Environmental Law and Climate Policy Insights
This post was originally published on the Law & Political Economy Blog as “How Environmental Law Created a World Awash in Toxic Chemicals.”
Earlier this spring, the Biden administration finalized two important rules targeting a small subset of so-called forever chemicals: one establishing drinking water standards for six such chemicals and the other designating two of the more prominent ones as hazardous substances under CERCLA (the Superfund Law). These chemicals, which are part of a much larger family of some 15,000 chemicals known as Per- and Polyfluoroalkyl Substances (or PFAS), are called forever chemicals because of their extreme environmental persistence. They are now widespread in America’s drinking water, showing up in about half of the country’s tap water, and ubiquitous in the broader environment, where they bioaccumulate in living organisms. As their name suggests, these chemicals last, well, like, forever—or at least until we clean them up, which takes enormous effort, not to mention time and money.
First manufactured in the 1940s, the forever chemicals were highly valued because of their resistance to heat, oil, stains, grease, and water. For decades, the chemical industry has used them in a wide range of coatings and consumer products, including DuPont’s famous non-stick Teflon coating and 3M’s Scotchgard. Though manufacturers began to phase out two of the most widely used PFAS chemicals in the early 2000s, these chemicals are still produced for a handful of products and are still included in products imported from abroad. And, of course, there are literally thousands of other PFAS chemicals that are still being used in a wide range of products, with very little or no testing for their potential toxicity.
As a result, PFAS chemicals are now present in the blood of an estimated 97% of people in the United States. And despite years of public pronouncements from the manufacturers that these chemicals were biologically inert and posed no health risk, forever chemicals have now been linked to a growing list of human health impacts, including various forms of cancer, reproductive harms, immunotoxicity, and neurodevelopmental problems (among others). Thanks to documents produced in litigation and the work of investigative journalists, we now know that two of the largest manufacturers, Dupont and 3M, have known about potential health problems for some fifty years, notwithstanding their claims to the contrary. While these specific instances of corporate malfeasance are hardly atypical in the world of toxic harms, the current settlement dollars involving PFAS are quite large—more than $11 billion in 2023, a figure that is expected to increase in coming years.
To anyone paying attention, the message is clear: there is a huge toxic mess out there posing significant risks to public health and the environment. To his credit, EPA Administrator Michael Regan recognizes this and has prioritized the regulation of forever of chemicals across multiple EPA programs since taking over at EPA.
But as EPA moves forward on various fronts to clean up widespread contamination created by more than half a century of PFAS production, we are left with a worrying question: how did we let this happen in the first place? Indeed, the PFAS disaster points once again to the failure of our laws regulating toxic chemicals, which were intended to avoid just these sorts of problems. In effect, because PFAS chemicals were already “in commerce” at the time that the Toxic Substances Control Act (TSCA) was enacted in 1976, they (along with some 65,000 other chemicals in commerce at the time) were presumed to be safe and so were not subject to any sort of testing.
Much of the failure to regulate PFAS and other toxic chemicals is, I argue in a recent article and discuss in more detail below, symptomatic of a larger failure of environmental law over the past forty years: namely, it’s embrace of risk assessment as the dominant approach to environmental harms and its abandonment of earlier approaches based on precaution, endangerment, and a healthy respect for uncertainty.
The consequences of these failures are evident in the ubiquitous presence of toxic chemicals in the tissues of human beings all over the world and in the widespread contamination of terrestrial and marine environments. The rapidly increasing production and release of so-called novel entities (synthetic chemicals, pollutants, and heavy metals) are now pushing past planetary boundaries, damaging ecosystems and taking an enormous toll on human life and human health
On a global scale, the Lancet Commission on Pollution and Health estimates that pollution and toxic substances are now responsible for some nine million premature deaths a year, which is more than three times the number of deaths from AIDS, tuberculosis and malaria combined, fifteen times the number of deaths from all wars and other forms of violence, and thirty percent more than total global deaths from COVID-19. And this number is almost surely an underestimate given that we are still learning how damaging toxic substances can be. One recent study of the global health burden of lead contamination, for example, estimated that lead causes 5.5 million premature deaths per year—a six-fold increase over previous estimates. Research over the last several decades, moreover, has revealed that low-level exposures to a broad range of industrial chemicals, pesticides, and pollution are linked to various neurodevelopmental problems, immunotoxicity, endocrine system disruption, and reproductive harms (among others). Even on cancer, despite progress in reducing cancer deaths in the U.S. and other countries, the incidence of certain cancers, especially in children and young adults, continues to increase.
