Updated: Booming Export Industries, Agriculture & Mining, Easily Dodge EPA Regulations

the crossing point

Image credit: Paul Kedrosky

Until roughly 2010, US environmental regulation, as with financial sector regulation, had been 'back-tracking' steadily for nearly two decades. Environmental deregulation was often justified with the fantasy that all producers would on their own a.) voluntarily invest in system-wide efficiency improvements; and b.) add jobs in the USA if they had the freedom to operate without pollution control standards.* There were parallel fantasies for agriculture, as discussed below.Exports rule. Federal and state governments now strongly encourage exporting raw materials and food to where yesteryear's jobs went (Asia), in a desperate effort to maintain the balance of trade and to boost state economies.

The environmental corollary to encouraging commodity exports is acceding more political power to industries almost impossible to regulate for environmental protection and resource conservation sake. The significance of this added power hit me when I read in AgWeek that "Korean investors and North Dakota cattle ranchers plan a beef plant in North Dakota that could process about 1,200 animals each day. The Kim and Price Corp. plant would export about 60 percent of its beef to South Korea and sell the rest in the U.S."

Guess PETA will have to make a Korean language version of its next Super Bowl ad!

A similar trend can be observed for other commodities:
Sounds strikingly similar to recent reports of plans to export vast amounts of Western US coal to Asia.

Did you know, for example, that the US is the biggest fiber exporter in the world? See US cotton rises for third day as mills rush to buy for some back up on that claim.

The USA is also an increasingly important major supplier of soy and cereal grains to Asia.

Regulatory upshot:
EPA has an uphill battle ahead if it wants to enforce existing pollution control standards on the now-booming raw material export sectors. Non-point source pollution remains, by nature, diffuse and therefore difficult to measure and hold operators accountable for.

What you can't see you can't measure and what can't be measured can't be managed. It's that simple.

Vicious circle: The more China consumes of raw materials and food, the faster global prices for these items will rise, increasing US reliance on exports to hit that balance-of-trade sweet spot.

The more we export raw food and minerals to China, the greater the pressure to keep US production costs low - read as 'let them pollute freely.' ***
Viewed from a few steps back...
By the mid-1970's, the US had begin to transition away from the "dirty" history of the industrial revolution: a phase characterized by abundant, cheap natural resources, extensive reliance on a low-skilled work force, and use of inefficient (China-like) industrial processes for manufacturing and processing and food production.

Agriculture:- The Dust Bowl, which overlapped much of the Great Depression era, convinced the nation of the need to better conserve soil and water, led by government programs. More land had been under cultivation during the Dust Bowl than is cultivated now: by inexperienced farmers using crude techniques, flattening wind rows along streams, baring steep slopes, and suffering an extended drought ...enough said. It took half a century to rectify the really bad choices made by Dust Bowl era farmers.

Unfortunately, dumping programs put in place to prevent another Dust Bowl would be easy.**
Manufacturing:- The environmental strategy behind forward thinking companies wanting to exit the dirty phase in US manufacturing, doing it their own way, was nicely captured by the 3M Corporation-motto: 'Pollution Prevention Pays' or '3P.'

For those industries not willing to voluntarily invest in doing well by doing good, USEPA was at the ready with a regulatory kick at the pipe end, holding the foot-draggers to minimum performance standards.

And so it went, until China recently emerged as the world champion manufacturing competitor of all time, making pollution control and pollution prevention everywhere else a 'nice to have' rather than a 'must-have' item. Now we learn that the Champ must feed itself on not only US produced coal and fiber, but food. There are significant impacts fron China's increased consumption that will be felt right here and now, on what we eat and drink and breath.

Key point: Non-point source pollution attributable to the growth in exports will be in our nest. So, when we hear Obama and his economists remind us how important it is to increase US exports, helping keep the economy afloat, it's on us to remind them that effective non-point pollution control practices must be in place if soil fertility is to last for generations and drinking water to be fit for humans.

