Letters to the Editor

Cool Down About Global Warming

Ever since your February 2001 issue in which you seemed to accept the hypothetical notion that gases such as carbon dioxide (CO2) are causing the phenomenon called "Global Warming," I have scanned the "Letters to the Editor" to see if some of my more knowledgeable colleagues who share my disdain for the concept had written you. For various reasons, they remain silent. I shall now speak.

I shall first summarize three points of technological fact that refute the claims. (There are many more.) Then I shall speculate (wildly?) on why so many fear to speak and on just what drives the whole promotion.

1. The hypothesis of global warming rests upon the concept that ultra-violet radiation that impinges the earth's surface is absorbed, and most is re-radiated as infra-red. Agreed. The supposed greenhouse gases (usually blaming CO2) are not transparent to infra-red, and they absorb it. In the process, the atmosphere is heated, and this in turn warms the earth's surface. Now, your February editorial notes that the surface temperature has increased some "0.4 to 0.8 degrees C" in the past 100 years. (This questionable value is widely accepted by the proponents of the phenomenon.) Yet your report notes that there has been no increase in the temperature of the atmosphere. Your "scientific" report which suggests that aerosol particles from whatever source that reflect sunlight could be "possible sources of cooling" is somewhere between fatuous and specious. It should be absolutely obvious that if such particles reflect away the sun's radiation so that the surface is not heated and the atmosphere in turn is not heated, the "greenhouse" effect is not occurring. In other words, the claimed "cause" does not produce the predicted effect.

Ergo, the hypothesis should be rejected. (We should note that although the percentage increase in CO2 is large, about 50 percent over the past century, the absolute value of the increase is only about 100 ppm. Compared to the existing water vapor -- another acknowledged "greenhouse" gas -- of some 5,000+ ppm at 75 Fahrenheit and ~50 percent relative humidity, this is surely insignificant.)

2. It is well documented that during the period from about AD 1000 to 1400, most of the northern hemisphere was warmed to such an extent that vineyards flourished in Britain, and the Norse established highly productive agricultural colonies on Iceland and Greenland. Air samples taken from corings of dated glacial ice show that no change had occurred in CO2 content. Thus, the phenomenon of concern appeared on a grand scale in the total absence of the claimed causative agent. Again, therefore, the hypothesis should be rejected

3. It is virtually universally accepted that our earth is a radioactive planet with a liquid center at high temperature that is some 2170 miles in radius. This is surrounded by a mantle of relatively solid, dense rock some 1800 miles in thickness. This mantle is covered by a relatively thin crust: about 3 miles thick under the oceans and some 20 to 45 miles thick under the continents. All but the outer few miles of the solid mantle are at a temperature of thousands of degrees Fahrenheit! It would be white hot if exposed. There is motion in the mantle, which contributes to the movement of the tectonic plates. Over the course of time, it should be obvious to anyone with any grasp of the science of heat transfer that such a heated interior will cause some warming of the earth's surface. Thus the claimed warming of a degree or so over a century (which is the merest blink of an eye in geological time) can be easily understood. Since one of the dictums of good science (at least when I went to school) is to accept the simpler explanations for events rather than to conjure up complex possibilities, the "Greenhouse" hypothesis should again be rejected.

Given the above points, one must ask, "What drives the Greenhouse engine?"

I first became aware of the "push" for it at the 1990 symposium of The Council on Alternate Fuels. (Only much later did I learn that the United Nations (UN) had formed an Intergovernmental Panel on Climate Change in 1988.) Several of the papers presented by U.S. Department of Energy (DOE) people and UN representatives attempted to show that a real problem existed. At the conclusion of each presentation, many in the audience expressed skepticism. In virtually each case the response was the same, word for word: "The train has already left the station." It occurred to me later that this mantra represented a dictum from on high. When finally a UN official offered the only "solution" that I have yet heard to this day, the light dawned. The remedy was to impose heavy taxes on all carbon-bearing fuels (which is all we have!). Part of the funds would go to compensate the island people (whoever they were) whom rising seas would drive from their homes. Most would go to enrich the various governing bodies, including the UN. Since all would be done in the name of saving the planet, the public should support it. (I thanked him publicly for finally giving the rationale behind what I still believe to be a preposterous promotion.)

