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October 2011 Coastal Scuttlebutt

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Note: This post is typically updated each day by noon CDT.

Scary Perry doing what he does best.

 

October 14

Perry’s POTUS Philosophy

Having just posted a feature on Rick Perry’s complicity in sweeping coastal science under the political rug I was hesitant to post another scary Perry story today…but as an old Texas pal used to say, “Smoke ‘em when you got ‘em and drink ‘em while they’re cold,” I would add, “Write ‘em as you see ‘em!”

Phillip Elliott posted a storyin HuffingtonPost about Rick Perry’s first real policy speech in his presidential campaign, which was delivered yesterday in Pittsburgh. Although the author didn’t pick up on it, Perry’s speech had huge and scary coastal implications. The following quotes from the article include telling insights into Perry’s Potus philosophy:

In his plan, Perry called for

_ Allowing increased energy production on federal land, including Alaska’s Arctic National Wildlife Refuge.

_ Increasing off-shore drilling in the Gulf of Mexico and the Atlantic Ocean.

_ Reviewing the Environmental Protect Agency’s air quality regulations and take away its oversight of greenhouse gas emission regulation.

_ Forcing advocacy groups to sue the government by taking away agencies’ ability to compromise.

_ Maintaining a ban on drilling in Florida’s Everglades.

With a nod to a capital locked in partisan fights, Perry promised Congress would play only a small part in his plan.

The final quote indicates that Perry believes that he could bypass congress and accomplish his goals by the use of proclamation by executive order, rather than through the cumbersome legislative process. Perhaps having occupied one of the least powerful governor’s offices in the nation for eight years, Mr. Perry envisions becoming a dictator/president in the White House.

October 13

Recycling glass for the coast

Soon after founding LaCoastPost in 2008 I was contacted by a representative of a new curbside recycling business in New Orleans called Phoenix Recycling NOLA. At that time the company was exploring the feasibility and market potential for recycling glass to create simulated beach sand for beneficial coastal use.

As it turns out, Phoenix Recycling is still in business and now operating in Orleans, Jefferson, St. Charles, St. Bernard and St. Tammany Parishes. I’ve not heard whether or not any ground glass has been used for beach nourishment in Louisiana, however.

I just tried to contact them and am awaiting a reply, having recently stumbled onto a 2008 publication in the Journal of Coastal Research (JCR) by three Florida scientists who tested the suitability of using recycled glass as faux beach sand, with positive results.

The complete text is available only to subscribers, but here’s the abstract.

Because of the myriad of environmental concerns related to critically eroded shoreline areas, recycled glass (cullet) has been postulated as a potential alternative source material for beach fill. However, the newly proposed cullet beach material must uphold the nesting incubation properties of endangered species such as sea turtles. This study is the first in which the abiotic parameters of recycled glass cullet is investigated as an alternative beach fill material in relation to the nesting habitat requirements of marine turtles. By constructing a simulated sea turtle nesting hatchery and with the use of thermal/moisture logging sensors and extracted gas probe samples, we determined that recycled cullet maintains the abiotic nesting chamber properties to allow for successful sea turtle embryo development. Simulated nests containing recycled glass cullet recorded average temperatures (27.0–31.4°C) that fell within the acceptable incubation range for sea turtles and moisture content readings that showed no significant differences from the beach sand controls (p > 0.05). Similarly, gas probe samples analyzed from all the experimental cullet nests recorded high concentrations of oxygen (?20.0%) with no significant variations from the beach sand controls (p > 0.05). Overall, this study showed that nests constructed with a portion of recycled glass cullet offered a nesting environment equal to the developmental conditions of the native beach sand. Worldwide, the nesting beaches of sea turtles are under the constant threat of erosion, which ultimately results in the loss of nesting habitat. With this research, we document that recycled glass cullet can provide a sea turtle–friendly alternative for beach protection.

October 12

Dardenne leads Nungesser decisively in new poll

Ed Anderson reported in today’s The Times-Picayune that Jay Dardenne holds a commanding lead against his fellow Republican Billy Nungesser in a credible new poll sponsored by WWL-TV in New Orleans. This is the only competitive statewide race with serious coastal significance, and Dardenne is my choice, in that whoever wins will assume the governorship if Bobby Jindal pulls a Sarah Palin and moves out of the Mansion midterm.

