It Couldn't Happen Here, Could It?

In a previous post, we pointed out that Stephanie Buffum of the Friends is the ex-wife of renowned hardball environmentalist Kieran Suckling. Here is what he has to say in a 2010 interview:

Were you hindered by not having science degrees?
No. It was a key to our success. I think the professionalization of the environmental movement has injured it greatly. These kids get degrees in environmental conservation and wildlife management and come looking for jobs in the environmental movement. I’m more interested in hiring philosophers, linguists, and poets. The core talent of a successful environmental activist is not science and law. It’s campaigning instinct. That’s not only not taught in the universities, it’s discouraged.

Suckling's words lend credence to the P.J. O'Rourke quote, "Some people will do anything to save the earth, except take a science course." Meanwhile, in a separate story about environmental bullies elsewhere, the residents of Cape Hatteras are learning what it means to go up against big green beach bully birders.

Couch and 15 other local business owners each signed their own affidavits swearing the consent decree was destroying their lives and the lives of employees they had to let go. Families were losing their life savings, their college funds and their homes.

At the time, Defenders' president, Rodger Schlickeisen, scrimped along with his $295,641 salary and Audubon boss John Flicker got by on $322,422 -- not counting their handsome $30,000-plus benefit packages.

Jim Keene, director of the North Carolina Beach Buggy Association, is the go-to guy on how this disaster started. "The green groups wanted to get rid of ORVs [off-road vehicles] with the usual 'beer belly cowboy bird killers' propaganda," he said. "They don't recognize it was ORV users that first went out and flagged nests so everybody would drive with extra caution. We do more to protect beach birds than these big-shots in their fancy New York City skyscrapers -- we need this beach, and we need it open."

If you click on the linked article, be sure to note the size of the bird buffers. Each bird has its own individualized buffer with a diameter of 6,000 feet.  And yes, you read that right: 6,000 feet.

Taking Our Medicine

Imagine you sit on a citizen panel that is responsible for approving a new drug, a pill. This pill is an antidote for a poison. Actually, it's reported to be an effective antidote for an innumerable variety of poisons, and we are told by the finest scientists in the land that we are surrounded by undetectable but lethal poisons. This is surprising to us because we do not feel ill, but the scientists tell us that nearly everyone in the community must now take this antidote, in varying doses prescribed for us, or we will all die. We have to live with this pill for the rest of our lives, and by the way, this pill is very expensive and has crippling side effects. All the same, we must take it. We have no choice.

As a caring member of the community, you accept the imperative to protect. You are, however, very concerned about the side effects of the antidote.  As a member of the approval panel, you focus all your efforts towards reducing the pill's side effects, if only marginally.  If you make palliative modifications, you feel heroic since you have approved a vital community-saving measure while reducing negative consequences.

Based on recent conversations, many members of our Council and Planning Commission seem to feel this way. They have accepted that we are sick (eco-hypochondriacs?). They have accepted that we need to take the miracle pill despite the terrible side effects. They believe the (buffer) pill is the only solution that can save us: there is no alternative or combination of alternatives that might be a substitute remedy. There is only one final solution, and it is worth everything. Our officials feel embattled, but heroic. As such, they are focused only on forcing us to swallow the pill, and to that end, they are trying to gain our grudging cooperation by reassuring us that the side effects will not be as bad as they are reported to be.

But the surest way to prevent side effects is not to take the pill in the first place. That said, hardly any of our public officials are seriously scrutinizing whether the pill is needed to begin with. For its advocates, though the evidence is scant, the pill represents science. Although we have lived an apparently healthy life without the scientific pill, "they" insist that we cannot go on living without the new drug.

This is how most of our public officials think of the CAO, its buffers, and the diagnosis of Dr. Adamus and others. The fact that our officials can think this way is the most difficult pill to swallow of all.

Previous posts raised questions about our diagnosis, the remedy (i.e., pill), and the methodology used to compute our dose. Upcoming posts will ask whether the proposed remedy has any active ingredients at all? Or, is it just a placebo with crippling side effects?

BAS Ackwards

Why don't basketball players wear football helmets? The answer is that there is no need. There are few, if any, concussions in the NBA. Yes, there might be the occasional elbow to the head, but the risk of a serious head injury is considered to be de minimis. There just aren't enough serious head injuries in the NBA to warrant concern.

