PEOPLE hail the angelic face of the oil palm industry.
True, it nurtures Sabah with good money. But there is a dark side the industry needs to terminate to avert death to all its vaunted rivers.
One problem is oil palm's distorted importance, maybe arrogance, a single-minded economic pursuit for wealth to the exclusion of even more crucial parameters involving the overall will of the people.
Intense public pressure has come to force agriculture to think about others, especially Sabah's overall welfare.
Enough angry complaints about the mess they had inflicted on river water quality and loss of fisheries had reached the ears of politicians to warrant a serious State-commissioned probe.
They uncovered their dark side hidden from scrutiny because of their remote operations - that the industry hailed as producer of the golden crop actually played hangman's role which is about to sentence every river to death, where they operate.
What hasn't helped is the lot of public stupor.
Most Sabahans can't care a hood seeing rivers flow literally with mud, or walk by stinking, dark foul city drains or dead rivers filled with garbage of dead carcasses.
Well, even rivers flowing with mud from unbridled logging of upland forests is enough to kill off the fish because fish breathe dissolved oxygen through gills.
Choke their gills with dense suspended solids from unfettered soil erosion will make sure fish can't breathe - and die.
Large scale commercial logging preceded even more desolating large scale land clearing for mega scale oil palm plantations. The severe twin impacts of massive rough shod land use accompanied mushrooming of 140 palm oil presses on Sabah's rivers is becoming apparent.
In terms of land use, the probe found most planters don't give a hood about saturating rivers with mud.
They found 90pc of planters clear up all natural sediment traps - the riverine forest buffers, and plant palms right to the edge.
Nearly every river in Sabah is becoming too turbid or toxic, as a result of disregard for regulations and guidelines, and deliberate, illegal discharge of organic loaded effluents, the decomposition of which is removing, depleting, emptying dissolved oxygen in the water of every river they operate on.
So, Sabah's rivers are fast becoming dead zones.
How do planters and millers spread this killing field in the heart of Sabah?
Planters admit they have gone overboard The first is what looks most sensible to the planters' bottom line - NPK to boost yield and pesticides to protect them.
But even planters admit they have gone to excess, or force to excesses to force yields.
Inner circles told Daily Express because plantation soil become progressively less productive after years of chemical application, planters apply even more, such as 8-10kgs NPK (nitrogen, phosphorus and potassium) per tree per year, to maintain yield.
This means pummeling the soil with ever more ammonia from the nitrogen, which kills good soil microbes, on top of pesticides which finish off the kills.
So, for lack of beneficial microbial activity, plantation soil compacts and hardens.
One rain storm comes, it washes the NPK straight into the rivers.
The abundant phosphorus in NPK stimulates explosive algae growth and when this unnatural organic algal biomass dies, its decomposition eats up and removes the dissolved oxygen.
Not only that, the study also found in rivers water samples studied four banned pesticides - Alpha chlordane, Gamma hexachloro cyclohexane, Beta hexachloro, PP-DDE, a derivative of DDT, in addition to one for restrictive use - Chlorpyrifox which has to be either residues from past use or from continuing use by plantations.
So, the probe team found the oil palm plantations a major source of river killer pollutants.
Which also poses public health issues for Sabah.
On the mills side, even a First Board company was caught red handed deliberately, illegally and directly discharging large scales of palm oil mill effluents (Pome) into a river.
Since untreated Pome is very high in organic content, it similarly removes oxygen from river water since its breakdown also demands and consumes much oxygen.
When the probe team analysed such water for Dissolved Oxygen (DO), here is what they found - 0.06 that is close to zero, in Sungai Pang Burong, Tawau, compared to the ideal DO 7 for a Class 1 river, 5-7 for Class 2, 3-5 for Class 3, <3 for Class 4 and < 1 for Class 5 where the water cannot be used at all for anything.
So, what kind of warning is this to Sabah?
That fish, prawns and other desirable aquatic life in Sabah's rivers don't even have the oxygen to breathe any more!
In fact, some of the 20 villages downstream five rivers studied have "totally" given up fishing, because there is no more fish to catch, or too polluted to risk health, noted Faizal Parish, a probe team member.
So, should Sabah continue to accord the highest praise to the oil palm industry for doing such a wonderful economic job to Sabah, unless they clean up their acts.
