Why Peeps are Stupid and Crazy

In "The Hidden Toll of Traffic Jams" the Wall Street Journal explains that exposure to fuel emissions damages brain cells, and is epidemiologically linked to autism, in addition to the well-known hazards of cancer, emphysema, asthma, diabetes, heart disease, and Alzheimer's. "New public-health studies and laboratory experiments suggest that, at every stage of life, traffic fumes exact a measurable toll on mental capacity, intelligence and emotional stability."  So maybe that explains why people are so insane and dumb that they can't even see what is right in front of them - an ecosystem in collapse.

The NYTimes recently ran a long story about widespread forest dieback, interviewing many scientists, who were openly discussing the disaster of which I've been warning for some time - imminent loss of a major carbon sink.  Here's a map of gross forest cover loss (from all sources), developed from satellite data, for the period 2000-2005.  Given the extent of dying trees I have been documenting since 2008, a current map would be considerably worse.

“If this were happening in just a few places, it would be easier to deny and write off,” said David A. Cleaves, senior adviser for the United States Forest Service. “But it’s not. It’s happening all over the place. You’ve got to say, gee, what is the common element?”

Well, finally an "expert" asked the right question!!  "...gee, what is the common element??"

Another scientist answers with what I originally suspected was the cause, as well:

“A lot of ecologists like me are starting to think all these agents, like insects and fires, are just the proximate cause, and the real culprit is water stress caused by climate change,” said Robert L. Crabtree, head of a center studying the Yellowstone region. “It doesn’t really matter what kills the trees — they’re on their way out. The big question is, Are they going to regrow? If they don’t, we could very well catastrophically lose our forests.”

But that explanation - "the real culprit is water stress" - is WRONG.   It simply doesn't explain the empirical evidence, which is that young trees being watered in nurseries are dying too.  Only the composition of the atmosphere can adequately account for the universal damage to species in every habitat.  Grrrr!  All these experts and not ONE of them even mentioned the well-established fact that ozone damages vegetation and leads to worse infestations of insects?  How well established is it?  Let's take a quick look at the US Forest Service webpage:

OZONE IMPACTS ON VEGETATION

Physiological Effects

"Ozone enters a leaf cell through openings, called stomates, that allow for gas exchange.  Once inside the leaf the ozone can result in damage to the mesophyll cells in the center of the leaf.  The mesophyll cells contain the chloroplasts where the photosynthesis occurs.  Available research does not clearly show what happens once the ozone contacts the mesophyll.  The phytotoxic effects could be the result of:

Direct contact of the ozone with the mesophyll."

"The chemical product of ozone's reaction with other gases within the leaf's air space."

"The chemical product of ozone's reaction with the cell membrane."

"Most likely, it is a product of all three listed previously."

"Ozone effects on forest vegetation are most pronounced when soil moisture and nutrients are adequate, and ozone concentrations are high. Under good soil moisture and nutrient conditions the stomates are likely to be open and  the ozone will enter  into the leaf and can damage the cells that produce the food for the plants through photosynthesis.  Reductions in the photosynthesis will decrease the amount of carbohydrates produced and stored in the roots.  Continual reduction in the annual production of carbohydrates has the potential to decrease the amount of root growth, tree height, and crown width.  Individual trees with reductions in these three areas could be less competitive then neighboring trees for sunlight and nutrients, or the chronic stress could weaken the trees and make them more susceptible to insect attacks."

After the Tar Sands Action in DC last Sunday, I drove home with companions Roger and Susan Shamel, detouring to visit Longwood Gardens in Kennett Square, PA...which happened to be in the midst of their annual chrysanthemum exhibit.

While we were en route, Roger obligingly turned around and parked the car after I spotted the remains of this immense dead tree, so that I could photograph them standing next to its weathered carcass.

The Richards Oak was over 500 years old, but the trees surrounding it, much younger, are already dying too, prematurely.  The pine tree in the background is losing its needles.

The hardwood trees have enormous holes in their trunks that are vectors for insects, disease and fungus to finish them off.

We spent hours at Longwood, which is over 1,000 acres large, wandering outside in the beautiful sunny afternoon, and then in the vast greenhouses.  I bought a book in the gift shop, "Meetings With Remarkable Trees" which I'll be returning to in another post (this one is way too long already) because it's full of amazing photographs, quotes, and anecdotes about ancient trees in England, Scotland and Ireland - some of which still live even though they are so huge and hollow that dinner parties for 20 have been served inside them!

This is one of many stately tulip poplars at Longwood Gardens, which began as an arboretum in 1798 - so there are many venerable specimens to be found.  I want to include a couple of quotes about trees from the book, to put their age in perspective:

Three centuries he grows, and three he stays,

Supreme in state, and in three more decays.

- Dryden.

Put another way...

Three hundred years growing

Three hundred years living

Three hundred years dying.

- The life of an oak according to an old saying.

Trees are tenacious life-forms, so when damage is visible, you know there is something very wrong happening in their habitat.  The lack of fall color, premature senescence, and obvious injury to leaves, are all characteristics of foliage exposed to air pollution.

I suppose many people have forgotten that children used to be able to collect autumn leaves from the ground that were still brilliantly colored, smooth and supple, and preserve them between sheets of waxed paper.  Now they are battered and brown even before they fall.

I discovered that Penn State Arboretum has an Air Quality Learning and Demonstration Center.  Their webpage has a photograph with the following caption:

"Typical ozone-induced foliar symptoms on plants native to central Pennsylvania are shown in the plants below. These species and others will be established in open-top chambers and gardens at the Air Quality Learning and Demonstration Center. By late summer of every year in central Pennsylvania, these symptoms are typical on plants of sensitive species."

Here's the companion photo:

"By late summer of every year in central Pennsylvania, these symptoms are typical on plants of sensitive species."  This should be amended to:  "By late summer, everywhere, these symptoms are now typical on all plant species."

This photograph with a Chinese Princess tree in the center has just about every symptom documented in the scientific literature.

The leaves in the foreground are necrotic - large areas of tissue are dead.

The pine needles are chlorotic - turning yellow because they cannot photosynthesize and make green chlorophyll.

Roger and Susan joked that when they remark upon dying trees at home in Massachusetts, they usually just say, "Gail was here" - so they insisted I demonstrate my secret curse on the poor Princess tree, so I reluctantly complied:  Naturam expeles furca, tamen usque recurret!  (You can drive out nature with a pitchfork, but she always returns) - from Horace.

I like the heart shaped hole - but that and the serious rotting in the trunk are not indications of an auspicious prognosis.

