Monday, November 30, 2009

The Global Warming Data Scandal

A large number of emails from the Climate Research Unit (CRU) at the University of East Anglia webmail server were hacked recently from computers at the University of East Anglia's Climate Research Unit in the United Kingdom. The CRU is the data repository for much of the world's climate research and is a major source for the judgments reached by the U.N.'s climate reports.

Available now for anyone to read are hundreds of emails that give the appearance of a concerted and coordinated program by the leading climatologists to make the data fit their conclusions instead of modifying their models to accurately reflect the data. In addition, they engaged in attempts to silence and discredit their critics. This form of intimidation and manipulation is despicable and serves to silence true scientific inquiry. These scientists truly believed their conclusions and were operating in a world where the ends justify the means. In trying to rush forward, these scientists have now undermined their cause and damaged their own credibility.

In the June article by Michael J Economides PhD and Xina Xie PhD “Climate Change-What Does the Research Mean?” was a brief review of the scientific literature and research on the some of the postulated impacts that global warming might have on hurricane frequency and intensity, shrinking the ice field of Mount Kilimanjaro, melting the polar ice caps and rising sea levels. Both sides of each argument appear to be documented and supported by specific scientific measurements. Such contradictory conclusions indicated that the modeling of the earth’s climate and environment needed to be significantly reexamined and tested. Now we have some inkling of why the models were not predictive. Some research suggests that climate change may have some anthropogenic (human) causes. However, human cause is not the sole component in climate change. The consequences of climate change that have been cited as reasons for government action have not so far been born out by the facts.

The CRU e-mail scandal, changes the focus of the upcoming Copenhagen climate summit next month from attempting political action during a global downturn to discussing a potential fraud. Republicans are launching investigations, and the pressure is building on Democrats to hold hearings, since climate scientists were funded with U.S. taxpayer dollars. The office of Senator Jim Inhofe the ranking republican on the Senate’s Environment and Public Works Committee sent letters to federal agencies and outside scientists warning them not to delete their own CRU-related emails and documents, which may also be subject to Freedom of Information requests.

Carol Browner, the White House Environmental Czar in trying to downplay the controversy that the hacked e-mail has raised said “… we have 2,500 of the word’s foremost scientists who are in absolute agreement that this is a real problem and that we need to do something and we need to do something as soon as possible. What am I going to do, side with the couple of naysayers out there or the 2,500 scientists? I’m sticking with the 2,500 scientists.” The US EPA has stated repeatedly in the past that it based its findings on the UN science, which is now in question.

If you will recall at the end of June Alan Carlin and John Davidson of the US EPA’s National Center for Environmental Economics detailed their concerns about the science underpinning the agency's "endangerment finding" for carbon dioxide. The two said the US EPA accepted findings reached by outside groups, including the Intergovernmental Panel on Climate Change and the U.S. Climate Change Science Program, "without a careful and critical examination of their own conclusions and documentation." They raise questions about data that EPA used to develop the proposed finding. The Washington-based Competitive Enterprise Institute posted the document on its Web site and you can find it there. Can the US EPA move forward with their “endangerment finding” based on science that now needs to be reexamined?

Thursday, November 26, 2009

Soil and Water Conservation District Impact to Waters of the Chesapeake Bay Watershed

A large portion of both Prince William County and Fauquier County is within the Culpeper groundwater basin. In Prince William County the Culpeper basin consists of an interbedded sequence of sedimentary and basaltic rocks with a lack of overburden that limits natural protection to the aquifer, which is one of the most productive aquifers in the state. The Chesapeake Bay Preservation Act does not address the importance of groundwater to the watershed nor address the interconnected nature of groundwater and surface water. Under the Chesapeake Bay Preservation Act 2001 amendment, all the perennial flow surface water, connected and contiguous to tidal wetlands and buffer lands or within 100 feet of any of those features were made Resource Protection Areas of the Act. Virginia has not yet determined what percentage of the land area and population are subject to the act, but hopes to do so in the future. The “Tidewater” area as defined under the Act covers some of the most populous areas of Virginia. Portions of my land fall within the Resource Protection Areas of the Act, though according to the old geography books I live within the Piedmont of the Commonwealth. Nonetheless, I take my stewardship of this resource and my responsibilities under the Chesapeake Bay Preservation Act seriously.

