Virginia Tech OK’s Intelligent Infrastructure Initiative

The Virginia Tech Board of Visitors voted Monday to approve a $78 million plan to make the university a leader in “intelligent infrastructure.” The term encompasses everything from self-driving cars and drones to smart construction and energy systems — areas, in the words of President Tim Sands, that are “related to energy systems for the cities of the future and the way that people move in and around those cities.”

“We set … aggressive philanthropy and industry targets and were able to meet them quickly,” Sands said. “It was ready. … We already had industry and philanthropy champing at the bit.”

Intelligent Infrastructure is a fascinating field of endeavor, and one that is well suited to Virginia Tech’s engineering strengths. Further, the concept, while hardly original to Tech, has yet to become a trendy buzzword that every university in America is chasing, so Tech may have an opportunity to establish a leadership position in the field.

As an economic development initiative that stimulates the growth of R&D and, potentially, the spin-off of new technologies and business enterprises, intelligent infrastructure is an exciting idea. There is a double benefit for Virginia if the initiative helps state and local governments in the Old Dominion devise solutions to chronic problems such as traffic congestion and aging, ill-maintained infrastructure. Strategically, the initiative makes sense.

In other action, the board also approved a 3.5% hike for in-state tuition & fees in the next academic year, bringing the full-year cost to $13,329. That increase exceeds the 2% increase in Virginia’s median household income (2015-2016 numbers) by a hefty margin, but Tech remains a relative bargain compared to other Virginia’s other public, four-year institutions.

Here’s my question: Where does the $75 million come from to finance this significant new initiative? Tech officials say the money comes from corporate sponsorships, philanthropy and other sources but not from tuition & fees. In political terms, Tech is claiming that the project is not being financed on the backs of students and their families.

Here’s what the Roanoke Times has to say:

The … funding will come from non-general funds, which comes from revenue streams other than tuition and mandatory fees.

University officials previously vowed to put about $75 million into the intelligent infrastructure destination area. Millions in private dollars were in the plans since last year, and now Tech has $25 million. The donors include John Lawson, president and CEO of W.M. Jordan Co., and a former board of visitors rector; the charitable foundation controlled by the Hitt family of HITT Contracting Inc., in Washington, D.C.; and two other donors who Virginia Tech declined to name.

A briefing report included in the board briefing materials provides a few more details (my bold face):

At this time, the university is requesting to move forward with a $6 million planning authorization for the $69.5 million of outstanding capital projects and capital lease components. The planning authorization will cover establishing a scope, schedule, delivery method, and complete design documents for each capital component. As with all self-supporting projects, the university has developed a financing plan to provide assurance regarding the financial feasibility of this planning project. The funding plan calls for the use of private gifts, overhead funds, revenues derived from the Dining Services auxiliary, and future external support.

If Tech can make the Smart Infrastructure initiative essentially self-funding, then it would seem to be a win-win all around and a model for Virginia’s other research universities.

Two sets of questions, though. First, how much of the project will be paid through “overhead funds?” What overhead are we talking about? Who’s paying for that overhead now? Does that amount to an indirect subsidy?

Second, how certain are we that “future external support” will materialize, and how contingent is the Intelligent Infrastructure initiative upon obtaining that support? Is there any chance that Tech will spent $70 million+ on the project and the external support might not appear? If so, who gets left holding the bag? In other words, who bears the risk?

Bacon’s Rebellion…. asking the questions no one else will ask.

Update: “Overhead funds” come from sponsored research. “When an outside organization sponsors faculty research (e.g. NIH, General Motors, DOD, etc.) the university collects an overhead fee, in addition to the actual costs associated with the research (such as salaries or equipment costs),” says Larry Hincker, retired associate vice president for university relations. “This is a good example of how sponsored research leverages new activities without using any state funds.”
(This article first ran in Bacon’s Rebellion on April 6, 2017)

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Regulation by Any Other Name

Most consumers of electricity in Virginia are unaware that their electric market is deregulated and therefore have the option to purchase power competitively.  However, in many ways, the market is “deregulated” in name only.  

Since 2007, a hybrid version of electric choice has been in place that, despite its assumed intent, severely cripples the principles of a market economy.  Under this system, with the exception of some 100% renewable clauses, retail choice is only allowed for large commercial and industrial customers who use 5 MW and above (along with aggregated loads that meet the 5 MW threshold – subject to SCC approval).  More troubling is a problematic “five year minimum stay” clause embedded in the legislative bill which states that,

“If a customer purchases electric energy from licensed suppliers it shall not thereafter be entitled to purchase electric energy from their incumbent electric utility without giving five years advance written notice of such intention to such utility.”

