3rd World Country and International Law

We have discussed several times that international environmental law is not such a complicated matter.  The laws are all pretty much the same, it is the application that is different.  So it is more a matter of your corporate conscious on whether your company will abide by or go around these laws.  Small business has a tough time in navigating through the laws, business or environmental, of any 3rd world country because they simply do not have the horsepower to break through the consultants, in-country agents, and others who talk about helping but only see a easy meal ticket.  The more you do not understand, and admit that truth, the more they take advantage of you. 

Here is a little write up I did on another blog.  Sorry, it is a bit of a civics lesson, but one that is important in refreshing what we already know.



Life is a game, and we all play for keeps in this game.  The Constitution is the guiding document for the that outlines the rules of the game for the people of the country. It is the rulebook of game.  The only job of the government is to administer and enforce that document (rulebook). The government acts as the referee. It is the job of the people (players) to ensure that their government does their job.  When a government fails to do the job they were elected to do then it is the right and obligations of the people to change those who are in paid to be in charge of the rulebook.  In a democracy that involves voting out the government elected officials, which is the same as being fired.  This requires the players to be motivated, and educated in order to have a clear understanding that when the referees are doing their best to enforce the rules or are arbitrarily applying the rules based on personal preferences.

Imagine what would happen if fans found out that the referees at the final game of the World Cup ignored violations of rules by one side, and enforced the rules against the other side.  Most likely the referees would have to be flown out of the stadium to an undisclosed location in fear of reprisals from those fans.  Those people are passionate, motivated, and educated about their game.

Passion is the emotional fire required to motivate (move) people to do something.  Education is what is needed to know the difference between right and wrong, to understand that the rules and whether the referees are being honest.  Remove any one of the points of the triangle and results in whining and complaining, but no change. 

Passion can be removed through the use of many different distractions; outside threats, intoxicants, mass entertainment, to name a few.  In Djibouti there is no mass entertainment, outside threats are not ever mentioned, and the Islamic populace generally frowns upon intoxicants such as alcohol.  So the Djiboutia use khat to calm and control the masses.  Khat is a narcotic that calms the user, and gives a sense of euphoria.  The use of khat by the general population is encouraged by the government, and according to a document secured from the US military, the XXXXXX manages the khat trade.  Khat dulls the passion, dulls the senses to the point that educated people lack the motivation to do anything about the wrongs of a government that they talk about everyday.

Djibouti is a small country of less than 800,000 citizens, with an unemployment rate of over 50%.  There is nill manufacturing, or any real economic drivers other than having a deep sea port, and leasing of land for foreign military bases.  Service industry is the primary driver for the masses.  Education of the people is not a real priority.  Without a strong education program the people did not know the difference between democracy, dictatorship, communism, or any other method of governance.

Little passion, little education, and even less motivation results in a government with no oversight by the people, in a government that can do as it pleases.  Results in a government that arbitrarily administers the procedures and laws of the country.  The referees can rule on the game that meets their own personal needs.

Contracts in the 3rd World

Contracts and Environmental Law may not seem to be related, but as a is a written or spoken agreement, esp. one concerning employment, sales, or tenancy, that is intended to be enforceable by law it is a topic relevant to this discussion.

Contractual agreements that are funded by the International Finance Commission (IFC - World Bank), with the EU or USA, all require Environmental compliance as a prerequisite.  Actually the contracts will require environmental, safety, and health.  The IFC has a complete standard that must be complied.  Sounds daunting.  But it is not.  Just do the right things and you will be in compliance, and still make money doing so.  Not hard, really.  What is hard is dealing with the local contractors in these developing localities.

The level of business sophistication is just a hair above kindergarden.  A contract is not a bidding agreement to many of these businesses.  It is just suggestions, that can be ignore.  The bad part is that these businesses will ignore whole provisions of the contract, and yet expect to be paid as if they complied with the contract in full detail.  What to do then?

Normally we think the first step is to work it out with the contractor.  He'll understand that he has obligations under the contract.  It is a simple matter of communication, and working it out.  Yes that is one approach that can take months, which may or may not pay off.  What to do if that fails?  Go to court is the normal next step.

In the 3rd world the country government is formed by the extended family; ie the 'Tribe'.  This means the judges and those in position to make decisions are all related to the contractor in some method or form.  

