funding or just work for other agencies (DOD, ONR, etc...)?

It seems to me that this discussion is missing those other parts of DOE that are potential sources of funding, but perhaps WFO is defined at LANL (and by NNSA) as "anything other than NNSA".

Anonymous said...

From http://lanl-the-rest-of-the-story.blogspot.com/2007/11/and-in-next-months-mechanical-and.html

David H. Crandall, NNSA assistant deputy administrator for research, development, and simulation:

"We are moving from a mode where we would tolerate research that doesn't interfere with our nuclear weapons mission to one in which we are encouraging new research that is synergistic to our mission," Crandall continued, adding that researchers outside NNSA will have to pay the full price of using lab staff and facilities.

Quite simple. No more tolerance of "other" WFO. No special overhead rates for WFO.

Anonymous said...

Some more "big picture".... think back to recent history, the gloomy Nanos shut-down during which he proclaimed the root cause of "all the problems" (besides butt head cowboys) was LANL's diversification and being spread too thin, we need to be focused on fewer programs, more core mission. Do you REALLY think that fell on deaf ears at DOE coming from this guy? Don't make the mistake of thinking DOE is out on the cutting edge with their plans, they are responding to this input given them almost 4 yrs ago from an implant.