COLORADO WATER PLAN
To Governor Hickenlooper and the Colorado Water Conservation Board,
My name is Crystal Edmunds, and I am currently a graduate student at the University of Denver, studying Global Finance, Trade and Economic Integration with a focus in environmental security. In my second year of school, I interned for Water for People in Denver, CO, mostly writing due diligence reports. The organization currently works in nine countries around the world: Honduras, Guatemala, Nicaragua, Bolivia, Peru, Malawi, Rwanda, Uganda, and India-- bringing together local entrepreneurs, civil society, governments and communities to establish creative, collaborative solutions that allow people to build and maintain their own reliable and safe water systems.
For the past two years, I have worked as an AmeriCorps volunteer through the Western Hardrock Watershed Team with the Coal Creek Watershed Coalition in Crested Butte, CO, primarily involved in capacity building. This summer, I started interning with the Upper Gunnison River Water Conservancy District in Gunnison, CO, focusing on community development. Perhaps it was growing up on the banks of the Maumee River in Ohio, but my life seems to be perpetually linked to water! The more I learn, the more I recognize the profound significance of this natural resource and how much more energy needs to be directed toward its protection.
In the following pages are my major concerns regarding Colorado's Water Plan: Water quality standards for arsenic, fluoride and nutrients Fracking, outdated mining laws, abandoned mines, rare earth element mining Pesticides in agriculture and noxious weed control Chemical Regulation Environmental Education Environmental Health
Thank you for your work! Sincerely,Crystal Edmunds
Water Quality Standards_____________________________________________________________
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Arsenic
Perhaps my favorite part of working with the Coal Creek Watershed Coalition was researching, following
the process of and attending the April 2013 arsenic rulemaking at the Colorado Department of Public
Health and Environment. Crested Butte is impaired for arsenic, partly from historic mining and partly
because its geology. A major part of the work of the CCWC was to discern the contamination to the
watershed of arsenic from mining.
I had first learned of arsenic through interning at Water For People in Denver: Three decades ago,
health and development experts and local contractors dug millions of deep tube wells throughout
Bangladesh, encouraging the whole nation to drink well water because it was deemed to be safe, free of
the bacteria that causes water-borne diseases such as diarrhea and other intestinal maladies that have
long plagued the country. However, in switching from rivers and other surface sources of water, the
people of Bangladesh may have exchanged water-borne diseases for arsenic. In the 1970's public health
specialists and government policy-makers were unaware of the problem. It was only in 1993 that "clean"
well water was discovered to contain dangerous quantities of the metal. According to the World Health
Organization, estimates of contamination vary from a low of 28 to 35 million to a high of 77 million—
more than half the population of Bangladesh, one of the most crowded nations on the planet. It is
estimated that over a million Indians are also drinking arsenic-laced water. Newer cases of arsenic
poisoning in the Ganges Basin suggest that many of the region's 449 million residents are at risk.
Arsenic is the number one environmental health concern worldwide-- and is ranked number one on the
federal list of the top 275 most hazardous substances found at toxic waste sites. Exposure to high levels
of the metal can cause cancers of the skin, bladder, kidney, and lung, and diseases of the blood vessels
of the legs and feet, as well as possibly diabetes, high blood pressure, and reproductive disorders. It's
also linked to kidney, nasal, liver and prostate cancers. The predominant cancer risk is through drinking
water. Inconsistencies remain in the studies of arsenic carcinogenesis, but the main point is this: even
though much remains to be learned about how arsenic causes cancer, there is no doubt that it does. If
indeed arsenic is an endocrine disruptor as well as a silencer of cancer-protecting genes, then no safe
level of exposure may exist.
This is incredibly relevant with the development of transportation and tapping into groundwater
throughout the state-- as arsenic is found in bed rock, from which it can leach into groundwater or rise
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to the surface when coal or metal ores are mined. As a result of irrigation, arsenic is brought from the
subsurface to the soil surface. An increase in arsenic concentration in the soil surface, as a result of
irrigation, can detrimentally impact crop growth and is a source of entry of arsenic to the food chain.