Heavy metals found in some rivers Worth noting, too, is the high levels of heavy metals such as Manganese, Zinc and Iron found, particularly in the rivers and a lesser extent, palm oil mill effluents.
Manganese is essential to health in tiny amounts but chronic ingestion is implicated in Parkinson's disease and debilitating to the nervous system in children.
Even 0.05mg/litre of manganese in water can cause trouble.
That's why the manganese standard for Malaysia is 0.1ppm for Class 2 and Class 3 rivers.
But it reads 3.16mg/litre in Sungai Kalumpang and Pang Burong - the highest recorded from the rivers studied but also hit 2.48mg/litre in some palm oil mill effluent sample.
So, what will be the long-term health impacts for water consumers?
Sabah is left with no choice but to launch quite a costly remake of its rivers, when simply fining polluters would have been the cheapest clean job in the first place.
But the government agencies responsible didn't do it.
The succeed, the oil palm, sand mining industries must now set out to terminate the dark side of its business.
The State Government has vowed to be a 'Terminator' if moral persuasion fails, State Tourism, Culture and Environment Minister Datuk Masidi Manjun hinted.
Why?
Because the Study has identified a serious basic problem in Malaysian habit. The basic problem is identical to what happened to Sembulan River in Capital City Kota Kinabalu which once teemed with fish but is now dead, "because of the old habit of Malaysians in Sabah to use their rivers as sewers", Masidi pointed out.
That practise must be terminated once and for all, before all rivers in Sabah are dead!
The 'terminator' role is clear and certain. Both the oil palm industry and relevant government agencies must now brace themselves for a real terminator job to cut out the rot.
In a Paper 2 presentation on the National Seminar on Impact Study of Palm Oil Mills, Oil Palm Plantations and other Pollutants on the Quality of Selected Rivers in Sabah, Faizal Parish, delivered a very coherent outline entitled 'Proposed Strategies and Action Plans' aimed at addressing what he called "the basic problems."
Because the presentation makes so much sense, but no State leaders were there to give this clear and articulate thinking a personal hearing, we decided to publish it verbatim, so that the relevant agency heads and even the Cabinet can keep a hard copy to study and size up what must be done to save Sabah's rivers.
"The strategies and action plans cover the specific sectors : the oil plant plantations, the palm oil mills, sand mining and riverine human settlements, in line with the main sources of pollution, " said veteran Faizal, a 1982 Bachelor of Science graduate with Honours in Biology, Ecology from the Durham University, UK, with internationally recognised expertise in wetlands, river basin, natural resources assessment and management, and 30 years of working experience in 20 countries.
Faizal is particularly active in promoting integrated river basin management, because he believes is an overall holistic approach to managing natural resources that produce the only effective answer to sufficient and clean water supply for future generations.
Not surprisingly, he is author of a book entitled 'Global Guidelines on Integrated Wetlands and River Basin Management for Ramsar Convention .
Since he has done work on the conservation and rehabilitation on rivers and wetlands in West Malaysia, he'll be an asset in Sabah's quest to remake its rivers.
"As highlighted in previous session (by chemist Lo Su Mui -head of the Study team), the largest land use in the area is oil palm plantations, and in terms of pollution of the rivers with suspended solids, the main contributing source is from the oil palm sector," Faizal noted.
"For contribution of pollutants in terms of biological (BOD) and chemical oxygen demand (COD), the main pollution is coming from the oil palm mills," he added.
"And this pollution basically removes the oxygen from the river system and it kills aquatic life - the fisheries and also affect the quality later for drinking purposes," Faizal pointed out .
"Sand mining is probably the third ranked pollutant source but it concentrated at the moment one section of the Segama river."
"And Human settlement is a minor contribution but it is a still significant at the local level."
"So the to recap from the earlier presentation, the key findings from oil palm plantation is high total suspended solids in the rivers due to lack of or insufficient erosion control practices," Faizal listed.
"In addition, high organic matter in the rivers is due to discharge or overflow from palm oil mill effluents as well as excessive fertilizer use and runoffs."
"From our observation of the different companies and plantations, we found that in many cases, Best Management Practices are not consistently implemented by the different companies."
"We also found direct and serious violations of the regulations, such as this direct discharge (showed photo) by a Main Board company having a pipe connected to their pumping system from the pond directly to the river culvert under a nearby road (under a bridge)."
