THE GALLON ENVIRONMENT LETTER

Canadian Institute for Business and the Environment

Fisherville, Ontario, Canada

Tel. 416 410-0432, Fax: 416 362-5231

Subscriptions: subscriptions@gallonletter.ca

Vol. 17, No. 6, December 3, 2012

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This is the honoured reader edition of the Gallon Environment Letter and is distributed at no charge: send a note with Add GL or Delete GL in the subject line to subscriptions@gallonletter.ca. Subscribers receive a more complete edition without subscription reminders and with extensive links to further information following almost every article. Organizational subscriptions are $184 plus HST/GST and provide additional benefits detailed on the web site. Individual subscriptions are only $30 (personal emails/funds only please) including HST. If you would like to subscribe please visit http://www.cialgroup.com/subscription.htm If you feel you should be receiving the paid subscriber edition or have other subscriber questions please contact us also at subscriptions@gallonletter.ca. This current free edition is posted on the web site about a week or so after its issue at http://www.cialgroup.com/whatsnew.htm. Back free editions from January 2009 are also available.

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ABOUT THIS ISSUE

Our theme in this issue is the recent conference of the North America section of the Society for Environmental Toxicology and Chemistry. It is impossible to fully cover an event with more than 800 platform presentations and a similar number of poster presentation but we have selected some highlights both in this issue of Gallon Environment Letter and for some of our recent GallonDaily articles. The highlights in this issue range from behavioural changes induced by exposure to certain substances to stainless steel cook pots to the oil sands. We also cover in greater detail the Children's Safe Products Act now being implemented in Washington State. It is interesting how many reportable chemicals are found in children's products in that state, and presumably across the continent in most cases. Check out the links we provide. We also report on California's approach to discouraging toxic substances in consumer products and US EPA's Green Screen (TM) process for reducing or eliminating toxic substances for greener products.

In addition to the SETAC North America event, GallonLetter also visited the Los Angeles Green Expo. We bring you a report. In other news, Manitoba is introducing a Clean Energy Strategy, we bring you details, Highland Companies dropped its plan for a mega-quarry north of Toronto, and here is a dispute over whether pigeons or raptors should get greater protection.

By way of contrast, our editorial in this issue addresses the issue of holiday baking, or baking any time. Don't feel guilty if you don't!

Our next issue will feature the management of construction waste. We wish you a happy holiday season and the very best for the New Year. In the meantime we hope you enjoy the stories in this issue and invite you to send your thoughts and comments for possible publication to editor@gallonletter.ca.

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HOLIDAY BAKING AND THE ENVIRONMENT

Rather than reviewing environmentally preferred gifts or synthetic versus natural Christmas trees, as we have done several times in recent years, this year's holiday editorial theme is home baking. Is it better for the environment to buy or make our Christmas cake, pudding, mince pies, or whatever? As usual when reviewing comparative environmental footprints, the answer is not entirely definitive but it appears to be sufficiently clear that it may be surprising. Of course, our conclusions relate entirely to environmental impacts of production and exclude healthfulness, ingredient preferences, and other aspects.

Cakes and pies are too variable in composition to allow the kind of overview environmental comparison that GallonLetter's editor sees as most helpful for purchase or lifestyle decisions. If we have to compile a detailed environmental inventory every time we want to make a purchase or production decision then it is unlikely that we will ever be able to 'green' our personal supply chains. Inevitably, most decisions will only ever be made using general guidelines regarding environmentally preferred products. So our quick editorial review of environmentally preferred baking will be based on published European data for bread making: home baking versus industrial baking.

Bread baking is a fairly simple system for analysis because the inputs are essentially similar for home baked bread as for industrial bread. The major key differences come down to baking technology, packaging, and transportation. The environmental impact of bread packaging is quite small - most likely less than 5% of the total environmental footprint of the loaf of bread. The environmental impact of transportation is not measurable on a generic basis. Such factors as the distance from the bakery to the retail store to the purchasers's home have to be taken into account. Similar factors apply to collection of the ingredients: how far does the grain travel, how far is it from the flour mill to the bakery, and so on. While it is a gross approximation, it would appear not unreasonable to consider that the overall transportation of raw materials and finished product is not necessarily significantly different for the home baked bread as for the industrial baked bread, though in an individual case the differences could be quite large and in either direction.

So the major measurable difference comes down to the baking. Baking one loaf or one cake in a home oven almost certainly uses more energy than an industrial oven uses per unit of production. The energy used for baking of one cake or pie at home will be cut almost, but not quite, in half if two cakes or pies are cooked at the same time. If three are cooked at the same time, the energy footprint of baking will be cut even further.

There have been a number of Life Cycle Assessments of bread production. Essentially many have concluded that industrially baked bread, and, by extension, we assume cakes and pies and the like, will most likely have a lower energy footprint than home baked bread. This extends to the full environmental footprint if the industrial baking and the home baking use the same ingredients.

GallonDaily does not want this news to be seen as excessively Grinch-like, especially as baking is so much a part of the holiday season, so we conclude this editorial with a link to one of the LCAs of bread that focusses on how to reduce its environmental footprint. Published by authors at the Institute for Energy and Environmental Research in Heidelberg, Germany, the report concludes:

If land use is more important than all the other environmental impact categories: grain from conventional farming has to be preferred to grain that was produced organically

If land use is of minor relevance compared to saving of resources, greenhouse effect, ozone depletion, acidification and eutrophication: grain from organic farming has to be preferred to grain that was produced conventionally

Consumers are advised to minimize the environmental impact of bread by buying bread from organically grown cereals in a supermarket. If bread from organic grain is not available in the supermarket, customers should ask for it to increase the demand and buy it in a bakery. If baking at home, the paper concludes that cereals from organic production and flour from industrial mills have least environmental implications. Other advice is:

Use a domestic bread maker instead of an oven.
If an oven is used, increase the degree of utilisation.
Don’t use a car to transport bakery products. If a car is used, buy other groceries at the same time and without driving detours (on the way from/to work etc.).

Best wishes for your holiday season!

Colin Isaacs

Editor

Life cycle analysis of bread production – a comparison of eight different options. G.A. Reinhardt, J. Braschkat, A. Patyk & M. Quirin. Institute for Energy and Environmental Research Heidelberg. http://www.lcafood.dk/lca_conf/contrib/g_reinhardt.pdf

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SOCIETY OF ENVIRONMENTAL TOXICOLOGY AND CHEMISTRY MEETING

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The 33rd Annual Meeting of the Society of Environmental Toxicology and Chemistry North America SETAC was held in Long Beach, California November 11 - 15, 2012. The technical program began at 8 am, contained some decent time away from those rooms for coffee breaks and lunch and ended around 6 pm each day (not counting evening receptions) with another hour or more looking at technical posters and talking to people who did the research in the Exhibit Hall. There was free beer or wine at the end of each day so who's complaining although occasionally one wanted to quote Gibbs in the television show NCIS and ask, "Come on, Doc. English?".

