Models of Man: How rational are we?


Coal ash is the waste product left over from burning coal. Coal ash contains many high heavy metals such as boron, cadmium, selenium, mercury, arsenic, chromium, and other dangerous elements. In places like the United States coal ash still presents health and environmental problems because its disposal is still unregulated. Coal ash waste regulation is a matter handled by the Environmental Protection Agency (EPA) since 1976. The EPA is the agency in the United States responsible for protecting “human health and the environment by writing and enforcing regulations based on laws passed by Congress” ( In this brief text we will analyze the decision making process of EPA in regarding to this matter, but first we will dig a little deeper into the context, by looking at some punctual information: (from

  • Energy companies generate so many tons of coal ash each year to the point that its the second largest waste stream in the United States.

  • The American Coal Ash Association reported that 44 percent of coal ash is recycled. The rest of the coal ash is disposed in lagoons (wet pits), landfills (dry pits), and mine pits.”

  • The ash is often stored in large unmaintained surface impoundments, ponds, and abandoned mine sites.”

  • Coal ash accidents can take various forms from the collapse of a surface impoundments dam or in metals leaching into ground and drinking water.”

  • The contamination is concentrated in communities with family poverty rates above the national median.”

  • In 2007 the EPA confirmed 24 cases of leaking ash pits that resulted in contaminated water bodies. These leaking sites pose a health threat to the communities in which they are located.”

  • A risk assessment drafted by the EPA in August 2007, estimated that exposure to coal combustion waste (CCW) raises an individual’s cancer risk 9x higher than smoking a pack of cigarettes a day, and 900x higher than the ‘acceptable risk’ calculated under EPA’s regulatory framework. The assessment found that of people who live near a coal ash site, 1 in 50 are diagnosed with cancer from arsenic contamination (an ‘ingredient’ in coal ash).”

  • Despite the EPA’s analysis confirming the adverse health effects of coal ash exposure, there are no federal regulations on the waste and coal ash is entirely unregulated in at least 20 states.”

According to Eric Schaeffer, executive director at Environmental Integrity Project, the EPA promised to set standards for coal ash disposal sites more than a decade ago. But it was until the large-scale spill at a disposal pond in Harriman, Tennessee, in December 2008, that the EPA Administrator Lisa Jackson, finally put a dateline to the project (the end of 2009). Finally, in May 2010 the EPA proposed to set federal standards for coal ash disposal under the Resource Conservation and Recovery Act (RCRA), in which waste disposal could either be classified as a toxic ash hazardous waste (Subtitle C) or a household garbage (Subtitle D) (See table underneath).




Effective Date

Timing will vary from state to state, as each state must adopt the rule individually-can take 1 – 2 years or more

Six months after final rule is promulgated for most provision: certain provisions have a longer effective date


State and Federal enforcement

Enforcement through citizen suits; States can act as citizens.

Corrective Action

Monitored by authorized States and EPA


Financial Assurance


Considering subsequent rule using CERCLA 108 (b) Authority

Permit Issuance

Federal requirement for   permit issuance by States


Requirements for Storage, Including Containers, Tanks, and Containment Buildings



Surface Impoundments Built Before Rule is Finalized

Remove solids and meet land disposal restrictions; retrofit with a liner within five years of effective date. Would effectively phase out use of existing surface impoundments

Must remove solids and retrofit with a composite liner or cease receiving CCRs within 5 years of effective date and close the unit

Surface Impoundments Built After Rule is Finalized

Must meet Land Disposal Restrictions and liner requirements. Would effectively phase out use of new surface impoundments.

Must install composite liners. No Land Disposal Restrictions

Landfills Built Before Rule is Finalized

No liner requirements, but require groundwater monitoring

No liner requirements, but require  groundwater monitoring

Landfills Built After Rule is Finalized

Liner requirements and groundwater monitoring

Liner requirements and groundwater monitoring

Requirements for Closure and Post-Closure Care

Yes; monitored by States and EPA

Yes; self-implementing

After receiving feedback from many sources, in March 2011 EPA Administrator Lisa Jackson decided to delay the finalizing rule until 2012.