When I returned home I embarked on a truly overwhelming trail of information which has had me bogged down all week, so now I'm going to burden any unfortunate reader who strays by Wit's End with the results.  If you manage to slog through to the end, there are a couple of exuberantly violent youtube clips.  Somehow I discovered an annual "Air Pollution Workshop" that is to be held next May in Lithuania, with numerous sponsors including the USDA Forest Service International Programs (even though "due to anticipated budget cuts" they had to cease their own ozone biomonitoring program in the US!).  This and all the other conferences and organizations and research I will be linking to beg the question...How can so many universities, government agencies, and independent organizations be producing such a staggering volume of research about air pollution harming trees - and yet none of them are willing to acknowledge how acute the damage is?

There is a glossy brochure from the National Atmospheric Deposition Program, about "Critical Loads", which says:

"The purpose of NADP is to collect and analyze precipitation samples for acids, nutrients, base cations, and mercury to assess long-term spatial and temporal trends in wet deposition. The NADP has a longstanding interest in the effects of deposition on ecosystems, sponsoring many sessions on assessing ecosystem responses to airborne pollutants at its annual Scientific Symposium. In 2006, the NADP Executive Committee formed the Critical Loads Ad-Hoc Sub-committee (CLAD) specifically to facilitate coordination of the efforts of multiple federal and state agencies, scientists, and other partners related to the science of critical loads."

While the subject of their interest is the threshold where ecosystems become damaged or destroyed as critical loads of pollutants exceed their capacity to absorb them, the brochure is illustrated with pretty pictures like this one...as though no loads have yet become critical - ha!

One thing led to another and I found there is a manual (conveniently also available in Russian and Chinese) to identify foliar injury from ozone, from the International Co-operative Programme on Assessment and Monitoring of Air Pollution Effects on Forests, with instructions on how to select quadrates in the forest, advice on what tools to bring to take samples, and a helpful computer-generated chart to scale chlorotic mottling:

They include this helpful introduction:

"Tropospheric Ozone (O₃) pollution leaves no elemental residue that can be detected by analytical techniques. Therefore, visible injury on leaves and needles is the only easily detectable evidence in the field. Until now, experiments have concentrated on explaining the mechanisms leading to the injury observed in the experimental studies, rather than to identify and characterize the symptoms observed in the field. The evidence we have today strongly suggests that ozone occurs at concentrations which cause visible foliar injury to sensitive plants. Even though visible injury does not include all the possible forms of injury to trees and natural vegetation (i.e. pre-visible physiological changes, reduction in growth, etc.), observation of typical symptoms on above ground plant parts in the field has turned out to be a valuable tool for the assessment of the impact of ambient ozone on sensitive plant species."

They also issued their annual Executive Report, which begins with a rosy and wholly unjustified (in my opinion) assessment of the condition of forests in Europe:

"The data and findings from ICP Forests provide key information for managing the European forests in a future with changing climatic conditions and changing deposition of atmospheric air pollutants, while forest managers are also facing the challenge of halting the loss of biodiversity. Valuable knowledge concerning ongoing processes in the forest ecosystem has been obtained and utilized during the past 25 years. The future challenges of the programme lie in providing up to date information and in keeping the monitoring system sufficiently flexible that it is able to respond to ever more complex information needs."

What a "loss of biodiversity" actually means, is that certain more sensitive species are already dying out!  And then I hardly consider this chart comforting, since it means that FAR MORE TREES THAN NOT have at least some defoliation, since only the dark green bar has < 10% loss.

"There was no change in tree crown condition on 73.2% of the plots continuously assessed since 2002. Defoliation increased on 16.9% of plots monitored and decreased, indicating an improvement in crown condition, on only 10.0%."  See this figure:

This strikes me as being no cause for celebration, but rather very, very ominous since this is the percent CHANGE - the trees that didn't get worse were already at least partially defoliated in past years, so this is indicative of an ONGOING, WORSENING TREND.  Jesus!  But I guess they like to put a good spin on it, which is why they are refusing to mention that trees damaged by ozone are more prone to insect and fungal attacks, as well as damage from weather like drought and frost, in the section of their report indicates that declares insect and fungal damage is frequent:

"In 2010, over 20,000 trees corresponding to 27% of the trees with damages recorded displayed symptoms caused by ‘insects’ (Fig. 2-5). Roughly half the insect caused symptoms were attributed to leaf-eating insects (defoliators) with the remainder due to wood borers and other insects. Around 15% of trees (just over 11,000) had damage caused by ‘fungi’. ‘Abiotic agents’ such as drought or frost were responsible for damage in about 10,000 trees.  ‘Direct action of man’ includes damage induced by harvesting operations or road construction. On roughly 20,000 trees, damage was registered but the cause could not be identified. Identification of specific types of tree damage requires highly specialized expert knowledge. Damage due to ‘air pollution’ only refers to the direct impacts of smoke or gaseous pollutants, indirect effects were not assessed."

Great.  They couldn't identify the cause of damage to 20,000 trees  - but "indirect effects" of air pollution - like ozone absorption! - "were not assessed".  It's really quite astonishing how anyone can examine the results in the accompanying chart and not be in a complete panic.  Damages were detected in SIXTY-FOUR percent of all trees surveyed.  So, right there, you know of the remaining 36%, some may well be damaged but it just isn't visible yet (remember..."even though visible injury does not include all the possible forms of injury to trees and natural vegetation (i.e. pre-visible physiological changes, reduction in growth, etc.")  Furthermore, almost as many trees showed no signs of insect or fungal activity but were damaged nonetheless - by unidentified or other causes - no doubt by the indirect, un-assessed effects of pollution.  This is eerily similar to foresters blaming bark beetle damage on temperature - even though the aspen in the same location are also dying, for "unknown" reasons, since they don't host the bark beetle.

Anyway...I also perused the proceedings of  the COST (European Co-operation in the Field of Scientific and Technical Research) "Ozone, Climate Change and Forests" conference held in Prague last June.

Affiliated with that group is the International Union of Forest Researchers, and the Journal of Biogeosciences and Forestry, published by the Italian Society of Silviculture and Forest Ecology, which posits the following (Hallelujah!  This premise is what got me banned from commenting on Real Climate - but then, the Europeans are always in the vanguard when it comes to caring for the environment, as opposed to trashing it just because they can, like Americans):

"Ground-level ozone is recognized as a global agent of climate change, which requires merging research on air pollution and changing environment into one common perspective. The separation between these two research communities needs to be overcome.  The argumentation is based on the capacity of ozone to interact in tree and forest ecosystem response with other environmental factors like CO₂, N and drought, even driving below-ground processes and influencing carbon sink strength and pool formation in the entire plant-soil system.  Effects on competitiveness and stress defence, as mediated through genotype and site conditions, demand for enhanced research efforts on ozone effects on plant competition and biodiversity. In addition, awareness has proceeded recently about ground-level ozone as a local towards trans-continental agent, with new “hot spots” of distinctly enhanced regimes arising both in the northern and southern hemisphere. Conversely, ozone effects on global C fixation and storage remain uncertain, mostly because prognoses suffer from the lack of empirical databases and, hence, rigorous validation of modelling. Integrated research concepts are required that unify modelling with ecologically relevant experimentation on the actual O₃ uptake and the sensitivity per unit of O₃ uptake (“effective dose”) in trees and forests, in order to develop robust tools for reliable O₃ risk assessment."

