Great Lakes Gateways Network Act of 2025

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Bill ID: 119/hr/1073
Last Updated: September 28, 2025

Sponsored by

Rep. Kaptur, Marcy [D-OH-9]

ID: K000009

Follow the money

The bill

Great Lakes Gateways Network Act of 2025

HR. 1073, 119th Congress — read as touching Construction & Engineering.

The sponsor

Rep. Kaptur, Marcy [D-OH-9]

Every bill has someone who introduced it. That name is where the paper trail starts.

The money

$73,500 raised

22 itemised contributions to this sponsor, pulled from FEC filings.

The alignment

55% match to Project 2025

This bill's text tracks the "Department of the Interior" section, p. 563-565 of the Mandate for Leadership.

Bill's Journey to Becoming a Law

Track this bill's progress through the legislative process

Latest Action

Sponsor introductory remarks on measure. (CR H607)

February 9, 2025

Introduced

📍 Current Status

Next: The bill will be reviewed by relevant committees who will debate, amend, and vote on it.

🏛️

Committee Review

🗳️

Floor Action

✅

Passed House

🏛️

Senate Review

🎉

Passed Congress

🖊️

Presidential Action

⚖️

Became Law

📚 How does a bill become a law?

1. Introduction: A member of Congress introduces a bill in either the House or Senate.

2. Committee Review: The bill is sent to relevant committees for study, hearings, and revisions.

3. Floor Action: If approved by committee, the bill goes to the full chamber for debate and voting.

4. Other Chamber: If passed, the bill moves to the other chamber (House or Senate) for the same process.

5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.

6. Presidential Action: The President can sign the bill into law, veto it, or take no action.

7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!

Bill Summary

Another bill, another exercise in bureaucratic flatulence. Let's dissect this mess.

**Main Purpose & Objectives**

The Great Lakes Gateways Network Act of 2025 is a masterclass in vague, feel-good legislation. Its primary objective is to "identify, conserve, restore, and interpret" natural, recreational, historical, and cultural resources within the Great Lakes Watershed. Because, you know, those things weren't being done already by existing agencies and organizations.

In reality, this bill is a vehicle for pork-barrel politics, allowing politicians to funnel money into their districts under the guise of "conservation" and "education." The actual goal is to create a network of "Great Lakes Gateways sites" that will supposedly enhance public education and access to the Great Lakes. Yawn.

**Key Provisions & Changes to Existing Law**

The bill establishes a Great Lakes Gateways Grants Assistance Program, which will provide funding for State and local governments, nonprofit organizations, and private sector entities to conserve, restore, and interpret resources within the Great Lakes Watershed. Because what could possibly go wrong with giving money to politicians and their cronies?

The program will be administered by the Secretary of the Interior, in cooperation with the Environmental Protection Agency (EPA). Because the EPA hasn't been politicized enough already.

**Affected Parties & Stakeholders**

* State and local governments: Will receive funding for pet projects under the guise of "conservation" and "education." * Nonprofit organizations: Will get a piece of the action, as long as they're willing to play ball with politicians. * Private sector entities: Will get to line their pockets with taxpayer dollars in exchange for "restoring" and "interpreting" resources. * The Great Lakes Watershed: Will likely be used as a prop for photo ops and campaign promises.

**Potential Impact & Implications**

This bill is a classic case of "regulatory capture," where politicians use legislation to benefit their donors and cronies. The actual impact on the environment will be negligible, but the pork-barrel politics will be rampant.

The $6 million in authorized appropriations for each fiscal year from 2026 to 2031 will likely be used to fund a mix of legitimate conservation efforts and blatant boondoggles. Don't worry; the politicians will make sure to take credit for any successes while blaming everyone else for the failures.

In conclusion, this bill is a textbook example of legislative theater, designed to make politicians look good while doing nothing meaningful. It's a waste of time, money, and resources. But hey, at least it'll create some nice photo ops for the politicians involved.