Ground-water resources currently supply approximately 18 percent of the state’s needs and ground-
water development is continuing at a fast pace. However, the technology does not exist to detect
arsenic levels that EPA officials are pushing to reduce the standard to.
Boulder is the first in the state to have an arsenic effluent standard in its discharge permit; it has the
in house capability to test for arsenic at low standards, while in prior years there were only two labs in
the United States they were able to use for testing.
SUGGESTIONS FOR THE PLAN REGARDING ARSENIC CONTAMINATION
Utilize Boulder's arsenic action plan as a model for the state: channel more funding to water
treatment research and development, including ion exchange, reverse osmosis, and electric
dialysis.
Analyze construction dewatering rules statewide.
Develop more methods of education on the Colorado Primary Drinking Water Regulations.
Collaborate with Water for People on outreach!
Get the public more involved in water quality stakeholder groups by the next rulemaking in
2016.
Determine if there is substantial bioconcentration of arsenic occurring in Colorado’s surface
waters, and if so, determine the extent of this bioconcentration.
Fluoridation
"We make the mistake in reasoning that the fluorine in the water is the cause of the better teeth, when
we should look to the presence of liberal amounts of the calcium-bearing and phosphorus-bearing
apatite putting more calcium and more phosphorus in the foods at the same time that by decomposition
it is putting fluorine into the water percolating down through the soil." - Dr. William A. Albrecht,
Fluoridation of Public Drinking Water
Fluoridation was first advanced in the US at the end of the second World War, and it is now in about two
thirds of the water supply in the US. Proponents argued that fluoride in water and toothpaste would
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help to protect teeth and prevent decay. Over the following decades, fluoride was added to public water
supplies across the country. Fluoride is a key ingredient in industry used for making aluminum, steel,
high-octane gasoline, and for enriching uranium. The real issue was in "greenwashing" the pollution
from these industrial plants and pollution, as industries are responsible for potential damage for injuries
to workers. A medical study commissioned by industry at the University Of Cincinnati in the 1950s
showed that fluoride is profoundly injurious to lungs and lymph nodes in experimental animals. That
study was buried. Today the fluorides that goes in our drinking water is almost exclusively raw industrial
pollution from the Florida Phosphate Industry. It’s a waste that’s scrubbed from the smokestacks and
trucked in tankers and dumped into reservoirs.
While the benefits of fluoridation have been held to be unquestionable, accumulating evidence points to
a alternative prospect: that fluoride may have serious adverse health effects, including infant mortality,
congenital defects and decreasing IQ1. Fluoride poisons enzymes; the halogen inhibits many enzymes by
binding with the metal ions they require in order to function. It inhibits others by a direct poisoning
action of their protein content. Fluoride also has a toxic effect on genes and gene function; research at
the International Institute for the Study of Human Reproduction, Columbia University College of
Physicians and Surgeons, as well as at the University of Missouri, has proved that fluoride is mutagenic,
i.e. it damages genes in mammals at doses approximating those humans receive from artificial
fluoridation exposure.
Fluoride is used by the body in a desperate attempt to replace iodine if the body is deficient in iodine.
Any person without proper iodine levels invites fluoride mimicking iodine. The body then attempts to
utilize the fluoride as though it was iodine, always unsuccessfully. In the process, it shuts down all the
clinical pathways to the thyroid. Fully 71 pathways, or enzymes, thus become annihilated. Enzyme
construction and thyroxin utilization become the observed and measured results. Fluoride also has the
capacity to bind lithium in the brain2.
SUGGESTIONS FOR THE PLAN REGARDING FLUORIDATION
1 Democracy Now. "The Fluoride Deception: How a Nuclear Waste Byproduct Made Its Way Into the Nation’s Drinking Water."
<http://www.democracynow.org/2004/6/17/the_fluoride_deception_how_a_nuclear>.
2 Walters, Charles. "Minerals for the Genetic Code: An Exposition and Analysis of the Dr. Olree Standard Genetic Periodic Chart and the Physical, Chemical and Biological Connection."
