By Dr. Robert Thorson
Earlier this month, several journalists asked my opinion about dumping dredge spoils in Long Island Sound. Having offered off-the-record comments without doing any research, I decided to become better informed. What I learned is that the science on this issue is so buried by an excess of government “word sediment” that I made no progress on the main issue. Nature advocates deserve better. All unnecessary verbiage in government reports must be dredged up and dumped somewhere else.
Consider this: Last week, The Courant carried a story, “EPA Revises Dredging Plan: Seeks Alternative Uses for Materials.” That’s clear. The EPA version reads: “The amendments to the rule are intended to help reduce or eliminate open-water disposal of dredged material by requiring dredging project proponents to follow standards and procedures that will encourage the use of practicable alternatives to open-water disposal.” That’s word sediment.
And what’s so bad about open water disposal? Please tell me more about that, and less about agency this and that.
Now brace yourself. The 2005 EPA rule being discussed requires that the agency amend its own rule after receiving a DMMS for LIS from the NED of the NAD of the USACE after a FPEIS. In order, these acronyms are: Environmental Protection Agency, Dredged Material Management Plan, Long Island Sound, New England District, North Atlantic Division, U.S. Army Corps of Engineers, and Final Programmatic Environmental Impact Statement.
The last document is most critical, being the foundation for all others. Alas, it’s impenetrable, at least for me, someone who’s fairly well informed on the physical science of sediment within Long Island Sound. The obstacle for me is not comprehension, but the fortitude to behave like a burrowing mole so that I can dig through the dense dirt of this genre of writing.
The good news is that the acronyms used in the LIS DMMS FPEIS are clearly defined. The bad news is that I counted 162 of them not commonly used in environmental science; for example a PDT, a “project delivery team.”
These six pages of acronyms constitute a veritable glossary for agency-speak, one of the few non- English languages growing in popularity. Preceding this is a 14-page table of contents for nine sections of up to 330 pages each for a total of 595 pages, not counting the 26-page executive summary.
The LIS DMMS FPEIS isn’t authored. Rather it’s prepared, though the difference is undefined. There were 12 preparers from the principal contractor Battelle Memorial Institute, seven from the principal subcontractor AECOM (a publicly traded corporation with $5.66 billion dollars in assets) and six other contractors. Each was responsible for certain sections. Nowhere did I find that anyone was stipulated to read the whole thing. I was especially intrigued by the responsibilities of the quality control officer. Was the issue of readability taken into account? I think not.
Consider the first three “general impacts within Table ES-2 of the executive summary.” My favorite is: “Dredged material placed in open water may alter the topography of the site.”
How can this not be, given that solids must take up space? Alternatively, it states that dumping may change the surface materials. Again, how can this not be? It strikes me that someone is getting paid to write sentences that block understanding.
I don’t blame the contractors. They are only giving the government agencies what they think they need. That’s the crux of the problem.
The needs of the government should not take precedent over the needs of the public to inform itself. When I contemplate the millions of dollars spent writing, reading, reviewing this word-sediment, I wonder if the benefit to Long Island Sound justifies the expense.