On ‘sound science’
Consider data sources on Buffalo
Governor Hutchinson: We appreciated your letter of April 14 regarding the C&H operation. We agree with your sentiments regarding the value of the Buffalo National River as well as the importance of sound science for informing good decisions, but we respectfully contend that the sources of your scientific information are inadequate and politically tainted.
Consider the Department of Environmental Quality, which serves as the state’s nonpartisan source for reliable environmental science. Regrettably, its reputation was harmed by the mere act of issuing the C&H permit, especially without public notice or the requisite construction permit. As a result, the standard geological review by a staff geologist was bypassed. If a permit for a large industrial CAFO in a geologically sensitive watershed, which flows into our national river, is not significant enough to require review by a staff geologist, what permit would trigger such review?
Further, engineering guidance provided by the Agricultural Waste Management Field Handbook, a key regulatory document, was ignored when the permit was first reviewed. The agency has irreparably discredited itself scientifically.
Consider the Big Creek Research and Extension Team, whose role you emphasized as being of key importance in assessing the impact of the hog farm. Gov. Mike Beebe enlisted the UA School of Agriculture, which then created the Big Creek team, to monitor the environmental impact of the hog farm. Later the Cooperative Extension Service joined the team. The service primarily assists farmers, which creates an unavoidable conflict of interest for the team between its original mandate to monitor versus now, the role to help C&H succeed.
Early on, the Big Creek study was reviewed by an independent panel of experts who noted a number of shortcomings, including that the team was not sampling Big Creek during storm events, times which typically result in nutrients and pathogens being washed from the fields into the streams. The panel pointed out that the team was conducting tests under conditions that were less likely to reveal a problem. This and other panel recommendations were discounted. Most egregious however was the team’s withholding of the controversial taxpayer-funded electrical resistivity imaging pond data for over a year until our organization stumbled upon it and made it public.
The team’s credibility was severely damaged and its priorities are now in doubt.
In response to that scandal, the Department of Environmental Quality hired Harbor Environmental to drill a single hole near the C&H ponds. It ignored numerous credible scientists, including the project’s own independent geologist, who advised them that a single hole was inadequate to determine much of anything. M.D. Smolen, Ph.D., with 35 years of experience in water quality management said: “Although leakage from the ponds has not been confirmed to date, any seepage or direct leakage from the ponds would be transmitted to groundwater and ultimately to the Buffalo River. The fact that Harbor Environmental did not confirm any ground water contamination is not conclusive because they only drilled one hole.” When its report was completed, the department forbade direct communication between Harbor and the scientific community or the public. Whether Harbor did good work or not, the results were tainted by the way the department controlled the process, which further solidified its deteriorating scientific credibility.
Governor, you have characterized the public as “emotional,” but two to three million gallons of raw hog waste disposed of on fields upstream of our national river is certainly going to elicit a strong public response. Threats to treasured wild places do that. But the fact is that real science is validating the public’s concerns. The National Park Service and the U.S. Geological Survey agree that Big Creek is now impaired for dissolved oxygen, a sign of nutrient overloading. The Big Creek team’s own data shows elevated nitrate levels. Dr. JoAnn Burkholder, a William Neal Reynolds distinguished professor, says: “The data clearly indicate that the C&H CAFO is contributing swine waste pollution to adjacent public trust waters. The nitrate levels downstream from this CAFO commonly are levels that have been shown in other research to be toxic to sensitive aquatic life.”
The data also show elevated levels of E. coli, which as you know has human health implications. Dr. Burkholder notes: “These data indicate that the C&H CAFO is discharging E. coli bacteria which are contributing to the pollution of Big Creek in the CAFO area and downstream waters.”
Governor, we simply don’t have the space here to show you all of the real science. We recently submitted nearly 100 pages of comments to the Department of Environmental Quality. Our scientific sources are well-credentialed, reliable, and nonpartisan. Your current sources are pandering to special interests and are insufficient to properly inform your decisions. For the sake of our national river, its ecology, and the powerful tourism economy that it supports, please don’t gamble. Look beyond your current sources for truly “sound science.”