Marsha Shuler also reported on the poll results in today’s The Advocate. She noted the significant point that, according to this poll, Dardenne is leading Nungesser in south (i.e., coastal) Louisiana.

Between the two Republican candidates for secretary of state, Tom Schedler is philosophically closer to Jay Dardenne, who appointed him SOS when Dardenne was elected ten months ago as interim Lieutenant Governor. On that basis, and because Senator David Vitter has endorsed both Nungesser and Tucker, I recommend voting for Schedler.

In a complementary column in today’s The Times-Picayune Stephanie Grace described the fascinating political dance among Dardenne, Nungesser, David Vitter and Bobby Jindal, who’s now the short termer among the four.

Yesterday The Advocate published a letter from well-known Baton Rouge writer Mary Ann Sternberg, who articulated a clear rationale for why, in addition to coastal reasons, Dardenne deserves to stay on as Lt. Gov.

October 11

 

Hypocrisy on conserving coastal resources

In an opinion column on October 1st, Bob Marshall, outdoors editor of The Times-Picayune, eloquently called out the Republicans now in charge of state policy for sacrificing coastal conservation on the altar of fiscal conservatism. On October 5th Louisiana Congressman Steve Scalise (R-Metairie), defended his voting record in a T-P letter to the editor and cited his support in the US House for dedicating 80% of the BP fine for coastal restoration.

On October 9 the T-P published a letter to the editor by yours truly defending Marshall’s point that the GOP has lost its environmental conservation roots. I also noted that, although the energy industry has caused 50% of the coastal decline, Scalise is silent about reparations or some in-kind compensation for the damage.

Yesterday the T-P published a letter by Linda Kocher of New Orleans, who also defended Marshall and criticized Scalise (and Jeff Landry and David Vitter) for their Tea Party-inspired coastal frugality. I hope that Rep. Scalise responds in kind to his critics, which would call more attention to the need for dramatic coastal action.

The following facts cannot get too much publicity: (1) Our coast desperately needs restoration funding; (2) increased federal funding is highly unlikely, given the national debt and GOP frugality; (3) fining polluters won’t come close to paying the cost; and (4) a modest tax on coastal oil and gas production and transport is the only feasible solution…but the late Governor Dave Treen was the only Louisiana Republican official with the guts to propose such a radical concept.

October 10

 

 

 

 

 

 

Twelve days ’til the coastal election

As the founding editor of LaCoastPost I have made no bones about my serial concerns with the over-politicized coastal policy overseen by the Jindal administration…and the fact that our governor will receive a virtual free pass to a second term on October 22. Many voters in south Louisiana who have long felt their coastal interests marginalized by Bobby J. may elect to boycott the election.

Please don’t sit this one out! Express your concern by pulling the lever for Tara Hollis. If you want to learn more about Tara here are three good sources:

1) Listen to the podcast of Jim Engster’s 6-22-11 interview with the school teacher from Haynesville, during which she describes moderate and thoughtful political positions on specific issues

2) Today on Baton Rouge’s NPR affiliate WRKF-FM 89.3 Hollis enumerated some of the reasons why her candidacy for governor deserves serious consideration.

3) In terms of the coast, check out the environmental portion of Ms. Hollis’ web site here.

Update: After posting this I listened to Jim Engster’s interview with Eliot Stonecipher, Shreveport political consultant and former strong supporter of Bobby Jindal. Mr. Stonecipher emphasized that the governor has overseen the least transparent and ethically challenged governor’s office in recent history…and that Bobby Jindal is highly unlikely to complete his second term. Thus the Lt. Governor’s race, currently at a dead heat, is where the real (coastal) action is. I’m voting for Dardenne.

Rep. Scalise, coastal jester Bahr and Pulitzer writer Marshall

October 9

Calling out the cause of coastal collapse

In an opinion column in The Times-Picayune on October 1 Bob Marshall acknowledged the current red state condition of Louisiana. He eloquently beseeched our Republican leaders to: (1) acknowledge the desperate condition of the southeast part of our state; and (2) return to its conservation roots, rather than marching in anti-environmental, anti-regulatory, budget-cutting lockstep. Here’s a quote:

It’s proven science that carbon emissions are one of the main engines driving warming — yet the GOP is determined to prevent regulations of that pollution. House appropriation bills have been laced with policy riders forbidding federal agencies from enforcing carbon restrictions, and some the GOP’s leading presidential candidates even advocate shutting the Environmental Protection Agency.

