Environmental Anything v Environmental Something: Being Different

Twenty-five years ago, with a different vision about how environmental consulting should look, we opened our doors for business. We believed that science and ingenuity had a place in the market.  But, truthfully, the barriers to market entry were not very limited.  Environmental Anything would do just fine.  So, how did we start?  We didn’t put environmental in our name, we went with The Dragun Corporation.  From day one, we set out to be very different.

With an abundance of opportunities in the late 1980s, conventional wisdom suggested that if you simply follow the regulator’s requests for more work, you will have plenty of profitable work.  However, what we saw in these requests was flawed science that would not help our clients achieve their goals, and we resisted the request for more data for the sake of data.  The result: we had less short-term work, but more long-term clients.  This was different.

One of the industry limitations we recognized early was a need for more hard, scientific data that would allow for better informed decisions.  So, we tasked ourselves to write technical books and papers on our own time.  This was most certainly different.

The trend in the 1990s was to hire “any warm body,” to carry out tasks.  However, we believed that those with scientific and engineering degrees and those with a propensity to be complex problem solvers, were more suited to a long-term business model.  This was different.

And then as projects became more challenging and complex, some shied away; but we accepted the challenge.  We achieved many “firsts,” including risk-based closures and eliminating unnecessary remediation that benefited neither the environment nor the client.  This was a difference our clients appreciated.

Later, when tough economic times and shrinking market share began to reshape and test the industry, we focused on our strengths.  We were rewarded as we were engaged on challenging and consequential projects that made their way to the highest courts in North America, and another that involved aggressive negotiations with the Department of Justice.  This, too, was very different.

And today, there are global environmental challenges, leaving many with a cynical view…and so we find ourselves again taking a different view.  Because we see an abundance of opportunities and we are confident that we can, and will, find solutions – solutions based firmly on sound science and engineering principles.

In 1988, we set out to challenge the conventional wisdom and the norms of our industry.  We truly believed then, and continue to believe to this day, that there is a market for an environmental consulting company that uses science and ingenuity to find practical business solutions.  And so we remain – proudly different as we celebrate our 25th year.

The Dragun Corporation: Established May 18, 1988

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Are There NPRI Changes in The Making?

Reviewing The National Pollutant Release Inventory (NPRI) list has become increasingly important for many Ontario companies as they prepare their Toxic Substance Reduction Plans (TSRP).  As you know, your TSRP is based on your (prior year) reportable NPRI toxic substances.

If Environment Canada’s proposals are approved, the NPRI list may have some changes in the near future that may affect your future environmental reporting.

Here is a brief overview of some of the potential NPRI changes:

Proposed Reporting Threshold Changes

  • Acrylonitrile:  From 10 tonnes to 1 tonne/reporting year.
  • Particulate Matter:  If the reporting threshold for any one of the three PM fractions (total PM, PM 10 or PM 2.5) is met, then all three fractions would have to be reported.
  • Toluene Diisocyanates (2,6-toluene diisocyanate, 2,4-toluene diisocycanate and mixtures of 2,6-toluene diisocyanate and 2,4-toluene diisocycanate):  from 10 tonnes to 100 kg/reporting year and concentration threshold from 1% to .01% by weight.

Proposed Additions

  • Part 1 Additions
    • 2,2-bis (Bromomethyl) – 1,3 propanediol
    • Glycidol
    • Methyleugenol
    • Nitromethane
    • Phenolphthalein
    • Tetrafluoroethylene
  • Part 2 Additions
    • 1,6-Dinitropyrene
    • 1,8-Dinitropyrene
    • 6-Nitrochrysene
    • 4-Nitropyrene

Finally, Environment Canada is considering a change in reporting requirement for chemicals related to the oil and gas sector, and a proposal to add Naphthenic Acids (associated with oil sands).

For Ontario companies, remember the deadline for Phase II TSRP reporting is December 31, 2013.   For more information about the TSRP, see our Environmental Minute.  If you have questions about preparing your TSRP, contact Andrew Tymec (Licensed Toxic Substance Reduction Planner) atymec@dragun.com at 519-979-7300.

Water Shortages: Another Unrealized Environmental Disaster?

The drought in 2012 pushed some water supplies to dangerously-low levels and reminded us all of how deeply dependent our economy, and certainly agriculture, is on an abundance of water.

The recent drought gave rise to an increased focus on water supply, including the United Nations declaring 2013 the “International Year of Water Cooperation.”  Additionally, recent articles have surfaced that discuss future forecast of water supplies and growing populations.  Looking beyond the recent wet weather (rain and snow) that has covered much of America’s heartland, what are some of the water supply prognostications? In a word; fatalistic.

According to some sources, water is becoming an endangered resource.  The United States State Department said, “The need for fresh water will exceed the supply by 40 percent by the year 2030.”

