TO: Barbara A. Adkins, AICP <Date>
Mason County Dept. Community Development
411 N. 5th Street
P. O. Box 279
Shelton, WA 98584
Dear Ms. Adkins,
This letter is to request that Mason County take notice and into account the following concerns when defining the scope of the Environmental Impact Study for the proposed ADAGE LLC Biomass Incinerator Plant that is currently under consideration for our community. Although I have many concerns, perhaps Air Quality is the most critical.
The Environmental Impact Study for the Adage Mason LLC should require a thorough investigation to determine regulatory conformity and the impact on the following:
I. AIR QUALITY
1.1 The impact on air quality during times of inversion which frequently occur during the rainy season in Shelton. Currently, Air Quality has deteriorated to above the Washington State threshold of 15ug particulates/L health alert 55% of the hours in the 6 winter months (2009) October – March as measured by the station near Mason Co. General Hospital. This station isn’t even calibrated for the smaller (2.5 micron) particles–it merely measures the larger ones (10 micron).
1.2 The amount and impact of DIOXIN released by the biomass incineration plant into our air column; the contamination of Puget Sound Federal Waterways under the jurisdiction of the US Army Corp of Engineers; and the health risk to people who live, work and play in the areas exposed to the fall-out from this most toxic of all substances by the proposed plant. Currently Shelton Harbor is a hotbed of Dioxin contamination amounting to 175 ppt while Oakland Bay harbors 35 ppt – 65 ppt in its sediment. Dioxin is bio-accumulative. ORCAA admits it will NOT even be monitoring this poison although federal studies indicate 10mg to 167mg per Kg wood burned will be produced, depending on the kinds of wood incinerated. Some will be at the high end of the scale because in addition to the chlorine inherent in the woody material content, many logs can be seen stored in Oakland Bay’s salt (NaCl) water…adding to the chlorine content. No mechanism whatsoever will be in place to protect the public, and no verifiable release of Dioxin is proposed, and there will be NO schedule to check on it according to Gordon Lance of ORCAA.
To my knowledge, the US Army Corp of Engineers hasn’t been consulted about the inevitable transfer (through the air column) of this easily anticipated massive amount of Dioxin to our bays and estuaries, private property, pastures, agricultural and tidelands. Oakland bay is home to many commercial oyster beds which have a particular affinity to Dioxin (fatty tissue) but have never (in contrast to clams) been sampled for Dioxin. Industry claims of natural background sources being the explanation fly in the face of the fact modern human tissue has 50X the Dioxin as ancient human tissue. Were natural background sources responsible, we’d expect to see rough parity. We don’t.
1.3 Determination of the type and amount of other pollutants, not currently covered by the SEPA, that the plant will generate including, but not limited to, radioactive cesium and strontium, mercury, arsenic and other known pollutants. The impact that these pollutants will have on air quality, contamination of Puget Sound and the health risk to the people who live, work and play in the area exposed to the fall out from the plan.
1.4 The impact of the exhaust of the trucks commuting to the plant to deliver fuel including slash, supplies and chemicals, and the removal of by-products of the plant will exceed the pollution emitted by the plant itself by 7X, including the tons of ash left over as a result of the incineration process, on air quality in the area of the traffic routes. Although this ash is going to contain high concentrations of Dioxin, heavy metals, radioactive Cesium & Strontium, Adage suggests it will be spread on the fields of unsuspecting landowners willing to accept it. The trees that serve as lock safes for these hazardous materials that resulted from atmospheric nuclear tests, coal incineration, etc. will be destroyed by a massive release of these harbingers of death and illness once again to be inhaled by the population, a Pandora’s box of irreversible damage to the community’s air, health, families, children, quality of life, and future.
The Adage/Simpson proposal will add enormously to the already failing air quality and toxic burden sustained by area residents.
II. FOREST LANDS
2.1 Much of our forests in Mason County are in fragile ecosystems on steep/mountainous slopes…an area already beset by devastating floods resulting from past ill conceived government programs such as the ‘sustained yield’ promulgated by Simpson Timber Co.
2.2 The severity and incidence of destructive floods will be dramatically increased with the additional loss/destruction of woody material from area forests.
2.3 Bio-diversity will suffer from the loss of organic material and cover from our woodlands.
2.4 Bays, streams, and estuaries already sedimented will be further compromised. Stream banks will be further eroded. More homes/property will be destroyed and lives put at risk as a result of the extraction process from our forests contemplated.
2.5 Salmon and aquatic life will suffer harm from the reduction to its environment caused by the increased elimination of forests which tend to protect the watershed and water quality.
