Subtle Misdirection

Tony Shelton

BS Detector, Esquire
When Robert was posting all those pages and links I was trying to read all of them as fast as I could. I screenshot a lot of stuff from the PN$A's website he directed us to and lost them. I found them on my computer along with all my notes. I'm going to take a few minutes to explain some of what is buried in all that information.

First I'd like for you to take a look of the headliner listed under the "PWNA's Marketing Materials Examples" Titled "It harms the Environment". Here is one the headliner:


hinderliterstudy9a.jpg


This is a "marketing example for our industry?"

Contrast that with this that I found from a link at the Street Sweepers Association:

Because of sweeping’s demonstrated lower cost per pound of pollutant removal, MS4s under NPDES Phase I and Phase II mandates should now start the development of optimal sweeping programs designed to reduce solids, metals, nutrients, hydrocarbons, and other pollutants to the maximum extent practicable. Only by using appropriate physically based calibrated models and comparing the pollutant reduction benefits of optimal sweeping to both a range of end-of-pipe solutions and LID-based retrofit practices can the most cost-effective mix of sweeping and/or other BMPs be attained. This exercise, if done properly, will minimize the overall cost of meeting stormwater pollutant reduction goals throughout the communities’ built environments. Well-informed NPDES managers will then be able to determine what meaningful role cleaning programs can play in achieving numeric pollutant limits in stormwater. Numeric limits have arrived, and more are just around the corner.

The Sweepers have concluded and are publicly stating that they are the SOLUTION

The PW#A has determined and are publicly stating that WE are the PROBLEM.

Think about that for a minute. Is that what you pay PWNA dues for?

Where does all this misdirection come from?


This comes from the link on the PWNA site on their newly updated environmental page. Down at the bottom they have "resources for regulators". This comes from the "Characterization of Waste Wash Water". Most people who skim through it would think we are all destroying the environment.


First there is the misdirection that this "Characterization of Waste Wash Water" characterizes OUR industry as a whole. The fact is, the study referred to had nothing to do with general surface cleaning and everything to do with fleet washing only:

hinderliterstudy1.jpg




Another misdirection was the fact that the studies were done at places that were already compliant anyway:

hinderliterstudy2.jpg


Next, in the "Resources for Regulators" in the BMP section (also from Oregon, 1994) We can see that CETA was already involved in this and there was no contractor input:


hinderliterstudy3.jpg


Here is the worst misdirection of all. Ron has spent years saying and we spent weeks arguing that onsite treatment such as grassy swales, ponds, etc were sufficient to deal with our runoff in many cases, but Robert acted like we were out of our minds. Here is what it says buried DEEP in the study he put forth and now apparently denies! Note the last underlined sentence - 100% REDUCTION!!!!!!!>

hinderliterstudy4.jpg


Another misdirection is the "hot water" caveat. I have shown many BMP's that say nothing about hot water. Yet an org, pretending to represent our interests make more limitations than the toughest report and BMP in the country - Oregon. No wonder he is misdirecting again and now asking for sanitized input from sources where we have been banned and can no longer show the misdirection! Mark my words. The hot water caveat can only go two ways. 1) Someone else has to suggest it so that the can be removed at their request instead of mine. or 2) It stays in because Robert it too stubborn to ever admit he was wrong for putting it in there in the first place. Here is the permissible runoff for Oregon from the 1994 BMP's that are cited "for regulators" on the PWNA site:

Hinderliterstudy5.jpg


Here the same onsite treatments the Ron has been saying all along are mentioned again as treatment options:

hinderliterstudy6.jpg


Here even soapy washwater is allowed into the onsite treatment (grassy swales, landscaping, detention ponds, etc)

hinderliterstudy7.jpg


Here is the projected efficiency of different treatments, NOTICE an 80-100% reduction in pollutants when put in landscaping or onsite treatment! Also notice that they couldn't even come up with a number to represent the possible reduction when having power washers pick up the water!!!!!!

hinderliterstudy8.jpg


And finally, in the report we see this beautiful example of simple onsite treatment.....that same treatment that is expected to result in an 80-100% reduction.

hinderliterstudy9.jpg



Why the misdirection?

This information is 18 years old!

It has been around for a long time. There is evidence in these documents that could have been used for the past 18 years to move our industry forward and presented showing the positive effect we have on the environment.

Why the misdirection? Who benefits from it?

Why is this information buried in pages and pages of reports that Robert thinks no one will ever read?

Why are regulators and Robert reducing our education to CARTOONS? We are intelligent business owners. We don't need to get our information from Wile E. Coyote.

It's time to stop the misdirection.

Our industry cleans the environment. We make a safe and clean environment for our kids.

The time of Robert's insistence that just because his son has to reclaim that nasty stuff that comes out of the trailers of the food and livestock trucks he washes, that we all have to do the same, is over.

It was a petty way to treat competitors much less those of us who are in no competition at all with him or his son.

Let's all start becoming educated on this and help the regulators see that we are the solution, not the problem.
 
Great Info Tony, keep up the great work.

When Robert was posting all those pages and links I was trying to read all of them as fast as I could. I screenshot a lot of stuff from the PN$A's website he directed us to and lost them. I found them on my computer along with all my notes. I'm going to take a few minutes to explain some of what is buried in all that information.

