Search This Blog

De Omnibus Dubitandum - Lux Veritas

Sunday, May 10, 2009

The Butterfield Bill: Activity as a Substitute for Accomplishment, Part II

By Rich Kozlovich

On April 14th and 15th of this year the EPA hosted something that they called the Bedbug Summit, which “drew almost 300 state and federal regulatory, public health, and housing officials, academics, landlords/property managers, pest professionals, and other key stakeholders”

 On April 19th, 2009 I published a critique of EPA’s “Bedbug Summit”, called Bedbug Summit: Activity As A Substitute For Accomplishment, which clearly outlined what could only be called a great public relations deception and a farce. That is, if your goal is the control of bedbugs. If the goal was to misdirect, deceive and justify the creation of a massive, costly and ineffectual multilayered bureaucracy and promote ineffectual pest control programs such as IPM, then it was a smashing success. Quite frankly, it disturbed me to realize that for some reason I didn’t connect the dots at the time between this and the Butterfield bill. I know…I know…there is no such thing as a conspiracy.

Currently there is a bill introduced by Congressman G.K. Butterfield of North Carolina on May 5th, 2009 that the NPMA officially supports and has asked everyone in the structural pest control industry to openly support. The Butterfield bill is entitled, "Don't Let the Bed Bugs Bite Act of 2009", and based on what is in this bill that title is a misnomer.

NPMA believes that this:

“multi-faceted legislation provides critical resources to state and local officials to combat bed bug outbreaks in lodging facilities, residential housing and other settings. Specifically, the bill:

I. Establishes a state bed bug inspection grant program within the Department of Commerce for states to use to help fund inspections of lodging facilities;

II. Expands an existing grant program managed by the Department of Health and Human Services that already provides funds to states for cockroach and rodent control to be used for bed bug prevention and control;

III. Requires public housing agencies to include in annual plans,required by the Secretary of the Department of Housing and Urban Development, measures necessary for the management of bed bugs, similar to their current responsibility to manage cockroaches; and

IV. Directs the U.S. Centers for Disease Control and Prevention to investigate the public health implications of bed bugs.”

NPMA goes on to say:

“His legislation will grant state and local governments, in concert with the professional pest management industry, the necessary resources to more effectively and aggressively manage bed bug infestations.” 

 Before I go any further I wish to state for the record that I am not attacking any individuals at NPMA, their integrity or their work ethic. I have stated this in the past and I will restate it again….these people work and they work hard and they believe what they are doing is in the long term best interests of the industry. In their defense they believe that this bill is going to pass, whether we are on board or not, and in the long run this will give the pest control industry some positioning on these matters for the economic future of our industry.  It is that judgment and view that I wish to challenge.

Apparently Congressman Butterfield believes the first step in eradicating bedbugs is to create a grant program administered by the Commerce Department to inspect hotels and motels for bedbugs in each state. And that each state’s hotels will have 20 percent of their rooms inspected each and every year. Those inspections will be conducted by “trained inspection personnel” and money will be provided to “train the inspectors” and they shall do the following under this bill

I. inspections are conducted by individuals who meet the minimum competency standard or requirement for inspecting or treating rooms in lodging facilities for bed bugs, as adopted by the State agency charged with regulating pest
management
II. conduct inspections of lodging facilities for cimex lectularius, including transportation, lodging and meal expenses for inspectors;
III. train inspection personnel;
IV. contract with a commercial applicator, as defined in section 2(e) of the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136(e)), to inspect and treat lodging facilities for cimex lectularius;
V. educate the proprietors and staff of lodging establishments about methods to prevent and eradicate cimex lectularius.

And what will this little program cost. Fifty million dollars a year from 2010 to 2013! First off, Congress didn’t find anything that we didn’t already know. The fact of the matter is that taxpayer money is going to be wasted; and for what will the taxpayer’s money be wasted to the tune of fifty million dollars a year? To inspect rooms for bedbugs! We already have trained inspectors….they are called exterminators and they do it for free. They already know what to tell the owners and maintenance people and they certainly know what bedbugs look like and don’t need any further training. We already have health departments requiring treatment. We already have laws in each state that determines who can make those treatments. So, why is there a need to train “new” inspectors and who will these “new” inspectors be?

I don’t believe for a minute that pest controllers will be used for these inspections, except possibly at the beginning, no matter what it says about standards. This grant money is going to be used up by State Health departments, State Universities, State Agricultural departments or whoever is in charge of pesticide regulations in the state in question and they will set the standard to accommodate themselves. 

And because grant money will be available, they won’t have to take the inexpensive way out and use PCO standards. This money will go to state agencies, and I believe to the Health Departments, which will make them secondary de facto regulators of the pest control industry in their states.

This is nothing more than window dressing, creating a gigantic multilayered bureaucracy with the U.S. Department of Commerce, the Center for Disease Control and state agencies all over the country. Bureaucratic activity as a substitute for accomplishment, and when was the last time you saw a bureaucracy disappear?

Nowhere does it discuss the real issue: The EPA’s responsibility for this mess and the introduction of chemistry that works. This bill will spend fifty million each year and accomplish nothing, even if hotels are treated more often. Bedbugs will still be infesting homes, other businesses, buses, trains, cabs, schools…etc., etc., etc., ad nauseam, and where are the requirements for tools that will bring about proper control?

I. Inspections will not eliminate bedbugs.
II. It may fix the blame, but it won’t fix bedbugs.
III. Furthermore, I believe this will lay the ground work for more unnecessary regulations, unnecessary documented training sessions and added licensure.
IV. If that happens, and based on past history, I believe eventually that's where the grant money will go and the requirements will increase.
This isn’t leadership, nor will it manage bed bugs aggressively, effectively or otherwise. We need chemistry that works. This is a singular problem with a twofold solution.

First and foremost, we have to define the real problem. We need to outline the cause. Both of those are easy. We know the EPA is a fault for this plague, we need place the blame right at their feet. We need chemistry that works, either by returning old chemistry, changing labels of chemistry that is currently available or give us new chemistry that works. (NPMA is currently working with EPA on this matter)

Everything else is a waste of money, energy, time and only gives the impression of accomplishment where very little actually exists. There is nothing in this bill that provides for anything that isn’t already being done…. except for getting the fifty million dollars.

To perceive is “to become aware of, know, or identify by means of the senses, to discern, envision or understand. “ My "perceptions" of what is wrong with this bill were easily identified because they should have been obvious to the most casual observer.

So then, what are the “positive aspects” of this Bill?

I. Fifty million dollars is going to be spent every year, and who knows how much more in the future, and yet bedbugs will not be curtailed because of it.
Grant chasers will by positively impacted. That doesn’t seem very positive to me
except for those getting the money. Those with bedbugs will still have them.
II. A great deal of bureaucratic welfare is going to be created and still bedbugs are not going to be curtailed. That doesn’t sound positive to me except for the bureaucrats.
III. Legislators will give the impression that they are doing something worthwhile to stop this plague caused by the EPA. That doesn’t sound positive to me except for the legislators who will give the impression that they are actually doing something.
IV. The real cause of the problem isn’t identified. That doesn’t sound positive to me, except for the EPA who is responsible.
V. No new directives are part of this bill that requires EPA or anyone else to approve chemistry that works. That doesn’t sound positive to me, except for the pest controllers who will be getting large sums of money to control this plague with inadequate tools, and even if the tools needed to eradicate bedbugs are returned, this bureaucratic layer cake will never disappear.

What about the “general public”? How will they benefit? And please don’t tell me how better communications will make a difference in their lives. That isn’t even a logical fallacy.  That would be a blatant falsehood. The claim that this “proposed legislation …will be beneficial for all parties, including pest management professionals, regulatory agencies and the general public” is a fallacy of composition.

There is only one party that we should be focusing on. Not pest controllers, not regulators, and especially not regulators. The public!

It's the public and the public only who should be our one and only concern. In no way will this bill alleviate the public’s suffering. That, and only that, should be our concern. Everything else is horsepucky!

I would like to share a quote with everyone from Thomas Sowell.

“Life is all about tides. There are those who catch the tide and those who
row against the tide. Those rowing against the tide will always go in that
direction no matter which way the tide is moving. The rest have no direction and
will simply follow the tide. Those who row against the tide are in better shape
than those who go with the tide. Not only physically, but intellectually,
emotionally and psychologically! When the tide changes direction, and it will,
guess who will be in the lead? “

Saturday, May 9, 2009

Nuclear Reactor Realities

By DuPree Moore

From 1968 to 1973, I was an engineering officer aboard U. S. nuclear submarines. The chief engineer would routinely sneak back into the engineering spaces and trip some piece of equipment off the line. These were not computer simulations. The equipment really would be in an emergency condition. We would be sitting in the reactor control room, and suddenly alarms would go off. We would have to figure out what had happened, and recover from it. The equipment is designed to survive such accidents. After many decades of operation under those conditions, the Navy has had zero deaths from nuclear power. You are more likely to drown in your bathtub than to die from operating a nuclear reactor.

A coal-fired electric power generating plant uses 120 railroad cars full of coal every day. A nuclear plant uses one semi truckload of nuclear fuel rods every few years. All the spent fuel from every nuclear reactor in the United States could be stored on one football field, a pile nine feet tall. Recycle it as the French do, and the pile shrinks to three inches. In 500 years it will be less toxic than coal ash.