Exposures to pollution and toxics and the harms they cause are also radically unequal, as frontline communities and environmental justice advocates have been pointing out for decades. Most of the premature deaths associated with pollution and toxics today, for example, are in low- and middle-income countries, where the problems are getting worse, not better. In the United States, we now know based on extensive surveys of chemical biomarker concentrations that Black women and women of color have higher (often significantly higher) concentrations of various industrial chemicals, pesticides, and heavy metals in their blood. We know that people living next to Superfund sites have reduced life expectancy. And we know that despite significant progress in reducing the overall incidence of childhood lead poisoning, more than half a million children in America still have elevated levels of lead in their blood, including a disproportionately high number of Black children.
There are many reasons for these failures. But a big part of the problem lies with the standard approach to risk assessment that has come to provide much of the foundation for our approach to understanding and regulating toxic chemicals, pollution, and hazardous waste. There is a long history here that I have investigated in a series of articles (see here, here, and here), which show how formal approaches to risk came to dominate environmental decision-making starting in the early 1980s and, in the process, displaced earlier, simpler approaches founded upon precaution, endangerment, and a healthy respect for uncertainty.
Although risk assessment has often been understood as a largely technical, scientific exercise that provides the basic facts needed for the more value-laden exercise of risk management (itself cast as an exercise in cost-benefit analysis), the history of risk assessment makes clear that it has operated first and foremost as a political technology intended to discipline agencies and constrain their ability to solve complex problems, rather than as a tool to generate useful information about the world. Indeed, from the beginning, risk assessment was pushed by industry as a way of ensuring that no regulation would proceed until we determined exactly how many workers or how many people might suffer a particular harm from a certain level of exposure. Through the advocacy of organizations such as the American Council on Industrial Health, the Chemical Manufacturers Association, and the American Petroleum Institute, industry-funded scientists and lawyers commandeered the apparatus of fact-making that provides much of the basic infrastructure for regulatory science. This was a far more expansive and successful effort than simply working to manufacture doubt and uncertainty by questioning specific studies and funding alternative research. Indeed, much of the industry perspective was embraced and promoted by the science policy establishment, EPA, and the Supreme Court—all as part of a purportedly more rational and responsible approach to reforming regulation that moved into high gear during the 1980s.
But any honest evaluation of the practice of risk assessment over the past forty years would reveal an approach that has been unable to deliver on even the most basic metrics, as evidenced by reviews from the National Academy of Sciences (which was one of the original proponents of risk assessment) and the Government Accountability Office , among many others. Indeed, major individual risk assessment exercises have taken decades to complete, with many thousands of additional chemicals waiting in the queue. The dioxin cancer risk reassessment, for example, has been ongoing for more than thirty years, producing cancer risk estimates that vary by three orders of magnitude with no agreed criteria for how to achieve closure. Similar risk assessments for trichloroethylene and formaldehyde (among others) have also taken decades, with substantial variation in risk estimates depending on the models used. And these are some of the most data-rich and well-studied chemicals out there.
Risk assessment, in short, was never really intended to generate useful information for regulators. Rather, it was directed almost from the start at disciplining agencies and replacing expert judgment with a more formal, rule-governed rationality that saddled these agencies with impossible analytical demands, which in turn created seemingly endless opportunities for contestation and delay. From that vantage, risk assessment has been wildly successful. But from a public health perspective, it has failed in every way that matters.
By putting the burden on the government to demonstrate significant risk of harm before regulating, risk assessment has allowed the ongoing production of new chemicals and new forms of pollution for decades—much of which has been tied to the petrochemical industry. Indeed, one can trace direct line from the ongoing diversification strategies of oil and gas companies looking for new ways to make money from their massive reserves of fossil hydrocarbons to the exponential increase of production of plastics and other chemicals. The numbers here are staggering.