And of course, the United Nations must also have a forum on Forests, to be held in Istanbul in April, 2013.

Meanwhile next week in Raleigh, NC the AQAST team will be meeting with members of NASA and EPA (more on their research program later).

CEAM has a website, ozoneinjury, which states:

"Ozone is one of the most important pollutants in large areas of Europe. There is evidence that the ambient ozone concentrations found in Europe can cause a range of effects to vegetation, including visible leaf injury, growth and yield reductions, and altered sensitivity to biotic and additional abiotic stresses. Since ozone pollution leaves no elemental residue that can be detected by analytical techniques, visible injury on needles and leaves is the only easily detectable evidence in the field."

Most exciting, they provide an entire library of photos of ozone injury on different species, induced by deliberate controlled exposure!  Oh yes!  I highly recommend the list of over 50 types of plants to compare them to the leaves I've been posting on this blog for the past couple of years - following are a few copied from their survey.

 Acer

 Hibiscus

 Populus

 trifolium

Viburnum

Vitig vinifera - compare it to the grapevine leaves in the greenhouse at Longwood:

Those leaves and the hydrangea below are excellent examples where older leaves exhibit more severe injury from a longer period of exposure, while younger leaves that have emerged more recently are relatively unblemished and still green - exactly as described by the aforementioned guide to identifying injury from ozone:

"Symptoms are more severe on mid-aged and older leaves than on younger leaves. Older leaves are the first to develop symptoms (age effect)."  First, their fumigated plant:

Here's the hydrangea at Longwood, next to the Princess tree.  If this damage were frost or drought, the newer leaves wouldn't be unscathed.

This classic stippling and speckling is reproduced on many other websites that document ozone damage, at various US government agencies.

The EPA, Forest Service, Department of Agriculture, and National Park Service all have photos of leaves damaged by ozone that look exactly like these.  What they rarely discuss is that the background level of ozone is inexorably rising.

They also don't tell you that every single species is now affected, not just those designated "sensitive".  The unappreciated significance of this is that chronic, constant, cumulative damage from exposure to low background levels (low as opposed to extremely high but episodic peak levels...not low as compared to natural, pre-industrial levels) is much more toxic than assumed.

Deciduous and coniferous trees alike are dying.

It's horrible to contemplate, so for the rest of this post we will have mostly just flowers from the greenhouse, especially since I'm going to post a whole bunch of boring, confusing, headache-inducing  (at least for me!) hard science.  I hadn't expected to be especially impressed by chrysanthemums, but I was!

Enjoy the flowers, because the rest will be tedious excerpts of arcane research (you can skim most of it) from the busy busy scientists, who are toiling tirelessly to decide just how much ozone we're putting in the air, where it's coming from, and where it's going, and what can be done about it (nothing).  Always curious as to whether it's worse because of emissions from burning ethanol, I felt obliged to peruse a draft EPA report, "Biofuels and the Environment, First Triennial Report to Congress."

I am quite proud to share some of it, since every page is stamped:  DO NOT CITE OR QUOTE.

"The biofuel industry is poised for significant expansion in the next few years. A variety of new technologies likely will be implemented and old technologies modified to meet the demands of affordable and sustainable petroleum fuel alternatives. As emphasized by Congress in requiring triennial biofuel impact assessments, it is important to evaluate the environmental implications associated with the ongoing growth of the dynamic biofuel industry. However, as noted earlier, the inherent complexity and uncertainty of environmental impacts across the biofuel supply chain make it difficult to provide assessments that are sufficiently definitive to inform environmental decisions."  (p. 6-8)

"Increasing biofuel use presents the potential for distinct health effects separate from the known impacts of fossil fuels. The fate and transport of these new fuel blends in the environment and the subsequent exposures and human health effects have not been fully studied. Drawing definitive conclusions on health impacts is not realistic at this time, given the unknowns surrounding the feedstocks, technologies, and fuel blends that will be used to meet target volumes, and the relatively limited availability of toxicological data to directly evaluate the potential health effects of the various emissions.  Health effects will be assessed in the 2013 report, provided adequate data are available."  p. 7-2

"4.5.1 Air Quality

The primary impact associated with biofuel end use is air quality. Section 211 (v) of the Clean Air Act requires EPA to study the air quality impacts associated with the use of biofuel and biofuel blends. EPA has already adopted mobile source emission control programs that reduce air pollution emissions and improve air quality. If necessary, EPA will issue further regulations to mitigate adverse air quality impacts as a result of increases in biofuels."

"4.5.1.1 Ethanol

The following discussion is based on E10, because considerably more information is available about its use. A wide variation in evaporative and tailpipe emissions have been reported due to a range of factors, such as the age of the vehicle, the power output and operating condition of the engine, the fuel characteristics, how the vehicle is operated, and ambient temperatures (Ginnebaugh et al., 2010; Graham et al., 2008; Yanowitz and McCormick, 2009)."

"In the RFS2 RIA, EPA projected decreases in emissions of carbon monoxide, benzene, and acrolein in 2022 under the RFS2-mandated volumes of biofuels, while NOx, HC, and the other air toxics, especially ethanol and acetaldehyde, were projected to increase. The inclusion of E85 emissions effects would be expected to yield larger reductions in CO, benzene, and 1,3-butadiene, but more significant increases in ethanol, acetaldehyde, and formaldehyde (U.S. EPA, 2010b)."

"Studies of biodiesel and biodiesel blends show varying results depending on the fuel (i.e., type of biodiesel, biodiesel blend, type of base diesel), the vehicle being tested, and the type of testing. In general, combustion of biodiesel has been shown to decrease PM, CO, and HC emissions, increase NOx emissions, and increase ozone-forming potential (Gaffney and Marley, 2009; U.S. EPA, 2002)."

It is baffling.  If health effects on people - let alone plants - from emissions of biofuels v. fossil fuels are unknown (likely worse) - why the hell are we racing ahead to use them?  Hmm.  There is a series of tables towards the end of this draft report, and incredibly, the block on the far right, to describe the statutory authority of EPA to regulate "Use of Biofuel", is empty on almost all of them.  So, maybe that means they are charged with considering production, transport and storage, but not  the emissions from use.  Because we don't want to think about that.

According to NOAA's updated annual Greenhouse Gas Index, nitrous oxide emissions - the primary precursor to ozone -  continue to climb:

So how could we expect the levels of ozone to do anything BUT rise?