Why did EPA Administrator Lisa Jackson decided to make a public proposal of federal standards for coal ash disposal but not to not impose it?

Decision-making process

There are two methodologies useful for analyzing the decision making process. One is the Rational Actor Model (RAM), and the other which emerged as a critique to the first, but is still not as far from it is the Boundaries of Rationality (BR).

Rational Actor Model

First of all the Rational Actor Model (RAM) assumes that the individuals making the decisions are rational. Meaning that individuals “act as if balancing costs against benefits to arrive at action that maximizes personal advantage” (source: In other words, practitioners of the RAM first take into account the goals and objectives of the decision-maker and then they go through each alternative trying to balance cost against benefits by estimating likely consequences to each alternative. At the end the RAM practitioner assumes the decision maker chose the optimal choice; the one that ranked better in the cost-benefit evaluation. RAM doesn’t really recognize organizations, but the leader o decision-maker representing the organization.

The four key concepts are:

  1. the Goals and Objectives

  2. the Alternatives

  3. the Consequences

  4. the Choice

In regard to the case of study:

The Goal:

Protect human health and the environment by writing and enforcing regulations.

The objective:

Regulation and supervision of coal ash waste.

The alternatives:

  1. Make non public negotiations with stakeholders involved (senate, energy companies, and environmental agencies), and come into an agreement to solve health and environmental problems by using guidelines and promoting recycling of coal ash.

The consequences:

Quiet debates among the principal stakeholders have been happening for decades, without without coming up with a solution on how to solve the health and environmental problems associated with ash coal disposal.


Since the large-scale spill at a disposal pond in Harriman, Tennessee the problems has been pushed to the national spotlight and as time passes there is more attention in the problem. Know that the problem is in the eye of the public. To have private discussions now will be seen as secretive and non-transparent.

Replacing proper federal standards by guidelines and recycling promotion most probably enable electrical companies to continue doing business as usual.

Its most probable that continuing negotiations in a private manner, as has been done through decades, wont give new results. Or as said by Einstein “Insanity is doing the same thing over and over again and expecting different results”.


By using guidelines and promoting recycling of coal ash, which is a far less strict than imposing federal standards, the wont be set to high for the energy companies to actually spend some effort in measures to minimize environmental and health problems.

  1. Impose law and science guided standards for coal ash disposal to the energy companies and treating coal ash as a hazardous substance.

    The consequences:


    Regulating coal ash as hazardous waste would lead to economic hardship for the electric companies and their customers.

    Its most probable that there will be massive resistance from powerful stakeholders like electrical companies and the Senate to prevent the escape of imposed federal standards. The electrical industry has an important influence in the Senate, making them their allies in this regulation fight.

    It is probable that some electrical companies wont find it economically feasible to continue operating by following the regulatory standards.


    There will a strong regulation on coal ash disposal and the appropriate measures will be taken to prevent and mend for the health problems related to coal ash disposal.

    Release of pressure from some stakeholders, like environmental organizations, people directly and indirectly affected by coal ash disposals, public interested in the matter, etc.

  2. Make a flexible framework for federal standards for coal ash disposal, but not impose it to the energy companies.

    The consequences:


    Not imposing the federal standards will generate more pressure from stakeholders in favor of the standards, with the possibility of some lawsuits.

    Massive resistance from powerful stakeholders like electrical companies and the Senate to prevent the escape of imposed federal standards.


    Publishing the proposal for the federal standards is one step forward towards the imposing those standards and reaching the final goal of securing environmental justice and public health regarding coal ash waste disposal.

    To buy more time.

    To involve more important decision makers in the matter and gain support to impose the federal standards.

    Probably there will be important pressure from stakeholders in favor of regulating ash coal disposal, mainly coming from the public eye towards the Senate in order to shift bands and support the FDA in the regularization approval.