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End fluoridation of drinking water.
Mining____________________________________________________________________________
Outdated Mining Laws, Abandoned Mines
There are an estimated 500,000 abandoned hardrock mines in the West, according to Earthworks. The
US Bureau of Mines estimates that 12,000 miles of the waterways of the Western US, or about 40
percent, are contaminated by metals from acid mine drainage, mostly by abandoned mines, while
abandoned mine runoff continues to taint 180,000 acres of lakes. In Colorado, 2,751 abandoned mine
sites have possible impacts on water quality in 20 watersheds. All too often, no viable financially
responsible party exists for the abandoned mines. While the water quality in the vicinity of the mine
continues to be impaired, no one can be held responsible for cleaning it up. Further, the General Mining
Law of 1872 (GML) continues to regulate the extraction of hardrock minerals; according to Jane
Danowitz, public lands director for the Pew Environment Group, in a New York Times interview, "This is
a law that basically hasn't been changed in almost 140 years." As the GML allows mining companies to
take approximately $1 billion annually in metals from public lands without payment of a royalty, funds
for remediation efforts are not sufficient for the task.
While Superfund was developed to address abandoned hazardous waste sites when liable parties no
longer exist or either cannot or will not undertake a cleanup, it too lacks the necessary funds. Under the
Superfund law, the EPA was ordered to develop a list of more than 400 priority sites nationwide, at least
one in each state. The agency soon recognized that the scope of the problem was much larger,
estimating that 2,000 sites would ultimately be included on the National Priorities List. In 1985, as the
original legislation was about to expire, the now disbanded Office of Technology Assessment (OTA)
issued its report—Superfund Strategy—which concluded that the magnitude of the hazardous waste
problem was much larger than most lawmakers had envisioned. According to the OTA, the number of
sites could mushroom to more than 10,000, requiring cleanup efforts over a span of perhaps 50 years.
The report estimated that costs borne by Superfund could reach $100 billion and that overall costs to
the nation could total several times that amount. The Superfund program has in past received funding
from two sources: general funds from the Treasury and balances in the Superfund trust fund. In earlier
years, revenues for the trust fund came from three dedicated excise taxes and an environmental
corporate income tax. Those taxes expired in December 1995, and the amount of unobligated money in
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the fund declined to zero by the end of FY2003. The program is currently charged with the cleanup of
nearly 1,300 hazardous waste sites across the country; one in four Americans live within three miles of a
contaminated site posing serious risks to human health and the environment, according to the EPA.
For those concerned with job creation, think of how many jobs we can create through environmental
remediation efforts from historic mining and beyond. The economic crash and crisis of the past years
can be transformed into a catalyst for a new economic paradigm-- an economy that is not based off of
70 percent consumption, but creative thought, the health of the environment and subsequent
biodiversity.
Fracking
Before fracking much of Colorado, we collectively need to analyze the environmental, economic and
social impacts from historic mining to understand fracking’s potential ramifications. Over half of all the
shale gas ever developed in the world has been produced in the last three years, which has resulted in
nearly all of the peer-reviewed scientific research on the environmental and public health consequences
of shale gas having been done in the last year and a half. Environmental regulation remains incomplete.
The hydraulic fracturing process itself is exempt from seven major federal regulations:
• The Clean Water Act and Safe Water Drinking Act: The Safe Drinking Water Act's Underground
Injection Control program protects underground sources of drinking water from contamination by
injected fluids. In 2005 the Energy Policy Act amended the Safe Drinking Water Act to exclude
hydraulic fracturing from the definition of "underground injection.";
• the Resource Conservation and Recovery Act, which has exempted all oil and gas exploration and
production wastes from federal regulations pertaining to hazardous waste since 1988;
• the Superfund law, which requires that polluters remediate for carcinogens like benzene released
into the environment, except if they come from oil or gas;
• the Comprehensive Environmental Response, Compensation, and Liability Act, which excludes
parties involved in oil or natural gas that have contributed to environmental mess from legal
responsibility for the cost of cleaning it up. CERCLA excludes oil and gas products and any chemicals
contained in them (unless otherwise regulated);
• the National Environmental Policy Act, which requires government agencies to consider the
environmental impact of their actions, and requires public comment and evaluation of alternatives
through an environmental impact statement process when a significant impact is likely. The 2005
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Energy Policy Act created a categorical exclusion for some types of oil or gas well expansions,
allowing them to occur with limited review. The public now has to prove significant harm to
challenge anything on the basis of NEPA violations.