In other words do not hold your breath that you have more than a 50% chance of winning a contract case that is clearly in your favor.  This extends beyond environmental (HS) into any contractual dispute.  There is a reason the country is labeled "3rd World".  

The rules of law, and in this situation contract law, is what separates a developed country from an undeveloped one.  The same issues face both countries such as bridery, favortism, etc.  The difference is that in a developed country the rules are enforced so that everyone has a semblance of a equal playing field without regard to family.

How does this apply to environmental (H&S)?  It applies because if your contract is funded with IFC $ then you are obligated to comply with their rules, even if you don't know any better.  No slack for people coming from the modern societies.   This is where people get into trouble.  Because these 'family' members will want to side with their family there is the option to buy back their neutrality or vote.  They will typically present the option in a coy and secretive manner that would not implicate them, nor yourself.  Slight of hand, a nod in reference to some discussion about money about some other topic there are all sorts of tactics used.  

A lot of foreign companies simply do not want t deal with the EHS requirements of these contracts.  The sad part is that it isn't that difficult.  Instead of ignoring the issue, why not face up to it directly and working a system to comply.  A system that includes sub-contractors that will or will not comply.

You do have the option of sticking your head in the sand.  Hope you can get in do the job and then get out.  But why?  

Renewable Energy in Under-developed or Developing Countries

Electricity as we all know is the driving force for economic development, there is just no disputing that fact.  That does not make it right or wrong, good or bad, it is what it is.  There are people who say that it is not right to introduce, or push, economic development onto the developing nations.  Perhaps they do not want it, or it will not benefit them.  We can't push our lifestyle on others, etc. is how the story goes.  Although I see that Coke Cola has done an outstanding job of placing itself into every corner of the planet.

What is missing from those arguments is that democracy is part of economic development.  Even in China, as that economy has grown certain elements of democracy has crept into their political system.  My apology, I am deviating from the point.

Many of the developing countries do not have the infrastructure for generating, transmitting, or
distributing electricity.  Whatever they do have is typically rudimentary.  Now this in my opinion is a good thing all around.  Why?  Well we all know that it is easier to write on a clean blackboard (dating myself), and so it is in establishing a power infrastructure when it is being built from scratch.  Also, the pricing of electricity in these places is very high compared with the developed world.  This scenario has been identified by other much smarter people than myself, so it is not a new concept.

So what is the connection between a weak infrastructure, high energy prices, and the environment?  Ah, now that is the puzzle to be solved, because this triangle makes for the perfect market driven environment for the development of a renewable energy based economy.  No need for the government welfare feed-in tariffs that artificially create a market for renewable energy, but can not be sustained in economies such as the ones I am talking about.  In these economies the market makes for the perfect incubator.



So I say---

However, it is constrained by a limited pipeline of bankable projects, leading experts to complain about “too much money chasing too few bankable projects” and a lack of resources to prepare projects and develop a robust project pipeline.  Increased efforts are therefore taking place to mobilize human and financial resources and partner with countries experienced at private‐public partnerships (PPPs) to create facilities that either offer extensive and specialized technical assistance or combine such help with financial resources.

  Quality and reliability of infrastructure services is another challenge in developing countries. Power outages and water suspensions still frequently occur, hampering productive and efficient economic and social activities. Frequent interruptions in infrastructure services are significant constraints on businesses in developing countries.

Infrastructure services often are public goods or natural monopolies, or both. As such they are either run or are regulated by public entities and thus suffer from common inefficiencies of public services.

In response to the clear infrastructure deficiencies of most developing countries, and a broad consensus in the literature that infrastructure is important for growth, a number of authors have attempted to provide estimates of infrastructure “needs”. A useful starting point of course is to determine the level of demand. Demand for infrastructure increases with income. For instance we know from empirical studies that electricity use, telephone use and automobiles increase with disposable income. Countries also tend to increase their investments in environmental amenities as they become wealthier.

First establishing the level and type of demand that is welfare-improving and, second, in order to find out whether a project is worth undertaking, relying on a mechanism that tests whether the benefits of a project or service exceed its costs. For most types of infrastructure, cost- covering prices provide such a test. Relying fully on user fees to fund infrastructure services makes sense for all sectors. Cost-covering prices provide the strongest protection against wasteful investments. Relying on prices to reveal demand implies that policymakers instruct potential providers to proceed on the assumption that they will not receive any fiscal transfers or subsidies and that regulation will allow them to set prices at cost-covering levels in the aggregate. 

