Thursday, July 31, 2014
Criticisms of 35-mile tunnels under the Sacramento delta point to destruction of key habitats, loss of species existing only in California
"Delta tunnel plan called a fish death sentence by key group"2014-07-31 by Carolyn Jones for "San Francisco Chronicle" daily newspaper [http://www.sfgate.com/science/article/Delta-tunnel-plan-blasted-by-key-environmental-5657902.php]:
The state's plan to build a pair of 35-mile tunnels under the delta would cause the extinction of winter-run chinook salmon, steep declines in dozens of other species and devastate water quality in San Francisco Bay, an environmental group said Wednesday.
"This project would be a major step in the wrong direction," said Gary Bobker, policy analyst for the Bay Institute, which submitted its 250-page findings this week to the state Department of Water Resources as it updates its Bay Delta Conservation Plan. "Diverting more water from the delta is exactly what we need to stop doing if we're going to have a sustainable ecosystem."
The state's $25 billion plan for the Sacramento-San Joaquin River Delta calls for two 40-foot-wide tunnels to carry water from the northern end of the delta to the pumps at the southern end. The purpose is to improve water flow throughout the 1,100-square-mile delta; reduce reliance on old, crumbling levees; and potentially increase water allocations to farms and consumers in Central and Southern California.
But, according to the Bay Institute and other environmental groups, the tunnels will leave northern parts of the delta saltier, warmer and with less water - a death sentence for migrating fish, they said. The tunnels would also alter the makeup of San Francisco Bay because less cold freshwater would reach the Golden Gate.
To make up for the loss of habitat, the plan calls for more than 50,000 acres of wetland restoration, including floodplain habitat for salmon near the Yolo Bypass.
But the new wetlands won't be enough to compensate for the change in water quality, Bobker said. The new wetlands may be a boon for birds, but the most pressing need for salmon, sturgeon, longfin smelt and other fish is chilly water that flows from the Sierra snowpack to the Pacific, Bobker and his colleagues said.
'Circling the drain' -
"These species are already circling the drain. They don't have 20 or 30 years for us to see what works," said Jon Rosenfield, a conservation biologist at the Bay Institute who also worked on the report. "All of the chinook salmon would be very much harmed by this. They'd all see declines."
A consultant working on the state's delta plan agreed Wednesday that the northern delta will be saltier, warmer and more stagnant in years to come. But that's largely due to climate change, not the tunnels, the consultant said.
In fact, the plan would improve conditions for salmon by reducing the number sucked into the pumps and providing better water circulation throughout the region, she said.
The impacts of climate change need to be addressed separately, she said. The Bureau of Reclamation, among other agencies, is looking at broader issues related to water supplies and global warming.
The delta plan is backed by Gov. Jerry Brown as well as dozens of water agencies, cities and farming groups, mostly in Southern California. They say it's critical to the state's economy to upgrade its aging water infrastructure and provide a more stable supply of water for farms and development in the central and southern parts of the state.
A few Bay Area groups are also in support, including the Santa Clara Valley Water District, which supplies San Jose and parts of Silicon Valley, and the Alameda County Water District, which serves Fremont, Newark and Union City.
They also view it as a solution to environmental problems, such as inadequate water circulation and the volume of fish that get sucked into the pumps.
Impacts called overblown -
The Bay Institute's reading of the environmental impacts of the plan are overblown, said Nancy Vogel, spokeswoman for the Department of Water Resources. Water quality in San Francisco Bay would remain virtually unchanged, and salmon and other species should actually fare better than they do under the current conditions, she said.
"We wouldn't be doing this if it didn't benefit the salmon," she said. "And we've done extensive scientific analysis and concluded that the effects on San Francisco Bay would be minimal."
Dozens of environmental groups, water agencies and local governments filed responses to the delta plan's environmental impact report this week. The state will review the comments, update the report and eventually submit it to state and federal regulators who would issue the permits.
The California Sportfishing Protection Alliance vehemently opposes the plan.
"This plan puts the estuary on a scaffold and the interests of south valley agriculture on a throne," said the group's director, Bill Jennings. "It's going to make the delta look like an Arkansas lake - warm water and no flow."
Longtime sport fisherman Doug Chance, a press operator from Antioch who was fishing from the Antioch pier Wednesday, said his cohorts from throughout Northern California are fighting the plan.
"The freshwater is already drying up. We used to catch catfish like crazy around here. Now we hardly ever see them," he said. "If they put these tunnels in, hell, I wouldn't be surprised if we started catching stingray and sharks up here. It's all messed up."
Saturday, July 26, 2014
"The Deliberate Omission of any True BDCP Alternatives"
2014-07-25 by Bob Wright for "The River Advocate":
The BDCP Draft EIR/EIS alternatives chapter and "Draft Plan alternatives-to-take" chapter fail to include any real alternatives, let alone the required range of reasonable alternatives to the BDCP Water Tunnels water conveyance system upstream from the already imperiled San Francisco Bay-Delta. The Water Tunnels would divert enormous quantities of water from the Sacramento River near Clarksburg, California. As a result of this massive diversion, enormous quantities of water that presently flow through designated critical habitats in the Sacramento River and sloughs to and through the Bay-Delta would not reach the Delta. Flows would be reduced in the Sacramento River, sloughs and Delta to the detriment of listed and other fish species. All of the so-called project alternatives set forth in the Draft Plan and Draft EIR/EIS are simply different versions of the same project. They all create a capacity to divert more water by way of new conveyance upstream from the Delta. And they do so in the face of the ESA Section 7 command prohibiting federal agency actions that “result in the destruction or adverse modification of [critical] habitat of [listed] species.”
The failure of the BDCP Drafts to include so much as one alternative reducing exports seems at first blush astonishing. After all, a claimed purpose of the BDCP Plan is “Reducing the adverse effects on certain listed [fish] species due to diverting water.” (BDCP Draft EIR/EIS Executive Summary, p. ES-10). As the National Academy of Sciences warned back in May 2011-- in commenting on an earlier version of the BDCP Plan-- “Scientific reasons for not considering alternative actions are not presented in the plan.” (Report in Brief, p. 2, May 5, 2011). More than two years ago, the Environmental Water Caucus (EWC) (a coalition of over 30 organizations including Friends of the River) pointed out to the California Resources Agency Deputy Secretary:
The absence of a full range of alternatives, including an alternative which would reduce exports from the Delta. It is understandable that the exporters, who are driving the [BDCP] project, are not interested in this kind of alternative; however, in order to be a truly permissible project, an examination of a full range of alternatives, including ones that would reduce exports, needs to be included and needs to incorporate a public trust balancing of alternatives.
There has been a complete failure to develop and evaluate alternatives reducing diversions/exports including the EWC Reduced Exports Plan transmitted to the California Resources Agency in December 2012 as well as the more detailed Responsible Exports Plan developed in May 2013.
In fact, this BDCP process ignoring and concealing obvious and direct alternatives that would reduce the “adverse effects on certain [listed] fish species due to diverting water” is not astonishing. It is a deliberate, bad faith, end run on the alternatives analysis requirements of NEPA, CEQA, and the ESA. The exporters have money, lobbyists and power. They are driving the project. They do not want the public including environmental organizations, Indian tribes, Northern California, and San Francisco Bay-Delta interests to have a BDCP alternative that they could support. This concealment and silencing of any alternatives that would reduce exports as opposed to all of the current BDCP alternatives that increase the capacity for exports is calculated to increase the likelihood of the BDCP proponents getting what they want. This bad faith omission of alternatives reducing exports skews the debate in favor of new conveyance and against reducing exports since no other alternatives are presented.
The current BDCP Draft’s omission of the range of reasonable alternatives required by law requires the preparation of a new Draft Plan and Draft EIR/EIS and a new public review period to attempt to cure this fatal flaw.
The Deliberate BDCP Website Suppression of Comments -
After the 40,000 pages of BDCP project advocacy called the Draft Plan and Draft EIR/EIS were released in December 2013 for public review and comment, the BDCP website was closed to the posting of comments and correspondence from the public. Consequently, an organization or individual attempting to wade through the 40,000 pages of self-interested project advocacy to spot the issues and figure out the truth is unable to learn from the comments and correspondence from other organizations and individuals who are not project proponents. The public’s ability to be informed regarding this project including cons as well as claimed pros would have been facilitated by having access to comments and correspondence made by others during the review process. Instead, the BDCP agencies have done their very best to keep the public in the dark about issues spotted by those who are not project proponents.
This blinding of the public to critical environmental information even extends to comments by sister agencies. Here are just a few of the many possible examples of comments from public agencies that the citizen using the BDCP website does not get to see. “The BDCP is based upon this misrepresentation: that a massive new twin tunnel system, which would greatly reduce the natural flow of water through the Delta, qualifies as a ‘conservation’ project to restore the Delta ecosystem and protect species already verging on extinction.” (County of San Joaquin comments, p. 1, July 9, 2014). Another example is: “Chapter 8 of the current BDCP does not provide the detailed information necessary for potential participating agencies to evaluate individual agency cost-benefit (or feasibility) of the proposed project.” (San Diego County Water Authority, p. 2, June 2, 2014). There is the June 24, 2014, comment letter from the Delta Stewardship Council. The public trying to understand the project is not informed that the State agency responsible for ultimately determining whether the BDCP is consistent with the Delta Plan has found that the BDCP EIR: should “Identify the water available for export and other beneficial uses under alternative flow criteria considered in the draft EIR/S” (Letter p. 1), “The benefits of tidal marsh restoration to Delta smelt are likely overstated” (p. 2), “Water quality impacts are compared to SWRCB water quality objectives with little regard to specific water quality needs of aquatic species of concern” (Id.), “San Francisco Bay should be included in the scope of the analysis, especially for water quality” (p. 12), and so forth.
This is a double attack on the truth and on informed public review of the proposed project. The BDCP agencies have refused, as shown above, to identify, develop, or consider in the Draft Plan and Draft EIR/EIS any alternatives that would reduce exports. At the same time, the agencies have also shut down the BDCP website to the posting of public comments and correspondence to prevent independent organizations and individuals from informing the public about alternatives and critical information that the exporters do not want the public to see.
The government agencies would not be blinding themselves and the public to alternatives reducing exports while at the same time eliminating public comment and correspondence from the BDCP website if the agencies actually believed the BDCP proponents’ claims about the asserted benefits of the project. The silencing of comments on the BDCP website is powerful evidence that the BDCP proponents are afraid of the facts and the truth.
Friends of the River objects to approval of the BDCP and is in favor of reducing exports. That said, Friends of the River also believes in the American tradition of democracy and informed, indeed spirited, public debate of important and controversial issues. Because of that, we have been seeking and obtaining copies of BDCP comment letters under the Freedom of Information Act beginning in February 2014 and posting them on our website at www.friendsoftheriver.org/bdcpcomments . We have been posting all comment letters we have obtained regardless of whether the particular comments oppose or favor the Water Tunnels. The government agencies should be doing what we have been forced to do. That is the American way.
