OSCODA – More than 200 individuals, businesses and organizations have signed on to a letter which the Need Our Water (NOW) community action group has prepared, to comment on the Air Force’s (AF) proposed interim remedial action (IRA) plan for Clark’s Marsh in Oscoda.
As previously reported, three alternatives are being looked at to address the perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) – two types of per- and polyfluoroalkyl substances (PFAS) – which are migrating via groundwater to the marsh, due to the past use of PFAS-containing firefighting foam near the site.
Alternative No. 1 entails no action, Alternative No. 2 involves expanded hydraulic control using a pump-and-treat system with ion exchange and Alternative No. 3 – which the AF has deemed as the preferred method – would be expanded hydraulic control using pump-and-treat with granular activated carbon. Based on the current schedule, the IRA work at the marsh will start in July.
The AF had been accepting public comments on the proposal during a 30-day period, which ended April 17. They are to respond to the formal comments within a summary that will be included in the Clark’s Marsh interim record of decision.
NOW members reached out to other various entities, requesting that they sign the letter. According to NOW Co-Lead Cathy Wusterbarth, the document was created by the group, with the assistance and vetting of Robert Delaney, geologist and retired Department of Environmental Quality specialist at the former Wurtsmith Air Force Base (WAFB); Mark Henry, Wurtsmith Restoration Advisory Board (RAB) community co-chair; and Anthony Spaniola, NOW member and attorney.
“Unfortunately, the Air Force has given us very little time to respond to their complex plan and the end of the comment period is on April 17th,” Wusterbarth stated, when reaching out to potential letter signers.
“We are tirelessly working to help Oscoda/Ausable get the PFAS clean-up it deserves,” she also expressed.
The finalized correspondence, dated April 16, is addressed to the AF’s Base Realignment and Closure Environmental Coordinator, Dr. Catharine Varley. It appears in its entirety as follows:
“On behalf of the Michiganders, businesses, organizations, and individuals and organizations from around the nation, we are writing to provide comment on the Air Force’s proposed [IRA]plan for Clark’s Marsh.
“While we acknowledge the work that has gone into producing the IRA, the alternatives proposed in the plan fall short of the expectations of the community of Oscoda, and the Air Force’s resistance to include community voices in the process when alternatives were being actively developed and evaluated has resulted in a plan that does not center the concerns and local knowledge available in the Oscoda community.
“In short, the IRA plan being proposed does not provide an alternative that will adequately address the full extent of the imminent and substantial threats to human health and the environment from PFAS contamination coming into and out of the Clark’s Marsh area, falls short of acknowledging the full scale of the problem, and will not do enough to protect the health of families in Oscoda. Specifically, the Air Force has focused in on one narrow plume area, leaving out adjacent PFAS plumes for capture, and has wrongly chosen to ignore Michigan’s PFAS clean-up standards as the standards for the project.
“The Air Force must immediately and fully clean up the imminent and substantial threats to human health, fish, wildlife and the environment from PFAS contamination in the Clark’s Marsh area, including implementing additional interim actions to address all PFAS contamination plumes in the area. While alternative 3 proposed in the Clark’s Marsh IRA plan should be implemented, the IRA for Clark’s Marsh does not adequately address the imminent and substantial threats to human health, wildlife and the environment from PFAS contamination in the Clark’s Marsh area. In short, the number and the location of extraction wells do not capture the PFAS contamination in the Clark’s Marsh area to adequately address the imminent threats. Therefore, we urge the Air Force to adopt the revisions to alternative 3 being proposed in separate technical comments by community RAB members and community voices.
“Additionally, we urge the Air Force to comprehensively test and monitor the effectiveness of its clean up system now and into the future. Any clean up system expanded or installed at the site must be able to illustrate its effectiveness consistently in the removal of PFAS contamination from the environment. Just as importantly, the remedial investigation must include a comprehensive accounting of all PFAS contamination flowing into and out of the Clark’s Marsh area, and throughout the site, and tangible steps for eliminating or treating future contamination.
“It is clear, based solely on the comments during the Air Force’s town hall introduction to the plan on March 24, 2021, that the community does not agree that what is being proposed for this site is adequate to clean up the imminent and substantial threats to human health and the environment from PFAS contamination in the Clark’s Marsh area. Perhaps most concerning is both the Air Force’s refusal to comply with the state of Michigan’s new PFAS drinking water standards (which also serve as groundwater cleanup criteria) or the state’s longstanding surface water PFAS standards for this IRA. In 2017, the Air Force promised, in writing, to comply with Michigan’s groundwater surface water interface (GSI) standards at Wurtsmith (and at Clark’s Marsh in particular) – with the release of the first interim clean-up plan, the time has come to honor that promise and to honor the laws made to protect the health of Michiganders.