Providers, whether publicly or privately- owned, will then estimate demand and calibrate it against costs just as any private investors in a normal market would do. The infrastructure provider will then invest and provide the service. He/she can only make money if customers are actually willing to pay the required price. Thus it is assured that investments are welfare improving. Financing happens as in any other market and is again fundamentally the same for private or public enterprises. Firms seek to obtain bank or capital market financing based on the cash flow expected from cost-covering prices. Risks for creditors are limited by the equity of the provider. Proceeding in this way also means that policymakers themselves need not take a view on “need” or demand. They can delegate this to the service provider. 

Without adequate cash flow investment is not possible, and no amount of financial engineering or PPP structuring can change this basic fact. Once prices are allowed to cover costs, the financial constraints on infrastructure investment become significantly less binding. Focus can then move to the optimal market structure, which is what we turn to next.

Maintain the stability and enforceability of laws and contracts. A clear and enforceable legal framework is also among the top priorities for investors. They want the “rules of the game” to remain credible and enforceable—not altered at the government’s convenience once they have made investment decisions based on those rules. A government’s willingness and ability to honor its commitments are key.

• Improve responsiveness to the needs of investors. Investors identified government unresponsiveness to their needs and time frames as the most important factor in the failure of investments. And they considered the administrative efficiency of a host government one of the top factors in their decisions to invest in a country. Completing better preparation of trans- actions before inviting investors to participate can help reduce processing delays and the related opportunity costs for investors. 

Minimize government interference. Investors are most satisfied with investment experiences when they are free to realize returns from their investments with- out government interference. Where investment experiences were successful, investors pointed to their ability to exercise effective operational and management control of their investments as a key factor. And when investors consider investing in a country, they give much weight to the independence of regulatory processes from government interference. 

Economies also depend on electricity supplies that are free from interruptions and shortages
so that businesses and factories can work unimpeded.  

Africa faces a huge energy deficit: the 48 countries of sub-Saharan Africa, with a combined population
of 800 million, are estimated to generate roughly the same power output as Spain, a country of 45 million.  This energy deficit is the result of the region’s limited generation capacity—the result, in turn, of a lack of long-term planning on the part of each of those countries.  The lack of large-scale investment is a consequence of the limited participation of private players and the difficulties in mobilizing long-term financing from African financial systems to fund big-ticket items such as infrastructure, in places that historically have not followed a strict financial regime that encourages long term investment.  

The monthly, daily, or hourly change in government, or policy, along with little internal investment makes for high risk for low returns on investment.

In addition, aging infrastructure and rising demand have led to intermittent blackouts across all regions of Africa, undermining competitiveness. The blackouts largely started in the 1990s in East and West Africa, in 2007, once again due to lack of planning or any formalized plan that was strictly followed. 

Energy facilities across Africa are in urgent need of new and innovative sources of investment, particularly for generation, transmission lines, and distribution. This much-needed investment
is held back because across Africa—especially sub- Saharan Africa—even though tariffs are very high, they do not reflect actual cost because they account for only about 50 percent of the historical production costs.  The thought process within most of these areas is that they deserve to have the lowest priced electricity on the planet, and the developed countries are obligated to provide it.

Even beyond the much-needed physical investment, there is an urgent need to invest in the diversification of the energy mix so as to make the infrastructure sustainable. In East and Southern Africa, over-reliance on hydropower energy makes the economies vulnerable to hydrological conditions. The major drought in the mid-2000s caused substantial economic losses—as high as 4 percent of GDP in Tanzania—and increased the demand for expensive emergency diesel power generation. In Northern and Western African countries, the energy mix depends largely on gas and oil reserves (thermal energy), which is more reliable than hydropower but more costly.  

In Djibouti a country with no conventional resources that has placed its short/mid-term economic and political life on the back of Ethiopian hydropower have suffered considerable set backs with the up and down availability of electricity.  The price of electricity has not dropped since the power started coming from a 200km interconnection line as no more than 35MW is available at anyone time.  The Djiboutian negotiators were out maneuvered by their Ethiopian big brothers as the metering cost is at the point of generation so that the 20% plus line loses are absorbed by the people of Djibouti.  This keeps the cost of electricity at above $400/MW, with continued brown and black outs.  The Ethiopian government is also able to keep their little brothers in line by a flip of a switch, which is not uncommon.

