Text of Letter
Mr. Jeff Skipper
Technical Advisor
Wendy Schmidt X-Challenge
Dear Jeff,
Thank you for taking the time to speak with us on Wednesday.
We wish to make the case that, to fairly and thoroughly address the goals of the X-Challenge and the Schmidt Family Foundation, the X-Challenge competition should allow any product and method that fulfills the following:
1. Has absolutely no negative impact on the environment with or without retrieval.
2. Is virtually 100% retrievable after deployment in open waters, even under high wave conditions, (with effective oil captrure and retrieval in any waves of navigable height, not just the minimal one foot waves of the Ohmsett simulation) and deployable in all adverse weather conditions where skimmers are otherwise not at all effective.
3. Allows recovery of 95% of the oil for reuse, as clean, or cleaner than before spilled.
4. Offers faster and more complete retrieval of oil than the highest presently known retrieval method for recovery of spilled oil.
5. Has the potential to be recognized as the ultimate first response method, since its mere deployment immediately neutralizes all the potential harmful effects of an oil spill.
6. Is safe to all aquatic life, animals, humans and plant life and once deployed prevents any pickup of oil by birds (and incidentally, also can safely clean oil from any birds or animals that were otherwise contaminated by oil due to this product not having been used as a first response).
7. Arguably has superior advantages over all known alternatives, to be recognized as the ultimate method of response to oil spills.
8. Is incidentally a product whose method of use on land has just been patented, (in December 2010).
9. Is incidentally, an equally effective method for removal of oil spills on land or water, in all weather conditions, in all temperatures, that works in rain, sleet, and snow, and on all surfaces such as ice, snow, and all soils such as heavily organic, as in rain forests (where it is currently in use in Ecuador), where the oil saturated soil problem has resisted a suitable answer for decades.
10. Is a product and method even capable of rapidly cleaning the 21 year old oil spill that remains from the infamous EXXON Valdez where, to this day, the oil still remains on the beaches.
11. Is a product and method for which there is no other comparable alternative.
Consistent with the objectives of the X-Challenge, it only makes sense that this patented product and method of its deployment and retrieval, be allowed to be demonstrated and to thereby compete againt all alternatives, for recognition of its ultimate superiority as the current best answer for the retrieval of oil spills.
Please take these things into consideration by allowing it to compete in the X-Challenge.
Attached is a preliminary summary of our product and methods. Our team is providing this information to facilitate a revision to the WSOSXC Guidelines and its description of “allowable” methods. Currently those guidelines prohibit the use of sorbents on the water surface.
Our objection is not as a company marketing a product. Our objection is based on our view that the restriction is contrary to the goals of the X-Challenge and the Schmidt Family Foundation. The decision to eliminate our product and method because it happens to include a sorbent, runs contrary to the goals of the X-Challenge and all the historic data since 1971 regarding EPA approved sorbents.
Further, we contend that the decision to disallow loose sorbents in the Gulf of Mexico spill was the precipitating event in a process that turned a manageable spill into an environmental disaster.
It is easy to trace the cause of this ill advised decision due to the fact that the most common loose sorbent is polypropylene pulp. Rather than making a distinction between hundreds of different sorbents - all sorbents have been lumped into one category and erroneously summarily dismissed under the belief that every loose sorbent must be the most commonly known loose sorbent which is polypropylene, a plastic not allowed by the EPA for deployment into open waterways in accordance with the EPA's absolute mandate of “no plastics overboard.”
This, despite the fact that some sorbents have been created through a process of scientific inquiry every bit as rigorous as any other high tech solution. Furthermore, the use of environmentally benign sorbents is the method of choice in the European Union where dispersants are banned entirely. While we are not making the case that the European Union’s approach is the only approach, we are making the case that their preferential use of environmentally benign sorbents strengthens the case that they should at the very least should be allowed where, in accordance with the EPA guidelines, the absorbent contains absolutely no ingredients that are harmful to the environment, (such as plastics and polypropylene).
Our EPA reviewed product is a surface modified cellulose that will not absorb water, floats, and aggressively captures oil at a ratio of 30 times its weight. Our MOP product has been submitted to the EPA wherein the EPA has declared our product, is not in any way restricted for deployment in open waterways. It is as benign to the environment as a leaf falling from a tree.
Our product MOP is quickly, easily and fully retrievable from the waterway, where up to 95% of the absorbed oil from our product is then easily separated, extracted, and thereby recovered for reuse and thereby has all the obvious prerequisites to be qualified and allowed to compete within the X-Challenge guidelines.
During the Gulf of Mexico spill last summer, any idea that did not fit the “boom, burn and disperse” mentality was dismissed automatically, resulting in their inability to avert a national disaster and the need for the X-Challenge to step forward with a competition to resolve this issue once and for all.