Incredibly, Louisiana’s GOP delegation has supported those measures and those candidates.

Congressman Steve Scalise took Marshall’s comments personally and attacked him as a knee-jerk liberal in a letter to the editor in The Times-Picayune on October 5. Scalise bragged about having fought to ensure that 80% of the BP fine would be used for gulf coast restoration. Well duh!

Today’s The Times-Picayune published a letter to the editor from yours truly in which I defended Marshall against Scalise’s attack. Half of the loss of America’s Delta is the result of big oil and a fine against one company for an oil spill will never pay for the loss…especially when the GOP that Scalise represents wants to do away with such fines and safety regulations!

October 8

 

 

 

 

Graphic from Mother Jones, inset photo of tar sand pit from Greenpeace

Tar sands oil pipeline decision coming during the throes of the 2012 presidential campaign

Lucia Graves reported in HuffingtonPost on the final public hearing on whether or not the US State Department should grant a permit to allow construction of a $13 billion 1661 mile transnational pipeline known as the Keystone XL. If approved, the pipeline would bring oil extracted from Canadian tar sands all the way to the gulf coast near Houston. At issue is short-term job creation vs. greenhouse gas emissions, concern over leaks into the Ogallala aquifer and highly questionable estimates about the overall net energy remaining after the extraction process is complete.

The decision will come toward the end of 2011, during the highly charged political climate of the 2012 presidential campaign.

So far Louisiana officials have been strangely silent on the project but if the Obama administration denies the permit I can just imagine the sky-is-falling outcry from our Chicken Little pols. If it’s approved, as I expect, given the crying need for jobs and our addiction to oil, the president will get nary a word of credit from these same folks. Talk about a lose-lose proposition!

Click here to access an interactive graphic map of the route from Mother Jones.

October 7

 

 

 

 

 

 

 

Lt. Gov. Jay Dardenne (who supports coastal restoration) and Plaquemines Parish Prez Billy Nungesser (who'd like to be Coastal Czar)

The Lieutenant Governor and the coast

Last night the Baton Rouge Tea Party sponsored a debate between the two candidates for the Louisiana office of Lieutenant Governor, the incumbent Jay Dardenne and Plaquemines Parish President Billy Nungesser. Marsha Shuler and Mark Ballard summarized this debate for The Advocate.

Nungesser has been floating the prospect that if he wins Governor Jindal will anoint him to play a serious role in coastal restoration. Given Billy’s hyperbolic claims about the $240 million BP sand berms and his angry confrontations with coastal scientists who dare to bash the berms, this is indeed a scary scenario. Check out the coastal case for voting Dardenne here.

Ed Anderson reported in nola.com that these two very different rivals will be debating a lot more leading up to the October 22 election. Maybe some credible coastal advocates will be present to ask questions.

October 6

 

 

EPA administrator Lisa Jackson (photo from the Times-Picayune)

 

Gulf coast restoration plan comes to light

Yesterday in nola.com Mark Schleifstein reported on the basic contents of the much-anticipated Gulf Cost Ecosystem Restoration plan just released by the federal government. The article includes the four primary goals of the plan, all of which are appropriate, although I agree with Garret Graves, coastal advisor to Governor Jindal, that a little more specificity would have been nice. Here are the goals:

1)   Restore and conserve habitat, including wetlands, coastal prairies and forests, estuaries, seagrass beds, natural beaches, dunes and barrier islands.

2)   Restore water quality, in particular reducing the excess nutrients flowing down the Mississippi River system that create an annual low-oxygen “dead zone” covering an average 6,700 square miles along the coasts of Louisiana and Texas.

3)   Replenish and protect living coastal and marine resources, including depleted populations of fish and wildlife species and their degraded habitats.

4)   Enhance community resilience to a variety of threats, including storm risk, sea-level rise, land loss, natural-resource depletion and compromised water quality.

Today The Times-Picayune carries a contributed op-ed column on this plan by its overseer, Lisa P. Jackson, New Orleans native and administrator of the EPA. Since her appointment by President Obama, Ms. Jackson has been the object of a love-hate relationship by Louisiana officials…who decry regulations and government spending…almost as much as they long to bring home the bacon.

 

 

 

 

Congressman Steve Scalise and journalist Bob Marshall engage in a hypothetical dialogue over coastal policy.

