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EXPERT SCIENTIFIC REPORTS
Many expert reports have been issued during this battle, and many citizens
have questioned how the average layperson can make sense of
the conflicting reports coming from environmentalists and from the
developer.
It isn't easy, of course.
Consider, however, who stood to make millions from this
project, and who did not. While money isn't always the whole story,
it's always a major factor.
No one from the grassroots opposition stood to profit from blocking
the construction of this development. LeylandAlliance, obviously,
could not say the same.
Furthermore, during the public hearings, Leyland refused
to provide any kind of guarantee that their wastewater
system would perform as promised. If they were so
sure that their experts' opinions were 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 for SGOD during the
Madison Planning and Zoning hearings.
From the beginning, Schreiber maintained that the
engineering firm hired by LeylandAlliance based its claims on insufficient
data and insufficient analysis.
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.
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 served 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.
LeylandAlliance
responded to the Howes report with an analysis written by Connecticut
College botanist Scott Warren. In his report, Warren recycled
old data previously discredited by Schreiber and Howes,
made no attempt even to appear
that he was providing any original information, and then
spun his data into a set of
conclusions that are at odds with objective science and
common sense. He argued that the
freshwater discharge from Madison Landing would not only
not harm the estuary, but would enhance it! He
also concluded 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..." Warren's claims, simply put,
were not believable. His report can be read
here.
In order to
generate a response to the Warren report, opponents of
the plan 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 relied heavily on
unsubstantiated assumptions which have not or cannot be
proven, and on making calculations based on previously
contested data. He
details the ways in which Warren grossly over-estimates
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. 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. 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.
Before the DEP
rendered a decision, Leyland withdrew the Amphidrome Plus
system from consideration and substituted the Zenon
system, another system which is inappropriate for this
site. For more about the Zenon system, click
here
and
here.
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