Without an exigent emergency there would be no excuse for not giving fair consideration to environmentally benign sorbents in general and MOP Maximum Oil Pickup in particular. The WSOSXC can put the question simply, and demand a simple answer---“What is the safest, fastest, and best method for recovering oil from an oil spill in water?” It would be a tragic irony if the competition which sought to encourage solutions beyond the status quo of the GOM, only served to reinforce the inappropriate exclusion of an environmentally sustainable solution with extremely effective and efficient results.
Our sense of your concern about sorbents is that they may be difficult to remove from the water. Quite naturally, nobody wants to risk adding another problem to an already bad situation by putting an uncontrolled substance on top of mishandled oil. There are three answers which should remove any fear or doubt: 1) We have the technology 2) MOP with or without removal is safe and 3) Profit encourages effort.
Quite simply, MOP is easy to collect. It floats and will not sink even when fully saturated. Its affinity to cling to itself is nearly as strong as its oleophilic and hydrophobic qualities. MOP draws in oil, repels water and inherently sticks together. MOP can be deployed even more rapidly than an oil spill develops. It can even preempt the release of oil thereby staying ahead of the problem. Which, in real world conditions, is an answer that no mechanical system or skimmer can equal. MOP is deployed rapidly at over 150 mph by our MOP CANNON. MOP is retrieved rapidly using fishing nets that cover a much larger area, in swaths up to 200 feet wide that are larger and more efficient than any known skimmer.
Depending on the size of the spill and the amount of MOP to be used, broadcast of the MOP sorbent and the collection of the saturated MOP is easily tailored to the task at hand and imminently scaleable. Our MOP product is in use in Ecuador where it has been extensively tested in comparison with all alternatives. The result is a discovery that for oil spills in water; what can be recovered “by hand” in less than one hour had previously taken more than two days to accomplish the same result with any known or attempted alternative. Larger spills, like those from a tanker, can be controlled with mechanical distribution directly into the spill or into nets trolling with MOP through the oil plume. Again, depending upon the size of the spill and the amount of MOP, the methodology for collecting the sorbent may range from collection by harvesters such as those used for harvesting weeds or using standard fishing nets, where the process far exceeds the rates of oil recovery otherwise attainable by skimmers.
Even if you assume, for the sake of argument, that unused or oil-saturated MOP is not recovered as timely as planned, there is no threat to the environment. MOP is completely safe before and after oil saturation and the oil will not be released until it is squeezed for purposeful extraction of up to 95% of the captured oil, actually cleaner than before it was spilled and thereby the oil is recovered for reuse. The MOP sorbent is all natural, nontoxic, biodegradable and completely safe. In fact, the MOP components are so safe that they could meet or exceed food packaging requirements! In large or small quantities, MOP does not harm the environment. Even unskilled deployment and use of MOP will not cause harm to the environment. Oil saturated MOP floats and is immediately available for collection or even weeks later, if necessary without degradation. Although our team does not favor it, MOP is combustible thus even the undesirable in situ burning is not hampered.
The low-cost and highly efficient use of MOP even allows for a profit potential from the value of the oil retrieved by the MOP recovery method.
Our MOP-PET (Petroleum Extraction Tool) allows reuse/resale of the oil which is now trading above $100/barrel. In light of rising demand and dramatic price increases, this MOP feature allows the power of a profit motive to be harnessed in favor of a cleaner environment. Make no mistake, MOP is both effective and efficient ---add to that an opportunity to cheaply and easily extract the oil for additional revenue and the MOP answer shows significant advantages over alternatives. Oil producers, handlers, and response companies are encouraged to maximize their cleaning efforts and maximize sustainability with a measurable offset effect on their costs.
We were very gratified by your receptiveness to our concerns. We respectfully request that the line restricting the use of sorbents on page 8 of the guidelines be removed. Short of this, a process for exempting a sorbent that can demonstrate its benign characteristics and a methodology for its removal plus recovery would also be a fair method for resolution. We have attempted to address what appears to be WSOSCXC (and the historical) objection to sorbents—ensuring recovery of the sorbent. The MOP Team is continually trying to answer the need for a sustainable solution to this issue and we are pleased to present this preliminary look at our proposal. Within our completed submission you'll see the full development of the techniques that we will be using to provide an effective demonstration of the capabilities and advantages of MOP Maximum Oil Pickup.
Thank you.
Charles M. Diamond 603-747-2200 cd@fsinh.com
Wayne D. King 603-515-6001 waynedking9278@gmail.com
Andrew Bronson 603-747-2200 andrew@mopenvironmental.com
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