Misrepresenting Taking Water to be a “Conservation” Plan -
The only difference between the BDCP and this same Governor’s “peripheral canal” that was rejected by a 2-1 statewide referendum vote in June 1982 is that the project proponents, their lobbyists, their lawyers, and their supporters inside the government have come up with the clever trick of calling this a “conservation” plan. That trick is Orwellian. War is not “peace,” lies are not “truth,” and a new water diversion is not “conservation.” The same interests at work now succeeded in essentially destroying the San Joaquin River decades ago by constructing the Friant Dam and diverting most of the water south. As a result, a 60 mile stretch of this once mighty river is dry almost all of the time. Having succeeded in greatly reducing the flows from the south through the Delta, the same interests now seek to reduce the flows through the Delta from the Sacramento River in the north by approving and operating the Water Tunnels. The Effects Analysis chapter (chapter 5) of the Draft Plan admits that the new upstream diversion would reduce flows but blames climate change as the most likely culprit for future salmon population extinctions. That chapter also claims that the adverse effects on listed species and habitats would be outweighed by various conservation measures having nothing to do with the Water Tunnels and that are to be paid for by the public rather than the exporters taking the water.
This massive new upstream diversion would include the National Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (USFWS) tying their ESA hands behind their backs for 50 years by way of regulatory assurances and the “No Surprises Rule” included in the Implementing Agreement. The California Department of Fish and Wildlife (CDFA) would likewise give away its powers and responsibilities for the 50 year term of the proposed permit. In the face of admitted declining fish populations caused by water diversions and the admitted worsening future threats caused by climate change, this giveaway by the fishery agencies would be astonishing in its scope and its trampling on the fundamental ESA federal agency obligation “to afford first priority to the declared national policy of saving endangered species.” Tennessee Valley Authority v. Hill, 437 U.S. 153, 185 (1978). This proposed action if carried out would be so contrary to the language and purpose of the ESA as to raise the appearance of impropriety.
A function of ESA § 10 Habitat Conservation Plans is to allow private property owners to make economically viable use of their lands avoiding “Regulatory Takings” issues under the Fifth Amendment of the Constitution. Those issues could arise if such use would be prevented because of prohibitions against adversely affecting critical habitat for endangered species on the land owners’ property. No such issues are present here. The contractors do not own the water in the Sacramento River and the Delta. The water is a public resource. Even the permits for use of the water are held by the Federal and State governments— not the exporters.
The exporters also have nothing to do with proposed mitigation funding; mitigation would be paid for by way of bonds or other public funds. The public, meaning the taxpayers, would pay for the conservation measures as well as for attempting to mitigate adverse effects resulting from the new upstream conveyance with the exception of the project footprint itself. Habitat restoration on the ground is no substitute for taking away designated critical freshwater habitat. Consequently, there is no nexus between either the fish or the contractors and the BDCP mitigation and conservation measures.
Again, calling this a “conservation” plan is a clever trick. New upstream conveyance needs to be treated lawfully for what it really is-- a proposed new diversion project to take massive quantities of freshwater away from the lower Sacramento River, sloughs, and the San Francisco Bay-Delta. New upstream conveyance is not properly or lawfully a “conservation” plan or part of a lawful Habitat Conservation Plan.
Secret BDCP Planning with the Exporters and their Consultants -
There are references throughout the BDCP Drafts including the “Effects Analysis” chapter of the Plan to the meetings with federal agency scientists “during the August 2013 workshops.” (Example, Plan ch. 5, p. 5. 1-32). There have been negotiations and meetings by the agencies with the exporters--the “water takers” -- who have had the seats that count on the inside of the process. Those interests are the “winners” in the BDCP processes. The ignored “water givers”-- the fish, the River, the Delta, Delta and Northern California agriculture, fishing, business, recreation and public interests have been excluded from the inside process.
The federal agencies are apparently trying to cover up issues that should have been resolved before the public Draft BDCP document review period commenced. These issues are instead being secretly planned to be decided in the Final BDCP Plan and EIR/EIS without being aired in new Draft documents and a new public review period. The close of the BDCP comment period in a few days affords time to only mention several examples since the subject documents were just obtained from the federal agencies under the Freedom of Information Act (FOIA). These examples come from something called the “BDCP Federal Open Issues Tracker:”
[begin excerpts]
“OPEN” ISSUES THAT WILL REQUIRE FURTHER REFINEMENTS BETWEEN DRAFT AND FINAL -
1. ISSUES WITH CM 1 OPERATIONS
1. Real Time Operations
a. STATUS: Further work is needed on four issues: . . ; 2) whether the High Outflow Scenario (HOS) draws from Oroville only or whether other COA [Coordinated Operations Agreement] “adjustments” will occur; 3) whether water transfer programs are part of meeting the HOS requirements, and if so, how to address their NEPA/CEQA-related effects; . . .
2. High Outflow Scenario (HOS) and Decision Tree
a. STATUS: At present only the HOS appears to be permissible based upon the best available science. The Services will only authorize operations that meet permit issuance criteria. The State’s proposed project may therefore need to be changed at the time of permit issuance.
b. The Plan needs to more clearly and specifically state the scientific work related to HOS/Decision Tree that will be carried out prior to operations with respect to salmonids.
4 . CVP Upstream Operations.
a. STATUS: Recent refinements to real-time operations state that meeting BDCP exports will require an (unspecified) accounting between the CVP and the State project. This accounting needs to be clarified and agreed upon.
b. This change raises several fundamental issues of project operations and Project impacts and it may trigger additional NEPA/CEQA analyses. This change may also affect the scope and timing of the ESA section 7 consultations associated with the BDCP.
[end excerpts]
These are just a few examples of critical issues that are being dealt with in secret with the project proponents being at the table while the public is relegated to trying to find out what is going on behind closed doors by Freedom of Information Act requests. The Effects Analysis chapter in the Plan represents over and over that the “only” changes in upstream operations will involve Oroville and the Feather River. It turns out that is not the case. Other upstream reservoir operations and upstream reaches of other rivers will also be affected. These critical issues of “adjustments” to other reservoir operations, water transfers, salmon survival questions, and change between the CVP and State project need to be aired openly in a new Draft Plan and Draft EIR/EIS circulated for a new public review and comment period. That is necessary to allow the public to have the opportunity to comment on the actual project as it is and will be as opposed to finding out those critical details after the horse is out of the barn and the public comment period is over.
The Deception and Delusion in the BDCP -
“[A]cross the globe, large infrastructure projects almost invariably arrive late, over-budget and fail to perform up to expectations. Cost overruns and benefit shortfalls of 50% are common; cost overruns above 100% are not uncommon.” Flyvbjerg, Garbuio and Lovallo, Delusion and Deception in Large Infrastructure Projects, 51 California Management Review 170, 171-2 (winter 2009). “The underlying reasons for all forecasting errors can usefully be grouped into three categories: delusions or honest mistakes; deceptions or strategic manipulation of information or processes; or bad luck.” (Id. at 172). [P]oliticians, planners, or project champions deliberately and strategically overestimate benefits and underestimate costs in order to increase the likelihood that their projects, and not their competition’s, gain approval and funding. These actors purposefully spin scenarios of success and gloss over the potential for failure.” (Id. at 173).
Large California infrastructure project proponents are masters of delusion and deception as evidenced by the explosion of the forecasted cost of the new San Francisco-Oakland Bay Bridge span from $1 billion to $6 billion.
Here, the BDCP project proponents are striving to be the all-time champions of carrying out “delusion and deception in large infrastructure projects.” The only true statewide benefit-cost study of the proposed Water Tunnels project conducted so far concluded two years ago that “We find the tunnels are not economically justified because the costs of the tunnels are roughly 2.5 times larger than their benefits.” Eberhardt School of Business, Business Forecasting Center, University of the Pacific, Benefit-Cost Analysis of Delta Water Conveyance Tunnels (July 12, 2012). “The recent recession is a powerful reminder that no amount of financial engineering can change the fundamental economics of an investment from bad to good.” (Id. at 13).” [I]t is clear that the Delta water conveyance tunnels proposed in the draft BDCP are not justified on an economic or financial basis.” (Id.). This helps explain the absence of information in the Draft Implementing Agreement about who is going to pay for what as well as the ongoing efforts of the exporters to quietly shift as many of the billions of dollars of costs as possible to taxpayers and to urban and suburban ratepayers.
Again, the deliberate omission of any alternative reducing exports and not including new upstream conveyance, coupled with the refusal to post correspondence and comments on the BDCP website, aids and abets the deception of the public with respect to the environmental, economic, and financial risks and drawbacks of the Water Tunnels.
Finally, what could be more deceptive or delusional than falsely claiming or actually believing that taking more water away from the fish and their habitats will be good for them and is “conservation?”
The Adaptive Management and Decision Tree Bad Jokes on the Public -
Over and over again throughout the Draft Plan, Draft EIR/EIS and Draft Implementing Agreement adaptive management and the decision tree are referred to as the future procedures that will save the fish from all of the claimed “uncertainties” in the BDCP. If the exporters have the money, political power and influence to get the controversial Water Tunnels approved now, that would evidence the worthlessness of adaptive management and the “decision tree” in the future. Now, the billions of dollars to build the Water Tunnels have not been spent. After that investment is made and the Water Tunnels have been constructed and are ready for operation adaptive management and the decision tree will be puppets dancing to the tunes played by the exporters. The exporters would then have an additional argument for their lobbyists and lawyers to make-- that the exporters invested billions of dollars in the development of the Water Tunnels and cannot equitably be stopped from filling them with water. The same powerful interests that succeeded in destroying the once mighty San Joaquin River will not hesitate to turn the Delta into a salty, polluted, stagnant pond.
The exporters have already had sufficient control over the BDCP agencies to prevent the development and consideration of a BDCP reduced exports no new conveyance alternative. The exporters have had sufficient control over the BDCP agencies to exclude public comments and correspondence from the BDCP website. Given that successful track record of power and domination over the BDCP agencies, the so-called adaptive management and the decision tree will be no safeguards at all against the extirpation of listed fish species and the destruction of the Delta.
Corrective Actions -
The BDCP agencies will eventually have the opportunity, should they choose to steam full speed ahead in the face of red flags flying, to convince the courts that they proceeded in the manner required by NEPA, CEQA and the ESA. That is, the agencies can try to convince the courts that they really did not have to develop and consider a range of reasonable alternatives reducing exports; it was okay to suppress public comments and correspondence from the BDCP website; it was okay to misrepresent a new water diversion as a “conservation” plan; and it is okay to make significant changes or “adjustments” in proposed project operations without disclosing and assessing those changes and adjustments in a new Draft Plan and Draft EIR/EIS.