Therefore you must buy power from a supplier for a minimum of five years and provide a five-year notice before returning to your incumbent utility’s standard rates.  This clause makes it nearly impossible for consumers to “work the commodities market”, which is the intent of any commodities market.  It can also create an endless loop for the consumer.  The five year term will in actuality turn into a five year plus term unless you give your five year notice to return on day one of your supplier purchase agreement. This in turn would force the consumer to negotiate another supplier agreement on day two.  But who would do that?  Wouldn’t you need some time before determining if the current market prices fit your strategic/operational market needs and wouldn’t you need time to “feel out” your relationship with the supplier (what company can decide on day one if they like their vendor)?  Imagine if one had this stipulation placed upon the selection of cable television providers. Who among us can foresee five years into the future?  It gives the appearance that the intent of this clause is to prevent consumers from entering this “competitive” market or, at a minimum, make it very difficult (if so, it has succeeded).

When informed that Virginia’s electric market is deregulated, a common refrain from consumers is “what has changed and why are consumers now hearing of this?”  The short answer is that market prices can now compete with power company rates.  Although major competitive suppliers, registered to sell power in Virginia, attribute lack of competition to the obstacles mentioned above, they also say that energy market conditions are now conducive to a competitive market in Virginia.  

In 2007, before the U.S. energy revolution had time to fully impact market prices, Virginia’s regulated power company rates were competitive with market prices.  Fast forward to 2017 and the dynamics have changed, thereby causing a divergence between market prices and regulated power company rates and in turn creating a more competitive market.  The cause of this divergence is due to plunging fuel prices which have resulted in electric market prices experiencing consistent declines. Simultaneously, regulated power company rates have not declined at the same pace as market prices.  This is primarily due to record-breaking spending by regulated power companies despite the fact that they are experiencing flat or declining demand (capital spending for the largest regulated power companies in the U.S. hit an estimated record-breaking $117 billion in 2016).  

According to the U.S. Energy Information Administration (EIA), the flattening of electricity sales (electricity sales have declined 5 out of the past 8 years) reflects declining sales in the industrial sector and little or no growth in sales to the residential and commercial building sectors, despite growth in building construction. In addition, declining growth rates are the result of increasing efficiency of electricity-using equipment, a slowing rate of economic growth, and the changing composition of the economy, which has significantly reduced the number of electricity-intensive manufacturing facilities in the U.S.  

The divergence between market prices and regulated power company prices has recently encouraged consumers in some states to push for full deregulation.  For example, in November 2016, 72% of Nevada voters cast their ballots in favor of the “Energy Choice Initiative” which will open their electric market to competition.  Also of note, electricity prices in states with competitive choice have outperformed monopoly states in every sector (see chart).

The legislative discrepancy described in this article is crippling to a free market and detrimental to the full development of customer choice in Virginia. With market conditions competitive, it’s time to make changes to the current law.  At a minimum, the five year minimum stay/notice requirement should be eliminated.  Virginia has two very good power companies that consumers should be proud of.  They often tout their low power rates (and they should).  Consequently, they should not be – and I suspect they are not – afraid of competition.   So, let’s allow the free market to work in the competitive manner in which we all naturally assumed was the purpose when the legislature passed this bill in 2007.

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New Misinformation on Public-Private Partnerships

Anticipation that the Trump Administration’s trillion-dollar infrastructure plan will be based largely on long-term public-private partnerships (P3s) has led to a number of attacks on the P3 concept, most of which either fail to understand what it is or deliberately misrepresent it.

One of the cheapest shots is being presented as the work of Congress’s respected Joint Economic Committee (JEC). You can download a six-page summary on what appears to be a JEC letterhead, titled “Risks of Relying on Private Sector to Address America’s Infrastructure Needs.” But down at the bottom of each page, in small type, are the words “Prepared by the Democratic Staff of the Joint Economic Committee.” The report is largely an attack on the 10-page proposal from last fall’s presidential campaign, by Trump advisors Wilbur Ross and Peter Navarro.