This paper, "Increasing background ozone in surface air of the United States" reported back in 2000 that:

"The long-term trend of background O3 in surface air over the United States from 1980 to 1998 is examined using monthly probability distributions of daily maximum 8-hour average O3 concentrations at a large ensemble of rural sites.  Ozone concentrations have decreased at  the  high end of the probability distribution (reflecting emission controls) but  have  increased  at  the  low  end.  The  cross-over  takes place between the 30th and 50th percentiles in May-August and between the  60th  and 90th  percentiles during  the  rest of the year. The increase is statistically significant at a 5% level in spring and fall, when it is 3-5  ppbv.  The maximum increase is in  the  Northeast.  A  possible explanation  is an increase in the O3 background transported from outside the United  States.  Better  understanding of  the  causes of  the increase is  needed because of  its  implications  for  meeting O3  air  quality  standards."

Okay, I slipped in some damaged camelia leaves.

It's likely that camelias appear more damaged than some other plants in the greenhouse, because they are very long-lived and evergreen.

"Ozone in surface air  is produced by photochemical oxidation of hydrocarbons and CO in the presence of nitrogen oxides (NOx =  NO q- NO2). High anthropogenic emissions of NOx and hydrocarbons in populated regions of the United States result in surface O3 concentrations that exceed air quality standards. As of 1998, 51 million persons in  the  United  States lived in areas failing  to  meet the current O3 standard (120 ppbv, 1-hour average), and 130 million persons lived in areas where O3 levels exceed the new proposed standard (80 ppbv, 8-hour average) [(EPA), 2000].  It  is estimated that anthropogenic emissions of hydrocarbons in the United States decreased by 30% from 1980 to 1998, while NO•  emissions remained constant within a few percent [EPA, 1998, 2000]. Hydrocarbon emission controls are credited for abating the most extreme O3 pollution events, but decreases in less extreme statistics of O3 concentrations have been far less conclusive, leading to concern over the achievability of the new standard [Lefohn et al., 1998]."

"Altshuller and Lefohn [1996] point out that an important consideration for pollution control strategies is the O3 background present in surface air over the United States.  They define this background as the O3 concentration that would prevail in the absence of domestic anthropogenic emissions.  They discuss different ways by which it  may be estimated including measurements at clean sites, analysis of the prob-

ability distribution of O3 concentrations, and correlations with reactive nitrogen oxides (NO•,  including NO•  and its oxidation products). By examining results from these different approaches they estimate a background daytime concentration of 35 q- 10 ppbv in summer, amounting to almost half of the new air quality standard.  Although  Altshuller and Lefohn [1996] view this background as natural, there is

in fact good evidence that it includes a major anthropogenic component associated with intercontinental transport of pollution [Marenco et al., 1994; Wang and Jacob, 1998]. The lifetime of O3 in the free troposphere is sufficiently long (several weeks) that anthropogenic O3 pollution can circumnavigate  the  globe and enhance O3 over the entire northern midlatitudes belt  [Logan, 1985]."

"We examine here the long-term trend in the O3 background in surface air over the United  States from 1980 to 1998 by analyzing the probability distribution of O3 concentrations at rural sites. A trend in the background could have important implications for meeting O3 air quality standards.  Jacob et al.  [1999] projected that industrialization of eastern Asia would increase mean surface O3 concentrations  over the United  States by 2-6  ppbv over the 1985-2010 period, significantly offsetting the benefits of domestic emission controls. Observations at Whiteface Mountain (1480 m) in New York State indicate an increase of 4q- 2 ppbv over the period 1974-1995 [Oltmans et al., 1998]. Ozonesonde data in the free troposphere at Wallops Island (Virginia) and Boulder (Colorado) show no significant increase over the past two decades but the data are sparse [Oltmans et al., 1998; Logan et al., 1999]."

I got a really awful feeling reading that report because it refers to the work of Allen Lefohn, who like a recurring nightmare, continues to muddy the discorse with complicated, confusing, misleading publications.  That of course is just the point.  Delay, delay, delay.  Every day that regulations aren't tightened, or aren't enforced, is another day of bigger profits for the people who pay him.  Actually maybe he's more like a zombie.  He just won't go away! 

But then I suppose if you've got the American Petroleum Institute giving you money to pop up at conferences and submit comments to the EPA regarding proposed regulations, why not?

Arg!  I've written about this despicable little man before.  It pleases me to do so because I think it's important to single out malefactors, like the Koch Brothers, who consciously make choices which lead directly to destruction of the natural world - and ultimately, us.  The Kochs are the big fish, why pay the moneh, while Allen Lefohn is like the biostitutes - academics and regulators who falsify environmental impact statements, to keep their paychecks.

One of the things Lefohn likes to do is attack the Policy Relevant Background level of ozone, so let's take a look at the eponymous AQAST website to see what they have to say...I, too, am often aghast at the heedless rise in ozone precursor emissions!

Of course the pertinence of PRB hardly matters until the next round of reconsideration, since Obama told the EPA to not tighten standards based on the previous Science Advisory Report that had concluded current limits are unhealthy - but the debate rages on in advance of their next scheduled review, as indicated in this slide presentation prepared by Pat Dolwick of the EPA (which doesn't mention Lefohn by name but alludes to him in the very last notation which I have italicized):

Policy-relevant background (PRB)

• What is PRB and what role does it play in the NAAQS setting & implementation process?

– PRB is only used in the health risk and exposure assessments

– 12 cities (2 in CA, rest in EUS), traditionally warm-season only

– See samples on next slide

• PRB in the 2008 NAAQS review:

– Defined to be those ozone levels associated with all sources except North American anthropogenic NOx, VOC, and CO,

– Concentrations were estimated through GEOS-Chem (Fiore et al., 2003),

– Vary spatially and temporally, highest in Spring and at high-altitude sites,

– Range from 25 +/- 10 ppb, tend to decline during conditions of high episodic O3,

– Criticized by some as underestimating this background and therefore inflating risks 

associated w/ O3 above PRB.

I'd also like to know where all that methane is coming from, wouldn't you?  Since it too is an ozone precursor.  Of course some of it is from melting permafrost peat - not much to be done about that.  But it would appear a significant amount comes from fracking leaks, never mind all the escaped volatile organic compounds, as described in this review, "Potential Shale Gas Extraction Air Pollution Impacts," which quotes the EPA,

"Ground level ozone also interferes with the ability of sensitive plants to produce and store food, making them more susceptible to certain diseases, insects, other pollutants, competition and harsh weather. It damages the leaves of trees and other plants, and reduces forest growth and crop yields, potentially impacting species diversity in ecosystems (EPA, 2008)."

