Tuesday, June 11, 2013

US Forest Service policies still affecting fires in New Mexico & the West.

Getting new planes for the US Forest Service won't save lives or property if the retardant used isn't replaced with something new. 
By Howard DeLaCruz-Bancroft, as reported last year, July 6, 2012

“It doesn’t make any sense” said Ed Kleiman former US Forest Service, MTDC (Missoula Technology & Development Center) Wildland Fire Chemical Systems employee, who now works with “FireIce” a company that produces SAPG (super absorbent polymer gel) based fire retardant. Why is the USFS (US Forest Service) using a 50 year old fire retardant that is as old as the planes performing the drops, and is mainly a phosphate salt, red metal oxide colorant, gum thickener, & unnamed corrosion inhibitor which has never been proven to stop a fire.

Andy Stahl from the Forest Service Employees for Environmental Ethics (FSEEE) has successfully sued the US Forest Service three times confirmed Kleiman’s assertion that the US Forest Service 50 year old “red slurry” Phos-Chek, fire retardant has no proof or documentation that it has ever been effective in preventing loss of life or property.

Federal Judge Donald Malloy recently decided in a most recent USFS case involving FSEEE and ruled against the use of “Phos-Chek”, which has the same phosphate based ingredient banned in 17 states in 2010 from household washing detergents, found to have polluted lakes, rivers and waterways. Phos-Chek was created by Monsanto who also created “agent orange” a controversial defoliant used during the US Vietnam conflict.

It was ruled that Phos-Chek was not to be dropped on any waterways or threatened or endangered species but as a compromised policy enacted by the US Forest Service and after being excluded from many areas by law the US Forest Service continues to drop the “50 year old red slurry” by using loopholes to avoid dealing with the toxicity of Phos-Chek http://www.pe.com/local-news/riverside-county/riverside/riverside-headlines-index/20100918-restrictions-may-eventually-hit-fire-retardant-airdrops.ece

The question I posed to politicians in New Mexico to include the Governor Susana Martinez was if you had a choice between something toxic with unproven effectiveness and something non-toxic that has been proven to save lives and structures what would your choice be. Her response was expected. She would rather use something non-toxic that could save lives and structures. http://nmgovtv.blogspot.com/2011/06/howards-meeting-with-gov-martinez-on.html

This same concern is expressed by New Mexico Congressman Steve Pearce who is working on an investigation into possible negligence of the US Forest Service, when it claimed it used all the available resources to fight the 2012 Little Bear fire in New Mexico, where almost 250 homes were destroyed.

An example is the non-toxic, gel based technology fire retardants, which is an alternative to Phos-Chek, but was not allowed to be used by air tankers. The USFS QPL (Quality Products Listing) which are products approved for use by the US Forest Service shows FireIce as approved for use http://www.fs.fed.us/rm/fire/wfcs/documents/qpl_we.pdf

When I asked the US Forest Service spokesperson, Jennifer Jones, the public affairs officer with the USFS National Interagency Fire Center, what would it take to get an alternative fire retardant to Phos-Chek, with something that is already listed in their QPL flown on air tankers for use in New Mexico? I was told that local fire managers could make that decision.

However, when I specifically mentioned not for use on trucks but by air tankers. There was a long pause and she said that was out of her area of expertise and I would need to contact the regional fire manager for New Mexico. She also asked “where was I coming from with that question”. She said I could email her and she would provide me the name of someone who could answer my question but as of yet that has not occurred, even after the next day I called to ask again for that same information with no response.

I saw an email from Joe Walsh spokesperson for the US Forest Service, that stated FireIce is an alternative to the phosphate based Phos-Chek and is available on the QPL and decisions to use any product are made at the local—or field unit—level. However, Ed Kleiman said this isn’t true for “multi-engine airtanker” usage and that decision is made by the Forest Service, Washington office for Fire and Aviation Management.

I contacted Peter Cordani, chief technology officer, an inventor for GelTech Solutions http://www.geltechsolutions.com, a publicly held company, GLTC, listed on the US Forest Service approved QPL regarding FireIce, which is an alternative to the phosphate based retardant “red slurry” which is at this time the only fire retardant allowed in large multi-engine air tankers.

