The Swamp School

Hello,

A major proviso of the Phase I is that it is a non-invasive assessment. This means that that soil, water, air or other sampling is not done. This is reserved for the Phase II. Upon completion of the Phase I the reviewer is left with one of two possibilities. Either the site has no known suspected hazardous waste discharges or it does and further investigation is required. Within the limits of the ASTM standard it is either clean or dirty.

Based upon the use of the ASTM standard, the lender can then make a decision about ownership of the land. If it turns out that upon further invasive investigation that the “clean” site turns out to be “dirty”, the lender can plead that they were an “innocent landowner.” This translates into the sites eligibility to be cleaned up using Federal money from the infamous Superfund. The lender would not be liable for this rather sizable expense if it can prove its due diligence.

However, the CWA and NPDES issue we previously discussed, while environmental in nature is not dealt with in the Phase I. As a matter of fact wetlands are one of the issues that are specifically excluded from the ASTM standard largely because you need to take soil samples to establish their presence. This would be considered an invasive out of scope item. To help address this many companies offer wetlands investigation as an add-on service. In addition many third party database vendors offer a review of the National Wetlands Inventory (NWI) as part of their standard Phase I package. This is helpful, but dose give the user a false sense of security. NWI is a great planning tool, but is not suitable for wetland delineation. Consequently, the database vendors usually include an often overlooked disclaimer about the NWI mapping and its accuracy.

To further muddy the waters, a number of database companies are offering a permits review package. The purpose of the review is to identify existing building, construction, and other development permits. Unfortunately, this database is largely incomplete. Many of the wetland and water quality permits are conspicuously missing from these data sets. I recently, ran a test on one of these permit review packages on a known violation site. To my great surprise, the review came back with no known issues. This was a NPDES and CWA violation site that had enforcement and corrective actions on it.

This issue with the data review is that many of the compliance agencies do not have a centralized database of permits and compliance sites. Oftentimes these sites are managed by a local or regional field office. Many times the files are indexed by the then property owner and not updated when the site changes hands. It usually requires a government employee’s individual personal knowledge of the site history to find the case files.

This is not meant at any critique of the way these case files are handled. It usually requires a few well placed phone calls with the right people to track down a site. In my experience the individuals that work with these cases can be quite helpful.

The critique is that the lenders should not assume a Phase I or any database review is going to pick up CWA or NPDES permits and compliance mandates. The data simply does not exist in that form. Consequently, decisions are being made about sites based upon either no data or incomplete data. Both of these circumstances can prove very costly. The compliance mandate for CWA and NPDES is very simple. You own it, you clean it up. You might be able to sue the previous owner. However, if the site is in foreclosure, what is the likelihood that the previous owner has any money to correct the problem?

Next week we will finish this discussion with some strategies for mitigating this concern.

Have a great week!

Hello,

We have put together this three part series on wetlands and lender liability to help you better understand this rather complex issue. In part 1 we will present to you what the issue is and why lenders are being asked to address this.

When a project is contemplated on a particular property there are a number of environmental issues that need to be addressed. Usually an Environmental Assessment (EA) is done that includes documenting the hazardous material concerns and potential natural resources that need to be identified. Wetlands are usually delineated and the developer tires to avoid them to the maximum extent possible.

Impacts to the surrounding environment from sediment runoff are a major concern on any construction site. The state and federal government requires that a developer prepare a plan to eliminate sediment runoff and control stormwater on the site during and after construction. This is usually called a Stormwater Pollution Prevention Plan (SWPPP). This plan requires that the contractor and owner ensure that stormwater pollution is controlled using Best Management Practices (BMPs). These BMPs usually come in the form of devices like silt fences, sedimentation ponds, berms, etc. The SWPPP is usually prepared by a civil engineer and the contractor constructs and maintains them.

All of this runs pretty much like clockwork when the money is flowing. There are a number of loans associated with a development project. These are oftentimes timed based upon achieving certain construction goals. For example, a bank may release funds to construct the soil erosion measures. Once that is complete the next loan amount may cover the road construction. At each phase money flows into the project until it is complete. Unfortunately, the money has dried up.

Imagine that you are in the middle of building a subdivision of $400,000 homes. Sadly, no one can afford to buy your homes and the bank gets nervous about lending you any more money. You cannot afford to rent equipment, pay for supplies and make payroll without the loan. So you leave the project in whatever state it was last in.

