pesti manuf's NESHAP, turf hardiness

[ttweed@wildrockies.org (Tony Tweedale)]

  (dioxin-l:  the 2nd item concerns ED's)
  
  turf management:  there may be a new info nugget in this even for those of
  you who already know about this.  having recently read a syndicated
  newspaper column (a scripps howard gardening writer) on gardening w/ less
  pesticides, i'm reminded to share the message of a great MT extension
  service talk on same  that i attended this summer.
  
  their take home message, "water infrequently (but deep); cut high" is based
  on some UNIVERSAL  real world observations.  constant cropping of the grass
  blade makes it put all its energy all the time into blade growing, not root
  establishment, which makes the lawn drought & weed resistant.  as to
  watering seldom, but deep, which also encourages root growth downwards,
  with the same hardiness benefits (to weeds, drought).
  
  but the beautiful application of an empirical observation is that
  infrequent watering creates a desert in the top 1/3 - 1/2 inch of soil --
  where the weed seeds must germinate!  with this kind of management &
  synnergy, who needs toxic chemicals?
  
  ---
  
  in case the major pesti activist groups aren't up to speed on the CAA, let
  me give you a heads up & my 2 cents worth on the recent F.R. notice,
  'Proposed Ntl Emission Standard for Haz's Air Pollutants (NESHAP),
  Pesticide Active Ingrdient Production' (p. 60,565 - 65,602; Nov. 10th).
  HAPs are the 188 non-criteria (non-major) pollutant part of the CAA, kicked
  into high gear by the '90 ammndments, industry by industry.
  
  
  -only herbicide, insecticide & fungicide ai manufacturers are proposed to
  be covered.
  
  -new, unspecified, chemicals have been added to the list for this source
  category.
  
  -the basic requirement of the act, that maximally achievable control
  technology (MACT) be iinstituted for HAPs, is definded as the best 20% of
  surveyed sources in your industry, but in control level was chosen from
  only 20 of 78 facilities identified!
  
  -ED:  tho there are 22 potential endocrine disruptors among the 188 HAPs,
  none are being proposed for control in this source category.  --> epa seeks
  comment on this.  recall that epa has authority to add chemicals to the
  list of 188 (or delete, it was originally 189), so maybe ED's, e.g. 2,4-D
  can be added (i assume it isn't currently listed).
  
  -"every effort" has been made to keep the rule simple, including making the
  same rule apply to the 10 previously ID'd source categories in the
  industry, ie making them 1 source category.  looks like a red flag to me.
  
  -alternative requirements for facilities "proving" source reduction, but as
  usual the verification of reduction is weak.
  
  -->epa requests comment on various compliance issues.
  
  -as per the new compliance monitoring rule, continous emission monitoring
  is not required, instead, one surrogate parameter has to be continually
  monitored.
  
  
  Tony Tweedale (Causality is a concept not subject to empirical
  demonstration.   -David Hume)