27 October 2010

ITT "Value of Water" Survey: Will it motivate infrastructure funding?

This morning I was watching a live feed from the CSIS Conference on "Bridging Knowledge Gaps in Water Management" (blog post forthcoming), during which an industry representative mentioned that ITT was releasing a new report on water at the same time. That report (pdf) released today comes from ITT's Value of Water Survey in which 1,003 registered voters and 500 industrial and agricultural businesses across the country were polled on their concerns within a selected set of "external" values. The result, in a nutshell, "reveals that Americans are ready to fix our nation's crumbling water infrastructure."

But the question is not whether the American people and businesses want the infrastructure fixed, but how much we're willing to pay for our government (and their private contractors) actually and finally to make the necessary repairs and upgrades. The American Society of Civil Engineers has been showing us for a decade now the declining state of critical infrastructure in their biannual "Report Card on America's Infrastructure." Their latest results from 2009 gave academic-like grades to the nation's dams (D), drinking water systems (D-), inland waterways (D-), levees (D-), and wastewater systems (D-), among other systems. One wonders, especially viewing the footage gathered by the ASCE, what evidence it would take for a failing grade in an infrastructure sector...

Anyway, ITT's survey details are interesting, because they give us (those in water as an object of vocation and profession...or obsession, if you prefer) not only a sense of the public's awareness of water issues in general, but also a deeper look into the public's valuation of water. According to the official press release accompanying the survey report,
"The survey found that nearly one in four American voters is 'very concerned' about the state of the United States' water infrastructure. In fact, the nation's pipes, treatment and delivery systems -- everything that gets clean water to homes and takes dirty water away -- are crumbling under the combined pressures of population growth, urbanization and chronic underinvestment. Every day in America, 650 water mains break, or one every two minutes. According to the U.S. Geological Survey, these breaks and other leaks result in the loss of roughly 1.7 trillion gallons of water every year -- enough to supply water to 68 million Americans.

"'Water is a necessity, but our survey confirms that most people take access to clean tap water for granted,' said Gretchen McClain, president of ITT Corporation's Fluid and Motion Control business. 'Indeed, water is one critical issue missing from the national infrastructure debate. Yet when presented with the facts, Americans recognize a looming crisis and are willing to pay their share to properly maintain the systems that bring clean water into their homes.'

"ITT's survey revealed that 63 percent of all American voters are willing to pay an average of 11 percent more on their water bill each month to help ensure continued access to a reliable and consistent supply of clean water. When applied across all American households, this increase is equal to $5.4 billion -- or four times the FY2009 federal investment in our nation's drinking water systems. In addition, a majority of industrial and agricultural businesses surveyed are willing to pay an average of 7 percent more per month for the water they consume.

"Most survey respondents also said that fixing our insufficient water infrastructure must be a national priority and is a shared responsibility between individuals, business and the government.

"'We all have a role to play, starting with more efficient use and conservation of water,' McClain said. 'Citizens and businesses need to understand that the delivery of clean water comes at a price and we need to value that clean water accordingly. Government can enact environmentally effective, economically sustainable and fair water policies that ensure proper investment in the infrastructure for future generations.'"
The motivation is obvious to many, but bears restatement for clarity:
"The U.S. population has more than doubled since much of the water infrastructure system was first put in place, and in many areas systems struggle to keep up with increasing demand. By one U.S. Geological Survey estimate, the value of lost water from water systems is $2.6 billion annually. Every year, 10 billion gallons of raw sewage are released into waterways as a result of insufficient infrastructure, polluting the water and increasing the cost of treating and cleaning it. According to the Congressional Budget Office, the gap between what is needed to invest and what is actually invested in the nation's water infrastructure is about $19 billion each year."
Note that the investment gap is highlighted here, not the actual or total investment. If some progress were made against that gap, it would diminish progressively to the point of simple maintenance costs and the cost to finance large capital replacement projects, which could be distributed over space and time in order to keep the infrastructure system in overall good repair and working order. It's more a matter of logistics and funding, not need or cost. It's going to cost what it costs, no matter how much more we need it now than we needed it last year or last decade. It's a matter of the political will to collect and appropriate the adequate funding in the right places. As the gap in any individual year is determined, the cumulative spending deficit grows unbounded until we end up with infrastructure more akin to that in the American Colonies, not the United States.