It is preposterous to talk about nuclear waste remaining toxic for tens of thousands of years. It is preposterous to talk about tens of thousands of deaths from a nuclear accident. Those analyses are based upon a laughable error. If one person eats 200 aspirin, he will die. These people figure that if 200 people eat one aspirin each, there will be one death. If two million people are exposed to a dose rate of one aspirin per person, there will be 20,000 deaths. In fact one aspirin is beneficial, and low levels of radiation are beneficial. Geographical areas with higher background radiation have lower levels of cancer.

Chernobyl proved just how safe nuclear power is. There was no containment vessel. All radiation was released to the environment. There were less than 200 deaths, all among on-site personnel. An exhaustive international inquiry under the UN found no documented health damage beyond the immediate vicinity (except for a slight increase in thyroid cancer among children, which can be completely prevented by taking inexpensive iodine supplements in the event of a nuclear accident). The area around Chernobyl has been declared a radioactive dead zone at radiation levels about the same as downtown Warsaw, Poland, and five times lower than Grand Central Station in New York City. Plants and animals flourish in the region, showing no ill effects. It is stark raving mad.

Three-Mile Island nuclear accident caused zero deaths, zero injuries, and zero radiation release to the environment. And it was not a close call. It might have been a close call from having much more extensive equipment damage, but the worst possible accident would still have been kept entirely within the containment vessel. There would have been zero deaths, zero injuries, and zero radiation released to the environment. If terrorists flew an airplane into a nuclear reactor, it would not rupture the containment vessel.

During the 1970's there was an anti-nuclear campaign, similar to the global warming campaign today. It was based on grossly inaccurate information, but it prevailed politically to impose onerous regulations which killed nuclear power as a source of electricity. I have seen a comparison of two nuclear power plants in the United States which began construction at about the same time. One finished up before the new regulations went into effect. It came in on budget, and generates to this day the cheapest, safest, and cleanest electricity on this planet. The second reactor ran afoul of the new regulations. It ran into massive cost overruns, and never was completed.

Lawrence Solomon was part of the anti-nuclear campaign during the 1970's. Today he has done some excellent research disproving the global warming theory, especially disproving the assertions of a scientific consensus about it; but to this day he is wrong about nuclear power. To this day he says, "Nuclear reactors run flat-out 24/7", and cannot be adjusted to match power demand. He is simply wrong. The reactor remains critical 24/7, but a reactor can be critical at zero power. The power output automatically matches the power demand. I have personally operated nuclear reactors, and I know for a fact what I am talking about. That is the kind of misinformation which has destroyed nuclear power, the greatest scientific advance in the history of the world.

Back to the “good old days”

US energy and climate plans would drag us back to 1905 – or 1862

By Paul Driessen

Today, President Obama wants to prevent “runaway global warming,” by slashing US carbon dioxide emissions to 80% below 1990 levels by 2050. According to Oak Ridge National Laboratory data, this reduction would return the United States to emission levels last seen in those halcyon days of 1905!

But America’s 1905 population was 84 million, versus 308 million today. We didn’t drive or fly, or generate electricity for offices, factories, schools and hospitals. To account for those factors, we’d have to send CO2 emissions back to 1862 levels.

The Civil War was raging. The industrial revolution was in its infancy. Malaria, typhus and cholera killed thousands every year. Life expectancy was 40 – half of what abundant, affordable energy have helped make it today.

No matter. The 648-page Waxman-Markey climate bill would compel an 80% CO2 reduction, by imposing punitive cap-and-tax restrictions on virtually every hydrocarbon-using business, motorist and family.

That’s making some legislators nervous, as they ponder the health, economic and employment effects of restricting energy supplies and driving up the cost of everything we eat, drink, make and do – especially in 20 states that get 60-98% of their electricity from coal.

So to prod Congress into action, or achieve the 80% target via regulatory edict, the Obama Environmental Protection Agency has decreed that plant-enhancing, life-sustaining carbon dioxide “endangers human health and welfare.”

The authoritarian actions it is contemplating would regulate cars, trains, boats and planes; pave the way for regulating farms and factories, hospitals, schools, apartment buildings, malls and lawn mowers; and send energy prices skyrocketing.

Thousands of climate experts say there is no crisis, computer model scenarios and predictions are meaningless, and CO2 plays little or no substantive role in climate change. A new Rasmussen poll finds that 48% of American voters now believe climate change is caused by natural forces; only 34% now think it’s due to humans.

Climate realists also recognize that, even if America eliminated all of its greenhouse gas emissions, soaring Chinese and Indian carbon dioxide emissions would promptly offset our draconian cuts.

This alarms climate alarmists. They fear it’s now or never to wrest control over energy and the economic, manufacturing and transportation activities it fuels. Now or never to profit from cap-and-tax laws and renewable energy mandates.

Corporate groups like the Carbon Offset Providers Coalition are banking on passage of Waxman-Markey. They want a “rigorous and efficient” CO2 scheme, to foster high carbon prices, maximum subsidies and strong profits.

President Obama says cap-and-trade will “raise” $656 billion over the next decade. The National Economic Council and other analysts put the tax bite at $1.3 to $3.0 trillion.

This is not monetary manna. The wealth will be extracted from every hydrocarbon-using business, motorist and family.

The intrusive energy rules and taxes will clobber households, manufacturers, farmers, truckers and airlines. The poorest families will get energy welfare, to offset part of their $500-3,000 increase in annual heating, cooling, transportation and food expenses. Everyone else will have to trim health, vacation, charity, college and retirement budgets to pay the higher costs.

Every increase in energy prices will result in more businesses laying off workers or closing their doors, more jobs sent overseas, more families forced into welfare, more school districts, hospitals and churches into whirlpools of red ink. Exactly how will they eliminate 80% of CO2 emissions by 2050, and pay skyrocketing fuel bills?

Where will we site hundreds of thousands of towering onshore and offshore wind turbines – to replace electricity we get from coal? Where will we get billions of tons of steel, concrete, copper and fiberglass to build and install the expensive, unreliable, subsidized monsters?

My grandmother used to say, The only good thing about the “good old days” is that they’re gone.

Few Americans will be enthralled by the prospect of returning to that era. Fewer will relish the hefty price tag – and damage to their freedoms, budgets, jobs, living standards and environment.

The White House, EPA and Congress need a serious reality check.

Saturday, April 25, 2009

20 Years of “Big Fears, Little Risks”

By Rich Kozlovich

In 1989 the American Council on Science and Health (ACSH) released a documentary called, Big Fears, Little Risks. This was very well received by the pesticide application, distribution and manufacturing industries. Back in those days I always “knew” where our industry stood. We “knew” that what we did was saving lives and protecting property with pesticides. Overall, people in agricultural “knew” that they were saving lives by feeding the world by growing and protecting their crops with herbicides, insecticides, fungicides and chemical fertilizers. We “knew” that the activists were wrong and needed to be stood up to and needed to be challenged. Somehow that has all changed. It was subtle and insidious, but greenies now infest our industries, and many times in positions of responsibility.

Many of these people, fresh out of school, “knew” that pesticides were evil and needed to be eliminated. They “knew” that IPM was the answer...for a while. When that didn’t eliminate pesticides, then they “knew” that we needed to start performing “sustainable” pest control that was “green", terms that are so indefinable that they can be defined and redefined to meet any new criteria the greenies want. They apparently accept every irrational scare promoted by the greenies. Whether it is asthma, endocrine disruption, cancer, or a host of other scares, they seem to embrace them and promote the idea that they are true.

Recently I attended a recertification class where the speaker presented slides that showed the whole list of irrational, theoretical scares promoted by the greenies. I challenged this as unscientific. He and I have had this conversation before, and even though he agreed with everything that I said…..the slide remains part of the training. Why?

It came as quite a shock to me when I came to the realization that there already was a cadre of greenies within the industry, hiding right in our midst, out in the open. As a result; things have certainly changed philosophically in pest control.

The real question is this; has reality changed? Do we really need to "go green"? What does it really mean? Have we protected society for over sixty years or do we really believe that we been killing society and the environment? If we are doing so many bad things, why then are more people living longer healthier lives than ever before. Do we really believe that getting rid of pesticides won't have seriously negative consequences? Why do we really “need” to go green?

I have been told by people that should know better that, “everyone knows what IPM is”! Really? Then why are there so many definitions? Why do state legislative bodies require that someone provide them with a definition for IPM? We have lost sight of reality in order to become acceptable to the activists and their latest philosophical flavor of the day, and that flavor being “green”.

I always remembered the film, Big Fears, Little Risks, and I wanted to get a copy so that I could harvest some of the quotes from men like Bruce Ames for an article I was working on. I sent out a request to a large number of people who might still have a copy. Some said that they would look and if they still had it they would send it to me. One finally did; I would like to thank Ted Bruesch of Lipha Tech for his generosity. A number of people in my network informed me that I could download it from the ACSH web site. That was embarrassing, since I am a member and didn’t know it was there.

Well, twenty years has gone by and it seems that the irrational thinking is greater than ever. I will be sixty three soon and I have watched the world changing in ways that I would have never dreamed possible. I see people being washed back and forth with every new philosophical flavor of the day like the waves of the sea being dashed against the rocks by the wind. I feel more and more like the voice in the wilderness. Big Fears, Little Risks was roundly praised in 1989. I really think that it would be a good time for everyone to review this documentary once again. We can never return to Camelot, but it would be nice to remember who we used to be; because if we fail to recognize who we were, how can be realize who we will become? Or more important; who we should become!

To go to the download page, click here and click the title - Big Fears, Little Risks and then follow the directions. You might consider becoming a member of ACSH. Donate here.

The Mighty Ohio

By James Marusek 

 Mr. Marusek has shown a remarkable ability to find historical references in old records and American literature to show that it is the sun’s cycles that is impacting the Earth’s climate; not anything done by man, and certainly not CO2.

