Yes, I can, absolutely.
I think there's a challenge because the department, so far, has seemed to interpret that addition of cumulative effects into the act to mean consideration of the broader effects on the landscape when it issues an authorization.
The part we're concerned about is the accumulating effects of all of the projects with small footprints that the department allows to happen. It doesn't use the authorization process.
The department works to minimize that harm, but it happens regardless. They're not considering, managing or addressing that accumulation of harm. That's what we're concerned about.