• the Toxic Release Inventory under the Emergency Planning and Community Right-to-Know Act,
which the oil and gas industry is exempt from reporting releases of toxic materials in the Toxic
Release Inventory.
• the Clean Air Act, which requires the EPA to list major and clustered minor categories of sources of
air pollution, but has not included wells or fields allowing operators to avoid emissions controls
standards.
In the past year, Colorado, Texas and Pennsylvania have moved to tighten state regulations and require
mandatory disclosure of what's in the fracking fluids, but loopholes still remain. "We don't know the
chemicals that are involved," Vikas Kapil, chief medical officer at the National Center for Environmental
Health, admitted at a recent conference.
"We don't have a great handle on the toxicology of fracking chemicals." Dr. Theo Colburn of the
Endocrine Disruption Exchange has spearheaded research on the toxicology of fracking chemicals,
paying particular mindfulness to endocrine disruption. Endocrine-driven disorders include ADD and
autism. She noted in a 2010 Democracy Now interview that 944 chemicals are used in natural gas
extraction, and that we know between 95 and 100 percent of about 14 percent of the chemicals that are
being used, and nothing is known about 43 percent of the products in use. Shale gas development has
already caused significant surface water pollution. Fracking fluids extract chemical substances from
shales, including toxic and carcinogenic aromatic hydrocarbons, toxic metals, and radioactive materials.
Some of these materials are released to the environment when blowouts and other accidents occur. A
greater route of release and exposure comes from disposal of frac-return fluids. Approximately 20
percent of the material used in hydraulic fracturing flows back to the surface in the first few weeks after
fracturing with all of the added and extracted chemical substances.
Rare Earth Elements
US Rare Earths said in a release that it has staked additional claims in the area beyond its 4,000-acre
holding Colorado's Powderhorn mineral belts. Thorium has been found since 1949 in at least 33 deposits
in an area six miles wide and 20 miles long in the Powderhorn district, Gunnison, CO; the district has
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long been known for its alkalic igneous rocks, of which the best known are those of the Iron Hill
composite stock. The district is drained by three northward-flowing tributaries of the Gunnison River:
Willow Creek, Cebolla Creek, and the Lake Fork of the Gunnison.
US Representative Hank Johnson reintroduced the Resource Assessment of Rare Earths (RARE) Act of
2013 to Congress in March 2013. It is a bill aimed at securing rare earth supplies and reducing China’s
monopoly on the market. RARE directs the United States Geological Survey (USGS) to conduct a three-
year, comprehensive global mineral assessment of rare earth elements (REEs). The USGS global
assessment, conducted with geological surveys of partner nations around the world, will identify and
quantify individual rare earth elements in known deposits, improve understanding of the distribution
and formation of rare earth element deposits, assess likely undiscovered deposits worldwide, analyze
the state of the complete rare earths supply chain from mining to manufacturing, and recommend
further research and steps to improve our understanding and ensure access.
SUGGESTIONS FOR THE PLAN REGARDING FRACKING, ABANDONED MINES, OUTDATED MINING
LEGISLATION AND THE MINING OF RARE EARTH ELEMENTS
Clarify potential disposal options for wastewater and other wastes containing radioactivity.
Encourage congressional members to pass General Mining Law reform, the Good Samaritan
Law, the federal budget with the hardrock mining language intact, reinstating Superfund taxes--
and demanding parallel regulations and taxation for the hydraulic fracturing industry.