Now suppose a determined helmet maker wants to increase his sales, and he seizes upon the idea of selling football helmets to the NBA. He discovers that, compared to the NFL, there is a frightening absence of head injury data in the NBA. This is disturbing since the helmet maker really believes that serious head injuries are ubiquitous in sports. He makes a sales pitch to the NBA where he characterizes the NBA's lack of data about harm as being a genuine cause for concern, and he proposes that every player wear a helmet, to be precautionary in the face of the NBA's scientific uncertainty.

Ah, but some trouble makers challenge the helmet maker over the need for NBA players to wear helmets, so the helmet maker responds by trotting out Best Available Science (BAS) about helmets.  The BAS shows that helmets reduce injuries to professional athletes by a significant amount. The NBA finds the science to be very persuasive, and as a result, it decides that all of its players must wear football helmets from now on.

What went wrong here? Can you spot the syllogistic errors that led to pointless (and expensive) safety measures being taken for a situation that was already de minimis? For one, the salesmen's BAS is about helmets, not the risk situation in the NBA. In fact, to make his pitch, the salesmen never needs to know the actual risk to NBA players. He only needs to be persuasive about head injuries being ubiquitous, point out that the NBA lacks data on this ubiquitous problem, and then propose a plausible solution ... his helmets.

That brings us to San Juan County where expanded buffers (i.e., helmets) are being proposed for our wetlands, streams, and shorelines. Despite data showing many positive aspects to our ecosystem, there is an absence of data showing no harm. We are told by authorities that pollutants are ubiquitous, and many citizens and officials tell frightening stories about our ecosystem's dire prospects if we don't do something. The proposals for much bigger buffers are justified by BAS about buffers, not BAS about the county.

I believe this misconstrues BAS, and it allows the buffer scientists to flip the CAO process on its head. The scientists aren't using BAS about San Juan County to design buffers; they are using BAS about buffers to design the county.

When that happens, buffer scientists become little more than buffer salesmen and BAS becomes just a sales brochure for the salesmen's latest product. Like all pitchmen, the buffer salesmen would love to see you kitted out in the deluxe model.

Let's Assume We Have A Can Opener

A physicist, a chemist and an economist are stranded on an island, with nothing to eat. A can of soup washes ashore. The physicist says, "Lets smash the can open with a rock." The chemist says, "Let’s build a fire and heat the can first." The economist says, "Lets assume that we have a can opener..."

Unfortunately, that famous joke about economists has a great deal of relevance to our CAOs because the State and County CAO "experts" just want to assume that we have "pollution." That is no laughing matter.

What is "pollution" anyway? The notion of pollution is inherently linked to the concept of ecological or human health risk. Pollution occurs when a constituent of potential concern (COPC) is evaluated and found to be present in the environment at concentrations sufficient to cause a quantifiable increase in the likelihood of harm above background levels (i.e., excess risk). When a COPC has been confirmed to be present at concentrations presenting unacceptable excess risk, it is re-titled a constituent of concern (COC).

If you have COCs or if you have constituents exceeding a defined regulatory limit, you have "pollution," and as I hope you can see, that concept is inherently linked to concentrations.  The mere presence of a substance alone does not constitute "pollution." It has to be present at concentrations exceeding de minimis risk.

Where do you find published concentration limits that might be useful in evaluating whether COPCs are above de minimis? You find the regulatory limits for surface water here.  You find the regulatory limits for groundwater here.  You find the regulatory limits for drinking water here.

What about ecological screening levels? Those must be really hard to find ... and expensive too, right?  Actually, they are quite easy to find. Ecological screening levels for soils are part of MTCA, sediment management standards can be found in the WAC, and EPA provides recommended criteria for aquatic life here.

Despite all the available information on potential contaminants, how is it that after years of working on our CAOs, none of our "experts" have come up with a list of constituents that might need a remedy here? They have identified no COPCs. None. Instead, "they" simply want us to assume that pollution of unimaginable variety is present in San Juan County, and all of it can be miraculously treated by buffers. In one conversation, Dr. Adamus even referred to the potential list of contaminants here as, "so soluble and so toxic, and there are hundreds if not thousands that have not been studied in terms of their toxicological effects." And he referred to them as, "contaminants that are the inevitable results of having people around."

Okay, why don't you name a few of them?

