Oct. 7, 2014. Dear Editor,
Imagine how astonished we were when we discovered a June 22, 2010 revision of the 2009 Environmental Assessment (EA) for Boone’s proposed water intake. Go figure, we were investigating the Watauga County Floodplain Permit debacle and we discover Boone officials have been referring us to an obsolete document for four years. Dysfunctional comes to mind, inability to properly interact with constituents; in other words, not fit for public service!
We understand why Boone instructed the engineers to not comment, why governmental agencies are stalling record requests and threatening to scrub information clean; all indications point to a breach of public trust.
Breach of public trust- We believe these reports have been written so as to derive a predetermined outcome, to justify selection of a “sweet spot” 12 miles from Boone’s corporate limits on the South Fork of the New River in Todd, NC, at the Ashe/Watauga County Line, on a river enjoyed by many, the oldest river in North America, the second oldest in the world, adjacent to property on the National Historical Registry, and on property designated as an archeological area of interest.
Why? The answer is found in the meeting minutes from a joint meeting held on February 17, 2010 between the Town of Boone, NCDENR, the N.C. Wildlife Commission, the USDA and WK Dickson — control of Ashe & Watauga Counties’ growth and development using water, action item 7 :
“Make a point to specify in the revised EA that all areas receiving water from Boone would be required to adhere to development restrictions/guidelines at least as stringent as Boones.”
The cozy relationships between contract service providers who write reports, grease the funding rails to acquire multi-million dollar Government backed financing, small town politicos operating in the shadows, and those same private contracting firms ultimately providing the lucrative construction engineering and oversight smacks of conflict of interest and is a subject for further investigation.
Over half of the revised Environmental Assessment is negative comments from other governmental agencies and citizens. Yet, the USDA issued a Finding of No Significant Impact (FONSI). However, the citizens have not issued a FONSI. PONZI comes to mind, government financing of propaganda with taxpayers’ money to garnish more taxpayer funds to invest in expensive boondoggles.
Recently, New River Advocates analyzed only 2 pages of the original 2009 Assessment and opined on 1) the citation and recitation of a law that has never existed by Boone and its’ engineers ,2) illogical methodology and 3) the inability to solve a basic equation, an equation which WK Dickson solved to equal 6.8 million gallons per day instead of a one-day use of 6.8 million gallons (the correct solution of 6.8 million gallons nullifies WK Dickson’s entire justification for the additional 4 million gallons of water per day and the claim that the only feasible alternative is the South Fork of the New River in Todd, NC)
We have also reviewed the first 5 pages of the 2010 revised Assessment and have found, in just these few pages, serious factual, logical and computational problems. It looks like, in an effort to even dismiss the concerns of NCDENR water supply experts, the engineers bring a new meaning to delivering factual information. We believe the engineers have a problem marshaling readily available facts, facts that do not support the proposed intake project.
Basic addition, subtraction, multiplication and division have even taken on a new meaning. As Patrick Beville, member of Boone’s Water Use committee and an engineer, explains, how engineers operate under a different set of standards, rules, methods and applications; they are in a different league:
“I understand your perspective that WK Dickson did not follow the letter of the law. What you don’t understand is that there are many different legitimate methods of engineering analysis that are acceptable and meet the intent of the law (and, therefore, are accepted by regulatory agencies)…” (HCPress,”Comments” Sept 9, 2014)
We question whether this arrogant attitude, as expressed by a member of the engineering brotherhood, to defend WK Dickson, should ever be accepted to justify the work of a firm with such an esteemed professional reputation, especially considering the fees they command. Who reviewed and signed off on this garbage? Taxpayer funded governmental agencies that declare their very existence is to look out for our interest. Slipshod comes to mind, ‘shady’, sloppy, and ‘greasy’!
The engineers cite sources; but, when we check the source, the data the engineers cite does not match the source. The engineers make statements and then later contradict their statements. It is obvious to us that the engineers have derived some bizarre baffling charts and conclusions. Here is just a sampling
Example 1. 2.60 MGD is reported as the Maximum Day Demand. It is actually 2.30 MG. It is not a daily demand; it is the largest volume of water used on one-day out of the year. If you divide 2.60 MGD by 3.00 MGD, you can then claim Boone has exceeded 80% of their daily capacity. However, they really have not. The erroneous citation of the law that does not exist is very critical to the engineers. It is not important that the law exists; it is only important that we believe that it exists. The engineers claim there is an NCDENR regulation that recommends that plans addressing expansion of water supplies be under way when 80% of capacity is exceeded, that construction be under way when 90% of capacity is exceeded and threatens moratoriums on water hookups if not. If you consider the Average Daily Demand of 1.80 MGD, then you would be at only 60%. So, we believe it was necessary to add that the imaginary 80%-90% rule was based on Maximum Day Demand. Whala! They have magically proven that Boone must plan for a new intake immediately. But, there is a real law that is based on Average Daily Demand and it is quite different than the imaginary law. However, if the engineers use that actual law, they could not deliver the goods that Boone wants.