Special symposia were held on 21st Century environmental risk assessment, the 50th anniversary of Rachel Carson's book Silent Spring, and models for collaborative problem solving in line with the theme of the conference "Catching the Next Wave: Advancing Science through Innovation and Collaboration."

Plenaries had speakers such as William J. Adams of Rio Tinto and Charles Fishman, investigative journalist and author of the Wal-Mart Effect, a bestseller with his latest book being The Big Thirst about the importance of water resources.

SETAC, with a global membership of 6,000, has units in five geographical areas, North America (founded 1979), Europe (1989), Asia/Pacific (1992), Latin America (1999) and the newest regional unit, Africa (2012) and a global World Council (2001). Through meetings of the units and global meetings, its journals, workshops and symposia, the organization tries to take an interdisciplinary approach to issues of the time: global climate change, pollinators and pesticides, life cycle analysis, ecotoxicology, developing methods of sampling for emerging contaminants including endocrine disruptors, and impacts of the 2010 Gulf of Mexico oil spill and the Canadian oil sands.

GallonLetter’s editor presented in the Interactive Poster Session held on Thursday November 15 on the title "Application of LCA to Consumer Product Environmental Claims." As a chemist working the environment field, GallonLetter's editor has been a SETAC member for a long time and thinks business would do well to pay attention to the information that is available through the organization's conference because it is very likely that some of that research will affect your business some time sooner or later.

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SETAC: A FEW SELECTED TAKEAWAYS

Some toxic chemicals are here, there and everywhere: For example, indoor dust contains a complex set of chemicals. Even though some chemicals may become restricted in commerce, homes as buildings in use and in their contents continue to release toxic chemicals. Fossil fuel and wood burning, smoking, candle burning, and bringing in outdoor dirt due to foot traffic add to toxic chemicals in indoor dust. Phthalates and brominated flame retardants are detected in indoor dust, on people's skin, and in urine.

Behavioural changes: When rats and mice ingest rodenticides but aren't killed they change behaviour. Instead of seeking shelter when a predator is around, they wander around above ground and are more likely to be prey to owls and hawks, which in turn eat more rodenticides than they would if the rat behaved normally. GallonLetter notes that in the latest CBC Marketplace episode on flame retardants, University of Toronto chemist Miriam Diamond said that exposure to some chemicals may change human behaviour as well.

Technology: Remediation through technology does help some but (for example) many wastewater treatments don't remove some chemicals of concern. If in addition to whatever remains in the waste water, the sludge is also applied to the land then the soil and runoff into streams and drinking water can release the chemicals into the environment and drinking water. Even wastewater treatment plants with tertiary treatment, which is additional to what many WWTP use, do not remove all the PPCP (Pharmaceutical and Personal Care Products) including antidepressants. Under simulated lab conditions, certain microbes were able to reduce PPCP concentrations by more than 90% but few such microbes have so far been identified in operating WWTPs.

There is no away for some chemicals: The human body, geochemical actions, bacteria and other microorganisms, and just settling into water or sediment which remains undisturbed, has been enough to render many toxic releases harmless at least for now. Although many people think bacteria and other tiny critters are invariably bad, if we harm the "good" organisms such as in the human gut, soil and water, we could really be in the chemical soup. Some of the research discussed at the SETAC conference seeks to discover treatment processes that remove these chemicals though, as some of the articles in this GallonLetter indicate, at least some regulators are turning to the concept of pollution prevention: don't use chemicals with seriously harmful effects unless necessary.

The old chemicals are still there: Many of the "old" chemicals such as mercury, lead, arsenic, PCBs, DDT, hydrocarbon pollutants, residues from munitions sites and Great Lakes Areas of Concern, and other industrial chemicals are still there because they take many years before they are removed from the environment or they create breakdown products that continue to be problematic. Even if some countries ban a chemical, others continue to allow it.

Emerging contaminants: The SETAC conference reported on the growing evidence for concern about contaminants of emerging concern including Endocrine Disrupting Compounds EDCs, natural and synthetic hormones and plasticizers, pharmaceuticals including anti-depressants and caffeine, insect repellents such as DEET, a range of chemicals in personal care products such as triclosan, flame retardants, nanoparticles - the list is long. Numerous studies document the global presence of these "new" chemicals in the environment and in many cases in animal and human bodies. Research also indicates a range of harm caused by these chemicals. Even when data is available, some of this research concludes with statements such as "uptake of DPH (Diphenhydramine - a sleep aid and antihistamine) by fish in the field was underestimated."

Dynamic Over Time and Geography: Exposure and effects vary due to many variables. Chemicals releases into one media like the air may settle on soil or water or be transported long distances which is why we have polar bears with chemicals from far away in their bodies. Nature's tendency to disperse chemicals over vast areas doesn't stop just because it might cause harm. Crop plants can take up chemicals including drugs and biocides into their roots and leaves and after eating them, humans may retain some of the chemicals as body burden or excrete some which ends up in water and soil which then is taken up by more plants and animals and in turn humans. Half life in the human body of one of the flame retardants, the time it takes rid of half of the chemical, is at least 15 years.

The types of chemicals vary e.g. personal care products contain a fatty alcohol-based detergents in a number of simple or complex forms and when released these convert to other chemicals. Any of these may degrade readily, others are not taken up biologically. The sources of the chemicals such as from personal care products may be not only from the household but from manufacturing and other commercial sources.

Increasingly there is evidence that some impacts are site specific: e.g. affected by the acidity of the water or the effect of drought. Even very tiny microorganisms as well as fish are capable of moving e.g. by swimming, either escaping toxicity or even taking it with them. Some species are more sensitive to pollution than others, molluscs may not be affected while fish might be. Changes in commerce can affect concentrations of chemicals: water shortages in some agricultural areas has fostered use of recycled water which could lead to the uptake of chemicals such as antibiotics in lettuce.

The effects of the Gulf of Mexico oil spill are different at the time of the spill compared to later but the physiological and reproductive impairment of fish and habitat may be worse over the long term than the direct killing of fish at the time of the spill. The sticky bitumen pollutants of the oil sands may not travel very far into the Athabasca River right away but in time may move to pollute further away from the source. Urban areas concentrate chemicals in geographic areas with more air pollution as well as chemical release inventories and may distribute chemicals into surrounding areas, what researchers at the University of Toronto call the Urban Travel Distance.

Low Doses: The conventional tenant of toxicology was developed hundreds of years ago by alchemist Paracelsus and that is "the dose makes the poison" or even if a chemical is detected it doesn't mean there is harm. The idea is that below a certain level, a chemical doesn't cause harm. This is being challenged as for some endocrine disrupting chemicals some researchers think that high doses might not be harmful but low doses are. In addition, for some chemicals there is agreement that there no safe levels of exposure. The research reported at SETAC doesn't provide a conclusive answer but quite a few express concern about the risk of a lifetime exposure of low or even ultra low doses of some of these chemicals which are routinely detected in drinking water.

