Dr. John Van Brahana Highlights Potential for Substantial Impacts Due to Region's Karst Geology in Letter to ADEQ Director Teresa Marks
Mount Judea, AR – On June 3, Dr. John Van Brahana – a renowned hydrogeologist and an expert in Arkansas’ karst geology – sent a letter to Arkansas Department of Environmental Quality (ADEQ) Director Teresa Marks urging her to suspend C & H Hog Farms’ permit until significant omissions and problems with the permit application could be addressed. Dr. Brahana’s expert opinion, as outlined in his letter, aligns with concerns raised by the National Parks Conservation Association, Buffalo River Watershed Alliance, Arkansas Canoe Club and the Ozark Society over the lack of study of groundwater on and near the site; the lack of discussion of the karst hydrogeology present in the region; and the lack of public notice provided, along with various other issues.
Dr. Brahana has worked in Arkansas as a Research Hyrologist with the U.S. Geological Survey, as a Professor of Geology in the Department of Geosciences at the University of Arkansas, and as a Registered Professional Geologist. He has directed student research and theses on the subject; conductedfunded-projects; and has published numerous reports describing groundwater flow, transport of contaminants, and factors affecting them. Brahana has previously worked with ADEQ staff to ensure water-quality issues were addressed in the karst terrane of northern Arkansas, and has volunteered to share research, field-work and his time to allow for sound decision-making within the agency.
“It’s unfathomable to think that Dr. Brahana was not originally consulted during the permitting process for this factory hog farm,” said Robert Cross, president of the Ozark Society. “He is one of the most respected hydrogeologists in the State of Arkansas and has previously provided guidance to ADEQ. You’d think that an agency concerned with ensuring adequate protections for the Buffalo National River would have thought to ask for his research and opinion.”
An excerpt from Brahana’s letter to Director Marks touches on the failures around the National Pollutant Discharge Elimination System Notice of Intent (NOI):
“Although many of the regulations of the NOI appear to have been met (exceptions include the letter from Hank Bates of Carney Bates & Pulliam PLLC), the heart of the regulations—the questions of nutrient loading and waste leakage—are weak and incomplete and do not give confidence that the NOI plans are adequate for preserving environmental quality. My personal perception is that this document does not satisfy the requirements. Coupled with what was perceived as an air of secrecy and a less-than-obvious need for rapid or immediate action, the response of ADEQ in dealing with this project has reinforced the overall feeling that the proposed C & H Hog Farms is a highly risky water-quality endeavor in a fragile, lovely location. Subsequent actions have done little to alleviate those fears. Without addressing these omissions, I, too, have serious reservations.”
Brahana notes that the Big Creek area – where C & H Hog Farms was permitted – includes karst geologic conditions with a fragile ecosystem. In karst areas, groundwater flow enlarges the dimensions of the conduits through which groundwater flows. The groundwater moves as quickly as water in a stream, but the path of that flow is difficult to predict and would be capable of transporting sediment, organic matter, fecal waste, and dissolved solids from the factory farm. Within this geology, if a waste-lagoon were to breach, there would be little opportunity for it to be naturally remedied or lessened.
The letter goes on to read: “I know of no active karst consultant who recommends that a CAFO be sited on karstified limestone, particularly upgradient from so sensitive a natural resource as the Buffalo National River, with its direct-contact use by canoeists, fisherman, and swimmers.”
To address these issues and the missing data within the NOI, Brahana plans to propose a research program to assess the water quality of the region, conduct dye-tracing studies to document the point-to-point connections; and map all known karst features from upstream of the farm, down the valley of Big Creek, and below the confluence with Buffalo National River. The information would help to fill gaps from the original NOI and allow for a more complete understanding of the impacts of the factory farm.
Brahana has also called for the development of a new means by which all stakeholders are included in plans for major projects that require environmental impact statements, NOI, or other permissions required by law. A more transparent and open process would have allowed those who have an interest in, a stake in or knowledge about the environmental impacts of this factory hog farm project to have weighed in.
In May, Hank Bates – a Little Rock environmental attorney – sent a letter to ADEQ Director Teresa Marks challenging the factory farm’s permit based upon the Nutrient Management Plan and its many holes and inaccuracies. Earlier in the month, the National Parks Conservation Association, Buffalo River Watershed Alliance, Arkansas Canoe Club and The Ozark Society filed a notice of intent to sue the U.S. Department of Agriculture over its multi-million dollar loan guarantee to the factory farm, as their actions may have violated the Endangered Species Act.
To view Dr. Brahana’s letter, please click here: http://buffaloriveralliance.org/Default.aspx?pageId=1545631&mode=PostView&bmi=1309071
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