How much industry self-regulation is too much?

The Environmental Law Centre at the University of Victoria, British Columbia, has recently published a report entitled Professional Reliance and Environmental Regulation in British Columbia. The ELC is a non-profit society that operates an environmental law clinic at the Faculty of Law. While the extensive report is focussed on BC government environmental activities it contains a number of insights that are worth broader consideration. Among these:

Much of BC’s deregulation goes too far in handing over what are essentially matters of public interest to those employed by industry.

  • Just over a decade ago the government adopted a goal of cutting or deregulating one-third of the regulations, coupled with an equivalent reduction in the size of the public service. Natural resource management and environmental protection laws and agencies were a prime focus for this initiative as government believed resource companies were significantly over-regulated.
  • Since then there has been negligible effort by government to assess the effectiveness of the current professional reliance regimes, or resolve to address known problems identified by the Auditor General, Ombudsperson, Forest Practices Board and others.
  • The approach to professional reliance is variable across regulatory regimes. Therefore, it would not be credible to make a blanket statement that “professional reliance is a success” or “professional reliance is a failure.”

The report proposes a set of ten criteria for regulatory “best practices” needed to maintain public confidence in resource management and environmental protection. These include:

  1. Clarity on who is qualified to perform professional reliance functions
  2. Clarity on professional functions, responsibilities and objectives
  3. Role reserved for government
  4. Formal procedures and clear rules for certification
  5. Conflict of interest, self-interest and independence
  6. Record keeping, disclosure and transparency
  7. Civil liability, insurance & bonding
  8. Duty to report non-compliance
  9. Auditing and reviews of professional work product
  10. Monitoring, compliance and enforcement

The report also proposes a series of threshold tests to determine whether it is appropriate for government to devolve responsibility for activities which have significant environmental impact:

  • Environmental, Health and Safety Risks: Government should regulate activity that poses a moderate to high degree of risk to the environment and public health.
  • Risk to Third Party Interests: In some cases the degree of risk to private property rights (e.g. pipelines on farm land), rights acquired through other Crown tenures (water licences, woodlot licences, commercial recreation tenures, etc.) and Aboriginal rights and title, and power imbalances in the ability of those third parties to defend them legally, argue for a role for government maintaining a greater degree of approval authority.
  • Decisions Involving Trade-offs: Many activities in the natural resource sector involve trade-offs between proponent interests and public interests in fish, wildlife, water, air, soil, scenic viewscapes, outdoor recreation, and more. Practices-type regulations cannot always effectively anticipate or address all of these issues. It is inappropriate to delegate decision making over trade-offs to private interests, unless the issues are minor and the activity poses low risk to these public interests.
  • Values versus Technical Expertise: Matters that are essentially about the values society places on a given resource that will be impacted by the activity or decision are problematic for single discipline oriented professionals. For example, it is one thing for a forester to prescribe seedling and stocking standards in a relatively uniform lodgepole pine stand without species at risk, and quite another to prescribe a harvesting system in a complex old growth forest that provides habitat for species at risk. The latter crosses over into issues requiring wildlife habitat expertise, and is not simply a technical issue squarely within a forester’s training.
  • Latitude for Discretion: In situations with broad latitude for discretion there is considerable merit in retaining the expertise resident within government agencies, and incorporating public input into decision making.
  • Scientific Certainty: There is a big difference between the engineering and biology advice required to construct a bridge or fish stream crossing, and the biological advice required to predict and evaluate broader ecosystem and wildlife impacts.
  • Conflicts of Interest: When government delegates decision making to professionals who are retained or employed by proponents, it introduces a risk of biased decisions.
  • Essential Government Functions: Some matters are essential government functions and should never be delegated to independent professionals employed by proponents. One example is compliance and enforcement.
  • Alternatives to Professional Reliance: Inherent in the notion of professional reliance is the need or desire to rely on a person with expert qualifications for matters that require discretionary judgment. However, in the natural resources sector there are many activities that have reasonably well known impacts that can be regulated in other ways, such as through international engineering standards or other industrial practice standards, sometimes known as Codes of Practice.