Methods: While the public might believe that government has "tested" their drinking water, researchers don't "test" the water in a holistic way and reassure the public: well, there's nothing in there to worry about. They look for specific chemicals using validated testing methods. A number of the sessions at SETAC are focussed on developing methods and lab equipment which would meet standards for detecting chemicals and their impact on organisms, fish, wildlife and humans. Science requires that the tests be reproducible. Some of the chemicals of emerging chemicals cannot be identified through a recognized test methodology.

Methods 2 Byproducts: Just because a chemical isn't measured doesn't mean its release isn't causing harm. Commercial chemicals may be produced using starting materials, contain impurities, produce byproducts and degrade or get metabolized (converted by an organism). Even if the original chemical is low risk, any of these steps may produce contaminants which could be harmful or more harmful than the parent substance. Environment Canada has began to develop software and databases for 600 persistent and bioaccumulative chemicals to predict the chemical structure of the breakdown substances and to predict whether they are likely to be persistent or bioaccumulative.

Mixtures: Although sampling and testing may be of a number of different chemicals, the toxicity of each individual substance is usually the focus. But chemicals interact with each other and with the environment. In the Gulf of Mexico, organisms are exposed to a mix of oils: crude, weathered, oil mixed with dispersants. Efforts are underway to develop methods to test for this type of complex mixture of hydrocarbons. Even though some chemicals are in low doses, people and other organisms may ingest a whole mixture of small doses.

Society of Environmental Toxicology and Chemistry North America 33rd Annual Meeting Catching the Next Wave: Advancing Science Through Innovation and Collaboration Long Beach Convention & Entertainment Center, Long Beach, California 11–15 November 2012. Abstract Book. http://longbeach.setac.org/sites/default/files/SETAC-abstract-book-2012.pdf

and

Presentation Book. http://longbeach.setac.org/sites/default/files/2012-LB-presentations-web-10_19.pdf

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Washington State: Children's Safe Products Act

Washington State's initiative to find safer alternatives under the Children's Safe Products Act using the associated High Priority Chemicals list was presented at a SETAC poster session with Alex Stone, Chemist for Safer Alternatives at the Washington State Ecology Department speaking to it. The program is part of the State's Reducing Toxic Threats Initiative "based on the principle that preventing exposures to toxics is the smartest, cheapest and healthiest way to protect people and the environment."

The Children's Safe Product Act is in two parts. The first limited the amount of lead, cadmium and phthlates allowed in children's products sold in the state after July 1, 2009. This part was preempted when Congress passed the Consumer Product Safety Improvement Act in July 2008 but the state continues to monitor whether it needs to take action under state law. The second part of the CSPA requires reporting of chemicals of high concern for children's health. The chemicals on the list are toxic and have either been found in children's products or in human tissue. The mere presence of these chemicals is not considered necessarily to cause harm. This part 2 was not preempted by the federal law. The final rules were adopted in 2011 and beginning in August 2012, manufacturers of children's products must report to the Department if their products contain these chemicals either deliberately or due to inadvertent contamination.

The definition of children includes not only specific age groups e.g. children's cosmetics made for, use by or marketed to children under the age of twelve but also if advertised as appropriate for children, sized for children, sold in a vending machine, sold in a part of a retail store, catalogue or online web site packaged, displayed or advertised as appropriate for use by children. Among the products are toys, children's cosmetics, clothing, car seats, and products used for sucking or teething, feeding and sleeping.

There is also a list of exempt items such as chemistry sets, exclusions from cosmetics such as soaps, dietary supplements and food and drugs approved by the US Food and Drug Administration, bicycles, a large range of electronics, batteries, sporting equipment such as gloves, pucks and pads.

Reasons for the listing as a high priority chemical include

harming normal development of a fetus or child
cause cancer, genetic damage or reproductive harm
disrupt the endocrine system
damage the nervous system, immune system or organs or cause other systemic toxicity
be persistent, bioaccumulative and toxic
be very persistent and very bioaccumulative

Manufacturer means the producer of the children's product or the importer or domestic distributor. Retailers who do not know that the product is restricted from sale are not liable.

Amending the chemical list might not be easy as the State Governor issued an order to suspend non-critical rulemaking, Ecology's Director decided to proceed with a rule listing tris(1,3-dichloro-2-propyl)phosphate (TDCPP) (CAS # 13674-87-8) to the Chemicals of High Concern to Children list because it meets the criteria. This flame retardant often used in foam cushioning in car seats and furniture was added to over 800 chemicals on California's Proposition 65 list October 2011 and after a year on the list is now subject to enforcement: companies must warn the public that the product contains the chemical or take the chemical out.

Product Database

Starting with specific manufacturers of larger size, Washington Ecology is compiling a publicly available database of chemicals on the list reported in products by each manufacturer. There are currently 66 chemicals on the list. The products are by groups. When we checked there were 2470 products containing the chemicals listed. One can also search for all the reports by chemical, company or by product group. For example, for IKEA there were so far 18 filings, mostly of antimony and related products.

Each report line identifies:

component. Where the chemical is located e.g. biobased material such as leather
concentration. e.g. greater than 1,000 but less than 5,000 ppm (parts per million)
chemical function. For example, no function (contamination), preservative, coloration
product description e.g. skin care, cleansing, child seat, footwears and number (called product brick)
company e.g. Wal-Mart Stores, Inc., Gap Inc., The Gymboree Corporation
documents. If any

Each search is prefaced by the statement "The reports are based on the data provided to the agency. The presence of a chemical in a children's product does not necessarily mean that the product is harmful to human health or that there is any violation of existing safety standards or laws. The reporting triggers are not health-based values."

The list of 66 chemicals joins those from other states which have chemicals of concern lists such as California's Proposition 65 substances, Minnesota and Maine as well as other countries such as Canada, Japan, EU and Australia although not all lists are directly linked to consumer product regulations.

Interstate Cooperation

GallonLetter thinks that this type of legislation is a lesson for industry which may work very effectively to avoid regulation but when a senior level of government, such as a federal level, is perceived to leave too big a gap, other jurisdictions may try to fill that gap creating a mess of regulations for industry.

Stone's department is active with other states in the Interstate Chemicals Clearinghouse IC2, which is self described as "an association of state, local, and tribal governments that promotes a clean environment, healthy communities, and a vital economy through the development and use of safer chemicals and products."

The group is developing guidance on alternative assessment process for identifying and comparing potential chemical and non-chemical alternatives that can be used as substitute to replace chemicals or technologies.

