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Whole-fish samples include the viscera, which contains more lipid than does muscle tissue, as well as organs that concentrate organic contaminants. Connor was also advised of this in the cover letter that accompanied the material he requested. Inspection of Connor’s Figure 1 suggests that this caveat was ignored in calculating the risks associated with the consumption of freshwater fish; according to the figure legend, the bar labeled “FW” is based upon “average concentrations from 1979 freshwater fish survey for US.” The only sources cited for freshwater fish residues are our publications (2, 3). We sincerely hope that we have incorrectly interpreted Connor’s article-that he derived estimates of contaminant concentrations in the edible tissues of freshwater fish from FDA market surveys ( 4 ) or that our values for whole fish were adjusted before they were used, which cannot be determined on the basis of information in the published article. If we have misinterpreted, we extend our apologies and await clarification of the methods he used; however, if Connor used the 1979 NPMP information without applying some modification to derive his assessment, then freshwater anglers, commercial fishermen, and fishery managers throughout the United States await his revised estimates.
Literatwe Cited (1) Connor, M. S. Enuiron. Sci. Technol. 1984,18,628-631. (2) Schmitt, C. J.; Ludke, J. L.; Walsh, D. F. Pestic. Monit. J. 1981, 14, 136-206. (3) Schmitt, C. J.; Ribick, M. A.; Ludke, J. L.;May, T. W. U.S., Fish Wildl. Seru. Res. Publ. 1983, 152, 1-62. (4) “FY 79 Pesticides and Metals Program”; FDA 7305.007: Washington, DC, 1982.
Christopher J. Schmitt,” J. Larry Ludke US. Department of Interior Fish and Wildlife Service Columbia National Fisheries Research Laboratory Columbia, Missouri 65201
SIR: Schmitt and Ludke (1)were very kind in providing me access to their data. They very clearly indicated that their data were for whole fish. In fact, it was often necessary for me to transform between data for whole fish or fish liver concentrations to concentrations in the edible portion of the fish. The figure legend does cite the lengthier publication where this transformation is explained in more detail ( ( 2 )ref 13 in my original publication). In brief, I matched fish by age, lipid content, year, and location where information for both whole fish or edible concentration were available. I used the ratio of edible/ whole concentration (for these data, 0.3) to convert the data from Schmitt’s laboratory. Naturally, there can be a great deal of variation in this ratio so I used several independent methods to estimate human consumption of contaminants from fish. As I discussed in the explanatory paragraph for the figure, where the lengthier publication is again cited, the different methods are in general agreement.
Literature Cited (1) Schmitt, C. J.; Ludke, J. L. Enuiron. Sci. Technol., preceding paper in this issue. 646
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(2) Connor, M. S. “Management of Wastes in the Ocean”; Wiley: New York, in press.
Michael Stewart Connor Region 1 U.S. Environmental Protection Agency Boston, Massachusetts 02203
Comment on “Red Herrings in Acid Rain Research” SIR: Regarding the feature article by Havas et al. (11, I agree that it is time for all concerned to work together and not rely on questionable truisms. However, it seems that regulatory zealots with help from the popular media have been the leaders in espousing untested hypotheses as listed below: (1)Nitric acid in rain has the same effect as sulfuric acid. (2) Liming of lakes is only useful for research while further controls on NO, and SO, should be effected immediately. (3) Effects of alkaline emissions can be ignored. (4) Midwest SO,-NO, utility emissions are responsible for the acidity in Adirondack lakes while rain acidity is proportionate to such emissions. (5) Benefits derived from stringent SO, controls would outweigh their costs. (6) Acid rain causes severe damage to vegetation while benefits are negligible. The lack of validity of these hypotheses is discussed in a recent publication (2). Another unjustified hypothesis is that there are significant human health effects from acid precipitation. Because there is a dearth of evidence on adverse human health effects from acid precipitation, this is usually implied by statements such as used by Havas et al. (“Why must we tolerate decades of emissions, damage to the environment, and often human health before abatement measures are even considered?”). They fail to cite a single reference to support the health effect implication. Pollution control measures for SOz, NO,, particulate, etc. have been considered and effected for decades even though health effects at US. ambient levels remain unproven.