Peter Cordani, stated FireIce is a gel based technology fire retardant proven to be non-toxic, & non-corrosive. He also stated GelTech Solutions has a federal BPA (blanket purchase agreement) for its product and the delivery equipment and although FireIce is approved for large multi-engine air tankers, helicopter, single engine planes & ground engines and is on the USFS QPL they are not being allowed use in multi-engine, large air tankers because of an contradictory US Forest policy that excludes gel based fire retardants.

While all other international, state & federal agencies recognize the validity of gel based fire retardants and direct fire attack and suppression, the US Forest Service maintains a restrictive control on the use of gel based fire retardant’s for any such usages in large multi-engine air tankers and their policy needs to be changed yesterday, Cordani said.

Tony Morris, of the Wildfire Research Network http://www.wildfireresearch.org/About.htm said “the US Forest Service is the only agency in the world that doesn’t directly suppress and attack fires immediately and look at the results they speak for themselves.”

Cordani added, the bottom line is, I know FireIce is going to revolutionize fire fighting all around the world, it will save lives, property and bring safety to the pilots and the ground crews. It is environmentally friendly, it saves millions of gallons of water, is lighter, cheaper than any product currently being used today, and hands down it is the most effective fire suppressant/retardant in the world.

A huge concern is pilot safety, Cordani declared, FireIce is one pound lighter per gallon than the “red slurry” currently being used. If you were to fill up a DC-10 to its maximum capacity of 12,000 gallons, that same air tanker using FireIce would be 12,000 pounds lighter. This means that pilots are safer because of less stress put on the planes. He pointed to past incidents of wings breaking off of planes during other drops. http://wildfiretoday.com/2012/06/07/24-fatalities-in-p2v-air-tanker-crashes-since-1974/

Cordani said the current US Forest Service policy needs to be changed to allow direct attack & suppression from the air with large air tankers using FireIce. The Forest Service states in its own publication found at http://www.fs.fed.us/rm/fire/wfcs/training/documents/aerialapp.pdf Long-term retardants (direct and indirect attack): … Note: Long-term retardants are no more effective than plain water in direct attack. Whenever possible, plain water, foam or gel should be used for direct attack.” * Long-term retardants used in this context is synonymous with “red slurry” or the trademark name “Phos-Check” (I added this asterisk marked comment)

Cordani continued, “So when you ask me why wasn’t FireIce used on the wildfire in Colorado, when it should have been a “no brainer”. It’s inconceivable why anyone would not use it, and makes me question the decision making process.

Cordani recently received hundreds of calls from firefighters and citizens asking why isn’t FireIce being used in Colorado?” Even his own mother and young son were so emotionally distraught over the losses, he decided to immediately fly out with a team of FireIce experts to Colorado and put the entire FireIce Staff on standby, to offer help to include cutting edge equipment and delivery systems.

After Cordani’s meeting with the Colorado Governor’s office, numerous calls, emails, late nights and offers to help, http://www.youtube.com/watch?feature=player_embedded&v=JD8mcHQidy0 the opportunity sadly never materialized to use FireIce, to save lives and property. After Cordani returned to his hotel and saw the devastation on the news reports he felt sick because he could have made a huge difference knowing that all the resources available were not used.

The opposite was true at the 300+ acre Romero wildfire, June 28, 2012 near Albuquerque New Mexico where Dutch Synder, a 27 year veteran of SEAT (single engine air tankers) credits FireIce for stopping the fires before they could grow out of control. “I have never seen a retardant hold a fire line like FireIce or any product knockdown a fire so quickly as a suppressant with the added safety of being lightweight.” http://www.marketwatch.com/story/geltechs-fireice-used-to-control-new-mexico-wildfire-2012-06-28

Fire Managers at the Bureau of Indian Affairs (BIA) credited FireIce and SEAT pilots with preventing another large wildfire in the southwest United States. “We witnessed the effectiveness of FireIce today and the results were exceptional, it’s a superior retardant,” stated Elizabeth Dick, BIA manger of Airtankers. “With 14 minute turnaround times, no other product mixes so fast and effortlessly without any cleanup problems, “ added mixmaster and loader, John Reinhart. http://www.fireapparatusmagazine.com/articles/2012/07/geltech-fireice-used-at-another-new-mexico-wildfire.html

Ed Kleiman added that although, FireIce is defined & classified by the US Forest Service as a “water enhancer” instead of a “fire retardant” it is a specification that doesn’t match the definition. FireIce is mixed the same, uses the same equipment, with the same viscosity, drop patterns, and ground coverage with the added benefit of being both a suppressant and retardant.