The Ohio River is one of America’s mighty rivers. The river is 981 miles (1,579 km) long and carries the largest volume of water of any tributary of the Mississippi River. In spots the river is almost a mile wide. In the days leading up to the Civil War, it was a physical boundary that separated the free states (e.g. Indiana, Ohio, Illinois) from the slave states (e.g. Kentucky, West Virginia).

Harriet Beecher Stowe lived in Cincinnati, Ohio from 1832 to 1850. In 1851, she wrote “Uncle Tom’s Cabin”. Her life in Ohio was intertwined in this book.

In “Uncle Tom’s Cabin”, Eliza was a young light skinned mulatto slave living in an estate in Kentucky. She had a son, little Harry. One night she overheard a conversation between her master and his wife. Her only son had been sold and the papers were signed and delivered. Before noon the next day a brutal trader (Mr. Haley) would pick him up and steal him away. She went back to her cabin, took her son in her arms and fled. This was a dangerous proposition. If caught, she would most likely be put to death, as an example.

“The frosty ground creaked beneath her feet, and she trembled at the sound; every quaking leaf and fluttering shadow sent the blood backward to her heart, and quickened her footsteps. She wondered within herself at the strength that seemed to be come upon her; for she felt the weight of her boy as if it had been a feather, and every flutter of fear seemed to increase the supernatural power that bore her on, while from her pale lips burst forth, in frequent ejaculations, the prayer to a Friend above - ‘Lord, help! Lord, save me!”

She arrived at the shores of the mighty Ohio river an hour before sunset. “It was now early spring, and the river was swollen and turbulent; great cakes of floating ice were swinging heavily to and fro in the turbid waters. Owing to the peculiar form of the shore on the Kentucky side, the land bending far out into the water, the ice had been lodged and detained in great quantities, and the narrow channel which swept round the bend was full of ice, piled one cake over another, thus forming a temporary barrier to the descending ice, which lodged, and formed a great, undulating raft, filling up the whole river, and extending almost to the Ohio shore.”

Eliza stood in shock. Her planned escape was by ferry-boat. But the ice dashed those dreams apart. “The boats has stopped running.” She temporarily took shelter in a little tavern. Later as the dusk of twilight set in, she was discovered. “Her room opened by the side door to the river. She caught her child, and sprang down the steps towards it. The (slave) trader caught a full glimpse of her, just as she was disappearing down the bank; and throwing himself from his horse, and calling loudly on Sam and Andy (plantation slaves), he was after her like a hound after a deer. In that dizzy moment her feet to her scarce seemed to touch the ground, and a moment brought her to the water’s edge. Right on behind they came and, nerved with strength such as God gives only to the desperate, with one wild cry and flying leap, she vaulted sheer over the turbid current by the shore, on to the raft of ice beyond. It was a desperate leap - impossible to anything but madness and despair.”

“The huge green fragment of ice on which she alighted pitched and creaked as her weight came on it, but she staid there not a moment. With wild cries and desperate energy she leaped to another and still another cake; - stumbling - leaping - slipping- springing upwards again! Her shoes are gone - her stockings cut from her feet - while blood marked every step; but she saw nothing, felt nothing, till dimly, as in a dream, she saw the Ohio side, and a man helping her up the bank.” This was how Eliza carrying her son snatched freedom from utter disaster.

We are transitioning into Solar Cycle (SC) 24 and the sun has become fairly quiet. During most of the last century (SC 16-23) the sun has been in a “Grand Maxima”. As a result the Earth has experienced warming. But with SC 24 the sun is again changing states. From the peak year 1998, the lower Troposphere temperatures globally have already fallen around 1/2 degree Celsius. This is despite the fact that during that same time period, atmospheric carbon dioxide has risen 5% from 367 ppm to 386 ppm. Several solar scientist are predicting the sun will slide into a “Dalton Minimum” event in SC 25, about a decade from now. If that happens, the Earth will experience some bitterly cold winters for several decades. “Uncle Tom’s Cabin” was written shortly after the “Dalton Minimum” (1790-1830) came to a close. At the time the book was written, the earth had become a little warmer. If the sun again goes quiet and fall into another “Dalton Minimum”, then we will once again see the mighty Ohio River freeze solid in the winter.

http://gcdailyworld.com/story/1533819.html

Sunday, April 19, 2009

Bedbug Summit: Activity As A Substitute For Accomplishment

By, Rich Kozlovich

In the 1800’s there was no greater showman than P.T. Barnum. His flair for the extravagant dazzled the crowds. His museum in New York City was a “combination of zoo, museum, lecture hall, wax museum, theater and freak show. Barnum noticed that people were lingering too long at his exhibits. He posted signs indicating "This Way to the Egress". Not knowing that "Egress" was another word for "Exit", people followed the signs to what they assumed was a fascinating exhibit...and ended up outside”. If they weren’t done seeing what they wanted to see….they had to pay again.

I couldn't help but chuckle and shake my head at the thought of those who are directly responsible for this plague of bedbugs now wanting to find a solution through this big public relations fest. What better way to deflect attention away from the real perpetrators of this mess, themselves. P.T. Barnum would have been truly impressed with this trompe l'oeil!

I followed Pete Grasso's Blog comments about this "summit", and kudos to Pete who did an excellent job. Separate breakout groups were created on the second day to outline suggestions as to what should be done in five categories:

• Research
• Role of Government
• Consumer Education and Communication
• Pest Management Professional's (PMP) Education and Training
• Role of Property Owners and Property Managers
Pete listed the suggestions recognizing that there was bound to be some duplication. There were; but even the duplicates were slightly different. Here is the breakdown as I saw it, although some could slop over into other categories, and someone could have easily created sub-categories while organizing the suggestions, I wanted to simplify it, not complicate it further.

There were 34 suggestions that would expand the bureaucracy at every level of government, expand training and licensure requirements and potentially mandate IPM. There were 15 for expanded public information and who should be doing it, 10 for grant money for the professional grant chasers, 5 that would shift the blame, and 9 that actual had some worth, however….. no one blamed EPA. Oh yes, there was one who wanted to do this again and one who wanted to do this regularly. I have "condensed" the suggestions for the 34 regulatory expansion suggestions into some type of logical order as to what would occur if these "ideas" were to be implemented.

The government needs to recognize bed bugs as a public health pest. Then the government needs to form an inter-agency task force to address bed bugs, involving all levels of government with a definition of each level’s role, with a joint task force made up of the Environmental Protection Agency and The Center for Disease Control to better coordinate these agencies and levels of government.

They will then create a tracking system for better data from PMP feedback which will be the basis to justify the creation of a national bed bug foundation where professional pest controllers can report infestations to help create, and have access to a confidential database, and allow (or require) self-policing by PMPs to report misinformation, misapplication and the use of illegal products.

This will also act as a multi-agency Web site as a clearinghouse of bed bug information under the auspices of the EPA who will take the leadership role for all stakeholder parties; who will then form a committee or panel to explore adopting best practices and guidelines for the pest management industry drawing from previously developed materials.

They in turn will require states to set sanitary guidelines specifically for bed bugs and require that all local governments have consistent message/rules within local governments in line with nationwide training standards which will allow for a legislative bridge based on education, including legislation for disposal of infested bedding . In this way best practices can be harmonized and implemented over different jurisdictions.

In order for this to work at every level, voluntary standards should be established, or if necessary, imposed at a national level for accreditation for bed bug specialists, implement pesticide applicator certification for bed bugs, requiring a separate licensing for bed bug treatment, with continuing and specialized education opportunities for PMPs.

No pest controller will be allowed to treat for bedbugs without a certification program for professional pest controllers. This should be monitored by the National Pest Management Association who will provide training at all levels and create a separate, more stringent Quality Pro program that can initiate IPM standards, which should be mandated as soon as possible. All this will help people find qualified PMPs, which shall be encouraged through public education through an outreach program and corresponding web site which will be designed and maintained by the EPA and will carry standardized fact sheets with realistic treatment definitions that will support and promote Integrated Pest Management (IPM). The EPA will review bed bug efficacy protocols and report the results. This will then in turn create a need to hold mini bed bug summits in EPA regions.
When organized in this manner...it almost sounds rational… even to me. The reality is this; the EPA started this whole mess in 1972 when is was created by Richard Nixon with the intent of banning DDT, irrespective of the fact that they didn’t have the science to justify it, which William Doyle Ruckelshaus himself admitted when he acknowledged that it was a political decision, not a science based one. Technically, it didn’t much matter as we had a host of products in our armory to defeat just about every pest that attacks man and his environment. Philosophically it was devastating because DDT’s ban has been the basis for every rationale that attempts to justify the elimination of all pesticides and for every action taken by the greenies in and out of government ever since.

Unfortunately, no one seemed to get the message then, and we amazingly can’t seem to get it now. The goal of the greenies and their acolytes at EPA is the elimination of pesticides. Fraudulent science, the invalid interpretation of science and theoretical health scares was used at EPA under Carol Browner in 1996 to justify the Food Quality Protection Act; that is how we lost chlorpyriphos and a host of other products that had been used safely for decades. That certainly should have been a huge wakeup call! It wasn’t for large number of pest controllers or for those in leadership positions around the country. IPM became the mantra leading up to “green” pest control within the industry.

What would have happened if it turned out the bedbugs were very real vectors for disease? Currently it is believed that they are not, but we do know that there are a host of vectors out there that only pesticides protect us from. If we continue down this path we aren’t just going to have “quality of life” issues, such as allergic reactions, and infections from scratching the bitten area; we are going to start having body counts. We need to stop this nonsense about “bedbug summits” as if this is going to fix anything.