October 5

 

Steve Scalise protests Bob Marhall’s view of the GOP

In his opinion column on October 1st The Times-Picayune’s Bob Marshall chided Louisiana’s Republican officials for abandoning the proud conservation heritage of their party by opposing legislation to address the root causes of our disappearing coast. His examples include staunch GOP opposition to regulation by the EPA of carbon emissions that cause global warming, rising sea levels and probably stronger storms.

Marshall’s words obviously got under the skin of Congressman Steve Scalise (R-Metairie) who vehemently objected to Marshall’s message in a letter to the editor published on October 5th in the T-P. Scalise pointed proudly to his recent support for dedicating 80% of the BP fine for gulf coastal restoration.

Did this position demonstrate political courage? Scalise is no hero for acknowledging that the Macondo well blowout did real damage to our coast…although Speaker Boehner may have preferred to spend BP’s possible $20 billion fine to offset even more subsidies for Big Oil. Scalise will be a true coastal hero when he calls out the energy industry that supports him for causing the disappearance of about 1,000 square miles of America’s Energy Coast…long before last April.

As was pointed out here in LaCoastPost.com on October 2, for better or worse the Republican Party in Louisiana has inherited the awesome responsibility for virtually all state decisions on coastal policy. Whatever action in south Louisiana happens or doesn’t happen during the next four years will be the result of that policy.

Coincidentally, it was reportedon October 3rd in Slate Magazine that 55% of registered Republicans don’t know what ‘GOP’ stands for. It sounds as though officials of the Grand Old Party also suffer from short memories.

Graphic modified from James Kuffner 2003

October 4

Cooling the planet the dangerous way

Cornelia Dean reported in The New York Times that a bipartisan panel of climate scientists and public policy experts today issued a report that endorses proceeding with highly controversial geoengineering research to artificially cool the planet, if politics continues to stall global carbon reductions. This would entail exploring the feasibility of playing God as a last resort to slow the catastrophic effects of global warming.

One of the principal measures being considered is mimicking volcanic eruptions such as occurred in 1991, when Mount Pinatubo erupted. The following quote from Wikipedia summarizes the global impacts of this eruption:

The effects of the eruption were felt worldwide. It ejected roughly 10 billion metric tonnes (10 cubic kilometres) of magma, and 20 million tons of SO2, bringing vast quantities of minerals and metals to the surface environment. It injected large amounts of aerosol into the stratosphere – more than any eruption since that of Krakatoa in 1883. Over the following months, the aerosols formed a global layer of sulfuric acid. Global temperatures dropped by about 0.5 °C (0.9 °F), and ozone depletion temporarily increased substantially.

The cooling effect of Pinatubo and other major volcanic eruptions suggests the feasibility of intercepting solar insolation with a stratospheric sunscreen of sulfur dioxide molecules…the principal cause of acid rain and a destroyer of stratospheric ozone.

Dan Borne: I'm a PR guy, not a scientist but manmade climate change is BS!

With all due respect to advocates of geoengineers, this concept reminds me of another ill-informed measure to solve an environmental problem…building temporary sand berms off the Louisiana coast to intercept oil. On the other hand, the completion of a serious report by thoughtful people who recognize the gravity of global warming may help convince the climate change deniers in Louisiana, such as Dan Borne, president of the Louisiana Chemical Association.

October 3

'Mahout' Marshall tries his hand at steering the elephant that dominates coastal policy back toward conservation.

‘Mahout’ Marshall urges Louisiana’s GOP elephant to use its awesome power for good.

Just as the 2011 hurricane season cools down the political weather in Louisiana and the nation is warming up. The future of the southern third of our state is arguably as contingent on political winds as on Gulf storms and rising sea levels.

It isn’t unusual for Sunday editions of The Times-Picayune to carry political opinion columns by senior staff members, such as James Gill or Stephanie Grace. Yesterday’s edition was different, however, in that it carried a passionate political plea by Pulitzer Prize winning Bob Marshall, Outdoors Editor and tireless coastal advocate.

Bob’s message was unusual not only because it didn’t mention fishing but because it was highly partisan, aimed solely at Republican officials in Louisiana. That’s because, for better or worse the Republican Party in Louisiana has inherited the awesome responsibility for virtually all state decisions on coastal policy.

Be that as it may, Marshall’s plea for the GOP to return to its conservative roots is worth a read by anyone who cares about America’s Delta, regardless of your political persuasion.