The full 155 page report can be found at

Research finds subtle connection between diethylhexyl phthalate and sexual change in infant males

A research project undertaken collaboratively by researchers at a number of major US medical schools has found a link between in utero exposure to diethylhexyl phthalate (DEHP) and male genital development in newborns. The effects are minor but are believed by the researchers to be statistically significant. DEHP is a phthalate that is used mainly in PVC plastic to make it more pliable but is also found in packaging, some hydraulic fluids, electrical devices (capacitors), some glowsticks, and plastics associated with medical devices.  One estimate is that about three million tonnes are produced worldwide each year. Most of this will eventually find its way into the environment. The male genital abnormality identified by the researchers is characterized as the anogenital distance (AGD). AGD, the distance between the anus and the genitals, is already known to be a biomarker of prenatal androgen (male characteristic hormone) exposure. The researchers found:

  • concentrations of diethylhexyl phthalate (DEHP) metabolites in first trimester maternal urine samples are inversely (adversely) associated with AGD in male, but not female, newborns.
  • even at current low levels, environmental exposure to DEHP can adversely affect male genital development resulting in reproductive tract changes that may impact reproductive health later in life.
  • these findings have important implications for public policy since most pregnant women are exposed to this ubiquitous chemical.

This is by no means the first time that GallonDaily has written about the possible endocrine disrupting effects of phthalates – enter phthalates into the search box at to see previous articles. DEHP is classified in the European Union as a Category 1B reproductive toxicant, a presumed but not proven human reproductive toxicant. In Canada the concentration of DEHP is restricted by regulation in soft vinyl children’s toys and child care articles where the soft vinyl can, in a reasonably foreseeable manner, be placed in the mouth of a child under four years of age. There are no regulations which serve to limit fetal exposure to DEHP in the womb.

An abstract and the full paper from which this brief summary is drawn will be published in the peer reviewed Oxford University Press journal Human Reproduction and are currently available at

US Government scientific panel explores food sustainability

Every five years the US Government establishes a scientific panel to review the Dietary Guidelines for Americans. This year, for the first time, the panel included food sustainability as part of its study. Two definitions provided by the Panel are relevant:

Sustainable diets: Sustainable diets are a pattern of eating that promotes health and well-being 24 and provides food security for the present population while sustaining human and natural 25 resources for future generations. 26 27

Food security: Food security exists when all people now, and in the future, have access to 28 sufficient, safe, and nutritious food to maintain a healthy and active life.

Among the panel’s findings in the area of food sustainability:

  • the environmental impact of food production is considerable and if natural resources such as land, water and energy are not conserved and managed optimally, they will be strained and potentially lost. The global production of food is responsible for 80 percent of deforestation, more than 70 percent of fresh water use, and up to 30 percent of human-generated greenhouse gas (GHG) emissions. It also is the largest cause of species biodiversity loss.
  • meeting current and future food needs will depend on two concurrent approaches: altering individual and population dietary choices and patterns and developing agricultural and production practices that reduce environmental impacts and conserve resources, while still meeting food and nutrition needs.
  • a diet higher in plant-based foods, such as vegetables, fruits, whole grains, legumes, nuts, and seeds, and lower in calories and animal-based foods is more health promoting and is associated with less environmental impact than is the current U.S. diet.
  • the average U.S. diet has a larger environmental impact in terms of increased greenhouse gas emissions, land use, water use, and energy use, compared to the Healthy U.S.-style Pattern, the Healthy Mediterranean-style Pattern, and the Healthy Vegetarian Pattern.
  • no food groups need to be eliminated completely to improve sustainability outcomes over the current status.
  • to supply enough seafood to support meeting dietary recommendations, both farm-raised and wild caught seafood will be needed. In the species evaluated, farm-raised seafood has as much or more EPA and DHA per serving as wild caught. It should be noted that low-trophic seafood, such as catfish and crawfish, regardless of whether wild caught or farm-raised seafood, have less EPA and DHA (both EPA and DHA are omega-3 fatty acids) per serving than high-trophic seafood, such as salmon and trout.
  • for the majority of wild caught and farmed species, neither the risks of mercury nor organic pollutants outweigh the health benefits of seafood consumption.
  • consistent evidence demonstrates that wild caught fisheries that have been managed sustainably have remained stable over the past several decades; however, wild caught fisheries are fully exploited and their continuing productivity will require careful management nationally and internationally to avoid long-term collapse.
  • the impact of food production, processing, and consumption on environmental sustainability is an area of research that is rapidly evolving. As further research is conducted and best practices are evaluated, additional evidence will inform both supply-side participants and consumers on how best to shift behaviors locally, nationally, and globally to support sustainable diets. Linking health, dietary guidance, and the environment will promote human health and the sustainability of natural resources and ensure current and long-term food security.

