The MOF&G Online
Letter to the Editor
I enjoyed Roberta Bailey’s articles about butterbeans (Dec. 2003-Feb. 2004 MOF&G), but would like to add a wonderful way to eat them: Boil the pods in very salty water for eight minutes. Then go sit outside on the deck and pop the warm beans out of their pods and into your mouth. A little salt from the water gets on your lips. Scrumptious and more fun than corn on the cob.
Warnings about Autumn Olive
I was concerned to read the article by Sarah Dilworth recommending autumn olive (Eleagnus umbellata)--this plant can be extremely invasive, taking over the edge between forest and field and driving out native species. It is also a nitrogen fixer, which further upsets the growth of natives. While Ms. Dilworth’s trees may not have seemed to spread, it is not the individual trees spreading that is the problem--the berries are eagerly devoured by birds (it used to be recommended as a bird-attracting landscape plant) and the seeds deposited far from the parent trees.
All the other New England states, as well as the New England Wildflower Society, consider this plant to be a threat. Russian olive (Eleagnus angustifolia, near cousin of the autumn olive) is considered an invasive in Maine. Natural systems in Maine are under enough stress so that perhaps it were better if we didn’t purposefully add one more potential threat to our native ecology.
In the December 2003-February 2004 issue of The MOF&G, Sarah Dilworth recommended planting autumn olive (Eleagnus umbellata) as a source of berries. Her enthusiasm reminded me of my own when I first encountered the plant 15 years ago. However, since then I have learned more about it. As a member of my local conservation commission, I have attended several workshops on invasive plants sponsored by the New England Wildflower Society where autumn olive and Russian olive were mentioned. Both plants are considered invasive exotics in Massachusetts, where the Massachusetts Division of Fisheries and Wildlife has prepared a fact sheet describing how they threaten native species. The fact sheet states, "their prolific fruiting, seed dispersal, rapid growth and ability to thrive in poor soils make them a heavy competitor with native species. Their nitrogen-fixing capabilities have the capacity to adversely affect natural communities whose native species are adapted to infertile soils." More to the point for people in Maine, I have been fighting autumn olive on my own property in central Maine (zone 4). A dozen specimens, which I planted about 15 years ago for wildlife habitat, have spread widely into the field, lawn and woods edges of my property and have also moved into my neighbor’s field. The plants resprout vigorously when cut and are impossible to dig out once they grow sizable trunks. Gardeners might want to consider planting native species instead--chokeberry (Aronia arbutifolia), American cranberry bush (Viburnum trilobum) or common winterberry (Ilex verticillata).
Sewage Sludge and Organic Agriculture
To the Editor:
I am writing on behalf of the Maine Wastewater Control Association (MWWCA) concerning both the recent article, "Sludge by Any Name Will Never Be 'Organic,'" by Sue Smith-Heavenrich (The MOF&G, Sept.-Nov. 2003), as well as MOFGA's new sewage sludge policy.
Ms. Smith-Heavenrich's article perpetuates an outdated perception of widespread and blatant water pollution from municipal and industrial sources that dates back literally decades. This stereotype of toxic wastewater emissions is a popular "bad guy" theme in the media even today, including references in children's cartoons and adult humor like "The Simpsons." While numerous "bad apples" have, no doubt, committed crimes against the environment and public health in the past, the cleanup of our nation's waters is one of the great environmental success stories of our times. Ms. Smith-Heavenrich's characterization of widespread toxic emissions has been outdated for years. Rather than elaborate on the many specific technical inaccuracies, I will focus on some of the broader issues that relate to this article.
