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EXPERT SCIENTIFIC REPORTS
Many expert reports have been issued, and many citizens have
questioned how the average layperson can make sense of
the conflicting expert reports coming from SGOD and from
LeylandAlliance. It isn't easy, of course.
Consider, however, who stands to make millions of
dollars from this project, and who stands to make
nothing. While money isn't always the whole story,
it's always a major factor.
No one involved with SGOD stands to profit from blocking
the construction of this development. LeylandAlliance, obviously, cannot say the same, nor can many
of the supporters of Madison Landing.
Furthermore, during the public hearings on the zoning
issue, Leyland refused
to provide any kind of guarantee that their wastewater
system would perform as promised. If they are so
sure that their experts' opinions are accurate, why
would they refuse to provide insurance to back up their
claims?
Robert Schreiber is an MIT-trained engineer and
specialist in wastewater flow who testified during the
Madison zoning hearings, and continues to serve as a consultant for SGOD.
From the beginning, Schreiber has maintained that the
engineering firm hired by LeylandAlliance, BL Companies
of Meriden, CT, has based its claims on insufficient
data, insufficient analysis, and circular reasoning.
With no data to support it, Leyland proposed that there
was a miraculous underground river from the
Griswold Airport site way out into Long Island Sound,
which would carry away all of the wastewater from the
site. This fairy tale has been soundly refuted
since then by SGOD's experts, but Leyland continues to
invoke such pseudoscience and wishful thinking to carry
its amended proposals forward.
In
this memo from
September 2005, Schreiber responds to BL Companies' report, dated August 18, 2005. He points
out repeatedly the inadequacy of their data collection,
and describes their results as
"questionable", "casual", "inappropriate", "not fully backed up by
data", "clear misrepresentations", and
more. Schreiber also provided detailed testimony
during the DEP hearings in Hartford, in May 2007.
Brian Howes, Ph.D.
is Professor of Marine Science and Technology at the University of
Massachusetts - Dartmouth, and the Director of their
Coastal Systems Program. He performed an extensive
review of all previous reports on the Griswold site, and
also his
own on-site study, to evaluate the potential for
damage to the Hammonasset tidal wetlands from the
Leyland proposal. He and his PhD student donned
hip waders and walked the site, toured the creeks by
boat, got their hands dirty, and took their own
measurements and samples. Dr. Schreiber points out
in his letter, outlined above, that Leyland has failed
to do this kind of careful data collection. Or
worse, perhaps they have done it, and suppressed
findings which were at odds with their agenda. We
have no way of knowing.
Dr. Howes provides
an outstanding overview of the plight of such estuaries
in general, and then of this one in specific. He
discusses the specter of losing the ecologic, aesthetic,
economic, educational, and recreational benefits of this
rare and precious resource. Dr. Howes' full report can be
read
here.
He provided additional detailed testimony during the DEP
hearings in May 2007.
Keith Ainsworth, Esq.,
who specializes in environmental law and serves as the
legal counsel for SGOD, summarizes key findings of Dr. Howes report in
this
letter to the Connecticut DEP. He emphasizes
the impact to the tidal wetlands not only from the
Amphidrome wastewater system, but also from increased
fertilizer use and the greater surface runoff.
Ainsworth notes that the impact on the Hammonasset River
estuary from Madison Landing is not permissible under
the Federal Clean Water Act, and he describes the Leyland wastewater model as "science
fiction".
LeylandAlliance
responded to the Howes report with an analysis written by Connecticut
College botanist Scott Warren. In his report, Warren recycles old data previously discredited by
Schreiber and Howes, makes no attempt even to appear
that he's providing any original information, and then
spins these flawed data into a set of outrageous
conclusions that fly in the face of common sense, never
mind objective science. He argues that the
freshwater discharge from Madison Landing would not only
not harm the estuary, but would enhance it! He
also concludes that the nitrogen loading (human waste)
from the Madison Landing wastewater system "...even
under the most pessimistic scenario, will have no
discernable impact on surrounding marshlands..."
These claims
simply don't pass the sniff test. If freshwater is
so good for the estuary, why don't we dig a freshwater
well there and start pumping it in? If human waste
will have no impact on the marsh, perhaps we could raise
some tax revenue by allowing septic system companies to
drive into the airport and dump their trucks' contents
into the estuary. Warren's claims, simply put, are
unbelievable. His report can be read
here.
In order to
generate a comprehensive response to the Warren report,
SGOD again consulted Brian Howes, Ph.D. Howes
composed a highly detailed analysis, which can be found
here.
Briefly, Howes concludes that the key assumptions and
conclusions made in Warren's report are inaccurate.
He notes that the Warren report relies heavily on
unsubstantiated assumptions which have not or cannot be
proven, and on making calculations based on previously
contested data (i.e. garbage in, garbage out). He
details the ways in which Warren grossly overestimates
the current nitrogen loading in the estuary, and thus
underestimates the impact of Madison Landing. He
also assails the viability of the Phragmites control
program proposed by Leyland, and again debunks the
pseudoscience of the underground river theory, for which
there is no evidence. See Howes'
full report for
details.
To follow up on
this report, Attorney Ainsworth wrote
this letter to
Warren Herzig of the Connecticut DEP Bureau of Water
Management. Ainsworth contrasts Howes' rational,
scientific report with Warren's insistence on using poor
data and wrong assumptions, and concludes: "A review of
the two reports leads me to believe that LeylandAlliance has become desperate and that it is not beneath
them to attempt to mislead the Department with
inaccurate and exaggerated claims." He also
reiterates that Warren's own report effectively
acknowledges that Madison Landing would transgress the
Federal Clean Water Act, by increasing nitrogen loading
in a water body designated as impaired.
Ainsworth
concludes with the following: "Given the mounting data
demonstrat-ing the failure of the Amphidrome Plus
system, the likely addition of nitrogen to an impaired
water body, Leyland's inexplicable continued reliance on
the underground pipeline to the Sound theory, and the
exposure of the end-result reasoning of Leyland's
experts' opinions, SGOD believes the Department must
issue a denial order to avoid the appearance of
supporting junk science."
Before either an
approval or denial order was rendered by the DEP,
Leyland "voluntarily" withdrew the Amphidrome Plus
system from consideration and substituted the Zenon
system. See The Issues
Today for further details on the change from
Amphidrome Plus to the Zenon system, and what we've
learned about the dismal performance of the Zenon system
at other Connecticut sites.
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