What is the Great Lakes Coal Tar Sealcoat PAH Reduction Project?

What is the Great Lakes Coal Tar Sealcoat PAH Reduction Project?

What is the purpose of Great Lakes Coal Tar Sealcoat PAH Reduction Project?

The Great Lakes Coal Tar Sealcoat PAH Reduction Project goal is “This project supports reduction or phase-out of the use of coal tar-based sealcoats for asphalt pavement surfaces”(Minnesota Pollution Control Agency, 2013a).  One must note that a different project goal is listed on a non-MPCA website which states “…promote phase-out of coal tar-based pavement sealcoat (CTS) in order to reduce environmental loading of polycyclic aromatic hydrocarbons (PAHs)”(Great Lakes Coal Tar Sealcoat PAH Reduction Project, n.d.).  Note that the consistent phase between the two definitions is “phase out”.  Product phase-outs (bans) are accomplished by the use of product demarketing and deselection.  Kotler and Levy (1971) define the concept of demarketing as “that aspect of marketing that deals with discouraging  customers in general or a certain class of customer in particular on either a temporary or permanent basis” (p. 75).  Product deselection is a campaign of misinformation and junk science for the sole purpose of discouraging product demand (Hall, 2011).  Product demarketing and deselection are tied to the notions of pollution prevention, the substitution principle and the precautionary principle.  These two advocate tools will be explored in a future posting.  Common ideas among these three concepts are vagueness of definition, non-science based and are prone to abuse by advocates and politicians.

Who are members of this group and what is their role?

This project group is made up of several organizational groups including:

Minnesota Pollution Control Agency (MPCA)

MPCA act as administrator for the Great Lakes Coal Tar Sealcoat PAH Reduction Project.  On September 12, 2013 MPCA is awarded a grant from EPA Region 5 Great Lakes National Program (Great Lake Restoration Initiative) in the amount of $207,000 for the project title: “Reduction of PAH releases from CTS” (Grant #00E00814-3)(U.S. EPA-Greal Lakes Retoration Initative 2012).  It should be noted that various environmental non-governmental organizations (ENGO) was also involved by way of grants provided by MPCA. Project activity includes:

●Approach manufacturers, suppliers and retailers (Al Innes, 2013a);

●Track phase-outs(Al Innes, 2013a);

●“Experts” support preservation role and performance of alternative (Al Innes, 2013a);

●Outreach to property owners and managers (Al Innes, 2013a) and;

●Applicator/supplier no-CTS pledge(Al Innes, 2013a).

            The MPCA also engages in product demarketing and deselection.  Referring to the MPCA web page titled “moving to safer alternatives to coal tar sealcoats”, this page nothing but product demarketing and deselection campaign (Minnesota Pollution Control Agency, 2013b).  In addition, MPCA uses selective information in this campaign in that MPCA only used information that help support their claims.  One assumes that since MPCA touts itself as a science-based organization and that evidence-based investigates hold the key to the true.  The person using that assumption is wrong and MPCA utilizes selective and citation bias to help support their argument. 

 

            US EPA (US EPA)

Supplied grants to MPCA and University of Wisconsin Extension Cooperative under the Great Lakes Restoration Initiative Program(U.S. EPA-Greal Lakes Retoration Initative 2012; U.S. EPA-Pollution Prevention, 2013).  According to grant documentation, these grants we issued by EPA knowing they were for the purpose of product demarketing and deselection.  Other than providing funding to MPCA and UW SHWEC with grants, it is unclear what EPA’s role is within the Great Lakes Coal Tar Sealcoat PAH Reduction Project.

            University of Wisconsin-Extension Cooperative Solid and Hazardous Waste Education Center (UW SHWEC)

            On April 22, 2013 The University of Wisconsin-Stevens Point was awarded a grant from EPA Region 5 Great Lakes National program (EPA Great Lake Restoration Initiative) in the amount of $101,156 for the program titled “Pollution prevention grant program” which will help businesses go green by reduce the use of CTS and more green sealants (Grant #00E01053-1)(U.S. EPA-Pollution Prevention, 2013).

            There are many examples of demarketing coal tar based pavement sealer by UW SHWEC.  What make this demarketing even more severe (considering this is an academic institution) is that SHWEC was selectively utilizing the studies that gave the largest negative impact.  Since these were produced in an academic setting, this would be an example of citation and selection biases (Liebl, 2012; University of Wisconsin Cooperative Extension-Solid and Hazardous Waste Education Center, 2012a, 2012b, 2012c).  In no way was SHWEC utilizing the body of literature that shows that disproves theories advanced by USGS, MPCA and others.

Michigan Department of Environmental Quality (MI DEQ)-Pollution Prevention Program

MI DEQ’s role within the group is unknown at this point.  MI DEQ does have a pollution protection program. 

