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May 03 2018

Texas Firm Developing A.I. Technology Application to Help Clients Navigate the Environmental Regulatory System

Launching “CERES”

(Houston) – May 2, 2018 – Letter from the Editor


Artificial intelligence or “AI” is coming to environmental management.  It is no longer “if”.  It’s “when”.




The AL Law Group’s focus on simplicity, innovation, and finding clients simpler and lower cost solutions has led us to developing this product.  We call it CERES.  The following is a “sneak peek” at how AI is likely to play-out in the environmental management system in the coming years.


A “Sneak Peek” at AI and Environmental Compliance


AI is already beginning to “butt heads” with the 1970’s regulatory structure.  There are 3 scenarios that will likely play out in the coming years.

  1. AI will be hindered by the current environmental regulatory structure. Think about what it would take to get regulatory approval for an algorithm.  Then consider that the algorithm learns from more data and adapts.  It’s no longer the same algorithm.  The new learning can’t be implemented without updating approvals.  In other words, the regulatory cycle is not set up to address the machine learning environment.  Because AI however will advance regardless of the regulatory system, conflict and confusion will occur as these systems increasingly “butt heads”.


  1. AI will learn how to traverse the regulatory system. Few if any realize this, but AI can be applied not only to the regulated equipment, but also to the regulatory system itself (either on its own initiative to solve the problem or at the directive of a person)—thereby changing the regulatory landscape (see discussion below).  The AL Law Group is at the forefront of this technological application advancement.


  1. AI will lead to updating the regulatory system. The 1970’s era environmental regulatory structures will be updated to accommodate, promote, and better regulate AI and other technology developments in the environmental arena.  The regulatory structure will be simplified and modernized in a way that holds companies accountable for results rather than procedures—leading to significant environmental and economic benefits.  AI and other developing technologies such DIAL, SOF, open-path FTIR, and space-based air quality monitoring will thrive in this results-driven rather than procedural-driven regulatory framework.




AI can and will change the regulatory system—even if the system never changes


I will explain.  To understand how this will work, one must carefully read and re-read the following statement.  Winston Churchill said, “If you have 10,000 regulations, you destroy all respect for the law.”  Again, “If you have 10,000 regulations, you destroy all respect for the law.”  What Churchill was implying was that if you have lots of complicated regulations . . . you can really do whatever you want.  Now imagine an artificial intelligence system that is always looking for ways to improve itself . . . and then runs across 10,000 regulations.  It will find a way to do whatever it wants.  It is the master of complexity.  The more complicated the system, the more it can find support for doing whatever it wants.


When clients call me and ask what the law is I sometimes kid with them and say “what do you want it to be?”  This is only partially said in jest.  The fact is that environmental regulation is one of the most complicated systems the world has ever seen (see link).  And the fact is that more regulatory decisions and data is coming on-line and is providing millions of data points that can be mined.  For example, TCEQ recently consolidated all data onto a searchable server.  I literally can search key terms and read people’s emails between the agency and others–looking for precedent.  Now imagine an artificial intelligence system that can sift through all these millions and millions of pages regulations, guidance, permit materials, agency decisions, and other data points—drawing inferences and creating regulatory algorithms for legally supportable work-arounds.


It’s better if the regulatory system kept up with AI


The breadth of environmental management methods that can be advanced through artificial intelligence and other developing technologies has grown significantly since the 1970s.  The regulatory environment hasn’t.  For AI to gain traction, and not to begin changing the regulatory framework on its own, new regulatory frameworks must be created.  Companies can then create the compliance structures necessary to smooth adoption into environmental compliance that will reduce more pollution at less cost.




Chesterton was right


G.K. Chesterton once said, “Conservatism is based upon the idea that if you leave things alone you leave them as they are.  But you do not.  If you leave a thing alone you leave it to a torrent of changes.”  One cannot deny that AI is coming.  According to Google’s CEO, AI will have a greater impact on humanity than fire or electricity.  I don’t think ceres3this was a far-fetched statement.  One cannot help but sit at the edge of one’s seat in gleeful anticipation of the future to come.  Challenges will present themselves, but for companies like the AL Law Group that are putting themselves at the forefront of creating technological applications in new dynamic ways that improve environmental and economic performance—the future is as bright as it can be.


For more information on the CERES product, please contact the AL Law Group at (281) 852-8064.



Jed Anderson is the editor of TexasEnvironmentalNews.com. Anderson is a principal attorney with the AL Law Group–and a former attorney with Baker Botts and Vinson & Elkins and an Adjunct Professor of Law at the University of Houston Law School where he taught the Clean Air Act.  In addition to his legal practice, Anderson has become a national leader over the past 15 years and a hub for Clean Air Act reform efforts–writing articles, gathering people and ideas, speaking across the country, writing a book, helping to lead national efforts to transform the Act, and even himself re-writing the Act (for more information, see www.cleanairreform.org).
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