I was very dismayed to read recently, that the Act was a “quasi-regulatory requirement” and is “likely only voluntary in nature because it does not require farmers or landowner to pay for the (soil and water quality conservation) assessments.” The September 2009 report from the Environmental Working Group Facing the Facts in the Chesapeake Bay,” is the source of that statement. The EWG identifies non-point source agricultural sources as the producers of a significant portion of the pollution in the watershed. This is an undisputed fact. The EWG points out that to achieve the target nutrient reduction in the Chesapeake Bay the six states have assigned two thirds or the nutrient reductions to agriculture. These are really the low lying fruit and can be obtained with agricultural “best management practices.” To achieve that end, the EWG argues that the six Chesapeake Bay states and the federal government must develop and effective regulatory framework to specifically implement the necessary farm best management practices by expanding federally regulatory authority over agricultural non-point source pollution. I do not believe that expansion of federal regulation and control are either cost effective or desirable. Self regulation is a proven and effective model. The resources available to educate and assist property owners should be more widely dispersed.

Virginia's Department of Conservation and Recreation (DCR) coordinates and directs programs and services to prevent degradation of the Commonwealth's water quality and quantity, though it is unclear if that mandate extends to groundwater. Most DCR soil and water conservation efforts are devoted to controlling nonpoint source pollution. Statewide nonpoint source pollution control programs support natural resource stewardship and assist local governments with resource management. These programs include technical assistance, education and research efforts are provided by the Soil and Water Conservation Districts which are funded through state agency budgets, through programs such as the sale of Chesapeake Bay license plates and by funds available from the federal Nonpoint Source Pollution Control Program under the Clean Water Act and the Chesapeake Bay Program.

Soil and water conservation districts (SWCDs) were established in the 1930s to take ownership of the dams within the state. Across the United States, nearly 3000 conservation districts almost one in every county are helping local people to conserve land, water, forests, wildlife and related natural resources. In Virginia, the SWCDs work to develop comprehensive programs and plans to conserve soil resources, control and prevent soil erosion, prevent floods and conserve, develop, utilize and dispose water. Today, forty-seven districts serve as local resources for citizens in nearly all Virginia localities except Arlington. Virginia's Conservation Districts take an ecosystem approach to conservation and protection. Their vision is to help all citizens of their District to have livable communities in harmony with the environment. The SWCDs offer free technical assistance and resources for many sustainable and environmentally-friendly projects from managing storm water, to technical assistance to farmers with specific nutrient management to protect our waterways. The SWCDs provide technical assistance for natural resource conservation best management practices and offer tax credits and financial incentives, when appropriate.
I plan to work with my local SWCD in the coming months to add my skills to their programs and to see how this great resource contributes to moving towards a sustainable Virginia and healthier Chesapeake Watershed.

Monday, November 23, 2009

Choosing Solar Power

Solar Photo Voltaic panels are one of the least cost-effective ways of reducing your use of non-renewable resources. The only way these systems get installed are by all of us subsidizing the cost. This is accomplished by tax credits, state rebates, and renewable energy credits. A tax credit is generally more valuable than an equivalent tax deduction because a tax credit reduces tax dollar-for-dollar, while a deduction only removes a percentage of the tax that is owed. The American Recovery and Reinvestment Act of 2009 extended the tax incentives under the Energy Policy Act of 2005 (EPACT) and eliminated the limit on the credit. Rebates from the state are an inefficient return of tax dollars paid because it requires administrative costs to funnel the dollars back from the stimulus package, but does ensure that the systems were actually installed. Finally, SRECs, solar renewable energy credits, are payments to the owner of a renewable energy system from a utility. They are currently greater than the value of the energy created. This is only possible because the utilities are required to have an ever increasing portion of their generation of power from renewable sources. To meet this requirement the utilities must buy the RECs and in turn charge all their customers a higher rate to cover the cost of the RECs. RECs paid in cash to the Solar PV system owner, increase the utilities' cost to operate, and thus, the cost they charge per kilowatt goes up making my solar system more valuable to me.

Though I want a solar system, I am concerned that my decision is based primarily on government incentives. Making an economic decision based on tax incentives, puts me at risk of capricious government action leaving me stuck with the economic reality of my decision if the tax incentives should be modified. Choosing solar now only makes sense based on the incentives and RECs. Then there is the problem of cash. In order to proceed with a 5 kilowatt project I would need to have about $40,000 in cash to pay for the Solar PV system, and then in turn I can reduce the taxes I pay the federal government next year and the years beyond by $12,000 (this is not a refundable tax credit) and can receive a rebate from the state from the state for about $7,700. The RECs will pay quarterly for at least four years and the power savings will be for the life of the system. Nonetheless, I will still have to pay (net assuming I navigate the rebate and tax credit requirements correctly) a bit more than $20,000 in cash. The estimated power savings of the system would be about $760 per year.

