Category Archives: environment

Winter Is Over If You Want It

It looks like the winter of 2012/13 is finally winding down. My yardstick that “you don”t get too wound up about spring until after Easter” is up against the earliest Easter in quite some time. So while we might get a dose of snow again, it won’t be much and it won”t stay long.

As I get older I can see the beauty in living in a place with a more moderate climate. Less extremes. Better temps. Less mosquitos. Less poison-ivy. But then we get a beautiful New England spring day and I forget all that. Yeah, I would love to give Maui a shot for a year or two. I have the feeling that it would not, as some suspect, “get boring”. It could also be a win/win from a physical perspective. Either I would skip winter weight gain all together, or I would just bulk up and tan up and melt in with the local populace. Mahalo, Bra!

But until that opportunity presents itself I will be content with the weird life of a Yankee, sitting on a beach blanket in jeans and a hoodie drinking hot coffee to stay warm. Nobody goes to the beach in the summer, it’s too crowded! Yogi knew it. You should too.

[If you are ok with Flash-heavy websites, I heartily recommend WeatherSpark for weather graphics and such. Killer website, very good presentation of information. Tufte would approve…. though an iPhone version would be nice]

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How to Muddy The Water on Fine Particulate Matter

One of the results of a career choice is that you meet other people in the same field and are in the habit of sharing information and comparing notes. This is true for me in the field of environmental protection, and it occasionally crosses over into my blogging habit. This is one of those times. This is my own opinion, on my own time, and has no bearing on the opinions of my employer or of my work on any related issues. It is a one-shot screed with one document as the focus.

A friend sent me a link to a recent issue of the Texas Commission on Environmental Quality‘s (TCEQ) informational publication Natural Outlook. It contains a piece on the subject of air quality standards for fine particulate matter (PM2.5 – particulates below 2.5 microns in diameter) and an argument against a more strict public health standard. This is in response to the EPA’s propsed lowering of the annual National Ambient Air Quality Standard (NAAQS) for PM2.5, and the document refers to the TCEQ’s public comment submission on this process, though it does not provide a link to those comments. It also give no details on how the annual standard is calculated or interpreted, and the relationship between that and the short-term or hourly standard. These are not minutiae, but the specific framework of the particulate matter health standard discussion.

On the face of it I have no problem at all with disagreement on public health standards. As a professional in the field I know that there is a need for disagreement, discussion, and a tolerance for diverse viewpoints. I also believe that a well informed populace is the best kind of populace, and that they can make better decisions, better process information, and make better personal decisions regarding public policy. Some of those personal decisions might take place in a voting booth, for instance.

That is where I began to have some concerns about the document in question. I believe it is chock full of misleading information and I believe it serves to confuse the reader about the public policy process and the science behind it. It also seems to cherry-pick over where to provide a technical discussion, and where to treat the reader a a pure layman.

The first paragraph is a basic description of the pollutant. No problem there. The article even includes an info-graphic depicting particle size relative to a standard-issue human hair. Enjoy it, because it is the only graphic you get. We then get a description of the change in the air quality standard: 15 ug/m3 to 12 ug/m3. OK, not much to freak out about yet, except the lack of context for an annual standard versus a 24-hour short-term “event” standard.

From here on out things get weird. TCEQ participated in the public comment period? OK, how? Where is the text of the comment? After that we find out that “many” studies have taken place… involving “large” groups of people… again, no references, citations, or details. This is equivalent to “some say”, a strawman alert if there ever was one. Then we find out that particulate matter is naturally occurring, which is true. And that it can be composed of many types of material, and be generated from many processes, which is also true. But pollen and spores are given as examples of naturally occurring PM2.5, which is not true.  Pollen and spores are larger than 2.5 microns, and in only a few cases are they smaller than 10 microns, so they fall almost entirely out of the regulated particulate matter discussion of PM10 (less than 10 microns) or PM2.5 (less than 2.5 microns). We also find out that PM2.5 is not regulated by composition, which is also true… But then then the penny drops when we find out that Texas thinks the problem might be regional. “The health effects that have been linked to PM2.5 exposure in human studies also vary by region. Multiple studies report potentially increased levels of disease possibly linked to PM2.5 in the eastern United States, but the evidence is inconclusive for the central and western portions of the U.S.“. Rough translation: “Yankee Problem”.