Landrieu calls out disaster relief hypocrisy

Gerard Shields, who usually divides his Sunday DC report in The Advocate among a variety of political goings on in DC, yesterday dedicated his entire column to Senator Mary Landrieu, who has become a tiger for disaster relief. Read this column.

Koch Bros’ in the hot seat

It was reported yesterday in Bloomberg Markets Magazine that Koch Industries, the huge privately held company of Charles and David Koch, is under investigation for what sound suspiciously like treasonous activities…doing illegal bid’ness with Iran .

These sibling energy titans and anti-environmental thugs are perhaps the most influential deniers of climate change in history. The coast of Louisiana is affected by their political influence. Their daddy Fred Koch supported the John Birch Society long before the sons became Tea Party supporters. If anything comes of these charges poetic justice will have gained new meaning.

 

 

 

 

Dean Wilson and one of the photos he has used to call the public's attention to callous coastal destruction. The small stump size indicates trees harvested for yard mulch that's inferior to pine straw!

October 2

Cypress mulch back in the news: kudos to Dean Wilson

Michelle Millhollon recently described a bizarre situation in The Advocate in which a bankrupt cypress mill in Tangipahoa Parish is defaulting on a loan from Texas backers. This sparked a flashback to the ‘glory days’ when it was a fad to turn young Baldcypress trees…one of the last best hopes to save coastal Louisiana…into yard mulch. Among many ironies of this story is the fact that Bob Odom, former Louisiana Secretary of Agriculture and Forestry, had subsidized with state funds an industry that was arguably contributing to coastal deterioration.

Dean Wilson wrote a typically heartfelt opinion column published yesterday (October 1) in The Advocate that brought back vivid memories about this time. I got to know and respect Dean during the late ‘90s, when logging Baldcypress trees on privately-owned lands surrounding Lake Maurepas became newsworthy and controversial. Read a summary of Wilson’s cypress mulch struggle published in April 2011 in 3rd Coast Connect by John Shephard.

Publicizing the unsustainable harvest of second growth cypress trees on private land called attention to the fact that huge areas of coastal forests were being killed by coastal subsidence and encroaching salt water. A key issue was whether logging forests that couldn’t long survive anyway should be allowed to proceed.

A win-win solution would be to allocate coastal funding to purchase at risk lands from their owners at a fair price, keeping the trees standing until they could possibly be saved to serve a higher and better purpose. The only way to accomplish this, of course is by diverting river water…into the Maurepas Basin, for example.*

Governor Blanco inherited this thorny issue. In contrast to the Jindal administration, which generally ignores credible scientific advice, she appointed an outstanding commission of experts on coastal forest ecology to report on the state of the coastal forests in Louisiana and whether logging could be practiced sustainably.**

Since Dean Wilson emigrated from Spain to south Louisiana in 1984 he has become our most dogged defender of coastal forests and the founder of the Atchafalaya Basinkeeper.

On a final note, during the tumultuous days of cypress mulch,the regulatory division of the New Orleans District of the Corps of Engineers denied a Livingston Parish landowner a permit to log a tract of coastal forest in Livingston Parish, under the River’s and Harbor’s Act, which regulates activities that may obstruct navigation. This gave Senator David Vitter apoplexy and he tried to change the law to allow more coastal destruction. Read a description here from peoplegetready.blogspot.com.

It’s ironic that Garret Graves, now Governor Jindal’s coastal guru but then a Vitter staffer, loyally carried the water for his boss on this issue.

*The ideal spot to do this is located on the east bank of the river near Convent. This is the site of Nucor Corporation’s new iron and steel plant now under construction, where the Garret Graves from the governor’s office should asking for access to river water to quench the thirst of the Manchac swamp. So far, not a peep has been heard from Garret.

**This scholarly report was published on April 30, 2005, exactly four months to the day before Katrina devastated New Orleans, effectively preventing the reelection of Kathleen Blanco…and pushing cypress tree logging into the background.

October 1

Flood risk projections in error…shame on me!

The Corps of Engineers has touted its post-Katrina enhanced flood protection system for southeast Louisiana as conferring protection against a 1% annual flood risk, or protection from a storm event considered likely to occur within 100 years. This figure sounds impressive at first blush but critics have pointed out that it creates an unwarranted sense of security.