And then goes on to say:

"The best explanation for formation of ozone that I know of is contained in the 2008 EPA Air Quality Criteria for Ozone and Related Photochemical Oxidants. Ozone is a secondary pollutant that is formed in polluted areas by atmospheric reactions involving two main types of precursor pollutants - volatile organic compounds (VOC’s) and nitrogen oxides (NOx). Carbon monoxide (CO) from incomplete combustion of fuels is also an important precursor for ozone formation. The formation of ozone and other oxidation products (like peroxyacyl nitrates and hydrogen peroxide), including oxidation products of the precursor chemicals, is a an extremely complex reaction that depends on the intensity and wavelength of sunlight, atmospheric mixing and interactions with cloud and other aerosol particulates, the concentrations of the VOC’s and NOx in the air, and the rates of all the chemical reactions.

"Map 3, NO2 Emissions in Tons for 2002 presents facilities releasing NO2 over the 4 state study area and an estimate of their NO2 emissions per tonnage category. Remember NO2 is a precursor gas for formation of ozone; areas downwind of these sites will thus have increased reactant for the formation of ozone. VOC’s from shale gas extraction activities may react with NO2 from these sources."

The greenhouse at Longwood has a long hallway where they display, on a rotating basis, some of their bonsai trees, of which several are a hundred years old.  They are more stalwart testimony that trees, even harshly pruned with restricted roots, can continue to thrive despite harsh circumstances.

In a webpost last October 2010, Professor Donald Brown of Penn State wrote about the ethics - or lack thereof - of industries that engage in deliberate attempts, through lobbying and by funding disinformation campaigns, to delay any regulation to curb emissions that cause climate change.  He mentions the excellent book, "Merchants of Doubt" which describes the similarity of their strategy to that of the tobacco industry's methods to emphasize uncertainty.  Here was my comment:

The same energy companies should be held criminally liable for their even more successful, ongoing campaign to obfuscate the science of ozone damage, and to delay regulation of the toxic emissions created when their products are burned, which cause cancer, emphysema, and asthma, as well as forest death and significantly diminished yields of important food crops such as wheat, soybeans, corn and rice.

This post has excerpts of testimony by Allen Lefohn (towards the end of it), who has been paid by the likes of The American Petroleum Institute, Northern States Power Company, Washington Water Power Company, and the Edison Electric Institute to testify as an expert witness and produce papers undermining the consensus about the impacts of ozone, acid rain, and other pollutants. Basically he has made a career out of impeding the EPA's ability to restrict greenhouse gases.

Research published this year, "Improved estimate of the policy-relevant background ozone in the United States using the GEOS-Chem global model with 1/2° × 2/3° horizontal resolution over North America" enlightens us further:

"Abstract

The policy-relevant background (PRB) ozone is defined by the US Environmental Protection Agency (EPA) as the surface ozone concentration that would be present over the US in the absence of North American anthropogenic emissions. It is intended to provide a baseline for risk and exposure assessments used in setting the National Ambient Air Quality Standard (NAAQS). We present here three-year statistics (2006-2008) of PRB ozone over the US calculated using the GEOS-Chem global 3-D model of atmospheric composition with 1/2° × 2/3° horizontal resolution over North America and
adjacent oceans (2° × 2.5° for the rest of the world). We also provide estimates of the US background (no anthropogenic US emissions) and natural background (no anthropogenic emissions worldwide and preindustrial methane)."

"PRB is particularly high in the intermountain West due to high elevation, arid terrain, and large-scale subsidence. We present for this region a detailed model evaluation showing that the model is successful in reproducing ozone exceedances up to 70 ppbv. However, the model cannot reproduce PRB-relevant exceptional events associated with wildfires or stratospheric intrusions. The mean PRB estimates for spring-summer are 27 ± 8 ppbv at low-altitude sites and 40 ± 7 ppbv at high-altitude sites. These include a mean enhancement from intercontinental pollution and anthropogenic methane of 9 ppbv at low-altitude sites and 13 ppbv at high-altitude sites. The PRB is higher than average when ozone exceeds 60 ppbv, particularly in the intermountain West. The annual 4th-highest PRB values in the intermountain West are typically 50-60 ppbv, as compared to 35-45 ppbv in the East or on the West Coast.  Our PRB estimates are on average 4 ppbv higher than in previous GEOS-Chem studies and this may reflect higher lightning, increasing Asian emissions, and improved model resolution."

"The US Environmental Protection Agency (US EPA, 2006) defines the policy-relevant-background (PRB) for ozone air quality as the surface ozone concentration that would be present in the US in the absence of anthropogenic emissions from North America (defined as the ensemble of the US, Canada, and Mexico). The PRB is used in the setting of the National Ambient Air Quality Standard (NAAQS) to estimate the maximum ozone reduction that could be achieved through North American emission controls.  It provides a baseline for risk and exposure assessments. The present US NAAQS is 75 ppbv (annual 4th-highest daily maximum 8-h average concentration), but the EPA is considering
decreasing it to a value in the 60-70 ppbv range. As the standard becomes more stringent and approaches the PRB, accurate specification of the PRB becomes increasingly important."

"Ozone is produced in the troposphere by photochemical oxidation of CO and volatile organic compounds (VOCs) in the presence of nitrogen oxides (NOx ≡ NO + NO2). It is also transported to the troposphere from the stratosphere. The NOx, CO, and VOC precursors of ozone have major anthropogenic sources from fuel combustion as well as natural sources including lightning, wildfires, and the biosphere. Ozone has a lifetime of only a few days in the continental boundary layer but weeks in the free troposphere (Y. Wang et al., 1998; Fiore et al., 2002). Ozonesonde, aircraft, and satellite observations show typical ozone concentrations of 50-70 ppbv in the free troposphere over North
America (Thompson et al., 2007; L. Zhang et al., 2010), with frequent occurrence over 80 ppbv in plumes from intercontinental pollution, fires, and stratospheric intrusions (Heald et al., 2003; Nowak et al., 2004; Bertschi and Jaffe, 2005; Liang et al., 2007; Thompson et al., 2007; Oltmans et al., 2010). Subsidence of this high-ozone air to the surface could result in PRB values approaching or exceeding the NAAQS (Jaffe, 2011). However, ozone decreases during entrainment into the boundary layer because of dilution, deposition, and chemical loss (Fiore et al., 2002; Hudman et al., 2004; L. Zhang et al., 2009; Cooper et al., 2011)"

"The PRB ozone is not an observable quantity, if only because of the contribution of North American anthropogenic sources to the northern mid-latitudes ozone background. It needs to be calculated with a global model of atmospheric composition that is evaluated with observations at remote sites where the PRB drives much of the variability....Here we present a further update of PRB, US background, and natural background ozone estimates with a 3-year (2006-2008) GEOS-Chem simulation at 1/2° × 2/3° resolution featuring a number of improvements over previous versions. Our motivation for this work is to assist the EPA in its revision of the ozone NAAQS, scheduled to be released in 2014. We include a detailed model evaluation in the intermountain West where elevated PRB is of particular relevance to the NAAQS."

Then there is this ominous statement:

"If the NAAQS is lowered in the 60-70 ppbv range, areas of the intermountain West will have little or no ability to reach compliance through North American regulatory controls."