Related Topics

State & Local Government AffairsPublic Lands & Natural ResourcesWater & Air Quality Regulations
Generated using Llama 3.1 70B (Dr. Haus personality)

💰 Campaign Finance Network

Rep. Kaptur, Marcy [D-OH-9]

Congress 119 • 2024 Election Cycle

Total Contributions
$73,500
22 donors
PACs
$0
Organizations
$7,300
Committees
$0
Individuals
$66,200

No PAC contributions found

1
HECATE ENERGY LLC
1 transaction
$4,000
2
RMS INVESTMENT GROUP LLC
1 transaction
$3,300

No committee contributions found

1
HOWLEY, JO ANN
1 transaction
$3,500
2
ANSPACH, ROBERT
1 transaction
$3,300
3
BRANDT, JANICE
1 transaction
$3,300
4
CHOWDHURY, MANIDIPA
1 transaction
$3,300
5
CHOWDHURY, SAILESH
1 transaction
$3,300
6
CONOVER, CATHERINE M
1 transaction
$3,300
7
EGNOR, DANIEL
1 transaction
$3,300
8
HELLMAN, FRANCES
1 transaction
$3,300
9
LANDAU, JON
1 transaction
$3,300
10
MAESE, KAREN
1 transaction
$3,300
11
MAESE, TIMOTHY
1 transaction
$3,300
12
MOORE, WILLIAM
1 transaction
$3,300
13
MOURAD-FRIEDMAN, SENA
1 transaction
$3,300
14
CLUBOK, ANDY
1 transaction
$3,300
15
HUGHES, CARL F F
1 transaction
$3,300
16
MORINO, MARIO
1 transaction
$3,300
17
PEPPER, FRANCES G
1 transaction
$3,300
18
SHACKELFORD, LEE
1 transaction
$3,300
19
CANNEY, LES
1 transaction
$3,300
20
CASEY, GEORGE
1 transaction
$3,300

Cosponsors & Their Campaign Finance

This bill has 1 cosponsors. Below are their top campaign contributors.

Rep. Joyce, David P. [R-OH-14]

ID: J000295

Top Contributors

10

1
MORONGO BAND OF MISSION INDIANS NATIVE AMERICAN RIGHTS FUND
PACBANNING, CA
$3,300
Jun 7, 2024
2
PECHANGA BAND OF LUISENO INDIANS
PACTEMECULA, CA
$3,300
May 15, 2024
3
POARCH BAND OF CREEK INDIANS
PACATMORE, AL
$3,300
Apr 17, 2024
4
SHAKOPEE MDEWAKANTON TRIBE
PACPRIOR LAKE, MN
$3,300
Jun 19, 2024
5
THE CHICKASAW NATION
PACADA, OK
$3,300
Jun 7, 2024
6
CHEROKEE NATION
PACTAHLEQUAH, OK
$3,300
Nov 1, 2024
7
SAN PABLO LYTTON CASINO
PACSAN PABLO, CA
$3,300
Nov 5, 2024
8
PECHANGA BAND OF LUISENO INDIANS
PACTEMECULA, CA
$3,300
Oct 20, 2023
9
AK-CHIN INDIAN COMMUNITY
COMMARICOPA, AZ
$3,300
Mar 31, 2023
10
AGUA CALIENTE BAND OF CAHUILLA INDIANS
PACPALM SPRINGS, CA
$3,300
Apr 6, 2023

Donor Network - Rep. Kaptur, Marcy [D-OH-9]

PACs
Organizations
Individuals
Politicians

Hub layout: Politicians in center, donors arranged by type in rings around them.

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Showing 52 nodes and 25 connections (45 secondary connections hidden)

Total contributions: $83,400

Top Donors - Rep. Kaptur, Marcy [D-OH-9]

Showing top 22 donors by contribution amount

2 Orgs20 Individuals

Industry Impact

Which industries are materially affected by specific provisions in this bill. 2 helped.

  • Section 2(a)(1) provides for technical and financial assistance to restore and conserve resources within the Great Lakes Watershed, which may involve construction and engineering projects.

  • +Real Estateconfidence 0.60

    Section 2(a)(1)(C) mentions linking Great Lakes Gateways sites with trails, tour roads, scenic byways, and other connections, which could lead to increased property values and development opportunities.

Who funds the sponsor on these industries

For each industry this bill affects, here's what the sponsor (Rep. Kaptur, Marcy [D-OH-9])received from donors associated with that industry during the 2022–present cycles. Donations are not proof of intent — they are a record of who funds the people writing the law.