Nothing doing apparently.  Instead, "they" seem to want us to live with the notion that "pollution" here is mysterious, present at dangerous concentrations, ubiquitous, but nevertheless, impossible to list much less test for ... so just trust us, it's here. It's all around us, and buffers will take care of all of it, provided they're gigantic.

As for me, I don't trust them, and I don't know how anyone could, because they are proposing buffer orthodoxy, not science. They have assumed a buffer (can opener) and think the problem solved, regardless whether one existed in the first place.

Catastrophically Bad Writing (to go with the incredibly bad science)

With all the talk about the CAOs, we shouldn't forget that there is an Inventory and Characterization Report in circulation about shorelines, as part of the County's effort to comply with the Shoreline Management Act (SMA).

The I&C Report, as it is known, was written by Herrera Environmental and The Watershed Company, among others.  If you've been following the County reports churned out for the CAO and the SMP, you may have noticed a repeating pattern of consultants. Herrera and Watershed are familiar names. They were co-authors of the San Juan County BAS Synthesis for the CAOs as well as the Shoreline I&C. The public appear to be generally underwhelmed with their work and with the draft ordinances based on their work.

Yesterday, a packed house at the Planning Commission were mostly critical of the latest BAS-based version of the wetlands CAO. Former code enforcement officials, former planners, scientists, farmers, and just plain ol' regular folk testified against it, calling it something that looked like it "came out of the back-end of a cow" according to one meeting participant.

These sentiments are reminiscent of a meeting last week (February 29) about the I&C report. Meeting attendees were highly critical of that report, and with statements from the I&C report like the excerpts below, it can be little wonder. Aside from allegations of poor quality science, the writing of the I&C report appears to be an affront to the English language.

The following excerpts are just a small set of examples that left me scratching my head and saying, "Huh?" Also, generally, I think words like "incredibly" are about as appropriate for a scientific report as words like "awesome." I wonder if Herrera and Watershed have ever owned a copy of Strunk & White?

The geology of the Doe Bay management area is both complex and simple.

If a landslide or earthquake were to occur in the management area it would occur catastrophically and would likely be very large.

The physical forcing on the shorelines of the Mud Bay management area varies dramatically.

The relatively competent bedrock means that very few areas are potentially unstable, even though slopes can be incredibly steep.

Pseudoscience Zombie - It's In Their Head

If you've never heard of Robert K. Merton, I'm sure you've at least heard of some of the phrases he's invented, such as self-fulfilling prophecy, or maybe you know of the Thomas Theorem or Matthew Effect. Aside from being the father of Nobel Economist Robert C. Merton, Robert K. was a giant in his own right, a social scientist whose principal area of research was the scientific process itself. Robert K. wrote a lot about science and even pseudoscience, and when I look around our community to see what is happening on the CAOs and SMP, I feel like we're living in a Robert K. Merton research project on pseudoscience.

The Stanford University Philosophy Department has a website about pseudoscience which discusses Robert K.'s ideas, along with those of others.  It is an excellent read. On that website, there is a list of pseudoscience criteria that really hits home for me. Here is what it says.

"One such list (of criteria for identifying pseudoscience) reads as follows:

1. Belief in authority: It is contended that some person or persons have a special ability to determine what is true or false. Others have to accept their judgments.
2. Nonrepeatable experiments: Reliance is put on experiments that cannot be repeated by others with the same outcome.
3. Handpicked examples: Handpicked examples are used although they are not representative of the general category that the investigation refers to.
4. Unwillingness to test: A theory is not tested although it is possible to test it.
5. Disregard of refuting information: Observations or experiments that conflict with a theory are neglected.
6. Built-in subterfuge: The testing of a theory is so arranged that the theory can only be confirmed, never disconfirmed, by the outcome.
7. Explanations are abandoned without replacement. Tenable explanations are given up without being replaced, so that the new theory leaves much more unexplained than the previous one. (Hansson 1983)"

In short, when I read this list, I can't help but hum the refrain from Zombie, the 1994 protest song from the Irish rock group, The Cranberries. Although written for a different time and place, the refrain still seems relevant to aspects of our lives here. When is something non-science?  When it's, "In your head, in your head ... ZOMBIE .... ZOMBIE ... ZOMBIE ... heh ... heh ... heh ... OH!