I am submitting these comments to you concerning the EPA’s permitting of the Pioneer Valley Energy Center.

Because the air of the Pioneer Valley is very close to being over the allowable amount of ozone, I am displeased that the EPA is deferring to MA DEP’s permitting of the Energy Center. EPA says the Center will “be a major new source of air pollution.” EPA also says that “the Westfield area meets all of the EPA’s health-based standards except for ozone.” For this reason, I think that the EPA’s deference to MA DEP is a failure of leadership and ethics; EPA is by law the leading, not the following, agency. In this case, the EPA’s ozone standards have been compromised.

I would like a discussion in the statement of issuance of the permit that assesses the contribution of the Center’s emissions, alone and along with existing and proposed power plants and manufacturing entities, to the overall air pollution load of the Pioneer Valley in terms of long-term and cumulative impacts.

At the hearing in Westfield, the EPA stated that it is not in charge of designing or implementing a regional energy plan for the Pioneer Valley; this is the task allotted to citizens and politicians. As a resident of Westhampton who runs a business in Northampton, I would like the EPA to confirm this, so that this news is brought to the attention of citizens and elected officials, with the idea of getting funding for the Pioneer Valley Planning Commission to do a study of the region’s existing and proposed energy sources. The facts this report presents will provide a valuable foundation for municipal and regional discussions of and planning for our energy future—in the context described above: the air of the Pioneer Valley is very close to being over the allowable amount of ozone.

thank you,
Kurt Heidinger

speak up!

the places we know are always remembered along with the people we know.

think of your favorite place

a face’ll soon appear

to remind you of what happened, what you did there that made it the best

made it a place where something worth remembering occurred, something transformational

the first kiss

the leap of faith

the fire, its dancing and hunger

the peak attained

the accident

the flower that glowed with the sounds of children—

find that place, and you’re nourished: happiness is the full plate, in tragedy fasting feeds enough:

think of the mountains & you’ll see a great friend.

We’ll look at PM 2.5: particulate matter of 2.5 microns or less. This stuff is bad for us to incorporate (ie, breathe)! If you have asthma, bronchitis, or heart problems, it brings on attacks.

The EPA sets an annual limit of 15 ug/m3 (averaged over 3 yrs) and daily limit of 35 ug/m3 (calculated by taking the 98th% highest daily average). These measurements are not, for the average person, user-friendly; which is why we have professional regulators, right?

In 2010, Springfield (@ Liberty St.) had a annual average of 9.24 ug/m3, 2nd highest in the state. Its 98th% highest daily average was 25.8 ug/m3.

In 2009, Springfield had a annual average of 9.4 ug/m3, 2nd highest in the state. Its 98th% highest daily average was 26.8 ug/m3.

In 2008, Springfield had a annual average of 10.78 ug/m3. Its 98th% highest daily average was 28.4 ug/m3, highest in the state.

In these years, the EPA found no violation of the PM 2.5 levels in Springfield. However, as yesterday’s post showed, PM 2.5 levels often soar on any given day, and if you’re breathing deeply when they do, the averages mean nothing. One day in 2008, a level of 200 ug/m3 was measured!!

Consider, though, that the EPA is reviewing permits for the proposed Pioneer Valley Energy Center in Westfield, and biomass-burning electrical generators in Russell, Springfield and Greenfield all at once. I will consider this situation soon; but tomorrow we will look at how the EPA regulates ozone, and how ozoney Amherst is.

Look @ this chart, that graphs the amount of smog (also known as “PM 2.5″) Springfield enjoyed last year:

Visualize a horizontal line @ 15 “um/g 3 LC”; b/c that’s where the blue line should be. Here’s the EPA’s legal definition of how much “PM 2.5″ is allowed in our air:

You’ll notice the EPA averages the “PM 2.5″ over 3 years, so let’s look at how much “PM 2.5″ Springfield enjoyed in 2010 & 2009:

In tomorrow’s post, I will present and contemplate the #s found in these MA DEP reports.