Among the more interesting results highlighted by ITT's survey:
  • 95% of Americans rate water as "extremely important," more than any other service they receive, including heat and electricity.
  • 80% of voters say water infrastructure needs reform; about 40% say "major reform" is necessary.
  • 85% of voters and 83% of businesses agree that federal, state or local governments should invest money in upgrading water pipes and systems.
  • 79% of voters and 75% of industrial and agricultural businesses agree that government officials must spend more time addressing water issues.
Regarding our "willingness to pay" for these services, as mentioned above:
  • 63% of voters are willing to pay as much as 11% more in their water bills per month to upgrade water systems and ensure long-term access to clear water. This translates to an average increase of $6.20 over their current water bills.
  • 57% of industrial and agricultural businesses would be willing to pay more in their monthly water bills for improvement purposes, with an average acceptable increase of 7%.
According to ITT, that willingness to pay more in the average voters' monthly household water bill could generate increased investment in our national water infrastructure to the tune of $5 billion per year. That amount, multiplied by financing plans and revolving funds that are already under consideration in Congress, could go far in cutting the massive investment gap that both ITT and the ASCE have found in their analyses. However, the question from my title for this post remains: will a new survey finally motivate government, from the municipal to the federal levels, to gather and assign funding to these long-overdue infrastructure repairs and upgrades? Will legislators and policy-makers step up to an apparently new level of leadership and responsibility for these needs?

15 October 2010

Commentary: UN Resolution on the Human Right to Water

Editor's Note: following is my commentary on topics surrounding the recent United Nations Resolution on the Human Right to Water and Sanitation, on which I reported previously and provided an annotated copy. This is my way of reaching out to others with interests in the state of international water governance, while still trying to figure out what we can do about it...



The United Nations General Assembly has proclaimed a universal Human Right to Water and Sanitation (document A/64/L.63/REV.1, in several languages including English pdf). In the voting on the resolution, 122 nations voiced their favor and 41 nations abstained. The United States, among several wealthy countries, numbered in the abstentions and was apparently among the most outspoken on their reasons.

The official explanation, according to the U.S. representative to the United Nations, was recorded in the proceedings of the Plenary Session:
The representative of the United States expressed his Government’s deep commitment to finding solutions to global water challenges, noting that water and sanitation would be an important focus at the upcoming Millennium Development Goal Summit. Safe and accessible water supplies furthered the realization of certain human rights, he said, noting that his country supported the work of the Human Rights Council’s Independent Expert on human rights obligations relating to access to safe drinking water and sanitation. The United States looked forward to receiving her next report, and to a more inclusive, deliberative approach to such vital issues in Geneva than had been seen in New York.

He said his delegation had hoped to negotiate and ultimately join the consensus on a text that would uphold the process under way at the Human Rights Council. Instead, the text fell far short of enjoying unanimous support among States and might even undermine the work under way in Geneva. It described the right to water and sanitation in a way not reflected in existing international law since there was no ''right to water and sanitation'' in an international legal sense, as described by the resolution.