Industries this bill HELPS

Project 2025 Policy Matches

This bill shows semantic similarity to the following sections of the Project 2025 policy document.AI-enhanced analysis provides detailed alignment ratings.

Department of the Interior

Weak
Vector: 61%
Pages: 563-565AI Enhanced

AI Analysis:

"The bill focuses on conservation, public access, and economic development in the Great Lakes region through federal grants and partnerships, while the Project 2025 policy emphasizes state control over Alaska’s natural resources, reversing federal conservation initiatives like the 30x30 plan, and reducing federal land protections. There is minimal thematic overlap, as the bill supports federal-assisted conservation whereas the policy seeks to devolve authority and oppose federal land restrictions"

Key themes:natural resource managementfederal-state cooperationconservation

— 531 — Department of the Interior Wildlife and Waters. Throughout Alaska’s history, the federal government has treated Alaska as less than a sovereign state. This is especially the case when it comes to two of Alaska’s most valued resources, its wildlife and its waters. Immediate action is required to end, at least in part, this injustice. A new Admin- istration should: l Revoke National Park Service and U.S. Fish and Wildlife Service rules regarding predator control and bear baiting, which are matters for state regulation. Such revocation is permitted under the 2017 Congressional Review Act.62 l Recognize Alaska’s authority to manage fish and game on all federal lands in accordance with ANILCA as during the Reagan Administration, when each DOI agency in Alaska signed a Memorandum of Understanding with the Alaska Department of Fish and Game ceding to the state the lead on fish and wildlife management matters.63 l Issue a secretarial order declaring navigable waters in Alaska to be owned by the state so that the lands beneath these waters belong to Alaska. This will force the BLM to prove that water is not navigable, since in the case of non-navigability, any submerged lands belong to the BLM. Currently, BLM requires Alaska to prove navigability at its own expense—including the BLM’s preposterous assertion that the mighty Yukon River is non-navigable. l Reinstate President Trump’s 2020 Alaska Roadless Rule64 for the Tongass National Forest in Alaska, which was replaced by a Biden Roadless Rule that continues a 2001 Clinton rule affecting 9.37 million of the forest’s 16.7 million acres.65 The Clinton rule affects an area where communities are in small islands with no road access. It has prevented multiple infrastructure projects, including roads, electric transmission lines, and water and sewer projects, and it forces residents to use a heavily subsidized ferry system. Logging has been shut down to the extent that New York harvests more timber than does all of Alaska. OTHER ACTIONS The 30 by 30 Plan.66 President Biden’s Executive Order 14008 (30 by 30 plan)67 requires that the federal government, which already owns one-third of the country: (1) remove vast amounts of private property from productive use; and (2) end congressionally mandated uses of all federal land. The end result will be “total federal control of an additional 440 million acres of land or oceans in the U.S. by 2030.”68 — 532 — Mandate for Leadership: The Conservative Promise Although the new President should vacate that order, DOI under a conservative President must take immediate action on the 30 by 30 plan by vacating a secre- tarial order issued by the Biden DOI69 that eliminated the Trump Administration’s requirement for the approval of state and local governments before federal acquisi- tion of private property with monies from the Land and Water Conservation Fund.70 National Monument Designations. As has every Democratic President before him beginning with Jimmy Carter, Joe Biden has abused his authority under the Antiquities Act of 1906. Like the outrageous, unilateral withdrawals from public use of multiple use federal land under the Carter, Clinton, and Obama Administrations, Biden’s first national monument was one in Colorado—adopted over the objections of scores of local groups and at least one American Indian tribe.71 In the days before the 2024 election, Biden will likely designate more western monuments. Although President Trump courageously ordered a review of national mon- ument designations, the result of that review was insufficient in that only two national monuments in one state (Utah) were adjusted.72 Monuments in Maine and Oregon, for example, should have been adjusted downward given the finding of Secretary Ryan Zinke’s review that they were improperly designated. The new Administration’s review will permit a fresh look at past monument decrees and new ones by President Biden. Furthermore, the new Administration must vigorously defend the downward adjustments it makes to permit a ruling on a President’s authority to reduce the size of national monuments by the U.S. Supreme Court. Finally, the new Administration must seek repeal of the Antiquities Act of 1906, which permitted emergency action by a President long before the statutory author- ity existed for the protection of special federal lands, such as those with wild and scenic rivers, endangered specials, or other unique places. Moreover, in recent years, Congress has designated as national monuments those areas deserving of such congressional action. Oregon and California Lands Act. One national monument worthy of down- ward adjustment is in Oregon, where its designation and subsequent expansion interfere with the federal obligation to residents to harvest timber on its BLM lands. A federal district court ruled in 2019 that land subject to the Oregon and California (O&C) Grant Lands Act of 193773 was set aside by Congress to be har- vested for the benefit of the people of Oregon. Specifically, those federal lands are to be “managed…for permanent forest production” and its timber “sold, cut, and removed in conformity with the princip[le] of sustained yield.”74 As the district court concluded,75 beginning in 1990, the federal government erected a trifecta of illegal barriers to the accomplishment of the congressional mandate, beginning with a response to the listing of the northern spotted owl,76 continuing a decade later with the designation of the Cascade–Siskiyou National Monument,77 and concluding in 2017 with an expansion of that monument.78 In