Since 1950, global chemical production has increased 50-fold and is projected to triple again by 2050 (relative to 2010), with an increasing share of production shifting to so-called emerging economies. Production of plastics has also skyrocketed, with cumulative global production expected to triple by 2050. There are now an estimated 350,000 chemicals and chemical mixtures on the global market. Only a handful have been properly tested and only for health endpoints that we know to look for.
Efforts to reform toxics regulation have typically pushed for better risk assessments, often tied to more pre-market testing of chemicals with the burden shifted to the manufacturers to demonstrate safety before they can sell their products—an approach that is more in line with that used for drugs (and to some extent pesticides). The EU, for example, has been working for almost two decades to implement a new regulatory framework along these lines, based on the simple rule that manufacturers seeking to sell chemicals on the European market must first produce a basic set of testing data for their chemicals: no data, no market. But even after twenty years of effort, basic safety information is still missing for the vast majority of chemicals sold in the EU.
In 2016, after many years of effort, the US Congress also enacted bipartisan amendments to the Toxic Substances Control Act, with the goal of fixing some of the most egregious problems with the statute. But only in the last year has EPA received any additional budget to implement the new provisions, and the agency is already behind on all of its major deadlines under the statute. More concerning is that fact that even if EPA were able to meet the risk assessment deadlines in the TSCA amendments, it would take an estimated 1500 years (!) to work through the backlog of existing chemicals.
There is something deeply irrational about allowing the ongoing production of novel chemical entities and their widespread release into the environment, especially those that are highly persistent and bioaccumulate, without any real understanding of how these chemicals will behave once they get out into the world. For decades, we have watched as various designer molecules are used in a wide range of products based on unsubstantiated claims of safety only to find that these molecules end up causing harm, either in ways that some had warned us about or in ways that were entirely unanticipated. Tetra-ethyl lead, DDT, PCBs, CFCs—all of these and many more stand as cautionary lessons that counsel against ever accepting claims of safety from those who stand to profit from their production and use. The looming crisis with forever chemicals and micro-plastics are just the latest examples.
Many of the harms associated with these chemicals are subtle and poorly understood. Some of them can take many years to develop and can even travel across generations. Most will surely be lost in the background mix of toxic insults, health setbacks, and cumulative stressors that shape our lives, albeit unevenly. And so we continue to allow industry to fill our world with toxic chemicals. Even as we work to end the use of fossil fuels as an energy source, we cannot stand by and watch as these same companies shift their production to plastics and petrochemicals. Decarbonization without detoxification is not much of a victory.
Rather than doubling down and trying to reform risk assessment, we should go back to simple, hazard-based triggers for regulation founded on a healthy respect for uncertainty and that lean toward precaution. As new information becomes available, regulations can be adjusted. In all cases, though, we should be vigilant before we allow widespread release of persistent chemicals into the environment, and we should recognize that even though we may not know precisely how toxic substances might cause harm in the future, we do know from experience that many (even most) potentially harmful agents turn out to be more harmful than initially suspected.
Put another way, it is past time to think about how regulation, and the regulatory science that supports it, can operate as a form of green industrial policy for chemicals, rather than as a forum for seemingly interminable debates over the nature and magnitude of harms and the zero-sum logic of risk-benefit balancing. The goal in all of this should be to move fast and protect people, to use simple default rules to drive innovation toward sustainability and health, and to make clear that the actual harms inflicted on real people living real lives in real places have both a moral and a legal significance that has been largely forgotten in the formulas and balancing acts that we have allowed to colonize the practice of environmental protection.
EPA, PFAS, plastic, toxics
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William Boyd is Professor of Law at UCLA School of Law and Professor at the Institute of the Environment and Sustainability. He is the founding Director of the Labora…
William Boyd is Professor of Law at UCLA School of Law and Professor at the Institute of the Environment and Sustainability. He is the founding Director of the Labora…
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Ken Silverstein: World will live with Putin's environmental policy long after he is gone – Huntington Herald Dispatch
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About a year ago, the Russian government committed an ecocide against Ukrainian citizens, blasting the Kakhovka hydroelectric power plant, which holds water equal to the Great Salt Lake. Industrial lubricants, fertilizers and chemicals poured into the waterfront town of Kherson, leading a distraught President Volodymyr Zelensky to tell reporters, “Life is ruined.”