Literature Cited (1) Havas, M.; Hutchinson, T. C.; Likens, G. E. Enuiron. Sci. Technol. 1984,18, 176A-186A. (2) Innes, W. B. Chemtech 1984, 14, 440-447.
W. 6. Innes Purad Inc. 724 Kilbourne Dr. Upland, California 91786
SIR: Dr. Innes (I) is using the excuse of a rebuttal to our paper to introduce more red herrings into the literature. Little of what he has to say relates directly to our paper. The techniques used by Innes and others are classics. One technique is to alter the wording slightly so that the meaning changes substantially and then claim the
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0 1985 American Chemical Society
authors said it. For example, we did not say that “nitric acid has the same effect as sulfuric acid”. Our statement was that of the inorganic acids, nitric and sulfuric predominate. These two statements are not identical. Another red herring. Another technique, which is even more blatant than the first, is to make a strong statement that has not been “proven” scientifically and associate that statement with the authors. Our paper dealt with the aquatic environment. We do not say that “acid rain causes severe damage to vegetation while benefits are negligible”. What is implied by the second half of this statement is that we should test some more untested hypotheses, namely, the beneficial effects of acid rain. Another red herring. It is true that S is a plant nutrient but not necessarily if it is delivered as phytotoxic SO2 and sulfuric acid. Only persistent reporta from the Tennessee Valley Authority have made such a claim. If sulfur and nitrogen are so good for plants in the form of air pollution, then why is it that in the most polluted cities very few plants are able to survive and that only a handful of tree species can be planted. Should not sulfur-polluted cities be a veritable jungle of vigorously growing species? Should not trees be bigger and more diverse near smelters? What happened to the trees around Sudbury, Anaconda, and Ducktown? Or do our eyes deceive us? Points 2, 3, and 5 made by Innes (I) are all concerned with remedial measures. We did not discuss remedial measures in our paper. However, since Innes mentioned this topic we should like to comment. It appears (although we may be wrong) that Innes is opposed to reducing acidic emissions as part of a remedial program. Instead, liming of lakes and alkaline emissions should be considered. Since we know that acid rain is caused by SOzand NO, emissions is it not logical to think that reducing these emissions should help? According to Dr. Innes, it may be much more logical to pollute the atmosphere with alkaline emissions as well as acidic emissions to solve our problem. Is it not wiser to remove the pollutants, perhaps by using neutralizing extracts a t the source? We do not consider liming the solution to lake acidification problems. At best, liming may buy us some time, and a t worst, it can be harmful to aquatic biota. There are a number of problems associated with liming that tend to be downplayed by liming advocates. The neutralizing effect of liming is temporary, and if we wish to maintain high pHs, liming has to be repeated as frequently as every 4-5 years in some lakes. Not all the effects of liming are beneficial to the biota. The rapid increase in pH and/or associated changes in aluminum speciation killed fish in Sweden (5) and caused zooplankton populations to crash in Canada (8). Liming reduces metal levels in lakes, but in some cases the metal concentrations may not be reduced sufficiently to allow for successful restocking of fish (8). As the lake begins to reacidify, the metals which have precipitated onto surface sediments can redissolve into the water column. Reviews on remedial measures which discuss the advantages and disadvantages of liming conclude that it should be considered only as an interim measure and not as the solution to acid rain ( 6 ) ,a conclusion with which we agree. Liming and other measures may be useful in the short term, but we believe that reducing acidic emission is the only possible long-term solution to the problems associated with acidic deposition. Not only will lakes and streams be protected but so will our forests, our buildings, and our monuments. The other point made by Innes is that we should consider the cost and benefits of SO2 control. We agree. To