The transition for usage would be seamless at a fraction of the cost. It does not require an emulsifier, pressurized or atomized equipment. FireIce is the only gel based fire retardant that uses a simple “gravity tank” system, there are no expensive compressors, pumps, piping or any heavy or complicated accessories needed and no harsh chemicals needed for clean up.

Ed Kleiman went on to recount the lack of advances in phosphate salt based fire retardants. When I asked had any changes or improvements been made to the 50 year old “red slurry” product. Mr. Kleiman said that different phosphate salts were substituted but it remained essentially the same with the mixing ratio recently changed to add more water, an increase in price with less product.

Kleiman recounted a forest service historical usage of retardant materials starting with Borate in the 50’s until it was found in 1956 to sterilize the ground it was used on. Borate was then replaced with both competing products of GelGuard a basic version of today’s polymer gel and Phos-Chek which is basically the same phosphate salt product in use today. Both products were used in Canada and the US in the 60’s until the early 70’s and tests were done which showed polymer gel products more effective.

The first Phos-Chek retardant product was available in 1962. The Phos-Chek brand belonged to the Monsanto Company until 1998, when ownership was transferred to Solutia Inc. In 2000, Astaris LLC acquired the Phos-Chek name. In November 2005, Astaris LLC was acquired by Israel Chemicals Ltd. (ICL) which is one of the largest miners of phosphate and develops and markets fertilizers, metals and other special-purpose chemical products, and the Phos-Chek brand was renamed “Phos-Chek Fire Safety Group” and assigned to the Performance Products division of ICL (ICL PPLP). http://en.wikipedia.org/wiki/Phos-Chek

The same ICL company that owns Phos-Chek is under scrutiny for its other toxic and ineffective fire retardant’s and is currently proposed to be banned in California, New York & Washington. http://www.mercurynews.com/health/ci_20891009/lets-cut-toxic-flame-retardant-use-furniture-gov

Fire-Trol & Phos-Chek were past competitors in the Ammonium Phosphate fire retardant industry. However, Fire Trol named all of the components of their ingredients specifically the corrosion inhibitor which used sodium ferrocyanide, that led to their downfall because it was determined to be toxic while Phos-Chek which used a corrosion inhibitor is commonly believed to be just as toxic but was classified as a trade secret so it did not have to be revealed or known. In 2000 the ban against sodium ferrocyanide was made and its usage were suspended for three week but the Forest Service continued to use the product.

However, in 2003 the US Forest Service made a determination to use only gum thickened retardant which reflected Phos-Chek’s patent. Fire-Trol filed suit against the Forest Service for failure to follow its own procedures when making changes to QPL which effectively put it out of business and Fire-Trol was bought out by Phos-Check ending any future claims.

I called Cecelia Johnson, one of the longest working employee in the US Forest Service fire chemicals program to gain a historical perspective on the issue. She still works at the Missoula Technology Development Center (MTDC) 42 years later. She made it clear that to discuss anything with any press or media needs to get clearance from Jennifer Jones, USFS spokesperson. It was obvious to me that she felt constrained to speak freely.

A 2010 Forest Service memo that appeared to be a “gag order” of sorts was sent to me outlining the concern of any USFS employee making comments to the press or media. I don’t know if this applies in this case but no doubt there is mounting pressure from all sides inquiring into Forest Service practice and policies in light of all the destruction and loss associate with recent mega fires in New Mexico, Colorado and in other Western states.

Two simple policies of the US Forest Service need to be changed. The rest of the world mandates direct suppression and attack on fires as soon as possible and so should the US Forest Service follow suit. The other USFS policy not allowing gel based fire retardant’s like FireIce to be used in larger multi-engine air tankers should be removed. Even the Bible seems to add wisdom to this issue in Luke 5:38 it advises to put new wine in new wineskins. My take is don’t put old retardant into new planes.

In my second part of this expose to be released later, I want to show how other current policies, practices & procedures hinder the US Forest Service from acting quickly and effectively in firefighting.

Sunday, April 21, 2013

Do "gun control advocates" wrongly believe the Police have an obligation and duty to protect them?