The BDCP agencies have the opportunity to instead take a different path. That is, the agencies can present a range of reasonable alternatives reducing exports in a new Draft Plan, Draft EIR/EIS and Draft Implementing Agreement. The agencies can welcome instead of ban public comment and correspondence on the BDCP website during a new public review period on new draft BDCP documents. The agencies can take the proposed new conveyance out of the Habitat Conservation Plan and deal with any such proposal in the normal, lawful project review process. The agencies can make sure that significant changes or “adjustments” in proposed project operations are disclosed in Draft environmental documents out for public review periods rather than attempting to unlawfully insert them in Final NEPA and CEQA documents to evade public review and comment. And there is so much more the agencies can, indeed must, do to represent the public as opposed to only representing the water takers. The agencies can require ESA consultations and California public trust doctrine analysis to take place before rather than after the BDCP Draft NEPA and CEQA processes so that the public can actually be informed by the work of agency scientists as opposed to attempting to wade through thousands of pages of financially-interested project proponent advocacy. The agencies can either finally admit that the costs of the Water Tunnels would be 2.5 times larger than the benefits or require their own statewide benefit-cost study to be performed comparing the Water Tunnels with reduced export alternatives.
CONCLUSION -
The fish and the Delta are in peril. Extinction is forever. The 40,000 pages of BDCP project proponent advocacy are unworthy of the epic decisions to be made guiding the future of the fish, northern California Rivers, and the Delta. If this is not worth the environmental full disclosure required by law and the NEPA, CEQA and ESA required do-over, what is?
The BDCP Draft EIR/EIS alternatives chapter and "Draft Plan alternatives-to-take" chapter fail to include any real alternatives, let alone the required range of reasonable alternatives to the BDCP Water Tunnels water conveyance system upstream from the already imperiled San Francisco Bay-Delta. The Water Tunnels would divert enormous quantities of water from the Sacramento River near Clarksburg, California. As a result of this massive diversion, enormous quantities of water that presently flow through designated critical habitats in the Sacramento River and sloughs to and through the Bay-Delta would not reach the Delta. Flows would be reduced in the Sacramento River, sloughs and Delta to the detriment of listed and other fish species. All of the so-called project alternatives set forth in the Draft Plan and Draft EIR/EIS are simply different versions of the same project. They all create a capacity to divert more water by way of new conveyance upstream from the Delta. And they do so in the face of the ESA Section 7 command prohibiting federal agency actions that “result in the destruction or adverse modification of [critical] habitat of [listed] species.”
The failure of the BDCP Drafts to include so much as one alternative reducing exports seems at first blush astonishing. After all, a claimed purpose of the BDCP Plan is “Reducing the adverse effects on certain listed [fish] species due to diverting water.” (BDCP Draft EIR/EIS Executive Summary, p. ES-10). As the National Academy of Sciences warned back in May 2011-- in commenting on an earlier version of the BDCP Plan-- “Scientific reasons for not considering alternative actions are not presented in the plan.” (Report in Brief, p. 2, May 5, 2011). More than two years ago, the Environmental Water Caucus (EWC) (a coalition of over 30 organizations including Friends of the River) pointed out to the California Resources Agency Deputy Secretary:
The absence of a full range of alternatives, including an alternative which would reduce exports from the Delta. It is understandable that the exporters, who are driving the [BDCP] project, are not interested in this kind of alternative; however, in order to be a truly permissible project, an examination of a full range of alternatives, including ones that would reduce exports, needs to be included and needs to incorporate a public trust balancing of alternatives.
There has been a complete failure to develop and evaluate alternatives reducing diversions/exports including the EWC Reduced Exports Plan transmitted to the California Resources Agency in December 2012 as well as the more detailed Responsible Exports Plan developed in May 2013.
In fact, this BDCP process ignoring and concealing obvious and direct alternatives that would reduce the “adverse effects on certain [listed] fish species due to diverting water” is not astonishing. It is a deliberate, bad faith, end run on the alternatives analysis requirements of NEPA, CEQA, and the ESA. The exporters have money, lobbyists and power. They are driving the project. They do not want the public including environmental organizations, Indian tribes, Northern California, and San Francisco Bay-Delta interests to have a BDCP alternative that they could support. This concealment and silencing of any alternatives that would reduce exports as opposed to all of the current BDCP alternatives that increase the capacity for exports is calculated to increase the likelihood of the BDCP proponents getting what they want. This bad faith omission of alternatives reducing exports skews the debate in favor of new conveyance and against reducing exports since no other alternatives are presented.
The current BDCP Draft’s omission of the range of reasonable alternatives required by law requires the preparation of a new Draft Plan and Draft EIR/EIS and a new public review period to attempt to cure this fatal flaw.
The Deliberate BDCP Website Suppression of Comments -
After the 40,000 pages of BDCP project advocacy called the Draft Plan and Draft EIR/EIS were released in December 2013 for public review and comment, the BDCP website was closed to the posting of comments and correspondence from the public. Consequently, an organization or individual attempting to wade through the 40,000 pages of self-interested project advocacy to spot the issues and figure out the truth is unable to learn from the comments and correspondence from other organizations and individuals who are not project proponents. The public’s ability to be informed regarding this project including cons as well as claimed pros would have been facilitated by having access to comments and correspondence made by others during the review process. Instead, the BDCP agencies have done their very best to keep the public in the dark about issues spotted by those who are not project proponents.
This blinding of the public to critical environmental information even extends to comments by sister agencies. Here are just a few of the many possible examples of comments from public agencies that the citizen using the BDCP website does not get to see. “The BDCP is based upon this misrepresentation: that a massive new twin tunnel system, which would greatly reduce the natural flow of water through the Delta, qualifies as a ‘conservation’ project to restore the Delta ecosystem and protect species already verging on extinction.” (County of San Joaquin comments, p. 1, July 9, 2014). Another example is: “Chapter 8 of the current BDCP does not provide the detailed information necessary for potential participating agencies to evaluate individual agency cost-benefit (or feasibility) of the proposed project.” (San Diego County Water Authority, p. 2, June 2, 2014). There is the June 24, 2014, comment letter from the Delta Stewardship Council. The public trying to understand the project is not informed that the State agency responsible for ultimately determining whether the BDCP is consistent with the Delta Plan has found that the BDCP EIR: should “Identify the water available for export and other beneficial uses under alternative flow criteria considered in the draft EIR/S” (Letter p. 1), “The benefits of tidal marsh restoration to Delta smelt are likely overstated” (p. 2), “Water quality impacts are compared to SWRCB water quality objectives with little regard to specific water quality needs of aquatic species of concern” (Id.), “San Francisco Bay should be included in the scope of the analysis, especially for water quality” (p. 12), and so forth.
This is a double attack on the truth and on informed public review of the proposed project. The BDCP agencies have refused, as shown above, to identify, develop, or consider in the Draft Plan and Draft EIR/EIS any alternatives that would reduce exports. At the same time, the agencies have also shut down the BDCP website to the posting of public comments and correspondence to prevent independent organizations and individuals from informing the public about alternatives and critical information that the exporters do not want the public to see.
The government agencies would not be blinding themselves and the public to alternatives reducing exports while at the same time eliminating public comment and correspondence from the BDCP website if the agencies actually believed the BDCP proponents’ claims about the asserted benefits of the project. The silencing of comments on the BDCP website is powerful evidence that the BDCP proponents are afraid of the facts and the truth.
Friends of the River objects to approval of the BDCP and is in favor of reducing exports. That said, Friends of the River also believes in the American tradition of democracy and informed, indeed spirited, public debate of important and controversial issues. Because of that, we have been seeking and obtaining copies of BDCP comment letters under the Freedom of Information Act beginning in February 2014 and posting them on our website at www.friendsoftheriver.org/bdcpcomments . We have been posting all comment letters we have obtained regardless of whether the particular comments oppose or favor the Water Tunnels. The government agencies should be doing what we have been forced to do. That is the American way.
Misrepresenting Taking Water to be a “Conservation” Plan -
The only difference between the BDCP and this same Governor’s “peripheral canal” that was rejected by a 2-1 statewide referendum vote in June 1982 is that the project proponents, their lobbyists, their lawyers, and their supporters inside the government have come up with the clever trick of calling this a “conservation” plan. That trick is Orwellian. War is not “peace,” lies are not “truth,” and a new water diversion is not “conservation.” The same interests at work now succeeded in essentially destroying the San Joaquin River decades ago by constructing the Friant Dam and diverting most of the water south. As a result, a 60 mile stretch of this once mighty river is dry almost all of the time. Having succeeded in greatly reducing the flows from the south through the Delta, the same interests now seek to reduce the flows through the Delta from the Sacramento River in the north by approving and operating the Water Tunnels. The Effects Analysis chapter (chapter 5) of the Draft Plan admits that the new upstream diversion would reduce flows but blames climate change as the most likely culprit for future salmon population extinctions. That chapter also claims that the adverse effects on listed species and habitats would be outweighed by various conservation measures having nothing to do with the Water Tunnels and that are to be paid for by the public rather than the exporters taking the water.
This massive new upstream diversion would include the National Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (USFWS) tying their ESA hands behind their backs for 50 years by way of regulatory assurances and the “No Surprises Rule” included in the Implementing Agreement. The California Department of Fish and Wildlife (CDFA) would likewise give away its powers and responsibilities for the 50 year term of the proposed permit. In the face of admitted declining fish populations caused by water diversions and the admitted worsening future threats caused by climate change, this giveaway by the fishery agencies would be astonishing in its scope and its trampling on the fundamental ESA federal agency obligation “to afford first priority to the declared national policy of saving endangered species.” Tennessee Valley Authority v. Hill, 437 U.S. 153, 185 (1978). This proposed action if carried out would be so contrary to the language and purpose of the ESA as to raise the appearance of impropriety.
A function of ESA § 10 Habitat Conservation Plans is to allow private property owners to make economically viable use of their lands avoiding “Regulatory Takings” issues under the Fifth Amendment of the Constitution. Those issues could arise if such use would be prevented because of prohibitions against adversely affecting critical habitat for endangered species on the land owners’ property. No such issues are present here. The contractors do not own the water in the Sacramento River and the Delta. The water is a public resource. Even the permits for use of the water are held by the Federal and State governments— not the exporters.
The exporters also have nothing to do with proposed mitigation funding; mitigation would be paid for by way of bonds or other public funds. The public, meaning the taxpayers, would pay for the conservation measures as well as for attempting to mitigate adverse effects resulting from the new upstream conveyance with the exception of the project footprint itself. Habitat restoration on the ground is no substitute for taking away designated critical freshwater habitat. Consequently, there is no nexus between either the fish or the contractors and the BDCP mitigation and conservation measures.
Again, calling this a “conservation” plan is a clever trick. New upstream conveyance needs to be treated lawfully for what it really is-- a proposed new diversion project to take massive quantities of freshwater away from the lower Sacramento River, sloughs, and the San Francisco Bay-Delta. New upstream conveyance is not properly or lawfully a “conservation” plan or part of a lawful Habitat Conservation Plan.
Secret BDCP Planning with the Exporters and their Consultants -
There are references throughout the BDCP Drafts including the “Effects Analysis” chapter of the Plan to the meetings with federal agency scientists “during the August 2013 workshops.” (Example, Plan ch. 5, p. 5. 1-32). There have been negotiations and meetings by the agencies with the exporters--the “water takers” -- who have had the seats that count on the inside of the process. Those interests are the “winners” in the BDCP processes. The ignored “water givers”-- the fish, the River, the Delta, Delta and Northern California agriculture, fishing, business, recreation and public interests have been excluded from the inside process.