"So this is a very direct and deliberate discharge."
Unfortunately, it is still going on, Faizal added.
"In addition, the POME treatment systems were generally not maintained."
"In fact, of all the mills in the basins we surveyed, we could hardly find maybe two or three mills which were regularly disludging."
"Some have never ever disludged in their operation period and no one need wonder why they were not able to meet their requirements."
Poor land irrigation system "The second major problem with the mills is Land Irrigation systems is poorly established and managed."
"The continuing direct discharge was unfortunately at a very high level," Faizal asserted.
"I would say we found the direct discharge, either directly from the mill or from ponds or from overflow from the land irrigation system in about 65% of the mills," he cited.
"And this was 25 months of study and the mills know that they are being studied but still a high percentage is still discharging into the river systems."
"One of the root causes and told to us by the mill owners is weak legislation and penalties pertaining to effluent discharge," Faizal related.
In fact, words reportedly had it that some mill owners confessed their standard operation procedure was pollute and pay the fine as that's the cheapest, lowest cost option that they could see for addressing issues because they were hardly ever fined.
So, that's a serious issue - inadequate enforcement.
There are insufficient personnel from DOE who are meant to be monitoring the mills.
And similarly for EPD, they have hardly had any personnel in the east coast region who can do the monitoring, Faizal said.
"So, these basic problems need to be addressed."
"And these problems are also compounded by habitat degradation - the loss of riverine forests and riverine habitats through conversion and these are having very severe impacts on the local people," Faizal said.
"Along the 5 rivers we studied, there are over 20 villages, and many of those villages depend on direct water supply from the rivers that leads to significant health problems when the rivers are polluted."
"The riverine fishery which was the lifeline or income source and protein source for many of the villagers were totally degraded."
"in fact, some had totally given up fishing as there is nothing worth fishing and if they eat the fish then they would get sick."
So, it's quite a serious situation, Faizal said.
"From our overall observation, the major impacts were from the mills and from the plantations."
"Broader than the impact on the villagers are the overall economic and social impacts and risks," Faizal said.
"Number one among these is the potential disruption of water supply to important towns and cities."
"The drinking water or 70pc of whole of Sandakan population get its drinking water which is one of the polluted rivers."
Water source under threat "All of Beluran town gets its water from the Muanad river while Lahad Datu gets its water from the Segama river. If these rivers are polluted, the drinking water supply is polluted and the current water treatment plants are unable to fully treat the level of pollutants which we are finding within the rivers," Faizal said.
"Secondly, at the lower end of the rivers is the loss and degradation of mangroves and their coastal fisheries."
"Coastal fisheries is maybe the number 2 or 3 income source in many of the east coast districts and important incomes for coastal villagers."
"Increased risks of flooding with the siltation of the rivers, as the bed is raised and likelihood of severe flooding especially in lower reaches."
And also the erosion of river banks which is tied to increased runoffs but also the sand mining damage rivers banks and infrastructures, he said.
"Also, there is potential loss of future development options, such as aquaculture, ecotourism, or even carbon finance," Faizal said.
The question is: What can be done about it?
Faizal said the proposed strategies and actions came up after a very extensive stakeholders discussion process.
"We have identified different goals for each sector and associated strategies plus actions that need to be undertaken," he said.
"The overall goal which has been set is to improve the water quality of the selected rivers in eastern Sabah to so-called "clean status".
That means better than Class 2."
"Class 2 means that you can use it for drinking water or for recreation and given that many of the rivers are directly supplying drinking water, they must all be at least Class 2 to continue to provide the water supply for the important towns," Faizal stressed.
"The target is to get to this status by year 2020," he said.
"So, there is a 10year period, although obviously for some rivers, some stretches as prioritized as mentioned by the Minister (Masidi), the target is for the end of this year."
"And for other rivers, it will be phased over a period of time," Faizal said.
The way to get there Control and minimise pollution from the oil palm sector, sand mining and human settlement, as well as strengthen catchment and forest protection, Faizal outlined. .
"For each particular sector, there are also goal statements to address the problems in oil palm plantation, palm oil mills, sand mining and riverine settlement," he said.
"Each sector has to look at its own goaI and then, overall, there is a goal to look at the Integrated River Basin Management," Faizal pointed out.
"There is no point that one sector is cleaning up while the other sectors continue to pollute," he said.