Example 2. The engineers claim that the “3 intake pumps will not be sized to exceed a total of 4 MGD” in the revised EA. Some other expert had read the 2009 EA, did the math and noticed they were constructing of a facility capable of withdrawing 6 MGD. However, the engineers summarily dismissed their concerns with the above statement. Yet, later in the same document, they stated the “the pumps were rated at 2 MGD”. Since the ‘rated value’ is the size, taking 3 intake pumps and multiplying by 2 MGD results in 6 MGD. But, it does not matter that 2 time 3 equals 6; it only matters that we believe the engineers’ stated claim that the “3 intake pumps will not be sized to exceed a total of 4 MGD”.
Example 3. We have all heard the mantra that 90%, 93%, 95% and even as much as 99% of the water withdrawn will be returned to the river. Another expert said ‘show me’. This is where the engineers really got clever. They reported “consumptive gains” as “consumptive losses”; they introduce into evidence a meaningless chart to support an imaginary percentage that they have no way of substantiating. Again, it does not matter whether the chart is correct or whether they actually substantiate their claims; it is only important that they baffle the reader with BS.
Example 4: The engineers report that the “unaccounted-for-water” in 2007 is 18%. The unaccounted-for-water is the water that was withdrawn and lost; probably due to leaks. In 2007 the unaccounted-for-water was an average of 708,000 gallons per day and the average amount of water withdrawn was 1,800,000 gallons per day. If you take 708,000 and divide it by 1,800,000 and then multiply by 100 you get 38.06%. Again, it is doesn’t matter whether the information is factual; it is only important that you believe it is. The unaccounted-for-water is a temporary situation. Because it is a temporary situation, the engineers should have made adjustments to the Maximum Day Demand and the Average Daily Demand for 2007 and noted the abnormality. However, that would have swung the results to the 50% of capacity range which is actually in line with current (2013) and historical trends. And, that does not support the boondoggle.
There is a term for this type of information, PROPAGANDA! We believe no one was supposed to read the document much less fact check the contents.
What is the best case scenario? WK Dickson made many errors and we the taxpayers unfortunately paid for it. WK Dickson has failed to support the need for an additional 4 MGD. And, thus there would be other feasible alternatives to meet Boone’s real water needs and the New River would be protected from an unnecessary intake.
What is the worst case scenario? We the citizens have paid for the “Kool-Aid” we refuse to drink. No one was supposed to question the contents of the “Kool-Aid”; we were simply supposed to get insatiably drunk.
The environmental scoping process was simply a method by which to identify, neutralize and/or snuff out any opposition. Round one of the environmental scoping process identified a large number of opponents, the governmental agencies and citizens registering concerns. We measure the success of round one by the number of agencies and citizens that responded thinking someone actually cared. This resulted in the 2009 EA which was cleverly formulated to appear to address their concerns. It did not matter whether the information was factual or based on sound methodology.
Round one was followed by round two, the publication of an open comment period on the 2009 EA. Again, round two was successful, another large number of governmental agencies and citizens registered concerns. This group was unknowingly vetting the 2009 EA (helping the change agent ‘tweak the Kool-Aid recipe’). This resulted in the 2010 EA. Again, it did not matter whether the information provided in the final publication was factual, based on sound methods or actually addressed anyone’s concerns; the ‘Kool-Aid’ was ready for production. By all appearances it addressed the so-called experts concerns. All of the governmental agencies had been given an opportunity to comment and by all appearances someone truly cared. All of the participating governmental agencies had become partners in formulating the ‘Kool-Aid’ recipe; they now had ownership of the final product. And, they each issued a FONSI, the ‘Kool-Aid’ was ok by them.
So, who got snuffed out? Those of the general public who registered concerns; they were summarily eliminated by comments that were buried in the 2010 final report that no one ever saw until now. The change agent didn’t need a FONSI from them; he only needed the experts, the other governmental agencies, to agree with the final product making any concerns of the non-experts, the general public, irrelevant. The public comment period was closed and the general public was supposed to give up, grab the ‘holy grail’ and drink up.
Yes, Mayor Ball, it is has become “a very serious situation”. The general public has not participated in drinking the ‘Kool-Aid’. It’s tainted! We think you need to throw it out. Try a little syrup of truth, a pinch of transparency, and a smidgen of respect for the general public for starters. Keep adding these ingredients; we’ll let you know when it tastes better.
A link to the first 80 pages of the 2010 revised EA and Part I of our “Analysis & Opinion” are in full at: http://www.newriveradvocates.com/ea.html.
Protect the New River from the Power Grab!
New River Advocates, Inc. Board of Directors,