Because of the recent rash of violence and debate over gun control I believe it is imperative to share this:

Warren v. District of Columbia 1981 set a precedent (US Dist Court of Appeals same force & effect as the US Supreme Court) that the Police have no constitutional or federal obligation to protect private citizens from each other but with two exceptions. Their job is to investigate crimes and arrest criminals.


Monday, March 11, 2013

Concerns about United Nations Agenda 21

NM HM96 Erosion of Sovereignty & Property Ownership

I was asked to draft a resolution for United Nations Agenda 21 concerns by New Mexico State Representative Thomas A. Anderson called HM96,  a resolution that is being heard on the New Mexico House of Representatives floor this morning.

Originally these concern were addressed in HB307 but it failed to reach the house floor for a vote.

One of many concerns in this resolution addresses language referencing "sustainable development" which is overly broad and can be misused to "condemn" private property in attempts to join all wildlands and wilderness areas.

If your property is surrounded by such "federal" lands then you can be displaced by imminent domain. The fair market value would be based on the property condemned.

However this would make it difficult for property owners to purchase replacement property in another location likely being more expensive, and gives no status or method for recognition for the previous historical usage.

Below is a map of Federal Public Lands. As you can see in the western portion of the United States a large percentage of land is NOT private and is a checkerboard mix.

Any attempt to join "wildlands" and "wilderness" will have detrimental affects on private property ownership. Other issues are concerns that single family homes, ranches, small farms will be condemned to create "sustainable development" multi-family dwellings and multi-use facilities to replace the inefficient single usage.
Some of these ideas are more easily understood back East where there is "urban blight" and a smaller percentage of Federal Public Lands. However, it still doesn't change a concern that "due process" may be circumvented by an application of the Supremacy Clause where "federal" law trumps "state" law and international law is seen to be increasing in authority and citation by local courts.

There are many other instances for concern that can be addressed more adequately in a future post. I wanted to respond to oppositional comments that this is an attempt to "demonize" global environmental organizations, including the (ICLEI) International Council for Local Environmental Initiatives and the (IUCN) International Union for Conservation of Nature.

I don't believe name calling is beneficial to any attempt to rationally debate the concern for the possibility for potential misuse, and misinterpretation of broadly construed initiatives. I do believe that any such initiatives must address such concerns as outline in HM96.

Thursday, January 17, 2013

Parking at the legislature?

I was bummed about the delay at the legislature with issuing parking passes, until I saw the number I received.

Tuesday, January 8, 2013

David Robbins, APS School Board re-election bid gets spiced with Latino Community support from Luis Acle endorsement

January 8, 2013
Contact: Howard DeLaCruz-Bancroft;

ALBUQUERQUELuis Acle, former Arizona US Senate candidate, former President of the San Diego Public School Board, President Reagan Associate Director appointee and founder of “Latino Values” Super PAC, announced his formal endorsement and support for David L. Robbins for re-election to the APS (Albuquerque Public Schools) board election to be held on Feb. 5, 2013.

Mr. Acle’s reason for supporting David L. Robbins for APS school board
Mr. Robbins has an MBA in Finance and an undergraduate degree in Economics. Having been the president and a public school board member in one of the largest school districts in the USA, I can assure you there is a great need to understand the budgetary issues to be effective. Otherwise, depending on others who may have vested interests is not responsible leadership. I know that Mr. Robbins currently serves as Governor Appointee under Taxation and Revenue Secretary, Demesia Padilla, as the Director of Administrative Services. I also understand he was the only board member who voted for an “independent audit” of the APS budget.”
  Mr. Acle’s reason for involvement
Mr. Robbins has included Latinos in his close circle of friends and advisors. He walks the talk and that is what is needed to bring Latinos into the circles of political influence. His willingness to be accountable is worthy of my support and endorsement. As the founding member of “Latino Values Super PAC” we are committed to helping elect both Latinos and supporters of the Latino community who believe in similar traditional, historically conservative values.
  There is a need for continued involvement in the local school boards
Luis Acle added, “There is an ongoing struggle to keep accountability and transparency in our local public schools. I am convinced that David Robbins is committed to both and he is someone that can be trusted with the publics’ fiduciary interests. I understand David L. Robbins, is the best candidate to fight for fiscal restraint, conservative, and traditional family values, something most Latinos favor and I am proud to support and endorse his re-election bid for APS school board.
   Results not Promises” campaign contact information:
Luis Acle, is encouraging others to help David L. Robbins,in his “Results not Promisescampaign, by visiting http://www.improveaps.com or email: drobbins10@comcast.net people can also call (505) 400-9355 for more information if they want to help improve APS.