The fact of the matter is that the structural pest control industry already knows how to kill bedbugs. We don't need specialized training, certification and licensure. This is a singular issue with a two -fold solution.

I. WE NEED CHEMISTRY THAT WORKS!
a. Place the blame for this problem at the feet of those responsible, the EPA and the green movement
b. Return products that work or generate new ones

Everything else is window dressing, misdirection and activity as a substitute for accomplishment. Of the 9 common sense suggestions, two were for the return of old products and easier registration for new ones. Currently it costs about three hundred million dollars (that is $300,000,000) to bring a pesticide to market and structural pest control doesn’t use enough (anywhere near enough) to justify that cost and the patents only last so long. I have been told that they last for seven years and others have said that they last twenty. I don’t know which is correct, but either way….they have to sell an awful lot of pesticide to make up that R&D money.

That leaves these solutions; return products or change the labels of current products. All of that other costly, intrusive and ineffectual claptrap will be unnecessary. However, I do not believe that will happen if we do not fix the blame for this plague right where it belongs. We need to point the finger of blame right at the EPA. We need to expose their irrational and misanthropic regulations along with the irrational and misanthropic actions of the greenies that drive and support them.


###

Saturday, April 18, 2009

The Basic Science Of Carbon

A protest against carbon/CO2 cap and trade or tax proposals. This summary is being sent to politicians, media outlets, scientists, and others across the world. It is a protest against the madness of anti-carbon thought and policies.

By Wendell Krossa Apr 18, 2009

The Basic Science of Carbon/CO2: a brief summary (Why are we trying to limit- cap and trade, tax- the basis of all life?)

All life is built from carbon. All life depends on carbon for its existence and functioning. “All living things, starting at the cellular level which is common to all life, is based on carbon compounds, including the DNA that carry the gene sequences of the genetic codes. Of the trillions of cells in the human body,
there is not one of them that is not made of carbon.   
 
We subsist almost entirely on carbon dioxide. “The food used by all living things, to grow and to live, is carbon dioxide…food is carbon dioxide…the food of all plants and animals is carbon dioxide”.   Everything is made of carbon and fueled by carbon. All things need carbon to grow and reproduce.
 
There is only one source of carbon for all life- CO2 in the atmosphere. Plants absorb CO2 from the atmosphere (“they consume almost entirely carbon dioxide for food”- www.bydesign.com) and process it into carbohydrates for the animal kingdom. We get our food from this chain of CO2/carbon processing. “The only gateway through which carbon can enter the food chain to enable the biosphere to exist is through the carbon dioxide in the atmosphere. There is no other way. It all starts with CO2 in the atmosphere. The entire chain of life starts with plants absorbing this entirely natural, colorless, odorless, absolutely non-toxic aerial gas called CO2…more than 90 % of the dry matter of plants is simply processed CO2. Whether it is a cow eating grass or humans eating cows, all are eating- and being fuelled- by processed CO2” (Brinsmead, The Vindication of Carbon).

Recent levels of CO2 in the atmosphere have been unprecedented and dangerously low. Plant growth shuts down at 200 ppm (parts per million in the atmosphere). Plant life is stressed and unhealthy at such low levels. Life evolved over the past 500 million years at levels of CO2 that were on average a more healthy 1500 ppm (see paleo-climate graphs at sites such as Geocraft.com). A dangerous upper limit of CO2 in the atmosphere would be from 5,000 to 10,000 ppm. We are in no danger of approaching these high levels. Our atmosphere is currently “CO2 deprived”.

Plants and crops are healthier at higher levels of CO2 than are currently present in our atmosphere (now 386 ppm). They produce significantly more biomass, and are able to cope better with such natural vagaries as drought, heat, and cold. “More CO2 makes plants more resistant to extreme weather conditions…and this expands the habitat of many plants…and enhances agricultural productivity…and helps tropical rainforests”. Animals also survive better with more plant life. The small increase in CO2 over the past century has significantly greened the earth and this has increased populations in the animal kingdom. It has also enhanced the impacts of the Green Revolution with notably increased crop production which has helped to feed the poor.

Higher levels of CO2 in the atmosphere are more normal and natural.
 
Current world average temperatures are also abnormally low. Higher temperatures on an ice-free earth (a warmer earth) are more normal and natural (see paleo-climate graphs at Geocraft.com). We are in one of earth’s infrequent and abnormally cold ice-age eras (the past two million years). A warmer earth would be better for all life.

CO2 is not a pollutant but is a rare gas (1 molecule to every 3,000 molecules of the atmosphere) that is the essential food of all life. “All plants and animals are growing and living on a rare gas”. And while there are other potential pollutants associated with fossil fuel use, CO2 and carbon are not among them.

CO2 does not cause dangerous global warming. Rising levels of CO2 follow warming periods and do not precede or cause warming periods. CO2 does not cause dangerous global warming. Rising levels of CO2 follow warming periods and do not precede or cause warming periods.

CO2 does not cause dangerous global warming. Rising levels of CO2 follow warming periods and do not precede or cause warming periods. See the Vostok Ice Core research. Oceans, which hold 90 times the CO2 that is in the atmosphere, release CO2 as they warm and this increases atmospheric CO2 levels. The CO2 increases tend to lag behind warming periods by about 800 years.

Oceans, which hold 90 times the CO2 that is in the atmosphere, release CO2 as they warm and this increases atmospheric CO2 levels. The CO2 increases tend to lag behind warming periods by about 800 years.


CO2 is a tiny part of the greenhouse gases and the greenhouse effect.
 
The warming effect of CO2 gets lost among other much larger natural climate drivers. Human emissions of CO2 are even tinier (1 part per 100,000 parts of the atmosphere) and a human fingerprint causing warming is even more lost among natural influences. The human contribution to climate warming, if it were statistically detectable, would amount to nothing more than “a fart in a hurricane”. Natural climate drivers with strong, clear correlations to warming/cooling periods include cosmic rays (see Henrik Svensmark’s The Chilling Stars), solar flare cycles, related cloud cover, ocean current decadal oscillations (changing current patterns), earth’s 100,000 year wobble, and others.

CO2 levels have been as high as 7,000 ppm in the past and no dangerous global warming occurred. During the Late Ordovician Period (some 400 million years ago) CO2 levels were 4,400 ppm and Earth was as cold as it is now. Note also that Earth has been cooling since 2002 despite the fact that CO2 emissions have been increasing. “There is no valid correlation between CO2 emissions and global warming”, concludes geophysicist Norm Kalmanovitch.

Therefore, there is no scientific reason for us to worry about contributing to increasing CO2 levels. We do not need to reduce our carbon footprint. We do not need to reduce CO2 levels in the atmosphere or decarbonize our economies. As the 31,000 plus scientists who signed the the Protest Petition have stated, “There is no convincing scientific evidence that human release of carbon dioxide, methane, or other greenhouse gases is causing or will, in the foreseeable future, cause catastrophic heating of the Earth’s atmosphere and disruption of the Earth’s climate. Moreover, there is substantial scientific evidence that increases in atmospheric carbon dioxide produce many beneficial effects upon the natural plant and animal environments of the Earth”

To demonize carbon/CO2, as environmentalists have done, is to demonize life itself. This is ridiculous hysteria and entirely unscientific. The only way to fully understand this anti-carbon movement is to recognize that it is ideologically-driven extremism now gone utterly mad. Its real goal is to slow, halt, and even reverse economic growth and development and it uses carbon as a proxy to fight growth and the human enterprise. But the Green movement in demonizing carbon has become anti-green, anti-life, and anti-nature.

Wendell Krossa wkrossa@shaw.ca

Friday, April 10, 2009

SLASHING U.S. EMISSIONS



This appeared as an email from geologist Paul Driessen [pdriessen@cox.net] on the web site Greenie Watch. I have received permission from both Mr. Driessen and Mr. Ray to repint anything they write. I thank them both once again. RK


Regarding the recent AP story about UN climate talks stalling over emission cuts by rich countries:

I am astonished at how casually activists, bureaucrats and politicians toss out these carbon dioxide reduction targets – as though cutting US (or EU, Canadian, Australian, et cetera) emissions by some essentially random amount by 2020 or 2050 is actually within the realm of possibility. Unless we assume major technological advancements … and even if we accept the risk of widespread social and economic upheaval … these targets land somewhere along the spectrum of fanciful, absurd, irresponsible and disastrous.

The group of 130 developing countries wants a 40% reduction from 1990 levels by 2020. A faction of this group wants a 45% cut by 2020. President Obama wants to slash US CO2 emissions by 80% below 1990 levels by 2050. Earlier congressional proposals talked about 60% cuts by 2050. Greenpeace and other Climate Armageddonites insist that the world must get global CO2 levels well below 450 ppm (0.045% of the Earth’s atmosphere) by 2050 or earlier, despite expanding emissions from China and India – which means “guilty” developed nations must slash their emissions by some 90% by that date.

To illustrate the absurdity of these demands, one need only look at US carbon dioxide emissions data assembled by the Carbon Dioxide Information Analysis Center at the Oak Ridge National Laboratory, for the years 1800 through 2004. The following summary shows how far back in time the United States would have to travel, to achieve these various emission targets.