Among the goals are:

continuous improvement to foster manufacture of products that are benign by design
reduce risk by replacing toxic chemicals in products with inherently safer alternatives
avoid substitution regret which is what happens when the replacement chemical is as bad or worse than the one replaced
alternative assessment processes which are flexible and transparent to meet a wide range of users from small, medium and large businesses.

Supporting Members include businesses, ngos, consultants and others; these pay annual dues and can participate in IC2 Council and workgroups. One of the tools is Green Screen(TM) for Safer Chemicals, a free publically available tool for chemical hazard assessment (see separate article)

SETAC 2012. Abstract: TP058 Analysis of Children’s Products for Chemicals of High Concern to Children. A. Stone, Wa Department Of Ecology / Chemist; J. Grice, Washington Department of Ecology / Waste 2 Resources Program; H. Davies, Washington Department of Ecology / Waste 2 Resources, St of Washington / Dept of Ecology; J. Williams, Washington Department of Ecology / Waste 2 Resources. Long Beach. November 13, 2012.

Paid subscribers see link to original documents and references here.

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THE GREEN SCREEN(TM)

The Green Screen was mentioned a number of times at sessions at SETAC. It began as a screening tool for chemicals in the US Environmental Protection Agency Design for the Environment Program.

The Green Screen(TM) is a freely available tool for assessing and classifying hazards for chemicals and possible alternatives and benchmarking in four categories:

avoid: chemicals of high concern
use but find alternatives
use but improve
preferred: safer chemicals.

Companies can use the screen and put "draft" on the assessment but if they want to promote the chemical or material product as having gone through the GreenScreen(TM), they have to have the assessment validated through Clean Production Action.

The tool uses life cycle thinking so that impacts during use and end-of-life are also considered.

Among the 18 hazard endpoints include:

environmental fate: e.g. persistence, bioaccumulation, evidence of long range transport
environmental toxicity: acute and chronic aquatic toxicity
human health effects - priority effects e.g. carcinogenicity, development toxicity, endocrine toxicity
human health non-priority effects: acute toxicity, systemic or organ effects, skin sensitization
physical properties: reactivity, flammability, particle size, solubility, degradation products.

The screen sets hazard thresholds so that the use can indicate whether the endpoint for that chemical is high, moderate or low.

Among the beneficial effects of the Green Screen are:

identification of chemicals of concern
the supply chain is involved in finding and evaluating alternatives
manufacturers may use the opportunity to use experts in green chemistry to find safer chemicals and products which fuel innovation
by finding the safer green chemicals in the first place, manufacturers save money when regulators target hazardous chemicals. It costs money to replace chemicals multiple times in products.

This tool is one of a number of tools for greener chemistry; some of the others include other issues such performance, energy, water and resource use, greenhouse gas emissions and ozone depletion.

The web site makes clear that to use the tool requires expertise, availability of test methods and available data.

Data Gaps

GallonLetter notes that the Green Screen(TM) begins to address the issue of data gaps. In the past, manufacturers would offer substitute chemicals with no data at all; GallonLetter's editor, when working as a product assessor, has consistently rejected these replacements because they could be worse than the ingredient they replace. It is good to see that Green Screen(TM) is in effect endorsing that position. Even so, many chemicals do not have publically available data on the full set of hazard endpoints.

Green Screen(TM) assigns a DG (data gap) for the hazard endpoint when data is not available. When there is limited data it may be sufficient to classify the chemical in Benchmark 1 (avoid: chemical of concern). Other benchmarks describe the minimum data set required to get to that level. At the Benchmark 4 (preferred safer chemical), the chemical must have sufficient data to assess all hazard endpoints.

Paid subscribers see link to original documents and references here.

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HP APPLIES THE GREEN SCREEN

The progression of laws affecting chemical use in their products has encouraged Hewlett-Packard to adopt the Green Screen (TM) (see separate article), according to Cory Robertson from HP. EU legislation banning certain heavy metals like cadmium and flame retardants meant they had to make changes to products. When a phthalate was banned, they decided that avoiding extra substitutions saved money so they moved to a non-phthalate substitute, thereby incurring the cost of transition only once. They see aligning with the Green Screen for Safer Chemicals as a cost effective action which allows for looking forward to anticipate future regulations. It also helps ease the way to obtaining eco-labels which have become a market requirement.

In order for suppliers to supply to HP, they have to provide documentation (if the company doesn't have it already) on all additives in order to be put on the approved suppliers list. Apparently just asking suppliers to complete the Green Screen was enough motivation to remove chemicals from formulations. If they were able so readily to remove these chemicals, the chemicals probably were not necessary. HP works with formulators to develop effective cleaners that meet hazard criteria. White lists tell what they can use so they don't have to rely just on lists of what they can't use.

SETAC 2012. Abstract 554 Applying the GreenScreen for Safer Chemicals to Electronics Cleaners C. Wray, C. Robertson, H. Holder, P. Mazurkiewicz, Hewlett-Packard Company. Long Beach, California. November 14, 2012

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California: Green Chemistry Bills - Deterring Regrettable Substitutions

The life cycle perspective in assessing chemicals with environmental and human health implications with the aim to replace them with safer alternatives was presented by Bob Boughton of the Department of Toxic Substances Control of the California Environmental Protection Agency. Alternative assessments have been part of the voluntary program of the US Environmental Protection Agency's Design for the Environment Program but this program will be mandatory for products which stay in California once the regulations providing the detail of how the law is to be implemented is passed.

Former California Governor Arnold Schwarzenegger signed AB 1879 and SB 509 in 2008, a set of green chemistry bills that require the DTSC to avoid regrettable releases by reviewing chemicals at the design stage of all consumer products. This seeks to avoid creating a patchwork of regulations dealing with products one by one and chemicals one by one. usually after the product has been on the market for some time causing problems. Most jurisdictions including Canada do the ad hoc regulation such as banning BPA in baby bottles without addressing whether BPA may be causing similarly harmful effects elsewhere or whether the replacement chemical for BPA may be even worse from an environmental or health point of view.

But if ever there is truth to the statement "It isn't easy being green", this is a case where the efforts of the DTSC to draft specific rules fits. One of the problems with such very innovative regulatory initiatives is that if they don't work, it might set back public support and government appetite for such approaches.

Since 2011, several informal draft regulations have been issued followed by notice not to proceed. The draft regulations issued in July 2012 were followed by a public comment period which closed in October. In the first phase, the department plans to look at a handful of chemical/products so as to develop a process that can be expanded. Chemicals are not banned but processes are in place to get them out of consumer products if possible. Some companies already follow a similar process in assessing chemicals in products.

