Volume 5 June 1998

THE RIO SALADO PROJECT - THE REST OF THE STORY

by Steve Brittle
There is a plan afoot named the Rio Salado Project, or the Rio Salado Habitat Restoration Project, as the City of Phoenix has named it. There are some Environmental Justice concerns that are raised by the plan, and questions about its actual environmental impacts on South Phoenix and local residents. (This same basic Rio Salado plan failed in previous democratic elections.) The recent Rio Salado proposal has been claimed to be many things, but it involves having some water flowing and pooling in the dry Salt River bed, with a Phoenix portion from the I-10 bridge over the Salt River (east of 24th Street) extending five miles west to 19th Avenue, and a Tempe portion extending from Priest Drive east to around the Indian Bend Wash.

The US Army Corps of Engineers is the lead federal agency "studying" the feasibility of this Rio Salado Project, and in order to properly conduct the study, the Corps was required to prepare a Draft and Final Environmental Impact Statement, which is required of any "significant federal action." The draft EIS was out for review and comment in March 1998, and the Final EIS and Feasibility Report was prepared in April 1998. An EIS must involve the public and look at the possible environmental impacts of a proposed federal project.

Can the ecosytem along this riverbed be restored, after 50 years of dryness and floods? Once a riparian ecosystem is destroyed, it cannot simply be recreated by adding water. There are other, serious, unaddressed problems with the Rio Salado Project. These range from:

ENVIRONMENTAL JUSTICE REQUIRES REAL COMMUNITY INVOLVEMENT

The problem is, not many in South Phoenix knew about the Rio Salado, or if they did, there are questions about what they were told about it. This is an Environmental Justice issue. A review of the groups that were provided presentations in South Phoenix shows that these presentations were attended by about 17-25 people, who could have been mostly the same small number of people, and that these presentations occurred mostly in the spring through summer of 1997. The groups include the South Mountain Village Planning Committee, the South Mountain Coalition of Neighborhoods, the Central City South Coalition, and a six-member Environmental Justice Committee that was hand-picked by the Arizona Department of Environmental Quality (ADEQ. Note: The Concerned Residents of South Phoenix were never allowed on this committee.] It is unlikely that most South Phoenix residents knew much more than what they were told by the City of Phoenix, and even more unlikely that the full range of comments regarding concerns about or questioning the Rio Salado, the downside, were ever presented. The Draft EIS was never provided to any groups that work on Environmental Justice issues in South Phoenix, even recipients of EPA Environmental Justice grants. There has not more than a small effort to conduct hearings or an outreach to South Phoenix about the Rio Salado Project, in direct violation of Executive Order 12898. The list of parties contacted about the Draft EIS illustrates this. The sand and gravel outfits, City of Phoenix, certain companies, all were contacted and provided the DEIS and opportunity to comment. The actual South Phoenix residents and community groups were left out of the process, unless they knew to look over the Draft EIS at their library.

ENVIRONMENTAL JUSTICE REQUIRES ENVIRONMENTAL ENFORCEMENT

But President Clinton's Executive Order 12898 on Environmental Justice requires the EIS effort to "promote enforcement of all health and environmental statutes." This, it would seem, would require the federal government and state to enforce the laws requiring the cleanup of these landfills and Superfund Sites along the riverbed, and not force the taxpayers to pick up the costs. If public participation were ensured, then it would have already happened, and there would have been meetings a plenty in South Phoenix about this, and there weren't. And if the goal of improving "research and data collection relating to the health of and environment of minority populations and low-income populations" were to be achieved, there would have had to have been these aforementioned meetings that somehow never happened, and these topics would have been discussed. The Executive Order on Environmental Justice seems to have been ignored and certainly not fulfilled.

The EIS process seems to have excluded almost everyone and every group in the Environmental Justice area identified by ADEQ, which includes the area adjacent to where the Phoenix Rio Salado would locate. ADEQ's Environmental Justice Committee did sponsor a trash clean-up in the area the Rio Salado would be built, curiously enough.

RIVER BEDS, DUMPS, LANDFILLS, AND SUPERFUND SITES--JUST MIX AND STIR

There are now a large number (63) of landfills and dumps along the Salt River bed that were not there when the riparian system existed before the Salt River dried up. The cost of cleaning up these old landfills is mentioned in the Draft EIS as $49.5 to $90.8 million, and the Final EIS states there is no plan to even clean them up first. A study completed years ago identified where these dumps and landfills are and who is responsible for paying to clean them up, but no one has ever made this cleanup happen.