Expressing regret that the text had diverted the Assembly from the serious international efforts under way to promote greater coordination on water and sanitation issues, he said it attempted to take a short cut around the serious work of formulating, articulating and upholding universal rights. It had not been drafted in a transparent, inclusive manner, and neither the Assembly, nor the Geneva process had yet considered fully the legal implications of a declared right to water. For those reasons, the United States had called for a vote and would abstain in the voting, he said.
Confusing, yes? The U.S. representative called for the vote, but also abstained from the vote. It was also at a time when the one person who could have presented overwhelming factual evidence to engender support for the resolution, the Independent Expert appointed by the Human Rights Council, was on the other side of the world at a meeting in Japan. But this "historical" event was truly an American thing, you see: this was the equivalent of a poll of voters ahead of the real action, by which decisions would be made and resources committed by a small and well-versed number of participants. The U.S. has here drawn out the essence of how deeply politicized the subject of "basic human rights" really can become, although here the political battleground is the sum total of the Earth's under-valued, over-priced, variously-privatized and unevenly-distributed freshwater resources and its intersection with the developing countries of the world, almost all of whom voted for the resolution.

This is the key differentiation to be made: with few exceptions (Western Europe, for example), almost all of those who voted for the Resolution would require direct foreign aid from the traditional donor countries, almost all of whom abstained from the vote, in order to make any progress toward the intended outcome. The traditional donor countries, on the other hand, put off their commitment to such an effort because they are (a) still counting the potential cost, (b) are dealing with their own crumbling infrastructure at the turn of a renewal cycle, and/or (c) waiting for some poorly-publicized and likely understaffed process in Geneva to come forward with its carefully-worded international treaty that could well have binding implications for signatories. I'll come back to that idea in a couple more paragraphs.

So a good question to ask at this point, since these poll results might still give us some real insight, is "Who else abstained?"


Click on the map for a larger version. I made it using a blank map from Wikipedia, so you're welcome to use it elsewhere, but please link back to this post or otherwise let me know if you do use it somewhere. Anyway, we see that, yes, much of the global population is in favor of such a right to water and sanitation. But knowing full well that the UN Resolution was non-binding; that it meant no commitment to pay for infrastructure and access in order to support, even enforce, such a right; still, several additional countries made the choice to abstain from the vote: Canada, Ethiopia, Australia, Greece, Denmark, and others...

I can posit a number of possible reasons for the "yes" votes. Not every country that voted in favor of the resolution fits into these broad categorizations, but I think these cover most of the world. Let's call it a "weight-of-evidence, sense-of-history" approach:
  1. They are relatively water-rich and have a robust infrastructure, as is generally the case in western Europe. These are high-GDP nations in which fiscal health is not resource-dependent, but rather advanced in reliance on industrial, service and information economics. Both food security and public health are of no practical concern, and indeed are more often taken for granted than examined in detail. These are, with some exceptions, countries counted in the G-8, or at least in the G-20.

  2. They are relatively water-rich but in need of funds, expertise, direction and/or time to build the required infrastructure to meet the needs of their populations, as we can see in much of South America, Southeast Asia, India, China and Russia. These are moderate-GDP nations with some resource-dependence but also a growing reliance on industrial and service economies, which can scale rapidly under the right conditions. Food security is a minor concern, but public health is a consistent issue where education and medical resources are in short supply outside of major urban areas.

  3. They are water-poor but otherwise resource-rich, and have established only the minimum industrial economy necessary to support the population that is required to extract and process those resources and otherwise support the command economy that the government has mandated. These are moderate-GDP nations for which this statistic is skewed heavily by the small percentage of highly wealthy people who control the resource economy, leaving the long tail at the poor end of the distribution to themselves and their own devices. Food security is a major concern, as irrigation in river valleys depends on annual flood cycles and is thus vulnerable to drought and the degradation of already-minimal infrastructure, which is maintained primarily by the manual labor of individual farmers and villages. Public health would be of concern if the government provided any such services, but they probably don't, unless one works for the government itself. The wealthy can find health care when and where they need it, while those in poverty rely on NGOs where those can be found.