The federal agencies are apparently trying to cover up issues that should have been resolved before the public Draft BDCP document review period commenced. These issues are instead being secretly planned to be decided in the Final BDCP Plan and EIR/EIS without being aired in new Draft documents and a new public review period. The close of the BDCP comment period in a few days affords time to only mention several examples since the subject documents were just obtained from the federal agencies under the Freedom of Information Act (FOIA). These examples come from something called the “BDCP Federal Open Issues Tracker:”
[begin excerpts]
“OPEN” ISSUES THAT WILL REQUIRE FURTHER REFINEMENTS BETWEEN DRAFT AND FINAL -
1. ISSUES WITH CM 1 OPERATIONS
1. Real Time Operations
a. STATUS: Further work is needed on four issues: . . ; 2) whether the High Outflow Scenario (HOS) draws from Oroville only or whether other COA [Coordinated Operations Agreement] “adjustments” will occur; 3) whether water transfer programs are part of meeting the HOS requirements, and if so, how to address their NEPA/CEQA-related effects; . . .
2. High Outflow Scenario (HOS) and Decision Tree
a. STATUS: At present only the HOS appears to be permissible based upon the best available science. The Services will only authorize operations that meet permit issuance criteria. The State’s proposed project may therefore need to be changed at the time of permit issuance.
b. The Plan needs to more clearly and specifically state the scientific work related to HOS/Decision Tree that will be carried out prior to operations with respect to salmonids.
4 . CVP Upstream Operations.
a. STATUS: Recent refinements to real-time operations state that meeting BDCP exports will require an (unspecified) accounting between the CVP and the State project. This accounting needs to be clarified and agreed upon.
b. This change raises several fundamental issues of project operations and Project impacts and it may trigger additional NEPA/CEQA analyses. This change may also affect the scope and timing of the ESA section 7 consultations associated with the BDCP.
[end excerpts]
These are just a few examples of critical issues that are being dealt with in secret with the project proponents being at the table while the public is relegated to trying to find out what is going on behind closed doors by Freedom of Information Act requests. The Effects Analysis chapter in the Plan represents over and over that the “only” changes in upstream operations will involve Oroville and the Feather River. It turns out that is not the case. Other upstream reservoir operations and upstream reaches of other rivers will also be affected. These critical issues of “adjustments” to other reservoir operations, water transfers, salmon survival questions, and change between the CVP and State project need to be aired openly in a new Draft Plan and Draft EIR/EIS circulated for a new public review and comment period. That is necessary to allow the public to have the opportunity to comment on the actual project as it is and will be as opposed to finding out those critical details after the horse is out of the barn and the public comment period is over.
The Deception and Delusion in the BDCP -
“[A]cross the globe, large infrastructure projects almost invariably arrive late, over-budget and fail to perform up to expectations. Cost overruns and benefit shortfalls of 50% are common; cost overruns above 100% are not uncommon.” Flyvbjerg, Garbuio and Lovallo, Delusion and Deception in Large Infrastructure Projects, 51 California Management Review 170, 171-2 (winter 2009). “The underlying reasons for all forecasting errors can usefully be grouped into three categories: delusions or honest mistakes; deceptions or strategic manipulation of information or processes; or bad luck.” (Id. at 172). [P]oliticians, planners, or project champions deliberately and strategically overestimate benefits and underestimate costs in order to increase the likelihood that their projects, and not their competition’s, gain approval and funding. These actors purposefully spin scenarios of success and gloss over the potential for failure.” (Id. at 173).
Large California infrastructure project proponents are masters of delusion and deception as evidenced by the explosion of the forecasted cost of the new San Francisco-Oakland Bay Bridge span from $1 billion to $6 billion.
Here, the BDCP project proponents are striving to be the all-time champions of carrying out “delusion and deception in large infrastructure projects.” The only true statewide benefit-cost study of the proposed Water Tunnels project conducted so far concluded two years ago that “We find the tunnels are not economically justified because the costs of the tunnels are roughly 2.5 times larger than their benefits.” Eberhardt School of Business, Business Forecasting Center, University of the Pacific, Benefit-Cost Analysis of Delta Water Conveyance Tunnels (July 12, 2012). “The recent recession is a powerful reminder that no amount of financial engineering can change the fundamental economics of an investment from bad to good.” (Id. at 13).” [I]t is clear that the Delta water conveyance tunnels proposed in the draft BDCP are not justified on an economic or financial basis.” (Id.). This helps explain the absence of information in the Draft Implementing Agreement about who is going to pay for what as well as the ongoing efforts of the exporters to quietly shift as many of the billions of dollars of costs as possible to taxpayers and to urban and suburban ratepayers.
Again, the deliberate omission of any alternative reducing exports and not including new upstream conveyance, coupled with the refusal to post correspondence and comments on the BDCP website, aids and abets the deception of the public with respect to the environmental, economic, and financial risks and drawbacks of the Water Tunnels.
Finally, what could be more deceptive or delusional than falsely claiming or actually believing that taking more water away from the fish and their habitats will be good for them and is “conservation?”
The Adaptive Management and Decision Tree Bad Jokes on the Public -
Over and over again throughout the Draft Plan, Draft EIR/EIS and Draft Implementing Agreement adaptive management and the decision tree are referred to as the future procedures that will save the fish from all of the claimed “uncertainties” in the BDCP. If the exporters have the money, political power and influence to get the controversial Water Tunnels approved now, that would evidence the worthlessness of adaptive management and the “decision tree” in the future. Now, the billions of dollars to build the Water Tunnels have not been spent. After that investment is made and the Water Tunnels have been constructed and are ready for operation adaptive management and the decision tree will be puppets dancing to the tunes played by the exporters. The exporters would then have an additional argument for their lobbyists and lawyers to make-- that the exporters invested billions of dollars in the development of the Water Tunnels and cannot equitably be stopped from filling them with water. The same powerful interests that succeeded in destroying the once mighty San Joaquin River will not hesitate to turn the Delta into a salty, polluted, stagnant pond.
The exporters have already had sufficient control over the BDCP agencies to prevent the development and consideration of a BDCP reduced exports no new conveyance alternative. The exporters have had sufficient control over the BDCP agencies to exclude public comments and correspondence from the BDCP website. Given that successful track record of power and domination over the BDCP agencies, the so-called adaptive management and the decision tree will be no safeguards at all against the extirpation of listed fish species and the destruction of the Delta.
Corrective Actions -
The BDCP agencies will eventually have the opportunity, should they choose to steam full speed ahead in the face of red flags flying, to convince the courts that they proceeded in the manner required by NEPA, CEQA and the ESA. That is, the agencies can try to convince the courts that they really did not have to develop and consider a range of reasonable alternatives reducing exports; it was okay to suppress public comments and correspondence from the BDCP website; it was okay to misrepresent a new water diversion as a “conservation” plan; and it is okay to make significant changes or “adjustments” in proposed project operations without disclosing and assessing those changes and adjustments in a new Draft Plan and Draft EIR/EIS.
The BDCP agencies have the opportunity to instead take a different path. That is, the agencies can present a range of reasonable alternatives reducing exports in a new Draft Plan, Draft EIR/EIS and Draft Implementing Agreement. The agencies can welcome instead of ban public comment and correspondence on the BDCP website during a new public review period on new draft BDCP documents. The agencies can take the proposed new conveyance out of the Habitat Conservation Plan and deal with any such proposal in the normal, lawful project review process. The agencies can make sure that significant changes or “adjustments” in proposed project operations are disclosed in Draft environmental documents out for public review periods rather than attempting to unlawfully insert them in Final NEPA and CEQA documents to evade public review and comment. And there is so much more the agencies can, indeed must, do to represent the public as opposed to only representing the water takers. The agencies can require ESA consultations and California public trust doctrine analysis to take place before rather than after the BDCP Draft NEPA and CEQA processes so that the public can actually be informed by the work of agency scientists as opposed to attempting to wade through thousands of pages of financially-interested project proponent advocacy. The agencies can either finally admit that the costs of the Water Tunnels would be 2.5 times larger than the benefits or require their own statewide benefit-cost study to be performed comparing the Water Tunnels with reduced export alternatives.
CONCLUSION -
The fish and the Delta are in peril. Extinction is forever. The 40,000 pages of BDCP project proponent advocacy are unworthy of the epic decisions to be made guiding the future of the fish, northern California Rivers, and the Delta. If this is not worth the environmental full disclosure required by law and the NEPA, CEQA and ESA required do-over, what is?
Friday, July 25, 2014
Monopolists in Agriculture say NO to responsible groundwater management, and YES to tax-funded dam building
"Does anybody check the numbers?"
2014-07-25 from "River Currents" column by Ron Sorok:
A few weeks back, I got a call from a local TV news station asking me to comment on a state Farm Bureau news release. It was a curious press release. In a nutshell, it blasted the state for even considering groundwater management legislation. Instead, we were told that we just needed to build more dams.
Well, it certainly is understandable that the Farm Bureau has some intense feelings about this. After all, most of the groundwater mining in California is done by agriculture. Groundwater management, ideally, tries to make groundwater use sustainable---and in the long run using more groundwater than is being recharged is not sustainable.
But even more important was the implication of the press release that if we only could build more dams we would not have to worry about keeping groundwater use sustainable.
Well, the USGS reports that 150 cubic kilometers of water have been evacuated from California’s groundwater basins over the past 160 years. In California’s San Joaquin Valley alone, the long-term groundwater overdraft is 2-million acre-feet per year and accelerating in California’s unregulated environment. The USGS thinks it might be twice that number.
We’ve also got some agency numbers about the yield (“new” water developed) from all the new or expanded dams that Congress might authorize and might be funded in the upcoming multibillion dollar water bond: it amounts to only 10% of the USGS San Joaquin Valley groundwater-overdraft estimate and 1% of the existing water use in the state.
A 10% groundwater solution for just one region in California. And who in their right mind thinks that this overdrafting farming region will get a significant share of the water from these proposed deadbeat dams costing almost 9 billion dollars. Your guess is right, not much under the beneficiary-pays principle.
And to put the costs into perspective, the Federal Central Valley Project delivers about eight million acre-feet of water in a typical year. Farmers, a few cities, and a few power users are still paying for this project. What do they still owe? About two-billion dollars. And they complain about their water and power bills now.
So somebody over at the Farm Bureau can’t do math very well.
Of course some of our state and national leaders can’t do math well either. The math challenged just might think that we can avoid responsible use of the state’s groundwater---its best drought reserve---by building more expensive, low-yield dams on California rivers. But we shouldn’t let them do it. The numbers don’t lie.
And rivers matter too.
2014-07-25 from "River Currents" column by Ron Sorok:
A few weeks back, I got a call from a local TV news station asking me to comment on a state Farm Bureau news release. It was a curious press release. In a nutshell, it blasted the state for even considering groundwater management legislation. Instead, we were told that we just needed to build more dams.