Followed by this conclusion:

"The annual 4th-highest PRB value in the model (representing the minimum standard achievable through suppression of North American anthropogenic emissions) is typically in the 35-45 ppbv range over the East and the West Coast but 50-60 ppbv in the intermountain West.  Such high PRB values in the intermountain West compared to the proposed revisions of the ozone NAAQS (60-70 ppbv) suggest that special consideration of that region may be needed in the NAAQS-setting process."

They have lots of charts but this is my favorite - the model line is red, the observed levels are black, the Policy Relevant Background is blue, and the natural is green.

Isn't this the same west where the pine beetle is killing trees?  Here's Figure S2, which depicts the ozone concentrations in the northeast, Great Lakes region and Southeast.  The PRB is significantly lower than the west, although the observed levels are high, especially Georgia!

Another recent publication from AQAST, "Transport of Asian ozone pollution into surface air over the western United States in spring," states:

"Many prior studies clearly document episodic Asian pollution in the western U.S free troposphere. Here, we examine the mechanisms involved in the transport of Asian pollution plumes into western U.S. surface air through an integrated analysis of in situ and satellite measurements in May-June 2010 with a new global high-resolution (~50x50 km) chemistry-climate model (GFDL AM3). We find that AM3 with full stratosphere-troposphere chemistry nudged to reanalysis winds successfully reproduces sharp ozone gradients above California due to the interleaving and commingling of Asian pollution and stratospheric air associated with mid-latitude cyclone passages.

"Asian pollution descends isentropically behind cold fronts, with a maximum enhancement to ozone at ~800 hPa occurring over the southwestern U.S., including the densely populated Los Angeles Basin. During strong episodes, Asian emissions can contribute 8-15 ppbv on days when peak observed daily maximum 8-hour average ozone (MDA8 O3) levels are above 60 ppbv. We find that in the absence of Asian anthropogenic emissions, 20% of MDA8 O3 exceedances of 60 ppbv in the model would not have occurred in the southwestern USA. For a 70 ppbv threshold, that statistic is 49%. Our analysis highlights the potential for trans-Pacific transport to contribute to high surface ozone episodes over the western USA. We further demonstrate a proof-of-concept approach using near real-time space-based CO measurements to identify strong Asian pollution plumes off the U.S. west coast and to serve at least as a qualitative early-warning indicator (lead time of 1-2 days) for the Asian enhancements to western U.S. surface ozone."

In this presentation to the US Dept of Ag. in 2010 by Kevin Percy, PhD, "Growth Responses of Trees to Tropospheric Ozone: Alternatives in Dose‐Metrics to EPA’s Proposed W126 Secondary NAAQS", he is sharply critical of Lefohn's pet formula, for being needlessly complicated.  One of his slides specifies that the method is flawed because of a:

"2. Lack of synchrony in O3 exposure and plant uptake

• Grünhage et al. 1994. Environmental Pollution 85, 125‐129.

“atmospheric conditions that facilitate the daily occurrences of peak (highest) O3 concentrations in general do not coincide with the conditions that promote plant uptake.”

Discover magazine quotes Dan Jaffe, professor of Atmospheric and Environmental Chemistry at U Washington and Mount Bachelor Observatory and co-author of a paper on Asian ozone coming to America.

"It found that ozone levels above western North America creep upward every spring. 'When air was coming from Asia, the trend was strongest. That was the nail in the coffin,' Jaffe says. 'The increase was estimated at 0.5 part per billion [ppb] per year. But that’s huge. In 10 years that’s another 5 ppb. Let’s say the epa orders a 5 ppb reduction and we achieve that, and yet, because of the growing global pool, in 10 years that gets wiped out. We’ll have to keep reducing our emissions just to stay even.'”

From the paper published in Nature:

"In the lowermost layer of the atmosphere—the troposphere—ozone is an important source of the hydroxyl radical, an oxidant that breaks down most pollutants and some greenhouse gases¹. High concentrations of tropospheric ozone are toxic, however, and have a detrimental effect on human health and ecosystem productivity¹. Moreover, tropospheric ozone itself acts as an effective greenhouse gas². Much of the present tropospheric ozone burden is a consequence of anthropogenic emissions of ozone precursors³ resulting in widespread increases in ozone concentrations since the late 1800s^{3, 4, 5, 6, 7}. At present, east Asia has the fastest-growing ozone precursor emissions⁸. Much of the springtime east Asian pollution is exported eastwards towards western North America⁹. 

"Despite evidence that the exported Asian pollution produces ozone¹⁰, no previous study has found a significant increase in free tropospheric ozone concentrations above the western USA since measurements began in the late 1970s^5, 11, 12. Here we compile springtime ozone measurements from many different platforms across western North America. We show a strong increase in springtime ozone mixing ratios during 1995–2008 and we have some additional evidence that a similar rate of increase in ozone mixing ratio has occurred since 1984. We find that the rate of increase in ozone mixing ratio is greatest when measurements are more heavily influenced by direct transport from Asia. Our result agrees with previous modelling studies, which indicate that global ozone concentrations should be increasing during the early part of the twenty-first century as a result of increasing precursor emissions, especially at northern mid-latitudes¹³, with western North America being particularly sensitive to rising Asian emissions¹⁴. We suggest that the observed increase in springtime background ozone mixing ratio may hinder the USA’s compliance with its ozone air quality standard."

I suppose I could pick on someone other than Lefohn, because there are legions of other consultants whose insidious agenda is to impede regulation.  I'll get to some.  It's too bad that Merchants of Doubt didn't have a chapter on ozone, because the exact same methods of casting doubt on science that have been used to attack efforts to pass legislation on climate change have been used, to even greater effect, to hide the harm air pollution is doing to the forests and agricultural crops.

Remember the Cleaner?  He's the guy in the movies - or maybe in real life, too - that criminals hire to remove all traces of a murder before the police arrive.  That's what I call Lefohn, who tinkers with the evidence to hide the ugly truth.  The important point to remember - the role of the Cleaner isn't to prove that ozone isn't harmful, that would be silly.  His role is to delay stricter regulation.  So he publishes research, goes to conferences, and, not to seem too ridiculous, agrees air pollution is a problem - but he quibbles over methodology, over PRB, and the "piston effect" about which he says:

"The answer may lie not in more stringent emission controls, but in changing the form of the 8-hour average standard to one that will provide for the same amount of human health protection and yet be attainable."