The plastic liners for landfills always eventually leak, according to a study by the Government Accounting Office, and so will the clay liners of the Rio Salado Project. Restoring the riparian areas by adding water constantly might cause these landfills to be inundated (soaked with water) and seep their chemical wastes and germs into the aquifer and riverbed. When the next floods along the Salt River arrive, and they surely will, much of these 63 landfills that have been softened up by the inundation of the groundwater caused by the Rio Salado Project might wash out and along the Salt River bed.

Also, the recharge caused by the seepage and constant waterflow from the Rio Salado Project will likely affect the flow of water into and around the 19th Avenue Superfund Site, where the groundwater is about 60 feet down.[A Superfund site is a place with serious contamination, and is generally required to be contained to prevent the spread of chemical contamination, and cleaned up.] Even as recently as May 1998, there have been no studies to determine the effect the Rio Salado could have on the groundwater, nor had the EPA's own Superfund staff ever seen the Draft or Final EIS. One comment on the Draft EIS by the EPA was that the Draft EIS did "not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment." The state version of Superfund, the Water Quality Assurance Revolving Fund (WQARF), also lists many contaminated sites near the Salt River bed. The impacts of the Rio Salado on these is also mostly unstudied and unknown.

JETS DON'T MIX WITH BIRDS AND WETLANDS

There is another, serious issue. There is one of the nation's busiest airports, with plans to add another runway, along the banks of the Salt River, and sandwiched between the Tempe and Phoenix projects. Federal Aviation Administration's (FAA) rules and regulations advise against wetlands and other "wildlife attractants" within a distance of 10,000 feet (about two miles) of the runway of airports serving commercial passenger jets. The FAA also recommends against wetlands and other "wildlife attractants" within a distance of a distance of five statute miles of approach or departure airspace for an airport. These FAA recommendations affect the Rio Salado, according to the Draft and Final EISs. The 10,000 foot advisory impacts the Rio Salado from the 24th Street Bridge on to the east. The five mile advisory impacts the Rio Salado from around Central Avenue east to the I-10 bridge over the Salt River. Of course, why would anyone restore habitat, a "wildlife attractant" near such a busy airport? The danger is in birdstrikes. Birds get sucked into engines of jets or hit them, and cause crashes. There is no way to know. Also, whether these birds will fly between the Tempe and Phoenix Rio Salado Projects is unclear. Evidently, the Corps seeks to gamble and find out what will happen.

WETLANDS EXPERIMENT BREEDS MOSQUITOES AND CREATES PUBLIC HEALTH MENACE

The Draft EIS mentions in a favorable light the Tres Rios Project, which was built to create a riparian (riverbed ecosystem) area in the vicinity of the 91st Avenue Wastewater facility operated by the City of Phoenix. The Tres Rios uses wastewater from the sewage treatment plant and has the artificial wetlands further treat the water. It has recently come to public light that all is not going as planned at the Tres Rio Project. The water coming out of the Tres Rios has high levels of fecal coliform in it because the animals that were attracted there don't use toilets. Worse, enormous numbers of the Culex mosquito that carries human and equine encephalitis have been attracted to and caught in mosquito traps near there. When mosquito traps were set out to find out how many mosquitoes were at the Tres Rios, these traps regularly caught 500-800 of the encephalitis-carrying Culex mosquitoes every night. One night, over 10,000 were caught! Yet, according to comments in the Final EIS from the Arizona Department of Health Services, Office of Infectious Disease Services, "Collections of 20 or more mosquitoes per trap night are considered a public health risk requiring corrective action by health officials." And the birds that wetlands attract actually carry the encephalitis disease and give it to the mosquitoes that bite them. The Rio Salado would be over 14 times the size of the Tres Rios.