Push legislation that would allow western states to tap federal funds earmarked for coal mine
clean-up and use them to address safety and environmental issues at abandoned hard rock
mining sites instead.
o In Colorado, the law’s passage would mean that the Division of Reclamation, Mining
and Safety would be able to afford to take on approximately 100 additional projects
annually for the next few years.
Support further studies on radioactivity before allowing rare earth element and uranium mining.
Regulate the hydraulic fracturing process under the follows laws and acts:
o The Clean Water Act and Safe Water Drinking Act;
o the Resource Conservation and Recovery Act;
o the Superfund law;
o the Comprehensive Environmental Response, Compensation, and Liability Act;
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o the National Environmental Policy Act;
o the Toxic Release Inventory under the Emergency Planning and Community Right-to-
Know Act;
o and the Clean Air Act.
Agriculture________________________________________________________________________
Fertilizers & Pesticides in Agriculture and Weed Control
The recent algal bloom crisis in Toledo warms us of the harms of excess nitrogen and fertilizer-- it also
debunks the no-till, nitrogen and phosphorus fertilizer-heavy, mono-culture agricultural paradigms
perpetuated by Cargill, Monsanto and the like.
Nutrients
Nutrient pollution from fertilizers is a leading cause of degradation of U.S. water quality, and nitrogen
and phosphorus are the nutrient culprits. While it has been discussed at the national and state levels for
many years, nutrient pollution is difficult to define and address because of the widespread use of
fertilizers in agriculture and landscaping. According to the National Academy of Sciences, even though
farmers use pesticides more widely, homeowners use 10 times more fertilizer per acre. Treated sewage
is also a major contributor of nutrient pollution.
Nitrogen and phosphorus together support the growth of algae and aquatic plants, which provide food
and habitat for aquatic life. However, excess nitrogen and phosphorus in aquatic systems can stimulate
over- production of biomass, leading to changes in biological integrity. Harmful algal blooms negatively
impact the food web by decreasing the amount of nutritious, edible phytoplankton that zooplankton
and other primary consumers need to survive. These organisms may then starve, leading to decreased
food for higher order consumers such as fish. Harmful algal blooms can block sunlight from
phytoplankton under the water’s surface, leading to decreased food and oxygen levels. When harmful
algal blooms begin to break down and die, they can decrease dissolved oxygen levels, a change that
can be lethal to other aquatic organisms and cause fish kills. The toxins produced by harmful algal
blooms are a concern for human health-- they are possible carcinogens to humans, and current
research is studying the link between certain cyanobacterial toxins and neurological diseases such as
Lou Gehrig’s disease. The most common toxin is called microcystins. There are at least 60 different
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types of microcystins, and their toxicity can vary significantly. The WHO standard for microcystin-LR in
drinking water is 1.0µg/L, but there are no similar standards for waters in the United States.
Toxins of mycrocystins:
Toxin Types Examples Effects
NeurotoxinsAnatoxin-a, anatoxin-a(s), saxitoxin,
neosaxitoxin
Affects central nervous system, causes
seizures, paralysis, respiratory failure,
and death
HepatotoxinsMicrocystins, nodularins,
cylindrospermopsin
Affects liver, causes hemorrhaging,
tissue damage, tumors, liver cancer,
and death
Dermatotoxins and
Gastrointestinal toxins
Aplysiatoxins, lyngbyatoxin-a,
lipopolysaccharide endotoxins
Affects skin and mucous membranes,
causes rashes, respiratory illness,
headache, and stomach upset
Cytotoxins Cylindrospermopsin
Affects liver and other organs; causes
chromosome loss, DNA strand
breakage, and organ damage
I am thankful that in March 2012, Colorado passed new rules to tackle nutrient pollution, yet
disappointed that agriculture is not be regulated. Agriculture remains the main source of nutrients; it
would be very wise for Colorado's Water Plan to make this amendment.