Solar PV systems and solar thermal systems for heating water will not save enough from electric (or gas) bills to make them financially viable in a homeowner's lifetime. There is an argument for installing solar panels but it is not an economic one. The various financial incentives provided by the government make the cost palatable. The incremental change in the use of fossil fuels because of the installation of solar panels will not prevent climate change, but the increased cost of power to consumers may reduce their use of power. These tax incentives seem geared to increase conservation of energy by increasing the cost of power. The reasoning presented is we are allowing the solar industry to develop better, more efficient products by encouraging and subsidizing the installation of Solar PV and thermal systems. The federal stimulus program is just “priming the pump” with a few billion dollars in federal money and an unknown amount in REC payments from utilities in order to make solar power economically feasible in total cost. In doing this we are burning the financial resources of the country in hopes of building a self sustaining solar industry. This makes me uneasy. The government incentives to home ownership ended up encouraging irresponsible behavior on the part of lenders and individuals and excesses that resulted in the real estate mess we are in now. I am trying to anticipate the types of problems that might result from my Solar PV system. Since I am looking only at the personal downside the analysis is much simpler.

The first thing is to make sure that I qualify for the federal tax credit, i.e. you would actually pay 30% of the total cost of the Solar PV system in taxes next year or beyond. Remember, you are going to have to pay the money upfront and reduce your withholdings or apply for a tax refund for the 2010 tax year in 2011. You might be out of pocket the money for the solar system for a year or more. There do not seem to be any more restrictions, no limits on income or the cost of a system. The state rebate in Virginia is limited by the $15 million in stimulus funds that the Commonwealth of Virginia has allocated to the program. In order to obtain a rebate, you first have to sign up and be accepted. This is a very simple procedure to ensure that some of the stimulus money is reserved for you. You can go to the website and sign up with little more than your name, address and type and size of system you intend to install- if you are serious about installing solar. Do not sign up until you have done enough research to be seriously considering the installation and only sign up for the size system you can afford or your home can support. Otherwise you will be tying up funds other people could use. Your request to conditionally reserve funds from the Virginia Renewable Energy Rebate Program will be immediately approved as long as funds are available. You then have 180 days to actually install the system and meet all the requirement of the program to obtain your rebate. Signing up only guarantees that there is still money available for your project not that you will receive the rebate. My reservation for funds has been conditionally approved. I am obtaining bids, reviewing references and checking contractor licenses for complaints, and looking for reviews of solar panels. The selected contractor will have to provide me with evidence of liability insurance, workman’s liability insurance (they will have people on my roof), and a bank reference. In these tough economic times, I can not afford a contractor to go bankrupt in the middle of my project. The delay could cost me the state rebate.

Thursday, November 19, 2009

Ideas for Modifying the Emergency Regulations for Alternative Onsite Sewage Systems

After much thought I have come up with some ideas on how to amend the Emergency Regulations for Alternative Onsite Sewage Systems in Virginia to better achieve the goals of the regulation and serve the people of Virginia. Alternative Onsite Sewage Systems are likely to be used more extensively in the future and may replace many of the conventional septic systems that fail. Though, conventional septic systems were designed to operate indefinitely if properly maintained, the truth is they have no alarms or ways to monitor them and the EPA states that most are not well maintained. The EPA estimates that the life of a conventional septic system is t 20 years or less. AOSS systems that are properly maintained will better serve the 30% of all homes that use on-site sewage systems and protect Virginia and Virginians.

To protect public health and the environment are essential and the goal of these regulations. In order to achieve this goal, regulation must be effective, clear and not overly burdensome. Self regulation is a proven effective model that can work to ensure that single family and low volume AOSS units are operated and maintained to protect public health and the environment. We allow people to operate their own automobiles on highways with school buses, ambulances, fire trucks, taxicabs, professional drivers and other citizens. We allow licensed pilots to fly planes. These citizens operate and maintain their machinery with annual inspections. The same self regulatory system can work for AOSSs.

First of all I believe that any PE, engineer licensed in the state of Virginia can operate and maintain their own AOSS.

Anyone who maintains an AOSS must personally hold either a PE, be certified under Chapter 23 of title 54.1 as being qualified to operate, monitor, and maintain AOSSs, or hold a (new) Class 2 License even if working under the direct supervision of an individual who is licensed or certified under Chapter 23 (§ 54.1-2300 et seq.) of Title 54.1 as being qualified to operate, monitor, and maintain an alternative onsite sewage system. I believe that the field employees should have at least a basic knowledge of AOSS systems, their operations, working parts and maintenance requirements before they are sent out to my house to work on my system.