Well, it certainly is understandable that the Farm Bureau has some intense feelings about this. After all, most of the groundwater mining in California is done by agriculture. Groundwater management, ideally, tries to make groundwater use sustainable---and in the long run using more groundwater than is being recharged is not sustainable.
But even more important was the implication of the press release that if we only could build more dams we would not have to worry about keeping groundwater use sustainable.
Well, the USGS reports that 150 cubic kilometers of water have been evacuated from California’s groundwater basins over the past 160 years. In California’s San Joaquin Valley alone, the long-term groundwater overdraft is 2-million acre-feet per year and accelerating in California’s unregulated environment. The USGS thinks it might be twice that number.
We’ve also got some agency numbers about the yield (“new” water developed) from all the new or expanded dams that Congress might authorize and might be funded in the upcoming multibillion dollar water bond: it amounts to only 10% of the USGS San Joaquin Valley groundwater-overdraft estimate and 1% of the existing water use in the state.
A 10% groundwater solution for just one region in California. And who in their right mind thinks that this overdrafting farming region will get a significant share of the water from these proposed deadbeat dams costing almost 9 billion dollars. Your guess is right, not much under the beneficiary-pays principle.
And to put the costs into perspective, the Federal Central Valley Project delivers about eight million acre-feet of water in a typical year. Farmers, a few cities, and a few power users are still paying for this project. What do they still owe? About two-billion dollars. And they complain about their water and power bills now.
So somebody over at the Farm Bureau can’t do math very well.
Of course some of our state and national leaders can’t do math well either. The math challenged just might think that we can avoid responsible use of the state’s groundwater---its best drought reserve---by building more expensive, low-yield dams on California rivers. But we shouldn’t let them do it. The numbers don’t lie.
And rivers matter too.
Saturday, July 19, 2014
Atrazine pesticide
Alarming new Atrazine data
by Kerry Kriger, Ph.D., Founder, Executive Director, Ecologist with "Save The Frogs" [www.savethefrogs.com/kerry-kriger]
Banned in the European Union since 2004, Atrazine is the most commonly detected pesticide in America's rainwater, tapwater and groundwater. Produced by Switzerland-based Syngenta (the world's largest pesticide company), Atrazine is a known endocrine disruptor that can turn male frogs into females at concentrations as low as 3 parts per billion. If you live in America, you are drinking and eating Atrazine. And if you think your government is working hard to protect you from Atrazine, you are wrong!
2013 EPA data shows Atrazine levels above legal limits in 25% of US water samples -
The US Environmental Protection Agency recently released their 2013 Atrazine Ecological Exposure Monitoring Program data. The data is extremely alarming: over 25% of the 938 water samples contained over 3 parts per billion and the concentrations went as high as 193 parts per billion: over 60 times the legally acceptable limit. These measurements came from water bodies in five states (MO, IA, TX, LA, NE). Atrazine has now been shown to satisfy the EPA's requirements for revoking a pesticide's registration: (1) it has well-documented harmful effects on a wide variety of organisms; (2) it is regularly found in ecosystems and tap water sources at harmful concentrations; and (3) banning Atrazine is unlikely to cause major economic problems for the American economy, just as its ban has not caused problems in Europe. The EPA's mission is to protect human health and the environment, and the EPA now has the necessary data - and thus the obligation - to revoke Atrazine's registration.
Hundreds of millions more pounds of Atrazine will be dumped onto American soil, minimum!
Earlier this year I had a phone meeting with two of the highest officials in the US Environmental Protection Agency: Jim Jones (Assistant Administrator for the Office of Chemical Safety and Pollution Prevention) and Dr. Steven Bradbury (Director of the Office of Pesticide Programs). I asked them what the EPA is doing about the 80 million pounds of Atrazine that get sprayed on America's soil each year, contaminating our food and water. They informed me that the EPA is expected to release a draft assessment of Atrazine in early 2015. This will go up for public comment and a final decision regarding Atrazine's legality will be made in 2016. Even if the EPA decides to cancel Atrazine's registration, it would still be years before it is taken off the market. That means that the EPA's current best case scenario is to allow hundreds of millions more pounds of Atrazine to be dumped onto American soil. I asked Jim Jones if he has the power to ban Atrazine with his signature, to which he replied that he does. I then asked him if he would please ban Atrazine. He said that he was not prepared to do that.
"The US should be the precedent and leader in scientific advancement and ecological protection, not an embarrassment of capitalism-driven destruction. Banning Atrazine will be a step in the right direction."
-- Excerpt of a letter to the USEPA from the students of Troy High School in Fullerton, California.
The EPA's Administrator Gina McCarthy has never been briefed on Atrazine -
Administrator Gina McCarthy took over the EPA in July 2013. I asked Assistant Administrator Jim Jones if she has ever been briefed on Atrazine. Mr. Jones reports directly to the Administrator and is in charge of everything related to pollution and pesticides, and thus he would know if she has been briefed on Atrazine, as it is his job to do the briefing. He informed me that Administrator McCarthy has never been briefed on Atrazine! That means that the highest ranking US government official tasked to protect America's people and wildlife from environmental threats may be completely unaware that Atrazine even exists, let alone that it causes reproductive problems for every vertebrate group on which it has been tested! You can personally brief Administrator McCarthy by calling her at 202-564-4700.
The EPA has disregarded the results of 74 of the 75 published atrazine studies that have been conducted on amphibians -
The EPA has assessed 75 published scientific papers on the effects of Atrazine, but they have disregarded the results of every single study other than a single study. The one study they have deemed worthy of use (Kloas et al. 2009) was funded by Syngenta, the manufacturer of Atrazine. The EPA's rationale for doing this was that they created a list of 17 criteria that every study must live up to; if a study did not meet all 17 criteria, its results were thrown out. Thus the EPA effectively deems all 74 scientific teams to be flawed, as well as all the peer reviewers, the editors and the journals that published the studies. Yet the EPA has provided no funding for new research and is not conducting its own research. This is in direct contradiction to President Obama's 2011 Executive Order: "By the authority vested in me as President by the Constitution and the laws of the United States of America, and in order to improve regulation and regulatory review, it is hereby ordered as follows: our regulatory system must protect public health, welfare, safety, and our environment while promoting economic growth, innovation, competitiveness, and job creation. It must be based on the best available science. It must allow for public participation and an open exchange of ideas." -- President Barack Obama, Executive Order 13563 (Improving Regulation and Regulatory Review), January 18th, 2011
by Kerry Kriger, Ph.D., Founder, Executive Director, Ecologist with "Save The Frogs" [www.savethefrogs.com/kerry-kriger]
Banned in the European Union since 2004, Atrazine is the most commonly detected pesticide in America's rainwater, tapwater and groundwater. Produced by Switzerland-based Syngenta (the world's largest pesticide company), Atrazine is a known endocrine disruptor that can turn male frogs into females at concentrations as low as 3 parts per billion. If you live in America, you are drinking and eating Atrazine. And if you think your government is working hard to protect you from Atrazine, you are wrong!
2013 EPA data shows Atrazine levels above legal limits in 25% of US water samples -
The US Environmental Protection Agency recently released their 2013 Atrazine Ecological Exposure Monitoring Program data. The data is extremely alarming: over 25% of the 938 water samples contained over 3 parts per billion and the concentrations went as high as 193 parts per billion: over 60 times the legally acceptable limit. These measurements came from water bodies in five states (MO, IA, TX, LA, NE). Atrazine has now been shown to satisfy the EPA's requirements for revoking a pesticide's registration: (1) it has well-documented harmful effects on a wide variety of organisms; (2) it is regularly found in ecosystems and tap water sources at harmful concentrations; and (3) banning Atrazine is unlikely to cause major economic problems for the American economy, just as its ban has not caused problems in Europe. The EPA's mission is to protect human health and the environment, and the EPA now has the necessary data - and thus the obligation - to revoke Atrazine's registration.
Hundreds of millions more pounds of Atrazine will be dumped onto American soil, minimum!
Earlier this year I had a phone meeting with two of the highest officials in the US Environmental Protection Agency: Jim Jones (Assistant Administrator for the Office of Chemical Safety and Pollution Prevention) and Dr. Steven Bradbury (Director of the Office of Pesticide Programs). I asked them what the EPA is doing about the 80 million pounds of Atrazine that get sprayed on America's soil each year, contaminating our food and water. They informed me that the EPA is expected to release a draft assessment of Atrazine in early 2015. This will go up for public comment and a final decision regarding Atrazine's legality will be made in 2016. Even if the EPA decides to cancel Atrazine's registration, it would still be years before it is taken off the market. That means that the EPA's current best case scenario is to allow hundreds of millions more pounds of Atrazine to be dumped onto American soil. I asked Jim Jones if he has the power to ban Atrazine with his signature, to which he replied that he does. I then asked him if he would please ban Atrazine. He said that he was not prepared to do that.
"The US should be the precedent and leader in scientific advancement and ecological protection, not an embarrassment of capitalism-driven destruction. Banning Atrazine will be a step in the right direction."
-- Excerpt of a letter to the USEPA from the students of Troy High School in Fullerton, California.
The EPA's Administrator Gina McCarthy has never been briefed on Atrazine -
Administrator Gina McCarthy took over the EPA in July 2013. I asked Assistant Administrator Jim Jones if she has ever been briefed on Atrazine. Mr. Jones reports directly to the Administrator and is in charge of everything related to pollution and pesticides, and thus he would know if she has been briefed on Atrazine, as it is his job to do the briefing. He informed me that Administrator McCarthy has never been briefed on Atrazine! That means that the highest ranking US government official tasked to protect America's people and wildlife from environmental threats may be completely unaware that Atrazine even exists, let alone that it causes reproductive problems for every vertebrate group on which it has been tested! You can personally brief Administrator McCarthy by calling her at 202-564-4700.
The EPA has disregarded the results of 74 of the 75 published atrazine studies that have been conducted on amphibians -
The EPA has assessed 75 published scientific papers on the effects of Atrazine, but they have disregarded the results of every single study other than a single study. The one study they have deemed worthy of use (Kloas et al. 2009) was funded by Syngenta, the manufacturer of Atrazine. The EPA's rationale for doing this was that they created a list of 17 criteria that every study must live up to; if a study did not meet all 17 criteria, its results were thrown out. Thus the EPA effectively deems all 74 scientific teams to be flawed, as well as all the peer reviewers, the editors and the journals that published the studies. Yet the EPA has provided no funding for new research and is not conducting its own research. This is in direct contradiction to President Obama's 2011 Executive Order: "By the authority vested in me as President by the Constitution and the laws of the United States of America, and in order to improve regulation and regulatory review, it is hereby ordered as follows: our regulatory system must protect public health, welfare, safety, and our environment while promoting economic growth, innovation, competitiveness, and job creation. It must be based on the best available science. It must allow for public participation and an open exchange of ideas." -- President Barack Obama, Executive Order 13563 (Improving Regulation and Regulatory Review), January 18th, 2011
Wednesday, July 16, 2014
Potrero Hills Landfill attempts to mitigate damage to salamander habitat
"Potrero Hills Landfill makes a place for salamanders"
2014-07-16 by Melissa Murphy, photos by Greg Trott, for the "The Reporter" daily newspaper [http://www.thereporter.com/ci_23668214/potrero-hills-landfill-makes-place-salamanders]:
Crews move dirt on property owned by Potrero Hills Landfill in preparation for a new wetlands site designed to help protect salamanders.