The attacks continue unabated, polluting Ukraine’s water resources with heavy metals and oil products. In May, the Russians launched drone attacks on the city of Kharviv and the Sloviansk Thermal Power Plant. In the meantime, threats to the Zaporizhzhia Nuclear Power Plan remain. That’s because there is insufficient water to cool the plant’s six units — a function of Russia knocking out the Kakhovka dam.
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Ken Silverstein writes on energy and the environment. This column was distributed by InsideSources.com.
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Green Horizons: Charting Türkiye's Sustainable Journey | BCG – BCG
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Climate Change and Sustainability
By Aykan Gökbulut, Burak Tansan, , Aliriza Sancar, , , and
In this report, Boston Consulting Group (BCG) provides a comprehensive analysis of Türkiye’s progress towards sustainable development amid global decarbonization efforts. Our approach includes a 360-degree assessment, focusing on three main areas: Türkiye’s sustainability policies and advancements, a detailed review of sustainability initiatives undertaken by the top companies in Türkiye, and an evaluation of the country’s positioning and potential in the path of sustainability.
Our objective is to deliver a detailed overview
of Türkiye’s ongoing efforts and prospects in achieving sustainability. We also identify key imperatives that could further strengthen Türkiye’s role in this global movement. Consequently, this report aims to equip stakeholders with critical insights and practical guidance to navigate and accelerate the country’s journey towards a sustainable future.
Climate action is progressively becoming more critical for the future of our planet to ensure both environmental sustainability and economic resilience. Businesses are increasingly drawn to decarbonization primarily due to 3 main immediate motivations: (i) regulatory compliance, (ii) market demand, and (iii) economic opportunities.
Regulations such as the EU’s Carbon Border Adjustment Mechanism (CBAM) set a legal framework for reducing emissions, while growing market demand in sustainability pressure companies to adopt greener policies. Additionally, economic benefits such as cost savings provide strong incentives. However, in EMs, where regulatory compliance and market demands are developing, the economic opportunity becomes the major motive for sustainability, causing a lagged or limited transformation in the market.
Türkiye, one of the major EMs and a key trading partner of developed economies, is also experiencing a path towards sustainability that is marked by global and regional alignments. These steps include communicating sustainability targets, as exemplified by the ratification of Paris Agreement, and preparing for requirements of regulations such as CBAM. Türkiye is also actively pursuing energy transition, underscored by initiatives in renewable energy and energy efficiency.
These efforts not only support Türkiye’s aim for energy independence but also contribute to reducing its current account deficit (energy imports account for over 60% of the deficit). Furthermore, despite currently not having a fully functional emissions trading infrastructure, Türkiye is preparing to launch the Turkish Emissions Trading System (ETS) to enhance its regulatory framework for greenhouse gas reduction. Türkiye has the potential to expand its measures proactively across other areas of sustainability, starting from actions that also complement broader national strategic objectives.
Businesses in Türkiye are also progressively embracing sustainability, primarily driven by the economic opportunities, similar to other EMs. This shift is exemplified by the emergence of pioneering ventures like TOGG and Siro in the mobility sector, which have tapped into new sustainable value pools. Alongside, there’s a rising commitment to sustainability.
Between 2020 and 2022, the number of Chief Sustainability Officers (CSOs) in Türkiye’s Fortune 100 companies jumped from 4 to 12, with an 84% increase in companies setting sustainability targets and a 17% rise in those publishing sustainability reports. However, there is still a big potential for Turkish businesses to enhance consistency between its sustainability intentions and outcomes.
Along with the growing importance of sustainability among businesses, the course of Türkiye’s sustainability journey also will rely on the evolution of its regulatory framework and the availability of green financing. Currently, Türkiye’s evolution to a more mature regulatory landscape is still in progress, which makes green financing an even more vital component.
Türkiye needs approx. $100 billion in investments by 2030 to achieve its ambitious 2050 net-zero target. As such, increasing access to green financing is essential for Türkiye to effectively advance its sustainability, setting the foundation for a prosperous and sustainable future.