One reason for the enhanced focus on the “eastern United States” may be that states in the northeast US found out very early in the PM2.5 monitoring process that they are heavily impacted by airborne PM2.5 transported from large combustion sources in the mid-west. The upshot is that regulating sources within a state’s borders may be, and has been, insufficient to meet the ambient air quality standard. In an effort to better define the sources of particulate matter, Northeastern states have conducted studies where particulate matter is collected and analyzed to determine the type and content of the actual particles. These states operated a monitoring network targeting the quantity and the composition of particulate matter, and did back-trajectory analysis to attempt to identify potential sources. They found out that you can tell a lot about the source of the particles by analyzing their composition. Another point that the TCEQ presentation misses is that there is over a decade of research into PM in many areas of the US, not just the eastern US. Since no specific studies are cited we can’t know how deeply they have investigated the issue. What we can conclude is that instead of deciding that a speciated (composition analysis) PM study might be useful in their region, they seem to be indicating that the problem itself is regional, not the response to the problem.

Then we are treated to a very odd health effects discussion, where the “London Smog” incident of 1952 is the sole example cited, despite the fact that there are many more current examples of PM-spikes, many in the US, and the London example predates any form of scientific PM measurement. The fact that it excludes any of the studies conducted in the US over the past 20 years, including the studies that made the primary case for PM-related health effects in North America, and form the basis for the original PM2.5 standard, is either perplexing or predictable.

There are a plethora of  studies that have shown a relationship between elevated fine particulate concentrations and increased hospital admissions and increased mortality in sensitive groups like people with pulmonary and respiratory problems. This kind of study has been repeated worldwide, both in active studies and in analysis of historical data. [In the news this very day, we could discuss the potential of China becoming little more transparent with its health data, and whether we would see a spike in admissions and mortality associated with their current particulate pollutions crisis]

This is followed by a very balky discussion of dose-response. We are taken back to Paracelsus… and the 14th century, and an example involving aspirin. Then we are told that PM levels are declining, since the year 2000, with no mention of the fact that “since 2000” corresponds to the implementation of the original EPA PM2.5 standards and the resulting requirement for PM2.5 controls. They just declined. That’s all.

The kicker is the introduction of our good friend Epidemiology! Yes, the “science” that couldn’t prove health impacts from either tobacco or asbestos [that required lawyers, with access to internal communications at places like J.R. Reynolds and Johns-Manville, with admissions that they knew of the health effects and were making business decisions based on them] is here to take the fall for lack of evidence on PM-related health effects.

At this point the damage is done. The reader has been set up for failure, having neither the information or the tools to dissect the final broadside against another crop of unnamed, unreferenced health effects studies that don’t measure up to the situational standards of the TCEQ.

I know that I am riding a fine line, and that it sounds like I am just out to blast some good-intentioned tech writer at TCEQ. I am not.What I am against is pamphleteering in the name of public health policy. I believe that someone intended this document to be informative, and that someone else had a lower bar for “informative”. There is an argument to be made against constantly tightening air quality standards in the absence of health effects evidence. That argument is made on the basis of sound science, and the arguer might have to get their hands dirty with actual research, or funding of actual research. At the very least they would prepare a peer-reviewable analysis of the current science and be available to defend their conclusions. What we have here is what I personally believe to be a good example of bad public communication. The reader has no chance to adequately understand the framework of the discussion, the details of the discussion, or the science behind the discussion.

