sence, we demonstrated that inappropriate models can be calibrated and verified, but the conclusions reached from their application can be dramatically wrong. Adequate monitoring data were critical to proper interpretation of model results. In fact, proper measurement of model reaction parameters and inputs substantially aided model calibration by removing degrees of freedom to the analyst. This study led to the QUAL2E model as a compendium of algorithms existing in other QUAL-II model codes. EPA held a workshop in Athens, Ga., last December designed to explore the agency's use and implementation of modeling across a variety of program offices. The workshop's genesis was a March 1994 report detailing the results of an ad hoc Agency Task Force on Environmental Regulatory Modeling. Subsequent discussions and communications by the Science Policy Council and the Science Advisory Board suggested an effort (1) to facilitate agency adherence to existing modeling guidance, and (2) to define and implement improvements to the way in which the agency uses and develops models. The outcome of the meeting and follow-up activities will be an agency-wide Models Implementation and Improvement Plan. A number of work groups were created at the December workshop to define and work on a path forward. The groups are interested in receiving input from all modelers. Contact Ray Whittemore (tel. (617) 627-3254, e-mail rwhittem@tufts. edu) for additional information. I am chair of the Monitoring and Modeling Action Team that will develop a white paper to illustrate that monitoring and modeling are inseparable for any media. A national workshop or conference is being discussed in which the information needs of modeling could be more fully presented. Other work groups are expected to work closely with the environmental modeling subcommittee of EPA's Science Advisory Board in implementing its assignment over the next few years. Glaze's editorial is an excellent lead to this task, and we commend him for his foresight, wisdom, and comments. RAY C. WHITTEMORE Tufts University Medford, MA 02153
Cleanup boom or bust? Dear Editor: Jacqueline MacDonald's well-researched article "Tough Times for Innovative Remediation Technologies" (Dec. 1997 p. 560A-563A) presents a stimulating perspective on the environmental remediation market, but other criteria indicate that, in fact, times have never been better for environmental innovative technologies. While long-term prospects for the remediation industry are fading, public sector initiatives are aggressively promoting innovative technologies. The criteria presented in the article to evaluate the health of innovative technologies—performance of initial public offering (IPO), stock prices of remediation firms, level of venture capital investment—are not the best yardsticks for gauging opportunities and prospects. IPOs and venture capital investment may be useful indicators for certain market sectors, but it may not be appropriate for relatively small and shortlived markets such as environmental remediation. The remediation market fundamentally cannot compete for the return on investment offered by larger and more lucrative sectors such as telecommunications, biotechnology, pharmaceuticals, and health care. Environmental remediation, on the other hand, has always been a finite market with a limited time horizon, and investors know it. The primary driver for environmental remediation is regulation, and this is where to look to evaluate the near-term outlook for the industry. The federal and state regulatory agencies are aggressively promoting development and use of innovative cleanup technologies. This is being accomplished through flexible permitting, creation of environmental technology centers, and new public sector programs specifically designed to identify promising technologies and to assist developers in getting their ideas to market. In addition, a multistate memorandum of understanding has been created to expedite implementation of successful environmental technologies. The long-term prospects for the remediation industry are, nonetheless, questionable. There were only so many contaminated sites created years ago and few, if any, new ones
are being created today. Of the contaminated sites that do exist, not all of them will be remediated to any significant degree. The prevalence of intrinsic bioremediation as a remediation strategy is evidence that regulators and industry alike are considering the cost-benefit and risk picture in approaching cleanups. It is no longer enough [for sites] to be dirty to warrant allocation of cleanup dollars. Within the next 10 years, assessment and remediation activity will be virtually nonexistent as viable sites will have been cleaned up and corporate pollution prevention and product stewardship initiatives become the norm. Until then, make hay while the sun shines. ALLEN HEMBERGER Technology Ventures Belmont, MA 02178 Response I disagree with the conclusion that strong regulatory programs will automatically lead to a healthy market for innovative remediation technologies. A strong regulatory program for site remediation has been in place since the passage of the Comprehensive Environmental Response, Compensation, and Liability Act in 1980, yet development of new remediation technologies has been slow. The National Research Council concluded in its report Innovations in Groundwater and Soil Cleanup (1997) that regulatory drivers alone are not enough to stimulate this market. Essential in any market is customer demand for the technologies, and existing hazardous waste cleanup regulations have not been enough to stimulate strong customer demand, in part because delaying cleanup is currently more cost-effective than remediation. JACQUELINE A. MACDONALD National Research Council Washington, D.C. 20007 Readers are encouraged to comment on articles published in ES&T and on other issues facing the environmental community. Contributions are limited to 500 words. Send letters to the Managing Editor within two months of the publication date of the original article. Submissions are subject to editing for clarity and length. Send letters to ES&T, 1155 16th St., N.W., Washington, DC 20036, or via e-mail to
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JULY 1, 1998 / ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS • 3 0 1 A
