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Zero means Zero

August 19, 2011 - 9:33am — John Jackson

Two of the essential cornerstones of the Great Lakes Water Quality Agreement are the enshrinement of “zero discharge” and “virtual elimination” as guiding principles. The Council of Great Lakes Industries is urging the governments to remove these two terms from the Agreement.

In its July 2010 submissions to the Canadian and U.S. governments, the Council of Great Lakes Industries said these terms are “vague and controversial”, “have outlived their usefulness”, and “attempts to define these terms have demonstrated how difficult it is to interpret or make practical use of them.”
 
Instead of unceremoniously dumping these terms, the governments should strengthen “virtual elimination” and “zero discharge” in the revised GLWQA. Persistent toxic substances continue to have sometimes insidious, sometimes dramatic, but always serious impacts on the wildlife, birds, fish and people who live in the Great Lakes and St. Lawrence River basin. We cannot afford to continue adding to the toxic legacy we are passing on to our children and grandchildren. The only rational, sane approaches for dealing with persistent toxic substances continue to be virtual elimination and zero discharge.
 
The revised GLWQA could help us along the path to virtual elimination and zero discharge by distinguishing the terms from each other and laying down the methods for achieving them.
 
In the current Agreement, both terms are applied to the amount of a substance that can be in the discharge. The new Agreement should distinguish these terms by stating that virtual elimination is an objective for the amounts of persistent toxic substances remaining in the waters of the Great Lakes. We realize that we cannot completely remove all persistent toxic substances from the Great Lakes ecosystem. Some of them occur naturally; in addition, despite our best efforts we will not be able to remove all of the huge amounts that we have already released into the environment. Therefore, our stated goal should be to continually reduce the amounts of these substances in the environment until we have virtually eliminated them from the Great Lakes. To achieve this goal, we must stop all current discharges of these chemicals; this means we must have zero discharge.
 
Secondly we must move beyond the misleading debates that have swirled around the basin over what “zero discharge” means. The definition is quite simple. “Zero” means “zero.” Zero discharge means no release of a particular substance into the environment as a result of human activity. Those who try to redefine zero to mean “some” are people who pretend they believe in zero discharge when they really don’t.
 
The Council of Great Lakes Industries says that the “zero discharge” approach should be replaced with a risk assessment approach. In their brief to the Agreement negotiators, they say:
“The key principle of toxic chemical management under the amended Agreement should be reducing the risks posed by PBT substances in the environment. These must be viewed proportional to the risk as characterized by scientifically-sound population-level risk assessments based on the weight of evidence where the selected risk reduction approach:
§ Is based on the best available scientific, economic, and other technical information,
§ Is feasible, with benefits reasonably related to costs,
§ Allows for voluntary and other non-regulatory risk management options,
§ Provides for public participation,
§ Takes into account political, social, legal, and cultural considerations, and
§ Can be evaluated upon implementation to demonstrate effectiveness.”
 
For substances with the characteristics of persistent toxic substances, the risk assessment approach will pose ever greater threats to the well-being of all life within the Great Lakes basin. The risk approach means that we wait to take action until we can measure the impacts. It is too late at that point; damage has already been done and the hazardous chemicals have been irretrievably dispersed throughout the environment. Also a risk approach based on a balancing of economic costs inevitably downplays the significance of the health impacts and leaves an unbelievably high economic burden for future generations as they try to cope with the toxic legacy we leave them.
 
Defining zero discharge in its literal way means that we shift our focus away from the futile and misleading effort of trying to measure releases and their impacts to looking for ways to avoid using toxics in the first place. This is why a literal definition of “zero” as “zero” is critical.
 