On Fracking…

Over at Reason and Politics, there was a really nice post about the use of shale gas as a short-term solution to reducing GHG emissions.  You can see the really nice post for my initial comment.  As we are finding out in Connecticut, there is a concerted national effort to get shale gas (the kind of gas you get from hydaulic fracturing, or fracking, the Marcellus Shale, a rock formation that stretches from upstate New York to West Virginia) on tap as a way to displace, for instance, fuel oil for space heating and light industrial/commercial needs.  This approach does have the potential to reduce GHG emissions and other pollutants on a BTU basis.  It will also generate jobs, though they are likely to be gone in 10-15 years once the gas distribution expansion is finished.  Its success also depends on the long-term costs and availability of natural gas regardless of its source.  All said, it can be seen as a placeholder/transition program until renewable energy technology can step in.  And before we go too far down that road, I prefer to immediately cease all subsidies to the fossil fuel industry and move them directly to renewable energy R&D and manufacturing.  That said, and regardless of its merit, I don’t have a billion dollars worth of government subsidy money that I can now use to hire lobbyists to ensure I get billions more in government subsidies… alas… the subsidy merry-go-round is not meant for chumps like me.  If only I had a lobbyist…. oh, yeah, right, congress…

So here, friends, is an open comment to R&P, instead of just posting another comment on their blog:

First, I really enjoy your blog.  It is as advertised, and you do a great job of bringing reason to political discussion.  Second, the risks of fracking are what they are… drilling through aquifers to get to to deep shale gas is always going to create a potential for contamination of the aquifer.  There are parallels to the mechanics of the Deepwater Horizon disaster, but the potential disaster in a fracking scenario could make that look like a walk in the park.  The risks are made worse by the failings of the US legal and regulatory systems.  There is simply too much palm greasing going on (see the subsidy merry-g0-round above) to effectively address things like safety and legal responsibility.  The US EPA has done things like requiring/allowing MTBE as a gasoline additive, which had the predictable side-effect of massively increasing the area impacted by a leaking fuel tank, and making the spill much harder to remediate (has a lot to do with MTBE having a high solubility in water), and allowing much higher public exposure to the pollutants the EPA is supposed to regulate.  And when I say predictable, I mean Chem101 predictable, not Nobel Prize predictable.  So I think it is fair to say that in the big picture we can’t rely on US EPA for anything, and I deal with their programs every day as part of my job.  I think the problem with energy and environmental policy in the US, if not the world, is that to get the job done right you have to be really effective at integrated long-range planning, and have effective regulations, and effective enforcement, and effective interface with economic policies.  And as if it weren’t hard enough, those things simply will not happen when you are having a multi-decade political slap fight… as we are finding out in the good old U S of A.  A common sense approach would use sound science, and lead to a pricing method that didn’t give the fossil fuel, nuclear, automotive, etc… industries a free ride on their social costs, not to mention the massive subsidies that these companies receive on the front end.

In short, we are screwed until we get adults in the room, and I don’t see that happening any time soon.

Fish, Barrel, Shotgun…

Shooting fish in a barrel.  Aside from getting very wet, it is the definition of something so foolproof as to be unsporting.  Which is why making sense of Mitt Romney is like shooting fish in a barrel.  I’m not saying Mitt makes sense, but I am saying that Mitt’s actions are both easily recognized and predictable.

Mitt Romney will say absolutely anything, regardless of any previous position he has verbalized, policy he has championed, or social group he hath shat upon.  He is simply the flippiest, floppiest, most vote grubbing, jellyfish of a candidate I have ever witnessed.

I was reading a piece about his environmental record as Governor of Massachusetts, which I can corroborate because I was working in Climate and Energy policy in Connecticut at that exact time.  If you don’t want to deal with the NYT’s latest annoying article limits, I’ll give you the skinny:

  • He was for “cap and trade” before he was against it
  • He was for green vehicles before he decided they were a bad choice
  • He was against heavily polluting energy until he was paid to realize how great it is!

The article uses the cutesy term “Potomac Fever” to describe his shift to positions that would get him in the door with the RNC.  But I would contest that he had “Charles Fever” before that, telling Massachusetts voters whatever they wanted to hear in order to secure their vote, then playing Lucy to their Charlie Brown when he got into office.

