Letters to the Editor

• By Katy Makeig
• Dec 01, 2000

Selling the client short

I read Richard MacLean's Manager's notebook (October '00), and I am curious to know exactly what he defines as "commodity environmental services". I strongly disagree with the statement that "commodity environmental services can be accurately defined, estimated and competetively bid" especially since the bulk of the article focuses on environmental consultants, implying that some environmental consulting services are "commodities". I strongly believe that there are very few environmental consulting services which can or should be considered "commodities", and that those who do so fail to consider the big picture of their environmental issues.

I have been an environmental consultant for more than 15 years, and it has been my experience that even the simplest of tasks (i.e., Phase I ESAs, UST closures) often require intelligent professional judgement due to unforseen circumstances which arise during performance of the work. Such decisions, which are routine, should not be part of a "commodity service." Furthermore, environmental managers who define a specific scope of work and then consider it to be a "commodity" are usually looking at their projects on a single-task basis, failing to see the big picture, and not looking at their project with the end in mind, which is the true job of competent environmental consultants.

It is my opinion that environmental managers who treat environmental consulting services as a commodity are acting in a short-sighted manner and are making a serious mistake in not allowing their consultants to be consultants. It is this kind of thinking that has driven many consultants to the use of "cookie-cutter" approaches in order to remain competitive and in business. As a result of this "commodity-based thinking", many sites end up with remedial strategies which are grossly over-designed, wasteful and not in the client's best interests. Consultants should be allowed to consult and not be lumped in with environmental commodity services such as landfills, providers of backfill, remedial equipment suppliers, etc.

Steve Sittler
APT Environmental
Mishawaka, Ind.

Author's response: Commodity examples are monitoring, stack testing, sample collection, sample analysis and IH monitoring. It is the stuff that comes in relatively small discrete units -- generally without much variation from client to client in terms of cost and scope per unit of delivered results. It is the low-end stuff you do not have to be a rocket scientist to do -- very repetitive.

I agree with most of what you are saying, but the real issue is tha business management views just about the entire profession as a simple service commodity. In part it is our own fault because we have been unable to make a good business case to management about the value we add to the business (as opposed to just being a cost drain). They view filling out permits in the same category as filling out payroll checks or accounts billable. That is why there has been such a movement towards outsourcing and shared services -- forced by business management.

Richard MacLean

Stuffing the ballot box

I take great offense at the coverage given Ralph Nader in your October '00 article Ballot 2000. The Green Party boasts 72 elected officials and 244 candidates in the upcoming election, including presidential candidate Ralph Nader - who espouses a rigorous communist manifesto. You totally ignored the Libertarian Party and their candidate, Harry Brown. They are a legitimate party that is also challenging the current way of doing things. The Libertarian party boasts 170 elected officials and 1,420 candidates in the upcoming election - including presidential candidate, Harry Brown. The Libertarian party is on the ballot in 50 states and the District of Columbia (Nader is only on the ballot in 44 states and Washington, D.C.). This is, in my mind, a gross disservice to your readership. As an environmental professional making my living representing my company in the environmental and regulatory arena, I find Nader an abhorrent individual who is living on his past successes and name recognition.

In addition, the phrasing of some of the questions is typical of persons who have already determined the answers required. For example, Global Warming. "... greenhouse gases are contributing to global warming..." Is there global warming and, if there is, how much is due to greenhouse gases from fossil fuels? How much is from the increase in human biota and the CO₂ from people living and breathing? Your question is so loaded, it cannot be neutral.

Alternative Energy Sources. How about fuel cells? MTBE Contamination. Nader response is so typical of his ilk, "...the expense... of cleaning up MTBE is borne by the companies that have polluted water supplies with this unnecessary cancer-causing additive." Totally ignoring the question, which states, "... EPA ... replacing lead with MBTE...". His idea is that companies obeying federal government directives are responsible for the resulting chaos. On the whole, a disappointing performance by you and your staff.

James Leagan
Director of Regulatory Compliance - Wolf Camera
Alpharetta, Ga.

Editor's response: Due to space constraints in our magazine, our staff chose to limit our focus to the three candidates -- Governor George W. Bush, Vice President Al Gore and Ralph Nader -- who were leading in the polls at the time that the article was written in late August 2000.

We prefaced our question about global warming with the statement that "scientific evidence is increasingly documenting that greenhouse gases are contributing to global warming." This question is based on recent scientific findings that corroborate this conclusion, such as a report presented by Dr. Jerry Mahlman, the director of the National Oceanic and Atmospheric Administration Geophysical Fluid Dynamics Laboratory at a seminar hosted by the U.S. Global Climate Change Research Program in November 1999.

We presented each candidate an opportunity to comment on our questions and state any objections to their form or content. We published the full, unedited versions of each candidates' responses to our questions on our Web site's version of the article.

From competitors to partners

I read Gail Sakamoto's article on UV disinfection of reclaimed wastewater (Finite and nonrenewable, October '00) with interest and appreciate UV's effectiveness in achieving the required degree of disinfection. However, one point that I did not see addressed was residual disinfection effects (i.e., the power to kill hours and days after the water leaves the treatment plant). This is a serious concern in municipal water systems that are inevitably plagued with "dead legs" and require manual flushing (typically not done often enough). Industrial cooling water systems exhibit many of these same problems.

The article reminds me of the controversy that continues to rage in the industrial water treatment periodicals concerning the use of reverse osmosis vs. ion exchange to produce boiler feedwater. Similarly, UV and chlorination (or other chemical use) for the disinfection of water supplies should be viewed as complementary rather than competing technologies. One method that immediately comes to mind is to use UV to sterilize the product water followed by a much smaller dose of chlorine to provide a residual in the system. The drawback to this methodology is that it is more complicated and requires more operator attention. The lesson to be learned here is that when dealing with living organisms, one plan of attack is seldom enough (at least, not for long). If these "critters" weren't adaptable, they wouldn't be such a problem.

Gordon Combs, PE
S&W Consultants
Houston, Texas

Have diploma...will travel

I believe that a fundamental issue raised by Grasso and Switzenbaum's article Education 2K (September '00) is whether there will be jobs for the environmental engineers and scientists graduating now and in the foreseeable future. The reality is that there are far fewer people working in the environmental industry than 10 years ago. Expenditures on the environment by government and private sectors have been declining sharply, and the allocation of funds has shifted away from studies and engineering design toward (mostly) low-tech cleanup. This trend is unlikely to change.

Development of new environmental engineering programs may be justified, but educators have a fundamental responsibility to prepare students for the marketplace that exists, not one that we would like to see. Universities must very carefully evaluate the employment opportunities in the environmental field before recruiting students into a career path where they will not be able to find work. Unfortunately, based on past evidence, the employability of graduates has not always been a criterion given sufficient weight in such decision-making.

Richard S. Nugent, PhD
Senior Program Manager - BAT Associates Inc.
Norcross, Ga.

Touch-up job

I just read the article Painting the PCB picture (Bloom and Gold, October '00). I found the article very well written and informative. It really opened my eyes to a new environmental concern. Living in St. Louis, lead-based paint (LBP) is a major issue and concern. The possibility of PCBs in paint has opened a whole new can of worms. I would be interested in obtaining additional information regarding the issue of PCBs in paint, specifically concerning:

• Manufacturers that used PCBs in paint;
• Was the practice more common in different regions of the country;
• Typical applications;
• Testing methods;
• Abatement and disposal options; and
• Federal regulatory stance/position.

Kevin S. Arnold
Project Manager
St. Louis, Mo.

This article originally appeared in the 12/01/2000 issue of Environmental Protection.