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The milk cases are certainly an inexpensive alternative for the DIY'er. If exposed to sun & elements, the plastic breaks down over a few years. There would also be structural integrity issues, I think. But, for using the BH media, the only short term negative I can think of is algae growth on the media due to light exposure. If someone is going to try this, I'd suggest looking for a way to block sunlight w/o blocking air exposure.
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