I wouldn’t be surprised if this was one of his tools in the world of Bain Capital.  In fact, I would say that:

“I think he just didn’t get comfortable [with the Regional Greenhouse Gas Initiative] at the very end, but he didn’t want to stop a creative activity,” Mr. Kriss said. “It was like that at Bain Capital. He would let some partner pursue some deal, and at the end he would say, ‘I know you worked on this for six months, but we’re not going to do it.’ ” – Bain Capital Co-Founder Eric Kriss

…tells me a few things.  Aside from being manipulative and inconsistent, he may very well have used this same technique in his private equity dealings.  You could take Kriss at his word about “comfortable” but the way these things often work is that you commit to one deal as a show of good will/intent to bolster a bigger deal, and then pull the plug on the “bait” deal when you have what you want out of the Big Fish.  So IMO, that could very well be a description of another bait-switch scenario, just like showing some environmental regulation support to Massachusetts voters with an initial commitment to reducing greenhouse gas, but pulling the plug before it comes to fruition.  The Big Fish was securing an election, the bait was faux-support for RGGI, and he didn’t have to be in any hurry to pull the plug because it wasn’t his money at risk… just like Bain!

So when I hear Romney telling the press in Colorado that he could see keeping DACA (executive order in lieu of DREAM Act) in place while he gets a “comprehensive immigration reform package” passed, I hear it through that lens.  I even hear his 47% tirade through that lens.  As in: tell these $50,000/plate bastards that you see the poor sucking at their ample teat… don’t give them an opening to doubt that you consider their money untouchable.

Of course, it is completely probable that Romney has no fucking idea what he is talking about… On that, I would push the whole stack of chips to the center of the table.

Late Additions, but good reads:

Romney Manages to Silence RNC!

Bull meets China Shop

At least the guy knows how to start a conversation….

Mitt “Mittens” Romney, that is.  I know, the statement made to those $50,000/plate donors last May is being dissected like it was the long lost second Zapruder film.  And rightly so.  I tried to find some kind of thread of sanity to Mitt’s little rampage on half the Nation as teat-sucking layabouts.  Really, I did.

Fot those of you under a rock, or in China, where this news may not have sufficiently penetrated your child-protection filter:

“There are 47 percent of the people who will vote for the president no matter what. All right, there are 47 percent who are with him, who are dependent upon government, who believe that they are victims, who believe that government has a responsibility to care for them, who believe that they are entitled to health care, to food, to housing, to you-name-it. That that’s an entitlement. And the government should give it to them. And they will vote for this president no matter what…

“Our message of low taxes doesn’t connect…so my job is is not to worry about those people. I’ll never convince them that they should take personal responsibility and care for their lives. What I have to do is convince the five to 10 percent in the center that are independents, that are thoughtful….”

And yes, it turns out that those freeloading Social Security recipients, active duty soldiers, working poor, low income families with children… all those freeloading yobbos who spend every last fucking red cent on food, clothing, housing and transportation and maybe have enough to spend something on education, but certainly aren’t stashing wads of Benjamins in their mattress… THEY are the problem.  Got that?

If you see one of the myriad copies of the fundraiser video, notice how vociferously the pillars of finance and industry shout down poor uninformed Mittens the Clown!  They can’t sit still while he runs an ideological bulldozer over their lives! NOT.  This is a high priest of “trickle down” preaching to the choir.

While Mitt scoffs at “redistribution” as a code for calling Obama a “socialist”, what exactly would Mitt be doing with the taxes received from those 47% of the Nation? Obama voters or not, wouldn’t those taxes be, by definition, redistributed?  Most likely upward, by my calculation.

