Blumenthal, Plum Island Danger

Blumenthal: Impact Statement Regarding Plum Island Seriously Flawed

September 1, 2008

The draft environmental impact statement is profoundly flawed — factually deficient, and legally insufficient — mis-assessing the monstrous risks of siting a proposed national bio- and agro-defense facility on Plum Island.

This facility would study and experiment with the most dangerous disease organisms, including pathogens transmitted from animals to humans, that have no known cures or vaccines. Some of these diseases do not otherwise exist in this country.

Although Plum Island has long hosted research into animal disease, the new facility would take the public health threat to a new level. The environmental security risks are intolerable in an area so densely populated, heavily traveled and environmentally valued. The threat of accident or attack is hardly hypothetical or speculative, as recent experience has taught. These dangers are real and substantial, and have not been adequately considered. While the nation will no doubt benefit from the scientific research, there are far safer and sounder locations than Plum Island. The danger here is unacceptable — to health and safety as well as the environment.

Among its many key failings, the impact statement fails to fully consider the following:

•The proximity of Plum Island to New York City, one of the nation's most populous cities and a repeated target of terrorist attacks.

•The fact that 20 million people live within 50 miles of Long Island Sound.

•The proximity of Plum Island to a nuclear submarine base, a nuclear submarine construction facility, the U.S. Coast Guard Academy, and a major nuclear power plant.

•The special security risks of protecting and providing emergency response services to an island.

•The risks of disease transmission to and through birds and wild mammals, particularly seals, a growing presence in Long Island Sound.

•The risks to an island laboratory from a Category 5 hurricane.

The Department of Homeland Security has a legal and ethical obligation to consider all reasonably possible alternative sites. The department inexcusably has neglected to study — or even acknowledge — the uniquely complex character of the area around Plum Island. Basic environmental data is absent from the impact statement and necessary impact analysis is therefore inadequate.

The department defies common sense and science by considering a facility for deadly and untreatable diseases within 12 miles of southeastern Connecticut and 100 miles from the heart of Manhattan. An accidental or intentional release from Plum Island poses a far greater risk to public safety than would a release at a more remote location. Simply by virtue of its charge to "research high-consequence biological threats involving zoonotic (i.e., transmissible from animals to humans) and foreign animal diseases," the facility is very dangerous. "High-consequence" foreign animal diseases are defined as those "diseases not present in the United States that are capable of rapidly spreading and causing high numbers of deaths and/or devastating economic consequences."

There is no dispute that the area immediately surrounding the proposed Plum Island location is densely populated. The impact statement itself notes that the estimated population for the "study area" alone for 2012 is 2,013,919. Approximately 20 million people live within 50 miles of Long Island Sound. In addition, the Navy maintains a vital nuclear submarine base at Groton, and the nearby General Dynamics Electric Boat facility is recognized as a potential target for terrorist attack. Nearby Waterford is home to the Millstone nuclear power station, which generates 2,020 megawatts of electricity.

The impact report recognizes, but then inexplicably ignores, that it is possible "for the viral pathogens to be transported significant distances by the wind. …" The report never addresses the impact to the area and the nation should there be a release from an accident or intentional act.

First responders to any accident or attack on the proposed facility will be drawn from the local communities. There is no state or federal fire department or paramedic unit. Fire and other emergency response units, other than law enforcement units such as the state police, are provided by towns and municipalities. The communities along the New York and Connecticut coasts are staffed and equipped to address only their own local needs.

Marine accidents are of a particular concern to Long Island Sound because it is heavily used by commercial shipping fishing interests and recreational boaters and because it is narrow. Vital fuel tankers and bulk carriers pass through the Sound constantly, as do nuclear submarines. Ships in the Sound come from all over the world, threatening to spread any released disease worldwide. This point is ignored in the impact statement.

Significantly, the potential siting of the proposed facility on Plum Island would impact a uniquely valuable and sensitive environment. The importance of Long Island Sound — environmentally, aesthetically, and economically — cannot be overstated. The Sound is one of the largest estuaries in the U.S., where the tidal, sheltered waters support unique communities of plants and animals. Numerous marine organisms, including many of the commercially valuable fish and shellfish species, as well as birds, mammals, and other wildlife, depend on the Long Island Sound estuarine habitats at some point in their development to live, feed, and reproduce.

One of the more obvious deficiencies of the impact statement is its failure to study the risks of disease transmission to marine animals and organisms in the immediate vicinity of the island. There is no scientific analysis of the risk of transmission through the sea or via marine animals, and especially marine mammals.

The proposed facility at Plum Island is a dangerous and unprecedented project. While the need for biomedical research on dangerous diseases may be clear, federal law mandates that the Department of Homeland Security carefully consider where such a facility should be located. The Long Island Sound area is clearly unsuited to a facility of this type. Absent complete and candid evaluation of the significant factors identified herein, the Department of Homeland Security cannot claim to have adequately studied the impact of the proposed facility as required by the National Environmental Policy Act. No adequate evaluation of the environmental impact of this project on the Long Island Sound area has occurred.

DHS must either completely redo this draft impact statement — going back to square one — or, very preferably, eliminate Plum Island from consideration as a site.

Richard Blumenthal
The writer is the state attorney general

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FAV

East Hartford, CT

Geez Blumenthal, no respact for our national security? We must have all the latest WMDs in case those terrorists in the W. Fijis beats us to it. That's why we need a dozen or so labs and some 14,000 employees. Fitting for EMPIRE which has scuttled the world's attempts to control this menace. The reason, we won't have inspectors snooping around our WMD facilities. That's only for the colonies.

African Bird Borreliosis

Courant.com (Comments are attached)

Blumenthal: Impact Statement Regarding Plum Island Seriously Flawed