Two of its criticisms are against the proposal’s call for federal tax credits for the equity investors—which I have argued are totally unnecessary, because there is no shortage of equity wanting to invest in US infrastructure: the shortage is of enough projects because most states don’t yet have workable P3 enabling legislation. Another is that the plan only deals with projects with bondable user-fee revenue streams, and therefore doesn’t address every infrastructure need. That’s true, and nobody ever claimed that it did. But there is a huge array of aging and inadequate airports, highways, and water systems that have or could have bondable user-fee revenue streams that would be good candidates. Would those fees be higher than what people pay today? Well, yes—things cost more to build today than 40 or 50 years ago, and current user fees aren’t enough; that’s why we have a large infrastructure backlog.

A more serious critique of P3 infrastructure is “No Free Bridge: Why public-private partnerships or other ‘innovative’ financing of infrastructure will not save taxpayers money,” by Hunter Blair, released by the Economic Policy Institute on March 21, 2017. Blair explains the difference between funding and financing, allegedly to debunk the notion that P3 concessions offer some kind of free lunch, which they obviously do not. He also seems to think P3s are being proposed because there is a shortage of financing, which he counters by defending traditional municipal bonding. But no serious advocate of P3s makes that argument. Instead, the case for P3s is based on advantages such as shifting (in particular) mega-project risks—cost overruns, late completion, inadequate user-fee revenue—from taxpayers to investors; tapping new pools of capital, including private equity and equity from pension funds; and guaranteed long-term maintenance, via enforceable performance requirements built into the long-term concession agreements. Blair never gets into those attributes of P3 concessions.

Blair does admit that boondoggle projects (with benefits far less than costs) “could be filtered out through the use of a P3.” He also concedes that, in principle, ongoing maintenance could be assured via a well-structured concession agreement, but then argues that most states don’t have the capability to craft or enforce such agreements. It is to address such needs that the U.S DOT has an office devoted to providing guidance on doing exactly that, including recommending that agencies such as state DOTs pay for high-caliber outside legal and financial expertise to be on their side of the table negotiating concession agreements.

But the worst part of Blair’s report is the section titled “Do P3s Yield Efficiency Gains?” Here he relies largely on a generally sound book by academic researchers Engel, Fischer, and Galetovic to make two of what he considers devastating critiques. The first is that “most of the lower costs for P3s come from sidestepping Davis-Bacon provisions that require the payment of prevailing [union] wages to construction workers.” I got in touch with Prof. Engel about this, and he expressed surprise, but in the book chapter that he emailed to me was the following sentence: “In general, PPPs often lead to efficiency gains because they allow firms to circumvent the provisions of the Davis-Bacon Act.”

In fact, the large majority of U.S. transportation P3 projects have received part of their financing from the TIFIA loan program and/or the issuance of federally tax-exempt Private Activity Bonds. A 2016 list from U.S. DOT’s TIFIA office listed 19 such projects. And because of the federal dollars involved in their financing, they are by definition subject to Davis-Bacon, Buy America, and other federal provisions. A larger table in Public Works Financing includes 32 such projects; besides the above 19, it includes three leases of existing toll roads, three totally private projects, two that were financed via all-debt 63-20 corporations and several others. I have no details on whether any of those used non-union contractors, but even if they all did, at most that would be 11 out of 32 projects—hardly what Blair claims are “most” such projects.

Blair’s second claim is that governments are taken advantage of by “opportunistic renegotiation” of concession agreements. This is a serious problem in parts of Europe and much of Latin America, where most of the concessions are not financed by toll revenues, and where government-business relationships are often, shall we say, cozy. I took part in a conference on this very subject at George Mason University several years ago, and was shocked to learn how common this practice is, especially in Latin America. But here again, Engel, Fischer, and Galetovic’s book’s section on U.S. P3s includes a table of 20 P3 concessions, and identifies eight of them (40%) as having been subject to “renegotiation”—a point Blair gleefully cites.