German scientist Justus Von Liebig was responsible for the theory that Nitrogen, Phosphorous, and
Potassium levels are the basis for determining healthy plant growth. However, this theory, which dates
to the 1800s, doesn't take into account the dozens of other nutrients and elements that are essential to
plant growth such as sulfur, hydrogen, oxygen, carbon, magnesium, etc. Nor does the theory talk about
the importance of beneficial soil organisms that help plants fight off pests and diseases3. In fact,
elements such as carbon, hydrogen, oxygen, sulfur, magnesium, copper, cobalt, sodium, boron,
molybdenum, and zinc are just as important to plant development as N-P-K4.
3 Explanation of NPK and fertilizers. <http://www.cleanairgardening.com/npkexplanation.html>. 4 Garrett, Howard. “Plants for Texas.” <http://www.utexas.edu/utpress/excerpts/exgarhow.html>.
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o People who depend on rural, private wells for their water source have one of the higher rates of a
condition called Methemoglobinemia, aka Blue Baby Syndrome, which damages blood cells and is
traced to high Nitrates5.
o Reactive nitrogen increases atmospheric ozone levels, causing respiratory diseases and hurting crop
yields and produces acid rain. To top it off, oceanic nitrogen is converted to nitrous oxide, a
greenhouse gas6.
o The kind of nitrogen typically found in chemical fertilizers dissolves very quickly in water. This means
that excess nitrogen may find its way into groundwater and freshwater sources and contaminate the
water. Additionally, many chemical fertilizers are now using phosphoric acid to create a high
phosphorous content quickly and cheaply; this kind of phosphorous essentially neutralizes other
important trace minerals from the soil that plants need.
According to Sandra Steinberger's "Raising Elijah," in 2009, nitrogen fertilizer was used on nearly all
conventionally grown durum wheat, 94 percent of other spring wheat, and 83 percent of winter
wheat. In 2009, 2,968,000,000 pounds of nitrogen fertilizer were used to grow America's wheat in
2009. Almost all of these nearly three billion pounds were created from natural gas. Five percent of
global natural gas reserves is turned into nitrogen fertilizer-- all by itself, the United States consumes
2.2 billion pounds of nitrogen fertilizer a year. Do we really want the whole world's agricultural system
to ride a tandem bicycle with the oil and gas industry? Further, a 2010 health ranking study undertaken
by the Robert Wood Johnson Foundation showed that some of the least healthy counties in the US are
located in bumper crop regions. And yet, for many of these counties, the list of their underlying
problems include the phrase: "lacks access to healthy, affordable food."
Pesticides
The first systematic comparison of pesticide residues in organic and nonorganic foods was carried out in
2002. Examining the data from more than 90,000 samples of produce, the authors of this study found
that nearly three-quarters conventionally grown foods had detectable pesticide residues. Three quarters
of organic crops had none. Organophosphates block the action of an enzyme that regulates a
neurotransmitter and are thus brain poisons. Assessing the power of pesticides to influence children's
5 Keim, Brandon. “Reactive Nitrogen: The Next Big Pollution Problem.” Wired Science. May 15, 2008. <www.blog.wired.com/wiredscience/2008/05/reactive-nitrog.html>. 6 Keim, Brandon. “Reactive Nitrogen: The Next Big Pollution Problem.” Wired Science. May 15, 2008. <www.blog.wired.com/wiredscience/2008/05/reactive-nitrog.html>.
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hormones is the part of the job mandated by the Food Quality Protection Act-- though it is not yet done,
even though the EPA was originally given a 1999 deadline.
2, 4-D is an herbicide that has been linked with birth defects.
Chlorpyrifos is an organophosphate that has been linked to cognitive deficits in children.
Emerging evidence also links it to autism. Organophosphate pesticides in particular can induce
spasms in bronchial tubes and contribute to airway hyperactivity by altering the functioning of
nerves that supply the muscles of the airways. Organophosphates interfere with the recycling of
the neurotransmitter acetylcholine, one of the messaging signals that flow between neurons.