Businesses in Türkiye should integrate sustainability into their operating models and strategic processes to boost their resilience and competitiveness.
Operating model changes required include (i) embedding sustainability within daily operations, (ii) adapting business models to climate change, and (iii) leveraging sustainable innovations; these must supported by key enablers of (iv) collaborations with policymakers and (v) a focus on sustainable know-how.
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Designers Propose Cuts to Library Sustainability and Historic Preservation – Amherst Indy
Amherst Indy
Critical, Progressive, Independent
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Photo: https://www.joneslibrary.org/
Green Building Features May be Eliminated
After rejecting a lone construction bid that would have put the cost of the Jones Library renovation-expansion $7.2 million higher than the Town Council’s $46.1 million appropriation for it, Town Manager Paul Bockelman has admitted that the options for moving the project forward are limited.
Finegold Alexander Architects (FAA) have suggested that rebidding the project in the fall may succeed in attracting more competitive general contractor bids. At the request of the Town, FAA has prepared a “value management” set of design changes aimed at lowering construction costs by $2.9 million. This compilation of potential modifications comes after an earlier value management exercise accepted $1.9 million worth of feature reductions in the over-budget design.
A close look at the FAA list reveals the possible elimination of features that may be dear to the hearts of project proponents and donors (which technically includes all Amherst property taxpayers).
As a privately owned building, the Jones Library is exempt from Amherst’s Zero Energy Town Building Bylaw and its renovation plan has never included full renewable energy operation. Nonetheless, promoters have long touted the project’s sustainability features. At a March 2022 public forum, Trustee President Austin Sarat described the future library as “one of the greenest buildings, if not the greenest building in Amherst.”
Sarat then ran through a list of features that would contribute to the library’s greenness. “The building is going to be more insulated. The building is going to have many solar panels. The building is going to have a lot of windows which will allow sunlight and warmth to come in. Right now, we have an HVAC system in our building which is failing, so the building will be adequately cooled. The way in which the building is being constructed will not be using steel beams. We’re using cross-laminated timber that’s designed to minimize the carbon output during the process of construction.”
To make the project affordable, FAA has proposed putting most of these sustainability features on the chopping block. Gone would be solar panels, new double-insulated windows, and cross-laminated timber construction. Also suggested for elimination is a roof “light monitor” that would mimic the effect of the current library atrium in letting in natural light.
At the May 28 Jones Library Building Committee (JLBC) meeting, Trustee Treasurer Robert Pam attempted to describe a potential energy efficient air source heat pump system that might be placed in the rear of the building if plans for a 15,000 sq. ft. addition are abandoned, but Chair Sarat cut him off, ruling his comment as out of scope. Design plans for such an HVAC system as well as for an updated fire suppression system have already been developed and are owned by the town, Pam has argued.
The FAA list also includes replacing larger curtain wall punched windows on the new building’s north side with storefront-style windows.
FAA principal Ellen Anselone has estimated that fees for redesign work to document the value management changes might be $800,000. The elimination of green materials could necessitate re-running a for-fee TALLY assessment that quantifies embodied carbon in the new construction, said FAA’s Josephine Penta.
In addition to possible lost pledges from donors who contributed to the project based on its sustainability promises, questions arise concerning the Jones Library’s continued eligibility to receive a $1.1 million federal earmark for specific energy efficiency measures.
Cuts to Preserving Library’s Historic Character Proposed
As a recognized historic property represented in the Massachusetts and National Register of Historic Places, the historic character of the Jones Library is protected by local, state and national regulations.
The significant historic assets incorporated in the original 1928 building have been catalogued in a Historic Structures Report commissioned by the town in 2021.
Protection at the local level is guaranteed by a Preservation Restriction Agreement signed between the Town of Amherst and the Library Trustees as a result of the library accepting CPA funds for historic rehabilitation work. In particular, the document states that the Library “shall not make any changes to the exterior of the Building, including additions to and the alteration, partial removal, construction, remodeling, or other physical or structural change to the facades of the Building, and any change in design, material or color thereof” without prior express written permission by the town.
