Thank you.
First of all, let me say that PCBs were originally identified for phase-out in the 1970s, and I think that it's quite amazing that in the U.S. and Canada large stockpiles still remain untreated. And part of the reason that they remain untreated is the debate over incineration and the fact that communities don't want them incinerated, for very good reasons. At the same time, when they are stored perpetually, they continue to leak to the environment many of the same pollutants that people are worried about from incinerators, such as what we called earlier the toxic equivalency of dioxin. PCBs also express the same toxic equivalency, so you can get the same effect by not incinerating them.
It turns out that quite a while ago Canadian scientists and entrepreneurs developed some very excellent technologies for destroying PCBs. The one I'm most familiar with is gas-phase chemical reduction. It was a former Environment Canada scientist who developed the GPCR technology. The company went out of business, not because it didn't work--every time it was tried it worked brilliantly, it's the one technology that NGOs all over the world really liked—but because the incinerator industry was so strong that they were always able to basically monkey-wrench any effort to move away from incineration.
So GPCR is a very good alternative. There are others. I'm less confident in some of the others. There's something that sometimes is called base-catalyzed dechlorination and sometimes is called base-catalyzed decomposition. They changed their name somewhere along the way. In some of the early applications there were problems, and I'm told that some of the more recent applications have had fewer problems. There may be some others, but those are the two.
If you have purely liquid PCBs and that's all you're dealing with, the BCD might be cheaper, although I don't know. I'm more partial to the GPCR technology, although the Canadian company that was vending it has gone out of business and we don't know if somebody is going to pick up the intellectual property and go forward.
So, yes, things like PCBs need to be addressed. Transportation is a big problem. Storage is a big problem because these are semi-volatile compounds. So if you transport it and then you move it around and you store it and then you put it into the incinerator, you can have as much toxic pollution of the environment coming from the transportation, storage, and handling as you would have come from the incinerator.
All these things have to be taken into account, but I believe incinerators are the wrong technology for this. I believe the right technology is there. But the fact that both Canada and the U.S. have sat on their PCB stockpiles, and therefore the people who develop new technologies could never make a profit out of them, not because they didn't work, but because they didn't get business, is a problem.
I don't know what it has to do with CEPA, but I think that's a very important issue and I believe there are good solutions. I believe they've just been monkey-wrenched over the years because there's a very mature industry that builds and operates incinerators, but also that operates and sells all the flue gas cleaning equipment that goes along with it. They've been very politically effective, and the start-up industries that had better ways of doing this just didn't have a chance.
Thank you.