Before I go, though, I read this last night in the latest “amcoutdoors,” the magazine of the Appalachian Mountain Club:

“AMC is moving forward with legal action regarding the EPA’s 2008 Federal Ozone Air Quality Standards. AMC and others are reactivating the original 2008 lawsuit against the EPA for its issuance of an unacceptable standard at 75 parts per billion (ppb), when health science supports a standard in the 60 to 70 ppb range. In addition, the suit will address the inaction on adopting a meaningful secondary ozone standard to protect plants and forest, as supported by EPA’s own science staff. The filing is part of a joint action with AMC, EarthJustice, the American Lung Association, and others.”

Read more about the AMC’s legal action—which interests me, b/c it 1) is by activist standards, a very conservative organization, and 2) is working with the Lung Association, whose “F” grade for our air quality prompted me to investigate it.

“WASHINGTON (AP) — The Obama administration is banning new hard rock mining on more than a million acres near the Grand Canyon, an area known to be rich in high-grade uranium ore reserves.

The decision, announced Monday by Interior Secretary Ken Salazar, hands a victory to environmental groups and some Democratic lawmakers who had worked for years to limit mining near the national park, one of the nation’s most popular tourist destinations.

“When families travel to see the Grand Canyon, they have a right to expect that the only glow they will see will come from the sun setting over the rim of this natural wonder, and not from the radioactive contamination that comes from uranium mining,” said Rep. Edward Markey of Massachusetts, the senior Democrat on the House Natural Resources Committee. [Yay Massachusetts!!] …

But congressional Republicans and industry groups opposed it, arguing that Salazar was eliminating hundreds of jobs and depriving the country of a critically important energy source. The area near the Grand Canyon contains as much as 40 percent of the nation’s known uranium resources, worth tens of billions of dollars.

Sen. John McCain, R-Ariz., called the ban a “devastating blow to job creation in northern Arizona.”….

During a speech at the National Geographic Society, Salazar said he was “at peace” with the decision, one of the most high-profile actions of his three-year tenure at Interior. Salazar twice had imposed temporary bans on mining claims.

“A withdrawal is the right approach for this priceless American landscape,” Salazar said. “People from all over the country and around the world come to visit the Grand Canyon. Numerous American Indian tribes regard this magnificent icon as a sacred place, and millions of people in the Colorado River Basin depend on the river for drinking water (and) irrigation.”Numerous American Indian tribes regard this magnificent icon as a sacred place, and millions of people in the Colorado River Basin depend on the river for drinking water (and) irrigation.”

Why?

Why doesn’t “our” culture understand, or value, land as sacred?

We do have a few a places that “our” culture understands as sacred: Gettysburg & the World Trade Center prime among them. But these places are considered sacred not because of the land itself, but b/c lots of people bled into them, and were turned by politicians into martyrs whose lives were not, politicians promise, sacrificed in vain.

Native Americans deserve to be honored for the way they understand, and value, land as sacred. But so do non-Native Americans.

I wish Salazar had added non-Native people to his group of animists. By not doing so, he ineluctably revived the colonial mythology of the noble savage, the Natty Bumppo story that “technology-less” people have a “primitive” religion that perceives God as nature. Most do. But inherent in this myth is the colonial prejudgement that “historical progress” or “social darwinism” has condemned the Native, and animism, to extinction—and if not that irrelevance. If Salazar thought Native religion was relevant, he’d have unhesitatingly embraced its values as his own, and expressed the perspective of a native culture he is part of, that is not—as his rhetoric expressed it—an “other” one.

What I’d like Salazar to know is that our non-Native culture has a proud and lively tradition of animism that is epitomized by Whitman in NYC, Thoreau at Walden, & Lincoln at Gettysburg. (Here, read more about this part of “our” culture.)

A native is a person who recognizes they are born from nature, and that recognition is the basis of their animism, their recognition that their own life is not individually-packaged; it is shared. They recognize the life they live is connected umbilically to the earth (thru water, food, shelter, etc.). Since one’s own life is sacred, this life we’re living the very presence and proof of “spirit” and God within us, one’s own sacredness is extends to the earth, which makes life possible, and is itself incomprehensibly alive.

Nativeness for “our” culture, comes/starts/appears when colonization ends; the colonist recognizes that their life is consubstantial with the land, and looks upon and treats the land as an extension, and source, of their own body. With that recognition comes the awareness that commodification is a delusion & pathology, a delusion because money is an illusion (you can’t drink pennies), a pathology b/c living an illusion leads to dashed hopes and illness (think of Detroit).