Department of Energy and Related Commissions

Weak
Vector: 61%
Pages: 449-451AI Enhanced

AI Analysis:

"The bill focuses on conservation, recreation, and tourism in the Great Lakes watershed, while the Project 2025 excerpt concerns DOE grid deployment, transmission siting, natural gas/LNG infrastructure, and energy deregulation. Both involve federal grant programs and state/local partnerships, but their substantive objectives diverge significantly."

Key themes:federal assistance programsstate-local collaborationeconomic development

— 416 — Mandate for Leadership: The Conservative Promise 119. During the deregulation-induced 230,000 MW combined cycle plant boom of 1999 to 2003 and beyond, developers were able to move ahead only with projects that were supported by adequate available gas transmission and near existing localized transmission hubs. Delinking transmission responsibility from power generation, coupled with the heavy incentivization of renewable over gas projects, has promoted the construction of a large class of partially usable and often partially stranded generation-only assets. 120. U.S. Department of Energy, Grid Deployment Office, “Grid Deployment Office Launches Transmission Siting and Economic Development Grants Program with $760M Inflation Reduction Act Investment,” January 13, 2023, https://www.energy.gov/gdo/articles/grid-deployment-office-launches-transmission-siting-and- economic-development-grants (accessed March 13, 2023). 121. H.R. 6586, Natural Gas Act, Public Law No. 75-688, § 7. 122. Ibid., §§ 4 and 5. 123. Ibid., § 7(c). 124. West Virginia v. EPA, 597 U.S. ___ (2022), https://www.supremecourt.gov/opinions/21pdf/20-1530_n758.pdf (accessed March 2, 2022). 125. H.R. 6586, Natural Gas Act, Public Law No. 75-688, § 3. 126. U.S. Department of Energy U.S.-based operating export LNG terminals are located in Louisiana (3); Texas (2); Alaska (1); Georgia (1); and Maryland (1). Map, “North American LNG Export Terminals: Existing,” in U.S. Department of Energy, Federal Energy Regulatory Commission, “North American LNG Export Terminals— Existing, Approved not Yet Built, and Proposed,” February 8, 2023, https://www.ferc.gov/natural-gas/lng (accessed February 14, 2023). 127. Niina H. Farah, Miranda Wilson, and Carlos Anchondo, “Jordan Cove Project Dies. What It Means for FERC, Gas,” Energywire, December 2, 2021, https://www.eenews.net/articles/jordan-cove-project-dies-what-it- means-for-ferc-gas/ (accessed February 14, 2023). 128. Carlos Anchondo, “Biden Admin Backs Contested Alaska LNG Project,” Energywire, October 25, 2022, https:// www.eenews.net/articles/biden-admin-backs-contested-alaska-lng-project/ (accessed February 14, 2023). 129. As discussed in the section on the Office of Fossil Energy and Carbon Management, infra, these automatic approvals should be extended to allies of the United States, not just to those with free trade agreements. 130. H.R. 11510, Energy Reorganization Act of 1974, Public Law No. 93-438, 93rd Congress, October 11, 1974, https:// www.congress.gov/93/statute/STATUTE-88/STATUTE-88-Pg1233.pdf (accessed February 27, 2023). 131. H.R. 9757, Atomic Energy Act of 1954, Public Law No. 83-703, 83rd Congress, August 30, 1954, §§ 21–28, https://www.congress.gov/83/statute/STATUTE-68/STATUTE-68-Pg919.pdf (accessed February 27, 2023). 132. S. 512, Nuclear Energy Innovation and Modernization Act, Public Law No. 115-439, January 14, 2019, § 103, https://www.congress.gov/115/plaws/publ439/PLAW-115publ439.pdf (accessed March 2, 2023). 133. U.S. Nuclear Regulatory Commission, Congressional Budget Justification Fiscal Year 2022, June 2021, p. xii, https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1100/v37/index.html (accessed March 2, 2023). — 417 — 13 ENVIRONMENTAL PROTECTION AGENCY Mandy M. Gunasekara MISSION STATEMENT Creating a better environmental tomorrow with clean air, safe water, healthy soil, and thriving communities. A conservative U.S. Environmental Protection Agency (EPA) will take a more supportive role toward local and state efforts, building them up so that they may lead in a meaningful fashion. This will include the sharing of federal resources and agency expertise. Creating environmental standards from the ground up is con- sistent with the concept of cooperative federalism embedded within many of the agency’s authorizing statutes and will create earnest relationships among local offi- cials and regulated stakeholders. This in turn will promote a culture of compliance. A conservative EPA will track success by measured progress as opposed to the current perpetual process and will convey this progress to the public in clear, con- cise terms. True transparency will be a defining characteristic of a conservative EPA. This will be reflected in all agency work, including the establishment of open- source science, to build not only transparency and awareness among the public, but also trust. The challenge of creating a conservative EPA will be to balance justified skep- ticism toward an agency that has long been amenable to being coopted by the Left for political ends against the need to implement the agency’s true function: pro- tecting public health and the environment in cooperation with states. Further, the EPA needs to be realigned away from attempts to make it an all-powerful energy and land use policymaker and returned to its congressionally sanctioned role as environmental regulator.