A new GLWQA must reconfirm the zero discharge goals for persistent toxic substances. The Agreement should be amended to layout the principles to guide us down the path to zero discharge. The Agreement should adopt a Green Chemistry and Green Engineering approach as the guiding principles for getting to zero discharge. This should be defined in the Agreement to incorporate the use of substitution, alternatives and sunsetting to achieve zero discharge. The Great Lakes Green Chemistry Network has put together a Green Chemistry and Green Engineering annex for the Agreement. Citizens groups from throughout the Great Lakes basin submitted this proposal to the governments in their July 2010 submission. It can be found starting at page 60 at the following site: http://www.glu.org/sites/default/files/ENGO_GLWQAcomments_july9_FINAL.pdf
 
Finally, the GLWQA should be amended to include those substances that are not technically persistent bioaccumulative toxic substances but are regularly released and therefore persistent through repeated and regular exposure. The concern here is that even if a substance does not persist in the environment because of being long-lived, if it is regularly released, there can be constant exposure that is harmful to humans and wildlife. The virtual elimination and zero discharge goals should also apply to these substances.

 

Comments

 Great blog John. What I

August 24, 2011 - 12:33pm — John Jackson

 Great blog John.

What I perceive happening is a conceted effort to drag the Great Lakes Water Quality Agreement down to the level of national policies in the two countries.
Over the past half century we have always done the opposite - set a very high standard in the GLWQA, and used it as a springboard for upgrading national policy.  Insidiously iIncreasing health risks demand that we do no less. -  Ralph Pentland

The Council of Great Lakes

August 22, 2011 - 11:00am — Anonymous

The Council of Great Lakes Industries has suggested that the new Great Lakes Water Quality Agreement "Takes into account political, social, legal, and cultural considerations." When the 1972 GLWQA was renegotiated in 1978, we lived with a very different worldview from today. We lived in the closing years of a Keynesian era in which the US and Canadian Governments could and would commit to a philosophy of zero discharge and to a policy of virtual elimination of discharges of persistent toxic substances.

President Reagan brought all this to a halt by embracing the tenets of neo-liberalism formulated by Friedrick Von Hayek and Milton Friedman, and extending the concept "deregulation" from industrial, economic and commercial ventures to the "social envelope" in which was included environmental considerations, including environmental health. When Brian Mulroney became Canada's Prime Minister in 1984, neo-liberalism gradually filled his economic policy vacuum.

The 1970s were a golden age for social reform on the environment and on environmental health. Since the 1980s, the progressive corporatization of governments and the anti-societal influences of corporate lobbying have rendered society in the Great Lakes Basin not only vulnerable to the injurious effects of exposures to pollutants, particularly persistent toxic substances and endocrine disruptors, but also practically impotent to remedy these large scale societal ills.

Neo-liberalism, like every other -ism, will eventually come to an end. In the meantime, the negotiators of the GLWQA need to retain these principles and policies that have guided the Great Lakes community for more than 30 years in their attempts to maintain and restore water quality to protect human health and property from transboundary water pollution by persistent toxic substances. Michael Gilbertson

I didn't want to make the

August 21, 2011 - 7:24pm — Anonymous

I didn't want to make the last comment anonymous, but the website didn't give me an opportunity to do otherwise--or to put a more informative tagline than the first few words of the posting. This blog needs some competent tweaking. --Barry Boyer

Right on, John--well, maybe I

August 21, 2011 - 7:22pm — Anonymous

Right on, John--well, maybe I don't fully agree with your last paragraph, but that's a longer discussion. The subtext here (at least as I see it) is that the governments want to move toward an agreement that is "all gums and no teeth"--something that is vague and aspirational and virtually meaningless, so that whatever they decide they want to do in their bureaucratically-defined workplans is what the agreement really means. That would keep pesty enviros (such as the readers of this blog) from pointing out in a variety of public ways that the governments are failing to live up to their promises. The best way to avoid "unfulfilled promises" is not to make any, or to promise so little that you're guaranteed to get over the very low bar. Can you say "Binational Toxics Strategy?"

This is a thoughtful analysis

August 21, 2011 - 9:50am — Anonymous

This is a thoughtful analysis that provides clarity in the definitions of terms commonly misunderstand or misused, either accidentally or intentionally. The inclusion of virtually persistent substance by their high volume discharge is also contemporary and necessary. Thanks John.