" We will get zero outcome that way, " Faizal cautioned.
"All sectors got to move in an integrated manner.
"And that means all government agencies, private sectors, other stakeholders to work with one vision," he said.
First, Strategies on Oil Palm Plantations - the largest land use within the area.
"We have identified and agreed on a number of strategies," Faizal said.
"First, improving the legal and regulatory requirements and development planning for the plantations."
"Second, promote, implement sustainable and best agricultural practices.
In fact, for many of the problems we are seeing there are win-win solutions.
Better agricultural management means less environmental degradation.
"It means better profits, better economic situation - that's the real sustainability we are looking for."
"Third, there is a need to improve the capacity of key stakeholders both in oil palm plantations and particularly in the mid and small scale plantations, who need support in this but also support is needed to enhance the capacity of government agencies responsible for monitoring and enforcement of the regulations."
Looking in details under these strategies, Faizal said the first area related to legal and regulatory requirement.
"The first thrust here is to is to strengthen implementation of environmental impact assessment and the PPM (Proposals for Mitigation Measures) requirements," he said.
"This is under the enactment managed by the Environment Protection Department and a number of actions to strengthen the implementation of that including the inclusion of mandatory sediment control plans as part of the EIA," Faizal said.
"The second area is review and enhance the implementation of agricultural development plan requirements," he noted.
"Every plantation is required to develop an agricultural development plan which is submitted to the Department of Agriculture."
"In the past, it was only the Department of Agricultural approving those so we have now we have incorporate a mechanism where the Department of Irrigation and Drainage, the Environment Protection Department and other relevant agencies are also closely involved in the process in the future," Faizal said.
"And also, we are looking for those scales of operations less than 100 hectares which did not need an EIA or Proposals for Mitigation Measures (PMM)"
"For those medium and small scale plantation options, we are proposing certain measures for sediment control are incorporated at that level through the Agricultural Department."
"For land clearing and slope erosion control, already in Sabah you are not allowed to develop slopes above 25 degrees. But even so, slopes lesser than 25 degrees ca lead to significant erosion," Faizal pointed out.
"And we have identified a number of areas where the regulations can be enhanced to lesson the risk of serious erosion problem."
"With regard to high conservation value forests, there are still high value conservation areas, particularly in the Segama river basin and the Kalumpang river basin," Faizal pointed out.
And so the requirements for identifying and setting aside those areas in future development strategies, is also important."
"Finally, looking at the land use planning for plantation siting for any new plantations, our general recommendations for the river basin we looked at is the plantations have already reached the maximum appropriate extent.
This is because all of the areas outside the forest reserves have all been converted to plantations and that's what I could say the legal maximum for the development of the river basins that we have looked at," Faizal said.
Almost 90pc had lost river reserves "Some of the specific actions which are linked to the strategies we believe will be the better co-ordination between EIA and agricultural plan requirement, mandatory sediment and erosion control plans as part of both the EIA for plantation smaller than 100 hectares, ensuring land clearing does not damage river reserve," Faizal said.
"As shown in previous presentation by Lo, almost 90pc of the areas we have visited there were no river reserves left! The plantation was right up to the river edge!" Faizal noted.
"In some of the stakeholders workshops, people claim, the rivers move, we planted it there, the river was there, the river moved to our plantations.
But we said then the river moved but where because the oil palm is on both sides banks of the river.
The river can't move both ways at once."
"Indeed the river does sometimes move but it doesn't move both directions at once," he noted.
"So, if there were oil palms on both banks of the river, it was planted there.
It wasn't that the river suddenly moved into the plantations," Faizal reckoned.
"So this I think is a basic failing within the Land and Survey Department in the designation of the Land Titles. In enforcement of the areas developed must be within the land title area."
"If you planted on the river bank, then you have gone beyond what normally is the legal land title."
And the State is perfectly right in taking back those lands," Faizal said.
"There are some plantation companies, for example, Wilmar Group of Plantations who have already recognised the problem and for 50km along the Segama river, have planted back the forests along that river corridor which was inadvertently developed by the river corridor earlier," he cited.
"So this is the type of initiatives which needs to be expanded elsewhere, " he praised.
"It's also critical to establish other crops immediately after land clearing operations."
"Very often the normal practice is, clear the land, wait some time, wait till your seedlings are ready, only after you have planted all your oil palm, then maybe add a cover crop."
