The poultry litter advisory group’s work has continued over the last month, and apparently the scope of work for the study has been drafted and circulated. I have not seen it made available for public review, although I have seen some of the comments – starting today, I will publish summaries of three of them, in full text. Even without seeing the scope of work itself, from these comments it is easy to draw conclusions about the direction of the scope of that study.
This first one is from an NPS stakeholder. I found it insightful not only for the commentary on the scope of work - the DEQ has apparently ruled out the consideration of air pollution in the current draft scope - but from a more general perspective on the health of Shenandoah National Park.
"…Although we do not have time for a more formal response to your email and the indicated changes to the scope of work, I do want to express that the National Park Service is disappointed in your decision to defer elements of air quality impacts in this review. Although we fully understand that it is difficult to assess air impacts without specific details that are normally provided in the regulatory/permitting process, we believe that some elements of air quality impacts need to be retained to inform the process.
"As you may know, Shenandoah National Park has been a research and monitoring site for air quality impacts for decades. There are few if any other sites in Virginia (or the mid-Atlantic) that are better studied.
"For example, the park and Western Virginia datasets provided by UVA are used by EPA as one of two study sites in the nation to evaluate Acid Deposition Recovery. The National Park Service, colleagues, and cooperators have developed hundreds of related publications on air quality trends and impacts. The impacts are chronic and, depending on the pollutant, few trends are improving.
"In a feasibility study as proposed, we believe that context is important. With the study focusing on a plant in the Shenandoah Valley - the information available from the decades of work noted in the above paragraph needs to be considered. The body of knowledge available is significant and important to use - even if a detailed air impacts modeling effort is not included in your study. The information available is wide ranging and covers many pollutants of concern - especially acid deposition.
"The focus of this group's work surrounds the impaired waters of the Chesapeake Bay. Shenandoah National Park has at least six watersheds that are listed by your agency as pH impaired due to acid deposition (air pollution). Other park data indicates that there are likely many more streams that should be included as impaired. A quick tally of the VA DEQ's 2010 report on statewide impaired waters indicate that roughly 150 or more watersheds in Virginia are currently listed as pH impaired. I wasn't able to tally the cause of impairment for all - but I suspect a significant portion [is] a result of acid deposition.
"Permitted poultry litter fired generating facilities in the U.S. and United Kingdom emit significant amounts of pollutants which are precursors to acid deposition. Annual permitted emissions from poultry incineration facilities compare to levels of some coal-fired generating facilities in VA. Again, without a basic review of these air pollutants in the study - in the context of cumulative effects to the airshed or how it may exacerbate already impaired systems - essentially avoids the widescale air pollution issues until the permitting process begins.
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