Now you did build the BMPs, but they are only temporary and require frequent maintenance. There is nobody around to fix the blow-outs and repair storm damage. All of a sudden sediment is leaving the site and being dumped into wetlands and other waterways. This is where the liability starts.

However, the bank is quite familiar with environmental issues. Especially, hazardous materials identified in a Phase I EA. The procedure is to document that the bank had nothing to do with the hazardous material. After all the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) provides for an “innocent landowner” defense. In short, if the bank has done its proper due diligence, they cannot be held liable for simply owning the property.
Similarly, the Resource Conservation and Recovery Act (RCRA) provides similar landowner protections for underground storage tanks. A background review and site inspection are usually all that need be done to alleviate the bank form the environmental liability.

These “innocent landowner” protections are not present in the Clean Water Act (CWA) or the stormwater program of the National Pollutant Discharge Elimination System (NPDES). Both of these laws are administrated by the Environmental Protection Agency (EPA) and the state. EPA has made it quite clear that they look to the foreclosing lender as the owner or operator of the construction site. As such they must comply with the SWPPP and are held liable for the plan compliance.

More next week.

Banks are facing unprecedented pressures to foreclose on non-performing loans and to seize title to the underlying real estate. This activity is in commercial loans as well as residential. Often, the bank did its due diligence prior to the loan and may even have a Phase I or Phase II Environmental Site Assessment (“ESA”) in the file. So, why not just brush that off and review it again prior to foreclosure?

There are a number of reasons why a lender needs to do additional environmental due diligence before a foreclosure. Ideally a lender’s pre-foreclosure policy would be in place that has an environmental component. The first reason for performing a new Phase I is because Phase I ESA’s do not have an unlimited shelf life, and rightfully so. Conditions and uses change. The lender needs to move forward with the latest information available. There are situations where the environmental liability might exceed the loan amount. If the borrower was unable to make the mortgage payments, the conventional wisdom is that it is highly unlikely that appropriate funds were directed to environmental compliance, mandatory record keeping or monitoring, or even to appropriate responses to regulatory enforcement.

There are numerous examples of post-foreclosure remorse due to environmental surprises. In Florida, they sometimes involve wetlands. When a lender takes title to real estate in Florida, the lender becomes responsible for wetland compliance. If, for instance, a stormwater system fails, or an erosion control plan is needed, the property owner has liability for non-compliance. One lender took title to a development that was incomplete and the land was essentially cleared and abandoned. A creek ran through the property. The site experienced severe and recurring washouts. Initial efforts at soil stabilization undertaken by the lender were unsuccessful. After several efforts, the scope of the stabilization project was expanded and the site was finally stabilized. The bank’s investment in the land had significantly increased.

In another recent Florida case, the developer had done some unauthorized dredging as part of the land clearing of a residential subdivision. That developer went out of business and another company acquired the property and borrowed development money secured by the land. The bank did its standard due diligence, a Phase I ESA. That borrower subsequently defaulted and the bank foreclosed on the cleared property. The first developer had paid penalties to the Water Management District for its unauthorized dredging. The second developer had executed a Consent Order with the South Florida Water Management District. The bank’s pre-foreclosure due diligence did not pick up on any of that because the standard ASTM Phase I ESA does not include an agency records search–an inexpensive option–which should usually be considered in pre-foreclosure or any time a partially developed property is involved. The lender, who became the owner, ultimately had to enter into a second Consent Order, pay for mitigation credits, secure two development permits, and undertake a partial restoration of the destroyed wetlands. The realization that these costs were unavoidable came at a time the land value plummeted due to the economy. The only good news is the bank will own a fully entitled project which should be significantly more desirable than properties that have no permits regarding on-site wetlands.

A pre-foreclosure file review might alert the lender to other issues such as stormwater, wildlife, dredging or enforcement issues. Asbestos should be considered for older buildings. There may be zoning or comprehensive plan issues. Construction permits may have clocks that are ticking that will need to be addressed right away. Waste disposal and the storage of hazardous materials can be an issue. Pre-foreclosure due diligence needs to be customized to the specific property and circumstances.

I was recently speaking with a group of recent college graduates about wetlands. I talking about organic soils and was assuming that we were discussing the same topic. To my dismay, they thought that organic soils were something you grew organic tomatoes in. I suppose this is possible but unlikely. Consequently, I thought it might be with expanding on this topic.