  4. They are just simply poor, with little water or other natural blessings on which to build a resource-based economy, and with very little industry in only the most isolated locations. Food security is non-existent, with a heavy reliance on international assistance in times of drought because the only domestic agriculture is rain-fed, not irrigated by river floods or manual labor or state works or any other method. It's all a family can do, simply to survive off the land from one week or month to the next, let alone through a drought year. Public health isn't a concern even in the crowded capitals, where near-permanent NGO facilities remain the only providers.
So what would a full, binding "Human Right to Water and Sanitation" mean to these various countries? Basically, ensuring access to adequate water and sanitation is a guarantee of one of the most fundamental human needs, regardless of ability to pay for that access. The right to life, simply living, with a reduced proximity to illness and death, is advocated in this proposal. In the U.S. we take for granted our "inalienable rights ... life, liberty, and the pursuit of happiness," in the words of Thomas Jefferson, himself a champion of the burgeoning agricultural economy of the 18th-century United States. But mere access to water and sanitation certainly does not guarantee liberty, or even happiness, and not even necessarily life. It could help, if the activity to make such a provision is carried out in a manner beneficial to the people and their countries. Such a Human Right could lift whole regions from poverty, an existence of subsistence into which too many are born.

But still, it's a UN resolution. It is a non-binding declaration of the wishes expressed on behalf of the people who sent representatives to the UN General Assembly. It's not a law, not a budget item, not a commitment or pledge of assistance from one country to another. It is really just a piece of paper, a message of intent. It is simply this: a call to action. What really matters is what the numerous governments and NGOs do with that kind of call. Whoever answers the call gets to decide when, where and how much they can commit to the cause. In this case, and at this time, when we are not even sure that the Millennium Development Goals oriented on water, sanitation and the environment can still be reached (Goal 7), the UN Resolution on a Human Right to Water and Sanitation goes even farther in its goal. Instead of just halving the proportion of people unable to reach or afford safe drinking water, we who support such a resolution aim to reduce that proportion to zero. To do so will take time, and talent, and lots of money to get the right ideas and technologies to the right places. But that is the very goal of a growing number of people and groups around the world.

Just recently, the 10th anniversary of UN Security Council Resolution 1325 on Women, Peace and Security was celebrated. Nobel Peace Laureate Jody Williams, who was honored in 1997 for her leadership and advocacy in the International Campaign to Ban Landmines (ICBL), is now a member of the Nobel Women's Initiative and had much to say on the occasion. That campaign led to the international Mine Ban Treaty in 1997 and, more recently, the international Convention on Cluster Munitions in 2008. The U.S., among several other heavily militarized countries, has yet to ratify either of these. Does that call into question the efficacy of UN resolutions? Not at all, according to Ms. Williams. In reference to UNSC Resolution 1325 and its potential for results, compared with the process she experienced with and results achieved from the ICBL, she said this:
"It’s a tool, and the utility of a tool depends on how it is perceived and how activists employ it. Just because the United Nations passes a resolution does not in itself mean anything. In and of itself, it’s just words on a piece of paper. You have to have civil society involved pressing government to see that these policy tools are used. Governments are not enthusiastically enforcing these policies if civil society isn't pushing...

"The reason [the ICBL] worked was because activists used it. So we have this resolution. Great; so what? Tell me how we can get people fired up on the ground. We need to take a coordinated look at this and say, 'What is the leverage point? Where do we push?' Since 1981, that has been my experience: that people need to understand policy as it relates to their own role. In ten years that hasn't happened for [UNSC Resolution] 1325. We need to be educated about 1325 and how it can be used practically on the ground."
It is a message not simply of hope, but of effort and strategy, that Ms. Williams emphasizes here, and I think it's not just about UNSC Resolution 1325.
"You have to keep at it...It is going to take decades of pushing. You have to recognize that and not think you are going to change it overnight."
The same message applies to the presently uncoordinated campaign for improvements in freshwater availability in developing countries, as listed in the MDGs, as well an an eventual Human Right to Water: the UN resolution means little on its own, but can lead to great things when knowledgeable leaders and civil society get in on the effort.