    The Choice

    EPA Administrator Lisa Jackson decided to publish proposed federal standards for coal ash disposal without imposing them to the energy companies.

    According to this line of thought this decision was the optimal because it would move the fight into public arena. Finally the stakeholders in favor of the regularization (mainly the public) may summit so much pressure to the government (the Senate) through scientific evidence of the threat of the ash coal to public health, that this may turn the Congress into supporting the FDA to take the final step into imposing the standards.

Bounded Rationality

Simon criticized the Rational Actor Model, arguing that the model did not explain how people really made decisions. Through the Bounded Rationality model Simon explained that decision makers are not fully rational and in fact they lacked the cognitive abilities and the resources to arrive to an optimal solution. He explained that decision-makers arrived instead to a satisfying conclusion only after having simplified the choices available, for example by exploiting pre-exisiting structure and regularity in the environment.

Bounded rationality at the organizational level (Jones, 2003)

Organizational memory: Organizations encode experiences into routines, rules, and standard operating procedures

Agenda setting: Organizational capacity of prioritizing external stimuli

Parallel processing: Decentralization by providing people with the ability to processing information through an array of preprogrammed solutions.

Serial processing: When routine solutions are inadequate organizations look for new solutions through central processing

Emotional contagion: Emotional arousal is a trigger from moving from parallel procesing to serial processing and; emotional commitment and ‘contagion’ are important elements for mobilizing major initiatives.

Identification: People identify emotionally and cognitively with the organizations they participate in, developing a sort of attachment which can be good or bad depending on the circumstances.

After the large-scale spill at a disposal pond in Harriman, Tennessee, in December 2008, the EPA Administrator Lisa Jackson, finally put a dateline to the project of coal ash regulation. Finally, in May 2010 the EPA proposed to set federal standards for coal ash disposal. The large-scale spill was an alarming stimuli to EPA to finally stop with the routine solutions and give an adequate, centralized solution to the ash coal problem.

The coal ash regulation problems goes back to 1976, since then EPA has only being offering prepackaged solutions such as handling the battle behind closed doors and postponing the regulations. Both actions suggest low levels of energy and attention investment.

Since 1976 there has been many calls-for-attention to the EPA to solve the problem, this including a vast array of public comments, recherches and reports by scientists and advocate groups, and sufficient evidence that coal ash can propose significant threat to human health and the environment. There has also been serious accidents and health problems related to coal ash disposal. Some of this external stimuli made a shift in the organization from parallel processing to serial processing through emotional arousal. Even through new efforts where spent by solving the problem through serial processing, there was no change in the routine.

Finally until the large-scale Tennessee spill the signals couldn’t be ignored by EPA any more. This lead to an allocation of attention. The BR theory states that “attention shifts in policy making imply changes in standard operating procedures, which in turn predict major punctuations in policy outcomes” (Jones, 2003). The EPA put efforts through serial processing to finally propose a set of federal standards and moved the problem to the open. Through my perspective is a big step towards the solution of the coal ash disposal problem.


Sturgis, Sue. “Big energy vs. coal ash regulation .” 27/05/2010. N.p., Online Posting to Girst. <;.

“United States Environmental Protection Agency.” 03/10/2012. N.p., Online Posting to Wikipedia Encyclopedia. <;.

Allison, Graham, and Philip Zelikow. Essence of Decision. New York: Longman, 1999.

“Coal Ash.” N.p., Online Posting to The energy forum network. <;.

“Coal Combustion Residuals – Key Differences Between Subtitle C and Subtitle D Options .” 04/03/2012. N.p., Online Posting to United States Environmental Protection Agency. Web. 7 Oct. 2012. <;.

Cernansky, Rachel. “Largest U.S. Coal Ash Pond to Close, But Future Rules Still Undecided.” 9 Aug 2012. N.p., Online Posting to National GeographicNews. Web. 7 Oct. 2012. <;

Saylor, Jared . “Delayed Coal Ash Protections Put Public Health at Risk.” 18 Jan 2012. N.p., Online Posting to Earth Justice. Web. 7 Oct. 2012. <;.

