Editor’s note: I posted this letter to Ed Tullock, at the Idaho Department of Environmental Quality’s Coeur d’Alene Regional Office, and Philip Cernera, at the Coeur d’Alene Tribe, on January 24, 2003.
COMMENT ON THE ADDENDUM TO THE LAKE MANAGEMENT PLAN
Dear Messrs. Tulloch and Cernera:
The introduction to the proposed draft Addendum to the Lake Management Plan (A-LMP) offers a series of five recent changes in the situation of Lake Coeur d’Alene and the Coeur d’Alene Basin that, in turn, are employed as wouldbe justifications for the need for the Addendum‘s creation.
The third of these five wouldbe justifications is titled ” Superfund Basin wide RI/FS” and begins with the following two sentences:
In 1996, a human health blood lead study was conducted by the State of Idaho. This study indicated that a significant percent of children tested in the Basin, outside the current 21 square mile Bunker Hill Superfund site had elevated blood lead concentrations.
I will focus my comment almost exclusively on these two sentences, referring to them hereinafter as “the quotation.”
- Why does the quotation use 1996 data to describe the Basin’s childhood blood lead level (BLL) situation? Basin-wide screening surveys have been conducted annually since 1996, and the results of the two most recent studies (in 2001 and 2002) show BLL exceedance frequencies at roughly the national average. Are not the most recent data the most salient and appropriate in describing a phenomenon that is known to be trending downward in this region and in the nation as a whole? In other words, it would have been more accurate, and more appropriate, for the A-LMP to assert that recent screening survey data placed the Basin’s BLL exceedance rate at or below the national average. Why was that more accurate assertion in fact not made?
- Of course, the 4% exceedance rate for the Basin measured in the summer 2002 survey might have been inaccurate and underestimated the true exceedance rate. The same might be said, however, about the 1996 survey. Indeed, the 95% confidence interval offered for the 1996 survey allowed that the true exceedance rate figure might be as low as 4.3% (see ATSDR, Coeur d’Alene River Basin Environmental Health Assessment, August, 2000, p. 1). Better survey methodologies might resolve the issue of high error around population screening surveys, but DEQ and EPA have repeatedly turned a deaf ear to our requests for better surveys or even a full census of childhood BLLs. Might the quotation have mentioned that awkward fact as well?
- Of course, EPA no longer relies on survey estimates to justify its human health remediation enterprise in the Basin. EPA relies instead on its IEUBK simulation model, which generates exceedance estimates rather higher than those generated by screening surveys. Why didn’t the quotation rely on IEUBK estimates instead of survey estimates that EPA tends to regard as uncertain and inaccurate?
- EPA argues that the Basin’s current, IEUBK-identified BLL risk is in effect a statement about potential risk rather than actual prevalence. Yet, the same sort of problem-exaggerating rhetoric occasioned EPA’s removal from the Smuggler Mountain Superfund site in 1993. Perhaps the quotation might have mentioned this aspect of the scientific situation as well.
- The quotation asserts that “a significant percent” of children report elevated BLLs. The text eschews reporting an actual percent and moreover leaves the reader to imagine what a “significant percent” might be. In fact, the Basin’s most recent 4% figure compares favorably with other counties or even entire states around the nation. For example, Indiana reported a statewide childhood exceedance rate of 9.6% in 2001; Rhode Island reported 8.1% in 2001; Ohio reported 6.2% in 2001; Virginia reported 6% in 2000. Of course, county-level figures vary around state-level means — and it would require many person-hours of work to assemble a list of county results in the U.S. that exceed, that double, treble, quadruple, or show even higher exceedance rates than Shoshone County’s rate. Where, then, was this sort of contextual information in the quotation?
More might be said about the quotation that I’ve highlighted. For instance, what is such an assertion doing in the Addendum to the Lake Management Plan at all? But I will stop with what I’ve said already, above. The quotation offers a biased picture of the childhood BLL situation in the Basin in order apparently to achieve the authors’ rhetorical ends. Those ends appear to require exaggerating the human health and environmental circumstances of the Basin in order to justify the A-LMP‘s measures. The quotation is just one small element of this larger rhetorical enterprise.
Yet the quotation illustrates how capricious and biased the authors of this text can be. The authors did not employ the most recent BLL data, they did not draw attention to the weaknesses of BLL estimates, they did not frame their assertions in a wider national context that would show the Basin’s BLL levels in a favorable rather than an unfavorable light.
Moreover, one of these authors — namely, the Idaho Department of Environmental Quality — is ostensibly the servant of the Idaho’s citizens and communities. Yet DEQ appears to have been quite willing to create or at least acquiesce regarding assertions that paint our human health circumstance in the darkest possible — and inaccurate — shades.
I wonder what would result from a sentence by sentence evaluation of the rest of the draft A-LMP‘s text? Could the same sort of biased, self-serving, and propagandistic orientation be lurking elsewhere, often, or everywhere in the text?
The quotation, I fear, speaks volumes about the authors’ disregard for accuracy and fairplay.
[signed] Ron Roizen