Impact of BODs on Fish

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Impact of BODs on Fish
Normal clean water organisms (Trout, perch,
bass, mayfly, stonefly)
Trash fish (carp, gar, leeches)
Fish absent, fungi, sludge worms, bacteria (anaero
bic)
Trash fish (carp, gar, leeches)
Normal clean water organisms (Trout, perch,
bass, mayfly, stonefly)
8 ppm
Types of organisms
Dissolved oxygen (ppm)
8 ppm
Biological oxygen demand
Clean Zone
Recovery Zone
Septic Zone
Decomposition Zone
Clean Zone
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NPEDES

• Rulemaking Process
• Regulatory Output
• Abatement Costs
• Compliance
• Environmental Impact
• Perverse Incentives

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Permitting

• Permits are the legally binding terms that a
  control authority imposes on a pollution sources
  as a conditions for building or operating the
  sources. Permits are designed to reconcile what
  the source emits with what standards allow.
  Permits are the basis for compliance, the key to
  pollution control, the nexus between the control
  authority and the pollution sources.
• Davies, Reforming Permitting

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Permitting Process

• Expensive
• Complex, Long
• Many agencies,
• Separate permit for each media
• CAA, Title V
• CWA
• RCRA
• Dynamic nature of process

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Regulatory Impact

• Permits Bargaining
• Consent of regulated? Success
• New facilities versus Renewal

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Compliance

• Bethlehem Steel, MD
• 48th biggest toxic metal polluter
• CWA permit expires 1985
• Fragmentation- Frigidaire

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Power!

• Administrative Discretion Power!
• Manchester Sewer Overflow
• Permit requirements are in policy guidance to
  states
• No one sues, it is legal

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A Better Way?
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Cheaper, Faster, Better

• Goals of the program are to achieve a cleaner
  environment at the lowest cost.
• President Clinton
• "The old way of doing business was that
  government dictates every move a business must
  take to protect the environment. The new system,
  envisioned by Project XL, is to work
  cooperatively and focus on the results a cleaner
  environment a faster, less costly system with
  more input from the local community."
• Intel CEO, Gordon Moore

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Project XL

• Flexibility for Superior Environmental
  Performance (SEP)
• Site-specific plans
• Stakeholder negotiations
• Voluntary

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Intel

• Why go XL?
• Deliver SEP?
• Stakeholders?

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SEP

• Intel trades
• 50 less air pollutants
• Conserve water
• Reduce Chemical waste 60
• Pretty Campus
• EPA
• Modest flexibility
• Sound good?

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Weyerhaeuser, GA

• 500 jobs, 75 million
• 320,000 mton of bleached softwood kraft market
  fluff pulp

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Weyerhauser

• SEP
• 60 air emissions
• Renewable forest mgmt practices 300k acres
• Stricter h2o effluents limits
• Innovation
• Closed loop
• No bleach dumping
• Reduce hazardous waste 90

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Merck Stonewall Plant

• Trading Ozone for Smog

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Substantive Issues

• What is superior environmental performance
• Whats the baseline, Kenneth?
• Clear reduction in risk ?
• Whose environmental priorities habitat, green
  space, parks
• Okay to trade for social/political benefits

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Procedural Issues

• Role of outside stakeholders
• Power of stakeholders, veto?
• Absolute conesnes
• Expertise
• Time Consuming
• Legal?
• No protection from citizen suits

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Big ?s

• Goals of Reinvention?
• Balance between environmental quality and
  reducing compliance costs
• When to trade-off
• Who makes trade off?
• What if no-one wanted to reinvent the process?