In a March 22, 2013, article in the Washington Post, author Steve Traction writes, “The indisputable fact is that water scarcity is rapidly becoming a significant factor in the way of life in the U.S…the problem will become critical in just a decade or two…the range of effects may include…long-term restrictions on home and community water usage; significant declines in agricultural outputs as well as meat and dairy produce that require huge amounts of water for irrigation and sustenance of livestock; shortages of just about every product made using water-dependent manufacturing processes…and disruptions or complete shutdown of several critical sources of hydroelectric power.”

The author also points to dwindling water levels in Lake Mead, as well as depletion of the massive Ogallala Aquifer, which (conservatively) takes thousands of years to recharge.

More bad news on the water front:  The Christian Science Monitor (referencing a report in the journal Science) reported two years ago that that the snowpack along the Rocky Mountains is as low as it has been in the past 800 years.  But the population and demands are far greater now than they were in the 1300s and 1400s…including irrigation and power generation needs.

Water demands are growing, supplies are stressed, and our way of life is in jeopardy…

This is not the first time we have heard horrific environmental predictions.  Henry Fairfield Osborn wrote “Our Plundered Planet” in 1948 in the same year William Vogt wrote “Road to Survival.”  Both of these books issued warnings of dwindling resources, famines & over population, and an inevitable fall in the standard of living.

In 1980, there was a famous bet between ecologist and doomsayer Paul Ehrlich and economist Julian Simon.  Simon offered to let anyone pick any natural resources and a future date – according to Simon, the increased population would not cause scarcity and increased prices, rather prices would fall.  Paul Ehrlich, who famously wrote “The Population Bomb” in 1968 has long warned of dwindling resources and mass famine, took Simon up on the bet.  Ehrlich picked five metals (chrome, copper, nickel, tin, and tungsten).  The future date was 1990.  Simon was right; Ehrlich paid, but he continued to forecast more ecological doom (see John Tierney, New York Times, 1990 “Betting on the Planet”).

While bad news certainly grabs headlines, business decisions need to have a more rational approach.

As it relates to water supply, all the news isn’t bad.  In a recent book, The Big Thirst: The Secret Life and Turbulent Future of Water, Charles Fishman looks at the global water issue.  Interestingly, Fishman explains that Americans use less water today than we did in 1980, not just in per-capita terms, but also in absolute terms.  Fishman notes water use in the United States peaked in 1980 at 440 billion gallons per day.  Twenty-five years later we are using less than 410 billion gallons a day even though our population increased by 70 million people.  (See “The Big Thirst.”)

Water conservation practices and new drought resistant crops have helped us get the most out of the planet’s fixed amount of water.

The past predictions of environmental/ecological doom were wrong, because, as with other environmental threats, it’s science, ingenuity, and creative minds that find solutions, while naysayers look for the next disaster.

So, should agriculture be concerned about water supply?  Yes, we cannot afford to ignore any environmental threat.  But focus on the facts and solutions rather than hysteria.  As Julian Simon said, “There’s nothing wrong with worrying about new problems, we need problems so we can come up with solutions that leave us better off than if they’d never come up in the first place.”

Hydraulic Fracturing and Communicating Environmental Risks

At first blush, it would seem that hydraulic fracturing combined with horizontal drilling technology to harvest natural gas is an environmental panacea:

  • It provides abundant natural gas, which reduces the need for coal.  Using natural gas as opposed to coal reduces (among other emissions) global warming gases and NOx emissions – which, in turn, reduce eutrophication and acid rain.
  • The surface footprint for drilling is reduced as more subsurface drilling is accomplished with horizontal drilling.
  • And regulators from former EPA administer Lisa Jackson to state regulators have by and large offered support for the technology.

…perfect, right?  Not so much.

Why some view “fracking” as a panacea and others view it as an unacceptable risk is, perhaps, one of those environmental communication dilemmas.  Dr. Peter Sandman’s formula for environmental communication may help explain the current state of hydraulic fracturing (Risk = Hazard + Outrage).

Dr. Sandman offers a couple of other environmental risk communication thoughts to consider:

  1. Are people upset about a risk because they think it’s dangerous?  If this is the case, then the solution is to convince them it’s not dangerous, or
  2. Do people think it’s dangerous because they’re upset?  If this is the case, then the solution is to stop upsetting them.

Generally, it’s the latter of the two.  Obviously, this makes it that much more difficult from the standpoint of communication, because to stop upsetting them usually means ceasing your operations.

To make matters worse, technical people try to appease upset stakeholders by providing more data!  How well does that work?  Again, according to Sandman, they will resist data, and when you prove they are wrong, outrage is magnified.

Communicating environmental risks, whether it’s from hydraulic fracturing, manufacturing a widget, or farming, may well be one of the most challenging tasks for any business.  And if you think the answer is simply more data…then be prepared for more outrage.

Stakeholders (upset or otherwise) are informed daily by blogs, tweets, and various on-line communities.  And this reality will continue to pressure companies of all shapes and sizes to think seriously about how they communicate to minimize the outrage factor, not necessarily the hazard…and this is no small task!