I have followed all eight of those projects, and none of them experienced the kind of “renegotiation” that is common in Latin America. Here is the list:

  • Port of Miami Tunnel—completed on budget, a few months late, at substantial cost savings compared with FDOT’s initial estimates.
  • I-495 Beltway Express Lanes—to maintain debt service after a low-traffic first year, Transurban, on its own, made a significant additional equity investment.
  • Pocahontas Parkway—defaulted on its debt service, changed hands several times, but no taxpayer bail-out.
  • Indiana Toll Road—filed bankruptcy due to over-leveraged initial financing and recession-induced traffic decreases; was repurchased by pension funds at a large premium over initial price. No taxpayer loss or bailout.
  • South Bay Expressway—bankrupt due to low traffic from Great Recession; equity wiped out, debt restructured; TIFIA office says no net loss; SANDAG bought toll road out of bankruptcy at half price, a great deal for them.
  • Las Vegas monorail—bankrupt due to low revenue; no taxpayer bailout.
  • Dulles Greenway—had to be refinanced due to early revenue shortfalls; the concession term was extended by the State of Virginia, but there was no taxpayer bailout.
  • SR 91 Express Lanes—profitable and successful, but bought out by OCTA to void a stringent non-compete clause.

As part of my email discussions with Prof. Engel, I sent him this list, and the only two points he made to justify any of them as having been “renegotiated” concerned the Indiana Toll Road and SR 91. In both cases, he pointed to taxpayers’ money benefiting the company involved. Because the State wanted to shield Indiana motorists from the increased toll rates for several years, it made a deal with the company to charge residents lower tolls initially, and compensated the company with shadow tolls. But that was the state’s initiative, not the company’s. As for SR 91, the company had no intention of selling what was moving forward as a profitable concession. When the County insisted on buying out the contract, the company rightly insisted on a market-based purchase price, which was calculated by a neutral third party based on the expected net revenues over the remaining years of the concession.

Prof. Engel and his co-authors have concluded, and say so in their book, that P3s are “the best option for transportation infrastructure,” and have devoted several books and many articles to this subject. But in this case, I think their definition of “renegotiation” has been shaped largely by their greater familiarity with the Latin American experience than that of the United States.

(The article first ran in Surface Transportation Innovation’s April issue)
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Farmers Score Win with Insecticide Decision

Mark March 28, 2017, on your calendar. The USDA and the U.S. EPA have been engaged in an epic dispute regarding the use of chlorpyrifos. The insecticide is used on at least 40,000 farms in the U.S. and on 50 different types of crops. If you read The New York Times story on the insecticide you would conclude that EPA scientists were merely protecting the health of young children and farm workers. The New York Times suggested EPA’s science had been rejected. The news article made no effort to review the powerful arguments made by USDA against EPA banning the use of chlorpyrifos.

Powerful new forces at USDA brought agriculture’s arguments to Mr. Pruitt’s attention and based on USDA arguments, the new EPA Administrator rejected the views from EPA staff. Mr. Pruitt last Wednesday evening declared “We need to provide regulatory certainty to the thousands of American farms that rely on chlorpyrifos, while protecting human health and the environment.” He said, “By reversing the previous administration’s steps to ban one of the most widely used pesticides in the world, we are returning to using sound science in decision-making – rather than predetermined results.”

All of agriculture owes an enormous debt of gratitude to Dr. Sheryl Kunickis, director of the USDA Office of Pest Management Policy. She summed up the importance of the March 28 decision saying, “it means that this important pest management tool will remain available to growers, helping to ensure an abundant and affordable food supply for this nation.” Kunickis and her team, in comments filed by USDA, obliterated EPA’s arguments to ban chlorpyrifos.

A few examples:
EPA proposed to revoke all tolerances for the insecticide chlorpyrifos. Kunickis and USDA declared EPA used overly conservative assumptions to calculate exposure to chlorpyrifos. USDA said EPA’s population adjusted dose led to higher exposure to chlorpyrifos “…which leads to the mistaken conclusion that chlorpyrifos as it is currently used, is unsafe.” USDA argued that the drinking water risk assessment used by EPA overestimated exposure because of removal of the insecticide at a treatment facility. EPA apparently made the assumption that chlorpyrifos would always be used at the highest application rate and on all possible crop acres. USDA said this approach was “…overly conservative and could be refined.” I would suggest the information shouldn’t be refined but it should be declared false because it does not represent fact.

Another devastating fact apparently ignored by EPA and The New York Times “[T]he USDA Pesticide Data Program (PDP) has sampled groundwater and drinking water for chlorpyrifos, including at school and daycare wells, for the past 15 years. No chlorpyrifos was detected in hundreds of water samples in 2010-13 at the parts per trillion level. USDA suggests that PDP water data be used in the chlorpyrifos analysis instead of the overly conservative modeling estimates.”