date there has been little information on what the benefits might be. It was believed that recovery of lakes might be a slow process, if indeed they would recover at all. We have some recent data for the Sudbury region that suggest that not only will lakes recover but also recovery might be quite rapid if acidic emissions are reduced (Hutchinson and Havas, unpublished results). Noticeable improvements in pH, SO4, and metal concentrations may occur within a decade or less. Regarding the cost of reducing SO2emissions, two recent estimates suggested that the cost of energy would increase by 3% in Europe and by a higher amount in the United States. Since these were based on different reduction schedules, different technology, etc., it is difficult to determine whether they can be directly compared. We know that there will be a substantial overall cost in cleaning up the environment, but it must be remembered there is also a hidden cost if we do not. One hidden cost that Dr. Innes could not have taken into consideration, since he believes that the proven health effects of air pollution are minimal, is the cost to public health. According to Ostro ( 4 ) the annual health costs of air pollution, which includes mortality, morbidity rates, and lost productivity of workers, is calculated to total $250 per family. This is far greater than the annual inflationary costs of air pollution control which he estimated to be $31 per family.’ He concludes that the inflationary costs of air pollution are more than offset by the damages to public health from unabated air pollution. The fourth point, which deals with the relative contribution of the midwest to problems of acid rain in the Adirondack lakes, has been well documented. According to a report by the New York State Department of Environmental Conservation (3) for 1980,less than 30% of the sulfur deposited in the State of New York came from local sources within the state. Therefore, the remaining 70% must have come from long-distant transport of air pollutants. The final statement that Innes makes relates to human health effects. It seems incredible to w that Innes suggests that “pollution control measures for SO2,NO,, particulates, etc. have been considered and effected for decades even though proven health effects are minimal”. Why did the U.K. bring in its Clean Air act to control SO2 and particulates? One key reason was the 4000 excess deaths caused by these components during the London smog of Nov 1953. Or consider the statements made by Lave and Seskin (2): “(1) There is a close, statistically significant association between air pollution (as measured by sulfates and suspended particulates) and mortality rates in the United States; this relationship is evident over time and across metropolitan areas. (2) The close association is relatively robust, as evidenced by analyses of various data bases.... (3) If the estimated relationship is a causal one, the estimated effect of air pollution on health is large, warranting stringent abatement of sulfur oxides and particulates (and perhaps other air pollutants).” Recently Dr. D. V. Bates found a significant relationship between the number of people admitted into hospitals complaining of respiratory problems and the daily SO4 levels in Southern Ontario. Furthermore, there is evidence that groundwater is becoming more acidic and that concentrations of potentially toxic metals are increasing in drinking water from shallow w e b in areas exposed to acid rain (7). Several studies have shown that mercury levels are higher in fish from acidic lakes (cited in ref 6 and 7). How much evidence does Dr. Environ. Scl. Technol., Vol. .19, No. 7, 1985
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Innes need before he might consider the possibility of human health effects?
Literature Cited Innes, W. B. Environ. Sci. Technol. 1985, preceding paper in this issue. Lave, L. B.; Seskin, E. P. 1980. Environ. Health Perspect. 1980,34, 181-183. New York State Department of Environmental Conservation 1984, Policy for New York State to Reduce Sulfur Dioxide Emissions, Executive Summary, pp 1-20. Ostro, B. D. Environ. Health Perspect. 1980,34,185-188. Bengtsson, B.; Dickson, W.; Nyberg, P. Ambio 1980, 9,
(8) Yan, N. D.; Dillon, P. J. In “Studies of Lakes, Watersheds near Sudbury Ontarion: Final Limnological Report”; Ontarion Ministry of Environment: Rexdale, Ontario, 1982; SES 009/82, pp 1-60.
Magda Havas, Thomas C. Hutchinson Institute for Environmental Studies University of Toronto Toronto, Canada M5S 1A4
Gene E. Likens
34-36.
Flick, W. A.; Schofield, C. L.; Webster, D. A. In “Acid Rain/Fisheries”; Johnson, R. E., Ed.; American Fisheries Society: Bethesda, MD, 1982; pp 287-306. Swedish Ministry of Agriculture Stockholm Conf. Acid. Environ. 1982, 1-232.
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Institute of Ecosystem Studies The New York Botanical Garden Mary Flagler Cary Arboretum Millbrook, New York 12545
