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Impact of BODs on Fish
Types of
organisms
Dissolved
oxygen
(ppm)
Biological
oxygen
demand
Normal clean water organisms
(Trout, perch, bass,
mayfly, stonefly)
8 ppm
Trash fish
(carp, gar,
leeches)
Fish absent,
fungi, sludge
worms,
bacteria
(anaerobic)
Trash fish
(carp, gar,
leeches)
Normal clean water organisms
(Trout, perch, bass,
mayfly, stonefly)
8 ppm
Clean ZoneDecomposition
Zone
Septic
Zone
Recovery
Zone
Clean
Zone
NPEDES
• Rulemaking Process
• Regulatory Output
• Abatement Costs
• Compliance
• Environmental Impact
• Perverse Incentives
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
Permitting Process
• Expensive• Complex, Long• Many agencies, • Separate permit for each media
– CAA, Title V– CWA– RCRA
• Dynamic nature of process
Regulatory Impact
• Permits = Bargaining
• Consent of regulated Success
• New facilities versus Renewal
Compliance
• Bethlehem Steel, MD– 48th biggest toxic metal
polluter
– CWA permit expires 1985
• Fragmentation- Frigidaire
Power!
• Administrative Discretion = Power!– Manchester Sewer
Overflow
– Permit requirements are in “policy guidance” to states
– No one sues, it is legal
the initial
“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
Project XL
• Flexibility for Superior Environmental Performance (SEP)
• Site-specific plans • Stakeholder
negotiations• Voluntary
SEP
• Intel trades– 50% less air pollutants
– Conserve water
– Reduce Chemical waste 60%
– Pretty Campus
• EPA– Modest flexibility
• Sound good?
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%
Substantive Issues
• What is “superior environmental performance”– What’s the baseline, Kenneth?– “Clear reduction in risk” ?– Whose environmental priorities– habitat, green
space, parks – Okay to trade for social/political benefits
Procedural Issues
• Role of “outside stakeholders”
• Power of stakeholders, veto?– Absolute conesnes
• Expertise
• Time Consuming
• Legal?– No protection from citizen suits