Selected Elements of the Legislation

Among the elements in the July 2012 proposed regulations are:

The definition of consumer products covered is very broad excluding only certain items such as pharmaceuticals and certain medical supplies and historic products and second hand products.
the list of initial Chemicals of Concern will be about 1200 chemicals
there is a petition process to remove chemicals from the list (with some exceptions), to add an entire list of chemicals, and to revise the alternatives analysis threshold for a chemical in a Priority Product
if the manufacturer removes the chemical then a listed Priority Product can be removed without an alternative assessment
an extension of up to 3 years may be granted from the one year plus a one year extension if manufacturer indicate that they need that much time to assess multiple alternatives
certified assessors need 2 years experience. There is also a conflict of interest standard said to be set at a level which doesn't exclude capable organizations from participating.
regulatory responses may include use restrictions, sales prohibitions, engineering or administrative controls and research and development. Inventory recall for a product sales ban is not mandated.
within 90 days of a manufacturer/importer failing to comply with AA or regulatory response requirement, retailers must either comply or notify DTSC that they have stopped ordering the product
a response status list will list manufacturers who have provided the information, those who haven't but said why not and those who have not.
occupational health is considered as part of public health
the ability of the chemical to degrade, form reactions products or metabolize into another chemical has been incorporated into the regulations
public comment periods apply to proposed chemicals and products lists and proposed regulatory response determination
trade secret protection may not be claimed for hazard trait submission information
posting product information at point of sale is voluntary but the consumer must be informed with the required information e.g. on packaging/written material accessible without breaking the seal and for online sales, web site.

Lifecycle Approach

The regulation specifies what aspects of life cycle assessment are addressed including such elements as product function or performance, useful life, energy efficiency and others including economic impacts. GallonLetter found particularly interesting how the regulation deals with economic impacts: it is not only the manufacturer's costs which are to be reported but other costs as well:

"Economic impacts. The responsible entity shall evaluate and compare the economic impacts of the Priority Product and the alternatives. If the comparison of economic impacts leads to a determination to retain the Priority Product, then the responsible entity shall take into account all projected direct and indirect cost impacts during the life cycle of the product and the alternatives being considered. A cost impact is an increase or decrease in one or more of the following:

Capital;
Consumer costs associated with the purchase or lease and use of the product;
Government agency, public, and/or business costs associated with the product;
Jobs or businesses;
Manufacturing costs;
Marketing costs;
Materials and resource consumption costs; and/or
Waste and end-of-life management costs"

Nevertheless, as in other legislation and indeed international agreements there is a requirement that alternatives be feasible. Here the definition "Technically and economically feasible alternative" means an alternative product or chemical for which:

(a) The technical knowledge, equipment, materials, and other resources available in the marketplace are expected to be sufficient to develop and implement the alternative, and to meet consumer demand after an appropriate phase-in period; and

(b) The manufacturer’s operating margin is not significantly reduced."

GallonLetter wonders if over time to deal with this possible escape hatch adopted by some manufacturers, regulators will expand producer responsibility programs increasing the cost for handling and disposing of products containing chemicals of concern. Such fees similar to carbon taxes increase the cost and make available alternatives more economically viable choices.

Industry Comment

Various concerns were expressed by industry in the public comment period ending October 11, 2012 on the latest version of the regulation. Among the concerns expressed by Koch Industries, based in Wichita, Kansas, also known for its funding of climate denial groups, include:

difficulty of defining "safer" as part of the alternative analysis.
conflicting with federal jurisdictions including the Consumer Product Safety Commission, exceeding its authority as a state. Federal law is said to preempt certain parts of the regulation
intrusion into confidential business information by requiring unit margin and marketing information. Koch wants to self-certify as allowed with many local, state and national regulations.

Federal Cooperation

The US EPA has signed a memorandum with state DTSC to pool resources on Green Chemistry to expand pollution prevention in a scientifically sound way. Among the objectives are advancing the science of alternative assessment and developing chemical information databases.

GallonLetter notes that if California is successful in this initiative it could be seeding new ground just as the REACH initiative has been doing in Europe: to start requiring those who put chemicals of concern on the market to collect at least specified information about hazards to health and the environment before the chemical is released and to report on what evidence there is that less harmful alternatives wouldn't do the job just as well.

SETAC 2012. Abstract 551 Application of LCA in safer products alternatives analysis- a California perspective | B. Boughton. and 547.1 Introduction to the Proposed Safer Consumer Products Regulations E. Rodriguez, Department of Toxic Substances Control / Pollution Prevention and Green Technology. Long Beach. November 14, 2012.

Paid subscribers see link to original documents and references here.

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Oil Sands and Pollution in the Snow

Environment Canada researchers travelled to the Fort McMurray, Alberta area in March 2011 and 2012. They cut out cubic metres of snow from sites in growing distance from two upgraders processing the oil laden sand, packed the snow in containers and took them back to Burlington, Ontario. Joan Parrott showed some of the filters used to strain the snow as it melted arranged in the same order as the sites; the ones closest to the "stacks" were black (lots of particulate) and further out they became light coloured. Pollution concentrations of 13 priority chemicals were higher up to 50 km away but further away were not dissimilar to what is commonly found in large Canadian cities. Three snow samples nearer were toxic to fathead minnow larval at 25 to 100%. The nearer to the upgrader the more deformities in the fish post hatch with one site causing 70% of the fish to have deformities. The sampling was from about 90 sites ranging from 0 to 200 km from the upgraders. Samples from the Athabasca River into which the snowmelt flows indicated that water is not toxic to fish.

Oil sand advocates often say that significant releases are from natural erosion of the oil sands not due to mining but this study and previous studies such as Dr. David Schindler and Dr. Erin Kelly of the University of Alberta (shortened to Kelly et al) indicate that it is the oil sands operations in the Athabasca region of Alberta that is releasing pollutants to the watershed of the Athabasca River and the River itself. The Water Monitoring Data Review Committee on four studies on contamination agree with the conclusion that it is the oil sands operations introducing heavy metals and other contaminants into the area although the amount of deposition the reviewers say is still undetermined conclusively. Kelly et al's study published in the Proceedings of the US National Academy of Sciences (PNAS vol 107, 2010) demonstrated that the oil sands industry released 13 elements identified as priority pollutants (PPEs) under the US Environmental Protection Agency’s Clean Water Act, via both air and water, to the Athabasca River and its watershed. Among the releases are a group of chemicals called polycyclic aromatic hydrocarbons PAHs, listed by the US Agency for Toxic Substances and Disease Registry as ninth from the top on their list of chemicals with the highest priority to be dealt with at toxic waste sites to be cleaned up.

One of the problems is that the oil sands has been operating for years with little data being collected, relatively little is known about the natural flows in that area, and it is difficult to get agreement as to where to locate a reference site which is clean as it might have been before the start of the operations. There is also a huge discrepancy between what the oil sands facilities report to the National Pollutant Release Inventory and what Kelly et al measured as deposition of particulate matter; the Water Monitoring report says it could be that there are more fugitive sources (leakages and other uncontrolled emissions) of toxic chemicals like mercury. lead, zinc and nickel from oil sands operations than expected but "It is also conceivable that considerably more particulate matter and trace metals are being released from the oil sands facilities than is being reported in the NPRI."