...nibbling around the edges, like a rat, to distract.  Imagine, it is more economical for the fuel companies to fund guys like the Cleaner, and lobbyists, and lawyers for lawsuits, and to bribe legislators and promise jobs to politically appointed agency employees, than it is to allow the EPA to regulate their emissions.   Assuming industry is not irrational, that alone should tell you there are one of two possibilities here:

1.  To really clean up their emissions - to the point where they are safe for humans and plants - would be incredibly expensive and cut into their profits more than it costs them to fund the denial factory; or

2.  There just isn't any way to make their product - energy derived from burning fuel - safe.

In this 2004 letter to the California Air Resources Board, the Western States Petroleum Association relies on an analysis by Allen Lefohn to object to more restrictive ozone standards, based primarily on his assessment that the CARB has chosen a policy relevant background level of ozone that is too low, and other absurd notions such as:

"Our review has found significant problems in the methodology and assumptions that are used in the benefits assessment.  We feel that the document should not be finalized until these problems are resolved.  This chapter moves far beyond previous health risk assessments conducted by EPA in their 1997 Ozone Staff paper, and introduces the concept of a link between ozone and mortality, which is likely an artifact of the analysis methodology and statistics. As such, we recommend that any benefits predicated on mortality be removed, as these are not scientifically supportable."

Lefohn and his co-contributor, a Dr. Stanley Hayes, are described in the cover letter:

"...nationally recognized experts have been deeply involved in many aspects of ozone research, have authored important sections of current and past chapters for the federal Ozone Criteria Documents or conducted research cited in previous Ozone Staff Papers, and helped develop and apply approaches for assessing ozone risk."

Dr. Stanley Hayes works at Environ Corp, so I looked them up.  Their website is hysterical!  Here is how they advertise their services:

Bringing clarity to issues at the intersection of science, business and policy.

Since 1982 ENVIRON has helped clients manage their most demanding health and environmental challenges.
Our interdisciplinary network of more than 1000 consultants operates from over 80 offices in 18 countries.

Right away several very interesting and funny things surface.  One is the word, "manage".  That's what they do - they don't prevent pollution, they "manage" it.  The other amazing thing is the sheer size of this company - one thousand consultants!  It takes a lot of people to "manage" pollution.  But what I loved best was the photos that illustrate their website!

Their industrial facilities are not only sparkly clean, they have bright yellow buttercups growing in front of them!  Isn't that sweet?

It's not difficult to find Lefohn and Environ in bed together - just last February they give testimony at an EPA Scientific Advisory Committee Ozone Review Panel meeting cheek by jowl with representatives from API and BP at a hearing last February:

"Allen Lefohn, A.S.L. and Associates, criticized EPA’s estimate of policy relevant background for being too low, in particular, the maximum monthly diurnal concentration.  Chris Emery of Environ Corporation suggested that policy relevant background (PRB) O3 could often exceed 50 ppb, citing deficiencies in EPA’s global modeling to estimate PRB.  Stuart Sessions, on behalf of the American Petroleum Institute (API), said that given the wide range of uncertainty in EPA’s regulatory impact 

analysis, it cannot be said whether the net benefits of a tighter standard will exceed costs.  Dana Wood and Doug Blewitt, both on behalf of British Petroleum, presented information showing a policy relevant background of 60 ppb O3 in the West."

The following is an email I received quite some time ago from a fellow blogger, who shall remain anonymous, on the topic of biostitution.  I reproduce it because it's very thoughtful and gives an nuanced perspective on the role of scientists in regulation...and also mentions DuPont, which is a meaningless but amusing coincidence, because it was Pierre DuPont who first owned, then endowed and bequeathed Longwood Gardens to the public.


"I found the book I was thinking of on the back shelves.  Whatever Happened to Fresh Air? Michael Treshow, illustrated by Eugene K. Shepherd, University of Utah Press, 1971.  See especially chapter 6, where he discusses the agricultural damage from air pollution.  The orchid industry in Los Angeles and other places in California was particularly hard hit after 1942."

"When I was working for those guys, everybody who was anybody had industry connections, for good, usually much-less-than-nefarious reasons.  Before air pollution regulation, when farmers found damage to their crops or animals, they just sued the local air polluter for nuisance damage.  Nuisance is an interesting maneuver -- it's a chancery issue rather than law.  If the polluter is found to be liable, they can work out a financial arrangement to keep paying the injured party, or they can close up shop.

So in the 1940s and 1950s, there were a lot of farmers around steel mills and other ore producers, especially, who got monthly payments from the companies so the companies could continue to operate.

U.S. Steel, for one, paid a lot of scientists a lot of money to figure out what of their effluents were really doing damage, and what wasn't.  If the stuff that was doing the damage was cheap and easy to control, they'd do that.  If not, they'd pay the farmers.

At the Geneva Steel Works outside of Orem, Utah, for example, one end of the plant emitted a lot of fluoride -- gas, if I recall correctly.  This stuff settled on the grasses for a couple of miles around.  Dairy farmers complained because their grazing cows got huge doses of fluoride, which will prevent cavities in small doses, but weaken teeth in big doses.  Expensive milk cows were ruining their teeth, and therefore ruining their ability to turn grass into milk, more than twice as fast as expected.  Once the scientists figured out what the culprit substance was, they often helped figure out how to control it.  That's where Dr. Hill and Dr. Treshow and others came in.  They were paid to make the determinations as accurately as possible, and they were paid to consult with engineers to construct systems to control the offending pollution.

Up through the 1960s, no air pollution scientist worth his salt (few "hers") did NOT have an employment record with the polluters."

"Many of us who went into environmental law didn't think that one through, either.  In the end there are only a tiny handful of jobs at NRDC, or Sierra Club -- but every steel mill needs an environmental law specialist, usually a legal guy on staff, and a legal guy in a private firm on regulatory compliance, and someone with environmental expertise at the other firm they use, the litigation firm.  It's uncomfortable as hell if you've got a bad company who wishes to avoid regulation, but it's relatively rewarding if you're working for a company like American Airlines who wants to keep a good record and is a stickler for following the rules and finding better (and cheaper) ways to comply.

It's a little different in wildlife issues, where you have state wildlife management agencies, sometimes two for a state (game and non-game wildlife), plus the USFWS, plus the land management agencies, sometimes one for the state and one, or two or three, for the federal government.  But air pollution is still dominated by good scientist who work well with corporations.

So I don't dismiss somebody who has corporate connections.  But you need to look at the body of work and the actions of the corporation to see which way the corporation goes."

"And even then, sometimes a corporation will come down on different sides of the same issue, sometimes in different locations, sometimes in the same location.  You remember the Cuyahoga River near Cleveland?  "Burn on, Big River," as Randy Newman sang it.

DuPont Chemical (I think I remember the company correctly) had a plant that literally used every drop of the river, but it was downstream from almost all other polluters.  They needed clean water, especially water clean of chemicals that would screw up the paints and other stuff they manufactured, so they campaigned hard to get everyone else to clean up, upstream.  Unfortunately, before everybody else upstream cleaned up, DuPont also resisted efforts to make them comply with clean water standards at the same plant, arguing that they had to treat the water before they used it, and the treated it after they used it, and though the water didn't meet standards, it was much cleaner coming out of the plant than going in.  That one produced lots of litigation and legislative vexation.