First, Ms. Smith-Heavenrich never provides constructive thoughts on what a sustainable society should do with sewage sludge or suggestions to improve the current situation. She seems to be unaware that many dedicated professionals have chosen to tackle these problems, rather than run from them; people who recognized that municipal wastewater treatment solids are fundamentally an organic material that, with proper treatment and control of contaminants, is best suited for agronomic use; people who have supported extensive research to assess the risks posed by heavy metals and other contaminants to agronomic use; people who have investigated the sources of contamination in your communities and implemented industrial pretreatment and pollution prevention programs to reduce contamination to safe levels. In fact, members of the Maine wastewater community were among the early leaders in the environmental movement to recognize that agronomic use of wastewater solids is the preferred management approach for a sustainable society. In Maine, agronomic use of sewage sludge has a track record of safety and positive benefits dating back to at least the early 1960s. Until the early 1990s, MOFGA allowed the use of sewage sludge meeting specific criteria on organic fields.
The reality is that for over two decades industries have not been allowed to discharge toxic materials that would adversely affect either the wastewater treatment process or the suitability of the resulting solids for agronomic use. For these and other reasons, the industry has been under intense pressure to minimize or eliminate the use of toxic compounds whenever possible, and most have successfully achieved dramatic reductions. Over this time period, the levels of heavy metals and other contaminants in wastewater solids have decreased dramatically. Moreover, the Maine Department of Environmental Protection has been a leader in assessing the potential risks of agronomic use and has developed one of the most comprehensive and conservative sets of regulations in the country. Furthermore, the Maine DEP has a strong and active enforcement team.
The strong emotional response against sludge-derived products by a relatively small portion of the population is an ongoing public relations problem. The wastewater industry is a target of suspect, because of the past history of abuse. One comment that we hear repeatedly is, "How can you be sure that there are no toxic dumps?" Part of the answer is that we can see the impact of a toxic dump immediately on wastewater treatment processes, long before there is an issue in the resulting solids. Part of the answer is the strong regulatory and enforcement framework that is in place to protect from these abuses. There are also strong economic incentives for industries that rely on municipal wastewater treatment facilities to comply if they are to continue to receive wastewater treatment services and stay in business.
Another critical issue is that Ms. Smith-Heavenrich's article never provides any assessment of the relative risk of sludge-derived products compared with other agricultural fertilizers and amendments. She seems to be unaware that all organic soil amendments and most inorganic fertilizers contain heavy metals. A number of papers are cited regarding the risk of heavy metals without relating the risks specifically to current regulatory limits or the actual levels found in sludge-derived products. In fact, the levels of contaminants in sludge-derived products are monitored more thoroughly than any other soil amendment and are subject to stringent regulatory limits that may not apply to other agricultural amendments. Because of the strict regulations on the use of sludge-derived products, a recent study by the Water Environment Federation found greater potential environmental effects from the use of manures with respect to phosphorus, some metals, and pathogens, and from mineral fertilizers related to nitrogen impacts.
With regard to the new MOFGA policy, I would like to express our disappointment that MWWCA was not invited to provide input. While we understand that MOFGA is a diverse group with many opinions, this new policy is clearly a shift toward the viewpoint presented in Ms. Smith-Heavenrich's article. The policy statement includes constructive elements, but it offers no specifics. I would like to challenge MOFGA to move forward and put the flesh of specific criteria into the policy. If agronomic use of sludge-derived products is the preferred management approach of a sustainable society as the MOFGA policy statement indicates, and as we strongly believe, then what are the criteria that MOFGA believes need to be met for agronomic use in conventional farming or landscaping applications? And in the future in organic agriculture applications? If we are to move forward toward a sustainable society, these questions must be answered. I would further challenge MOFGA to assess the relative risks posed by sludge-derived products compared to other agricultural fertilizers and soil amendments including inorganic fertilizers, raw manures, and composted manures, yard waste and food wastes.
In the wastewater industry, we are accustomed to facing new challenges every year as our understanding of the environment improves and the pressures of population growth increase. In this context, we must continually assess the safety of current practices and not be afraid to make improvements when necessary. I hope that we can work with MOFGA to help further the dialogue on these important issues in a constructive way.