" Basically that's too late, because already, the erosion has started, you are losing your top soil, you are losing your nutrients."
"So this way the whole basis of our plantations is being eroded in front of you.
It's a very bad practise."
"You can put the cover crop immediately after land clearing and then if you need to clear a little bit of cover crop when you plant the palm then it's a very small cost for having saved your top soil which will save your fertility."
"And we have recommended no land clearing in wet seasons and in wet areas because this really is one of the major causes of large scale erosion into the rivers," Faizal said.
"The second strategy is promote and implementing sustainable and Best Agriculture Practices."
"Firstly, promoting optimum and precision fertiliser management." "Secondly, integrated pest management."
"Thirdly, soil and moisture conservation practices."
All of these practices are well known and practised in many parts of Malaysia, Faizal asserted.
"But in the studied areas in eastern Sabah, many times we saw that they were not being complied with, even though they are fundamental of having a good crop, good production."
"Fourthly, establishing and managing high conservation areas, including river reserves, which again, is badly implemented in this region," said Faizal.
"With regards to workers' quarters, we observed solid wastes, scheduled wastes, and the fuel storage that need to be addressed in many places."
In general, the zero burning concept is widely applied throughout Sabah but certainly in the smaller scale plantations, and small holders, we still saw burning taking place."
And burning, as I think all the oil palm plantations know, is not good for the bottom line.
In fact it leads to greater losses of the fertilizer benefits of the decaying tree trunks in the replanting as well as causing air and other pollution."
The third strategy relates to improving the capacity of stakeholders to support the plantations management.
This includes increased stability for the relevant government agencies for enforcing the EIA requirements, agricultural development plans, and other regulations as well as increasing the capacity of the plantation sector, especially medium and small scale plantation for undertaking best management practices, Faizal said.
Few of the action, capacity building, best management practices, promotion of use of waste through composting and other value added products, we propose incentive schemes for the implementation of best management practices.
"So we have proposed an incentive fund in the different best management practice areas which would be prioritized maybe to the medium and small scale operators but also for other operators who want to introduce new technology or new approaches.
"Overall, for the four basins studied, we have said no further expansion of oil palm plantation because already the oil plant plantation has reached the maximum extent," Faizal said.
"And also the study has agreed to promote the certification and compliance with code of practice for existing plantations. That is, the Malaysian Palm Oil Board code of practice , RSPO principles and criteria and encouragement of oil palm plantation within the area to become RSPO members, ISO and other standards in relation to good management for the mills.
What the Palm Oil Mills need do "As mentioned earlier by our chemist Lo Su Mui in her Paper 1 presentation, one of most serious point source pollution within the selected basin is coming from the mills, particularly from direct discharge but also from the overflow of Land Irrigation systems," Faizal said.
"So, our first strategy is similar to the plantations - improving the legal and regulatory requirements."
"Although the Minister (Masidi) said, well, it's good if everyone out of voluntary basis, puts their own house in order, but unfortunately, for some, the only way forward is the use of the stick," Faizal reckoned.
"We need the carrot and the stick and currently, the stick is already broken and doesn't work or we have some masochistic people (people who enjoy what causes trouble) who like the stick and maybe the stick is a very cheap way to deal with the problem."
He said if offenders were only sent for "canning" only occasionally, they carry on with business as usual.
"The second strategy is to implement Best Management Practices for Mill Waste Management," he said.
"In fact, we should not be thinking any more about mill wastes.
Instead, these are the potential new products, new sales items, new income generating options, it's not wastes, it's utilisation of them," Faizal suggested a new way of looking at resources in Sabah.
"Thirdly, and this is very serious - improve the palm oil mill effluent treatment process, particularly the implementation," he said..
"Lastly, enhance the capacity of these stakeholders."
Mandatory closure of 'recalcitrant' palm oil mills Elaborating on the details on regulatory requirements for the mills, Faizal said: " It has been agreed one important step for the mills is that since the mills come under the Environmental Quality Act, 1974 and enforced by the Department of Environment (DOE), it is agreed to amend provisions for structured fines and compounds. And that basically this new provision will mean an increasing scale and mandatory closure for mills," Faizal said.
"This I think is sincerely believed and also the feedback from members of the industry the only way to bring recalcitrant companies in line is closure of the mills," Faizal added.