For the purposes of understanding wetlands there are two major divisions of soil types. This first as you might suspect is organic. The second is mineral. These are subdivided further in the new Corps Regional Supplements.

In a post a few months ago, I discussed the three Corps soil indicator types. They include All soils (Type A), Sandy soils (Type S) and Loamy soils (Type F). We all know what loamy soils are called type F. Iron of course .

The A soils include all of the organic soils as well as the mucky mineral soils. The F and S types include the mineral soils.

So what is an organic soil? In short it is composed of almost entirely organic matter. What is organic matter? It includes decomposing and partially decomposing carbon based material. This includes leaves, twigs, grass, squirrels, ducks and you. Well, hopefully not you, not yet.

What makes organic soils so important to wetland identification is the extent of decomposition. The less the organic matter is rotting the more likely that the area is a wetland. Why you may ask? It is quite simple. The bacteria and other decomposers need oxygen to function. Water being an EPA listed asphyxiant, will impede the decomposers ability to break the organic matter down. As a result, you have very deep layers of what is commonly called peat. If the thickness is greater than 16 inches it is called an organic soil. Organic soils are almost always hydric. There is one major exception to this. Tundra soils tend to be thick organic layers. They do not decompose due to water, but rather due to being frozen.

If the organic layer is greater than 8 inches thick, but less than 16 inches thick it is called a histic epipedon. This is also indicative of hydric soils.

One soil organicy type tend to be a bit of a problem. The mucks may or may not be hydric. A muck is a heavily organic soil with lots of mineral material in it. Strictly speaking these are not organic soils. They can be hydric and often are. However, mucks in floodplains tend not to be. These areas are too well aerated.

Now our mineral soils are all over the place with regards to wetland identification. But that is a subject for another day.

We have another isolated wetlands court case to discuss. In early July of this year the South Carolina State Supreme Court ruled in favor that the S.C. Department of Health and Environmental Control has jurisdiction over isolated wetlands, a reversal of the Georgetown County Circuit Court’s ruling and previous operating procedure.

The Post and Courier – July 16, 2011 – Gina Vasselli

The suit was filed over a 0.332-acre lot on Pawleys Island, 0.19 acres of which is an isolated wetland, meaning it does not have a direct connection to other waters or wetlands.

That wetland area was filled in by the Smith Land Co. The work was done after the company notified the Army Corps of Engineers and the DHEC of its plans.

Such wetlands were previously ruled outside of DHEC’s control, said Smith Land attorney David DuRant.

“Historically speaking, South Carolina DHEC has not taken the position that they have been given that authority by the [South Carolina] House and Senate,” said DuRant.

Those wetlands had been ruled isolated by the Army Corps, meaning no Federal Clean Water Act permit was required. But the Supreme Court said while a previous case “holds that the Corps may not regulate isolated wetlands, [that case] … has no impact on DHEC’s ability, as a state agency, to do so.”

Armstrong said the case established “protections for isolated wetlands throughout the state, and mandating that a state permit be obtained prior to filling any of our state’s unique and essential wetland resources.”

Now, according to the court’s ruling, before any isolated wetland area is filled in a permit must be obtained through S.C. DHEC, which is given the authority to issue such permits under the state’s Pollution Control Act.

Armstrong said the decision will have a larger impact on the areas outside the state’s eight coastal counties, which already have protection under stormwater regulations.

“It adds another layer of protection” in those coastal counties, Armstrong said, but “the implications are going to have much greater impact outside that area.

The Supreme Court also ruled that the act has a “private right of action,” meaning a private person or group has the ability to bring a lawsuit if they observe violations of that law. The circuit court had previously ruled that the Georgetown County League of Women Voters had no standing to bring the suit.

There are several interesting issues that come from this case. The main issue is that SC DHEC can regulate isolated wetlands. This includes wetlands that would not be considered jurisdictional by the US Army Corps of Engineers or the Environmental Protection Agency. On a national level this is not precedent setting. But it is a new thing for the Southeast. The New England states have been doing something similar for years. But in the South if the Corps did not deem it jurisdictional the wetland generally went unregulated. This opens the door for many state 401 or even 301 programs to include wetlands.