This raises the specter of what will happen when and if the Rio Salado Project is built. In the Draft EIS, mosquitoes would be controlled by "native predators" that "will be introduced or attracted to the area should mosquitoes become problematic." But it seems that once these mosquitoes become "problematic," the damage is done and it is too late. Mosquitoes can travel up to five miles from where they hatch out after the larval stage.Once there is an outbreak of any disease carried by these mosquitoes, and/or when clouds of these mosquitoes find the spectators at a night game at the baseball stadium, or in the residential areas of South Phoenix, the effect would likely be that people will avoid the downtown area and Salt River bed, and the businesses and communities nearby will likely suffer severe economic hardships. Besides, these natural controls somehow have not worked well enough at Tres Rios to prevent a problem. Fortunately, the Tres Rios Project area is sparsely populated at present; the Rio Salado Project is near hundreds of thousands. In the Draft EIS, there assertion is made that "No chemical pesticides shall be employed." The Final EIS admits that there would have to be spraying of chemical pesticides. If natural controls fail than clouds of the pesticide Malathion will surely blanket the area, as well as downtown and South Phoenix.
DON'T GO NEAR THE WATER
(See Table 1.)

Table 1: Surface Water Quality Standards for the Salt River

Partial Body Contact
Acute/Chronic 		Wildlife/Aquatic
(warm water fishery)
Acute/Chronic
Fecal Coliform (cfu/100ml)4,000 / 1,0004,000 / 1,000
Arsenic (ppb)2,800360 / 190
Mercury (ppb)42 T2.4 / 0.01
TCE (ppb) 20,000 / 1,300
PCE (ppb)4,0006,500 / 680
TCA (ppb)13,0002,600 /1600
Benzene (ppb)4702,700 /180
Chloroform (ppb)1,40014,000 / 900
cfu/100ml is coliform-forming units per 100 milliliters
ppb is parts per billion
No standards for Total Suspended Solids, Total Dissolved Solids, Chloride, Fluoride, or Nitrate

Another issue the "quality" of the water allowed in the Rio Salado. The Surface Water Quality Standards for the Salt River in this Rio Salado Project are horrifying. [See table above] Considering that the Motorola 52nd Street Superfund Site is considered a federal Superfund site due to the Trichloroethylene (TCE) that is there, and considering that there is a requirement that the aquifer in the Superfund Site is required to be cleaned up to 5ppb (parts per billion) TCE, having a standard of 20,000 ppb acute and 1,300ppb chronic for TCE in the surface water of the Rio Salado is an abomination and a threat to public health. There has already been discussion of taking water treated to the 5ppb standard from the Superfund Site and channeling it to the Rio Salado, so one can only wonder if it is likely that the contaminated water from the aquifer will be pumped, untreated, directly into the Rio Salado. The standards for the other chemicals are similarly unacceptable. Benzene in any concentration provides an additional, unacceptable, cancer risk. The cumulative impact of all these dangerous chemicals, TCA, TCE, PCE, Benzene, and Chloroform, as they volatilize and waft over the South Phoenix area, an identified Environmental Justice area, are not addressed in the Draft or Final EIS. The cumulative effects of these chemicals with the other many industrial chemicals already in the air in South Phoenix are completely unaddressed by the Draft or Final EIS. To be adequate, the EIS would have had to reviewed the chemicals already in the air in South Phoenix and then reviewed the additional chemicals to be put into the air in South Phoenix from the offgassing from Rio Salado Project.

The absence of this type of cumulative risk study further raises questions about Environmental Injustice, Environmental Racism, and Clinton's Executive Order 12898. These chemicals present a health hazard to children and weakened populations, and their cumulative effects remain unaddressed. The fecal coliform limits of 4,000 cfu/100ml acute and 1,000 cfu/100ml chronic in surface water are dangerous, more than five times the normal discharge standard as allowed by federal Clean Water Act. Children and animals can conceivably get wet and carry home diseases. If they don't, there will be plenty of flies, mosquitoes, and other vectors to do this. Tres Rios has already shown us that fecal coliform limits will be exceeded when wildlife is attracted to these wetlands.

EFFORT IN FUTILITY?

The Draft EIS even admits that many of the plants planned for revegetation in the Rio Salado Project would be harmed by high concentrations of Total Dissolved Solids (TDS), but there are no Surface Water Quality Standards for the Salt River in the Phoenix portion of the Proposed Rio Salado Project for TDS, Total Suspended Solids (TSS), or even Chlorides, Fluorides, Nitrates, which are all salts and harmful to plant life, or DBCP. Since there is no standard, there is no way to enforce a water quality that would prevent the revegetation project from being poisoned and replanted year after year on taxpayer expense.