All these situations come back to the same point of lack of planning, and serious focus on long term economic development on the part of each of the countries' private and public leadership.

Hazardous Chemicals Transferred from Developed Nation to Third World Locals

Washing hands with Trichloroethylene

I start off this month's blog with this image as it symbolizes a major international issue that is spoken about infrequently yet should be one of the main topics of discussion in all international commercial discussions.

An example of this issue is a local 'recycling facility', aka junkyard, that has provided the French military with an exclusive location to dispose of all of it unwanted material (trash).  This material includes jeeps, generators, furniture, ammunition boxes (empty), ammunition clips, washers, refrigerators, trucks, tires, barrels, and drums.

There does not seem to be any controls placed on the 'waste' material that is given (or sold) to this local recycler.  I was told this man has been in business for over 30 years and been exclusive with the French military for all of that time.
As you see in the above photograph of drums of 'acid' it does not appear that the containers have been properly drained and cleaned prior to be 'transferred'.  There were a number of drums that were full, of what I don't know, but I would not be interested in doing any taste test.

I watched a laborer who was painting a drum wash his hands using Trichloroethyene (TCE).  I tried to explain to him that this was not a good idea, but I was not able to properly communicate this to him=French does not translate well to English or versa.  Which is just as difficult when we are speaking with people in our own country.  

TCE has been used for years as a solvent by both private and government industrial sectors that includes the military.  It has been used as an anesthetic, in food processing, dry cleaning solvent, industrial cleaner, and in refrigerant manufacturing.

When talking with long time TCE users, who usually look like long time TCE users, it was always difficult to explain to them the hazards associated with the improper use and disposal of this solvent.  It is not uncommon to hear statements such as; "I've been using this stuff for years and nothing has happened to me", "It is great, so what do you have that will replace it", "You environmental people are all nancy boys", etc.  

So trying to speak with someone in a third world country is that much more difficult as they have the same opinion.  This is a parts cleaner product that comes from France so it has to be good, never mind being safe or not.  The man actually did say to me "no problem, good".  

Something as simple as a parts cleaner that is dangerous at best when used properly, is associated (according to the CDC) with depressed brain function, kidney/liver toxicity, associated with the development of Parkinson's Disease, reproductive toxin, and of course cancer whose impacts are magnified when used improperly; i.e. hand washing.

The improper use of hazardous chemicals is a norm in third world countries where a combination of a high illiteracy rate, and general understanding of health is common.  If someone can't read a label how can they understand the dangers or how to protect themselves?  If that same person has no basic health science back ground how can they understand the risks?  Answer to both questions is they can't.  


This is not an isolated incident.  As I have seen large US firms supporting the same type of activity, especially when operating in these third world countries.  One temporary energy firm I worked for had a plant in Ecuador.  The diesel engine mechanics had a local deaf/mute janitor wash parts using gasoline.  When I told them to immediately stop they complained to 'senior' management that I was impacting the operation.  They had used gasoline for parts washing for years, and there is no other alternative.  Of course I identified an alternative within a few days, that was cost effective and safe.  Old ways of doing things are always hard to change.

According to UNESCO the majority of illiterate people in the world are located in the sub-sahara, arabic countries, and south Asia.  The sub-sahara of Africa is where hazardous waste/chemicals has been disposed of or stored legally (as in the case of the French military mentioned about) and illegally.  

The Basel Convention agreement was designed to stop the illegal transboundary movement of these substances.  In the case of the US military it has caused an increase in the price that is paid to dispose of hazardous wastes.  This increased price can put pressure on other country governments to identify other means of disposal as was identified at this one location, either intentional or inadvertent.  

Business Side of Environmental

Money is a word that for most people in the environmental world is not always good.  The thought that we get into this field more for altruistic reasons and less for personal gain.  The personal gain or reward is primarily knowing that we made a difference.  But on the other hand we know we still have a car payment, groceries to be bought, and a mortgage payment.

So in the international world of Environmental Compliance how does money and how you will pay your grocery bill correlate?  Well, let us say you do some type of environmental work for some middle eastern firm, for example a company from the UAE.  And this work is based on a contract between your USA or EU based company and this UAE firm.  By the way I am using the UAE as an example, this is in no way a reflection only on the UAE.