04 October 2010

Policy by Ignorance, Surgery by Bulldozer

What happens when the regulations of one federal agency lead to decisions that violate the policies of another? Depending on the agencies, often the purpose and need supported by the one agency are considered more "valuable" in some way that those of the other. When no-one wants to rock the boat, bad decisions are propagated through the bureaucratic system, and mistakes are allowed to go forward.

Of course, on this blog, I'm referring to an issue in which water and nature come out on the losing end of the bargain. This is, in fact, one of the very issues that led me to name my blog as such: it's just defies my sense of logic when the causes of natural conservation and water preservation lose out so easily to regulatory inconsistency, bureaucratic inflexibility, and territorial stubbornness. Since I, myself, am not a lawyer, the blog is my outlet. Most often I present the facts, and sometimes I actually have an opinion. There is one case in particular in which I served as an expert witness in a court setting, but that's a story still to be told in this forum. In the meantime, let's see where this one goes...

In the Berkshire Mountains of western Massachusetts, an absolutely beautiful area that I have had the pleasure of touring more than once in my youth (college-interview trips with sisters, and Appalachian Trail Conferences with parents), are the headwater streams and lakes of the Housatonic River. The Housatonic forms at the convergence of three tributaries in the vicinity of the City of Pittsfield and flows southward through Massachusetts and Connecticut. The Housatonic is constrained by the coastal and upland Appalachian geology, flowing roughly parallel to the Hudson River to the west in New York and, along its lower reaches, the Connecticut River to the east. The Housatonic River eventually empties into Long Island Sound between Stratford and Milford, Connecticut. Five hydroelectric dams regulate the Housatonic River in Connecticut, and several more regulation and control structures are found along the Housatonic and its tributaries within Massachusetts. A map of the watershed, shown in light blue on a background of the region's counties, is reproduced at right from the website of the Housatonic Valley Association. Pittsfield, our location of interest, is located in the upper portion of the figure where the Southwest, West and East Branches of the Housatonic headwaters merge.

Pittsfield is a bit of a troubled community, but it hasn't always been that way. Its Wikipedia page characterizes an early entry in the Industrial Revolution, with numerous well-know residents over time. Of particular interest was one of the first American factories to produce electrical transformers, established as the Stanley Electric Manufacturing Company in 1890. This plant was bought by General Electric in 1903, and divisions of GE in military ordnance and plastics were also established there over time. Well-known former CEO Jack Welch originally joined GE as a chemical engineer in the Pittsfield plastics division in 1960 and moved to the C-level in 1972, eventually taking over as CEO from 1981 to 2001. Unfortunately, it was during Mr. Welch's tenure that the company was brought before the U.S. Environmental Protection Agency for massive contamination of the nearby North and East Branches of the Housatonic River, among numerous other locations, with polychlorinated biphenyls (PCBs), an organic component and byproduct of electrical equipment and device manufacturing with unprecedented environmental persistence. The sole market producer of PCBs for industrial use in the U.S. was Monsanto from their development by a smaller company in the 1920s. Though PCBs were finally banned in the U.S. in 1979, it wasn't until 2000 that GE entered into an agreement with the EPA to begin remediation on several miles of the Housatonic River in and downstream of Pittsfield in order to remove PCB-contaminated sediments and shoreline soils, a sensitive and intensive project. By 2009, according to GE's website, the company had spent more than $1.7B on PCB-removal projects at more than 89 locations across the country, with more than 85% of that cost (including EPA-shared projects) taken up at GE's three largest Superfund (CERCLA) sites: along the Hudson River in New York, at the Pittsfield location in Massachusetts, and at another manufacturing facility in Georgia. These projects are all ongoing. In the process, GE ceased manufacturing electrical equipment at the Pittsfield facility and spun off its plastics division (also known as GE Advanced Materials) there to become SABIC Innovative Plastics. Now, after a long-term decline and hints at a revitalization of the area's industries and commercial viability, Pittsfield is touted as a commercial center for western Massachusetts and hosts the GE-SABIC facility, an office of General Dynamics Advanced Information Systems, and several other industrial- and information-based companies. Still, during the commercial evolution of the city over the past 40 years in order to maintain competitiveness, Pittsfield's population has declined slowly since approximately the time of the 1970 census and is predicted to fall below 40,000 before 2020.