FLOODS

The Salt River has had devastating floods in the years that Phoenix grew up around it. Even the bridges have washed out during some of these floods. What if a new flood wipes much of the Rio Salado out again? How can anything be built in the riverbed without the chance that someday it will all wash away?

FOREIGN SPECIES CROWD OUT NATIVE PLANTS

There are also new invader species since the Salt River bed dried up that would irreversibly complicate a "restored" riparian ecosystem. An example of this is bermuda grass, which in a short amount of time would choke all the banks and areas adjacent the Rio Salado Project with its growth. There are no natural controls on this bermuda, or on several other invasive foreign plant and animal species that would prevent the successful re-creation of the riparian area planned for the Rio Salado Project. The newly renamed Rio Salado Habitat Restoration Project claims to be about "environmental restoration," restoring a riparian ecosystem along the Salt River bed. The Final EIS says the same, but also admits it is for "incidental recreation along the Salt River." So there remains a real question about what amount of public recreation in the Rio Salado would be encouraged, and what the real agenda is behind the proposal. The Rio Salado Project would be funded by federal tax dollars. The Congressman for South Phoenix is the Honorable Ed Pastor. His local office number is 256-0551.

MORTALITY (DEATHS) IN THE AREA AFFECTED BY THE QPC FIRE

by Steve Brittle
For purposes of tracking and statistics, our populated areas are divided up into census tracts. We get reminded of this when the Bureau of the Census counts the people living in an area every ten years, or more often as is needed. When the census count is taken, we often get forms in our mailboxes to fill out and/or people come to the door asking questions. After the 1992 QPC fire, when several people had died in the affected community under strange circumstances, these deaths were mapped out by the community. The map of these deaths showed the deaths in a straight line going east from the fire, especially on Chipman Road, the same route of the thickest toxic plume from the fire. A trail of five deaths on this street within two blocks and within a few weeks focused attention on Chipman and the issue of deaths in the affected community. (Now twelve to fourteen deaths have been reported in the same vicinity.)

Knowing that the Arizona Department of Health Services (ADHS) and Maricopa County health department were going to "study" the rising death rate, and expecting a flawed conclusion, especially after officials from these two agencies had already tried to brush off the community's concerns as "stress and hysteria,"the Concerned Residents of South Phoenix and DWA, held a demonstration at the state capital to ask for help.

The ADHS and county health agencies' studies looked at the census tract information, and even provided and compared the census tract data for many census tracts in South Phoenix, but compared different census tract data from areas where the smoke from the fire was known to have traveled. The government studies and press release asserted that there had not been an increase in the death rate in the census tract (1160) downwind of and adjacent to the fire. An ASU student (a DWA volunteer) showed these government agencies their simple math error, and they responded in writing about how she was wrong. The community then hired an ASU professor, an internationally-known statistical expert, to review the mortality study. When he proved that the death increase was statistically significant, the county admitted its math error and concluded the death rate had indeed increased, but blamed their fundamental "error" on a "software problem." Another interesting item that surfaced during the comparison of the death rate in census tract 1160 was that there had been a very steep increase in the number of deaths in that census tract in the time after the 1989 fire at Quality Printed Circuits and had just started to come down when the 1992 fire occurred. But no one at the government agencies that gather and study census tract death information even noticed something had happened in 1989! This lack of a "safety net" helped the community understand that something awful could happen that could harm or kill people and no one in the government was actually watching out for these types of problems. Even today, if a chemical disaster happened that caused people to die in one area, the "system" is not geared to detect this. In other words, a very large number of people have to die quickly, about the same time, and in a large area, before the government would notice or acknowledge it. And this is still not a guarantee that the government is geared to take timely action. The mortality information for a census tract is released in May for the previous calendar year. People could be suffering or dying for months before this system would even have an idea that something had gone very wrong. This is with the assumption that the government agencies would not try to cover up or refuse to discuss the problem. The Arizona Department of Environmental Quality (ADEQ) had put out a community newsletter that stated there was no significant increase in deaths in the area affected by the fire, but when the ASU professor proved there was an increase in deaths, the next ADEQ newsletter dropped the subject of the deaths, but it exhorted people to clean their homes.