On September 19 in the LaCoastPost coastal scuttlebutt I fell victim to the confusion caused by this metric and posted a statement that further muddied the floodwaters. As I reported that day, the draft 2012 coastal Master Plan now under preparation will include the specific…and highly ambitious…goal of developing three levels of flood protection for coastal residents, based on the population density of their surroundings.

Here’s the relevant quote from the post:

…The plan will aim for the following levels of flood protection: Rural areas: 50 years; Urban areas: 100 years; Metropolitan: 100+ years.

Keep in mind that 50-year ‘protection’ implies a 2% risk of flooding during any given year (a 60% likelihood in 30 years) and 100-year ‘protection’ means a 1% risk of flooding during a given year (and a 30% likelihood in 30 years). Even if these goals could be achieved they offer little comfort to a 30 year mortgage holder.

A statistician friend of mine (not my brother-in-law Maurice Fox) pointed out that I made a naive statistical error converting 50 year and 100 year flood risk over a 30 year mortgage. He sent the following emailed message:

Aren’t you forgetting something? Somewhere, your high school science teacher is weeping.

Each year, by definition, is a Bernoulli trial. The outcome of thirty Bernoulli trials has a binomial distribution (kindergarten statistics) giving a 45% risk instead of 60%, and 26% not 30%. These differences are not trivial. Worse, the “common sense” approach to probability you used is exactly the kind of bogus science I have come to expect from the Jindalackies.

Your tardiness in correcting this seems only a modest step up from building sand berms!  Don’t make me get ugly!

Signed: A concerned (but not necessarily about you) neighbor.

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  5. We have used Phoenix for many years and hope very much Phoenix can have a place in using glass to help save the coast.

  6. Walt Sikora says:

    Grinding glass to make sand is an absurd, energy-wasteful idea. The world has an abundance of sand, thank you very much. (though maybe not always where people want it to be)

    Recycled glass is much more valuable as glass because of the energy it took to make it from sand in the first place, I’s analogous to recycling aluminum cans, which saves 95% of the energy to make aluminum from bauxite ore.

  7. Kelly Haggar says:

    Two personal observations:

    As a state senator in 2004, Dardenne was on the judiciary committee hearing my suggested change to the treatment of non-professional goodwill in divorces. He listened carefully, asked thoughtful questions, and voted to make the change. His opinion carried weight with the other senators, even the ones who were also attorneys. I’m having real trouble picturing Nungesser doing the same.

    In 1999, also a state senator back then, Tom Schedler’s secretary’s son was in my Cub Scout pack. I ran into Sen. Tom at a function and, on the spur of the moment, asked him to take some Cub Scout stuff back to his offce to save me a trip. He instantly said “Sure.” I have no clue if Tucker would have also done the same for someone in his district but I know Tom did.

    Coast or not, I’m voting for the Jay-Tom duo.

  8. Oct. 4, 2011
    A statement attributed to Mr. Dan Bourne, president of the Louisiana Chemical Ass’n. would probably be more appropriate if it were:
    I’m a BS guy, not a scientist, but man made Climate change is PR!

  9. Walt Sikora says:

    Here’s a follow up on The Koch Brothers in the hot seat for “doing illegal bid’ness with Iran “.

    This is nothing new for the Koch brothers and their billions, here is an interesting “nature note” on how the Koch fortune came about.

    The Koch brothers father, Fred Koch invented a more efficient thermal cracking process for turning crude oil into gasoline, that led to bigger yields and helped smaller independent oil companies. He was immediately sued by the larger oil companies who filed 44 different lawsuits. [Proof that there really is no honor among thieves.] Fred Koch eventually won all of the trumped-up lawsuits but the cost put him out of business.

    So Fred Koch went elsewhere, and guess where he went? To the Russkies. That’s right, he worked for old comrade Joseph Stalin where he made his fortune developing an oil industry for the Soviet Union. Isn’t that something?

  10. “Each year, by definition, is a Bernoulli trial.” I could be wrong, but Bernoulli trails assume the probability of occurrence each year is an independent with equal probabilities. But, hurricane climatology follows temporal trends, so these assumptions aren’t valid.

    • The definition of a 100-year event ignores trend and ignores serial correlation. A 100-year event is a pseudo-parameter that changes faster than the Corps and FEMA are capable of estimating. I hope the actuaries are using better models, but we’re talking about something that is very hard to do.

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