While Potrero Hills Landfill in Suisun City waits to move forward on an expansion, it's in the process of creating new wetlands and a new home for the tiger salamander.
The landfill was in the midst of expanding to 167 acres before Solano County Presiding Judge Paul Beeman ruled that the Bay Conservation and Development Commission (BCDC) should vacate its approval of a marsh development permit for the project because he said proponents of the expansion had failed to prove that a reduced size project alternative is economically infeasible.
However, regardless of that particular ruling, the landfill can move forward with mitigation measures in order to be ready for construction when officials are allowed to expand, explained Jim Dunbar, district manager at Potrero Hills.
A California salamander. The creatures are the target of a project by Potrero Hills Landfill to create new wetlands.
The five new habitats for the tiger salamander, a protected species in California, consist of wetlands and ponds on property the landfill already owns.
Construction crews were busy at work Friday morning creating a half an acre pond that will be 5 to 7 feet deep for the tiger salamander. Crews are in crunch time to finish before August.
"This is a necessary activity to maintain our business," Dunbar said. "Land restoration is part of our business and we're building something that will last for decades."
He said the marsh land that sits between the landfill and Travis Air Force Base won't be developed.
"Might as well get use out of it the best way we can," he said. "This is an ecologically sensitive and productive place.
Having the marsh flourish is not a bad thing."
The dirt dug from the ground to create the ponds will be used as daily cover at the landfill.
Biologists are in the process of creature capture, to watch the population of the tiger salamander and to relocate them when the times comes, which is likely during the next rainy season. Once they're relocated, they'll continue to be monitored for 10 years.
"We'll see if the tiger salamander likes his new home," Dunbar said.
Jim Dunbar, a manager at Potrero Hills Landfill shows off a crude trap used to capture salamanders.
2014-07-16 by Melissa Murphy, photos by Greg Trott, for the "The Reporter" daily newspaper [http://www.thereporter.com/ci_23668214/potrero-hills-landfill-makes-place-salamanders]:
Crews move dirt on property owned by Potrero Hills Landfill in preparation for a new wetlands site designed to help protect salamanders.
While Potrero Hills Landfill in Suisun City waits to move forward on an expansion, it's in the process of creating new wetlands and a new home for the tiger salamander.
The landfill was in the midst of expanding to 167 acres before Solano County Presiding Judge Paul Beeman ruled that the Bay Conservation and Development Commission (BCDC) should vacate its approval of a marsh development permit for the project because he said proponents of the expansion had failed to prove that a reduced size project alternative is economically infeasible.
However, regardless of that particular ruling, the landfill can move forward with mitigation measures in order to be ready for construction when officials are allowed to expand, explained Jim Dunbar, district manager at Potrero Hills.
A California salamander. The creatures are the target of a project by Potrero Hills Landfill to create new wetlands.
The five new habitats for the tiger salamander, a protected species in California, consist of wetlands and ponds on property the landfill already owns.
Construction crews were busy at work Friday morning creating a half an acre pond that will be 5 to 7 feet deep for the tiger salamander. Crews are in crunch time to finish before August.
"This is a necessary activity to maintain our business," Dunbar said. "Land restoration is part of our business and we're building something that will last for decades."
He said the marsh land that sits between the landfill and Travis Air Force Base won't be developed.
"Might as well get use out of it the best way we can," he said. "This is an ecologically sensitive and productive place.
Having the marsh flourish is not a bad thing."
The dirt dug from the ground to create the ponds will be used as daily cover at the landfill.
Biologists are in the process of creature capture, to watch the population of the tiger salamander and to relocate them when the times comes, which is likely during the next rainy season. Once they're relocated, they'll continue to be monitored for 10 years.
"We'll see if the tiger salamander likes his new home," Dunbar said.
Jim Dunbar, a manager at Potrero Hills Landfill shows off a crude trap used to capture salamanders.
Friday, July 11, 2014
"Army Corps of Engineers Takes a Strong Stand Against Caltrans Multiple Violations in the Wetlands by Suspending Their Work Permit...Then Caves and Reinstates it"
2014-07-11 from "Bay Area Coalition for Headwaters":
In a move that was welcomed by but that stunned long-time opponents of the highway project and stung Caltrans, the Army Corps of Engineers (ACE) suspended the permit for the Caltrans Willits Bypass on Friday, June 20, reported ABC News [http://abc7news.com/traffic/caltrans-ordered-to-stop-work-on-willits-bypass/127879/]. ACE is the agency that regulates impacts on federally protected wetlands. Unfortunately, on July 10, the permit was reinstated--under conditions, but many conditions are promises that Caltrans has been making all along.
“This appears to be the first time ACE has ever pulled a permit on an approved project under construction,” said Ellen Drell, co-founder of the Willits Environmental Center upon learning of the suspension.” We are surprised and elated that ACE has finally acted, although we have been pointing out the enormous problems with Caltrans’ plans for years. Since construction began last year, Caltrans’ violations have been so blatant and egregious that the Army Corps could not overlook them any more.
Over 50 people were arrested last year in protests to stop Caltrans construction and advocate for alternative plans. In addition to the issues of wetlands destruction, a long list of violations of the Migratory Bird Act, Clean Water Act and numerous permit violations and other habitat threats, it has come to the attention of local Tribes that archaeological sites were buried with new fill without Tribal consultation, as required by law.
A resolution was put forward in April by the Coyote Valley Band of Pomo Indians [http://www.savelittlelakevalley.org/2014/06/21/coyote-valley-band-of-pomo-indians-resolution-regarding-willits-bypass/], in addition to a resolution opposing the Bypass by the National Congress of American Indians [http://www.savelittlelakevalley.org/2013/10/28/national-congress-of-american-indians-passes-resolution-against-caltrans-bypass-desecration/], the “oldest, largest and most representative American Indian and Alaska Native organization serving the interests of trial communities.”
On Thursday, June 26, American Indian Spirit Runners ran through Willits in support of Indigenous people, sacred sites threatened and destroyed by Caltrans, and to support the campaign to stop the Bypass. This pass through Willits was part of a 500-mile Spiritual Marathon [http://www.savelittlelakevalley.org/2014/06/18/join-american-indian-movement-500-mile-spirit-run-in-willits-thurs-june-26th/].
It has just been learned through a phone call between Caltrans Assoc. Environmental Planner Timothy O’Keefe and Coyote Valley Band of Pomo Indians (CVBPI) Historic Preservation Officer Eddie Knight that another archaeological site was damaged by construction crews on June 12. The damage occurred in the area where Caltrans is carrying out “environmental mitigation.” It is covered in a piece in the Anderson Valley Advertiser [http://theava.com/archives/32555].
The Coyote Valley Band Pomo Indians is currently requesting government-to-government consultations with Caltrans and the Federal Highway Administration regarding damage done to ancestral villages and sites in the construction area. Priscilla Hunter, Tribal Representative to the consultations said, “There are so many archaeological sites in the contruction area that the CA. Office of Historic Preservation has declared that the entire area of the Bypass could be designated an “archaeological district”, and thus our Tribe has called for a downsizing of the Project’s footprint in order to protect these sites.”
In a move that was welcomed by but that stunned long-time opponents of the highway project and stung Caltrans, the Army Corps of Engineers (ACE) suspended the permit for the Caltrans Willits Bypass on Friday, June 20, reported ABC News [http://abc7news.com/traffic/caltrans-ordered-to-stop-work-on-willits-bypass/127879/]. ACE is the agency that regulates impacts on federally protected wetlands. Unfortunately, on July 10, the permit was reinstated--under conditions, but many conditions are promises that Caltrans has been making all along.
“This appears to be the first time ACE has ever pulled a permit on an approved project under construction,” said Ellen Drell, co-founder of the Willits Environmental Center upon learning of the suspension.” We are surprised and elated that ACE has finally acted, although we have been pointing out the enormous problems with Caltrans’ plans for years. Since construction began last year, Caltrans’ violations have been so blatant and egregious that the Army Corps could not overlook them any more.
Over 50 people were arrested last year in protests to stop Caltrans construction and advocate for alternative plans. In addition to the issues of wetlands destruction, a long list of violations of the Migratory Bird Act, Clean Water Act and numerous permit violations and other habitat threats, it has come to the attention of local Tribes that archaeological sites were buried with new fill without Tribal consultation, as required by law.
A resolution was put forward in April by the Coyote Valley Band of Pomo Indians [http://www.savelittlelakevalley.org/2014/06/21/coyote-valley-band-of-pomo-indians-resolution-regarding-willits-bypass/], in addition to a resolution opposing the Bypass by the National Congress of American Indians [http://www.savelittlelakevalley.org/2013/10/28/national-congress-of-american-indians-passes-resolution-against-caltrans-bypass-desecration/], the “oldest, largest and most representative American Indian and Alaska Native organization serving the interests of trial communities.”
On Thursday, June 26, American Indian Spirit Runners ran through Willits in support of Indigenous people, sacred sites threatened and destroyed by Caltrans, and to support the campaign to stop the Bypass. This pass through Willits was part of a 500-mile Spiritual Marathon [http://www.savelittlelakevalley.org/2014/06/18/join-american-indian-movement-500-mile-spirit-run-in-willits-thurs-june-26th/].
It has just been learned through a phone call between Caltrans Assoc. Environmental Planner Timothy O’Keefe and Coyote Valley Band of Pomo Indians (CVBPI) Historic Preservation Officer Eddie Knight that another archaeological site was damaged by construction crews on June 12. The damage occurred in the area where Caltrans is carrying out “environmental mitigation.” It is covered in a piece in the Anderson Valley Advertiser [http://theava.com/archives/32555].
The Coyote Valley Band Pomo Indians is currently requesting government-to-government consultations with Caltrans and the Federal Highway Administration regarding damage done to ancestral villages and sites in the construction area. Priscilla Hunter, Tribal Representative to the consultations said, “There are so many archaeological sites in the contruction area that the CA. Office of Historic Preservation has declared that the entire area of the Bypass could be designated an “archaeological district”, and thus our Tribe has called for a downsizing of the Project’s footprint in order to protect these sites.”
"Timber Wars Continue: Old Growth in Mattole River Watershed Being Logged by Humboldt Redwood Co.; Humboldt Activists Begin New Tree Sit To Defend Unlogged Forest"
2014-07-11 from "Bay Area Coalition for Headwaters":
Resistance to Humboldt Redwood Company’s (HRC) plans to cut hundreds of acres of previously unlogged forest escalated today with the creation of a new tree sit blocking road access to the Long Ridge area in the Mattole.
“We see HRC’s plans to log old growth Doug fir in the Mattole watershed as a ‘testing of the waters’, in that if they get away with it, more old growth forest will come crashing down” said the activist tree sitter who is suspended 70 ft. in air on a net seat as part of a complex blockade.