It those were all of Pittsfield's problems, there wouldn't be such concern right now. The upper headwaters of the Housatonic provide plenty of fresh, uncontaminated resources, and the area is dotted with clean and fresh lakes upstream of GE's contamination sites. In fact, only two of the three Branches constituting the principal Housatonic headwater streams that meet in Pittsfield were directly impacted by PCB dumping and remediation activities. The Southwest Branch of the Housatonic remained outside GE's area of activity, but it has problems and special considerations in its own right. More specifically, in the vicinity of Pittsfield and because of direct actions by that City, rare ponds and wetlands along several streams and tributaries of the Southwest Branch are under immediate threat. The problem is development and expansion, under the guise of FAA regulatory compliance for public safety, at the Pittsfield Municipal Airport (PSF). I was contacted by an interested party last week, in the wake of a recent permitting decision (that I will get to below), regarding the impacts of this expansion. I present here some of the background information that was provided to me; in future posts I will present more information that I have started to gather on the topics at issue. Overall, it's beginning to form a compelling story on the willful blindness of bureaucracy and the leverage that money seems to hold over natural treasures.

PSF serves the private, corporate and general aviation sectors in northwestern Massachusetts, but its main runway is not currently up-to-code with proper safety areas on the runway ends. For smaller, single-engine and light aircraft, this is not so much an issue. PSF was built in 1941 and has been serving the region and local users continually since then. An aerial photo of the airport, taken from southeast of the facility, is provided at AirNav.com and shown on the right. The main runway is just over 5,000 feet long and runs from the upper left (generally, from the west) to lower right (east) in the photo. The problem with the runway, according to FAA regulations, is that the ends of the runway do not have proper safety areas. At the western end, only 150 feet of off-runway safety area is provided for possible aircraft over-shoot and braking before a relatively steep drop to a road that abuts the airport property. At the eastern end, about 200 feet of runway safety area (RSA) is provided. For the aircraft that PSF is expected to serve, which is reported to extend up to the Gulfstream V corporate class, the FAA regulations mandate 1000 feet at each end of the runway. In addition, the City of Pittsfield (which owns the airport) has elected to use the construction required for bringing the runway up to these FAA standards to add another 790 feet of runway length. For many small airports, these would seem reasonable actions to meet safety requirements and to expand the class of service, or at least make existing service safer, in an effort to boost economic development in the area. For PSF, however, the environment stands in the way.

Specifically, and despite many considered alternative development plans, the City of Pittsfield has elected to "relocate" the main runway about 650 feet to the east, extend the runway overall, and construct the RSAs at each end to meet FAA requirements. Overall, this will ensure continued FAA support and funding for operations and maintenance at PSF. Essentially, this means several things. First, 650 feet of runway at the western end will be removed, and an additional 200 feet of field will be regraded, in order to meet the FAA requirement for a 1000-foot RSA. This 650 feet will be subtracted from the western end and added to the eastern end of the runway, where an additional 790 feet of runway will also be constructed, and then the required area for the 1000-foot RSA would be developed. The construction probably would not proceed in this order, to ensure continued use of the airport, but those are the basics.

You'll notice in the photo, however, that the airport is surrounded on its east and south sides by wetlands. Because of their chemistry these are actually classified as "fens" in the professional literature, but in more general terms I'll stick with "wetlands" as a more widely recognized term. A look at the airport in Google Maps gives an even better idea on the extent and proximity of these wetlands around PSF.