At this same meeting, there was shown a British-produced videotape entitled "The Greenhouse Conspiracy." This documentary effectively refuted the (at that time) four pillars that supported the fear of global warming. This was described in The Wall Street Journal in an editorial on January 11, 1991. I later tried to get copies of the tape for distribution here in California, but I was informed that "it is no longer available." It essentially was censored!

Now, almost every research scientist is funded, one way or another, by some government agency. As Dr. Kary Mullis (a Nobel Laureate) pointed out in his book, Dancing Dangerously in the Mind Field, disagreeing publicly with the party line can lead to loss of funding. Whether or not this concern influenced the apparent "acceptance" of so many scientists, I do not know. I am acquainted with some who strongly disagree with the "Global Warming" concept, but they are not acknowledged by our news media.

Let me close with the suggestion that the "Greenhouse" hypothesis is analogous to the fabled suit of clothes that some "fine" tailors made for an ancient Japanese emperor. If we look critically, we shall see that he is naked!

William A. Samuel, PE
Oceanside, Calif.

These Budget Cuts Don't Hurt

I just read your editorial "The Unkindest Cuts of All" and am compelled to respond. Your list of doom and gloom budget cuts proposed by the Bush administration sounds like good management practices to me. After 20 plus years in industry with more than 12 of those years dealing with environmental issues, it never ceases to amaze me the variety of way our government can find to waste money. The only thing more amazing is how there are always people ready to explain how vital is the need for spending all that money.

Your column suggests that all the money being cut is critical to the next vital scientific breakthrough in dealing with our various environmental crises.

I doubt it. The suggestion that government spending has been the wellspring of scientific discovery doesn't stand up too well to scrutiny. Give me a list of all the great scientific breakthroughs that owe their existence to government planned and funded research. Particularly if you confine yourself to the areas cited in your column; solar power, wind energy, biomass and energy conservation. The only areas of success that come to my mind are the NASA program and military research.

It is also implicit in your column that these are the only agencies and departments funding these fields of research. Again, I doubt it. I would expect that the U.S. Department of Energy (DOE), U.S. Department of Defense (DOD) and U.S. Environmental Protection Agency (EPA) all fund some sort of research on toxic contaminants in groundwater (not just U.S. Geological Survey USGS)). The first two due to the fact that they own so many contaminated sites and the last because they are of course responsible for the clean up regulations.

Not to make too much of a math error, but in the one value you cite with enough information to allow a check of the calculation, the percent cut is overstated by almost a factor of three (the USGS budget goes from $883MM to $813MM, a drop of $70MM which is a 7.9 percent cut, not your figure of a 22 percent cut). It leads me assume that you are using "Standard Washington Math" in which a "projected reduction of a planned budget increase" is the same as a spending cut! Anyone other than the government using those accounting rules would be behind bars.

Instead of crying over these projected cuts, why don't you educate us on how well these programs have been spending our money over the last 10, 20 or 30 years. Regale us with the great accomplishments in solar power that are directly related to all the tax money that has been poured into that program. Expound upon the great improvements in wind energy production that have rolled out of these programs. The truth is that pretty much everything we know today about these issues we already knew 10 to15 years ago (and billions of tax dollars ago).

Lets trim the excess and get refocused on issues with some potential for a return on investment.

The decoding of the human genome is a classic example of this kind of refocusing. The government funded and managed genome project was projected to be very expensive and to take a long time until a private firm announced that they would do it for far less money and far faster. Suddenly the government project found a way to compete. Obviously there is much more to that story, but fundamentally there was no driving force for the government project to optimize prior to competition.

There is a lot of promising research going on in many fields, and a lot of it is government funded, but none of the areas listed for cuts are ones that are going to cause us to lose "our role as world leader in scientific research." I suspect that your real complaint is that these cuts will directly impact some of your readers adversely. Isn't it amazing where your can find the not in my backyard (NIMBY) syndrome.

Joe Griebstein
Compliance Associates

Editor's Response

Your point about my fuzzy calculations is well-taken. It was not my intent to use "standard Washington math" or voodoo mathematics. In the future, I promise to dust off the cob webs from my calculator and do a better job of tackling percentages and other computations.