“Maintenance” means performing adjustments to equipment and controls and in-kind replacement of normal wear and tear parts such as light bulbs, fuses, filters, pumps, motors, or other like components. Maintenance includes pumping the tanks on a periodic basis. Maintenance shall not include replacement of tanks, drain field piping, distribution boxes, or work requiring a construction permit and installer.

The DPOR must develop a test to qualify anyone seeking capability to maintain an AOSS system. All field employees of any entity that is licensed or certified under Chapter 23 (§ 54.1-2300 et seq.) of Title 54.1 as being qualified to operate, monitor, and maintain an alternative onsite sewage system, must have at least a Class 2 License. The new Class 2 License can not have a professional work experience requirement, but must demonstrate knowledge of AOSSs.

An owner of an AOSS of less than 1,000 gallons a day may operate and maintain their own system if they have obtained a Class 2 License demonstrating knowledge of the systems.

All AOSSs less than 1,000 gallons a day must be inspected annually. Inspections can only be performed by the department of Health or an individual who is personally licensed or certified under Chapter 23 (§ 54.1-2300 et seq.) of Title 54.1 as being qualified to operate, monitor, and maintain an alternative onsite sewage system.

All AOSS under 1,000 gallons a day must be operated by either an individual who is licensed or certified under Chapter 23 (§ 54.1-2300 et seq.) of Title 54.1 as being qualified to operate, monitor, and maintain an alternative onsite sewage system or the owner of the system and is either a PE in Virginia or holds a Class 2 License.

All AOSS less than 1,000 gallons a day must be maintained according to the requirements of the operating manual and maintain a log.

No AOSS less than 1,000 gallon a day will be required to sample the system. All of the approved AOSS systems were demonstrated to perform satisfactorily to meet the requirements of the Commonwealth. Operation and maintenance of these AOSS systems by professional operators, PEs, or trained homeowners ensures that a low volume unit is functioning properly. A sampling and testing requirement is burdensome, without public health or environmental benefits.

Monday, November 16, 2009

Renewable Energy Incentives and Solar PV Panels

On October 6, 2009 Governor Kaine of Virginia announced that a portion of the stimulus dollars we are all paying for as been allotted to its Residential and Commercial Solar and Wind Incentive Program. Up to $15 million will be provided in rebates to partially reimburse the costs of residential, commercial and nonprofit renewable energy systems. For residential users the first 10 kilowatts, the rebates will be $2.00 per watt for Photovoltaic Solar systems, $1.50 per watt for small wind turbines and $1.00 per watt for solar thermal units (solar hot water heaters). The rebate is less than you might think because system capacity is defined in Virginia as the installed system’s predicted peak alternating current (AC) output. The system’s predicted peak alternating current (AC) output is calculated as: PTC output Watts per module x Number of Modules x Inverter weighted efficiency. Thus, the rebate is for the AC output not the DC installation size that you are sold. The predicted peak alternating current output would be around 75%-80% of the DC rating.

Virginia has net metering. Combining this with the federal tax credit of 30% and the sale of the renewable energy credits, REC’s, which can be sold to California utilities who’ve just had their renewable energy hurdle rate increased or to others needing RECs. Current prices quoted for RECs are $220-$300 per kilowatt/year and are sold in 4 or 5 year contacts to REC aggregators. (Packaging RECs might be a nice clean business to be in.). Solar mounting modules with connectors built in cost about $7-$8 per (DC) watt installed. All of these incentives added together could bring solar PV within range of dreaming of actually having a payback period.

Though, I am fully aware that the payback period for my hybrid car is around infinity, due to my extremely low driving (less than 4,000 miles annually). I am tempted once more by green technology. So I went to the renewable energy recourse center to use their PVWatts Version 2 calculator to see if I could get an estimate of the energy cost savings for the Solar PV cells. It helps to have your latitude and longitude (get it off your cell phone GPS function) and know what you actually pay for electricity and if you have net metering (the credits for power generated is at the same rate as you are charged). The model uses hourly weather data and a PV performance model to estimate annual energy production and cost savings for a crystalline silicon PV system. It allows users to create estimated performance data for any location in the United States. The PVWatts Version 2 calculator uses the data from a typical meteorological year data station and site-specific solar resource and maximum temperature information to provide PV performance estimation. (Solar systems work more efficiently on sunny cool days.)