On top of using models, EPA said it did not have enough data and it used what is known as a default 10X FQPA safety factor which means you have a number and you lower it by ten times. The purpose of the safety factor is to account for uncertainties. USDA pointed out the enormous amount of data available and such a safety factor is simply inappropriate for chlorpyrifos.

EPA and its experts used epidemiological data. USDA claimed EPA’s studies were federally funded and the data should be made available. At the time USDA commented EPA had not nor would not release the data. Several pages of the USDA January 5, 2016, comments obliterate EPA’s science arguments. USDA outlines for EPA what a valuable tool chlorpyrifos is for farmers and the loss of the product would have major negative impacts on our production capacity and the economic stability of farms. Not an issue EPA concerns itself with. Several crops were highlighted. EPA was advised that chlorpyrifos is the only insecticide for cotton which has an adequate efficacy to prevent boll damage and damage from cotton aphids. For non-citrus tree fruit chlorpyrifos is critical to control tree-boring insects. Without chlorpyrifos there would be a 100% loss of the plantings. Other tree-boring insects must be controlled in stone fruit such as peaches. For some of these insects chlorpyrifos “…is the only effective option for control of borers in cherry and peach. There are no alternatives.” In citrus, chlorpyrifos is the only effective control for ants. USDA’s comments rely on science.

Result: Win for USDA and farmers.

(This article first ran in Farm Futures on April 3, 2017)

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Coal Ash Scare – Real or Not?

Coal-fired power plant scrubbers now remove 80-90 % of airborne particulate, mercury, sulfur dioxide, nitrogen oxide and other pollutants. But that means “fly ash” and noncombustible residues (what we used to call clinkers) must be sent to landfills. That’s opened a new front for anti-energy activists, who use accidents, “detectable” pollutants in water, and scary stories about health threats to advance their agenda.

In 2008, a Tennessee Valley Authority earthen retainer dam near Knoxville ruptured, sending 5.4 million cubic yards of rain-soaked fly ash into a nearby river, lake and neighborhood. Twelve homes were damaged by the muck, which contained low levels of arsenic, cadmium and other metals. The TVA’s cleanup efforts were less than exemplary, as were its measures to prevent the accident in the first place.

Companies and regulators clearly must do more to prevent accidents and pollution – and more to educate people about the actual risks involved. With a new fly ash playbook being tested in North Carolina, Virginia and other states, as part of the war on coal and the keep-fossil-fuels-in-the-ground campaign, those informational efforts are vital.

Duke Energy operates 14 coal-fired electricity generating plants in North Carolina – and several large fly ash facilities. Like coal itself, the ash contains trace amounts of hexavalent chromium (chromium-6 or Cr-6) and other metals that can be toxic to humans in high doses. Blazing temperatures bond the vast majority tightly in glassy vitrified ash, and well maintained impoundments ensure that few seep out.

However, tiny amounts can still escape into nearby surface waters and groundwater. Highly sensitive scientific instruments can now detect parts per trillion – the equivalent of a few seconds in 3,300 years. In 2016, an NC state toxicologist ruled that metallic levels detected in surface and ground water around the state were dangerously high. He blamed ash from coal-fired power plants and persuaded Tar Heel health officials to send “do not drink” letters to several hundred families living near coal ash disposal sites.

In his view, there is “no safe level” for exposure to Cr-6, and the state should slash its allowable level from 100 parts per billion down to 0.07 ppb (1,428 times lower). Other health officials reviewed the scientific literature, determined that amounts detected pose no health risk, noted that Cr-6 often seeps from natural rock formations into surface and ground water, and rescinded the warning letters. But the resulting controversy continues, and the company, regulators and politicians are trying to resolve it.

Duke Energy and many health experts maintain that Cr-6 levels found near the ash facilities (and miles away, from natural sources) are far below what cause health risks. But it wants to assuage concerns among families closest to the ash facilities. So the company offered to provide alternatives to their well water, by giving them access to public water sources or installing state-of-the-art home filtration systems.

In January 2017, the NC Department of Environmental Quality (NCDEQ) granted preliminary approval to these company plans for homes within one-half-mile of a coal ash impoundment. Final approval is contingent on state health and environmental departments certifying that water provided via these systems meets “applicable” or “appropriate” standards for each location.