III. RIPARIAN RIGHTS
3.1 Much of existing water/aquifers is spoken for through the mechanism of senior riparian rights. The proposed bio-incineration would use massive amounts of what is in thin supply. Ground Water supplies/aquifers will be reduced/eliminated.
3.2 The waste water from the proposed bio-incinerator(s) will foul existing aquifers, streams, bays, and estuaries.
3.3 The water use of the bio-incinerator(s) will deprive current and future residents of water they need to dwell here.
3.4 This intense water use by the bio-incinerator(s) will reduce stream flows and fish runs.
IV. ECONOMIC DISPLACEMENT
4.1 Many forest based cottage industries currently exist which will be displaced by the bio-incinerator(s) proposed. These include tourism, recreation, wreath and florist companies, mushroom harvesting, hunting, camping, fishing, photography, eco-tourism, beach combing, picnics, medical therapy, meditation, and spiritual remediation. Rather than improve the local economy, ultimately the bio-incineration proposal(s) will destroy it over time.
4.2 Many now and future businesses offer employment in Mason County. Part of the inducement they tender is the quality of life and environment in this region as an alternative to urban life. The bio-incineration industry will directly offset/destroy such incentives.
V. PROPERTY/HOME VALUES and GOVERNMENT TAX REVENUE
5.1 Homes sales and property values are already beginning to suffer in the areas adjacent to the proposed bio-incinerator site(s).
5.2 Washington State Supreme Court case law instructs permits (e.g. ORCAA) are no defense against chemical trespass/nuisance lawsuits. No agency may authorize trespass against private property. The liability the County, Port of Shelton, and corporations will incur is monumental. Kitsap County was successfully sued under the legal theory of chemical trespass as was ASARCO. Obtaining duly issued permits availed them naught when defending against these suits.
5.3 As property values across the board decline, government revenue based on property taxes will keep pace. Even a small percentage loss will be devastating to the County budget.
5.4 Much of the infrastructure proposed will be paid for by local taxpayers with only glib assurances the ‘robust economy’ resulting from burning area forests and construction of the incinerators will make up for the loss.
5.5 The massive destruction of forest buffers is likely to increase premiums for flood insurance and property damage.
VI. CLIMATE CHANGE
6.1 Burning our forests is NOT ‘carbon neutral’. That is an ill advised legal fiction. Burning wood produces 1.5X to 2.0X the CO2 emissions of coal and about 4X the CO2 emissions of natural gas.
6.2 Burning our forests will NOT improve the environment despite the claim it promotes the sequestration of fossil fuels. In fact, burning our forests imposes an immense and immediate CARBON DEBT which will never be repaid. Even if it were possible to somehow repay it, the time to do so would be on the order of 50 to 200 years…an irresponsible sub-prime loan to rapacious companies seeking cheap carbon credits under an ill considered immature perverse Cap and Trade scheme. Permitting the destruction of our forests, as this scheme does, reduces the bio-diversity and inhabitable attributes of the planet itself.
VII. FIRE/TRAFFIC HAZARD(s)
7.1 Mason County does not have the fire control facilities to contain the dimensions of a catastrophic fire at a plant the size Adage proposes.
7.2 Massive increase of truck traffic will result in substantially higher traffic fatalities/injuries and congestion, possibly preventing/slowing emergency services response time.
VIII. SOIL CONSERVATION
8.1 ‘Slash’ and undergrowth is not ‘waste’ as the term is commonly understood. The organic material contained in forest residue after a logging operation is absolutely necessary to maintain the sustainability of forest regrowth along with the micro-ecology of soil organisms and structure.
8.2 Removing the forest based residue proposed by the bio-incinerator industry will permanently bankrupt area forest soils and micro-nutrients. Forest soils denuded of their last vestige of organic material will be exposed to winter rains/elements, erode into already sedimented stream beds, and leach vital nutrients from those soils forever.
IX. FISH AND WILDLIFE
9.1 To my knowledge, no advisory for the proposed bio-incinerators has been sought from Washington’s Fish and Wildlife Department. So far as I know, governing federal agencies have been left out of the mix too. (e.g. US Army Corp of Engineers)
9.2 To my knowledge, no advisory for the proposed bio-incinerators has been sought from all of the areas Treaty Rights tribes with respect to their traditional fishing rights and the impact the bio-incinerator(s) would have on the same.
I appreciate your department’s careful consideration of all of the important environmental questions raised by a project of this type and size. It is my hope that your department will hold ADAGE LLC to the highest possible standards during the EIS process compatible with human life, environmental sustainability, and that you will do your utmost to protect our health, safety and quality of life we Mason County residents depend on you to safeguard.
Shelton, WA 98584