Editorial by Tribune Publisher Jordan Hedberg
I have watched local leaders think and deliberate on the question of whether Round Mountain Water and Sanitation District should be allowed to spread 30 years of accumulated sewage sludge (also called biosolids) on farm acreage on the Valley floor. This farm is within one mile of Grape Creek and welcomes seasonal Macey Creek running through the middle of the pasture. Round Mountain Water has proven to be an excellent organization, coming up with a myriad of solutions to problems that seemed impossible to solve. However, the issue here, which is a problem that the community seems to understand intuitively but does not know how to articulate fully, is that spreading sludge is not a standard risk-making decision. For Round Mountain Water, this process of getting approval to dump sludge is just another box-ticking exercise with the Colorado Department of Public Health and EnvironÂment. For Round Mountain, the decision boils down to the financial cost to the district, as spraying the sludge on farmÂland locally is cheaper than other methods of disposal.
(Featured photo cutline: The old Johnson Ranch where Round Mountain Water and Sanitation District wants to spread sewage sludge for fertilizer. The ranch sits on the northeastern corner of the intersection of Horn Road and Colony Lane, five miles south of the Cliffs)
So, the question is, why is this decision different than standard pro-con risk assessment decisions? What makes this request to spread sludge on farmland, done in many places around the nation, so difficult for the community? The answer lies in the fact that there is a tremendous amount of uncertainty about the risks to the waterways if something goes wrong. Worse, this decision is irreversible. If something goes wrong now or 30 years from now, there is nothing that can be done to fix the problem. Those 750,000 pounds of sludge cannot be scooped up if it proves the pollutants in the sludge are leaking from the area where they are being spread.
We need a different framework for dealing with risk in this situation because the stakes are not only high but irreversible. In 2014, researchers from New York University and the New England Complex Systems Institute published a paper that proposed the proper risk assessment process to use in these situations. This approach is called the Precautionary Principle, which states:
âTaking risks is necessary for individuals as well as for decision-makers affecting the functioning and advancement of society. Decision and policymakers tend to assume all risks are created equal. This is not the case. Taking into account the structure of randomness in a given system can have a dramatic effect on which kinds of actions are, or are not, justified. Two kinds of potential harm must be conÂsidered when determining an appropriate approach to the role of risk in decision-making: 1) localized non-spreading impacts and 2) propagating impacts resulting in irreversÂible and widespread damage. Traditional decision-making strategies focus on the case where harm is localized, and risk is easy to calculate from past data. Under these cirÂcumstances, cost-benefit analyses and mitigation techniques are appropriate. The potential harm from miscalculation is bounded. On the other hand, the possibility of irreversible and widespread damage raises different questions about the nature of decision making and what risks can be reasonably taken. This is the domain of the Precautionary Principle.
Round Mountain Water and the company they hired to deal with the sludge, Denali Water Systems, argue that the sludge is safe and that with proper application, the sludge will not move from the 150 acres in volumes large enough to cause problems in Grape Creek. They liken this to spreading nearly the same thing as farmers spreading fertilizer or a cow pooping in a creek. Yet, this is hardly a complete explanation of what sludge contains.
This sludge is not only 30 years of concentrated human excrement but is also a collection of every type of houseÂhold cleaner, residues from cooking pans, and
And the problem is that the testing for certain pollutants is still in its infancy. Forever chemicals have only started being tested in Colorado for the past two years. The Federal Environmental Protection Agency is now exploring a comÂplete rethink of sludge spreading on farmland. Because this sludge is a super concentrated form of waste from thouÂsands of households over three decades, it is inaccurate to claim that it is similar to cattle manure or fertilizer.
There is a huge amount of uncertainty, even among professionals, about how safe sludge is to use and how damaging it can be to the environment when it spills into water systems.
So, what does the Precautionary Principle say? âThe aim of the precautionary principle is to prevent deciÂsion-makers from putting society as a wholeâor a signifiÂcant segment of itâat risk from the unexpected side effects of a certain type of decision. The precautionary principle states that if an action or policy has a suspected risk of causing severe harm to the public domain (such as general health or the environment), and in the absence of scientific near-certainty about the safety of the action, the burden of proof about absence of harm falls on those proposing the action. It is meant to deal with effects of absence of evidence and the incompleteness of scientific knowledge in some risky domains.â
Sludge contains pollutants that are only now becomÂing known to be dangerous. Part of the issue is that there were no methods to test for certain dangerous pollutants until recently (so-called forever chemicals are one of these pollutants that the Environmental Protection Agency calls âemergent,â even though they were created in the 1950s). So can Round Mountain or the Colorado Department of Public Health and Environment (CDPHE) give the commuÂnity certainty that they know all the dangerous concentrated chemicals in the sludge wonât be a problem in the next decade? Or the next 30 years? Of course, they cannot make this promise because evidence of harm in a complex system often comes a long time after the event.
Because there is no absolute certainty that the sludge is safe, the question then becomes what risks are posed by the spreading on farmland. We know that a significant rain event could easily wash much of the proposed 2.5 tons of sludge applied per acre off the ground in a single storm. Grape Creek not only serves many ranches, but it also conÂnects directly to the large aquifer that rises to the surface in many parts of the Valley, several miles in each direction of Grape Creek. Lastly, the wells that serve the towns of Westcliffe and Silver Cliff pull from the groundwater downstream from the proposed spraying site.
To conclude, let us apply the precautionary principle in this situation; here are the two conditions that must be met for the principle to be used: 1) non-localized spreading impacts and 2) propagating impacts resulting in irreversÂible and widespread damage. First, any mistakes about possible pollutants or random weather events mean that the problem will not stay on the land on which the sludge is applied; it will spread along the entire Grape Creek drainage and the aquifers and wells that tap into the water fed by that creek. Second, if the sludge does have dangerÂous pollutants, it could be years, if not decades, until the damage becomes apparent, and by that point, it would be irreversible.
When using the precautionary principle method of risk calculations, there is far too much uncertainty, and the conÂsequences of being wrong are just too significant of a risk for this community to be allowed.
With that being said, I have long argued that the two town governments and the County Government need to find a way to start investing and helping Round Mountain with the cost of dealing with this sludge safely and not spreading it on a field. Without water and sewage services, the small economic engine that powers the tax revenues of all the local government organizations will fail. We cannot go back to 1969 and fix the fact that Round Mountain was created so that the towns of Silver Cliff and Westcliffe could wash their hands of any liability regarding clean and safe drinking water. Round Mountain has been facing the threat of shutting down for over a decade. During that time,e the town of Westcliffe and the Custer County Government have wasted millions of dollars. Just a brief example is the $581,962 at 2% per annum to buy vacant land for a Justice Center that was never built. Another example is the town of Westcliffe, which spent millions on sidewalks to nowhere and rebuilt a park that didnât need to be remodeled.
The Wet Mountain Valley region has the resources to build a water treatment facility safely, but for a lot of reaÂsons, it has never been a priority for the regionâs governÂments. That has to change.
â Jordan Hedberg
To read about the Round Mountain Water and Sanitation District’s Plan, click here to read the story.