I’ll stop trying to make sense of this Möbius Strip of Fuckwit VooDoo.  Someone else did a better job that i could ever do…

As is becoming disturbingly regular (and hilarious) John Stewart beat me to the more obvious points in this, the most awesome video EVER:

Chaos on Bullshit Mountain

It hits on a lot of the things that struck me as particularly baffling:

  • What about corporations that pay no taxes *at all*?  Freeloaders, failing to take “corporate person” responsibility?
  • Since when does paying income tax = personal responsibility for anyone?
  • Don’t most/all of those fine ladies and gentlemen paying $50,000/plate (to listen to Mittens put a boot in the ass of the poor) put a lot of effort into paying as little income as possible?
  • Does Mittens himself not enjoy a massive dose of tax relief by virtue of living off investment income?
  • Does this douchebag really think that the only people who vote for Obama are completely dependent on Government assistance and take no responsibility for themselves at all, ergo, all Romney voters must be paying income tax whether they owe it or not and refuse any assistance from the U.S. Government, on principle?

And this is really just the tip of the iceberg.  Dissecting the words of this captain on industry is bound to become a cottage industry, and I am sure there is someone breaking down a transcript *right now* and you will see that book on Amazon before November 2012.

The sad part of this is that it is completely predictable.  I put a lot of weight on what people say when they are riding high.  After winning the Iowa caucus, Mittens flew directly to New Hampshire to gloat and cement his stature as frontrunner.  When asked about “profiteering” Mitt didn’t even blink, mainly because he thinks profiting and profiteering are a singularity.  He went on to praise “profit” as the driver of the little people’s 401K’s and pensions… proving that he has never even glanced at a 401k or pension because both of those instruments got raped as a result of the exact kind of market de-reg that Mitt thinks will “make America great again”.  Who runs this guy’s campaign?  Monty Burns?

Back in the Saddle

Quick update before I get back to blogging again…

The Halloween Storm did a number on things here at the ranch.  A few trees down, a week without power, and a general setback for musical, photographic, and otherwise enjoyable productivity.  If productivity involved a rake or a chainsaw, then yes, it has been a productive period.

Got a gig coming up with two NHIC groups at Firehouse12 on December 3rd. 8:30pm and 10:00pm.  The first is nhic:atlas, a six-piece mostly acoustic affair.  I am playing my Tacoma CB10F fretlsss ABG and it sounds really nice with this group.  The second is NHIC Electric, a noisy electric affair.  That is a job for the Zon Sonus. I am in hog-heaven as a bass player because Atlas will have Mike Paolucci on drums, and he played in my short-lived jazzy Soul Cryptographers band.  I really enjoy playing with Mike and it is good to be working with him again.  NHIC Electric will have Peter Riccio on drums, and that is VERY badass.  I had been hoping that we would have this opportunity, and it is sounding very nice in rehearsal.

If there is any bright side to this “winter” it is that we are still getting warm temps.  Last weekend I put on about 20 miles on the bike, in short sleeves!  getting that opportunity after Thanksgiving in New England is rare.  I am definitely not complaining.  My friend Chris James calls it Global Weirding… Well, let’s keep it weird!  Oh… rising sea level and food chain disruption?  P’shaw!

a little bit o’ change

The big news on the work-front has been that the Gina McCarthy, commissioner of the Connecticut DEP (my employer), has been appointed to an administrator post at the US EPA. I’ve had the pleasure of working closely with her on a few projects and as much as it is a huge loss for the staff of the DEP, it is a kind of confirmation that someone else agrees that she is as great as some of us think she is. If it sounds like fawning, it isn’t. What it is: The CT DEP has had some truly awful commissioners in the 16 years that I have been there, ranging from ineffective to demonstrably corrupt. With Gina we have had a true professional. She set a very high bar for performance, ethics, and public service, treated staff and management in a professional manner, and expected the same in return. Being treated as a professional is rare in the public sector, and it was nowhere to be found in the years before her appointment to our agency. Gina brought that approach to an agency that had been at a morale nadir when she arrived. There is no such thing as turning a bureaucracy on a dime, but she did alter the nature of the agency, in a huge way, for the better. When you have a focused and consistent commissioner you get a focused and consistent agency. I wouldn’t believe it if I didn’t see it with my own eyes. The bar has been set for whoever fills that job next. The pressure will be on that person to not backslide. The Fed will be picking up a strong leader and a dynamic personality. I’m gripping the rails hoping that we get someone even half as qualified in her place.