You see this kind of end-of-colonization nativeness, for example, in Georgia O’Keefe’s paintings of the high desert badlands.

Pedernal -- From the Ranch #1, Georgia O'Keeffe

You see it, too, at the farmer’s market (& not @ hole fudes). Every organic farmer knows their life is shared with the land, and many non-organic farmers, too.

You feel it on the beach during summer vacation, in those striking moments of shiver and goosebump as you loll in the sun. Looking out at the Atlantic, you know you can’t swim to England, the ocean’s too vast and will gobble you up as soon as you let it. The sun in your skincells feels like butter on hot popcorn, and your brain turns off for a moment as you exult in the most basic lizard feeling of warmth, still and quiet. Then, you think about skin cancer, alert to the fact that the warmth is radiation, subatomic particles hitting you like rain on a sponge: your skin soaking it in is the feeling of it damaging your the cells. You save your life by retreating to the shade or the sunscreen; and in retreat express your awareness that your dust-to-dust body is connected to the sun. You are more than you have ever been taught; that’s why it’s important to think outside.

If only Salazar knew our life is the earth, for without it, we’d have no body for our spirit to live as…and if he does know, if he had mentioned how non-Native Americans understand, and value, land—the earth—as sacred. Then he wouldn’t have uttered the sentence that, in a few words, revives the entire colonial myth of “our” culture: the tree-hugging Natives who value land as sacred versus the materialistic colonists who value that land as a commodity.

Again:

“Numerous American Indian tribes regard this magnificent icon as a sacred place, and millions of people in the Colorado River Basin depend on the river for drinking water (and) irrigation.”

“Salazar’s” culture does not value land as sacred. If the land was, to them, sacred would it not be for him a grave sin to commodify it, the same thing as commodifying God? To poison land, to destroy land, would be to poison and destroy God? Could it be that the act of not valuing of land as sacred—of viewing it as “natural resources”—might be essential to relieving its commodifiers of these sins?

Notwithstanding this, I applaud Salazar for prohibiting uranium mining in the Grand Canyon National Park; but we must realize the land is not saved. In 20 years another administration can permit uranium mining there; and it’s possible that it could be mined before then under another president.

Could it be that the only way to permanently save Grand Canyon National Park is to understand and value it as sacred? And by extension, is it possible that the only way to permanently save the biomes our bodies are connected to is to understand and value those biomes as sacred: sacred because our own sacred lives are consubstantial (water, food, shelter) with our biome?

Is it possible that the only way to save “America” is for its citizens to become native?

Nativeness for “our” culture, comes when colonization ends: if this is true, then in “our” colonial history, the Natives were always the “advanced” people, and the colonists always the “primitive.”

___
Ah that was fun, feeding the tail end of the myth of the noble savage back into the mouth of its professor.

I wish I could tell Salazar the Grand Canyon has been deemed sacred by former Department of Homeland Security Security Tom Ridge and former Governor of Pennsylvania Edward Rendell.

When they defined the value the Grand Canyon has for Americans, their theology was—for a flashbulb moment—”native”:

“America’s national parks preserve our most sacred natural spaces, such as Yosemite and the Grand Canyon, as well as important pieces of our national history such as the battlefields at Gettysburg.”

Before I present them, though, allow me to reminisce about how, in the summer of ’04, I was relaxing on a beach in Truro, reading a murder-mystery book about a homicide committed in the same town, when I beheld this scary passage:

Truro has the worst air pollution in Massachusetts. A scientist at the federal Environmental Protection Agency calls Truro “the tailpipe of the nation” because it takes a direct hit from the prevailing western winds that spew smog and ozone sources far inland. Sulfur dioxide, nitrogen oxide and fine particulate matter created by industries and power plants in the Midwest, augmented by pollution from the heavily populated Northeast Corridor, from D.C. to New York, are funneled over the Outer Cape. Charles Kleecamp of Cape Clean Air said that the EPA issues warnings when ozone levels reach one hundred, but the monitoring station in Truro records ground-level ozone at two hundred. People can drop dead.

I remember little else from this beach-read, because I couldn’t believe my family was vacationing in one of the most polluted places in New England. I had no clue, until then, that places that look so clean can be so dirty.