Jeffrey Pinnette, P.E., Chairperson
Response to Pinnette’s Concerns
From the author--I appreciate Jeffrey Pinnette taking the time to comment on my article. He notes that in the past 20 years, industries have cleaned up their effluents. The problem isn't how "clean" wastewater is, but whether spreading sludge on our cropland is sustainable.
Pinette asks how manures and other fertilizers compare to sludge with respect to heavy metals. Here is one example: Dairy manures contain a mean concentration of 7.5 ppm lead, while triple superphosphate contains about 11 ppm, and composted sludge from the Syracuse, New York, N-Viro facility contains a mean of 132 ppm. [Ed.: The maximum allowed in Maine sludge is 300 ppm lead.]
The issue isn't just heavy metals. A report from Chicago ("Will Suburbs Clean Up Water By Dirtying Land?" by Dave Orrick, Daily Herald www.dailyherald.com, 1/25/04) examines the problems with the concentration of radionuclides that occur naturally in the water accumulating in sludge. And on Dec. 31, 2003, the EPA said that it would begin regulating 15 more pollutants in sludge -- pollutants that are already considered to be hazardous to the health of humans and wildlife.
Science News (Jan. 15, 2004) cites the USGS study on treated sludge and sludge-derived products. Says the USGS, "If these results are indicative of biosolids around the country, then sludges constitute a ubiquitous, diffuse source of organic contaminants to soil and water through runoff."
Even folks at the EPA are having second thoughts. On Oct. 29, 2003, Paul Gilman (EPA spokesman and assistant administrator for research and development) said, when asked about sludge safety in a CBS interview, "I can't answer it's perfectly safe."
I wish I had space to examine water pollution, air pollution, livestock health, alternatives to current waste stream management and other sludge-related issues, but I was writing an article, not a book. Folks who want more background on sludge may wish to order the "Sewage Sludge Report" from NOFA-NY, a 10-page introduction to the issues. Send a check for $2.50 to NOFA-NY, PO Box 880, Cobleskill, NY 12043-0880.
From MOFGA’s Public Policy Committee--
The MOFGA policy statement on spreading sewage sludge on land, calling for better monitoring and regulation of its use on nonorganic farmland, does not deny the good work of the Maine wastewater community to make sewage sludge safer for agronomic use. MOFGA and the Maine Wastewater Control Association share the ultimate goal of making the best use of the valuable plant nutrients in sewage sludge, instead of wasting this potential fertilizer in landfills or by incineration. In fact, MOFGA’s public policy committee did meet with the Maine DEP before drafting its new policy.
However, the MWWCA is also responding to the enormous pressure (after ocean dumping was banned) to dispose of large quantities of sewage sludge as cheaply as possible. The concern of environmentalists is the insufficient ongoing testing of the changing "biosolid" waste stream or longer term monitoring of the land where it is applied and the water that runs through that land. Standards need to be reexamined over time, additional contaminants of concern added to those monitored as new research surfaces, contamination loopholes need to be addressed (householders, smaller industries, institutions and others... that still dispose of toxics into municipal sewers). And future changes in the use of land where sludge has been applied, from nonagricultural to agricultural, need to be considered.
The charge that sludge spreading is monitored for toxics better than other agricultural amendments only argues that these other fertilizers should be better regulated, not that the monitoring of sludge is adequate.
As for not offering specific solutions, MOFGA's policy statement is a position, and a social goal--and it conforms to USDA organic standards that prohibit sludge spreading on certified organic land.
To state a concern is to begin a process of change. MOFGA is one organization with a broad agenda and limited resources. Everybody needs to think about this enormous problem of how to dispose of our waste safely and with overall benefit.. Pressure needs to be applied "back up the pipe" to where the contaminants (heavy metals, chlorinated hydrocarbons, pharmaceuticals...) enter the waste stream. We need a safe "cradle to grave" system of tracking the toxics generated in our economy; we need to eliminate the use of many of these materials by adopting new technologies; and we need better ways of catching unsafe innovations. In the meantime, we need to put more money and effort into monitoring.
Our land is all we've got.
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