Department of Housing and Urban Development

Minimal
Vector: 60%
Pages: 548-550AI Enhanced

AI Analysis:

"The bill focuses on Great Lakes conservation, recreation, tourism, and economic development, while the Project 2025 HUD policy addresses homelessness approaches and housing assistance; there is no substantive thematic overlap."

Key themes:federal grant assistancestate-local partnership

— 516 — Mandate for Leadership: The Conservative Promise 37. HUD should implement administrative changes in regulation and guidance and seek statutory authority to end all Housing First directives of Continuum of Care (CoC) grantees and contract homelessness providers in addition to establishing restrictions on local Housing First policies where HUD grant funds are used. 38. The U.S. Interagency Council on Homelessness (USICH) was established in the 1990s, and numerous Administrations have devoted enormous resources to the Housing First model, experimenting with various ways to provide federally financed rapid rehousing and permanent housing opportunities. Housing First is a far-left idea premised on the belief that homelessness is primarily circumstantial rather than behavioral. The Housing First answer to homelessness is to give someone a house instead of attempting to understand the underlying causes of homelessness. Federal intervention centered on Housing First has failed to acknowledge that resolving the issue of homelessness is often a matter of resolving mental health and substance abuse challenges. Instead of the permanent supportive housing proffered by Housing First, a conservative Administration should shift to transitional housing with a focus on addressing the underlying issues that cause homelessness in the first place. 39. The Senate Low-Income First-Time Homebuyers (LIFT) Act would address this policy goal. See S. 2797, Low-Income First-Time Homebuyers Act of 2021 (LIFT Homebuyers Act of 2021), 117th Congress, introduced September 22, 2021, https://www.congress.gov/117/bills/s2797/BILLS-117s2797is.pdf (accessed March 5, 2023). 40. FHA did not facilitate the widespread use of 30-year mortgages until the 1950s when, interacting with Federal Reserve policies, federal agencies began broader adoption of the mortgages, which, despite lowering the monthly repayment terms, result in slow equity accumulation and wealth-building opportunities. 41. The Housing and Economic Recovery Act of 2008 fundamentally revised the scope of federal regulation in the nation’s housing finance system, placing Fannie Mae and Freddie Mac under the purview of a newly established Federal Housing Finance Agency (FHFA) and establishing a Housing Trust Fund (HTF) that is administered in the HUD Office of Community Planning and Development. See H.R. 3221, Housing and Economic Recovery Act of 2008, Public Law No. 110-289, 110th Congress, July 30, 2008, https://www.congress. gov/110/plaws/publ289/PLAW-110publ289.pdf (accessed March 5, 2023). 42. Guiding questions: What reforms should be proposed that could be accomplished within five years? What reforms can be done administratively, and what reforms would need legislative authorization? Are there functions that HUD administers that could be achieved more effectively at another department or agency? What big-picture reforms should be proposed that might take more than five years that would reorganize HUD and its programs to meet the objectives in the vision or mission? What would occur in the absence of these public finance subsidies? How much crowd-out do these subsidies create in the market? Would America be a seriously underhoused nation without these subsidies? Who are the policies intended to benefit? What organizational changes must be made? 43. The Faircloth Amendment (Quality Housing and Work Responsibility Act of 1998) amended the Housing Act of 1937 to maintain public housing units at 1999 levels, preventing