To examine the information about the death rate in census tract 1160, but to use census tracts that were not exposed to the smoke from the fire, DWA gathered the mortality information for three census tracts that were outside of the smoke plume, all the way back to 1982. These are Census tract 1158, 1164, and 1165. Census tract 1158 is bordered by Broadway, Southern, 7th Street, and 7th Avenue. Census tract 1164 is bordered by Baseline, Southern, 7th Street and 16th Street. Census tract 1165 is bordered by Southern, Baseline, 7th Street, and 7th Avenue. (The control homes used by EPA in its recent round of sampling were from this area.) Census tract 1160 is bordered by Southern, Broadway, 16th Street, and 24th Street.

Using the exact same format and methods used in the original mortality studies, but using the correct math, DWA found that the death rate in these three census tracts that were outside of the smoke plume did not change too much in the last fifteen years. The death rate in census tract 1160, however, did change, remarkably, after both fires. (The graph of this information is here for you to see.) Meanwhile, the overall population of census tract 1160 has been declining by about 10% since the date of the fire.

The number of deaths per year per census tract averaged over 16 years (1982-1997) is also plotted out on the graph. In general, the number of deaths per year in a census tract will flunctuate from year to year, and looking at the average annual number of deaths will perhaps help visually in determining if there is something unusual happening. (All census tracts do not have the same numbers of residents.) The average annual deaths for census tract 1158 is 38.9, and the largest margin away from this is about 11 or 12 deaths. The average annual deaths for census tract 1164 is 22.1 deaths, and the largest margin away from this is about 8 deaths. The average annual deaths for census tract 1165 is 30.3 deaths, and the largest margin away from this is about 12 deaths. But the average for census tract 1160 is 47.1, and the largest margin away from this is about 26 deaths. If we look at the number of deaths in census tract 1160 from the time of the fire in 1992 to 1997, the average annual deaths is 54.5 deaths. So it looks like census tract 1160 has a very different pattern of deaths than the other, unaffected census tracts, especially after the fire.

On a final note, the information about the deaths and causes of death in the census tracts in Arizona is gathered and available to the public at the Office of Health Planning, Evaluation and Statistics of the Arizona Department of Health Services. This office of the Arizona Department of Health Services has always been helpful by providing all of the public information to those who request it. The staff in that office, however, while always expressing their sincere sympathy for the community, have also always insisted that the methods of studying the deaths used by the Arizona Department of Health Services' Office of Risk Assessment and Investigation and Maricopa County's health department is SIMPLY NOT the way these studies are conducted. The staff at the Office of Health Planning, Evaluation and Statistics of the Arizona Department of Health Services have always asserted that there is no valid way to "statistically" study such a small population of even a few thousand, that the statistical studies must always include far larger populations, and agree that there is no way currently used and recognized by statisticians to determine if many people in a small area are being killed by the toxic aftermath of a chemical disaster.

This last note, of course, questions all of the work that has been done, including the state and county's earlier assurances that there was never a problem with excess deaths in the affected community, according to their "studies." All of this raises other issues in Environmental Justice. People in poor and minority communities have claimed for years that environmental toxins have made their people ill or caused early and excess deaths, and perhaps even now there is no way for the "experts" really know. Unfortunately, when there is uncertainty about an environmental problem, it seems that the benefit of doubt always goes to the polluter and not to the people making the complaints.



TOSC UPDATE:

THEN:In the last newsletter, TOSC stated it had sent a letter to the Arizona Department of Health Services (ADHS) requesting specific mortality data from the area affected by the QPC fire. TOSC was attempting to get from ADHS the dates and specific addresses of deaths in the Census Tract in which the QPC facility was located. With this information, TOSC would attempt to map out the deaths to see if there was a concentration or clustering of deaths in the area where the plume of smoke from the fire went. The ADHS has to maintain the confidentiality of the names of the deceased, and has not provided the mortality information in the past. NOW: TOSC submitted its request for the data and its proposed methodology for maintaining confidentiality to the ADHS Human Subject Review Board on May 11th. This was to be reviewed at their meeting on May 21st. As of June 2, 1998, TOSC had not heard back from them regarding the status of TOSC's request or their decision. For the time being TOSC's plan is to contact them sometime during the week of June 22nd if TOSC still has no update by that time.

Perhaps with TOSC's assistance, we will get to see a map of the deaths. The state had promised the Environmental Protection Agency this information about the actual locations and dates of deaths the summer of 1997, but still has not provided this information, although it is in its computer database that could easily provide this information.

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