September 25, 2007

 

                                                                                            - Copyright Anthony Canales 2007

 

                           - View From a northern gate of the Green Acres

                              Bio-Solids Land Application Facility, near the

                              intersection of Interstate 5 and State Hwy 119

                              in California's "South A-Zone". Note the mountains

                              in the back-round-These are in the general

                              direction of Frazier Park and the Bitter Creek

                              National Wildlife Refuge.

 

 

"...Green Acres is the place for me.

     Farm livin' is the life for me.

     Land spreadin' out so far and wide

     Keep Manhattan, just give me that countryside..."

 

                                                    - Partial lyrics from the theme song for the

                                                      1965 television show of the same name.

 

 

To All,

     Is State Senator Dean Florez aware of what is going on in his district?

 

Condor Pasa Update-  The Answer Is Blowing In The Wind:

    One of the more frequent questions asked by lead ammunition ban advocates revolves around where else would condors "get the lead from" if not ammunition fragments left in carrion.

 

    Interestingly enough, simple research demonstrates a number of possible sources of soluble lead compounds in the condor's environment. What is more, public health data substantiates that these particular forms of soluble lead compounds are instrumental in elevated blood lead levels in humans. As such, they are capable of causing elevated blood lead levels in wildlife in the area, including a goodly number of condors raised in captivity, then released into portions of Kern County under the auspices of the current recovery program.

 

     One significant source of soluble lead compounds in the environment, but one that goes without hardly a mention in certain state reports supposedly designed to take stock of various threats to condors, involves bio-solids application activities in those areas of Kern County proximate to condor habitat. One of these is the City of Los Angeles' very own little slice of heaven, colloquially known as "Green Acres". (Note: Information about Green Acres and it's operation has been given to the California State Fish & Game Commission at it's June 2007 Hearing in Truckee, California. Said testimony can be had at http://www.cal-span.org/ ).

 

    The Green Acres facility itself consists of a livestock feed farm between 4845-5000 acres used for the dispersal of some 200,000 tons of "Class A EQ" bio-solids annually, which is the dehydrated and treated remainder of sewer sludge processed by Los Angeles' Hyperion Wastewater Treatment Plant. Los Angeles has been depositing bio-solids (otherwise politely known as "fertilizer") since about 1994, and had purchased the land outright in 1999 for a price of $ 9.63 million.

 

     In general, Class A EQ bio-solids are permitted to have certain approved "pollutant limits", which includes a number of heavy metals including lead. As noted on Page 29 of Chapter 2 of the EPA's " Guide to Part 503 Rule", the following concentrations are permitted for land application and home "gardening uses" (All other uses require disposal in an approved landfill):

 

 

              

    Using the Annual Pollutant Loading Rate Limit alone, the Green Acres facility is permitted to apply to the land enough bio-solids resulting in the deposition of over 29,000 kilograms (or more than 64,000 pounds) of soluble lead onto the land per each 365 day period of operation. Even if one were to use some of Hyperion's lower reported monthly averages, current annual deposition of soluble lead at only the Green Acres facility by itself can be over 12,000 lbs. Other bio-solids operations nearby in the Central Valley can only add to the current situation.

 

     Now, if the material deposited at the Green Acres facility were to somehow remain fixed to the fields themselves, there would most likely be nothing to worry about. But anecdotal reports by locals seem to indicate otherwise. What is more, personal observation back in June, during what has been labeled one of the driest drought periods on record, noted a great deal of dust lifting off of the posted fields in the general direction of Tejon Ranch, Bitter Creek National Wild Life Refuge, and possibly even the Hopper Mountain National Wildlife Refuge (Current campaigns by the Center for Biological Diversity note that pesticides can travel great distances, so one can wonder whether dust from bio-solids operations can go as far.).

 

    Of course, one could theoretically argue that dispersal would reduce exposure concentrations in such cases. But since inhalation of soluble lead compounds, in dust form, is a much more efficient way of absorbing lead into the body, it may just be that the dust fallout from Green Acres is having an impact so far ignored by biologists fixated on a pet hypothesis. Evidence of this last can be detailed from public health sources from across the country.

 

    For example, the Los Angeles County Department of Health Services operates a Childhood Lead Poisoning Prevention Program, which has recorded data about reported blood lead levels among children in the time period from 1991-2003. Two charts that come mind are as follows:

 

 

 

       

 

 

 

           

 

 

    Items of interest in the above noted charts include the total number of children with blood lead levels above 45 micrograms per deciliter (In 2003 there were 6 children reported after what appears to be a fall off in total children tested), and that significant sources of possible lead contamination include dust, take home (vapor or dust on work clothes) sources from working parents, and soil presumably contaminated with lead. Of course, in these cases, metallic lead ingestion is not indicated.

 

   Now, all of this may be "academic" were it not for the general requirement in the EPA's Rule 503 related to endangered species. Page 46 of Chapter Two of the EPA's "Guide to Part 503 Rule" reads as follows:

 

    "...The Part 503 rule prohibits the application of bulk biosolids to land if it is likely

         to adversely affect endangered or threatened species or their designated

         critical habitat. Any direct or indirect action that reduces the likelihood of

         survival and recovery of an endangered or threatened species is considered

         an ' adverse effect ' . Critical habitat is any place where an endangered or

         threatened species lives and grows during its life cycle. The U.S. Department

         of Interior, Fish and Wildlife Service (FWS) publishes a list of endangered

         and threatened species at 50 CFR 17.11 and 17.12.

 

         Practices that involve applying biosolids to lands (subjected to normal tillage,

         cropping, and grazing practices, or mining, forestry, and other activities that

         by their nature are associated with turning the soil and affecting vegetation)

         are not likely to result in any increase in negative impacts on endangered

         species and in fact may be beneficial given the nutritive and soil-building

         properties of biosolids. It is the responsibility of the land applier, however,

         to determine if the application of biosolids might cause an adverse effect

         on an endangered species or its critical habitat..."

 

     Hopefully there are allowances for the public to weigh in as well as to whether the deposition of thousands of pounds of heavy, hazardous metal compounds into the land, air, and possibly even water sources in "condor country" constitute actions that threaten certain listed species.

 

    As public officials continue the information gathering process, in the context of evaluating whether legislation should become the law of the land, or whether certain issues should somehow survive administrative rule-making procedures, it is certain that the public has a right to know the entire context of the issue involving the condor's recovery. The condor currently faces formidable hurdles of lethality that threaten the recovery of those birds raised in captivity and released to the wild, including such man-made objects as power lines, windmills, common trash related to human activities, diseases such as West Nile (Not to mention the possible advent of avian flu), and the general lack of natural biomass that the Department of Fish and Game notes is critical for condors to survive as required under the Endangered Species Act (Whether or not carrion left by hunters qualifies as a natural food source, for recovery purposes, may end up being resolved only in the courts). And why the caretakers of Gymnogyps californianus would want to release, on an artificial time-table, their charges into an environment so hostile to a bird specifically evolved for an ecosystem that existed 38,000 years ago also remains a mystery. Suffice it to say that as long as significant questions remain as to the efficacy of the current program, hurried or artificial timetables are not recommended at this time. Let the birds stay in captivity until all of the other real hurdles are surmounted.

 

Respectfully,