Wednesday, February 23, 2005

Environmental Dance

The "dance" is a very formal ritual in which all participants dance to their own music. Pick a topic or new initiative and, with a little observation and practice, you can write the script for any of the ritual participants. For example, the EPA proposes a new regulation. In their proposal, they gladly demonstrate that it is needed, implementation will save lives and it will cost so little to implement that we should be glad to do it. EPA, quite often, isn't bothered by actual science. They will tell you that this new regulation will save lives (I've even seen a proposed reg that would save 65 lives. You know, by the time they get to a busload, they ought to be able to give us the names of those who would be saved)

The environmental community enters the dance. Their tune is the regulation does not go far enough and that, as a minimum, civilization as we know it is doomed.

The regulated community enters the dance. Their tune is that the regulation is overly burdonsome, does not address the issues, is much to costly and, if promulgated, civilization as we know it is certainly doomed.

The media enters the dance and, since the science and environment writer cannot be hired if he/she ever took a science course, proceeds to publish the most outlandish quotes from both sices.

Once all the dance partners are doing their dance, the EPA takes the tunes (comments) and attempts to bring some order to the shindig. Of course, having made their decision, EPA gives in only on small matters and denies any comment of substance. If the regulation goes to a scientific review board and the SRB says the regulation is based on bad science, EPA decides to continue anyway.

The regulation must meet it's quota of arcane acronyms. Recently, the EPA promulgated the RICE MACT in, appropriately, Subpart ZZZZ. They don't offer No-doze. A RICE is not a little white or brown kernel in a bowl, it is a reciprocating internal combustion engine. This rule regulates RICE at major HAP sources (hazardous air pollutants). The best one, is a HON. People actually talk about their HON's (Hazardous Organic NESHAP (National Emission Standard HAP (Hazardous Air Pollutant))). An acronym containing an acronym containing an acronym. Don't you feel safer already?

Once the regulation is promulgated (notice they are never put into force, they are promulgated), the trainers enter the dance. The trainers train those that have to write permits and enforce the regulation and try to entice those who have to comply with the regulation to go to some exotic place for an expensive training session. I've always liked the training sessions in a warm place in the winter. After about 5 years, half the regulators and half the regulated actually understand half the regulation. (but usually not the same half.)

The dance ends with a brand new regulation with permits written by folks who don't understand the regulation for people who don't understand the regulation, but get to spend loads of time and money complying with the regulation. Little is changed in the way of reducing pollution (remember this is why it all started), the regulated community doesn't go broke, the enviro-saviors find another cause and civilization as we know it somehow manages to survive.

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