Sunday, January 6, 2013

Teil Plont withdraws to endorse David Robbins for APS 2013 school board

Teil Plont withdraws to endorse David Robbins for APS (Albuquerque Public Schools) 2013 (District 6, NE & East Mtns.) school board

January 5, 2013

Contact: Howard DeLaCruz-Bancroft;


Teil Plont, Official withdrawal filed, December 31, 2012

ALBUQUERQUE – Teil Plont, former candidate for APS (Albuquerque Public School Board) District 6, announced his withdrawal, so he could support David L. Robbins, the incumbent for re-election on February 5th, 2013.

Mr. Plont's reason for supporting David L. Robbins for APS school board
After sitting down with Mr. Robbins, I felt that we shared similar viewpoints on most issues. I was very impressed with his in-depth understanding of the ongoing concerns of parents like me.”

There is a need for continual improvement at APS
Teil Plont further explained. “There are still problems that need attention and I believe David L. Robbins, is the best suited candidate to make those changes. He continues to fight the good fight, for fiscal restraint, conservative, and traditional family values.”

David L. Robbins background
Mr. Robbins has an undergraduate degree in “Economics” and an MBA in “Finance”, and it will take someone very knowledgeable to sort out the complexities of APS financial issues. He was the only APS school board member to vote for an “independent audit” of the APS budget and that was very re-assuring” said Teil Plont.

Mr. Plont's reason for involvement
Teil Plont became interested in helping APS because of his children, where he saw the need for developing resources without spending taxpayer dollars by motivating volunteers.

Mr. Plont's background
He refined his academic training skills in the US Army, where he began his military career in 1987. Mr. Plont was assigned to TRADOC (Training & Doctrine Command) in 2006, where he became attached to the US Army's “Schoolhouse Operations” which performed: Management, Quality Control, and developed, Course Protocol and Curriculum. He will continue to pursue his interests in developing volunteers by working with David Robbins and his local school.

Results not Promises” campaign contact information:
Teil Plont is encouraging others to help David L. Robbins, in his “ Results not Promises” campaign, by visiting http://www.improveaps.com or email: drobbins10@comcast.net people can also call (505) 400-9355 for more information if they want to help improve APS.



Friday, July 13, 2012

Anonymous Response to Comments on USFS fire suppression/retardant story

I received a response to Eddie G.'s comments on my initial story on the USFS firefighting issues from air tankers in the US. I was unable to insert the comments as a reply so I created a new post. The first in black are the comments by Eddie G. The second in red italic is the anonymous response to the comments. 

Eddie G.: Gel is NOT a retardant. Gel is a water enhancer that simply makes water more effective by allowing it to stay in place. Once the water is gone, after only minutes under fire conditions, there is ZERO effectiveness. Retardants react chemically with the fuel to render it non-combustible, don't rely on water to be effective, and are effective until physically removed. Calling a gel a "retardant gel" is wrong, misleading and dangerous.
Anon Response: The definition of a retardant is anything other than water that slows or stops combustion.  The USFS own Specification 5100-306a for “water enhancers” states in the first paragraph:
1.1 Scope:
They may be applied from ground or aerial application equipment, directly to the fire area to SLOW OR STOP COMBUSTION, and for exposure protection.
Effectively defining the product as a RETARDANT!