I was also struck by the fact while Truro creates very little air pollution, it inherits the pollution from places far away, in many cases from states that have anti-environmental political leadership. It bothered me to think that people in, say, Kentucky were profiting handsomely off the pollution they pumped into the sky, and that my little girls splashing in the waves were getting 0% benefit from those Kentucky profits. All they were getting was poisoned.

Westhampton never seemed the same to me after read that, not that I liked it any less; no, what was different was me, the way I looked at blue skies with the knowledge they weren’t as blue as they once seemed. I vowed that, someday, I’d take the time to learn what we’re breathing—and when I received the note last week from Concerned Citizens of Westfield about the oil & natural burning electrical generation plant proposal being reviewed by the EPA, I realized I’d procrastinated for too long. My goal is to amass credible data so I can write a reasonable letter of concern about the proposal, and send it to the EPA by 1/20 so that it will be read and considered by that agency as it ponders what it will and won’t permit.

My initial concern arises from the conclusion of the Lung Association which gives our air an “F” grade; here is its most recent report for Hampshire and Hampden counties.

The ozone issue is a big one, b/c in 2004 Hampshire and Hampden counties were “designated nonattainment for EPA’s health-based standards for ground-level ozone pollution.” As far as my research tells me so far, there’s been no improvement in our “F” grade ozone situation. If this proves to be the case, I have a factual basis for my concerns.

The EPA is also concerned: “EPA-New England determined the new facility proposed by Pioneer would result in significant emission increases of particulate matter less than 10 microns and 2.5 microns in diameter, nitrogen oxides, carbon monoxide, sulfuric acid mist, and greenhouse gases.”

Let’s look closer a the issue of fine particulate matter, or soot. Mass DEP says that “the primary standards for PM2.5 are 15 ug/m_ averaged over an entire year and 35 ug/m_ averaged over a 24-hour period.” Fine soot is bad for us: “Because of their miniscule size, these particles can penetrate deeply into the lungs and accumulate in the respiratory system.”

Look at this graph tracking fine soot levels @ the Springfield Public Library I generated here:

I see 2 things in regards to fine soot pollution: winter months seem to be the worse, and the yearly average looks like it’s close to the 15 ug/m threshold.

In this permitting process, the EPA and DEP will have to add the extra fine soot generated by the oil & natural gas burning plant to the sum load that’s generated everywhere else, and calculate if the 15 ug/m annual-average threshold is going to be broken. Natural gas burning yields less fine soot; petroleum more—so, to get a sound estimate, we’ll have to figure out how much of either is burned, and for how long.

Welcome to regulatory lalaland! How am I, or any average citizen, supposed to get those figures? And without those figures, how are we expected to write useful comments?

A commenter on the biocitizen facebook page wrote about this difficulty in trying to get good #s:

“My husband raised some important questions about the oil “backup” when natural gas demand is high (which is going to be more than the 2 month winter season they stipulate– 2 mos. winter season, where do they think we live?!?). Do the emissions projections include oil burning?”

I don’t know! I will continue to research—maybe the #s are available but I need to dig deeper. This, and allied questions, can be asked at the public hearing in Westfield on Thursday night, and then a letter be drafted & sent afterwards:

The purpose of a hearing is to offer a forum where questions can be raised and answered. I’ll have one post on this subject before the hearing, and hope to offer readers a list of hearing questions.

Consider, then, that a new oil & natural gas burning electricity-generating plant is proposed for development in Westfield. And that the permitting-process is almost over!

Have you heard about it? It’s called, by its proponents, the Pioneer Valley Energy Center.

Having heard absolutely nothing in any area media source about this proposal, at least in the Daily Gazette, I received this notice in the biocitizen email account on January 2 (click on notice to see a clean view):

Here is the EPA’s announcement of the hearing:

EPA announcement of public hearing on January 12 for a gas-burning electricity-generation plant in Westfield

Please consider this—the development of a significant new source of air pollution in a region that gets an “F” for its air quality.

What do you think?

My next post will report on the EPA notice, so we can understand what it means by “prevention of serious deterioration.”

I wonder 1) how “deterioration” is defined by the EPA and 2) what deterioration below an “F” grade air quality status is.

Do you?