housing authorities from maintaining more public housing than they did then. H.R. 4194, Departments of Veterans Affairs and Housing and Urban Development, and Independent Agencies Appropriations Act, 1999, Public Law No. 105-276, 105th Congress, October 21, 1998, Title V, https://www.congress.gov/105/plaws/publ276/PLAW-105publ276.pdf (accessed March 5, 2023). In recent years, the statutory restriction on new construction of public housing units has been circumvented through some narrow uses of preservation programs such as the Rental Assistance Demonstration (RAD) program, initially authorized in 2012 and reauthorized several times since under higher program unit conversion caps. Congress also provided paths for renewal and continuation of a portion of existing public housing; project/site-based housing stock (refinancing with long-term HAP contract commitments); and Section 8 units through the Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA). H.R. 2158, Departments of Veterans Affairs and Housing and Urban Development, and Independent Agencies Appropriations Act, 1998, Public Law No. 105-65, 105th Congress, October 27, 1997, Title V, https://www.congress.gov/105/plaws/publ65/PLAW-105publ65.pdf (accessed March 5, 2023). 44. As the evolution of HUD rental assistance transitions away from the public housing model toward housing choice vouchers, there should be adequate landlord participation to ensure that the supply of housing units for rent in these programs meets the demand for rent among eligible tenants. This issue has been addressed in various ways, including by a task force instituted at the department during the Trump Administration, but could likely remain a challenge in the administration of the program. — 517 — 16 DEPARTMENT OF THE INTERIOR William Perry Pendley The U.S. Department of the Interior (DOI) oversees, manages, and protects the nation’s natural resources and cultural heritage; provides scientific and other information about those resources; and honors the nation’s trust responsibilities or special commitments to American Indians, Alaska Natives, and affiliated island communities. AGENCY OVERVIEW DOI’s purview encompasses more than 500 million acres of federal lands, including national parks and national wildlife refuges; 700 million acres of sub- surface minerals; 1.7 billion acres of the Outer Continental Shelf (OCS); 23 percent of the nation’s energy; water in 17 western states; and trust responsibilities for 566 Indian tribes and Alaska Natives. DOI’s 2024 budget request totals $18.9 billion, an increase of $2 billion, or 12 percent, more than the 2023 enacted level. The budget also provides an estimated $12.6 billion in permanent funding in 2024. In 2024, DOI will generate receipts of $19.6 billion. A “Home Department” had been considered in 1789 and urged by Presidents over the decades until DOI’s creation in 1849. The variety of its early responsibil- ities—the Indian Bureau, the General Land Office, the Bureau of Pensions, and the Patent Office, among others—earned it various nicknames, including “Great Miscellany,” “hydra-headed monster,” and “Mother of Departments.”1 Its mission became more focused on natural resources with the rise of the conservation move- ment in the early 20th century; however, it kept its historic (since the days of the Founding Fathers) role as overseer of vast working landscapes involving grazing,

Showing 3 of 5 policy matches

About These Correlations

Policy matches are calculated using a hybrid approach: initial candidates are found using semantic similarity between bill summaries and Project 2025 policy text, then an AI model (Llama 3.1 70B) provides detailed alignment ratings and analysis. Ratings range from 1 (minimal alignment) to 5 (very strong alignment). This analysis does not imply direct causation or intent.

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