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	<title>The Smug Baldy Speaks &#187; Environmental Management</title>
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		<copyright>2008 </copyright>
		<managingEditor>paulus@smugbaldy.com (The Smug Baldy)</managingEditor>
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		<itunes:subtitle>The Smug Baldy Speaks</itunes:subtitle>
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		<title>ADEM: Air Quality Twilight Zone</title>
		<link>http://www.smugbaldy.com/2008/07/25/adem-air-quality-twilight-zone/</link>
		<comments>http://www.smugbaldy.com/2008/07/25/adem-air-quality-twilight-zone/#comments</comments>
		<pubDate>Fri, 25 Jul 2008 19:12:01 +0000</pubDate>
		<dc:creator>Smug Baldy</dc:creator>
				<category><![CDATA[Alabama Politics]]></category>
		<category><![CDATA[Rants]]></category>
		<category><![CDATA[Corruption]]></category>
		<category><![CDATA[Environmental Management]]></category>
		<category><![CDATA[Pollution]]></category>
		<category><![CDATA[Stupidity]]></category>

		<guid isPermaLink="false">http://www.smugbaldy.com/2008/07/25/adem-air-quality-twilight-zone/</guid>
		<description><![CDATA[You&#8217;re about to travel through another dimension, a dimension not of logic and reason, but of political influence and deep pockets. Your are journeying into a land where up is down, and more pollution is less pollution. If you could read that signpost through the smog, you would know you&#8217;ve entered the Alabama Department of [...]]]></description>
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<p><em>You&#8217;re about to travel through another dimension, a dimension not of logic and reason, but of political influence and deep pockets.  Your are journeying into a land where up is down, and more pollution is less pollution.  If you could read that signpost through the smog, you would know you&#8217;ve entered the Alabama Department of Environmental Management Twilight Zone</em></p>
<p>In the past two days, there have been three major reports concerning the Alabama Department of Environmental Management (ADEM) that makes me wonder what kind of wacky weed these guys must be smoking.</p>
<p><span id="more-227"></span></p>
<p>First, there were two yesterday concerning Alabama&#8217;s air quality.  In the first, we learn of the State of Alabama&#8217;s <a REL="external nofollow" href="http://www.al.com/news/mobileregister/index.ssf?/base/news/1216890947103170.xml&#038;coll=3" target="_blank">proposal to codify ADEM&#8217;s illegal practice of allowing the largest air polluters in Alabama to exceed the maximum limits set by the US Clean Air Act</a>.  </p>
<blockquote><p>The Alabama Department of Environmental Management has been seeking federal approval for the rule change since 2003, when ADEM&#8217;s Environmental Management Commission adjusted the existing smokestack law at the behest of major air polluters in the state, including the power, paper, chemical and cement industries.</p></blockquote>
<p>The rule change that&#8217;s mentioned is one in which ADEM routinely allows some large polluters in the state to exceed the limit of soot they discharge into our air by an average of 2%.   In 2005, the ADEM practice was ruled illegal in federal court, although ADEM and other State entities have been in negotiations with the EPA to allow the practice (which is actually still occurring).  Interestingly, ADEM is selling this proposal as an effort to <em>improve</em> air quality, and Alabama Governor Bob Riley is in a buying mood:</p>
<blockquote><p>Riley&#8217;s office argued that the new rule change &#8220;ensures that air quality (in the state) will continue to improve.&#8221; The governor&#8217;s e-mails also state, &#8220;we are not asking for a relaxation of air quality regulations. In fact, Alabama has proposed more stringent standards for our state.&#8221;</p></blockquote>
<p>Dear Mr. Governor, allowing more pollution isn&#8217;t actually more stringent.  You see, pollution is generally bad, so any standards that allow <em>more</em> of it would actually be <em>less</em> stringent.  I know the whole more/more thing has a cool syntactic symmetry, but sometimes you have to leverage the actual meanings of words to make your arguments less insane.  </p>
<p>When you think about how ADEM and the Governor&#8217;s office could claim that allowing more pollution into Alabama&#8217;s air would improve Alabama&#8217;s air quality, you have to ask yourself just what would motivate seemingly bright and intelligent people to act so stupidly.  It turns out that there&#8217;s a clue:</p>
<blockquote><p>&#8230; the rule change the judge objected to came about because the state&#8217;s biggest power providers &#8211; including Alabama Power and the Tennessee Valley Authority &#8211; and other industrial polluters asked for it.</p></blockquote>
<p>Oh, right.  If big polluters ask for it, it must be a good thing.</p>
<p>In the second report yesterday, we learned about <a rel="external nofollow" target="_blank" href="http://www.al.com/news/mobileregister/index.ssf?/base/news/1216890985103170.xml&#038;coll=3">ADEM&#8217;s failed attempt from the 1990&#8242;s to block the use of electronic pollution monitoring equipment, in favor of using trained monkeys to spot excess soot emitted from smokestacks</a>.  OK, trained monkeys may be a bit over the top, but given that ADEM wants to use &#8220;trained smoke readers&#8221; instead of more reliable and precise monitoring instruments, the metaphor is completely appropriate. </p>
<p>The report points out that critics of this <em>Monkey&#8217;s Eyeball</em> method makes it impossible to effectively monitor and enforce federal clean air standards.  The EPA, for it&#8217;s part, would rather have something called &#8220;credible evidence&#8221; of whether a company was complying with clean air limits.  ADEM, however, would prefer the Monkey&#8217;s Eyeballs to modern measuring instruments, because they <em>think</em> it would be impossible to requiring polluters to meet clean air standards.</p>
<p>And finally, there was a report today about how <a href="http://www.al.com/news/mobileregister/index.ssf?/base/news/1216977354265960.xml&#038;coll=3">ADEM testing over the past year show high levels of mercury contamination in some species of fish</a>.  Mercury contamination has been linked to several birth defects and developmental disabilities, and the ADEM is pointing out that this is a particularly good year to avoid eating largemouth bass caught in south Alabama.  Of course, what is missing from the report is the fact that the largest source of mercury contamination in lakes and streams is industrial air pollution that eventually falls as contaminated rainwater, pollution that is commonly emitted from coal-fired power plants like the ones that ADEM is OK with emitting more soot. </p>
<p>So &#8211; there you have it &#8211; the perfect storm that is the ADEM twilight zone:  ADEM wants us to believe that more pollution will give us better air quality.  They also want us to believe that trained monkeys are capable of monitoring soot emissions as well as automated instruments.  And finally, they want us to make sure we don&#8217;t eat the contaminated fish.</p>
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