TMDL: When is Enough, Enough?

I really enjoyed Angela Neville's editorial, "The New TMDL Rule: The Maximum Load of Controversy," (October 2001). I had lost track of where total maximum daily load (TMDL) stood but you brought me back and I am still perturbed over what I am hearing and reading (again). Does anyone working on this remember that we have stricter effluent guidelines coming out for indirect dischargers as a result, in part, to TMDLs? I am an indirect discharger and the Metal Products & Manufacturing (MP&M) rule, if it ever comes out and I for one hope it doesn't in its present form, is a nearly unattainable standard that has caused a major uproar too in the world of water dischargers. Let me give you one specific example of the potentially damaging and business killing effluent standards under MP&M: effluent guidelines in Part 433 include a Chromium max at 2.77ppm and a monthly average of 1.71 ppm. The new MP & M standard decreases every one of these limits by at least 10 times or more. I cannot make it without total reengineering and possibly a significant add-on technology of my wastewater treatment plant (WWTP). I am not the only industry in our county in Alabama that would be in grave trouble. Our county sanitation engineer visited with me not long ago and stated that most indirect dischargers in this county would fail under MP&M and probably go out of business.

So where am I leading with this? The TMDL is what I would call the

"overdriver" of this situation. If a body of water can stand so much pollutant loading in a year, and then the load is parceled out to existing dischargers, I ask "What about new dischargers and economic/industrial growth?" The TMDL almost smacks of something similar to non-attainment areas for national air quality standards. Once a body of water has its limits imposed, it then may become an "off-limits" area for new industry. Remember, there is no such thing as "zero pollutants" in most industrial pretreated discharge. Even if some smart authority held back some of the TMDL to allow for future growth, the limits to direct and indirect dischargers might have to decrease further to accommodate this allowance. Has anyone at EPA, in this case in the water divisions, thought about what other water regulations are doing or how regulations in one area affect those in another aspect of the same area? When is enough, enough? We are going for the final 10 percent of pollutants it seems, and as pointed out, compliance costs are becoming disproportionate to ultimate benefits. We are drowning ourselves in a sea of minute regulations -- air, water and to a lesser degree, hazardous waste management. Even states will be hard pressed to spend on unfunded mandates such as the TMDL as implied toward the end of the article. I call them unfunded mandates.

I suppose something is needed if water bodies are still that polluted, and I know some are, and I agree that we should at least have very sound scientific backing and forecasting of results BEFORE we toss the regs out there. It appears we are headed that way and yet the pending MP&M rule betrays this very statement I just made unless in its review it is modified to a more equitable level. All I ask for is to balance cost, protection and social/economic growth when new rules are drafted. Eventually if we aren't careful, we will have a rule or a couple of rules out there that do one of two things and both are backlash type situations: 1) No one can comply and they shut down. This will have industrial, economic and possibly political backlash impact on the country and 2) No one can comply and we all keep discharging and go to court and hope for the best because shutting down is not an option. I pray it doesn't come down to this.

Mark D. Ryan
Birmingham, Ala.

Who Makes the Rules?

The April 2001 edition of Environmental Protection has the article "Clean-Air Standards Upheld" that you complied.

The article effectively describes the following two points that the U.S. Supreme Court upheld in its ruling on February 27, 2001 in the case Whitman vs. American Trucking Association, which rejected industry challenges:

1) U.S. Environmental Protection Agency's (EPA) authority to enact air quality standards does not violate the constitutional prohibition on the delegation of legislative power, and

2) U.S. EPA should set air quality standards at levels necessary to protest public health without taking into account the economic impact of the air quality standards.

Those are two important points. However, a third point was missed. U.S. EPA still has to redo its rulemaking for the eight-hour ozone standard, originally set at 0.08 parts per million (ppm), because of a legal conflict with the 1990 Clean Air Act pertaining to the one-hour ozone standard.

So, who won the industry challenges? Perhaps both for now. You may want to report on U.S. EPA's timeline for its current rulemaking effort on the new ozone air quality standard.

Bill Juris, Supervisor,
Volatile Organic Compound (VOC) Control Unit
Engineering Section
Columbus, Ohio

This article originally appeared in the 11/01/2001 issue of Environmental Protection.

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