“The Mattole watershed’s forests contains some of the country’s last remaining 3% of old growth forest. Protecting this unique ecosystem would not only enrich restoration efforts in our local community but would also contribute to the fight against climate change.” said another activist who is part of the protest.
HRC was forced to admit to the existence of unentered forest on their property after their logging plans had already been approved. HRC submitted and Cal Fire accepted the Timber Harvest Plan (THP) as not containing even a portion of unentered forest. Residents of the Mattole Valley and activists alike feel that Cal Fire should reopen the THP approval process in order to consider this new information.
HRC has manipulated their definition of old growth to avoid intervention by the Sustainability Certifier for the Forest Stewardship Council (FSC), under whose certification guidelines the logging is ostensibly carried out. Direct action to block logging operations came after the company failed to offer a solution to residents’ concerns.
The activists further maintain that, “With the president of Humboldt Redwood also sitting on the Board of the FSC, the fox has been let loose into the hen house on this plan. HRC should tell their customers that their so-called sustainable lumber may actually be coming from an ancient forest that has never been logged before.”
This remote area in southwest Humboldt County is geologically young, and therefore unstable—actually one of the most seismically active in the world—making slopes susceptible to landslides and erosion. The river still supports salmon and steelhead runs and the area contains one of the largest intact old growth Doug fir forests left in California, which a coalition of local residents and activists help protect from Maxxam/Pacific Lumber logging in the 90’s and 2000’s. HRC’s purchase of the old PL property was supposed to herald a new era of more sustainable logging in which no old growth was cut and clear-cuts were not employed. Now Northern California activists are trying to hold them to that standard.
Resistance to Humboldt Redwood Company’s (HRC) plans to cut hundreds of acres of previously unlogged forest escalated today with the creation of a new tree sit blocking road access to the Long Ridge area in the Mattole.
“We see HRC’s plans to log old growth Doug fir in the Mattole watershed as a ‘testing of the waters’, in that if they get away with it, more old growth forest will come crashing down” said the activist tree sitter who is suspended 70 ft. in air on a net seat as part of a complex blockade.
“The Mattole watershed’s forests contains some of the country’s last remaining 3% of old growth forest. Protecting this unique ecosystem would not only enrich restoration efforts in our local community but would also contribute to the fight against climate change.” said another activist who is part of the protest.HRC was forced to admit to the existence of unentered forest on their property after their logging plans had already been approved. HRC submitted and Cal Fire accepted the Timber Harvest Plan (THP) as not containing even a portion of unentered forest. Residents of the Mattole Valley and activists alike feel that Cal Fire should reopen the THP approval process in order to consider this new information.
HRC has manipulated their definition of old growth to avoid intervention by the Sustainability Certifier for the Forest Stewardship Council (FSC), under whose certification guidelines the logging is ostensibly carried out. Direct action to block logging operations came after the company failed to offer a solution to residents’ concerns.
The activists further maintain that, “With the president of Humboldt Redwood also sitting on the Board of the FSC, the fox has been let loose into the hen house on this plan. HRC should tell their customers that their so-called sustainable lumber may actually be coming from an ancient forest that has never been logged before.”
This remote area in southwest Humboldt County is geologically young, and therefore unstable—actually one of the most seismically active in the world—making slopes susceptible to landslides and erosion. The river still supports salmon and steelhead runs and the area contains one of the largest intact old growth Doug fir forests left in California, which a coalition of local residents and activists help protect from Maxxam/Pacific Lumber logging in the 90’s and 2000’s. HRC’s purchase of the old PL property was supposed to herald a new era of more sustainable logging in which no old growth was cut and clear-cuts were not employed. Now Northern California activists are trying to hold them to that standard.
Thursday, July 10, 2014
"'Alarm Bells Are On': New Study Links Neonics to Bird Declines"
Save the Birds! [link]
"New study finds scope of ecological damage caused by widely used insecticides worse than thought"
2014-07-10 Andrea Germanos for "Common Dreams" [http://www.commondreams.org/headline/2014/07/10-7]:
A class of insecticides linked to the decline of bees may be even more ecologically damaging than previously thought, possibly causing declines in birds as well.
The new findings by researchers from the Netherlands was published Wednesday in the journal Nature [http://www.nature.com/nature/journal/vaop/ncurrent/full/nature13642.html].
The researchers looked at one neonicotinoid or "neonic" called imidacloprid, and found that where the concentrations of that insecticide were more than 20 nanograms per liter, bird populations dropped by 3.5 per cent on average annually.
"In ten years it's a 35% reduction in the local population, it's really huge," study co-author Hans de Kroon from Radboud University told BBC News. "It means the alarm bells are on straight away."
The scientists suspect that the imidacloprid builds up and can persist for years in the soil, killing insects that the birds depend on for food, therefore leading to their decline.
"Our results suggest that the impact of neonicotinoids on the natural environment is even more substantial than has recently been reported and is reminiscent of the effects of persistent insecticides in the past," the study reads.
The new study comes on the heels of an analysis by a global team of scientists which found "clear evidence" that neonics—the most widely used insecticides in the world—pose threats to bees, other pollinators, earthworms and ecosystems across the globe.
"Our study really makes the evidence complete that something is going on here," de Kroon told the Guardian. "We can’t go on like this any more. It has to stop."
"New study finds scope of ecological damage caused by widely used insecticides worse than thought"
2014-07-10 Andrea Germanos for "Common Dreams" [http://www.commondreams.org/headline/2014/07/10-7]:
A class of insecticides linked to the decline of bees may be even more ecologically damaging than previously thought, possibly causing declines in birds as well.
The new findings by researchers from the Netherlands was published Wednesday in the journal Nature [http://www.nature.com/nature/journal/vaop/ncurrent/full/nature13642.html].
The researchers looked at one neonicotinoid or "neonic" called imidacloprid, and found that where the concentrations of that insecticide were more than 20 nanograms per liter, bird populations dropped by 3.5 per cent on average annually.
"In ten years it's a 35% reduction in the local population, it's really huge," study co-author Hans de Kroon from Radboud University told BBC News. "It means the alarm bells are on straight away."
The scientists suspect that the imidacloprid builds up and can persist for years in the soil, killing insects that the birds depend on for food, therefore leading to their decline.
"Our results suggest that the impact of neonicotinoids on the natural environment is even more substantial than has recently been reported and is reminiscent of the effects of persistent insecticides in the past," the study reads.
The new study comes on the heels of an analysis by a global team of scientists which found "clear evidence" that neonics—the most widely used insecticides in the world—pose threats to bees, other pollinators, earthworms and ecosystems across the globe.
"Our study really makes the evidence complete that something is going on here," de Kroon told the Guardian. "We can’t go on like this any more. It has to stop."
Monday, July 7, 2014
The Profit Motive and the Government Mandate of Environmental Protection
EPA, under influence of private plastic cartels, covers-up the fact that BPA-Free Plastics are still toxic [link]
"The Poisoners and Their Accomplices"
2014-07-06 by Tony Pereira, Truthout | Book Review for "Poison Spring: The Secret History of Pollution and the EPA" by E.G. Vallianatos and McKay Jenkins, (Bloomsbury Press) [http://truth-out.org/opinion/item/24696-the-poisoners-and-their-accomplices]:
Poison Spring follows on the tracks of a massive story of deceit, corruption, lies, fear, cover-ups, fascism, i.e., the collusion of corporations with the government, and falsehoods that started to be told over 60 years ago in 1962 by Rachel Carson, a chemist, in Silent Spring, which warned of an impending collapse and death of our country's and planet's bio-systems due to the gratuitous use of chemicals, pesticides, insecticides and herbicides in our agriculture. Rachel Carson described a world without the excited celebration of spring, voided of birdsong and the rustling of animals anxiously preparing for another season of new life and renewal.
Sixty years later, we are no better off. In fact, as shown in this remarkable new book, Poison Spring, we are worse off. Silent Spring has turned into Poison Spring.
This work shows the path that has been taken by the Environmental Protection Agency (EPA), year after year, director after director, US president after US president, Republican or Democrat, from Reagan to Obama, to relinquish enforcement of all regulations and forego all oversight. It demonstrates the agency's obligation to protect the American people and the environment, as mandated by the US Congress and signed into law by President Nixon, but its opting instead to let corporations and the chemical-industrial complex (CIC) perform their own tests, pronounce their own decisions, regulate themselves and deploy an ungodly cocktail of chemicals, biocides, pesticides, insecticides, herbicides, fungicides, chlorinated hydrocarbons, neonicotinoids, neurotoxins, carcinogens, hormone mimickers and disruptors, mutagens, bee, pollinator, developmental and reproductive toxins, and otherwise poison in unimaginable quantities - about 1.2 billion pounds per year in the United States alone. That's about 4 pouns per per person per year in the United States on average, and 5 billion pounds each year worldwide, close to 1 pound of biocides per person on the planet each year, year after year round the clock. It's an amount that has risen a depraved 50-fold since 1950, going straight into our food, environment, agriculture, air, water, land, rivers, oceans, plants and animals.
Data published by the US Department of Agriculture (USDA) show that up to an incredible 86 pesticide residues can be detected in a single food item (cucumbers) that has been grown by the agricultural-industrial complex (AIC) using any or all the chemicals above.
A bizarre new assault wave that seems to have come straight from a Hollywood horror hell nightmare, is headed by a new type of perfidious chemical being deployed in combination with genetically modified organisms (GMOs) and their associated weed killers, glyphosates, growth inhibitors that work by blocking the uptake of nutrients by weed roots, thus stunting plant growth and ultimately killing them, leaving behind the GMO plants only that were genetically modified with DNA from anything such as viruses, bacteria, insects, plants or animals and are resistant to the biocides.
However, this genetically engineered plant resistance is rapidly waning, and an old chemical, 2-4-D dioxin, a defoliant component of the infamous Agent Orange concoction used in Vietnam, is in the initial stages of being approved by the EPA. Dioxins are a class of chlorinated hydrocarbons that are the most poisonous chemical known to mankind, causing birth defects with 500,000 reported cases in Vietnam alone, reproductive problems, cancer, leukemia, and immuno-suppression. Even the remotest idea of approving one of the most toxic chemicals for use in food is complete madness, regarded by many as a criminal act against people, life and the planet.
With close to 400 references, Poison Spring is an extraordinary account that required courage to relay. Some battles have been won; many more urgently need to be won against a relentless chemical/agro-industrial complex. Our nation must come to terms with the rampant dishonesty and deceit in industry and government, hold both accountable, and chart a new, clean, poison free future for the world, for all of us.
"The Poisoners and Their Accomplices"
2014-07-06 by Tony Pereira, Truthout | Book Review for "Poison Spring: The Secret History of Pollution and the EPA" by E.G. Vallianatos and McKay Jenkins, (Bloomsbury Press) [http://truth-out.org/opinion/item/24696-the-poisoners-and-their-accomplices]:
Poison Spring follows on the tracks of a massive story of deceit, corruption, lies, fear, cover-ups, fascism, i.e., the collusion of corporations with the government, and falsehoods that started to be told over 60 years ago in 1962 by Rachel Carson, a chemist, in Silent Spring, which warned of an impending collapse and death of our country's and planet's bio-systems due to the gratuitous use of chemicals, pesticides, insecticides and herbicides in our agriculture. Rachel Carson described a world without the excited celebration of spring, voided of birdsong and the rustling of animals anxiously preparing for another season of new life and renewal.