The second major issue is that this case was not brought to the courts by the state. Rather it was the League of Women’s Voters that filed the case. Again, this is not a national precedent, but it is a new enforcement action taken on by a southern private group.

One of the major criticisms of the Clean Water Act is the lack of effective enforcement by the regulatory agencies empowered with the task. It is not that they are lacking in intellect or desire but rather simple issue of too few staff and too many cases.

This gets back to the issue of privatization of the wetland delineators. The federal agencies do not have sufficient resources to manage the litany of cases for permitting, jurisdictional determinations, enforcement, etc. A certified and qualified program would greatly help with this. To that end please consider signing our petition to the Corps for the RE-establishment of the certified wetland delineator program. More can be found ==> HERE.

Thanks and have a great week!

The new Regional supplements to the 1987 Wetland Delineation Manual are slowly being finalized. The next one to become final is the North Central/ North Eastern Regional Supplement. This one covers northeastern PA up into New England. It is slated for final release sometime in August of this year.

One of the biggest fears/complaints of these supplements is the inclusion of the Field Indicators of Hydric Soil. This was originally published by NRCS in 1998 and was pretty much ignored by most of the folks in the wetlands delineation business. It is not that it is a bad document. Rather, it is just that is very hard to use. It assumes a fairly advanced understanding of soil taxonomy and formation.

The Corps has included this manual into all of the Regional Supplements. They have modified many of the indicators and in some cases added new ones. This is mostly done to reflect regional variations of the local soil types. Quite frankly, it is pretty good.

Many in the consulting and regulatory sides of the wetlands business have fought the use of this soil procedure tooth and nail. Citing that it will add a significant amount of time to the assessment (it does) and that only highly qualified individuals can use it (perhaps). In any case it appears to be here to stay.

To help you warm up to this part of the supplement I would like to offer you few observations. First, all of the indicators are to one degree or another and analysis of how the following react to an anaerobic environment:

a.  Iron and Manganese
b.  Sulfur
c.  Carbon

Iron turns gray when reduced. Manganese turns black. Roots that are in a hydric soil turn red (aka oxidized rhizospheres). Sulfur in a hydric soil stinks (rotten eggs). Lots and lots of carbon (organic matter) in a soil is there because there is too much water for the bacteria to break down the carbon. Consequently, high organic material soils tend to be hydric.

That is about it. Easy!  Now all you have to do is figure out which indicators matches what you are seeing.

Well there is a bit more, but you will have to take one of our classes to find out.

Have a great week and stay cool!

Hello,

A major proviso of the Phase I is that it is a non-invasive assessment. This means that that soil, water, air or other sampling is not done. This is reserved for the Phase II. Upon completion of the Phase I the reviewer is left with one of two possibilities. Either the site has no known suspected hazardous waste discharges or it does and further investigation is required. Within the limits of the ASTM standard it is either clean or dirty.

Based upon the use of the ASTM standard, the lender can then make a decision about ownership of the land. If it turns out that upon further invasive investigation that the “clean” site turns out to be “dirty”, the lender can plead that they were an “innocent landowner.” This translates into the sites eligibility to be cleaned up using Federal money from the infamous Superfund. The lender would not be liable for this rather sizable expense if it can prove its due diligence.

However, the CWA and NPDES issue we previously discussed, while environmental in nature is not dealt with in the Phase I. As a matter of fact wetlands are one of the issues that are specifically excluded from the ASTM standard largely because you need to take soil samples to establish their presence. This would be considered an invasive out of scope item. To help address this many companies offer wetlands investigation as an add-on service. In addition many third party database vendors offer a review of the National Wetlands Inventory (NWI) as part of their standard Phase I package. This is helpful, but dose give the user a false sense of security. NWI is a great planning tool, but is not suitable for wetland delineation. Consequently, the database vendors usually include an often overlooked disclaimer about the NWI mapping and its accuracy.

To further muddy the waters, a number of database companies are offering a permits review package. The purpose of the review is to identify existing building, construction, and other development permits. Unfortunately, this database is largely incomplete. Many of the wetland and water quality permits are conspicuously missing from these data sets. I recently, ran a test on one of these permit review packages on a known violation site. To my great surprise, the review came back with no known issues. This was a NPDES and CWA violation site that had enforcement and corrective actions on it.