40% below 1990 levels = CO2 emission levels last seen in 1957

45% below 1990 = 1951

60% below 1990 = 1929 or 1940 (emissions fell during the intervening years of the Great Depression)

80% below 1990 = 1905

90% below 1990 = 1897

Barring major technological breakthroughs, a massive shift to nuclear power – or blanketing America’s wild, scenic, desert, grassland, agricultural and coastal areas with hundreds of thousands of wind turbines and solar arrays – the only way I see to achieve these goals is via enormous reductions in industrial output, air and auto transportation, food production, internet server use, heating and air conditioning, and living standards. (Right now, the United States is 85% dependent on hydrocarbon energy, and twenty states get 60-98% of their electricity from coal. The repercussions of cutting off access to that energy – or pricing it out of reach of poor families, small businesses and manufacturers – would be intolerable and immoral. And let’s not forget that every wind and solar “farm” needs CO2-producing natural gas-fired generators for backup.)

Perhaps millions of Americans would be willing to go part way along this route if Al Gore, James Hansen, Barack Obama, Nancy Pelosi, Harry Reid, John and Teresa Kerry, Henry Waxman, Nick Rahall and every warming alarmist environmental group would lead the way – beginning right now – by slashing their (private) jet travel, limousines, mansions, 78-degree White House offices, Bali and Bonn excursions, and big-carbon-footprint eco-lobbying offices. And perhaps millions of Africans would be content to continue living in poverty and deprivation – when elite eco-activists move into their own electricity-free, disease-ridden huts. But until then, I don’t foresee a citizens’ stampede to the lifestyles of 50 to 110 years ago.

As my grandmother always told me, “The only good thing about the ‘good old days’ is that they’re gone.” She grew up doing backbreaking labor on a Wisconsin farmstead, and didn’t have running water, indoor bathrooms or electricity until after she was married. I think her perspective is much more valuable than that of the climate alarm activists just mentioned.

Somehow I don’t see any of them adopting the lifestyle of the deprived and unfamous. They have no business imposing it on anyone else, especially by telling impoverished Africans (et cetera) that they must continue living “indigenous” lifestyles, to save the planet.

This is where the hysteria about “runaway global warming” and “catastrophic sea level rise” has taken us.

Before we head any further down this path, we (and our putative leaders) need to take a long, cold, honest look at scientific, energy and economic realities … our planet’s history of climate change … the absence of global warming over the past decade, even as CO2 levels continued to climb … the views and findings of 700-plus climate scientists who do not agree with the IPCC Summaries for Policy Makers … the enormous adverse impacts associated with biofuels … the speculative worst-case scenarios conjured up by abjectly unreliable computer models … the allegations, headlines and special effects that substitute for actual evidence in many circles … and the unwillingness of too many climate alarmists to engage in debate or even valid peer review with climate realists and skeptics.

Only then will we have anything remotely approaching ethical, responsible, reality-based policies on energy, economic, health, living standards and developmental issues that right now are governed far too much by an unsupported assumption that catastrophic, anthropogenic, CO2-driven global warming threatens our planet.

Friday, April 3, 2009

There are two paths ahead; each marked with a “Danger” signpost

(As everyone knows who has been a regular reader of Paradigms and Demographics and my weekly newsletter, Green Notes, Mr. James Marusek is a nuclear physicist and an engineer. He clearly demonstrates his expertise in this work. Please follow the links. The information is somewhat long, but I can’t emphasis enough how important that information is. I would like to thank him once again for allowing me to reprint his work. Click HERE in order to see the original PDF. RK)


James A. Marusek
2 April 2009


The sun has gone very quiet as it transitions to Solar Cycle 24. The Ap index is a proxy measurement for the intensity of solar magnetic activity as it alters the geomagnetic field on Earth. Anthony Watts (meteorologist) referred to it as the common yardstick for solar magnetic activity. The Ap index for February and for March is "5" a slight uptick from the three consecutive months of "4's" (November 2008 - January 2009). An Ap index of "4" is the lowest recorded number since measurements began in January 1932. This solar minimum has a long ways to go before it can be declared officially over.

As of the end of March, the cumulative number of spotless days (days without sunspots) is now at 586 days. The transitions into Solar Cycles (SC16-23), referred to as recent solar cycles minimums, averaged 362 cumulative spotless days. Those minimums ranged from 227 - 568 spotless days. Since the current transition now exceeds 568 spotless days, it is becoming clear that sun has undergone a state change. It is now evident that the Grand Maxima state that has persisted during most of the 20th century has come to an abrupt end.

The old solar cycles (SC 10-15) averaged 797 spotless days, over twice that of the recent solar cycles. Those solar minimums ranged from 406 - 1028 spotless days.

An increase in the number of cumulative spotless days during a solar minimum correlates to a reduction in the number of sunspots over the entire solar cycle. The old solar cycles overall produced 38% fewer sunspots than the
recent solar cycles.
We are now at a crossroad. Two paths lie before us. Both are marked with a signpost that reads “Danger”! Down one path lies monstrous solar storms. Down the other path lies several decades of crushing cold temperatures and global famine.

If either of these threats materializes, this nation will be hit blind-sighted. Both are related to the current state of the sun. The sun has been in a “Grand Maxima” for most of the past century. This has accounted for much of the natural warming the earth has experienced. But as evident in this solar minimum, the sun is changing states. It might (1) revert to the old solar cycles or (2) the sun might go even quieter into a “Dalton Minimum” or a Grand Minima such as the “Maunder Minimum”. It is still a little early to predict which way it will swing. Each of these two possibilities holds a great threat to our nation.

(1) Reverting to the “Old” Cycles (Solar Cycles 10-15)

Since the old solar cycles produced fewer sunspots, one might draw the conclusion that we will be entering a period of reduced solar storms. But this is not true. It is quite the opposite. The old solar cycles produced very intense solar storms. The greatest solar storm in modern time known as the Carrington flare of 1-2 September 1859 occurred in Solar Cycle 10. In addition to the Carrington flare, several other massive solar storms occurred during the old solar cycles. These massive solar storms occurred on 12 October 1859, 4 February 1872, 17-18 November 1882, 30 March 1894, 31 October 1903, 25 September 1909 and 13-16 May 1921. How can this be? This is because the old solar cycles produced massive sunspots. It was like the magnetic field energy was still there and had to still be released but during a shorter time interval, so the sunspots exploded in size and power.

If a solar storm of the magnitude of the Carrington flare were to occur today, the effect on our modern technologically dependent society would be grave. Of these, the greatest threat would lie in the loss of stable electrical power. A massive solar storm could destroy many of the large custom Extra High Voltage (EHV) powert ransformer in the United States. These items are unique, costly (around $10 million each) and have manufacture lead time of a year or more for replacement. In 2007, I described the effects from a massive solar storm in
Solar Storm Threat Analysis. I also laid out a civil defense plan for major solar storms called The Solar Storm Disaster Preparedness Plan. In 2008, the National Research Council took up the subject holding a public workshop to define the solar storm threat. Their finding (which mirrored mine) were published in a report titled Severe Space Weather Events Understanding Societal and Economic Impacts. In their findings, their bottom line was if a massive solar storm struck the United States today “it would result in large-scale blackouts affecting more than 130 million people and would expose more than 350 major transformers to the risk of permanent damage”. Imagine the effect of a total power blackout for months/years on 100 million people in the U.S. along with many millions across the globe. The report then goes on to say “Historically large storms have a potential to cause power grid blackouts and transformer damage of unprecedented proportions, long-term blackouts, and lengthy restoration times, and chronic shortages for multiple years are possible.”
(2) The Sun slipping quietly towards a Dalton Minimum or even a Grand Minima such as a Maunder Minimum.


Climate change is primarily driven by nature. It has been true in the days of my father and his father and all those that came before us. Because of science, not junk science, we have slowly uncovered some of the fundamental mysteries of nature. Our Milky Way galaxy is awash with cosmic rays. These are high speed charged particles that originate from exploding stars. Because they are charged, their travel is strongly influenced by magnetic fields. Our sun produces a magnetic field wrapped in the solar winds that extends to the edges of our solar system.

This field deflects many of the cosmic rays away from Earth. But when the sun goes quiet(minimal sunspots), this field collapses inward allowing high energy cosmic rays to penetrate deeper into our solar system. As a result, far greater numbers collide with Earth and penetrate down into the lower atmosphere where they ionize small particles of moisture (humidity) forming them into water droplets that become clouds. Low level clouds reflect sunlight back into space. An increase in Earth's cloud cover produce a global drop in temperature.

If the sun becomes quieter than the old solar cycles, producing more than 1028 spotless days,then we might slip into a Dalton Minimum or maybe even a Grand Minima such as the Maunder Minimum. This solar state will last for decades. Several solar scientist have predicted this will begin in Solar Cycle 25, about a decade from now. But a few have predicted this will occur now in Solar Cycle 24. A quiet sun will cause temperatures globally to take a nose-dive. We will experience temperatures that we have not seen in over 200 years, during the time of the early pioneers.

Temperatures are already falling. Satellites provide generally the most accurate atmospheric temperature measurements covering the entire globe. From the peak year 1998, the lower Troposphere temperatures globally have fallen around 1/2 degree Celsius due to the quiet sun. This is despite the fact that during that same time period, atmospheric carbon dioxide (at Mauna Loa) has risen 5% from 367 ppm to 386 ppm. The main threat from a “Dalton Minimum” or “Maunder Minimum” event is famine and starvation (affecting millions or hundreds of millions worldwide) due to shortened growing seasons and harsher weather. In the past, in addition to great famines, this cold harsh weather has also lead to major epidemics.

A taste of the cold weather due to a quiet sun.

Evidence of the Mississippi River, Ohio River, Allegheny River, Delaware River and Hudson River freezing and of very harsh winters.