Evaluation of Four Reports on Contamination of the Athabasca River System by Oil Sands Operations Prepared By: Water Monitoring Data Review Committee Peter Dillon, George Dixon, Charles Driscoll, John Giesy, Stuart Hurlbert, Jerome Nriagu Prepared For: Government of Alberta. March 7, 2011. http://www.environment.alberta.ca/documents/WMDRC_-_Final_Report_March_7_2011.pdf

SETAC 2012. Abstract 425 Larval Fish Toxicity of Snow Melt Waters from Oil Sands Areas J.L Parrott, Environment Canada / Environment Canada, National Water Research Institute / Environment Canada; W.P. Norwood, Environment Canada / Aquatic Ecosystems Protection Research Division; P.L. Gillis, J.V. Headley, M. Hewitt, J. Kirk, R.A. Frank, J.R. Marentette, M.E. McMaster, Environment Canada; D. Muir, Environment Canada / Aquatic Ecosystem Protection Research Division, Environment Canada / Aquatic Contaminants Research Division; Z. Wang, Environment Canada. Longbeach, California. November 14, 2012.

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LEGACY OF OIL SANDS DEVELOPMENT

A key issue to determining the effect of oil sands development has on the environment and human health is establishing a baseline. Derek Muir, Environment Canada scientist reported on the difficulty of assessing what the Athabasca oil sands area was like before development. The research used cores from 5 lakes within 35 km of bitumen upgrading facilities and 1 lake as a reference site, 100 km northwest of the upgraders. It is thought that only atmospheric deposits have been added to these lakes. The sampling indicated that concentrations of polycyclic aromatic hydrocarbons, which are chemicals of concern, are currently 2.5 to 23 times higher than they were pre-1960s. Climate change combined with this pollution since has "influenced lake-ecosystem functions and zooplankton assemblages in the oil sands regions. Stressors have forced freshwaters toward new ecological states largely distinct from those of previous centuries of lake-ecosystem history."

SETAC 2012. Abstract 427 A legacy of a half-century of oils sands development: the PAH and paleolimnological record in lake ecosystems D. Muir, Environment Canada / Aquatic Ecosystem Protection Research Division, Environment Canada / Aquatic Contaminants Research Division; J. Kurek, Queen’s University / Department of Biology; J.L. Kirk, Environment Canada / Research Scientist, Environment Canada / Aquatic Contaminants Research Division, Environment Canada; M. Evans, X. Wang, Environment Canada / Aquatic Contaminants Research Division; J.P. Smol, Queen’s University / Department of Biology. Long Beach. November 14, 2012.

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OIL SANDS SCIENCE NOT READILY AVAILABLE TO CANADIANS

In November, several major news media carried the story of a relatively small number of studies on the oil sands prepared by Environment Canada scientists and presented at SETAC, both in Boston in 2011 and this year in Long Beach. The media reports highlighted that pollution from the oil mining and upgraders is travelling as much as 100 km, harming fish in some areas and that the government restricted the scientists from talking to the Canadian press. Story titles included "Scientists discouraged from commenting on oilsands contaminant study" and "Harper government’s ‘muzzlers’ still discouraging scientists from speaking to reporters." Meanwhile, the same scientists were talking in a foreign country (the US).

GallonLetter finds it disturbing that our scientists are presenting for at least two years in a row crucial scientific information about the oil sands not freely available to the Canadian public. We were sitting in a number of the SETAC sessions on the oil sands by these same scientists and we have no quarrel with them. But SETAC does not allow recording or photography of the Powerpoints and publishes abstracts only. The federal government limits scientists from communicating otherwise so we assumed that we can't get a copy of these presentations which ought to be posted on Environment Canada's web site for the Joint Canada-Alberta Implementation Plan for Oil Sands Monitoring which was released in February 2012 and which committed to being transparent and accessible: "The Implementation Plan will be managed in a way that delivers integrated, credible and transparent environmental monitoring." On that web page there are some earlier reports on the process and three news releases, the last from July 2012 none of them providing the promised monitoring data made available to all which includes the type of studies that the scientists were reporting at SETAC.

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NICKEL FROM STAINLESS STEEL COOKWARE

For those of us who switched from aluminum pots to stainless steel with the idea of avoiding toxic releases, an experiment simulating home cooking shows nickel leaching from stainless steel into tomato sauce. The testing covered three variables: grade of stainless steel, cook time, and repeated cooking, for nickel leaching from stainless steel pots into tomato sauce. After two hours the amount of nickel in the tomato sauce was 4.99 mg/kg, after twenty hours 7.63 mg/kg. The "pot" decreased its release of nickel over time so the first cooking produced the highest nickel concentration at 5.76 mg/kg, and with each cooking cycle, less nickel was released.

A factsheet from the Nickel Institute says:

the Council of Europe recommends that manufacturers design use of metals and alloys intended for food contact to be as low as possible and be no more that 0.1 mg of nickel migrating per 1 kg of food.
"In one typical study, new stainless steel pots showed an average pickup of 0.2 micrograms nickel per kilogram of food cooked. After five cooking and cleaning operations, the stainless steel pots showed an average pickup of 0.03 micrograms nickel per kilogram of food cooked. These are relatively small contributions to the average range of dietary intake of 100 - 600 micrograms nickel per day." GallonLetter notes that these are significantly lower numbers of nickel released per kg of food than shown in the study reported at the SETAC North America conference.
that the risk is reduced by thoroughly washing new cookware in water and detergent and boiling water in new pots and discarding the water.

SETAC 2012. Abstract: WP267 Nickel Beyond Environmental Exposure: Stainless Steel Cookware’s Contribution to Nickel Exposure from Cooked Foods K.L Kamerud, Oregon State University; K.A. Hobbie, Oregon State University / Environmental Molecular and Toxicology, Oregon State University / Department of Environmental & Molecular Toxicology, Oregon State University; K.A. Anderson, Oregon State University / Environmental & Molecular Toxicology, Oregon State University / Dept. of Environmental & Molecular Toxicology. Long Beach, California. November 14, 2012.

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LOS ANGELES: GREEN FESTIVAL

While GallonLetter was in California attending the SETAC meeting, we visited the Green Festival held in Los Angeles on November 17-18, 2012. Unlike the pioneering EcoExpo which was held across the US organized by Nina and Marc Merson in the 1990s, the audience for the Green Festival were primarily consumers while the Eco-Expo had more business to business exhibitors with new products with the potential to become available on the market. However, there was a good range of exhibits on green topics at the LA event - green energy, burials, university degrees, business, living, kids, fashion, DIY, and community action - and many presentations at the various stages including Ed Begley, author of several books and host of a television show on green living, and Romel Pascual, City of Los Angeles Deputy Mayor for the Environment. Attendees were encouraged to "do your holiday shopping at the nation's largest green marketplace."