This issue with the data review is that many of the compliance agencies do not have a centralized database of permits and compliance sites. Oftentimes these sites are managed by a local or regional field office. Many times the files are indexed by the then property owner and not updated when the site changes hands. It usually requires a government employee’s individual personal knowledge of the site history to find the case files.

This is not meant at any critique of the way these case files are handled. It usually requires a few well placed phone calls with the right people to track down a site. In my experience the individuals that work with these cases can be quite helpful.

The critique is that the lenders should not assume a Phase I or any database review is going to pick up CWA or NPDES permits and compliance mandates. The data simply does not exist in that form. Consequently, decisions are being made about sites based upon either no data or incomplete data. Both of these circumstances can prove very costly. The compliance mandate for CWA and NPDES is very simple. You own it, you clean it up. You might be able to sue the previous owner. However, if the site is in foreclosure, what is the likelihood that the previous owner has any money to correct the problem?

Next week we will finish this discussion with some strategies for mitigating this concern.

Have a great week!

Hello,

I just returned back from a 10 day stay in northern New Jersey. I wanted to relay to you a few observations of my adventure. As you may recall, Hurricane Irene paid us a visit. here in North Carolina most of the devastation was limited to the coastal areas. The damage was significant but it is something most of the folks in NC are experienced with. It is not that they are used to it. I do not know how one would get used to losing a home. However, they were prepared and are now working to get their lives back together.

New Jersey is looking at a something a bit different. The coastal areas were more or less spared. I have relatives in the coastal town of Belmar, that really did not see much damage. My in-laws in Blairstown which is close to 100-miles to the west of the shore have been without power for over a week. They did not see much hurricane damage, they had rain. Lots and lots of rain. In fact it has been raining most of the summer.

The damage to north Jersey is significant. The photo below (courtesy of the Star Ledger) is Interstate 287 in Boonton. The Rockaway river has washed away the north bound lanes. This backed up traffic for miles and days. At one point porta potties were set up along the highway and gas was being sold along the roadway. It was a mess.

In Denville, the entire down-town went under water. US Route 46 was impassible as the mighty Rockaway flooded the town. I saw large dumpsters floating down the river.

More recently, the town of Lincoln Park was flooded by the Passaic. Actually most of north Jersey was flooded by the Passaic. In Little Falls, NJ the flood stage of the Passaic is around 7 feet. It crested at over 14 feet. As of the date of the article the river has still not receded below flood stage.

As the cleanup begins there are many issues facing folks in these soaked areas. Foremost in many people’s minds is the issue of property loss. Thankfully, loss of life was minimal but tragic none the less. I believe 45 people lost their lives to the storm. This is far less than what happened in Katrina but the loss is still very sad. We knew the storm was coming and in New Jersey the Governor urged (rather colorfully) to seek higher ground.

I am focusing on New Jersey because it is a very good example of the problems we are faced with in urban watershed management. The storms and rainfall are unusually high this year and last year. Property loss is well into the millions if not billions. Communities have been destroyed. Life has changed.

In the following weeks we will be presenting a series on urban watershed management. There are many issues and controversy over how to best address the problem. We will use some of the towns in New Jersey as an extreme example of what worked and what did not. We will suggest ways in which some of the damage can be mitigated and avoided in future events. Perhaps this was an isolated event, but weeks later the rivers are still cresting and its going to rain again on Thursday. Stayed tuned.

I guess I just keep looking for trouble. The new Chesapeake Bay Total Maximum Daily Load (TMDL) limits went into effect late last year. It basically establishes a “safe” pollution diet that the Bay can tolerate. The problem is that this comes at a time when no one perceives that they can afford the new standard.

In the Chesapeake watershed the developers have absorbed most of the historic blame for the state the Bay is now in. To compensate for the development, developers have been tasked with implementing the Best Management Practice (BMP) trend of the day. Some were good. Some, not so much. But all were very expensive. In the end, the Bay is in worse shape than ever.

Well we need to blame someone. Let’s go after the farmers. After all they have not been brought into this and I saw PBS’s “Poisoned Waters” a couple of years ago. Lots of runoff from chicken houses is running into the Bay. They must be the problem.

OK, I bought into this too. It seems logical and I suspect it is occurring. However, I recently read a local newspaper article about this issue that was an eye opener. At issue was the cost of the Bay restoration and who was going to pay for it. The quote that woke me up was that it was not who was causing the problem, but rather who can afford to clean it up. The thought was that the developers are bankrupt and the farmers have money. Let’s get the farmers!