View Larger Map

Overall, the development plan proposes to fill 5.72 acres of wetlands and 0.10 acres of streams that are designated "waters of the United States." These are all essential environmental systems that are protected from development impacts in Section 404 of the Clean Water Act. That legislation designates impact review and permitting authority to the U.S. Army Corps of Engineers (USACE), while the remainder of the Clean Water Act is administered by the U.S. EPA. The focus here of the USACE is primarily on "dredge and fill" activities, and not necessarily on the science of surface waters or groundwater, their origin and behavior, and the determination of impacts on their ecosystem services through rigorous scientific analysis.

What bothers me here, in addition to the narrow focus of the USACE in Section 404 Permit decisions, is the relative dearth of public information about this project. When wetlands and water resources are to be altered, there ought to be an overflow of information regarding the existing function of the environment, including both hydrology and ecology, on which an impact study would be based. In this case, there seems to be very little volume of related information, reports, submitted studies, etc. Instead what I have found is woefully insufficient and out-of-date. The City of Pittsfield maintains a web page with information about the Municipal Airport, but links to detailed information and reports on the development and expansion project are incomplete. Of the Final Environmental Impact Report, only the City's responses to citizen comments (pdf), the FEIR chapter on the project "Purpose and Need" (pdf) and a report on stormwater management from the contracted design engineering company (pdf) are made available. The stormwater management report essentially comprises a part of the required Stormwater Pollution Prevention Plan (SWPPP) for the project as well a portion of the design requirements for site construction. The last Fiscal Annual Report for the airport that is listed by the City on their website is from 2006 (pdf). Of reports or other information on the details of site hydrology, the long-term potential impact of fill and construction on the surrounding wetlands, the viability of constructed and "enhanced" wetlands in mitigation efforts, the impact of straightened stream channel segments in the vicinity of the runway construction, or the essential role of groundwater in the ecological and environmental system and potential impacts on that resource, there is no useful information at all put forward by the City. To wit, on the city's FAQ webpage regarding the airport expansion and development project, there is this:
"What are the environmental impacts of the project?

"The project will comply with all applicable federal and state environmental laws. The Environmental Assessment/Environmental Impact Report (EA/EIR), publically developed and prepared by the Pittsfield Muncipal Aiport Commission and its consultants, has complied with the National Environmental Policy Act (NEPA) and the Massachusetts Environmental Policy Act (MEPA). During the course of developing these assessments and reports the Airport Commission proposed adding up to five acres at Wild Acres for every acre of land acquired at the preserve. Moreover, the commission has said that the fishing pond at Wild Acres will not be altered by the renovations. In July 2005, a project milestone was reached when certificates were received from federal and state environmental agencies stating that the project was consistent with NEPA and with MEPA environmental regulations."
That didn't even answer the question! This FAQ response is, essentially, an effort at misdirection. My paraphrase: "The government has issued for us the permits and certificates that will allow the environmental impacts that we simply cannot or will not avoid. You don't need to know all the details. Just let us handle the technical stuff."

The New England District of the U.S. Army Corps of Engineers issued a Public Notice on 2 February 2010 regarding some of the project details and requesting comments, though those were due to the Corps by 4 March. Though some details of the proposed project were given in that Notice, as well as some indication of the efforts to mitigate environmental impacts of the project, numerous comments were received from the public. The Corps Decision to issue the Section 404 Permit, on 7 September 2010 and made available to me last week, reads as a simple (and highly simplified) review of earlier documentation and decisions made by other permitting authorities. Specifically, those have been the Federal Aviation Administration (FAA) as the lead federal agency, the Massachusetts Aeronautics Commission (MAC), the Massachusetts Department of Environmental Protection (DEP), and the U.S. Army Corps of Engineers (USACE). Variances from regulatory standards have been issued along the way, by the FAA (regarding part of the safety area) and most notably by the Massachusetts DEP, who issued a variance permit and then tacked on an additional project (more on that below) in the process of issuing a Water Quality Certification for the project. Above all, it seems as if the Final Environmental Impact Report was seen in its entirety only by the FAA and MAC. The contents of such a report should have been evaluated instead by subject-matter experts that the DEP and USACE could provide. It seems, from my perspective, that the latter agencies took the decisions of the former and simply passed those through the chain of decision-makers who asked no questions. This is bureaucracy at work, and the failure of due diligence is readily apparent.