Among the Panel’s recommendations:

  • Enhance what is already being done by the private and public sectors to improve environmental policies and practices around production, processing, and distribution within individual food categories.
  • Support robust private and public sector partnerships, practices, and policies across the supply chain and extending from farms to distribution and consumption that can incentivize actions to develop a food system that embraces a core set of values that embody healthy, safe, and sustainable dietary patterns. Monitor, evaluate, and reward sectors that do this.
  • Establish new, well-coordinated policies that include, but are not limited to, agriculture, economics, transportation, energy, water use, and dietary guidance. Encourage all participants in the food system, as they are central to creating and supporting sustainable and safe diets.
  • Shift toward a greater emphasis on healthy dietary patterns and an improved environmental profile across food categories to maximize environmental sustainability, including encouraging consumption of a variety of wild caught or farmed seafood.
  • Improve the nutrient profiles of certain farmed seafood species, particularly EPA and DHA levels, through improved feeding and processing systems and preserve the favorable nutrient profiles of other seafood.
  • Establish strong policy, research, and 390 stewardship to improve the environmental sustainability of farmed seafood systems.
  • Offer consumer-friendly information that facilitates understanding the environmental impact of different foods in food and menu labeling initiatives.

The 571 page report is available at It is a long report with a great deal of information about nutrition as well as food sustainability and safety but it is well worth reading not only for the entire food industry but also for everyone who eats!

Very cold winter in eastern North America may be linked to warming of the Arctic

GallonDaily readers may have noticed that the recent very cold winter in eastern Canada has caused a number of climate change deniers to write letters to editors and elsewhere claiming that the winter is proof that climate change is not happening. A recent article by Jennifer A Francis of the Institute of Marine and Coastal Sciences, Rutgers University, and Stephen J Vavrus of the Center for Climatic Research, University of Wisconsin-Madison in the journal Environmental Research Letters provides evidence that the recent very cold winter in eastern Canada may in fact be a result of the impact of climate change in the Arctic.

The article presents evidence supporting a linkage between rapid Arctic warming and more frequent wavy jet-stream configurations that favour persistent weather patterns. Their results suggest that as the Arctic continues to warm faster than elsewhere in response to rising greenhouse-gas concentrations, the frequency of extreme weather events caused by persistent jet-stream patterns will increase.

The Arctic has warmed at approximately twice the rate of northern mid-latitudes since the 1990s owing to a variety of positive feedbacks that amplify greenhouse-gas-induced global warming. This disproportionate temperature rise in the Arctic is expected to influence the large-scale circulation, perhaps with far-reaching effects. The North/South temperature gradient is an important driver of the polar jet stream, thus as rapid Arctic warming continues, one anticipated effect is a slowing of upper-level zonal winds. The authors’ analysis supports the hypothesis that these weakened winds will cause the path of the jet stream to become more meandering, leading to slower Eastward progression of ridges and troughs, which increases the likelihood of persistent weather patterns and, consequently, extreme events.

Widespread Arctic change continues to intensify, as evidenced by continued loss of Arctic sea ice, decreasing mass of Greenland’s ice sheet, rapid decline of snow cover on Northern hemisphere continents during early summer, and the continued rapid warming of the Arctic relative to mid-latitudes. These events are driven by a phenomenon known as Arctic amplification – the enhanced sensitivity of Arctic temperature change relative to mid-latitude regions, but they also amplify it: melting ice and snow expose the dark surfaces beneath, which reduces the surface albedo (heat energy reflectivity) , further enhances the absorption of insolation (the total solar energy received on a given surface in a given time), and exacerbates melting. Expanding ice-free areas in the Arctic Ocean also lead to additional evaporation that augments warming and Arctic precipitation.

Put in the most basic language, the paper, if its analysis is correct, indicates that, when it comes to extreme weather events in eastern North America, you ain’t seen anything yet! For corporate, government, and even household planners the resulting advice might be to get ready for even greater extremes, both higher and lower, of temperature, wind, and precipitation. Far from being evidence that climate change does not exist, the cold winter in eastern North America may in fact be evidence that climate change is already happening.