Recent periods of quiet sun were the Dalton Minimum (1790-1830 A.D.), the Maunder Minimum (1645-1715 A.D.) and the Spörer Minimum (1420 to 1570 A.D.). The Maunder Minimum and Spörer Minimum were solar Grand Minima and each were individually referred to as the Little Ice Age.

A few decades after the Dalton Minimum
In the spring Eliza, a slave, carrying her young son, fled from Kentucky by crossing the Ohio River on foot. The river was “swollen and turbulent, great cakes of floating ice were swinging heavily to and fro in the turbid waters.” She leaped from one chunk of ice to the next until she reached freedom on the Ohio shore. [Source: Uncle Tomʼs Cabin. Harriet Beecher Stowe lived in Cincinnati, Ohio from 1832 to 1850. In 1851, she wrote “Uncle Tomʼs Cabin”. Her life in Ohio was intertwined in this work of fiction.]
During the Dalton Minimum
The Hudson River at the New York Harbor froze, enabling people to walk across the ice from Manhattan to Staten Island. The Hudson froze over completely during particularly brutal winter of 1779/1780, when the surface was solid for five weeks straight and the British rolled cannons over the ice. In 1821, taverns were constructed in the middle of the river to offer warmth and refreshment to pedestrians.
During the Dalton Minimum
Early settlers routinely waited till winter to cross the frozen Mississippi river in their wagon trains. In 1799, George Frederick Bollinger led a group of early pioneers from North Carolina to establish early settlements in Missouri. They hoped to cross their largest obstacle, the Mississippi River, on the ice, frozen solid in mid-winter. They arrived on the east bank of the Mississippi river opposite St. Genevieve in late December, pitched camp and explored potential river crossings. St. Genevieve is located about a hundred miles downstream from St. Louis. Daily the thickness of the ice was measured and then on December 31, a chopped hole in the ice indicated thickness well over two feet. The next day the settlers successfully drove their heavy loaded wagons across the river. [Source: “The Bollinger Migration to the Louisiana Territory”, part of "Bollinger Collection" compiled by Orena Bollinger in 1984.]

During the Dalton MinimumFrom 1803 to 1806, Captains Lewis and Clark lead a transcontinental expedition to explore the greater Northwest. During the winter of 1804/1805, the explorers set up a winter base camp near the Big Knife River near what is today the town of Bismarck, North Dakota. The winter was bitterly cold. There were 6 days with temperatures of -30oF or lower. These occurred in 1804 on December 12 (-38 degrees F), December 17 (-45 degrees F), December 18 (-32 degrees F), in 1805 on January 10 (-40 degrees F), January 11 (-38 degrees F), and January 13 (-34 degrees F). Compare this to the current low temperatures of Bismarck, North Dakota in which only one day in the past decade fell below -30 degrees F. On January 15, 2009 the temperature fell to -44 degrees F. [Sources: (1) The Journals of the Expedition under the Command of Captains Lewis and Clark, (2) Weather Underground for Bismarck, ND]

Between the Dalton Minimum and the Maunder Minimum
December 1776 was a desperate time for George Washington and the American Revolution. During the night of December 25, Washington led his small Continental army of 2,400 troops from Pennsylvania across the Delaware River made dangerous and barely navigable by huge chunks of ice. Once across they launched a surprise attack on the Britain's Hessian mercenaries at Trenton, New Jersey, capturing 1,000 prisoners and seizing muskets, powder, and artillery.
Between the Dalton Minimum and the Maunder Minimum
In Boston, Massachusetts on February 22, 1772, Anna, a young school girl, writes in her diary “Since about the middle of December, we have had till this week, a series of cold and stormy weather - every snow storm (of which we have had abundance) except the first, ended with rain, by which means the snow was so hardened that the strong gales at northwest soon turned it, and all above ground to ice.” In some streets about town this mixture of ice and snow is 5 feet thick. On March 11, she writes that the snow is now 7 feet deep in some places around her house[Source: “Diary of a Boston School Girl” written by Anna Green Winslow from 1771-1773, edited by Alice Morse Earle in 1894.]
Between the Dalton Minimum and the Maunder Minimum
Just before the opening battles of the French and Indian War in December 1753, George Washington, then 21 years old, crossed the Allegheny River. In their first attempt, Washington and a guide used a raft to cross the ice-choked river and this ended in disaster as Washington was knocked overboard in deep water and saved himself only by catching the raft as it swept by. The severe cold that night froze their clothes and the guide's fingers. The river also froze, however, allowing them to walk across on the ice the next morning. Soon they reached the safety of an English trader's settlement.

During the Maunder Minimum
During the Great Frost of (1683–1684) in England, the River Thames was completely frozen for two months, the ice was 11 inches thick at London. Sea ice was reported along the coasts of southeast England, and ice prevented the use of many harbors. The sea froze, so that ice formed for a time between Dover and Calais, joining England and France. The Thames was recorded to have frozen over at London during the years: 1649, 1655, 1663, 1666, 1667, 1684, 1695, 1709, and 1716.
During the Little Ice Age, growing seasons in England and Continental Europe generally became short and unreliable, which led to shortages and famine. These hardships were nothing compared to the more northerly countries: Glaciers advanced rapidly in Greenland, Iceland, Scandinavia and North America, making vast tracts of land uninhabitable. The Arctic pack ice extended so far south that several reports describe Eskimos landing their kayaks in Scotland. Finlandʼs population fell by one third, Icelandʼs by half, the Viking colonies in Greenland were abandoned atogether, as were many Inuit communities.

During the Spörer Minimum
By 1518, early explorers made significant progress in probing and surveying the New orld. They described North America as a “land of frozen seas, horrid, barren and scarcely habitable for cold”. “In the New World, cold predominates. The rigor of the frigid zone extends over half of those regions which should be temperate by their position. Countries where the grape and the fig should ripen, are buried under snow one half of the year; and lands situated in the same parallel with the most fertile and best cultivated provinces in Europe, are chilled with perpetual frosts, which almost destroy the power of vegetation.” [Source: The History of the Discovery and Settlement of America by William Robertson, 1826]

Saturday, March 21, 2009

Nuances and Good Vision

by Rich Kozlovich

Some time back a very good long time friend of mine accused me of not seeing the nuances of the issues we face. He stated; “You see things in strictly black and white. This one is an enemy, this one is a friend and there is no in between with you”. I told him that wasn’t true and that I actually understood the nuances and his comment was; “You think you understand them”.

Actually....., I think I understand them because I do understand them. I just don’t agree that we should have to constantly gray the facts and blur the truth while representing our industry.

• I believe that by accepting the nuances as truth we are actually accepting lies and publicity in place of facts and truth.
• I believe that when we do this we are giving aid and comfort to those that wish us ill.
• I believe that every time we give up something unnecessarily or inappropriately we are backing our industry into a wall.
• I believe that it is imperative that we recognize that we really do have enemies; that we must recognize them for what they are and deal with them accordingly.
• I believe that if everyone keeps turning reality into nuance, it becomes increasingly difficult to see reality and worse yet; to know what to do about it.
• I believe that it is important to understand the opposition’s views, but that doesn’t mean that I have to accept them. There is a difference between seeing the nuances and thinking that this is the way things should be.
• Aren’t nuances the shadow of substance? What reality do we face when we make the shadows real and the substance shadow?
• I believer that some things really are right and some things really are wrong.
• I believe the color gray is the same color as fog.

In my opinion there has never been a social phenomenon more nuanced than Corporate Social Responsibility. What exactly is Corporate Social Responsibility you ask? This link provides a good explanation of this business phenomenon. After following the link and reading the infromation; here are some points to ponder.

1. If CSR is being promoted because these ideas are so stupid they can’t be passed through the normal regulatory or statutory systems, why would anyone agree to them? What is the nuance here? Those who adopt CSR impositions don’t’ see the nuances.

2. If some businesses are embracing this concept so as to get a financial edge over their competitors, are they prepared for the unintended consequences that will appear long term? What is the nuance here? They will sell facts and truth to look good and make a few dollars more! They are totally unaware or uncaring about the long term consequences. In an attempt to look good to the public through publicity over this (in effect declaring that all others are irresponsible) are they selling their integrity for 12 pieces of silver?
3. If businesses feel they can use this publicity for the purpose of avoiding unpleasant regulations and joining with the “self-appointed representatives of "global civil society," are they destroying “the foundations of a free society”? What is the nuance here? “By obscuring the inherent conflict between individualism and collectivism, the doctrine of corporate social responsibility subverts the institutions of a free society. As these institutions—including private property, the modern corporation, and the free market—are the foundations upon which business depends, business leaders do a great disservice to their own interests—and ours—when they acquiesce to the demands of a Greenpeace or to the flatteries of the anti-capitalist intellectual class.” (I only wished I had said that myself. RK)

This leads me to ask some pointed questions.

1. Isn’t CSR actually irresponsible social behavior?

2. What if becomes socially responsible for corporations to demand the elimination of pesticides. Who will be responsible for the lives it will cost.

3. What if it becomes socially responsible to demand we all give up our property rights?

4. What if it becomes socially responsible to all accept a 30% hike in taxes so money becomes available for “the common good”? Who will decide what is the common good?

5. Has this socialist style mentality ever succeeded anywhere in the world? Has this socialist style mentality eliminated corruption or has it exacerbated it?

6. If you disagree with CSR, should it be okay if CSR activists picket you out of business. (this includes just about everyone in the activist community no matter what they call themselves.)

7. What happens when all responsibility for decision making is placed in the hands of these activists? Isn’t that what eventually happens when people use Neville Chamberlain’s “policy of appeasement”.