At highest political risk now...
EPA, statutorily bound to require best management practices at mines and feedlots, is increasingly being painted as unnecessary.

Witness, for example, the push-back against efforts to prevent mining waste from being used to fill river valleys in Appalachia, or to have feedlot manure odor and runoff curtailed.

Shrinking technological talent pool.
In the 1970's and 80's, the cost-effectiveness of end-of-pipe treatment was reasonably estimated by experienced process, industrial, and agricultural engineers: within the Agency and in regulated industries. Regulatory agencies and Congress could debate proposed standards based on straightforward cost curves, no hypothetical models needed.

Many of the engineers working in the USA when EPA developed discharge standards studied engineering to 'bootstrap" themselves up, off the farm, and into the middle class. They understood farming and mining and construction through personal experience. That's changed. Americans don't want to be engineers any more. Visit the top US engineering schools today and you'll see much of the talent base coming from where the jobs went.

So, who's going to straighten this out and how?

The politics are especially challenging.
It will always be difficult - maybe wrong-minded depending on your point of view - to try to control invisible, non-point source pollution sources only with a top-down command and control regulatory approach. Volunteer programs and indirect incentives will be essential in the future, as they are now.

However, it's very easy for politicians and lobbyists to portray a regulatory Agency as threatening jobs for no reason when there is no visible pollution to point to - when there's no 'in my backyard' mess to deal with. (Odor problems, pig stink on a big scale, for example, being one exception. Last year's coal fly ash spills were a paradigm smasher; but already we're back to business as usual.)

Green life style trends won't make it any easier for EPA to require controls of farm pollution, as organic and free range livestock raisers prefer to have their stock crapping all over the countryside instead of into a nice controlled lagoon.

You vegetarians don't get off the hook either. Exposed soil erodes no matter who eats the food grown on it.

The math.
Best management practices for non-point source pollution control in agriculture, construction and surface mining are commonly based upon the Universal Soil Loss Equation, which uses climate (rainfall frequency/intensity) as a key variable.

Foundation for solutions - a renewed believe in national self reliance.
Americans in general love to talk about self reliance and individual responsibility - usually in the abstract, or just focused on the right to own specific things or paying bills. Farmers, however, don't have time or resources for such blather. They wade in the muck and dust of our sustainance every working day.

I'm betting US farmers will be among the first to point out that soil erosion, drought, flooding, and wind erosion are putting the nation's food self-reliance in doubt. As does the issue of older farmers calling it quits with no exodus out of the city to the abandoned acres. And as does the rising price of oil.

Miners and mine owners we can't count on to support reasonable controls because the business model of liquidating mineral assets is traditional, as is calling in the Guard to put down any complainers.

So farmers it is. Not many Americans have even heard of the US Farm Service Agency, but as time goes on more of us will be involved the political debate over how soils can be stabilized and kept fertile to keep the nation food self-reliant in coming generations. When that debate kicks in, organic and free-range style production will be compared directly with industrial agricultural techniques. You know what? It won't be pretty.


* Continuing reductions in Toxic Resource Inventory (TRI) emissions, a trend tracked for decades by USEPA, was driven initially by increases in manufacturing efficiency. Now it looks to be a reflection of factory closure, mainly.

**I recently read where the US Ag Department might want to revisit for next year's budget the "working lands conservation programs" which keep tillable land on steep slopes in grass or as wildlife habitat, for example. Balance of trade...blah blah...tight budgets blah blah...re-allocation of resources blah blah.
***Secondary effect of China's rapidly increasing food consumption and inability to feed itself is creation of political instability in Egypt - also unable to feed itself - where dense-packed urban poor are given incentive to riot as food prices rise globally. Tertiary impact is when the riots threaten oil shipping through the Suez. A vicious downward spiral.

Updated: Booming Export Industries, Agriculture & Mining, Easily Dodge EPA Regulations
Until roughly 2010, US environmental regulation, as with financial sector regulation, had been 'back-tracking' steadily for nearly two decades. Environmental deregulation was often justified with the fantasy that all