1. Shifting to New Technology in an Old Regulatory World

2. Two Controlling Factors in Technology Advance  The S-Curve Phenomena  The Scientific Hubris Conundrum

3. The S-Curve

4. Waste Water Treatment Technology Advance

5. Primary Treatment Removal Efficiency  90-95% settleable solids  40-60% suspended solids  30-40% Biological Oxygen Demand  18% Nutrients removal

6. Secondary Treatment Removal Efficiency  70% Biological Oxygen Demand  75% Chemical Oxygen Demand  1% Nutrients removal

7. Tertiary Treatment Removal Efficiency  30 – 75% Nutrients removal  Massively Expensive  Difficult to operate

8. Cost-Efficient Alternatives to Tertiary Treatment Will require Reassessment of the Pollution Control Mentality

9. EPA Standards reflect a static assumption about “Assimilative Capacity”

10. It is possible to increase assimilative capacity

11. Shift to a Diatom Ecology Nutrients Oxygen released Blooms Death Diatoms Blue-Green Zooplankton Oxygen consumed Dead Zone

12. What nutrients do algae need? Diatoms Blue-Green Nitrogen Phosphorus Nitrogen Phosphorus Silicon Iron Others

13. The Alternative to Tertiary Treatment “Rather than considering treatment procedures which remove the nutrients nitrogen and phosphorus from a sewage discharge July 31, 1980 one might consider the addition, if feasible, of silica in quantity at the discharge site to alter the receiving waters to a diatom population and a consequent fertile and productive region.”

14. To Accomplish a Paradigm Shift to a New Technology  Research, test and demand use of the new paradigm

15. Contact Information: David W. Schnare, Esq. Ph.D. General Counsel Energy & Environment Legal Institute 722 12 th St. NW (4 th Floor) Washington, D.C. 20005 www.eelegal.org Schnare@eelegal.org 571-243-7975