Friday, August 31, 2012

Countdown To CAOmageddon: Flaw #28 - Cray Risk (Summary)

This "series within a series" has made an effort to explain the following points:
  1. Management of ecological risk is the way we protect the environment.
  2. The term "risk" as used by the County, Ecology, and the Friends does not conform to the customary definition of "ecological risk." They've made up their own definition, and they keep changing it.
  3. There is a difference between a "safe" environment and a "zero risk" environment. Our goal is, or should be, to maintain a safe environment.
  4. A risk evaluation involves a conceptualization of receptors, stressors, linkages between the two, and an effect transmitted by the linkages ... at a potency significant enough to have an effect on the receptor population.
  5. The County may have mapped locations that identify populations of receptors, but they have not quantified site-specific stressors, identified the magnitude of their effects, or conceptualized the pathways by which the stressors are supposed to be affecting the receptors.
  6. It is impossible to identify mitigation measures without the information required in #5.
  7. Buffers are a presumptive mitigation that are believed to attenuate the effects of stressors, but there is no proof that county-originating stressors exist on a county-wide scale, so there is no proof that county-wide mitigation is needed. Even if needed on specific sites, there is no proof that buffers are capable of breaking complete or potentially complete pathways for all exposure routes within a given exposure scenario. It is more likely that stressors do not exist in the first place at levels above de minimis. The assumptions used to design our buffers are not based on accepted fate and transport science and ignore pollutant characteristics (e.g., solubility coefficients, partition coefficients). They are based on generalized flow methods, which were not designed for general application as pollutant fate and transport models.
  8. There is ample data to suggest that the exposure scenario for our marine environment is affected primarily by exposure routes originating from Canada. Our marine environment is oceanographically distinct from Puget Sound.
  9. Because of #8 and because site-specific stressors have not been identified in this county, we cannot borrow solutions from other locales in the Puget Sound region, especially urban areas. There is simply no evidence that our exposure scenario is the same as that found in other places.
  10. The "professionals" and "regulatory experts" who have been advising the County have a poor to non-existent understanding of "risk," as demonstrated by their written submittals to the County. "Risk," "error," "uncertainty," "level of concern," and "unknown" are all different concepts, but the "experts" have regularly confused the meanings of those words in their advice to the County.
  11. There is a large body of literature from the EPA, from the National Research Council, and from the National Academies on risk and scientific uncertainty. The "experts" advice regarding BAS is inconsistent with this body of literature. It is inconsistent with science.
We could go on, but those are the main summary points about risk. To use a modern term, our County's ideas about risk are cray cray.

Next up, we'll describe what the National Academies have to say about functions and values.

1 comment:

  1. And to those chowder-heads who compelled have the County County to have their Prosecuting Attorney give them a reason to shut down this blog because some comment on the blog suggested you all were crazy ... well ... you are crazy. Cray Cray Crazy. You live on Fantasy Island where Nothing is Real. No wonder you get so "up about" when your make believe world is challenged by reality. It's beginning to make sense.