The second most common pesticide used in the US, atrazine, enhances the production of an
enzyme called aromatase, which is used by the body to convert testosterone into estrogen. The
end result is higher estrogen levels. Like children, amphibians are uniquely sensitive to
pesticides. Trace exposure to the weed killer atrazine has been found to emasculate male
tadpoles-- in a recent study, male frogs exposed to atrazine turned into fully functional females
that mated with males and produced eggs. According to researchers at the National Institute for
Environmental Health Sciences, 60 percent of Americans are exposed, mostly through drinking
water, to atrazine. In 2006, in spite of the remaining uncertainties of atrazine's health effects,
atrazine was banned for use in the European Union. Along with phthalates, PCBs, and air
pollution, atrazine appears on the list of chemicals with demonstrable links to shorter pregnancy
and lower birth weights.
There is no national pesticide registry in the US. Farmers are not required-- as are manufacturers-- to
report their chemical releases.
In a 2007 study, a team of biologists at the University of Michigan concluded that legumaceous cover
crops could fix enough nitrogen to replace all the fossil-fuel derived fertilizer now in use. Thus, they
dispute the idea that organic agriculture is constrained by lack of nitrogen. More centrally, the same
research team disputes the evidence that organic farming suffers from lower yields. In a review of 293
studies that compared yields of organic and conventional farms in both developed and developing
nations, researchers found parity. In the US, yields on organic farms were about 92 percent of the yields
produced by conventional agriculture, whereas in developing countries, yields were actually higher.
Organic farming prohibits the use of synthetic pesticides. Organic acres still only account for 0.7 percent
of total US crop acreage. Of US cows, 2.7 percent are raised organically. Of US egg-laying hens, 1.5
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percent are raised organically. In essence, organic agriculture is a form of farming that replaces synthetic
chemicals with ecosystem services. Organic agriculture sows the seeds of its own preservation.
Weed Control
I am calling for an alternative approach to noxious weed management; the new field of ecology, invasion
biology, sprang forth from Charles Eton in just 1958. Seen from a different perspective, the development
termed "invasion" could also be described as vegetation dynamic or successional change that is a
natural process of plant species and ecosystems to deal with disruptions and openings. In addition to
widespread physical alterations to landscapes, massive upheavals to ecosystems occur from
contamination by numerous invisible pollutants that have leached into the water, soil, and air. In such
disturbed ecosystems, many of the native plants are poisoned and are less able to deal with upheaval,
but the weedy, invasive plants cope well and even flourish in the toxic surroundings. For example,
Canada thistle, bindweed, leafy spurge, sowthistle, knapweed, and yellow star thistle displayed a
significant growth response (110 percent) to increasing CO2 levels during the twentieth century, with
the growth anticipated to be an additional 46 percent over the next 100 years. Overused and depleted
rangelands are the areas most in need of thistle; it keeps foraging cattle from such lands and
discourages farmers with its virulence. Thistle's roots aerate the generally hard soil of improperly
managed rangeland, and over time, the plant increases biomass to restore and conserve the topsoil
from blowing away.
By the dawn of the twentieth century, laws were passed by the US Congress to control the plants that
impeded the progress of the great agricultural machine. The regulations started with the Lacey Act of
1900, follow by the Plant Pest Act, the Plant Quarantine Act, and the General Noxious Weed Act of
1974, in which were targeted plants that "can directly or indirectly injure crops, other useful plants,
livestock, poultry, or other interests of agriculture, including irrigation, navigation, fish and wildlife
resources, or the public health. Cornell University claims that each year the US spends 34.7 billion
dollars in fighting noxious weeds7.
SUGGESTIONS FOR THE PLAN REGARDING AGRICULTURE, NUTRIENT POLLUTION & PESTICIDE USE
Support organic agriculture.
Support perennial grain production.
7 Lee Scott, Timothy. "Invasive Plant Medicine: The Ecological benefits and healing abilities of invasives."
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Regulate agriculture for nutrient pollution, eventually discontinuing use of synthetic fertilizers as
well as nitrogen and phosphorus rich fertilizers-- -- opting instead for legumaceous cover crops
to fix nitrogen.
Support studies of growing hemp to absorb excess nutrients.
Support research of mycrocystins.
Develop a standard for microcystin-LR in drinking water.