For the past 20 years “Save the Bay” has been a catch phrase. Heck, it’s even on the license plates. The problem is that we have become desensitized to the issue. Case in point. This week’s newsletter was supposed to be about the North East flooding. Bet you thought I forgot. But, no one seems to care about the flooding anymore. It’s old news. That is until it rains again and the folks in Little Falls are floating again.

It seems to me that the Bay issue is well beyond the farmers and developers. It is beyond the waste water treatment plants. It is even beyond the “save the bay” storm drains and license plates. It is a classic case of economic enterprise overtaking environmental stewardship and vice versa. The Bay is a massive ecosystem with numerous subsystems. Each system is unique and requires local stewardship. It is not a matter of establishing a LD-50 for the Bay in the form of TMDL’s. It is a matter of local individuals looking at how the Bay helps and hurts their ability to exercise their right to pursue happiness in the form of economic prosperity. If the Bay is destroyed many non-Bay related enterprises will suffer. If we pass universal rules that result in severe economic hardship on the Bay community, they Bay will suffer again. This is because no one will be able to work in or near it.

Now this may sound like we need to have a meeting to come to consensus to reach our paradigm shift. Shoot me now. No, what we need is for the individual to come to grips with how their individual behavior may be effecting the Bay. Some individuals will have greater influence. Some may be small. But all will affect a change. In short, the individual needs to identify how Bay restoration satisfies a selfish (I mean this in a good way) need that will result in economic prosperity to said same individual. Saving the Bay will make me money, happy, etc. Government largess has yet to work to save the bay.

This may seem a bit off topic, but I wanted to bring to your attention an issue with wetland equipment. This may in fact be a rant. Never the less I hope you will enjoy.

I am often asked about various types of equipment needed to conduct wetland delineations. There are various types of augers, Munsell charts, data forms, etc. out there. Which one is the best is an issue mostly of personal preference. I am quite fond of the Eljikamp soil augers. Although they are no fun in the glacial till of the northeast. There, a tube sampler is your best bet.

Various types of field attire is also a topic of discussion. Rarely if ever will you need chest waders to do wetlands delineation. Heads up. You are in the wetland if you need these. There are various types of footwear, pants, shirts, etc. that make you more comfortable in the field.

As a matter of personal preference, I like Dickies brand work pants. The twill is almost bulletproof and it is somewhat water resistant. Carhartt used to make some nice duck cloth pants, but lately they are starting to become fashionable and thinner.

Now this is really not a fashion article. When I go into the field I look like a cross between Rambo and Old McDonald. So I hardly have a leg to stand on. However there is a new development in the work clothes market that gives me great concern.

Have anyone tried to by work clothes lately? Can you find any?

I went to Wal-Mart, Sears, JC Penny, Target, Agri-Supply, Tractor Supply, and various Army-Navy stores trying to find work clothes. Nobody has work clothes. I found lots and lots of Dockers, girly jeans (sorry ladies – I do not know what else to call them), and lots of pretty clothes that would fall apart on the first wetland job. But I could not find any work clothes.

Where are all the work clothes? Doesn’t anybody do any work? I mean get your hands dirty work. I believe this is what we now call skilled and unskilled labor. I checked with my friends in the farm business and all of their workers have clothes they brought up from Mexico. They cannot find any decent work clothes here in the US so they import from home.

This must mean something. Has everyone gone to college and nobody does any real work in the US. Apparently, the garment industry thinks so. If there was a market for work clothes I am sure the stores would have them. I did find a couple of Dickies pants in the back of a Sears in a corner of the store in a discount rack. They were all size 28. I am not a size 28.

Back in August, CBS News did a story on the skilled labor shortage. At issue is the fact that the average age of skilled workers is almost double the age of the recent college graduates. The recent college graduate is also unemployed. Meanwhile the skilled labor market has more jobs than laborers and the current workforce is getting older. There are less and less workers entering the skilled trades and none of them are buying work clothes!

Wetland delineation sort of straddles the line between the college graduate and the skilled trades. It is sort of like being a surveyor. A college diploma really does help, but the vocational training is at the heart of the trade. So, take one of our classes, buy some work clothes and get to work.