Great Lakes Regional Pollution Prevention Roundtable (GLRPPR)

  This organization is an environmental non-governmental organizations (ENGO) that “is dedicated to promote information exchange and networking to pollution prevention (P2) professionals in the Great Lakes Region of the United States and Canada” (Great Lakes Regional Pollution Prevention Roundtable, n.d.-a).  The organization states that “GLRPPR is your link to quality pollution prevention information, research, and expertise. GLRPPR has assisted thousands of industries, organizations, small businesses, and citizens within the Great Lakes Region to locate quality information and resources about compliance and pollution prevention. GLRPPR and its members are working together to make a cleaner tomorrow for the Great Lakes Region”(Great Lakes Regional Pollution Prevention Roundtable, n.d.-a).  Member organizations include MPCA, University of Wisconsin SHWEC, U.S. EPA and MI DEQ(Great Lakes Regional Pollution Prevention Roundtable, n.d.-b).  Specific members shown are Al Innes from MPCA and Dave Liebl from University of Wisconsin SHWEC(Great Lakes Regional Pollution Prevention Roundtable, n.d.-b).

            The sole purpose of Great Lakes Coal Tar Sealcoat PAH Reduction Project is to engage in product demarketing and deselection which will damage the market of coal tar based pavement sealer.  We have observed that there are many examples of these two activities occurring.  Al Innes from MPCA even stated these actions are to “phase-out” (ban) this product(Al Innes, 2013b; Al  Innes, 2013).  It ironic when a NGO or government entity states that they wish to help business.  Why then, are their action the opposite of what they stated? 

 

References

Great Lakes Coal Tar Sealcoat PAH Reduction Project. (n.d.). PAH Reduction through Phase-Out of Coal Tar-Based Pavement Sealcoats. from https://sites.google.com/site/greatlakespahreduction/home

Great Lakes Regional Pollution Prevention Roundtable. (n.d.-a). About GLRPPR. from http://glrppr.org/aboutus/glrppr_brochure.pdf

Great Lakes Regional Pollution Prevention Roundtable. (n.d.-b). GLRPPR members. from http://glrppr.org/memberlist/

Hall, B. (2011). Defending against product de-selection attacks-Where do we stand? Paper presented at the SPI’s Flexibile Vinyl Products 22nd Annual Conference, Bulington, VT. http://spi.files.cms-plus.com/about/VPD/Tuesday%207.%20Bill%20Hall-%20Venable%20%3D%20Defending%20Against%20Unwarranted%20Product%20De-Selection%20Attacks.pdf

Innes, A. (2013a, October 29, ). Great Lakes Coal Tar Sealcoat PAH Reduction Project Webinar 1:  Overview of Issues. from https://sites.google.com/site/greatlakespahreduction/home/fall-2013-webinar-materials

Innes, A. (2013b, November 20,). Great Lakes Coal Tar Sealcoat PAH Reduction Project Webinar 2:  State/Provincial Programs. from https://sites.google.com/site/greatlakespahreduction/home/fall-2013-webinar-materials

Innes, A. (2013). Webinar 1:  Overview of Issues. Great Lakes Coal Tar Sealcoat PAH Reduction Project. from https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxncmVhdGxha2VzcGFocmVkdWN0aW9ufGd4OjEwZWQzNmU5OGU5Y2Y1YzI

Kotler, P., & Levy, S. (1971). Demarketing, Yes, Demarketing. Harvard Business Review, 49(6), 74-80.

Liebl, D. (2012). Toxic Driveway Sealants=Public Health Hazard. from http://fyi.uwex.edu/shwec/2012/07/09/toxic-driveway-sealants-public-health-hazard/

Minnesota Pollution Control Agency. (2013a). Great Lakes Coal Tar Sealcoat PAH Reduction Project. from http://www.pca.state.mn.us/index.php/water/water-types-and-programs/stormwater/stormwater-management/great-lakes-coal-tar-sealcoat-pah-reduction-project/index.html

Minnesota Pollution Control Agency. (2013b). Moving to safer alternatives to coal tar sealcoats. from http://www.pca.state.mn.us/index.php/water/water-types-and-programs/stormwater/stormwater-management/moving-to-safer-alternatives-to-coal-tar-sealcoats.html

U.S. EPA-Greal Lakes Retoration Initative (2012). 2011 grants. from http://www.epa.gov/greatlakes/glri/2011grants.html

U.S. EPA-Pollution Prevention. (2013). Fiscal year 2012 pollution prevention grant summaries. from http://www.epa.gov/p2/pubs/grants/ppis/p2sum2012.html

University of Wisconsin Cooperative Extension-Solid and Hazardous Waste Education Center. (2012a). Beware of toxic driveway sealants. from https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxncmVhdGxha2VzcGFocmVkdWN0aW9ufGd4OjVhZWMyNjIzMDdmMzNjYTg

University of Wisconsin Cooperative Extension-Solid and Hazardous Waste Education Center. (2012b). Coal Tar-Based Asphalt Sealcoats-A Health and Environmental Hazard. from https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxncmVhdGxha2VzcGFocmVkdWN0aW9ufGd4Ojc1MzEwNDE5ZjRmMDRkY2U

University of Wisconsin Cooperative Extension-Solid and Hazardous Waste Education Center. (2012c). Identifying Coal Tar Based Asphalt Sealcoats-A Guide for Applicators. from https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxncmVhdGxha2VzcGFocmVkdWN0aW9ufGd4OjFjMmJlMWJkZDk5MTlhNGY

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