The research paper Evidence for a wavier jet stream in response to rapid Arctic warming is available at

Evidence suggests mercury a possible factor in autoimmune disease in women

New research from the University of Michigan and McGill University suggests that mercury and methylmercury exposure may increase the risk of autoimmune disease in women of childbearing age. Autoimmune diseases, of which there are many, are diseases in which a person’s immune response starts attacking the person’s own proteins. Such diseases are often chronic, debilitating, and life threatening. They are reported to be among the top ten causes of death in women under the age of 65.

The study looked for association between an already existing database of mercury concentrations in the hair, blood and urine of pre-menopausal women and the concentration of antinuclear antibodies, an indicator of autoimmune problems. The study found that “low levels of methylmercury exposure are linked to subclinical autoimmunity, among females of reproductive age in the general population. As autoantibody development is a marker of immune dysregulation and may predate clinical autoimmune diagnoses by several years, the prospect that organic mercury acts as an early but potentially modifiable trigger relevant to a spectrum of autoimmune conditions warrants more intense investigation”.

Evidence of harm to health arising from mercury has been building slowly over the last few decades but this appears to be the first study suggesting a link to autoimmune disease. Inorganic mercury, from coal-fired power station emissions, dental amalgam, broken mercury thermometers, older thermostats and medical equipment, older mercury button cell batteries, a few medical liquids, some contaminated sites, and fluorescent lightbulbs and methylmercury in  mercury-contaminated fish are among the sources of environmental mercury. Mercury is an element and hence cannot be destroyed, nor can it be readily converted to non-toxic compounds though stabilization in certain matrices is possible.

Mercury and its compounds are subject to increasing levels of government regulation and those are likely to become more stringent as the evidence of the harmful effects of mercury builds. Brandowners still reliant on mercury in their products are encouraged to seek effective replacements as soon as possible. Meanwhile all end of life mercury-containing products should be collected and sent to properly managed mercury recovery and recycling facilities.

The report Mercury Exposure and Antinuclear Antibodies among Females of Reproductive Age in the United States: NHANES is available as a PDF file at





Marine plastic pollution and seafood safety

An article by a reputable science and environment journalist in the current issue of Environmental Health Perspectives, a journal of the US National Institute of Environmental Health Sciences, summarizes what is known and not known about the public health effects of eating seafood from oceans that are contaminated with plastic residues. GallonDaily’s summary: we do not know much about this complex topic, we need to conduct much more research, but in the meantime we should recognize that seafood is probably not the major pathway for human exposure to microplastics and their possibly associated toxic chemical burden. Among the findings:

  • Studies have demonstrated plastics’ tendency to take up persistent, bioaccumulative, and toxic substances, which are present in trace quantities in almost all water bodies.
  • The constituents of plastics, as well as the chemicals and metals they have taken up, can travel into the bodies of marine organisms upon consumption where they may concentrate and climb the food chain, ultimately into humans.
  • While current research cannot quantify the amount, plastic in the ocean does appear to contribute to persistent, bioaccumulative, and toxic substances in the human diet.
  • There is a lack of controlled experimental work completed on the topic and it’s very difficult to disentangle direct human pollutant exposures and bioaccumulation via plastic versus food and environmental sources.
  • Due to their hydrophobic nature, persistent organic chemicals—including polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), polybrominated diphenyl ethers (PBDEs), dioxins, and DDT—have been shown to preferentially sorb to [be taken up by] plastics when they encounter them in the ocean.
  • Once plastics have been consumed, laboratory tests show that chemical additives and adsorbed pollutants and metals on their surface can leach out and transfer into the guts and tissues of marine organisms. However this process has not been proven to occur in the natural environment.
  • A 2014 study showed an association between concentrations of certain PBDEs in fish and levels of plastic debris accumulation in the South Atlantic Ocean. However, no such association was seen for concentrations of BPA, alkylphenols, alkylphenol ethoxylates, or PCBs in fish.
  • Government, academic, and independent sources interviewed for the article almost unanimously expressed a mix of skepticism and concern toward the thought of ocean plastics posing a human health risk.
  • Human exposure to microplastics and plastic additives is more likely to stem from intact goods prior to disposal than from seafood. Clothing fibres make up a large proportion of the microplastic found worldwide and even drinking water and foods such as honey can be contaminated with microplastics.
  • The end goal need not be to abandon the use of plastic. The benefits of plastics can be realized without the need for emission to the ocean.
  • New laws could require handling plastics more responsibly at the end of their useful life through recycling, proper disposal, and extended producer responsibility.
  • Rolf Halden, director of the Center for Environmental Security at the Biodesign Institute at Arizona State University, advocates for another solution: manufacturing more sustainable plastics from the start. “We need to design the next generation of plastics to make them more biodegradable so that they don’t have a long half-life, they don’t accumulate in the oceans, and they don’t have the opportunity to collect chemicals long-term,” he says. “There’s just no way we can shield people from all exposures that could occur. Let’s design safer chemicals and make the whole problem moot.”