8. Does appeasement actually appease the activists or will it make them bolder and more demanding?

9. What if it becomes socially responsible to pay everyone twice a much? This actually happened in Russia after the Communists took over and they went broke.

10. Who decides how much people are to be paid?

11. What about the stockholders concerns for profit? Does this kind of action make someone liable for civil or criminal action if money is lost because the corporation flew off on some social crusade? What if the business goes under? If these kinds of actions cause someone to lose investment profits should the employee making these decisions be fired? Should investors like this kind of activity? Should stockholders concerns be ignored in place of appeasing activists? Should someone be arrested for misuse of company funds?

12. My final question is this. Are the chemical companies who manufacture pesticides part and parcel of all of this gamesmanship to the detriment of our industry?

Good questions, don’t you think? Actually I have one more question; does understanding nuances become a catch phrase that stands for the corruption of thought and action?

Oh....there is one more question to my good friend. Have I provided enough nuances for you, or do you think I missed something?

Truth Will Very Patiently Wait For Us.

By Rich Kozlovich

Activists make unscientific claims, totally convinced that they have all the answers and demand that everyone accept the idea that they know best about everything.  And they insist they should be put in charge of everyone’s life!

This is really scary! I'm not even sure if they have the questions!

Not only because they have crazy ideas, but also because as soon as they come up with a solution, they end up protesting the very solutions they have promoted. Worse yet, their solutions always seem to be meaningless failures at best, but at the worst, their solutions are deadly.

They make all sorts of claims and express deep concern about environmental disasters that are supposedly manmade. It would be nice if they were as concerned about the disasters they really have caused worldwide with their policies. Unlike their lunatic claims, these disasters are not theoretical.


These disasters are very real and very real people really are dying very real deaths and suffering very real afflictions; and it is happening to millions because of them. So then, why do we want to become green?

In spite of the fact that there is a whole history out there that shows what happens when greenie policy becomes government policy; we have this feel good activism within our industry. An industry that should know better! What could be more distrssing then that.

Over the years I have seen more junk science in the media than I thought possible. How could I be so sure that this stuff is “Junk”? I have read enough to know when something is odiferous and where to go to properly research the information for myself.


Also, some time ago I became a member of the American Council on Science and Health (ACSH) and as a result I found that every scare promulgated by the activists was responded to by ACSH; usually by the very next day. In 2007 they instituted the Morning Dispatch to members. Just about every morning ACSH has a dispatch in my e-mail box letting me know what new scare is being pushed and their response to it. 

These responses aren't always unfavorable as they are concerned with the facts and they are prepared to follow the facts wherever they may lead. Great stuff! This gives me a leg up in order to see what the whole story really is…..I don’t always agree with ACSH, albeit, I have great confidence in their expertise and integrity.

Last year their integrity was challenged by activists who didn’t like a stand they took on some issue. They claimed that ACSH only touted their position because they received funding from some large corporation, in spite of the fact that the amount was very small, and compared to be huge take the greenies bring in every year it certainly was a case of the pot calling the kettle black. At any rate Elizabeth Whelan handled this in a way that I will never forget. She told the activists whom ACSH stood against that if they thought that their views could be swayed by funding; then fund ACSH and see what happens. She didn’t get a check.

I would like to recommend that everyone consider joining…… This link
"Donate to ACSH" will take you to the appropriated page, and while there, take time to explore their site…..it is worth the trip.

Eco-colonialism degrades Africa


Green, UN, rich nation and African elites impose deadly anti-development colonialism


by Willie Soon and Paul Driessen

Sub-Saharan Africa remains one of Earth’s most impoverished regions. Over 90% of its people still lack electricity, running water, proper sanitation and decent housing. Malaria, malnutrition, tuberculosis, HIV/AIDS and intestinal diseases kill millions every year. Life expectancy is appalling, and falling.

And yet UN officials, European politicians, environmentalist groups and even African authorities insist that global warming is the gravest threat facing the continent. They claim there is no longer any debate over human-caused global warming – but ignore thousands of scientists who say human CO2 emissions are not the primary cause of climate changes, there is no evidence that future warming will be catastrophic, and computer models do not provide valid projections or “scenarios” for the future.

Warming alarmists use the “specter of climate change” to justify inhumane policies and shift the blame for problems that could be solved with the very technologies they oppose.

Past colonialism sought to develop mining, forestry and agriculture, and bring better government and healthcare practices to Africa . Eco-colonialism keeps Africans “traditional” and “indigenous,” by insisting that modern technologies are harmful and not “sustainable” in Africa .

Abundant, reliable, affordable electricity could power homes, offices, factories, schools and hospitals, create jobs, bring clean running water, and generate health and prosperity. But Rainforest Action Network and other pressure groups oppose coal and natural gas electricity generation on the grounds of climate change, and hydroelectric and nuclear power for other ideological reasons. They promote wind turbines and solar panels that provide electricity unreliably and in amounts too small to meet any but the most rudimentary needs.

Biotechnology could produce bumper crops that overcome droughts, floods, insects, viruses, and even global warming and cooling. But Greenpeace and Sierra Club oppose this precision hybrid-making technology, and instead promote land and labor-intensive subsistence farming.

DDT and insecticides could slash malaria rates that Al Gore and other climate alarmists falsely claim are rising because of global warming. But Pesticide Action Network and other activists stridently oppose their use, and the European Parliament recently imposed new pesticide restrictions that will further restrict African access to life-saving chemicals.

Recent incidents dramatize how depraved and deadly global warming politics have become.

In Gambia , a UN-subsidized “national ministerial dialogue” promoted extremist views on “catastrophic climate change” and “sustainable development.” A Forestry and Environment department representative asserted that it would be “nearly impossible to adapt to … impacts such as the loss of the West Antarctic ice sheet … and [resultant] 5-15 meter sea level rise.”

There was no mention of the near-zero probability of such an event happening. Average annual temperatures in Antarctica hover around minus 50 Centigrade (-58 F), while average temperatures for the two-month summer in its Western Peninsula are barely four degrees above freezing.

Scary tales of runaway temperature spikes melting 200,000 cubic miles of peninsular ice might be expected from Al Gore and James Hansen. But when Gambian ministers engage in such unscrupulous propaganda, they further degrade the health and welfare of their people.

Cameroon hosted a “fact-finding” visit from seven senior British Members of Parliament, who declaimed that climate change is “a jinx that threatens humanity more than HIV/AIDS.” They were joined by Cameroon ’s Minister of Forestry and Wildlife in urging that forests be managed to increase absorption of planetary carbon dioxide and “reduce global warming.”

Few climate actions, however, come close to the travesty being played out in nearby Chad . There the government has banned the manufacture, importation and use of charcoal – the sole source of fuel for 99% of Chadians.

“Cooking is a fundamental necessity for every household,” its Environment Minister pronounced. But “with climate change every citizen must protect his environment.”

The edict has sent women and children scavenging for dead branches, cow dung, grass and anything else that burns. “People cannot cook,” said human rights activist Merlin Totinon Nguebetan. “Women giving birth cannot even find a bit of charcoal to heat water for washing,” said another.

The government admitted it had failed to prepare the public for its sudden decree, but announced no change in plans – saying only that scarce propane might be an alternative for some. When citizens protested, they were violently dispersed by police.

“We will not give up,” a women’s group leader said. “Better to die swiftly than continue dying slowly.”

So this is where radical climate change alarmism has taken us. When the health of Planet Earth is at stake, human life means little – even if the “disasters” are nothing more than worst-case scenarios conjured up by computer models, headline writers, Hollywood , and professional doomsayers like Gore, Hansen and NOAA alarmist-in-chief Susan Solomon.

“Every time someone dies as a result of floods in Bangladesh , an airline executive should be dragged out of his office and drowned,” British arch-environmentalist George Monbiot hectored readers of The Guardian, in a typically hysteria-laced column.

One has to wonder if he would apply the same standard to eco-colonialist executives who continue to perpetuate poverty, disease, malnutrition and death in the name of preventing “global warming disasters” that fewer and fewer respectable scientists still believe are caused by human greenhouse gas emissions.

As economist Indur Goklany and even the UN climate panel acknowledge, future generations will be far richer than today’s. Poor families today should not be asked to bear the burden for richer families tomorrow, especially to guard against speculative climate and sustainability “disasters” whose “solutions” are worse than the purported problems.

The United Nations, European Union and United States need to address Africa ’s real problems and replace lethal eco-colonialism with fact-based science and humane public policies. And African countries need to take command of their future.

Africa needs to curb corruption. Adopt property rights and free enterprise principles. Promote sustained development. Utilize disease-preventing insecticides and modern agricultural biotechnology.

Rely less on foreign aid that is shriveling in the global recession and often comes with conditions and prohibitions that keep communities and nations deprived of energy and mired in poverty. Work with companies that want to develop natural resources, to get help building hospitals, schools and large-scale power plants that provide dependable, affordable electricity.

In short, Africa needs to remember Milton Friedman’s sage advice: “Poor countries should not do what rich countries did once they became rich. They should do what rich countries did to become rich.”

Soon is chief science adviser for the Science and Public Policy Institute and author of numerous papers on climate change. Driessen is senior policy advisor for the Congress of Racial Equality and author of Eco-Imperialism: Green Power Black Death.

Wednesday, March 18, 2009

The Power of Indefinable Words

By Rich Kozlovich

*-Updated 7-2-11

Words are powerful tools, especially when those words can't properly be defined and evoke a tremendous emotional response. Safe is one such word. Everyone wants their families to be safe. Everyone wants safe products. Well, what exactly does that mean? Does it mean that there can be no margin for error? Does that mean that there must be a total amelioration of all pain? Does that mean that nothing must ever go wrong?