FAA’s cost reduction proposals include abandoning the planned reinstallation of much original millwork crafted from exotic woods, opting instead to “remove and discard millwork instead of retaining, restoring and reinstalling.” Only the staircase near the main entry would be retained.
FAA has estimated that eliminating historic millwork would save $1 million. Anselone explained that reinstallation is complicated by the presence of asbestos in the plaster throughout the original building.
“A specialized abatement person [would be responsible for] removing this, cleaning the asbestos off, tagging it with where it goes, and then storing it in the proper climate. Then when the new gypsum is put in, they would then have to fit all of this back in place, and that is tricky because you know the walls currently may be not be quite straight, and then the new walls go on and they’re straight and so it doesn’t always match up so there’s a lot of work,” she said.
Anselone described two options for replacing the millwork. An attempt could be made to match the original pieces, but this would likely be expensive and require extensive architectural drawing. The alternative is to replace it with simple trim like “what you’d see in a house.”
Another proposed hit to historic preservation would be abandoning the planned synthetic slate roof and going with asphalt shingles which have a shorter lifespan. Facilities Supervisor George Hicks-Richards wondered if this would be acceptable to the Amherst Historic Commission.
Also affecting the building’s exterior would be the proposed replacement of brick walls with fiber cement siding that would require periodic painting.
Trustee Pam cautioned that adopting these cost reductions would likely disqualify the library from receiving $2 million in state historic tax credits that the Capital Campaign has been counting on.
Also in jeopardy could be a $1 million National Endowment of the Humanities grant from the federal government that requires a Section 106 review of the project’s compliance with the National Historic Preservation Act.
Landscaping and Furnishings May Be Dropped
FAA proposed delaying several landscaping and utility upgrades to potentially reducing project cost. When this work would be completed and who would pay for it was not fleshed out.
Other cost savings raised by the JLBC consists of items outside the scope of design, such as furniture, fixtures and equipment (FFE). Library Director Sharon Sharry acknowledged that purchase of a $400,000 automatic book sorter to be placed in the historic director’s office is no longer planned. “Staff have already accepted the fact that the book sorter is gone,” she said. “It could it come another time,” she added.
FAA’s Anselone stated that the window for completing value management redesign in time to bid out in September is 12 weeks. If the Massachusetts Board of Library Commissioners agrees to extending the grant-imposed deadline for starting construction at their June 6 meeting, “the clock starts ticking on June 10,” she said.
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- Rob Kusner on Town Poised to Recommend Additional Funding for Regional Schools
DS Smith reports sustainability milestone – Recycling Today
The company has replaced more than 1 billion pieces of plastic across its international markets, surpassing its target 16 months ahead of schedule.
DS Smith says it has marked a key sustainability milestone in its Now & Next Sustainability strategy well ahead of its 2025 target.
The London-based packaging company announced it has replaced more than 1.2 billion pieces of plastic across its international markets, surpassing its goal 16 months ahead of schedule. Its target includes any primary or secondary plastic packaging that has now been removed from customers’ packaging as a direct result of DS Smith’s plastic replacement solution.
The milestone is rooted in DS Smith’s plastic replacement and reduction program that was established in 2020 as part of the Now & Next Sustainability strategy, which the company says supports its “purpose to redefine packaging for a changing world.”
By 2030, DS Smith aims to have all its packaging be recycled or reused.
“When we set our Now & Next Sustainability strategy, we wanted to include goals that delivered environmental change beyond as well as within DS Smith,” Chief Executive Miles Roberts says. “By innovating to help our customers replace or reduce plastic, we are responding to societal demands to reduce plastic pollution as well as growing our partnerships with customers.
“However, this is very much the beginning. There are many more positive impacts we can make by supporting our customers and communities in their sustainability goals and we are extremely motivated by this mission.”
These sustainability targets extend across DS Smith’s operations in 27 countries across Europe and North America, working toward what the company says is a shared, circular objective to design out waste and keep materials in use longer.
Several markets are highlighted in a news release announcing the achievement:
The United Kingdom has replaced the most plastic across DS Smith markets, having replaced more than 274 million pieces.
France ranks second, having replaced more than 260 million pieces of plastic.
Germany ranks third, having replaced more than 153 million pieces of plastic.