Eddie G.: Gels and retardants must meet the SAME health, safety, toxicity and environmental friendliness requirements in order to be qualified. Calling retardant toxic and gel non-toxic is a lie.
Anon Response: Washington Journal of Environmental Law & Policy 2011
Similarly, a U.S. Fish and Wildlife Service study found that use  of  aerial  fire  retardant  likely  causes  an  “increase  in invasive species,  loss of substantial fraction of population or habitat, and harm to soil chemistry and plant physiology,” as well as direct mortality to fish and amphibian populations.160
Aerial fire retardant consists of eighty-five percent water and fifteen percent fertilizer, thickeners and corrosion inhibitors.161
Each   year,   firefighters  drop   millions  of   gallons  of   this substance  on  the  nation’s forests, which may  inadvertently
land on people, on animals and in streams.162 The retardant’s
effect  on  streams  can  be  catastrophic  and  can  kill  fish, including  some threatened species.163     For example, in 2001
Fire Regimes, 284 SCIENCE 1829, 1829–32 (1999).
1995) [hereinafter Beschta Report], http://www.saveamericasforests.org/congress/Fire/ Beschta-report.htm.  The  Beschta  Report  is  an  independent  scientific  study  that questioned about salvage logging in severely burned areas. See Keiter, supra note 6, at 336.
158. Beschta Report, supra note 157, at 12.
159. Id.
160. Forest Serv. Employees for Envtl. Ethics v. U.S. Forest Serv. (FSEEE III), 726
F. Supp. 2d 1195, 1226 (D. Mont. 2010).
161. Id. at 1225.
162. See id. at 1244–45 (discussing Forest Service guidance on use of aerial fire retardants that prohibits drops within 300 feet of streams).
163. See   Restoration   Project:   Omak   Creek,   WILD   FISH   HABITAT   INITIATIVE, http://wildfish.montana.edu/Cases/browse_details.asp?ProjectID=48 (last updated Apr.
7, 2007) (According to a study by the Wildfish Habitat Initiative, a cooperative effort between  US   FWS  and  the  Montana  Water  Center,  Omak  Creek  in  Eastern Washington State  experienced catastrophic environmental harm from fire retardant drops. In 1992, the Confederated  Tribes of the Colville Reservation began restoring Omak Creek to rehabilitate historic steelhead  and salmon spawning grounds. The project involved removing large boulders and other barriers  that tumbled into the stream as a result of decades of blasting from mining and expansion projects. In 2001, the project experienced a major setback. That summer a wildfire raged on the public lands near the creek. Firefighters called for retardant to be dropped to stop the blaze, but instead of  blanketing the trees, the drop blanketed the fragile creek eventually killing a significant amount of the threatened steelhead in the creek. 

Eddie G.: In addition, retardant must also pass a burn test to prove it is effective stopping and slowing a fire. Gel has no such requirement. There is no data anywhere that proves gel will stop a fire.
Anon Response: Gel has been used since 1960 to STOP fires and many documents exist from the USFS describing its retardant properties on hundreds of fires
In addition all “water enhancers” go through a LIFT test for extinguishment completed by the USFS

Eddie G.: The 300 foot buffer around water streams, a policy that has been in place for 10 years, is good policy because anything dropped directly into a water stream will impact water quality and could impact fish. Including gel.
Anon Response: There are exceptions to the rule when public safety is threatened, and the current Record of Decision on retardant by specification states water or more environmentally friendly product should be substituted ie. Gel

Eddie G.: GelTech's BPAs for Delivery Equipment are for RETARDANT not gel. Perhaps you should read them.
Anon Response: Interesting Issue and may be a violation of FCIC laws concerning competition in contracting

Eddie G.: There is no evidence that FireIce is "the most effective suppressant/retardant in the world." In fact, the QPL would say otherwise. It takes 2-4 times as much FireIce as either AquaGel or Thermogel 500P to achieve the same result.
Anon Response: The QPL is a recommendation from a laboratory looking at “water enhancer” products from a primarily structure protection aspect.  All other firefighting agencies currently use the product at the same viscosity as long term retardant with a 100% success rate.

Eddie G.: The planes breaking off wings happened 8 years ago and had nothing to do with the chemical on board. Read the Blue Ribbon Panel Report.
Anon Response: After reading the report the loads associated with the payload causes fatigue on some airframes including the plane in question.

Eddie G.: Just because FireIce is mixed the same, uses the same equipment with the same viscosity...does not make it a retardant versus a water enhancer. That's like saying potatoes and watermelons are the same because they both cut with a knife in a kitchen. Retardants and water enhancers are totally different chemicals that do totally different things. FireIce does not function, in any aspect, as a retardant.
Anon Response: The USFS has called gel a “RETARDANT” since 1960

Eddie G.: Finally the mix ratio of the new Phos-Chek products was reduced to reflect its INCREASED effectiveness. It takes less of the new concentrate than the old to achieve the same effectiveness. That REDUCES the cost per gallon.
Anon Response: The standing joke around the USFS, Tanker Base Managers, and pilots is that Phos-Chek is gum thickened water