The complete eight page article, with 53 references, can be found at

Cautionary case study: a climate change mitigation initiative that increased GHG emissions

An article in the current issue of the journal Nature Climate Change illustrates how poorly designed climate change policies and initiatives can be worse than useless.

The research, by a scientist at the University of Queensland, Australia, reviewed the results of an initiative in Brazil to replace coal used in the making of steel with charcoal from sustainably managed forest plantations. Superficially this might appear to be a very worthwhile initiative, especially as the global steel industry accounts for 7% of human-caused greenhouse gas emissions annually.

The project resulted in a decline in the use of coal by the steel industry. However the analysis shows that it also resulted in a doubling of greenhouse gas emissions.

Infrastructure upgrades and a shortage of plantation forests resulted in increased industry reliance on charcoal sourced from native forests, which, on a net basis, emits up to nine times more CO2 per tonne of steel than coal. The authors state that preventing use of native forest charcoal could have avoided 79% of the CO2 emitted from steel production between 2000 and 2007; however, doing so by increasing plantation charcoal supply is limited by socio-economic costs and risks further indirect deforestation pressures and emissions.

The results of this project illustrate the importance of reviewing the lifecycle implications of a climate mitigation project before launching the project. Ideally the review should be conducted by an independent third party who has not been involved with design of the project and who can most effectively identify unintended consequences which can arise from a number of sources. In the Brazil steel project discussed in this article the unintended consequences arose because of an insufficient supply of charcoal from sustainably managed plantations. Sourcing the charcoal from native forests led to an increase in net GHGs when steel-making emissions using charcoal were compared to those arising from the previous use of coal.

The abstract (free) and the full article (fee or subscription required) are available at


A refreshing approach to the bacterial exposure issue

Readers may recall the media uproar over a scientist’s finding of elevated levels of bacteria on the structures of a kids’ playroom associated with a well-known brand of fast food restaurant. GallonDaily’s editor was sceptical, not about the findings but over the interpretation that children were at high risk of sickness caused by the bacteria. Now the results of research undertaken in the New York city subway that found much more elevated levels of many more types of bacteria, some previously unknown to science, are being reported in what GallonDaily considers to be a much more responsible fashion.

The research article, with the unhelpful (to ordinary people) title of Geospatial Resolution of Human and Bacterial Diversity with City-Scale Metagenomics, is the first article published as part of a new Elsevier journal Cell Systems. The researchers, a huge team led by Weill Cornell Medical College professor Christopher Mason, took swab samples at every station in the New York City subway system and in some other locations around the City. Among the findings:

  • identified organisms spanned 1,688 bacterial, viral, archaeal (a type of single-celled microorganisms), and eukaryotic (a broad category of microorganism) taxa (species).
  • nearly half of the DNA (48%) identified does not match any known organism.
  • predicted ancestry of human DNA left on subway surfaces can recapitulate U.S. Census demographic data, and bacterial signatures can reveal a station’s history, such as marine-associated bacteria in a hurricane-flooded station.
  • some evidence of pathogens, eg the bacterium that causes anthrax, was found. but a lack of reported cases in NYC suggests that the pathogens represent a normal, urban microbiome.
  • densely populated, highly trafficked areas of human transit show strong evidence of bacteria that are resistant to antibiotics and some presence of potentially pathogenic organisms.

The authors state that their baseline metagenomic map of NYC could help long-term disease surveillance, bioterrorism threat mitigation, and health management in the built environment of cities.

GallonDaily particularly applauds the author’s conclusion that the potentially infectious agents found in the subway and elsewhere in the City are not creating widespread sickness or disease. Instead, they likely represent normal co-habitants of a shared urban infrastructure, and they may even be essential to maintaining such an environment and likely represent a normal “healthy” metagenome profile of a city. They conclude: “Indeed, these data indicate that the subway, in general, is primarily a safe surface. Although evidence of B. anthracis, Y. pestis, MRSA, and other CDC infectious agents was found on the subway system in multiple stations, the results do not suggest that the plague or anthrax is prevalent, nor do they suggest that NYC residents are at risk.”

