Thursday, September 27, 2012

Florida's DEP: Injecting Waste Under Our Feet

Excerpts from a PBCEC letter to Cathleen McCarty of the DEP's Underground Injection Control program,

The UIC is a dangerous program. It is an embarrassment to science and a threat to public health. I can only hope that I'm telling you something you already know.

I receive the UIC notices, and I am utterly disgusted with the amount of permits approved through this agency. Waste water should be treated above ground, where it can be responsibly managed and returned into the aquifer through a healthy and natural process, which can also provide possible restored habitat for wildlife. If the waste is too dangerous for this sort of treatment, then its creation should not have been permitted in the first place. This is common sense. Only extreme corruption and greed can argue otherwise.

Sadly, there is far too many permits deserving challenge for our group to keep up with. It seems perhaps only a karmic justice can stop this curse.

The following is an excerpt from a report entitled: Injection Wells: The Poison Beneath Us, by Abrahm Lustgarten, for ProPublica, published on this Summer's Solstice (June 21, 2012)

It features Florida's failures in waste water injection, among dozens of other examples. Please share this information with others in your office:

"...When sewage flowed from 20 Class 1 wells near Miami into the Upper Floridan aquifer, it challenged some of scientists' fundamental assumptions about the injection system.

The wells — which had helped fuel the growth of South Florida by eliminating the need for expensive water treatment plants — had passed rigorous EPA and state evaluation throughout the 1980s and 1990s. Inspections showed they were structurally sound. As Class 1 wells, they were subject to some of the most frequent tests and closest scrutiny.

Yet they failed.

The wells' designers would have calculated what is typically called the "zone of influence" — the space that waste injected into the wells was expected to fill. This was based on estimates of how much fluid would be injected and under what pressure.

In drawings, the zone of influence typically looks like a Hershey's kiss, an evenly dispersed plume spreading in a predictable circular fashion away from the bottom of the well. Above the zone, most drawings depict uniform formations of rock not unlike a layer cake.

Based on modeling and analysis by some of the most sophisticated engineering consultants in the country, Florida officials, with the EPA's assent, concluded that waste injected into the Miami-area wells would be forever trapped far below the South Florida peninsula.

But as Miami poured nearly half a billion gallons of partly treated sewage into the ground each day from the late 1980s through the mid 1990s, hydrogeologists learned that the earth — and the flow of fluids through it — wasn't as uniform as the models depicted. Florida's injection wells, for example, had been drilled into rock that was far more porous and fractured than scientists previously understood.

"Geology is never what you think it is," said Ronald Reese, a geologist with the United States Geological Survey in Florida who has studied the well failures there. "There are always surprises..."

Read the whole report here:

Thursday, September 20, 2012

Why we support the "No Build" option on FDOT's 710 Expansion plans

A view of the JW Corbett's hydric pine ecosystem
Letter of Public Comment
Re: FDOT's 710 Expansion plans

Sent to Patrick Glass, FDOT
Dated 9/20/2012

Of the alternate options presented on this road expansion plan, the Palm Beach County Environmental Coalition supports FDOT in pursing the "No Build" option. While we support increased public transit, and "shared-use" plans that improve bicycle and pedestrian transit, we do not see those things justifying this expansion. In fact, we suggest the FDOT spend the public money it saves in not pursuing this expansion to make those improvements where they are most needed (not where developer and industrial and political interests dictate, as this corridor plan seems to be doing.)

The following are some of our concerns:


Constructing this road expansion involves over 570 acres of wildlife habitat negatively impacted, or completely destroyed, based on FDOT's own documents:

-Freshwater marsh was the most prevalent habitat in the corridor, totaling 185.14 acres.
-There were approximately 105 acres of hydric pine flatwoods in the study limits.
-There were approximately 97 acres of wetland scrub in the study limits.
-A total of 84.84 acres of wet prairie were delineated within the SR 710 delineation corridor.
-Mosaics of wet prairie containing either sparse cypress or small stands of cypress often neighbored the areas delineated as cypress forests: 42.77 acres
-Roadside or railroad fringe areas that also contained slash pine were classified as wetland scrub with pine: approximately 33 acres of this habitat type.
-The total acreage of cypress within the study limits was 26.27 acres

All of these habitat provide food and shelter for wildlife species, many of which are currently listed as Threaten, Endangered or Species of Special Concern.

Encroachment into this habitat for road construction will also result in an increase of roadkill incidents for many species.

The PBCEC is currently in the process of collecting independent data on this matter, as we worry that any data collected through the permitting process will be insufficient, as we have found time and time again. And the recent "streamlining" of public policy and environmental permitting will certainly not help--the appropriate state agencies were already underfunded to adequately protect listed species prior to these cuts.

Moving forward with any alternative options besides "No Build" could likely subject the state to lawsuits for violating its own laws on habitat protection.


This loss of habitat results in negative impacts to recreational use, as much of the above listed acreage occurs on public land used for hunting, fishing, hiking, bird-watching, and other activities. A loss of wildlife and habitat impacts the recreation opportunities that these lands exist to provide to the public.

This information is further verified in your Habitat maps:


On top of the impacts losted above, there are another 5 "segments" to this road, which are being permitted in sections to avoid a unified review of permits and associated impacts, as illustrated here

Other parts of this project in various segments to the north and the south have already been contested for a variety of reasons including: historical significance; imminent domain takings of private property; and "environmental justice" issues (as defined in the Environmental Justice Act, regulated federally under NEPA), such as negative impacts to historically-marginalized Black communities in Riviera Beach.


According to FDOT doc:

"The revised study area includes The Port of Palm Beach to the City of Okeechobee in District 1. In addition, the expanded study adds considerations for... , the inland port, analysis of the global economy, economic competitiveness on a global, national and regional level including: Trade between North America, Europe, India, China."

This document is talking specifically about increasing cheap exports from environmentally-exploited countries (with less labor, health, and environmental regulations) coming through the Panama Canal into the Port of Palm Beach. This is an ethical issue of great concern which negatively impacts people around the world, including our own country.

For the reasons stated, as well as others to be presented later in the process, we will fight this road.
We will be joining with other residents, organizations and attorneys who share our concerns, and have their own. We will not stop until the plan is cancelled.

Panagioti Tsolkas
PBCEC, Co-Chair
(561) 249-2071

Sent on 9/20/2012 to:
SR 710 PD&E Study
Attention: Patrick R. Glass, P.E.
Florida Department of Transportation
3400 West Commercial Boulevard
Fort Lauderdale, FL 33309-3421