Now they pay you using a check, which is not unusual.  Or even before that they give you a check as a security deposit, but you are told not to deposit it unless they say it is okay--which already should send a cold chill up your spine.

But because you are part of their family, as they will most certainly want to tell you, and they are very wealthy people you are awed into believing this is a great opportunity you do as they have directed you to do.  Accept a check as a security deposit, and agree not to deposit it.  Now you go about and do your work.  Great time in the middle east, etc.  But now it is time to be paid.  You go to your new found family leader and turn in your deliverable.  This is where the fun begins.

Your friend, and family, suddenly becomes less satisfied with your job performance.  They may even cite cultural issues related to how you work, or your life style while living in the country.  They want to discuss the terms of the contract.  This is not a good sign for you.  If you do not have a good in country lawyer, which most likely you will not, this will mean that he lawyer will be all over you.

What do you do?  You could always cash the security 'deposit'...I said this was going to be fun, not logical.  Why not logical?  Well, because our brothers/sisters in the Middle East do not have the same feeling about contracts as others.

What is a check?

Well our friends at Wikipedia say, "A negotiable instrument is a document guaranteeing the payment of a specific amount of money, either on demand, or at a set time, without conditions in addition to payment imposed on the payer. Chequesor promissory notes are common examples. Negotiable instruments are often defined in legislation.^[1] Although often discussed as foundational in commercial law, their modern relevance is sometimes questioned."

Contracts are viewed as memorandums of understanding rather than binding, fixed agreements.

So let us review.  Contracts are not viewed are seriously binding documents, more as a gentleman's agreement, that is based on the honor of the persons involved.  This sets you up for the next point.

People are people all around the globe.  Just because the one you are dealing with is wrapped in white garb, prays 3 times a day, and says you are part of his family, does not mean you are dealing with a honest and honorable person.  In fact, my experience, which maybe dumb luck, is that when the person is saying that you are family, speaking about God, calling you brother, then you better check your pockets.

So back to the check.  Go ahead and deposit that check, and then cross your fingers.  My bet, you are going home empty handed.

Advice--do not accept checks as a form of payment or security deposit.

When in Djibouti, or the UAE---Avoid INMAA Group, LOOTAH General Trading Company like the plague.  

Somalia - Environment, Electricity, Business, and Government Assessment

   
         
     
   


Somalia-Environment

My company TKE-International, LLC was invited to Somalia to meet with the current private electric power producer in Mogadishu.  Dallas Peavey, and I went to evaluate the current infrastructure, both electrical and business, to determine level of risk associated with both.  While there I took the opportunity to evaluate the country, although from a cursory point, the current environmental atmosphere.

The information regarding the current condition of Somalia is varied depending on whom is speaking.  Currently the situation in Somalia appears to be on the edge.  The environmental condition of the country is okay.  The business condition is dependent on whom it relates.

Based upon my on the ground evaluation the situation is still precarious, but improving.  Life never ended during the war, but continued on.  As in all wars certain people took advantage of the situation and prospered greatly.  While others suffered immensely.

The environmental consequences of an unbridled conflict with no holds barred, no rules of engagement, and little thought other than to obliterate the opposition party were tremendous.  The culture of thinking about how the spilling of oil onto the ground or into a water way does not exist, as one would expect that over the past 20 years there was more concern about not stepping on a mine in one's own neighborhood.

The African Union's military, paid for by the UN, that maintains order in Somalia states that there are many areas that are secured in the capital city.  Although travel by Americans in anything other than their amour personnel carriers is not recommended, nor do they move within the city after 4PM.  It is clear that they are doing a good job, as the city is peaceful at night.

The unfortunate issue for Somalia is the reputation that they have earned over the years, as a lawless country without any form of national government.  Any incident now is immediately reported in the international news, as if to confirm that the country has not changed.  Yet, put into perspective how many killings are occurring on a daily bases along the US/Mexico border, or even on US soil committed by Mexican gangs?

The Black Hawk Down incident is one that they do not like to discuss.  I suggested that instead of trying to forget it, they should memorialize the US servicemen who died in that incident as heroes.  Put a plaque in the spot of the incident to recognize it.  This would help the healing process.

The government officials of Somalia speak about power generation from renewable resources as one of their dreams.