First I'd like for you to take a look of the headliner listed under the "PWNA's Marketing Materials Examples" Titled "It harms the Environment". Here is one the headliner:


hinderliterstudy9a.jpg


This is a "marketing example for our industry?"

Contrast that with this that I found from a link at the Street Sweepers Association:

Because of sweeping’s demonstrated lower cost per pound of pollutant removal, MS4s under NPDES Phase I and Phase II mandates should now start the development of optimal sweeping programs designed to reduce solids, metals, nutrients, hydrocarbons, and other pollutants to the maximum extent practicable. Only by using appropriate physically based calibrated models and comparing the pollutant reduction benefits of optimal sweeping to both a range of end-of-pipe solutions and LID-based retrofit practices can the most cost-effective mix of sweeping and/or other BMPs be attained. This exercise, if done properly, will minimize the overall cost of meeting stormwater pollutant reduction goals throughout the communities’ built environments. Well-informed NPDES managers will then be able to determine what meaningful role cleaning programs can play in achieving numeric pollutant limits in stormwater. Numeric limits have arrived, and more are just around the corner.

The Sweepers have concluded and are publicly stating that they are the SOLUTION

The PW#A has determined and are publicly stating that WE are the PROBLEM.

Think about that for a minute. Is that what you pay PWNA dues for?

Where does all this misdirection come from?


This comes from the link on the PWNA site on their newly updated environmental page. Down at the bottom they have "resources for regulators". This comes from the "Characterization of Waste Wash Water". Most people who skim through it would think we are all destroying the environment.


First there is the misdirection that this "Characterization of Waste Wash Water" characterizes OUR industry as a whole. The fact is, the study referred to had nothing to do with general surface cleaning and everything to do with fleet washing only:

hinderliterstudy1.jpg




Another misdirection was the fact that the studies were done at places that were already compliant anyway:

hinderliterstudy2.jpg


Next, in the "Resources for Regulators" in the BMP section (also from Oregon, 1994) We can see that CETA was already involved in this and there was no contractor input:


hinderliterstudy3.jpg


Here is the worst misdirection of all. Ron has spent years saying and we spent weeks arguing that onsite treatment such as grassy swales, ponds, etc were sufficient to deal with our runoff in many cases, but Robert acted like we were out of our minds. Here is what it says buried DEEP in the study he put forth and now apparently denies! Note the last underlined sentence - 100% REDUCTION!!!!!!!>

hinderliterstudy4.jpg


Another misdirection is the "hot water" caveat. I have shown many BMP's that say nothing about hot water. Yet an org, pretending to represent our interests make more limitations than the toughest report and BMP in the country - Oregon. No wonder he is misdirecting again and now asking for sanitized input from sources where we have been banned and can no longer show the misdirection! Mark my words. The hot water caveat can only go two ways. 1) Someone else has to suggest it so that the can be removed at their request instead of mine. or 2) It stays in because Robert it too stubborn to ever admit he was wrong for putting it in there in the first place. Here is the permissible runoff for Oregon from the 1994 BMP's that are cited "for regulators" on the PWNA site:

Hinderliterstudy5.jpg


Here the same onsite treatments the Ron has been saying all along are mentioned again as treatment options:

hinderliterstudy6.jpg


Here even soapy washwater is allowed into the onsite treatment (grassy swales, landscaping, detention ponds, etc)

hinderliterstudy7.jpg


Here is the projected efficiency of different treatments, NOTICE an 80-100% reduction in pollutants when put in landscaping or onsite treatment! Also notice that they couldn't even come up with a number to represent the possible reduction when having power washers pick up the water!!!!!!

hinderliterstudy8.jpg


And finally, in the report we see this beautiful example of simple onsite treatment.....that same treatment that is expected to result in an 80-100% reduction.

hinderliterstudy9.jpg



Why the misdirection?

This information is 18 years old!

It has been around for a long time. There is evidence in these documents that could have been used for the past 18 years to move our industry forward and presented showing the positive effect we have on the environment.

Why the misdirection? Who benefits from it?

Why is this information buried in pages and pages of reports that Robert thinks no one will ever read?

Why are regulators and Robert reducing our education to CARTOONS? We are intelligent business owners. We don't need to get our information from Wile E. Coyote.

It's time to stop the misdirection.

Our industry cleans the environment. We make a safe and clean environment for our kids.

The time of Robert's insistence that just because his son has to reclaim that nasty stuff that comes out of the trailers of the food and livestock trucks he washes, that we all have to do the same, is over.

It was a petty way to treat competitors much less those of us who are in no competition at all with him or his son.

Let's all start becoming educated on this and help the regulators see that we are the solution, not the problem.
 
Great info Tony! Thanks.
 
It come down to dollars and cents...it's always been about dollars and cents.

It was part of my issues with the Org. many years ago. If we don't educate our customer someone else will who can profit from selling their knowledge and the equipment they say the solution.

Tony think about it...if we as contractors show our customers reclaim vacs etc aren't required the sale of said vac etc. will drop and there will be no need for a so called expert that charges a fee for his/her services.
 
It come down to dollars and cents...it's always been about dollars and cents.

It was part of my issues with the Org. many years ago. If we don't educate our customer someone else will who can profit from selling their knowledge and the equipment they say the solution.

Tony think about it...if we as contractors show our customers reclaim vacs etc aren't required the sale of said vac etc. will drop and there will be no need for a so called expert that charges a fee for his/her services.
Scott, didnt they threaten to put you out of business?
 
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