Some Quotes

“The  entire  industrial  system  relies  on resources  and  services  provided  by  the  biosphere,  from which  it  cannot  be  dissociated.” [Erkman, 1997]

“The  idea  is  first  to understand  how  the  industrial  system  works,  how  it  is regulated,  and  its  interaction  with  the  biosphere;  then, on  the  basis  of  what  we  know  about  ecosystems,  to determine  how  it  could  be  restructured  to  make  it compatible  with  the  way  natural  ecosystems  function.”  [Erkman, 1997]

“It is no measure of health to be well adjusted to a profoundly sick society.” [Krishnamurti]

S.  Erkman, 1997. Industrial  ecology:  an  historical  view,  J.  Cleaner  Prod.,  Volume  5,  Number  1-2

Industrial Ecology personal puzzle

“The oldest and simplest models of pro-environmental behavior were based on a linear progression of environmental knowledge leading to environmental awareness and concern (environmental attitudes), which in turn was thought to lead to pro-environmental behavior. By ‘pro-environmental behavior’ we simply mean behavior that consciously seeks to minimize the negative impact of one’s actions on the natural and built world (e.g. minimize resource and energy consumption, use of non-toxic substances, reduce waste production). Research showed that in most cases, increases in knowledge and awareness did not lead to pro-environmental behavior.”  [Kollmuss & Agyeman, 2002]


Puzzle: ¿Why knowledge and awareness does not lead to pro-environmental behavior?

  1. There is a lot of skepticism about environmental problems, about our power to provoke and correct the environmental problems, about the consequences of the environmental problems, etc.

  1. There is incoherence between what you think and what you do. Even if you are aware and concerned about environmental problems you will not act upon it because you have other priorities, because it is more energy-money demanding, etc.

  1. The type of source information influences the environmental attitude and the behavior. In other words you will have a different pro-environmental behavior if you heard about the environmental problems through television or newspapers, than if you lived them yourself.


Anja Kollmuss & Julian Agyeman (2002): Mind the Gap: Why do people act environmentally and what are the barriers to pro-environmental behavior?, Environmental Education Research, 8:3, 239-260

Social Science Perpective on Industrial Ecology

We are now standing in this space and time, victims and actors in this world that was handled to us by past generations. We learn through history that in a short lap of time man has created an artificial environment inside a natural environment. This environment called the techno sphere was built by humans and for humans to live. Know that we are beginning to understand that these environments are not compatible with each other, because they have different rules, different purposes, different mechanisms we yearn to make them both compatible in order to preserve the humanity.

Social sciences will help us understand the way we think, we act, we feel, our desires, our needs, our actions, our reactions… and their consequences. In other words, it is crucial to understand US in relation to the techno sphere in order to achieve a fusion and a balanced interaction between the natural and the artificial environment.

Personal Experience

Although my academic knowledge of social sciences is scarce, I have had a close encounter with the social component of a sustainability project. I was cooperating in a project called “Water and life” in a small deserted village in Mexico. The objective of the project was to turn this small, poor community into sustainable by covering many medium and long term objectives. I got involved in the project some years after it began so I was in an advanced phase of the project. Our goal was to help the community become economically auto-sufficient by planting, processing and selling a native edible plant called prickly pear (“Nopal” in Spanish).

Without the community’s cooperation the whole project couldn’t reach economic auto-sufficiency, so they were a pretty important component of the project. I learned that the social part of this project was the hardest one.  The community was resistant to cooperate because of their costumes, social structure, beliefs, etc. even though they were conscious that the long term goal if this project was their wellbeing, and that the project was specially designed considering their necessities and desires. I found out that humans actions are governed by many individual and collective concepts that belong to the past (such as customs) and not so much to the present or the future.


In this virtual space I will be publishing and sharing Industrial Ecology topics, giving my point of view about them.

This is my first weblog, so we’ll see how it goes 🙂