They understand that their future economy is directly related to energy costs, and they know that renewable energy is their ticket.  Does this mean that they are worried about 'green house' gases, or global warming?  No it does not anymore than anyone that spends the money to install a PV solar system on their home.  It comes down to practical element of 'money'.

Yes, it is a nice thing that not only will they be able to have inexpensive electricity, and be able to tell the world they are doing their part.  But global warming is not the key point.

Now that pricing for PV solar has come to a point where the common citizen can afford to install it, as well as a under-developed country, we will continue to see the growth of this sector.  Especially in these countries where the price of electricity exceeds $500/MW.

Reality and insanity sometimes are hard to discern, and in the case of what the government wants it is especially hard to know the difference.  They want to have the cheapest electricity in all of Africa, less than $0.21/kwh.  What someone wants and what they get are certainly two different things, but these leaders actually believe that can be done in 2 years, or so they say.  What they call a transmission and distribution system is nothing more than long extension cords running 440v from single generators located throughout the city.  In fact anyone that has a generator can be a IPP--talk about a world without regulations.  There are these extension cords that run from one person's generator to one house on the same pole that carries 10, 20 other extension cords from other IPPs to the same neighborhood.

3,000,000 are serviced this way with no more than 40MW.  Now to fix this system will take a concentrated effort of time and money.  And knowing the political system, the money part will include a brief case being left under tables of various key government ministers and their associates.  The Turkish are doing great in Somalia, because they have no problems with this way of doing business.  For the EU and USA firms, I say stay away.

Be Careful When Dealing With The French Military

Environmental compliance in other countries can be difficult as the question of whether rule of law applies there as it does in the USA, and other places.  We all hope that it does, and I believe to some extent that this is really what it means when we say "our way of life".

Law is what is used as the rules of how we conduct ourselves as civilized people.  Otherwise we live in a world of chaos and anarchy with everyone doing whatever they believe they can do, which may include bad or good.  Without a standard there is no way to judge, so it is a free for all, or there is a dictator.  Of course a dictator does have a rule of law as he/she is the rule(r).

Our field is used from time to time as a tool that is welded about by people or organizations to get what they want, which is not always associated with environmental protection.  They just use it to show that they don't have some self interest.  The good person simply trying to do the right thing.

LESSON LEARNED--FRENCH MILITARY

I am on a project in Djibouti, with the project site located next to French military ammunition storage area.  The project site was sold to the company by the Djiboutian land office in coordination with the Djiboutian military.  We provided the French with a copy of all our project documents to advise them of our operation to include air quality program, safety program, spill prevention/protection, and project layout.

The French general made a good point.  He was concerned about the four 18,000 gallon diesel fuel tanks in regards to fire safety for his ammunition storage area, and a one house residence.  He was also concerned about the generators interfering with the high frequency military transmission system located near by.  That we needed to postpone the project until his engineers could evaluate the potential impact.

It is always important to not wait on what maybe a local neighbor's concern, and let them do the report--this includes dealing with regulators.  So, I proceeded to conduct my own analysis, and found out very quickly that these questions had already been answered by the US military many years ago.  There are no impacts, and by following NFPA for the storage tanks we were very safe.

I provided this report, and yet the French military threw up another 'roadblock' by saying that as a military post they have jurisdiction over all the land that surrounds their bases.  They said it was a agreement with the host country.  But they could not provided the agreement or any other proof.

Asking them about it, they simply said it is a security issue and then they informed their Embassy.

During this time they brought in heavily armed military personnel to shadow our staff as we conducted our work.  They used binoculars to peer at us from close range, as our project is only 25 meters from the property line.

Then of all things, the French military actually stated that if we approached their fence line they would shoot us.  I think this is one war they could win.

The lesson is to document every aspect of your project to include any subject that may not seem important.  It is also important not to assume anything.  Legal documentation that is valid in the USA may not be as binding due to the political strength of the protester, so it is important to be prepared to go public to protect your interests as best you can.

Make it obvious that your project is USA.  Sometimes this is not possible due to security issues, but if at all possible raise your flag.

Get a couple of very good in country lawyers and do not hesitate to file a law suit.

SIDE NOTE:

Interesting also that the same people who are concerned about fires resulting from a aboveground diesel storage tank 300 feet away, are the same ones starting big fires right next to their munition storage areas.