Sludge Moratorium

Here’s how YOU can make a difference:

Send a message to Washington Governor Jay Inslee and Washington State Department of Ecology Director Maia Bellon: You must immediately impose a state-wide emergency moratorium on approving all pending permits for land application of sewage sludge

Please use the following text as a reference when writing your message. More details about our specific objections to spreading sewage sludge on agricultural lands can be found HERE.

You may also easily send your messages right from our website HERE.

Remember, it’s always good to add a personal message. Also, please cc us when you send your message:
headwaters@protectmillcanyon.org

Here is the pertinent contact information:

Governor Jay Inslee

Office of the Governor
PO Box 40002
Olympia, WA 98504-0002
Phone: 360-902-4111
Fax: 360-753-4110
Email: Governor.Inslee@Governor.wa.gov
Email (from his website’s contact form): http://www.governor.wa.gov/contact/contact/send-gov-inslee-e-message
Facebook: https://www.facebook.com/WaStateGov
Twitter: https://twitter.com/GovInslee

Maia Bellon, Director, Washington State Department of Ecology

Ecology Headquarters
PO Box 47600, Olympia, WA 98504-7600
Phone: (360) 407-7001
Fax: (360) 407-6989
Email: maib461@ecy.wa.gov

 

We are residents who live in an area near Davenport, Washington called Mill Canyon. We feel threatened by a proposal to spread municipal sewage sludge on nearly 900 acres of nearby agricultural land uphill from where we live, garden and farm. The area in question includes our natural watershed. As citizens, we are alarmed and are organizing to prevent permit applications to dump the sludge from being approved by the Washington State Department of Ecology. Pollutant contaminants from the sludge would cause contamination of our drinking and irrigation water supplies, mobilize via water and wind erosion, and migrate into the canyon.

With support from the Sierra Club, the Columbia Institute for Water Policy and the Northwest Fund for the Environment, we have formed a committee called “Protect Mill Canyon Watershed” to publicize the crisis we are facing. Not only do we demand that the permit application to apply sewage sludge in our “back yard” be denied, we are also demanding that Washington State Department of Ecology Director Maia Bellon and Washington State Governor Jay Inslee immediately impose a state-wide emergency moratorium on approving all pending permits for land application of sewage sludge until a thorough review of the science is completed and the findings incorporated into re-worked regulations pertaining to sewage sludge disposal and land application in the state.

We want the Washington State Department of Ecology (DOE) to deny the pending permit application it currently has under consideration that would allow sewage sludge to be spread on neighboring land and impose a state-wide moratorium because:

  • Hundreds of industrial, pharmaceutical and organic pollutant contaminants are known to be present in sewage sludge but are completely ignored by state regulators who routinely approve sewage sludge land application permits based solely on whether concentrations of only nine metals (Arsenic, Cadmium, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium and Zinc) are within its arbitrarily-set parameters for those metals;
  • There are virtually no controls in place to limit the introduction of any pollutant into municipal sewage systems. No sewage sludge regulatory regime could possibly make provisions to adequately protect the public and the environment from harm since it is impossible to know the exact composition of any given batch of sludge or the kinds or concentrations of pollutant contaminants it contains;
  • Antibiotic resistant bacteria and mobile antibiotic resistance genes are present in sewage sludge. Sewage sludge is a conducive environment for bacteria to reproduce in, raising the threat of antibiotic resistant human pathogen strains developing in and migrating from sludge-treated soils into the environment putting human and non-human life at risk;
  • Existing arbitrary, contradictory and inadequate regulations governing the land application of sewage sludge encourage the build-up of toxic heavy metals in soils in violation of state and federal law, especially when waste-derived fertilizers are used in conjunction with sewage sludge. The situation is compounded because testing soils for metals accumulation is not required and this could easily lead to unsafe and illegal concentrations, but no one would know;
  • The Cornell Waste Management Institute Center for the Environment investigated alleged health incidents associated with land application of sewage sludges. “Symptoms of more than 328 people involved in 39 incidents in 15 states are described. Investigation and tracking of the incidents by agencies is poor. Only one of 10 EPA regions provided substantial information on the incidents in their region. Investigations, when conducted, focused on compliance with regulations. No substantial health-related investigations were conducted by federal, state, or local officials. A system for tracking and investigation is needed. Analysis of the limited data suggests that surface-applied Class B sludges present the greatest risk and should be eliminated,” the Cornell researchers reported;
  • In the Mill Canyon permit application (as well as dozens of similar applications around the state), DOE erroneously certified that it has “determined that this proposal does not have a probable significant impact on the environment, [therefore an] environmental impact statement (EIS) is not required.” DOE based its determination on a flawed, incorrect and incomplete State Environmental Policy Act (SEPA) Checklist provided by the vendor seeking the permit. DOE failed to adequately scrutinize the submitted SEPA checklist. In making its determination, DOE also exhibited willful disregard of the science that has emerged in the decades since sewage sludge land application was initiated in the 1970’s. Because of the many inherent environmental risks known to be associated with the land disposal of sewage sludge and the vast acreages where it is being deposited in the state, it is obvious that Environmental Impact Statements must be prepared for every General Permit for Biosolids Management, that is, if permits are ever issued again after the moratorium that is being sought is over;
  • The requirement that the vendor develop a “groundwater protection plan” to monitor for any groundwater contamination resulting from sewage sludge application was improperly waived in the Mill Canyon permit application because an adequate, detailed hydrologic survey was not performed. Likely similar improper waivers have been granted in other permit applications around the state;
  • Much of the land near Mill Canyon where sewage sludge is proposed to be deposited is perched above the canyon and its waterways. It is classified by the USDA Natural Resource Conservation Service as “Highly Erodible Land,” a classification that renders those areas prohibited for sludge application. Soil scientists warn that the area is the worst place to experiment with “bio-solids” as a soil amendment;
  • Numerous irregularities, omissions and incomplete responses are present in the permit application for land application of sewage sludge near Mill Canyon which call into question DOE’s capacity and desire to adequately administer the entire state sludge program in fulfillment of its mission to “protect, preserve and enhance Washington’s environment for current and future generations.”