“Demand for plastic replacement continues to grow,” the company says. “Throughout east Europe, the company has almost doubled the amount of plastic pieces replaced since the target was set in 2020.”
DS Smith adds that critical to meeting its target of replacing 1 billion pieces of plastic are its circular design principles and metrics, which were created in partnership with the Ellen MacArthur Foundation. The company says each of its nearly 800 designers have been trained in the design principles and are able to assess performance against areas such as recycled content and recyclability, indicative estimated CO2 emissions, levels of excess waste and supply chain parameters in partnership with customers.
The company has implemented its design metrics across a range of sectors, including retail goods, food and beverage, automotive parts and industrial devices.
“Our Now & Next Sustainability strategy includes aspirations for ‘now’ and for ‘next,’ focusing on the sustainability challenges we are facing today as well as those that will impact future generations,” DS Smith says in a description of its sustainability goals. “This [will] allow us to lead the transition to a low-carbon, circular economy.”
The Potential Environmental Effect of Mycelium Composites on African Communities – AZoM
According to the findings published in Scientific Reports, scientists at the University of Bristol discovered that mycelium composites, biobased materials created from fungi and agricultural residues, can have a more substantial environmental impact than conventional fossil-fuel-based materials due to the high amount of electricity used in their production.
The team’s research demonstrates that this is further exacerbated in countries like South Africa, where fossil fuels are the primary source of electricity. This is made worse by the fact that mycelium composites have a shorter lifespan and require frequent replacements over the course of extended use, which raises the environmental impact overall.
Despite this discovery, they found that the total environmental impact of this technology could be reduced by combining alternate energy sources such as firewood.
Mycelium composites are considered a sustainable alternative to traditional fossil fuel-derived materials. However, the sustainability of these materials depends on various location-specific factors like resource availability, economic structures, cultural practices, and regulations. Our main focus was to determine if producing mycelium composites is sustainable in Africa and to identify which manufacturing processes have the most potential to damage the environment.
Stefania Akromah, Study Lead Author and Doctor of Philosophy, University of Bristol
The team now intends to assess the environmental impact of mycelium composite technology under various scenarios with the objective of reducing the overall footprint. They will conduct uncertainty analysis to confirm the accuracy of the current results and compare the footprint of mycelium composites to other emerging green materials that are or could be used in Africa.
They also want to explore the technology’s economic feasibility and societal ramifications to fully assess its long-term sustainability.
Stefania added, “Africa faces heightened vulnerability to climate change impacts owing to its limited financial resources, making it crucial to mitigate these impacts as much as possible. This study offers valuable insights that can be used to proactively address the potential impact of this technology on the environment and human health.”
Professor Steve Eichhorn, Director of the Centre for Doctoral Training in Composites, Science and Manufacturing (CoSEM), added, “It was interesting to find that even a technology that is generally perceived as sustainable can sometimes have a greater environmental impact than conventional fossil-fuel-based materials. This highlights the importance of life cycle assessment studies and the need to carefully consider all factors, including energy sources and lifespan, when evaluating new materials.”
He further stated, “Stefania’s work just demonstrates that it’s important, when conducting Life Cycle Assessments, that geographical considerations and cultural practices are taken into account to calculate sustainability. The right decisions can then be made to ensure that manufacturing has as low an impact as possible while also contributing to local economies and African livelihoods.”
The research was carried out utilizing a life cycle assessment (LCA) technique that adhered to the ISO 14040 and 14044 standards for assessing the environmental effect of materials or processes.
Akromah, S., et. al. (2024) Potential environmental impact of mycelium composites on African communities. Scientific Reports. doi:10.1038/s41598-024-62561-7
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DEQ working group haggles over environmental recommendations – Missoula Current
Last week, DEQ released the draft recommendations to the public, many of which had not received the full agreement of the working group members. DEQ Public Policy Director Rebecca Harbage said more than 40 public comments were submitted during the past week.
“We heard a lot of folks who really, strongly, deeply believe in the intent of MEPA, and that has been a point of conversation in this group. And a lot of folks who don’t want to see any recommendation move forward that seems to weaken any part of MEPA,” Harbage said.