Now activists say Duke and other companies should move millions of tons of ash from multiple depositories. Not only would that involve hundreds of thousands of dump truck loads, millions of gallons of fuel, and huge trucks lumbering through towns and along back roads and highways. A far more basic question is: Take it where, exactly? Who would want it? Activists certainly offer no viable alternatives.

Companies previously proposed turning fly ash into cement blocks or gravel, for construction projects. Activists quickly nixed that option, even though it would involve virtually no contamination risks. It’s becoming increasingly apparent that the real reason for all the vocal consternation is that these agitators simply want to drive coal out of business. Indeed, the same unaccountable, silver-tongued agitators also detest natural gas-generated electricity … and drilling and fracking to produce the gas. They oppose nuclear energy, and even want hydroelectric dams and power plants removed. They claim to support wind and solar, by conveniently ignoring the huge downsides pointed out here, herehere, here and elsewhere.

Forcing utility companies to spend billions relocating huge ash deposits to “lined, watertight landfills” (in someone else’s backyard) will bring no health or environmental benefits. But it will bankrupt companies, send electricity prices soaring, and hurt poor, minority and working class families the most.

If rates double from current costs in coal-reliant states like North Carolina and Virginia (9 cents per kilowatt-hour or less) to those in anti-coal New York or Connecticut (17 cents), families will have to pay $500-1,000 more annually for electricity. Hospitals, school districts, factories and businesses will have to spend additional thousands, tens of thousands or millions. Where will that money come from?

Virginia’s 665,000-square-foot Inova Fairfax Women’s and Children’s Hospital pays about $1,850,000 per year for electricity at 9 cents/kWh, but would pay $3,500,000 at 17 cents: a $1.6-million difference.

Will businesses have to lay off dozens or hundreds of employees, or close their doors? If they pass costs on to patients or customers, where will families find the extra cash? What will the poorest families do?

The war on coal, petroleum, nuclear and hydroelectric power is a callous, eco-imperialist war on reliable, affordable electricity, on jobs, and on poor and minority families. Policies that drive energy prices up drive people out of jobs, drive companies out of business, drive families into green-energy poverty.

Preventing ruptures and spills means selecting, building and maintaining the best possible ash landfill facilities. Safeguarding public water and health means properly addressing actual, proven toxicity risks.

The US Environmental Protection Agency and North Carolina set allowable Cr-6 limits at 100 ppb for drinking water (equivalent to 100 seconds in 33 years or 4 cups in 660,000 gallons of water). The state also applies a 10 ppb standard for well water. No one applies a 0.07 ppb standard (70 parts per trillion).

In 2015, the NCDEQ tested 24 wells two to five miles from the nearest coal plant or coal ash deposit; 20 had Cr-6 levels above 0.07 ppb but far below 100 ppb, underscoring its diverse origins. May 2016 tests could not even detect the chemical in Greensboro water, the News & Record reported.

A 2016 Duke University study found that hexavalent chromium is prevalent in many North Carolina surface and ground waters. Some comes from coal ash deposits, but much is leached from igneous and other rocks found throughout the Piedmont region of Virginia, the Carolinas and Georgia. Other health experts note that Cr-6 is found in 70% to 90% of all water supplies in the United States. Applying a 0.07 ppb would mean telling hundreds of millions of Americans not to drink their water!

Moreover, studies have found that Cr-6 in water is safe even at 100 ppb or higher. A 2012 paper in the Journal of Applied Toxicology concluded that regularly drinking water with 210 ppb of Cr-6 poses no health risks. (The real health problems involve airborne Cr-6.) ournal of Occupational and Environmental Medicine,US EPA and other studies buttress those findings.

Equally important, an ability to detect a substance does not mean it poses a risk. Cancer is certainly scary, but the risk of getting cancer is not the same as dying from it. And people routinely accept risks of dying from activities they happily engage in daily. For example, the National Safety Council puts the lifetime risk of dying in a motor vehicle crash at 1 in 113; that’s 8,850 times greater than the alleged lifetime risk of contracting cancer from 0.07 ppb Cr-6 in water. Drinking and smoking fall into the same category.

However, all too many people seem easily terrified by “detectable” levels of strange-sounding chemicals. 100% clean is not necessary, not possible, not found in nature and not a sound basis for public policy.

Coal and chemical controversies like these offer our nation, states and communities excellent opportunities to find novel solutions that recognize sound science, hidden agendas, often limited options, and undesirable repercussions of poorly informed policy decisions. Let’s hope they are up to the task.

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