Right now, your body is about 65% water. Your lungs, brain & muscles are especially water-rich, not to mention your blood, which is obviously almost all water.

The water you are comes from….where? Do you know where your water comes from?

we are water

This is not a trick question. It might seem like one, though, because our education system—from K through grad school—has no curriculum that teaches this subject, yet. (Biocitizen was created precisely to focus on this and kindred crucial, institutionally-ignored, subjects.)

Plato said the essential task of life is to know thyself. I have often wondered how, if a person doesn’t know where their water comes from, they can reasonably claim to know who they are. I have often wondered, too, how a culture that prides itself as being the most “advanced” in human history can know so little, while pretending to know so much—alas, the results of this pretense is seen everywhere around us.

Because we take showers and drink Fiji etc, water is very present in our lives. We have to bring our selves into contact w/it constantly, and absorb it into our cells, through willed effort.

Air is more abstract than water, at least to our visually-oriented minds, because it does not take too much effort to absorb it. We breath and it becomes us.

happy birthday! —we are air

So—do you know what your air quality is?

This is, for us in the Ct River Valley of Western MA, it:

All 11 Massachusetts counties that were rated for air quality due to smog, including Hampden and Hampshire counties, received a mark of F in a new report from the American Lung Association.

Yes, that’s right. Our air is worse than unsatisfactory. It is a “fail.” See the full report.

I’m just wondering: how many people in the Happy Valley know they are breathing disease-causing filth? And, how many schools—k-through grad school—teach this subject?

In my next post, I’ll consider what we can do about this situation. There definitely are things we can do—

Natural selection by love, or eros as it was anciently called, is observed here:

Scientists said on Tuesday that they had discovered the world’s first hybrid sharks in Australian waters, a potential sign the predators were adapting to cope with climate change.

The mating of the local Australian black-tip shark with its global counterpart, the common black-tip, was an unprecedented discovery.

blacktip shark

Love drove the Romeo and Juliet sharks together, and they created a new sub-species better adapted to the environment. (Freely anthropomorphise: imagine the union of their genetic histories as an overcoming of “racism.” Imagine their courtship; the swirl & flourish of whipping tailfins, the circular spinning and ogling and smelling and general confusion of being the first from either side to ever get so close to each other. That magnetism is eros, what the ancients called love.)

Natural selection by force is seen here:

First-quarter revenue rose 33 percent to $2.44 billion from $1.84 billion as farmers in the southern hemisphere bought more genetically modified corn seed. Chief Executive Officer Hugh Grant is increasing sales in Argentina and Brazil, the drivers of first-quarter earnings, where he plans to introduce the first insect-killing soybean seeds.

There is 0% love in the industrially-induced kind of natural selection, because the creature’s physiology is transformed to survive on Wall Street, a place of pretend, not actual, value. There is no eros intended by Monsanto because the seeds are patented as infertile.

The transformation of the physiology of the soy is an act of force, b/c it is not the intention of soy to be infertile, or to produce poison in every cell of its tissues. Those intentions are forced into its evolutionary continuum—as Bloomberg reports—to “increase sales.”

Now, there is an actual difference in the creaturely results derived from natural selection by love versus that of by force.

The difference is that genes of the new sharks harmonize with the genes of the larger body that is the biotic commons. Their children will have babies, and will survive.

The genes of the Monsanto product harmonize with the pretense of Wall Street, not the biotic commons, and the disharmony is self-evident,
first in the fact that the sub-species of Monsanto GMO is always on the verge of extinction b/c it can’t reproduce via eros, and
2nd because its infertile poison-seeds breed superbugs:

On August 16, Gray verified severe corn rootworm pruning on some Bt hybrids that express the Cry3Bb1 protein in Henry and Whiteside Counties located in northwestern Illinois. The fields were in continuous corn production systems for many years, and the producers had relied upon Bt hybrids that expressed the Cry3Bb1 protein as their primary protection against western corn rootworm injury….

“Unfortunately, yield losses will be significant in these fields,” he added. “In early July, severe storms swept through northern Illinois and caused significant lodging of many cornfields.”

