I am concerned about the toxins emitted by the materials being burned, and their potential to negatively impact my families health, as well as, the locally grown food movement.

I hope, in the future, you will be willing to explore the problem of Open and Burn Barrel Burning in rural Marquette County.

Instead, Dow’s 30-years war of disinformation, diversion, and delay with the public and the county, state, and federal public health and environmental agencies has worked beyond Dow’s wildest dreams. If the trace chemistries of fire smoke screen didn’t work, Dow could always fall back on the tried-and-true threat of reducing the work force in or closing one or more of its Michigan production plants or building new facilities elsewhere. Although the trade-off was never made explicit, apparently the state was willing to trade hundreds of jobs for tens of innocent lives lost prematurely from exposure to PCDDs and PCDFs in the workplace and/or the environment, even though it claimed to set its pollutant clean-up and emissions limits based on an acceptable lifetime increased cancer risk of one-in-one hundred thousand.

Once the federal government approved Michigan permits with effluent limits allowing the discharge of carcinogens, teratogens, and mutagens from Dow’s flagship facility above natural background levels based on an acceptable lifetime increased cancer risk of one-in-100,000 for each carcinogen, it effectively abandoned the zero discharge goal of the Clean Water Act. Following that watershed event, which went uncontested by any of the national environmental non-profits, there was no stopping the polluters, because it was OK to trade off people’s lives for jobs and profits rather than force the development and implementation of progressively improving treatment technologies toward the goal of zero discharge.

But Baal has an insatiable appetite, and a corporation has no heart or soul, so it was a Faustian bargain. If Dow had spent on cleanup what it did on its Dow Let’s You Do Great Things PR campaign and the Human Element campaign that followed, it would have done more for its image and the people of Midland and those living in the downstream floodplains.

But of course, with Dow, it is not the money but the principle involved. What is the principle that allows Dow to sacrifice its workers, the citizens of Midland, and the people living on the downstream floodplains for decades until it gets its way? It is that bottom-up, self-regulation is always and everywhere more efficient and effective at limiting pollution in the pursuit of profit than top-down regulation by governments, because companies always known themselves better than government agencies and can find the most flexible, least onerous way to accomplish the same environmental objective.

Of course, EPA has had a substantial equivalency program in effect for decades that allows companies to regulate themselves more efficiently than the EPA regulation, as long as the resulting emissions are no greater than what they would have been under the EPA regulation. The reality is that Dow cannot allow itself to be regulated in this instance or any other instance, because each is a slippery slope to being regulated in every instance, and this Dow cannot abide. So, for example, in the 1970s Dow fought the Agent Orange Vietnam Veterans on the issue of TCDD’s toxicities in hearings before Congress and subsequent lawsuits, fought every clean-up mandate in its own back yard since it filed its first TSCA Section 8(e) report in June 1978, and then worked to suppress the publication of the National Dioxin Study Final Report since the late 1980s. That report still has not been published. Dow did this because it knew that if it did not hold the line wherever PCDDs and PCDFs toxic effects were at issue, it would be forced to clean up the Tittabawassee River sediments and floodplain to safe levels based on those toxicities, and that would cut into its profit margins and Michigan jobs, and that Governor’s Milliken, Blanchard, Engler, and Granholm could not abide.

So Dow remains the undefeated champion in its fights with state and federal government public health and environmental agencies, and Granholm is now on Dow’s Board of Directors. Maybe she will have more of a positive impact on Dow pollution policy in that role than she did as Michigan Governor. In the meantime, remember that Dow lets you do great things, and don’t you forget it, you ungrateful whiners, lest you feel Dow’s mighty wrath.