The PVWatts tells me that a 5 kW array mounted on my roof would generate about $760 dollars of electricity a year at $0.0122 per kW. This is what I pay NOVEC, my power co-op. Taking that data and calculating a payback period using a 4% interest rate and assuming that I obtain all the available incentives, the payback period for the solar panels would be 30 years with power costs remaining constant. The life of solar panels is between 20 and 25 years, so the payback with these assumptions is about the same as my car- will never happen. However, the sale of the RECs changes the economics. RECs are bundled together and sold for 4 or 5 years, paying quarterly. They represent twice the annual savings in power. So counting the RECs the solar panels actually appear to have a reasonable return. There is no guarantee what the value of the RECs will be in the future or if there will be any value. RECs only have value because utilities are required to generate and increasing amount of their power from renewable sources. If the regulations change or the utilities find cheaper sources of RECs then the return evaporates.

Armed with this information, I was able to convince the husband that the solar panels might be worthwhile based on the above analysis and the fact that I would let him turn up the air conditioning in the summer. It is still a big decision because even with rebates and tax credits we would have to come up with the cash to pay for the system. So, its on to the next stage of investigating installing a solar PV array. Now, it is on to finding the right contractor and obtaining bids.

Thursday, November 12, 2009

Virginia’s Emergency Alternative Onsite Septic System Regulations Comments 2

On September 28, 2009 the Virginia Department of Health published their proposed Alternative Onsite Septic System, AOSS, regulations for public comment. There was a 30 day comment period that closed on October 28th 2009. On Friday, November 6, 2009 the Department of Health posted the comments. The comments and emergency regulations are posted on the VDH website for your review. There are 187 pages of comments from designers, regulators, manufacturers, environmental groups, consultants, and homeowners. Some of the comments are so technical in nature that I fear the resolution would require a multi year experimental program. Many comments are interesting.

Amelia McCulley of Albemarle County states that enforcement of noncompliance will be critical. The Emergency Regulations read:
“The Board, commissioner, and Department may use any lawful means to enforce this chapter, including voiding a construction or operation permit, imposition of civil penalties, or criminal prosecution.”

To ensure the successful implementation of the Emergency Regulations, the regulations need to be clear in the operating requirements for homeowners and the failure to comply with the operating requirements requires clearly spelled out appropriate fines and penalties the department of health is willing and able to invoke. Criminal prosecution of a homeowner for lack of an Operation and Maintenance contract is unlikely to be pursued. Therefore, As Amelia points out the necessary staffing, tools and procedures will need to be in place to assure that enforcement can occur as needed.

Ted McCormack of the Virginia Association of Counties strongly endorses the provisions of 12VAC5-613-110 that require all AOSS owners to maintain an ongoing relationship with an state-licensed AOSS operator, and further, to have the AOSS visited on a regular basis… In addition, current and prospective staffing reductions at local health departments mean that regular operator visits of AOSS by licensed professionals may be the only way the commonwealth will ever know that the systems are functioning properly. “ He concludes that the protections, the performance and laboratory sampling and monitoring provisions must not be weakened under any circumstances, and in some instances, should be increased. His argument is that the costs of maintaining, monitoring and regulating the AOSSs should be born by the property owner.

Scott York of Loudoun County supports annual maintenance and inspection requirements. “Unlike traditional septic tanks, AOSS are complex machines with components that must be properly maintained in order to continue functioning according to system design. Annual operator inspection reports filed with the health department will not only ensure that each AOSS is properly functioning, but it will also lead to improved maintenance as problems are identified during the required site visit and pointed out to the homeowner. Annual inspections and better routine maintenance will decrease the incidents of catastrophic system failures, which can cost many thousands of dollars to fix.” Because the costs of repairing a complete system failure are so high, Loudoun County goes on to suggest the Health Department to develop a requirement for the owner, designer, installer, manufacturer or operator to post a performance bond or other form of financial surety in order to cover the costs of major system failures in the event that routine maintenance and inspections are not enough to prevent such failure.

For the single family homeowner the requirements of the Emergency Regulations are about, ensuring and that these systems perform to protect public health and the waters of the Commonwealth of Virginia. For single family homes the typical homeowner cannot afford a gold plated regulatory system with every potential system and regulatory failure, monitored for, tested for, and insured against on the homeowner’s nickel. As was pointed out by the PEC, even waste water treatment plants, may not provide adequate protection of the waters of the state from man. We as a state could not afford the infrastructure necessary to be monitor and verify performance and operation, and the homeowner can not afford it all. The Department of Health needs to determine the reasonable compromises that will protect public health and the environment in a less than perfect world. Controlling the density of septic systems and the required inspections and maintenance will go a long way in ensuring the protection of public health and the waters of the state. It is a start.