Look again at the map of the airport. It looks to me like the original runways and terminal were built in a wetlands area in the first place, back in 1940-41. What were the impacts of that construction? We see now the seemingly healthy wetlands, but we can't know now what their conditions before the airport ever were. Further airport development will fill in almost six more acres of the wetlands, primarily on the east side of the airport. It is stated that the fill will consist entirely of local materials, that additional areas will be constructed to mitigate overall wetland loss, that transplanting of native plants will help the establishment of new "constructed" wetlands in the mitigation process, and that other procedures are incorporated in the construction plans to mitigate stormwater impacts. Essential topics that are not addressed in any of the available document are the basic scientific functioning of these wetland areas, their origin in calcareous outcrops on the margins of the Taconic Range where geochemical contributions have made a seemingly invaluable groundwater resource out of glacial deposits and more recent recharge from natural processes. These wetlands, along with similar areas to the south that are just recently being recognized for their rarity and quality along the border between New York and Massachusetts, are representative of what is arguably the next great source of freshwater for the northeastern U.S. megalopolitan region. The geology and chemistry of such calcareous deposits produce what many consider "hard" water, that is high in calcium and magnesium content, but that is also chemically buffered such that it does not hold metals in solution and is, essentially, pollution-free. What we don't yet know about this area of the country is how exactly that happens, and this development at the Pittsfield Municipal Airport threatens any effort at understanding the quality and interactions of groundwater and surface water in the area before it is destroyed, and for more than the local users and wildlife. A groundwater reservoir, once contaminated or depleted, is essentially lost forever; its remediation and recharge is unlikely to happen within one human generation or the next. The environmental assessment for this project, as reported to the FAA, seemingly contained little or no information on the science of these wetlands, just a rudimentary assessment of their capacity for modification by preferred development alternatives. Either that, or the FAA sees "safety" in ways different from the rest of us. I guess both can be true.

Finally, there is the side-project that the State of Massachusetts added as a condition to the Water Quality Certification granted to the project at Pittsfield Municipal Airport. This additional work involves the removal of the Sackett Brook Dam, a structure on a tributary of the East Branch of the Housatonic River in the Pittsfield State Watershed Area, not on the Southwest Branch in the vicinity of the Airport, which is actually about 5 miles to the west. How these two projects could be interpreted as connected, I don't know. How is it possible that the Environmental Assessment and Review for the Airport development can be in any way applied to the Sackett Reservoirs? Yes, that's plural, there are two; the documents that I have do not specify which dam is to be removed, but the Final Decision issued by the USACE does somehow list the removal of one of the dams on Sackett Brook as an element of stream bank restoration and enhancement as well as an element of open-water enhancement. Wait...when a dam is removed (which is getting to be a big, though delicate and controversial, business now) the impounded water is released, right? Doesn't that mean less open water after the removal of the dam and reservoir, not more? Where is the Environmental Impact Report for that activity?

So in that case, the USACE just issued a permit for an activity with unknown purpose and unknown potential impact, seemingly as a mitigating activity for wetlands loss elsewhere, with no supporting documentation or scientific (or even engineering) investigation, and with no intended oversight on the demolition activity or its effects on the surrounding environment, either the forested region surrounding the reservoir or the groundwater beneath it. Never mind that this reservoir is in the area affected by PCB contamination decades earlier, downstream in the groundwater flow patterns from the GE clean-up sites. If the reservoir does in fact receive any of the surrounding groundwater, the concentration of PCBs in lake sediments is likely higher than in the free-flowing downstream areas. Does the public get to see the study on that project and its impacts, or will it be allowed to go forward without a public hearing, just as a public hearing for the Airport project was denied as well?