“The Air Force must comply with the PFAS drinking water standards recently set by the state of Michigan and Michigan’s groundwater surface water standards when undertaking any clean up action at Wurtsmith. As the Air Force stated in the March 24 town hall meeting, it ‘will probably’ comply with state law during the next phase of clean up and has the technology to currently meet Michigan’s standards. With both the will and the means, there is no reason for delay as the longer we wait, the more PFAS that leaches into the environment and threatens the community.
“PFAS contamination flowing through Clark’s Marsh is a threat both to people and to the fish and wildlife living in the area. Clark’s Marsh currently has in place three consumption advisories (for fish, deer, and all other aquatic and semi-aquatic wildlife) the most, to our knowledge, of any area in the country for PFAS contamination. PFAS contamination from the base is flowing through Clark’s Marsh and into the Au Sable River – a renowned destination for fishing, the Huron Manistee National Forest – a crown jewel of Michigan’s public lands system, and discharges into Lake Huron, a source of drinking water for millions of people in the United States and Canada, as well as the drinking water source for Oscoda’s city water.
“These advisories and the clear impacts to drinking water and natural resources are another indicator that we cannot delay in taking comprehensive clean up action – the longer we wait, the more PFAS will be released into the environment, exposing people and wildlife. And most importantly, clean up actions that do not address the full scope of the contamination will only compound the real time threats to peoples’ health and the local economy.
“Preventing PFAS migration from the base sooner rather than later will minimize the ongoing release of these dangerous chemicals to the community and the environment. PFAS are migrating off-base at levels above state criteria across nearly half of the base boundary. This contamination needs to be hydraulically controlled as soon as possible through multiple IRA’s, and as new PFAS technologies become available they can be implemented to further address the problem.
“Finally, the Air Force must open its clean up development process at the front end to include input by community voices. Specifically, community RAB members who are designated by the Air Force as representatives of community voices must have access and a say in plans prior to being released to the public for comment. These community RAB members provide invaluable local knowledge, experience and input based on past history and present day conditions that would not be otherwise available to the Air Force or it’s sub-contractors. Only by doing this will the Air Force actually put together alternatives that take community voices into the planning conversations. Impacted residents must have a seat at the table in a process that has direct implications to their health, their livelihoods, their community and their way of life.
“The repercussions of the decisions made for the Clark’s Marsh IRA are a bellwether for future success at Wurtsmith, and we urge the Air Force to listen to the straightforward and attainable requests from Oscodians and Michiganders to take comprehensive, inclusive action for clean-up now.”
Those who signed the letter consisted of several NOW leadership team representatives, 12 RAB members, roughly 40 organizations, 25 businesses and more than 120 individuals.
Among the individuals who added their names were several residents/property owners in Oscoda Township, AuSable Township, Harrisville and other municipalities; retired military and fire department personnel; Realtors; attorneys; professors and representatives of such entities as District Health Department No. 2, Michigan League of Conservation Voters (LCV), National Wildlife Federation (NWF), PFAS Alliance, Oscoda Citizens for Clean Water, Sierra Club, Michigan Medicine, Ann Arbor Environmental Commission, Douglas County Land Conservation Committee and Cedar Lake Association.
The dozens of different organizations which also signed onto the NOW letter, included AuSable Township, Ducks Unlimited, Flint River Watershed Coalition, Michigan LCV, NWF, Villages of Oscoda Homeowners Association, Oscoda Township Board of Trustees, Anglers of the AuSable, Huron Pines, Michigan Environmental Council, Oscoda Convention and Visitors Bureau, Pine River Van Etten Lake Watershed Coalition, Oscoda Rotary Club, PFAS Alliance, Natural Resource Defense Council, Michigan Salmon and Steelhead Association, Michigan Citizens for Water Conservation, GreenCAPE, Environmental Working Group and Michigan United Conservation Clubs.
Of the businesses which participated – both local establishments and those outside of the community – this included Cathy’s Hallmark, AuSable Hardware, Nordic Sports, Metro Group Architects, Lake Huron Sportfishing Inc., MAWBY Vineyards and Winery, Sleeping Bear Surf and Kayak, David Kranker Creative, The Bear Factory, Desmond Liggett Wealth Advisors, Workshop Brewing Company and Dinon Law, PLLC.
Sign on letters of this sort are a critical tool for advocacy, as they illustrate the breadth and depth of people, organizations and businesses which are joined together in a unified voice for a common purpose, said Jennifer Hill, associate director of the Great Lakes Regional Center for the NWF. “They show how many groups and people, with different views and backgrounds, can unify around a message that they all support despite their differences. They are a powerful illustration of how people can come together to collectively call for action to solve problems.”
Following this correspondence, the NOW group also sent a technical letter and a series of slides to Varley, regarding their comments on the proposed IRA plan for Clark’s Marsh. The information will be summarized in a future edition of this publication.