Monday, November 9, 2009

Virginia’s Emergency Alternative Onsite Septic System Regulations Comments 1

On September 28, 2009 the Virginia Department of Health published their proposed Alternative Onsite Septic System, AOSS, regulations for public comment. There was a 30 day comment period that closed on October 28th 2009. On Friday, November 6, 2009 the Department of Health posted the comments. I was a little surprised to see both my comments and what I thought was a personal e-mail to Alan Knapp posted as comments. Nonetheless, I learned a lot reading through the comments and was really pleased with all the sheer number of people who participated in the regulatory process. The comments and emergency regulations are posted on the VDH website for your review. There are 187 pages of comments from designers, regulators, manufacturers, environmental groups, consultants, and homeowners. Some of the comments are so technical in nature that I fear the resolution would require a multi year experimental program. Many comments are interesting.

Thomas Crow of the Fairfax Co. Health Department points out that “In the initial stages finding an operator for home owners will be difficult and expensive. There are very few operators for a home owner to choose from in today’s market. We suggest providing an effective date for this paragraph to allow time for the infrastructure to be built to meet the demand.” He goes on to suggest that Emergency Regulations require that “…operating permits must be renewed every five years by the Health Department. We believe that requirement is necessary because local Health Departments lack the staff necessary to adequately provide oversight to the program as described in the regulations. Requiring a renewable permit will make it ensure that the Health Department is able to evaluate each AOSS at least every five years.” So, every year the Health Department will have to issue or renew operating permits complete with sampling for 20% of all AOSS in the state and every new system built. I do not think that will alleviate the staffing issue. Furthermore, if the operating permit lapses is the occupancy permit voided or must the homeowner begin pump and haul until such time that the department of health renews the permit. I think the idea of outside licensed operators and computer systems was intended to automate compliance someday, not create a system where the VDH needs to manually review and issue a new permit for an ever growing number of systems each year.

Scott Fincham also of the VDH points out that according to his reading of the regulations “Low Pressure Distribution System’s will be considered Alternative (AOSS) and thus require maintenance and monitoring.”

W. Todd Benson of the Piedmont Environmental Council points to the USGS research on the Potomac River that identified intersexed fish. Researchers identified the presence of endocrine disruptors. “Evidence is mounting that trace levels of prescription drugs in rivers and streams may be harming fish, tadpoles, frogs, mussels and oysters. Obviously, the same constituents in the solid and liquid waste stream of conventional waste water treatment works should be expected in AOSS effluent. One might assume that the risk posed by and individual AOSS is the same or better than individual, traditional septic system and, therefore, the permitting of individual AOSSs should be allowed. But the assumption of no greater harm dissipates as the systems grow in size.” Emerging chemicals of concern will be an issue to septic systems, AOSS, clustered systems and sewage treatment plants in the future. It is unknown which of these systems will prove most protective of human health and the environment. Soil filtration may prove to be more effective that point source release. There is still much research to be done in this emerging area of investigation. Todd is correct when he states “These regulations are prepared without any analysis of or attention to the problem of endocrine disruptors or other chemicals of concern.” The PEC recommends that all AOSSs other than individual AOSSs should be banned.

Several different investigations within the Fish and Wildlife Service and US Geological Survey studied the relationship between wastewater treatment plants, other chemicals, and the impacted fish. The study Todd refers to found the problem of endocrine disruption in fish to be widespread in the limited study area of a portion of the Chesapeake Water Shed, but increased in proximity to and downstream of the wastewater treatment plants. Chemical sampling that took place along with the fish sampling found higher concentrations of wastewater chemicals near the wastewater plants. Pesticides currently used in agriculture were detected at all locations. Hormones were not detected in the samples, but analysis using yeast screening assays found estrogenic endocrine-disrupting chemicals at all locations their specific source is not yet known. Though they cannot identify a single chemical or group of chemicals responsible, the US FW and US GS have embarked on further studies.

Anish Jantrania, Ph.D., P.E, a former VDH employee, is a supporter of the clustered systems and today makes his living designing and operating those systems. I should give him the opportunity to counter the PECs recommendation against clustered systems, but as always Anish’s comments are way beyond my knowledge base, but he does state “It is important that Lab Sampling be required for ALL types of AOSS, large and small, at frequency that does not create undue financial burden on either type of AOSS… It’s all about Performance WITH Verification.” I like the philosophy which would allow the regulations to evolve with the knowledge base. However, I am still thinking about that, after all, for at least the single family homeowner the requirements of the Emergency Regulations are intended to ensure that these systems perform to protect public health and the waters of the Commonwealth of Virginia. For single family homes the typical homeowner cannot afford a gold plated regulatory system with every potential system and regulatory failure, monitored for, tested for, permitted and re-permitted on the homeowner’s nickel. As Todd elegantly points out, highly regulated point source generators, waste water treatment plants, may not provide adequate protection of the waters of the state from man. We as a state could not afford the infrastructure necessary to monitor and verify performance and operation, and the homeowner can only afford essential protections to protect public health and the environment, not those that make a regulator's life easier. The Department of Health needs to determine the reasonable compromises that will protect public health and the environment in a less than perfect world.