"Fining is insufficient, closure of mills is the only proven effective means to wake people up," he said.
"As the Minister (Masidi) said, this is going to be phased in but I think all companies need to recognise this is coming and then to take action before the mill is closed down," Faizal added.
"Secondly, enforce the requirement for any new mills, for planning approval for new Mills."
"In fact, our assessment is there are already enough mills to cater to the amount of plantations," he said.
"So, if the plantations are not expanding, there is very little justification for new mills in Sabah.
In fact, since many mills are running under capacity, it may even be sensible to consolidate mills rather than open new mills," Faizal said.
"Thirdly, promote standards and code of practice for mill operations."
"Fourthly, develop extensive mechanisms for good management of mill wastes," he said.
"We cannot just have the stick, we must have the carrot as well."
"Those mill operators who have consistently performed well, who have met the requirements, who have exceeded requirements, should be getting some benefits, maybe some reductions, in the fees or payments, or other incentives provided to them, for example, access to low interest finance etc," Faizal said.
"The second strategy relates to mill wastes management, implement zero waste concept and convert the mill wastes to value-added products.
This is of extremely high potential for companies, the technology is there, financing is available but it just needs doing," he said..
"Optimize water use and recycle water. The less water, the less liquid waste coming out from the mills."
"Thirdly, sort out the problems with Land Irrigation practices which are very severe."
" The fourth area is improving the treatment process, as Lo (chemist and Head of Study team) indicated, there are already a lot of technology available. But unfortunately though they maybe installed, they are not managed properly and the systems may not be maintained.
So, implement and improved the Pome treatment systems."
"As the Minister (Datuk Masidi) said this morning, every mill must have its Environment Unit, headed by a Pollution Control Manager."
"There must be someone of appropriate level with the knowledge in the mill that can be in charge and be responsible for the pollution and pollution prevention. Therefore it is very easy to see who has the responsibility when it doesn't work."
"Fifthly, conduct scheduled maintenance of effluent treatment systems to ensure compliance with standards," Faizal said.
"In fact, this is the biggest problem."
"We have seen in many of the mills, every mill has a pond system but only 20pc of the mills are properly maintaining the pond system," he noted.
"Particularly in Sabah, we have a very high rainfall situation, some mills are facing the problem how to do disludge - how do you dry your sludge when you got heavy rains all the time. So, there are some real problems," Faizal conceded.
"But there is a technology available, there are appropriate ways forwards, " he added.
"And also it has been agreed, there should be independent third part reviews of all these , such as plant efficiency, equipment functionality and effluent treatment facilities so that it is very clearly laid out what is the fundamental problem that needs to be addressed in every mill," Faizal said.
"It is recognised that every mill has a different set of problem, that's why we need independent assessment."
Getting the public involved "To improve the capacity for these stakeholders as the Minister (Masidi) said, implement Self Monitoring is best but there is also a need to enhance engagement of the public or the local community," Faizal noted.
This must be done to achieve the dual purpose of Land Use Planning, that is, safeguarding the society's resources with planning to meet the needs of the people as the end in mind.
"In the rivers we looked at, we have 20 villages sitting downstream of mills. Every one of them knows when the mills are discharging and the government has to set up a proper feedback mechanism ."
"The Minister (Datuk Masidi) mentioned just now the Ministry will establish specific sites on the website for the public to give feedback and within the action plan, it is setting up a direct real time water quality monitoring from the mills being available on the web within one minute after the sampling is done!" Faizal said.
"But improved monitoring, enforcement capacity and efficiency is also needed," he added.
"For the mills, the main enforcement is by the Federal Department of Environment (DOE).
But they lack adequate staff and resources.
This needs to be addressed."
"To repeat, these are a few of the actions mentioned - there are going to be penalties for pollution, including mill closure, enhanced enforcement capabilities and real time web page monitoring downstream of mills," Faizal recapped.
"This means although you are in a remote place, you can no longer hide in a digital age," he noted.
"This means you can have continuous monitoring downstream of the mills which gives a readout in Kota Kinabalu, Kuala Lumpur or even New York within seconds after the reading is done," Faizal asserted.
"So, it's no longer possible to hide in the plantations and assume no one is looking."
The adoption of standards is a win-win situation for most, and an enhancement of the Pome treatment."