Approximately 50,000 people die (*It is claimed that this number has dropped signifigantly over the last 10 years, although it is still high.  The actual number seems to be in question. ) every year on America’s highways. Is driving safe? Every year people die from accidental electrocution. Is electricity safe? Every year a great many children drown. Is swimming safe?

Is it possible to show that any product is safe? NO! You can only prove something is unsafe, otherwise you are asking someone to prove a negative, a factual impossibility. We can only prove what things do, not what they don’t do. It is like asking someone to prove that they aren’t cheating on their spouse. You can only prove that someone is cheating. You cannot in any way prove that someone isn’t cheating.

Yet we are being required to show that pesticides are safe before we use them. This irrational, unscientific demand is made over and over again, and done so without protest. Worse yet it is done with support from many in and around our industry. Why? Because safe is one of those difficult to define words that can unite people in a cause that makes them feel all warm and fuzzy all over, not mention the feeling of moral superiority. After all, who is going to support un-safe products and practices?

These issues surrounding DDT demonstrate such unintended consequences of such emotional causes. Even after all the evidence has shown that most of what Rachel Carson said was inaccurate, even to the extent of misrepresenting the facts; even after everything she predicted turned out to be wrong; even after all the pain and suffering that has been, and is still being caused by the ban on DDT; people will not properly connect the ban with the disasters banning DDT caused.

There are those who will still defend the ban with fallacious arguments and demand more bans and more restrictions in the name of safety...especially "for the children". They simply refuse to admit they were wrong, in spite of all the pain and suffering, and mostly to the children. Why? It isn’t simply a matter of pride either. This refusal to admit that which should be obvious to the most casual observer is being driven by a misanthropic philosophy called environmentalism. Call it an “organic” philosophy, call it a “green” philosophy, simply call it IPM, it doesn’t matter; the goal is to eliminate products that allow more people to live longer, healthier lives; and they do it with fallacious health claims about pesticides.

Thomas Sowell, in his book, Economic Facts and Fallacies, defined logical fallacies in the following manner. Fallacies are not simply crazy ideas. They are usually both plausible and logical – but with something missing. Their plausibility gains them political support. Only after that political support is strong enough to cause fallacious ideas to become government policies and programs are the missing of ignored factors likely to lead to “unintended consequences,” a phrase often heard in the wake of economic or social policy disasters. Another phrase often heard in the wake of these disasters is, ‘It seemed like a good idea at the time.” That is why it pays to look deeper into things that look good on the surface at the moment-

Let’s take the Fallacy of composition.  It goes like this; DDT is found in birds. DDT killed the birds. Let’s ban DDT. Since DDT was a pesticide, and it was found in birds that died, all pesticides must kill birds; let’s ban all pesticides. Pesticides are chemicals and pesticides were found in dead birds so chemicals must kill birds; let’s ban all chemicals.

Our industry is so hot to be green and yet we don’t seem to have a clue as to what “going green” is going to mean to society as a whole. GO GREEN! GO GREEN! is the cry, but where is this leading? The activists never seem to have to explain their motives or ultimate goals. What are those goals? Let us have no doubts that the elimination of pesticides is one of them.

Actually it should be immaterial to intelligent, insightful, compassionate people whether they explain their goals or not. We should be able to see what their motives and goals are by the devastation they have wrought in the rest of the world.

We now know that environmentalism isn’t safe. Tell me; do you think that environmentalism should be banned?

Sunday, March 15, 2009

The Approaching Winters

By James Marusek, Nuclear Physicist, Engineer U.S. Department of the Navy, retired

It was the year 1799, during the “Dalton Minimum” when the sun was quiet that George Frederick Bollinger led a group of early pioneers from North Carolina to establish early settlements in Missouri. They hoped to cross their largest obstacle, the Mississippi River, on the ice, frozen solid in mid-winter.

The pioneers and their wagon train moved westward a few miles each day, making and breaking camp each night, fording the small streams and floating across the larger ones on rafts which they made from the nearby trees, following roads that were barely trails through forests and valleys.

They arrived on the east bank of the Mississippi River opposite St. Genevieve in late December, pitched camp and explored potential river crossings. St. Genevieve is located about a hundred miles downstream from Saint Louis. Winter had come early and the Mississippi river was already covered with ice. It was bitterly cold. They determined the ice was not yet thick enough to support a crossing of ox-carts and covered wagons. Daily the thickness of the ice was measured and then on December 31, a chopped hole in the ice indicated thickness well over two feet. They tested the ice by making a few trips across on foot and horseback. The believed the ice was thick enough to support a loaded wagon.

As a test, a wagon was selected to be driven across with no one riding and the driver would walk ahead watching the ice and leading his team. The trip across and back to camp was made without the ice cracking and preparations were made for an early crossing New Years Day.

The next morning final preparations were made to break camp and all supplies were loaded. The weather remained bitter cold with dark skies overhead and light snow falling, but the decision had been made to cross and there was no turning back. The group was devout German Reformed Protestants and they gathered together in the early cold gray dawn to seek guidance from their God for a safe crossing.

The cracking of whips like pistol shots rang out over the heads of the oxen to coax them out onto the ice; the crossing had began. All that were able, walked to lighten the loaded wagons, keeping a safe distance from the wagons, which were also spaced far apart to lessen the danger of breaking the ice. The crossing was made successfully with no mishaps, except extremely cold hands and feet.

The townsfolk of St. Genevieve had built a large fire to welcome and warm these new settlers. Safely across the Mississippi, they were relieved of their crossing fears and enjoyed the local hospitality. They exchanged news from the East for information of what they might expect ahead. Needed supplies were purchased and even the weather abated a little as the sun broke through the clouds. They settled along the Whitewater River where the soil was rich.

We are transitioning into Solar Cycle (SC) 24 and the sun has become fairly quiet. During most of the last century (SC 16-23) the sun has been in a “Grand Maxima”. As a result the Earth has experience warming. But with SC 24 the sun is again changing states. From the peak year 1998, the lower Troposphere temperatures globally have already fallen around 1/2 degree Celsius. This is despite the fact that during that same time period, atmospheric carbon dioxide has risen 5% from 367 ppm to 386 ppm. Several solar scientist are predicting the sun will slide into a “Dalton Minimum” event in SC 25, about a decade from now. If that happens, the Earth will experience some bitterly cold winters for several decades.

The winters may once again resemble the winters 200 years ago during the time of the early pioneers. Imagine for a minute the west fork of the White River near Bloomfield, Indiana freezing into a block of ice two feet thick.

Thursday, March 12, 2009

Scientific Sanity and 2,4-D!


On February 23, 2009, the U.S. Environmental Protection Agency (EPA) closed the public comment period on a petition submitted by Natural Resources Defense Council (NRDC) seeking to cancel registrations of 2,4-D herbicide and revoke its residue tolerances. The Industry Task Force II on 2,4-D Research Data anticipates that EPA will deny the petition and stand on its major scientific reassessment of 2,4-D and determination of eligibility for continued registration completed in 2005. EPA is also well aware of ongoing studies to further strengthen the database on 2,4-D.

It is not unusual for the NRDC and other interest groups to petition EPA for the cancellation of a pesticide registration. In response to several recent petitions, EPA has published a notice inviting public comments, carefully reviewed those comments and ultimately issued denials of the petitioners’ requests. The EPA’s reviews and responses obviously take time to complete. NRDC's petition to cancel dichlorvos in 2006 resulted in an order denying the petition in 2007. EPA followed a similar time course in response to a petition to revoke tolerances for carbaryl in 2007 by denying the petition in 2008.

For 2,4-D, the Task Force does not take for granted that EPA will deny NRDC’s petition. Rather, the Task Force submitted detailed scientific comments in response to NRDC’s petition, and was pleased that its many friends also urged EPA to deny the petition given EPA's recent thorough and thoughtful review of 2,4-D in the June 2005 Re-registration Eligibility Decision.

During the 2,4-D comment period, over 431 comments were submitted; overwhelmingly supporting EPA’s 2005 re-registration decision. Some 14 comments were negative, but provided no new or compelling evidence for EPA to cancel the product. Thank you to all the foresters, ranchers, farmers, scientists and habitat managers that wrote the Agency, providing real-world information on the value of 2,4-D to their management programs.

The Industry Task Force II on 2,4-D Research Data and the many users of 2,4-D are proud of the more than 300 state-of-the art GLP studies on mammalian toxicity, ecotoxicity, environmental fate and residue that support 2,4-D registrations. EPA’s recent Re-registration Eligibility Decision thoroughly reviewed this data base against the demanding environmental, food and child safety standards of the pesticide laws, FIFRA and FQPA. Other governmental authorities, such as Canada’s PMRA and the EU’s pesticide regulatory authority have also given 2,4-D a clean bill of health. Simply put, few pesticides, indeed few substances of any type, have been so thoroughly tested and so often reviewed by authorities worldwide as the herbicide 2,4-D. The NRDC petition raises no new issues that have not been thoroughly considered by others before.

The Task Force’s comments that carefully respond to the petition’s allegations are posted on the Task Force website at www.24d.org. We are confident that the Agency will deny the petition and re-confirm its 2005 decision that when used according to label directions 2,4-D meets FIFRA and FQPA standards for registration and establishment of residue tolerances.


Jim Gray
Executive Director
Industry Task Force II on 2,4-D Research Data
james.gray@24d.org
1-800-345-5109
www.24d.org