Develop mandatory testing of algal-bloom heavy areas for mycrocystins. Thus, support new
technologies to monitor pollution levels in the environment. EPA is studying innovative
technologies that will measure nutrient pollution in the air and water using satellites, portable
and ground remote sensors as well as measurement and model data. These technologies
enhance current monitoring activities and also provide cheaper and faster information on
nutrients and other pollutants.
Oregon and Washington in the U. S. have fertilizer registration programs with on-line databases
listing chemical analyses of fertilizers-- create the same in Colorado.
Create a functioning endocrine-screening program, with validated protocols, as mandated by
the 1996 legislation.
Chemical Regulation_________________________________________________________________
According to Sandra Steinberger's "Raising Elijah: Protecting our children in the age of environmental
crisis," only 200 of the more than 80,000 synthetic chemicals used in the United States have been tested
under the Toxic Control Substances Act of 1976, and exactly none of them are regulated on the basis of
their potential to affect infant or child development. Current laws do not require the screening of
chemicals for their ability to damage or alter pathways of brain growth, and only about 20 percent of
the 3,000 chemicals produced in high volume in the US have been tested for developmental or pediatric
effects. Further, of the 300-odd chemicals that are presumed ingredients of fracking fluid, 40 percent
are endocrine disruptors and a third are suspected carcinogens. A third are developmental toxicants.
Over 60 percent can harm the brain and nervous system.
SUGGESTIONS FOR THE PLAN REGARDING CHEMICAL REGULATION
Provide support for the Toxic Chemical Safety Act. Chemical reform should be based on the
precautionary principle.
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Education_________________________________________________________________________
According to the National Environmental Education Foundation, the average American adult,
regardless of age, income, or level of education, mostly fails to grasp essential aspects of
environmental science, important cause/effect relationships, or even basic concepts such as runoff
pollution, power generation and fuel use, or water flow patterns. For example, about 80 percent of
Americans are heavily influenced by incorrect or outdated environmental myths; just 12 percent of
American can pass a basic quiz on awareness of energy topics.
Further, NEEF asserts that national studies indicate that 47 percent of all natural resource agency field
staff and 77 percent of all leadership staff are expected to retire by 2015, leaving a void in outdoor
and science positions in Colorado and across the nation. Nearly one third of children in Colorado live
in neighborhoods without a park, playground, recreation center, trail, or other safe place to play.
Thus, in addition to environmental literacy, Colorado schools and community providers must promote
outdoor recreation, such as hunting, fishing, archery and adventure education, to ensure all
Coloradoan students have the opportunity to foster connections and routines in the outdoors.
Colorado teachers and students have worked on wetland creations, xeriscaping, windbreaks, nature
trails and urban wildfire habitat projects around their schools.
Professional environmental educators often give short shrift to the media. But children get more
environmental information (83 percent) from the media than from any other source. For most adults,
the media is the only steady source of environmental information.
SUGGESTIONS FOR THE PLAN REGARDING ENVIRONMENTAL EDUCATION
Set a goal that a greater number of Colorado Schools become U.S. Department of Education
Green Ribbon Schools (ED-GRS) in Colorado. Typical characteristics of these award-winning
schools is that they exercise a comprehensive approach to creating “green” environments
through reducing environmental impact, promoting health, and ensuring a high-quality
environmental and outdoor education to prepare students with the 21st century skills and
sustainability concepts needed in the growing global economy.
Encourage environmental education partnerships with the media.
Support experiential learning and school gardens.
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APPENDICES In 1860, humanity produced 15 metric tons of reactive nitrogen. By 1995, that number stood at 156 tons, and swelled to 185 tons by 2005. Those numbers are small in comparison to global CO2 emissions — 27 billion tons annually — but the impacts are magnified by what James Galloway, a University of Virginia biogeochemist and co-author of the review, calls the nitrogen cascade8.
8 Keim, Brandon. “Reactive Nitrogen: The Next Big Pollution Problem.” Wired Science. May 15, 2008. <www.blog.wired.com/wiredscience/2008/05/reactive-nitrog.html>.
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