During Wednesday’s meeting, it was the opportunity for the working group members to voice their concerns with the recommendations or how they were worded, and there were plenty.
The working group disagreed on a number of details related to the three recommendations on state consideration of the effects of climate change. Some of the debate was whether the state should conduct a climate “analysis” or an “assessment.” A few members, including Sen. Keith Regier, R-Kalispell, said he preferred “assessment” because it’s more subjective as opposed to an analysis, which can be interpreted as more rigorous.
Talen Montana representative Gordon Criswell added that any analysis should consider only the direct effects of greenhouse gas emissions, because the models used to calculate social cost are controversial. But Anne Hedges, Montana Environmental Information Center executive director, said it was lopsided to consider the economic benefits of a project but not the economic and social costs.
DEQ Director Chris Dorrington said that the social costs of climate change are highly contested.
“Social cost of carbon is a multiplier,” Dorrington said. “If social cost of carbon provides a multiplier, I’m arguing that people can do their own math and say the economic impact of those tons equals this, based on my dollars. I don’t want to become the governor of dollars in a model, and it’s obviously outcome-oriented beyond the responsibility of the agency.”
After a long discussion of whether having DEQ carry out “legal obligations under existing law” meant DEQ could set limits for greenhouse gases or just that DEQ didn’t get to rewrite MEPA, Harbage encouraged members to write up their dissents and submit them by the end of the week.
One recommendation was to create a predefined environmental assessment to fast-track permits related to asbestos, “high and dry” gravel pits and motorcycle wrecking facilities. Hedges said she strongly dissented on the gravel pit permits.
“The uptick in litigation against DEQ over gravel permits really indicates this is not a place to streamline the process. Instead, we need to get a handle on why we’re seeing such an increase in litigation since the (high and dry) legislation passed a few years ago,” Hedges said.
The other item that stirred heated debate within the working group was whether MEPA merely describes how the public process should be carried out or whether the public process has some teeth to the point of prompting the denial of a permit or project.
Darryl James, an energy and natural resource development consultant, wrote the recommendation that says Montana’s laws, such as the Mining or Clean Water Act, provide protection for the environment and MEPA just the process to provide a review of any impacts of a project. But Hedges disagreed.
“We think this section is trying to revise 25 years of case law, it’s trying to pretend like those decisions by the court didn’t in fact happen, and it completely repurposes MEPA. This is where Darryl and I disagree about substantive vs. procedural and what those two things mean,” Hedges said. “We think this section really misrepresents the state of the law and it would be a great disservice if people read this and thought this is how the law is supposed to be implemented today because it’s in error.”
James said the Legislature writes the laws, so it was up to the Legislature to look at the case law and decide whether more clarification was needed in the law to ensure MEPA was procedural.
“Is there language that’s confusing to the courts? Such as when every substantive statute starts with “mindful of our obligation of the Constitution to provide a clean and healthful environment.” That also appears in MEPA. The courts looked at that and said clearly, that’s meant to be substantive because it says the same thing that all the substantive statutes say. Well, maybe that was a miscue to the courts.”
After several minutes of back-and-forth, Harbage said the final report would say there was “significant dissent.”
Hedges asked Harbage how the final report would address all the dissent.
“We disagree strongly with some of the text,” Hedges said. “So how are you going to write the disclaimers? Do we have to say every single word that we think is wrong?”
Harbage said DEQ staff had decided that the report will emphasize that the subtask leads were responsible for writing the recommendations and the dissent for each recommendation would be summarized.
Jon Bennion, Washington Companies representative, said the working group report was meant as a public engagement tool and should not be cited in litigation.
“This was a good faith effort to have a public conversation, and for it to be misused, whether in litigation or otherwise, would be harmful to public engagement,” Bennion said.
The one item that had no dissent was the fact that MEPA designated the Legislative Environmental Quality Council as responsible for overseeing MEPA and how state agencies handle the public process, but it has done little recently to carry out that responsibility.
“There must have been a feeling somewhere along the way that the job was done. EQC quit focusing in that arena. But as we’re discovering now, the law has continued to evolve as case law has been applied. And it’s time for the EQC to resume their responsibility there.”
Contact reporter Laura Lundquist at lundquist@missoulacurrent.com.