One comment on the Green Festival written by "David M. Los Angeles, CA" was, "I like Green Energy and kale as much as the next guy, but why include all the hippie BS like chakra alignments and magic crystals? C'mon..." Dozens of people participated in the yoga sessions so at least some people disagree. The kale referred to bags of dried kale chips and variations including sesame seeds as well as spicy seasoning to be eaten as healthy snacks. A farm coop selling one version of dried kale also sold organic dried oranges with their peel still on; there were variations including blood oranges which were really tasty. There were so many samples that one could fill up and skip a whole meal. The organic beer and wine had to be paid for but were worthwhile tasting. Here in the LA area, the servers apologize if they bring a glass of water without a straw so it is not surprising that glass straws were of interest to attendees although we can't see why straws are even necessary in most cases.

Entrance fees were only $10 but those who arrived by bicycle and parked at the Bike Valet received free admission. We took public transit from Long Beach for $2.00 per person each way, getting TAP, plastic transit cards which each rider taps on a scanner before each ride on this light rapid rail transit. They can be reloaded by credit cards or cash on the machines on the platform. The entrepreneurial spirit was strong on the train as there were a number of guys selling "brand name" chocolates and sunglasses. Even though a sign read "Eating and Drinking Not Allowed" most of our car was munching happily on large bars of something. When at one stop, a uniformed Sheriff and assistant arrived to inspect the TAP by tapping the tickets on small mobiles, the sellers scrammed pulling their carts from the train.

Among some of the 300 exhibitors at the Green Expo were:

Ford exhibited its electric and hybrid vehicles, the 2013 Focus (100% electric with a driving range of 76 miles) and the 2013 C-MAX Hybrid, both of which were available for test drives. Ford's exhibit featured how it is using renewable resources for making non-petroleum-based parts for its automobiles including a sample of beet salsa to eat which illustrated the ingredients used for bioplastics e.g. beet sugar. A fellow pressed out a blue plastic oval with the word Ford composed of 70% straw and the rest plastic which became a key ring handed out to those who watched (something else we don't need - environment grinches that we are).
Green America, formerly known as Coop America and one of the organizers of the event, provided information on topics such as green fashion, fair trade, sweat shops and socially responsible investing. It promotes socially and environmentally responsible businesses, their products and services, encourages certification at the bronze, silver and gold level and through Green Pages, a Green Business Network and this kind of festival encourages buyers to purchase green products.
Members also receive its Green American magazine. In light of yet another multitude of deaths due to fire and lack of fire escapes in a textile plant, the latest in Bangladesh, Executive Director, Alisa Gravitz wrote a timely editorial in the July-August 2012 magazine about the horrors of these sweatshops, "In 2011, US clothing sales totalled over $329 billion. To me, that's 329 billion reasons to stop buying conventional clothing and turn to green fashion."
Green Menu(TM) membership card of $25 is said to get discounts when the cardholder eats at the affiliated restaurants which are listed at three levels: vegan, vegetarian and veggie friendly.

But the most impressive of the features of the Green Festival is that finally we have seen an event recycling program that really worked. There were only a few resource recovery stations but each one had a person telling us where to put things: almost all of the items in the food service section went into the compostable bin as cutlery and most of the containers were either paper or bioplastics. One item we chucked into the garbage was scrutinized by person overseeing things who nodded that it was indeed waste only after checking it over. Time after time we have attended events, including quite a few environmental conferences where foodservice uses compostable dishware and cutlery and the location claims green practices but when it comes time to get rid of the items the only bins available are recycling (often only cans and beverage bottles) and the garbage, none of which will ever see a compost pile.

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MANITOBA: FOSSIL FUEL FREEDOM

Manitoba is adopting a Clean Energy Strategy announced November 20, 2012 by Innovation, Energy and Mines Minister Dave Chomiak who said, "Building on our strengths, this new plan sets the province on a course that will ensure reliable, affordable energy for future generations, reduce greenhouse-gas emissions and maximize local economic benefits." Previous decisions have focussed on hydro electricity rather than coal-fired power plants resulting in a power grid which is said to be 98% renewable.

The press release for the strategy lists the following as highlights:

"Canada's first Pay-as-You-Save (PAYS) financing program that covers the upfront capital costs of energy-efficiency upgrades based on the utility cost savings;
a biomass energy-support program that will help Manitoba's remaining coal users transition to renewable and locally grown biomass energy;
Manitoba's Electric Vehicle Road Map that will facilitate the adoption of all-electric and plug-in hybrid vehicles; and
the Green Energy Equipment Tax Credit for geothermal and solar-thermal heating."

The Pay as You Save initiative goes along with other encouragements towards energy efficiency and an 8-year green plan TomorrowNow said to lead to a prosperous and an environmentally conscious economy. Manitoba Hydro pays for upgrades to heating, insulation and home water heating and then the householders (starting with single family homes) pay back from the energy savings. The interest rate will be fixed at 3.9 per cent for the first five years. Examples include high-efficiency gas furnaces, geothermal systems, insulation, drain-water heat recovery systems and water-saving toilets.

Green Jobs Training

Eight courses on sustainable/green energy will be offered in a few school divisions in Manitoba to high school students. Four types of technologies, biomass, wind, geothermal and solar will be the focus. The provincial government will provide $30,000 for program development for the Technical Vocational Initiative and the Education Minister Nancy Allen announced $50,000 for purchasing equipment for the current school year.

Manitoba is also contributing $100,000 to Red River College for an electric-vehicle and demonstration centre, a partnership between New Flyer Industries, the Province of Manitoba, Manitoba Hydro, Mitsubishi Heavy Industries and Red River College. The project is receiving a federal Sustainable Development Technology Canada funding to New Flyer of $3.4 million to develop battery-electric bus propulsion technology.

A number of companies have in the last few years told GallonLetter's editor that they face skilled labour shortages as older workers retire and new company initiatives require higher or different skill sets. Programs such as in Manitoba may help although some companies may have to put more of their own money into creating skills upgrades initiatives consistent with their corporate needs.

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ONTARIO: MELANCTHON MEGA-QUARRY

The Highland Companies, with financing from a US investor group, announced that it is walking away from its application for a mega-quarry for mining limestone for aggregate in Melancthon Township north of Toronto, Ontario. The company previously bought several thousands of hectares of farmland with selling farmers saying that they believed the land was for a big potato farm.

Credit for the success of the opposition to the quarry is given by some of the media in part to activists expanding their base from pure environmentalism to including foodies and celebrity chefs who hosted SoupStock for fundraising, attracting people of broad backgrounds to the area and the campaign. Green Party of Ontario leader Mike Schreiner was part of that campaign saying that “We have to put taters before craters” highlighting the need to preserve prime farmland.

