In article ,
"Ed Huntress" wrote:

"Joseph Gwinn" wrote in message
...
In article ,
"Ed Huntress" wrote:

"Joseph Gwinn" wrote in message
...
In article ,
"Ed Huntress" wrote:

"Joseph Gwinn" wrote in message
...
In article ,
"Ed Huntress" wrote:

"Joseph Gwinn" wrote in message
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In article ,
"Ed Huntress" wrote:

"Joseph Gwinn" wrote in message
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In article , "."

wrote:

On 7/11/2011 7:49 PM, Ed Huntress wrote:
"Joseph wrote in message
...
In ,
"Ed wrote:

[snip]

So, the focus would have to be on agriculture. The problem is
that
crop
plants cannot be convinced that they don't need phosphorus to
grow.

Not having any background in this, I can't address the individual
issues.
But my understanding is that fertilizing timing is an issue;
release
rates
are an issue; plowing practice is an issue; quantities are an
issue.
All
are
being addressed by one institution or another.

It's better than sitting around and sucking our thumbs, but I don't
know
the
numbers.

Really? Given the considerable effort and cost yielding trivial
impact,
perhaps the same effort would yield far greater return elsewhere.

Maybe. If you're interested enough, there's plenty of information
around.
I'm mostly interested in the marine life in the local estuaries, and
the
rivers above them. I don't follow the issues closely. I've only read a
couple of reports about local efforts to keep phosphates out of the
Delaware.


This is the proof that the EPA doesn't know when to stop.

I don't think that this one example is "proof" of anything about the
EPA.
The proof I'm most interested in is how effective they are, and
there's
plenty of that. You can find people, I'm sure, who can discuss their
efficiency. You might even find one who knows enough to talk about it,
but
don't count on that happening on Usenet. d8-)

Spending all that effort and causing all that disruption for a measly
0.5% is a telling example. If the shareholders found out, a company
president doing such a grossly inefficient thing would soon be gone.


My general take on the EPA is that they have a very big job, with
pathetically meager resources to do it. So they paint a lot of things
with a
broad brush, out of necessity, and they're constrained in every
direction
by
our principles of equal treatment and so on. I don't envy their
position.
I
do admire many of their results.

And this only buttresses my point. If one has too little money, one
does not usually bother with efforts with such an astoundingly low
cost/benefit ratio. There are better ways to use the resources.

Joe Gwinn

It may be a matter of the responsibilities that Congress has charged them
with. I'd have to look carefully at that, and at what EPA has done with
it,
before I'd be critical.

Congress almost never gives that level of detail, expecting the EPA (in
this case) to write the relevant rules. And EPA could have adopted some
kind of de minimis rule, and would have been well advised to do so,
because cases like this do their larger agenda no good.

But certainly Congress has ultimate responsibility.

Joe Gwinn


http://en.wikipedia.org/wiki/De_minimis

Before I address that, I found the studies I had read several years ago. One
reports that the Delaware Estuary has the highest concentration of
phosphorus of any river or estuary in the United States, and one of the
highest in the world. What might be of more interest to you is that the
point-source phosphorus load is 4 times higher than the non-point-source
load. In other words, municipal outflows (treated wastewater) introduce 4
times as much phosphorus as the agricultural and residential use of
fertilizers, plus animal waste.

And this is one of the quotes I remembered, from "Marsh sediments as records
of sedimentation, eutrophication and
metal pollution in the urban Delaware Estuary," 2006:

"Recorded in the freshwater marsh sediment upstream is a dramatic increase
in total phosphorus (TP) starting in 1950 - 1960, and, as in the Delaware
River water, tracks the introduction of P detergent use. Although this might
include increased use of P fertilizers, there is a substantial decrease
after removal of the P detergent source in the mid-1970s."

And this:

"Starting in the second half of the century, there were coordinated studies
and a commission that resulted in stricter point source pollution,
particularly the institution of secondary sewage treatment. These
improvements in pollution and sewage control have expanded in recent
decades. The result is that since approximately 1980, there has been an 86%
reduction in both municipal and industrial chemical oxygen demand.
Phosphorus levels have dropped by a factor of five during this same period,
presumably from reduction in P detergent use, as tertiary treatment has not
been implemented."

So phosphate detergent is indeed a big issue here in the Delaware,
regardless of statistics on fertilizer and non-fertilizer sources in
general.

This would be for clothes washing detergent, although the cited articles
don't seem to make the distinction. And, Delaware is the outlier.


Now, about EPA overreach and the dishwasher detergent regulations: They
aren't from EPA at all. It's 16 individual states that enacted the near-ban
in 2009 and 2010.

The question is what prompted them.

And if the EPA had declared dishwasher detergent phosphate use as de
minimus, the states would not have argued. Actually, they could not
have argued, by federal preemption. So, we are back in Washington.

Joe Gwinn