Earlier this month, Aaron Gassman of Iowa State University confirmed field-evolved resistance by western corn rootworm to the Cry3Bb1 protein in an Iowa study. Resistant western corn rootworm adults were collected by Gassmann from continuous cornfields in northeastern Iowa where significant root damage had occurred. These Iowa fields had been planted with Bt hybrids expressing the Cry3Bb1 protein, Gray said.

corn rootworm

Monsanto breeds (but refuses to take ownership of?) a new sub-species of bugs that resist the patented genes it forces into ancient foodplants—increasing the bug’s invulnerability and proving in less than a decade its biotechnology a failure. With the Wall Street intention of increasing market share, it spreads this damage all over the earth, as quickly as possible—as Bloomberg reports. Its natural selection by force is stupid, because it creates more problems for farmers, by making the same old ones worse.

What do you feel about

love versus force
bios versus Wall Street
real versus pretend
babies versus monsters?

natural selection by love, and by force?

—is there a difference?

This post is dedicated to Chris and his love Alejandro! ¡¡Congratulations on making it sacred!!

It’s time to order seeds!! and when we’ve ordered ‘em, we won’t have to think about food weeds anymore…until spring.

We’ve looked @ mustards, tatsoi, wineberries, black walnuts, arugula, shallots, tomatillos, and maybe a few other promiscuous adorables, so lo and behold the procrastinator’s lastgasp list of nominees for the Medallia d’Oro de Dandelion for best food weed:

BUT before you see it,

let’s recall that food weeds demand minimum, almost non-existent, gardening skills except that

1) you must allow the food weed to grow to seed, and drop seed, in a safe, sunny and fertile location, and
2) learn to identify what its babies look like when they pop up all by themselves, and
3) then wait for rainy days to transplant these “volunteers” in patterns you can keep weeded (from the real weeds you can’t eat).

Rouge D’hiver lettuce: winter red, a succulent 1st & last of season romaine. how romantische!
Forellenschluss lettuce: another robust romaine, this time “the Jackson Pollack of lettuce”
Red Sails: a lovely lettuce, “lightly crunchy lobes with a good melting texture.” spreads like a plague of delectable goodness

Tomatoes—buy open-pollinated varieties and let a few ripen, drop & rot into the soil. They’ll be back!

Egyptian walking onion: see for yourself! Don’t buy them—ask around, you’ll find some.

egyptian onions

Jerusalem Artichokes: plant the ones you buy at the Co-op!

Sunflowers: get the Mammoth (trees w/frisbee-size heads) and let a few drop seed. Eat as much as you want and give the rest to the chickens.

Buckwheat: while on the subject of free chicken feed, buckwheat grows fast, improves soil, if sowed tight will block & kill other plants, offers the best honeybee nectar, looks cool (chinese fan type leaves), and drops seed that can be milled for flour.

Alfalfa: chicken and honeybee feed, soil improver, tea tonic, leaves have more protein than Wheaties, edible flowers, perennial.

Hops: yes, for beer and stuffing sleep-inducing pillows, but also for spring shoots cooked like asparagus, prolific perennial, beautiful vine for adorning entrance ways. A sign of civilization.

Asparagus: once going, productive for years. If not for yourself, plant it for others.

Dill and Cilantro.

Burdock: Japanese love them; my favorite oshinko is burdock. Great for the liver. For us, a culinary frontier. And a weed that produces burs you are already familiar with.

Peppermint, Sage & Thyme: don’t buy it! Ask friends for it—and let it take over part of your property. Excellent medicinal nectar for honeybees.

Borage: a woman’s weed that blooms earliest, then all summer, then last. Excellent honeybee nectar. Interesting edible flowers.

borage

Elderberry: grow on the edge of wetlands for edible flowers and berries. Keep your eye out for prolific, good-tasting natives; they grow wild around here.

Mulberries: raspberry trees. Go for trees that produce the darkest tartest fruits, and are cold hardy. (It’s not so easy to find a good-eating mulberry; I got mine from Miller Nurseries, but they are not presently selling the good kind.)

Hazelnuts: you can find these occasionally in the woods, as they are native, but buy some, plant them, and watch them take over.

Hmm…I know I’ve forgotten some food weeds, but I post them as they remind me who they are. In the meantime, help me by offering a few of the food weeds you’ve come to know and admire—

and decide which food weed deserves the legendary Medallia d’Oro de Dandelion.