More Efficient Use of Aggregate

The Green Party of Ontario as well as seeking additional protection for Class 1 to 4 farmland and a full environmental assessment for aggregate applications also says it is committed to:

"Revising the Aggregate Resources Act to create incentives for more efficient use of aggregates, aggregate recycling, sustainable mining practices and stronger site rehabilitation efforts."

GallonLetter would really like to see planning take resource use including aggregate into account. Here in Haldimand County where multiple companies are to build windmills, instead of locating a large number of windmills together on existing industrial lands as we have seen in some of the desert areas in the US, there are single turbines scattered in various parts of the back fields due to the requirement that they be a minimum distance from the nearest receptor (house). Quite a few of the fields have been cut up with newly made winding roads, many nearly a kilometre or more long and covered with thousands of tonnes of gravel. Aside from the loss of farmland, GallonLetter projects that these roads will need more aggregate as the Haldimand clay soil gets wet. The regular rural gravel roads should be a bit more resistant to ruts but may need extraordinary gravel top up as heavy vehicles deliver wind turbine and electrical parts, equipment and cement. Some of our roads have "No truck signs" on them because of this problem. Some jurisdictions are also giving thought to planning to improve the sustainability of the cement for the wind turbine foundation which varies depending on its size but uses hundreds of tonnes of cement e.g. on one wind farm a 2MW Vesta turbine foundation used 765 tonnes of cement.

Ontario Consumption of Aggregates Projected to Increase

A provincial government study of the Aggregate Resource in Ontario in 2007 said that established licensed sites won't be able to supply a growing demand. The public are concerned about the environmental costs of extraction but want roads and infrastructure requiring aggregates for cement, construction and roads.

Total aggregate consumption in 2007 was 184 million tonnes (including about 13 million tonnes of recycled and a small amount of imported material) with over 3 billion tonnes of aggregate consumed in the last two decades. The next two decades are projected to result in an increase of at least 13% in aggregate consumption.

Aggregates include sand, gravel and crushed stone, all non-renewable resources. Aggregates are relatively cheap so transporting them long distances is not considered viable: cities have the most demand.

It seems certain that confrontation between those wishing to preserve farmland and landscapes and companies wishing to fulfill this enormous demand for aggregates for roads, wind turbines, and concrete will increase in the years ahead.

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PIGEONS AND RAPTORS AT WAR

Among the exhibits at a previously top secret code-breaking site called Bletchley Park in the UK is a room honouring pigeons which carried secret messages during the Second World War as part of the National Pigeon Service. Over 250,000 pigeons were used by the British Army, Royal Air Force and Royal Navy and 32 pigeons were decorated with the Dickin medal, called the animal Victoria Cross after the war. The birds were dropped into Nazi territory with mini-parachutes where the resistance and spies filled tiny canisters with coded messages and released the pigeons which hopefully were able to return to Britain. Recently, international attention was drawn to the finding of a wartime carrier pigeon in a chimney in a home in Surrey, UK although so far the message on its leg cannot be deciphered.

The fact that these birds were feathered heros is part of a lobbying campaign by the Royal Pigeon Racing Association to be allowed to kill birds of prey such as peregrine falcons and sparrowhawks, which currently cannot be harmed unless a license under the Wildlife and Countryside Act is issued. During World War II, raptors were killed by the military in order to protect the message-carrying pigeons. The organization wants the right to protect their birds just as a farmer would be able to protect farm animals that are threatened by predators. The discovery of the dead wartime pigeon might add impetus to the lobbying group The Raptor Alliance which seeks changes for UK pigeon fanciers which number about 60,000.

Bird Strikes

GallonLetter has to confess our bias is on the side of birds of prey partly because birds of prey also serve - at airports (domestic and military), landfills and other sites to disperse other birds. But mostly we thought that a presentation at a conference of the Bird Strike Association of Canada jives with our view that we shouldn't be putting human interests alone as the factor to consider in decisions. How many raptors would have to be killed in order to safe guard the pigeons and how would this combine with other culling of raptors for other purposes such as by farmers?

Arie Dekker, of the Royal Netherlands Air Force, Nature Bureau says that in Western society that most people believe they have a God-given right to "...Rule over the fish in the sea and the birds in the sky and over every living creature that moves on the ground…” (Genesis 1:28). He suggests that the bird strike prevention Version 1.x and 2.x is based on the idea "Birds have to make way for undisturbed aviation operations.” The rest of the talk was on how while Ver. 1 (disperse the birds) and 2 (change or remove habitat attractive to birds) both at the airport have had some success, they have reached their limits. Dekker suggests that Version 3.x shouldn't rely on population management but should shift to bird avoiding strategies. Migratory birds can't be dispersed or managed readily because they fly at unpredictable times over the airport and surrounding area, don't stay at the airport but could land outside the airport grounds. The landscape which results in bird strikes gets quite large then and it is unlikely that the public would accept the large scale culling of birds many of them threatened or endangered that would be needed.

A July 2012 report by the US Department of Transportation supports the view that the existing approaches have helped at airports but aren't effective in the spatially larger landscape. In the US, bird strikes represent 97% of the wildlife strikes on commercial airlines. Deer, turtles and other terrestrial animals are other contributors to wildlife strikes. The number of strikes per year is increasing, with 2011 at 10,083 being five times those in 1990. The total number of strikes from 1990-2011 was 119,917. Only 10% result in damage, with 7% being minor. Bigger birds like Canada geese and turkey vultures can cause more damage. Risk is increased because planes used to have 4 or 5 engines so a strike in one or two wouldn't be disabling but now jets have two engines which are also less noisy so birds may not be alarmed by them but a strike in one or two of the engines becomes more dangerous. Since 1988, globally about 230 people have been killed and 220 aeroplanes lost due to some kind of wildlife strike. From 1990 - 2011, strikes have been reported from 1,714 US airports.

Almost 75% of strikes are below 500 feet but when the distance is higher, the damage is greater and the plane is likely away from the airport boundary. The record height for a bird strike is 31,300 feet. The most attention-grabbing story of birds downing planes was of the 2009 ditching of an Airbus A320-214 into the Hudson River after leaving New York LaGuardia airport. A few minutes out Canada Geese damaged both engines The plane was nearly 3,000 feet above the ground and 4.5 miles away from the end of the runway.

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READING GALLONDAILY

If you enjoy Gallon Environment Letter or find it useful for your work or interests, may we recommend the GallonDaily report. Found at http://www.gallondaily.com , GallonDaily provides short articles and reports on topics of particular interest to green businesses. One article appears almost every day Monday to Friday - we recommend visiting at least once a week. Our real enthusiasts can also sign up for email notification as new articles are posted.