Sixty years later, we are no better off. In fact, as shown in this remarkable new book, Poison Spring, we are worse off. Silent Spring has turned into Poison Spring.
This work shows the path that has been taken by the Environmental Protection Agency (EPA), year after year, director after director, US president after US president, Republican or Democrat, from Reagan to Obama, to relinquish enforcement of all regulations and forego all oversight. It demonstrates the agency's obligation to protect the American people and the environment, as mandated by the US Congress and signed into law by President Nixon, but its opting instead to let corporations and the chemical-industrial complex (CIC) perform their own tests, pronounce their own decisions, regulate themselves and deploy an ungodly cocktail of chemicals, biocides, pesticides, insecticides, herbicides, fungicides, chlorinated hydrocarbons, neonicotinoids, neurotoxins, carcinogens, hormone mimickers and disruptors, mutagens, bee, pollinator, developmental and reproductive toxins, and otherwise poison in unimaginable quantities - about 1.2 billion pounds per year in the United States alone. That's about 4 pouns per per person per year in the United States on average, and 5 billion pounds each year worldwide, close to 1 pound of biocides per person on the planet each year, year after year round the clock. It's an amount that has risen a depraved 50-fold since 1950, going straight into our food, environment, agriculture, air, water, land, rivers, oceans, plants and animals.
Data published by the US Department of Agriculture (USDA) show that up to an incredible 86 pesticide residues can be detected in a single food item (cucumbers) that has been grown by the agricultural-industrial complex (AIC) using any or all the chemicals above.
A bizarre new assault wave that seems to have come straight from a Hollywood horror hell nightmare, is headed by a new type of perfidious chemical being deployed in combination with genetically modified organisms (GMOs) and their associated weed killers, glyphosates, growth inhibitors that work by blocking the uptake of nutrients by weed roots, thus stunting plant growth and ultimately killing them, leaving behind the GMO plants only that were genetically modified with DNA from anything such as viruses, bacteria, insects, plants or animals and are resistant to the biocides.
However, this genetically engineered plant resistance is rapidly waning, and an old chemical, 2-4-D dioxin, a defoliant component of the infamous Agent Orange concoction used in Vietnam, is in the initial stages of being approved by the EPA. Dioxins are a class of chlorinated hydrocarbons that are the most poisonous chemical known to mankind, causing birth defects with 500,000 reported cases in Vietnam alone, reproductive problems, cancer, leukemia, and immuno-suppression. Even the remotest idea of approving one of the most toxic chemicals for use in food is complete madness, regarded by many as a criminal act against people, life and the planet.
With close to 400 references, Poison Spring is an extraordinary account that required courage to relay. Some battles have been won; many more urgently need to be won against a relentless chemical/agro-industrial complex. Our nation must come to terms with the rampant dishonesty and deceit in industry and government, hold both accountable, and chart a new, clean, poison free future for the world, for all of us.
Saturday, July 5, 2014
"Knitters answer WildCare's call for nests to save baby birds"
2014-07-05 by Peter Fimrite from "San Francisco Chronicle" [http://www.sfgate.com/bayarea/article/Knitters-answer-WildCare-s-call-for-nests-to-save-5600816.php]:
Noam Mendelson tends to rescued songbird nestlings. The knitted nests help regulate the baby birds' body temperature and simulate the soft protection of a nest in the wild. Photo: Paul Chinn, The Chronicle
It may seem like a natural fit, but until now one would have been hard-pressed to find a real-life scenario that combined the interests of knitters and baby birds.
Both are adorable, no question, but it was a case of never the twain shall meet until this year when a wildlife conservation group in Marin County figured out how yarn-wielding sweater weavers could help chirping downy-feathered avian offspring.
The solution was simple: knitted nests.
WildCare, the San Rafael nonprofit that treats almost 4,000 wild animals a year, made a request in April for local knitters to weave bird nests for the hundreds of orphaned chicks the organization cares for every year. The knitters of the Bay Area went wild, donating 529 nests to an organization that last year rehabilitated 540 chicks, most of which had fallen out of or were somehow dislodged from their nests during the spring nesting season.
"We use these nests primarily for the songbirds," said Alison Hermance, WildCare's communications manager, as she gestured toward a blue knitted nest carrying baby finches and a gray and white nest full of tiny and eager chestnut-backed chickadees, their beaks wide open in anticipation of a feeding.
"These nests provide good temperature control and they give the birds the soft feeling of a natural nest," she said.
Noticing problems -
The Baby Bird Nest campaign got its start two years ago when WildCare staff noticed that some of the chicks were bruising or developing other problems from the hard surfaces in the bowls that were being used as makeshift nests, Hermance said.
It wasn't the first time bird caretakers had noticed the problem. A worker at Sebastopol's Native Songbird Care & Conservation program was apparently the first to knit a nest. The pattern was published on the organization's website, creating a blueprint for the WildCare knitted nest program.
Dinka Velcich, 89, of Novato, was one of the first knitters to respond to WildCare's request. She has knitted 53 nests for the organization.
"It's my hobby," said Velcich, who was born on a farm on the Adriatic island of Cres, in Croatia, where she used to knit socks while herding sheep. "I love animals, and I love birds. I can't work in the yard anymore because I have arthritis, but I can do this."
Teri Rockas, a 57-year-old health care worker from San Rafael, has knitted 37 nests.
"My grandmother taught me to knit when I was about 5 years old and she loved birds," Rockas said recently as she worked on number 38. "Right before she passed, she told me to think of her every time I saw a baby bird. So this is a wonderful way for me to remember her."
Developing an enterprise -
The knitting fiesta has been a bonanza for California wildlife hospitals and bird rescue centers, which have received 250 of the nests donated to WildCare.
"We are now a knitted nest provider," Hermance said. "We've turned it into an enterprise."
It is important, Hermance said, because bird nests are often disturbed at this time of year. A prime example occurred in May when tree trimmers knocked down baby night heron nests outside an Oakland post office, creating a furor among neighbors and bird lovers.
Hermance said most bird mothers cannot pick up their chicks and put them back in the nest once they fall out. A chick that has downy fluff instead of feathers is not old enough to control its body temperature or feed itself and must be fed every 45 minutes in a warm, cozy place or it will die.
Hermance said it is a myth that mother birds will not take care of chicks that are handled by humans. The problem, she said, is that most people who find chicks on the ground cannot find the nest or the nest has been destroyed.
The baby birds are generally kept in the knitted nests at WildCare for two weeks where they are fed 15 times a day before they can move to a larger cage with a perch. Hermance said the birds are generally released where they were found within about two months.
The knitted nests "are like towels. You are always replacing them," Hermance said. "You just can't have too many of them. This program shows how much people really want to do things to help wildlife."
Knitted nests for baby birds -
The website for the campaign can be found at [www.babybirdnest.org].
The instructions for making a knitted nest can be found at [http://nativesongbirdcare.org/uploads/How_to_Make_Knit_Nests_.pdf]
Noam Mendelson tends to rescued songbird nestlings. The knitted nests help regulate the baby birds' body temperature and simulate the soft protection of a nest in the wild. Photo: Paul Chinn, The Chronicle
It may seem like a natural fit, but until now one would have been hard-pressed to find a real-life scenario that combined the interests of knitters and baby birds.
Both are adorable, no question, but it was a case of never the twain shall meet until this year when a wildlife conservation group in Marin County figured out how yarn-wielding sweater weavers could help chirping downy-feathered avian offspring.
The solution was simple: knitted nests.
WildCare, the San Rafael nonprofit that treats almost 4,000 wild animals a year, made a request in April for local knitters to weave bird nests for the hundreds of orphaned chicks the organization cares for every year. The knitters of the Bay Area went wild, donating 529 nests to an organization that last year rehabilitated 540 chicks, most of which had fallen out of or were somehow dislodged from their nests during the spring nesting season.
"We use these nests primarily for the songbirds," said Alison Hermance, WildCare's communications manager, as she gestured toward a blue knitted nest carrying baby finches and a gray and white nest full of tiny and eager chestnut-backed chickadees, their beaks wide open in anticipation of a feeding.
"These nests provide good temperature control and they give the birds the soft feeling of a natural nest," she said.
Noticing problems -
The Baby Bird Nest campaign got its start two years ago when WildCare staff noticed that some of the chicks were bruising or developing other problems from the hard surfaces in the bowls that were being used as makeshift nests, Hermance said.
It wasn't the first time bird caretakers had noticed the problem. A worker at Sebastopol's Native Songbird Care & Conservation program was apparently the first to knit a nest. The pattern was published on the organization's website, creating a blueprint for the WildCare knitted nest program.
Dinka Velcich, 89, of Novato, was one of the first knitters to respond to WildCare's request. She has knitted 53 nests for the organization.
"It's my hobby," said Velcich, who was born on a farm on the Adriatic island of Cres, in Croatia, where she used to knit socks while herding sheep. "I love animals, and I love birds. I can't work in the yard anymore because I have arthritis, but I can do this."
Teri Rockas, a 57-year-old health care worker from San Rafael, has knitted 37 nests.
"My grandmother taught me to knit when I was about 5 years old and she loved birds," Rockas said recently as she worked on number 38. "Right before she passed, she told me to think of her every time I saw a baby bird. So this is a wonderful way for me to remember her."
Developing an enterprise -
The knitting fiesta has been a bonanza for California wildlife hospitals and bird rescue centers, which have received 250 of the nests donated to WildCare.
"We are now a knitted nest provider," Hermance said. "We've turned it into an enterprise."
It is important, Hermance said, because bird nests are often disturbed at this time of year. A prime example occurred in May when tree trimmers knocked down baby night heron nests outside an Oakland post office, creating a furor among neighbors and bird lovers.
Hermance said most bird mothers cannot pick up their chicks and put them back in the nest once they fall out. A chick that has downy fluff instead of feathers is not old enough to control its body temperature or feed itself and must be fed every 45 minutes in a warm, cozy place or it will die.
Hermance said it is a myth that mother birds will not take care of chicks that are handled by humans. The problem, she said, is that most people who find chicks on the ground cannot find the nest or the nest has been destroyed.
The baby birds are generally kept in the knitted nests at WildCare for two weeks where they are fed 15 times a day before they can move to a larger cage with a perch. Hermance said the birds are generally released where they were found within about two months.
The knitted nests "are like towels. You are always replacing them," Hermance said. "You just can't have too many of them. This program shows how much people really want to do things to help wildlife."
Knitted nests for baby birds -
The website for the campaign can be found at [www.babybirdnest.org].
The instructions for making a knitted nest can be found at [http://nativesongbirdcare.org/uploads/How_to_Make_Knit_Nests_.pdf]
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