Sometimes it's almost impossible to tell whether a company is being honest that the standards are unfair or unworkable, or just intransigent on wishing to remain a polluter to make more profits.

Good luck, again."

Allen Lefohn's own words from his website:

"As part of the current review of the ozone standards, for the EPA's Clean Air Scientific Advisory Committee (CASAC) meeting in Chapel Hill, NC that took place on May 19-20, 2011, we prepared a 55-page summary of what we believe the research status is of surface ozone policy-relevant background. There is much controversy on what the range of background ozone is in the United States. The EPA, using a model, believes that background ozone is in the range of 15-35 ppb. However, models tend to poorly estimate the contribution of natural processes, such as stratospheric intrusions into the lower troposphere. Our research is indicating that frequent occurrences greater than or equal to 50 ppb that occur at both high- and low-elevation monitoring sites across the US are influenced by transport from the stratosphere to the lower troposphere. The enhanced ozone concentrations that appear to be related to stratospheric transport occur during the springtime and sometimes during the summertime. In addition, long-range transport of Eurasian biomass burning, as well as wildfires in the US, contribute to background ozone concentrations. Estimating the range of background ozone properly is important because the range of background concentrations is used in the EPA's risk assessment for human health and vegetation, as well as assessing the amount of emission reductions required to attain a specific ozone level (i.e., standard). If the actual background level of ozone is higher than EPA estimates with models, then the Agency may overestimate human health as well as vegetation risks and present inaccurate information to the public and policymakers. If you would like to read the 55-page report by Allen S. Lefohn and Samuel J. Oltmans on the status of policy-relevant background (PRB) ozone, please click here."

Wouldn't you love to know who paid him to produce that 55-page report?  I would!  In May, he and Oltmans (who works for NOAA) were commenting at another EPA hearing again:

"Dr. Allen Lefohn presented information on estimating the policy relevant background (PRB) concentration of ozone, emphasizing hourly averages as a preferred metric and the role of stratospheric-to-troposphere transport processes that contribute to ozone background concentrations.  Dr. Lefohn said his work had been funded by the American Petroleum Institute....By telephone, Mr. Samuel Oltmans presented ozone measurements from the National Oceanic and Atmospheric Administration’s Observatory at Trinidad Head, California.  Mr. Oltmans stated that air flowing into Trinidad Head represents the Pacific “background.”  Mr. Oltmans also showed the influence of Eurasian biomass burning in the surface ozone measurements at Denali National Park in Alaska."

A provocative tidbit at the end of the minutes:

"It was noted that the secondary of “cascading” effects of ozone on ecosystems (e.g. effects on hydrologic cycles, fire frequency or pest attacks) are likely to be more important than direct effects of ozone on vegetation but much more difficult to measure or model accurately.  EPA was commended for
considering these complex interactions despite the challenges in quantifying effects.  One panelist noted that on adult trees, foliar injury is usually not obvious to the casual observer given that it is 150 feet high and observed on leaves rather than flowers."

Also present at that session was Cindy Langworthy, a lawyer described this way on her firm's webpage:

"Cindy is a member of Hunton & Williams' Environmental Team, where her practice focuses on Clean Air Act issues, particularly effects of air pollutants on public health and the environment. She has experience in complex federal administrative rulemaking proceedings, compliance advice and appellate review of administrative actions.

• Represented industrial clients in numerous rulemakings by the Environmental Protection Agency to establish national air quality standards for ozone, particulate matter, sulfur dioxide and nitrogen dioxide.
• Represented industrial clients in numerous federal court proceedings concerning review, revision and implementation of National Ambient Air Quality Standards.
• Represented electric utilities before the Environmental Protection Agency concerning the Agency's rules and guidance related to implementation of its air quality standards.
• Participated in the Environmental Protection Agency’s review of its process for reviewing National Ambient Air Quality Standards.
• Participated on behalf of electric utility clients in a federal advisory committee proceeding to develop strategies for implementing air quality standards.
• Counseled clients on the significance of specific scientific publications reporting associations between industrial pollutants and health or environmental effects.
• Advised industrial clients concerning regulatory requirements related to implementation of federal air quality standards.

Member, Air and Waste Management Association"

She, together with a director from the API, co-authored this article for the Journal of the Air & Waste Management Association (there's that word again - "manage") about ozone regulations, which revealingly concluded:

"The efforts of EPA, the states, and local communities in providing cleaner air once again need to be acknowledged.  Looking forward, further improvements will come through fully implementing current regulations designed to meet the existing standards. Of course, the CAA mandates that the ozone NAAQS be established based solely on science.  A group of 10 scientists, knowledgeable about the science and policy issues underlying the setting of the NAAQS for ozone, have reviewed the available scientific information on ambient ozone and its health effects and have concluded that no scientific methodology can define the precise numerical level and related averaging time and statistical form of the ozone standard and that these are policy judgments.  This highlights the importance of getting the
science right, and the uncertainty in the current science does not support tightening the standards and imposing further costs for the uncertain benefits proposed."

That is exactly the methodology of the Merchants of Doubt.  They poke at uncertainties, to derail regulation. And whose work is cited over and over in the references?  Why, none other than Allen Lefohn!

When we left the greenhouse to wander back to the parking lot, the sun was setting and the beeches were blazing.  An almost full moon hovered in the sky.

Beyond this formal setting is a topiary garden.

Lilac leaves along the pathway are spotted.

They go from that to hideously shriveled.

A cedar is bright with the sun shining from a low angle, revealing needles that are the color of rust.

In the background is the greenhouse, with dying pines towering over the roof.

The topiary garden has been temporarily closed - and no wonder, the formations are in terrible shape.  The low boxwood hedge in the foreground has been completely replaced rather recently, so the original one must have died.  You can see through the sculptures, they have almost no leaf cover.

This garden is on the verge of total loss...and keep in mind, in Europe there are formal gardens that have topiaries much, much older than these.

I took the two younger daughters to Longwood Gardens about six years ago, and we were so enchanted by a clump of weeping hemlock that I promptly ordered three and planted them at Wit's End.  That was before I learned the trees are dying, of course.  What was so magical about this gigantic stand was slipping through the soft green needles that created a curtain, to emerge underneath the canopy, which was like a dark, dark cave with hardly any light shining through...marvelous writhing branches dimly visible in the depths.  The branches are still wonderfully contorted, but now the blanket of green is so thin that light pours in from every direction.

Yay!  I'm finished, for now, except for two clips of the Cleaner.  While perhaps the Cleaner is best known as "The Wolf" in my favorite movie ever (with the possible exception of Gone With the Wind"),  Pulp Fiction, Harvey Keitel made that role a classic in an earlier film, Point of No Return.  Gruesome alert!

Another version...Just think of him as shooting holes in EPA regulations...