Maybe other researchers who go around testing public surfaces for evidence of infectious agents will take notice of this perspective and, more important though less likely, perhaps society can begin to wean itself off its current infatuation with antibacterial cleaning agents, at least some of which are causing more environmental harm and more evolution of antibiotic resistant bacteria that may in future cause a much greater problem that the bacteria presently ubiquitous in urban environments.

The full article can be found at




Petroleum spills may cause release of arsenic to groundwater

Scientists from the Department of Geosciences at Virginia Tech and the US Geological Survey have found that the natural breakdown of petroleum hydrocarbons underground, such as from petroleum spills or from fracking wastewater, can promote the chemical release of naturally occurring arsenic into groundwater. Normally arsenic is tightly bound to soils and presents no environmental or health risk but the metabolization of carbon–rich petroleum by microbes in anoxic (low oxygen) conditions can cause the release of the arsenic into groundwater flows. The article provides information on the likely chemical processes involved.

Fortunately the arsenic may be readsorbed by contact with downstream soils but the researchers theorize that once released the arsenic may be much more easily made soluble by other chemistry going on in the soil layers. The research found arsenic concentrations associated with a hydrocarbon plume of up to 23 times the current drinking water standard.

Arsenic is known to be toxic and is a powerful carcinogen associated with numerous forms of skin, bladder, and lung cancer. It is a common and problematic contaminant of drinking water in several regions of the world.

An abstract of the research article, published in the journal Groundwater, and a link to the full article, fee or subscription required, is available at


Carbon tax or cap and trade?

The debate over carbon tax or cap and trade seems, with the support of many business organizations, to be tilting in Canada in favour of carbon tax. GallonDaily wishes to present a contrary opinion, in favour of cap and trade.

Before making our key argument we wish to stress:

  • either economic instrument is better than nothing. GHG emitters in most of Canada currently experience no mandated carbon emission reduction incentive
  • both tools are complex: a well designed program of either genre is better than a poorly designed program of any kind.
  • program design can easily tilt our opinion from the one to the other.

Having stated the above, let us explain briefly why we lean towards cap and trade.

Experience suggests that entrepreneurs, and business people in general, are much more incented (incentivised, if you must) by the opportunity to earn direct profits than they are by the opportunity for reducing costs. If that is not obvious, let us suggest as an example the relatively poor uptake of energy and other input efficiency programs. Even when a company is presented with the opportunity to reduce costs by a substantial amount through an energy or resource conservation program the likelihood is that they will sit on their hands until the government either mandates the program or provides a substantial economic incentive over and above the cost savings that the company will realize. Saving money is not something that corporate leaders get too excited about, at least until it comes to laying off employees.

On the other hand, if there is a new product on the radar or if a company faces the opportunity to increase revenue, many business leaders and entrepreneurs get very excited. More is better!

A carbon tax falls into the first category. The tax will increase costs and many companies will face the opportunity to reduce costs by reducing carbon emissions, but they will not face an opportunity to increase revenues or sell more products. A cap and trade program, on the other hand, presents carbon emitters and a multitude of entrepreneurs with an opportunity to make money and increase revenues by selling carbon credits and by implementing initiatives which create carbon credits. There is already evidence that this excites many CEOs and independent entrepreneurs much more than a less tangible reduction of costs. Cap and trade creates a new market for products – carbon credits – whereas a tax presents only a much more uncertain (or so it seems) opportunity to reduce input costs.

Given the above, we’ll plump for a cap and trade program. We are not surprised that many industry associations plump for the carbon tax, mainly because many industry associations are fundamentally anti-competitive, even if they expose that tendency in very muted ways.

GallonDaily supports a competitive marketplace in goods and services associated with a low carbon economy. Our 26 and more years of experience leads us to predict that we will see much more competition for low carbon goods and services, as well as products such as carbon credits, arise from a cap and trade program than we will from a carbon tax initiative. We hope that governments currently considering economic instruments for a low carbon economy are listening and will see the benefit of a competitive marketplace in low carbon instruments such as carbon credits.

The above is a GallonDaily opinion column.