Thursday, November 5, 2009

Sustainable Living with a Lifecycle Approach

The carbon footprint and IPAT approach failed to encompass the balance with which we live with the earth. When I lived in the city I did not often think about all the resources of the earth pulled to support the city entity itself. I never considered if urban living was more or less sustainable than country or suburban living. Certainly, when we worked in the city, living within walking distance of work seemed more sustainable. The work I did in environmental evaluations and redevelopment of Brownfield properties was clearly improved use or re-use of the land and a sustainable form of land use. How does the work you do contribute to the sustainability of your life? What is the cost of supplying cities with power, water and food? Is the ecological impact of a city greater than the ecological impact of the individuals merely because of the concentration of population? These are truly tough questions, and I do not have the simplicity of an answer that measuring a carbon footprint would. Truly measuring your ecological footprint and choices accurately might require some of the computing power of NASA.

All resources are finite. As humans our resources consist of money, time, passion and energy. In the end, where, how and when we deploy these resources will determine our comfort and happiness with our lives. Living within your personal means, financial means and your ecological means would be a sustainable life. The problem is how to determine what is or should be your ecological means, what is sustainable in a dynamic and interconnected environment. A useful model in sustainable living could be a great tool in decision making. In the real world of finite resources, careful consideration must be given to how and when we expend our resources. Recently, I came across an article by Phillip E. Savage, PE of the University of Michigan, “What Does It Mean To Be Green.” In the literature cited was a book, “Caring for the Earth: A Strategy for Sustainable Living,” written/published in 1991 by the International Union for Conservation of Nature (IUCN), United Nations Environment Programme (UNEP) and the World Wide Fund for Nature (WWF). Thanks to the internet excerpts from the book were available to read as well as a summary of the book. It appears to be a guide to the principles and actions of sustainable living on this earth. The first part of the book was even called “principals of sustainable living.”

There is a “popular adoption” of the book called “Caring for the Earth: A Strategy for Survival.” That is the book I ordered. The book summary reads in part, “The principles of sustainable living are respect and care for the community of life, improvement in the quality of human life, conservation of the earth's vitality and diversity, reduction of nonrenewable resource depletion, (and) maintenance of the earth's carrying capacity… Changes in community attitudes and practice in the care of their own environments, a national framework for integrating development and conservation.” Sounds like powerful and encompassing view that I hope has not been made obsolete with the passage of 18 years. Hopefully, I will find universal principles to evaluate choices.

Until I find a truly workable model of sustainable living I will try to stumble through life’s choices, balancing wants and desires with resources and trying to make good choices for us and the earth. Following a systematic plan to reduce the non-renewable the energy footprint of our home and lives. Living within the limits of the hydraulic system of the Culpeper Basin. Acting as responsible stewards of the watershed. Making responsible choices on how we spend the money we have available. For example, I will admit that for health and taste reasons (and because I evaluated the environmental impact of CAFOs in the northwest and Texas) I buy meat from what my husband refers to as the meat underground. Every six weeks or so, I drive my little hybrid on a 35 mile roundtrip to pick up my meat order from the appointed pickup location that the husband always describes this as “under a bridge by the river.” It is actually at the end of a cul-de-sac. My meat is more expensive than what could be bought in groceries (with the exception of the grass feed organic meat at Whole Foods that I buy when we are in California). My meat co-operative is a relatively local Shenandoah Valley Farmer, Joel Salatin of Polyface Farms. Just recently, Mr. Salatin and Polyface Farms received a Heinz Family Foundation Award for helping to bring about a cleaner, greener and more sustainable plant. After reading that in the local “Co-op Currents” I feel really good about all the money I spend on meat. Since I calculated that I have about 28,000-30,000 more meals to cook for my husband, they might as well be tasty, healthy and sustainable.

By the way, just in case you care, Salatin rotates his livestock’s location on the farm, so that different species are helped by the proximity of the other animals. He uses portable infrastructure and equipment, and does not use chemicals or fertilizers, instead using composting and pigs as aerators. He is too ornery and libertarian to jump through hoops for organic certification, so you take it or leave it with his guarantee. For anyone who has not spent time at concentrated feed lots or by their official government name “concentrated animal feeding operations, CAFOs, I recommend Michael Pollen’s excellent book, “An Omnivore’s Dilemma: A Natural History of Food.”

Sunday, November 1, 2009

Sustainable Living and Your Carbon Footprint

All resources are finite. As humans our resources consist of money, time, passion and energy. In the end, where, how and when we deploy these resources will determine our comfort and happiness with our lives. While there are some basic truths, the optimal allocation of your resources is based on your values and goals. Living within your means and your ecological means would be a sustainable life. The problem is how to determine what is or should be your ecological means. In the real world of finite resources, careful consideration must be given to how and when we expend our resources.

A very popular viewpoint right now is sustainability is tied to the individual and national carbon footprint. Carbon dioxide is a by product of combustion, all combustion. Human beings exhale it at over 3 pounds per day for the average sedentary adult. Carbon dioxide is also released when we burn fossil fuels such as gas, coal or oil. In a natural carbon cycle, carbon dioxide is used by plants and trees. However, the belief is that we are producing more carbon dioxide than can be absorbed by the plants and trees currently available to use it because we are burning too much fuel. The fuel represents carbon dioxide that was trapped under the earth's surface for millions of years. It is believed that the human population by breathing and burning fuels has caused the increase in the carbon dioxide content in the atmosphere from approximately 250 parts per million (0.025%) to 386 part per million (0.039%) in the past 100 years.

The popular belief is that this increase in carbon dioxide in the atmosphere has caused the under 1 degree Fahrenheit increase in average global temperature since 1900. (It is to be noted that that increase was 1.3 degrees Fahrenheit when measured in 1998 and 2005, but the average temperature has fallen somewhat since then.) This theory further postulates that the overall temperature of the planet is increasing (global warming) at a faster rate now and causing the earth’s climate to change in unpredictable ways (from floods and hurricanes to heat waves and droughts). The strongest adherents to this belief, hold that the burning of fossil fuels must be reduced immediately. The goal of Cap and Trade legislation is to reduce the amount of carbon dioxide released into the atmosphere by capping the amount of carbon dioxide that can be emitted by all industry, reducing that amount each year and allowing the industrial sector to reduce their releases off the base and sell each other release permits, thus reducing the burning of fuels. The belief is that if we could reduce our carbon dioxide emissions enough we could stop the climate of the earth from changing. The models predicting this are at the earliest stages of development because our knowledge of our environment is really limited, hard data points especially for the oceans has been limited in quantity and duration.

There is a price to reducing our emissions of carbon dioxide and we need to the costs and benefits in terms of comforts, services, possessions and environmental balance before we act. It is likely very important to reduce the burning or fossil fuels and increase the planting of trees; however, we should approach this in the most cost effective manner. It is not clear how regulations to limit point source carbon dioxide release, to reduce our carbon footprint (reduce our burning of fuels) will of its self make living more sustainable. Certainly, the current fuel usage in the United States will decrease and may make the climate of the earth more stable if carbon dioxide emissions do not increase else where in the world. In addition, as the previous review of global warming research showed some research suggests that climate change may have components that are other than of anthropogenic (human) causes. Certainly, anthropogenic activity has been a contributor to the 136 parts per million (0.014%) increase in carbon dioxide in the atmosphere over the past 109 years. The exact relationship of increases and decreases greenhouse gasses to climate change is unknown, if mankind were suddenly wiped off the face of the earth as in Alan Wisman’s February 2005 essay “Earth Without People”, climate change would not stop. The climate is neither static nor fixed, but without mankind it would certainly be different.

Building a bureaucracy to measure, control and tax carbon dioxide will have unintended consequences and consume resources and energy. There is real benefit to increasing the efficiency in energy use by selecting technologies, like hybrid or dimpled cars, ground source heat exchangers, solar panels or wind turbines. There is tremendous benefit to improving insulation in buildings and homes, passive use of solar and wind. Changes in how we live; urban dweller, rural dweller, suburban dweller; whether or not we commute or if we commute using public or private transportation, alone or in a groups, our purchasing and activity choices all will impact our “carbon footprint.” However, this approach only looks at one aspect of the carbon cycle and fails to identify what is a carbon budget if such a thing exists, it does not consider the other resources of the earth. Legislating the measurement of carbon dioxide release in all things will cost money and resources and of itself will not make our lives more sustainable. Limiting carbon dioxide emission by industry might reduce the use of energy in the United States by industry. Energy will become more expensive, a reduction in use will be achieved by a rationing of energy and products by price. A greater allocation of my resources to heating, electricity and food will make me poorer though not necessarily more sustainable in my living on this earth. Too many important aspects of sustainable life are missing from this viewpoint.