From: Barbara L. Rubin 
To: biosolids@deq.virginia.gov 
Sent: Monday, October 29, 2007 11:51 AM
Subject: Sludge Panel's Biased Work


Barbara L. Rubin

1496 Teague Drive

McLean, VA 22101

October 29, 2007

Biosolids Expert Panel Members:

I want the Panel and Assembly to be aware that there are sludge victims and citizens who feel
completely left out of the carefully orchestrated work of a group of members 
(who mainly have sludge industry affiliated jobs) plus two so called "citizen representatives.
(See letter below.) 

Henry Staudinger, who is labeled "citizen representative," does not represent the concerns
of all victims or citizens involved in this issue. Therefore, his agreements and conclusions
may not be acceptable to the greater public. 

The second so called "citizen representative" Alan Rubin recently retired from the EPA.
His entire professional career is dependent on the sludge program prevailing.
Now he is a well paid consultant to the sewage sludge industry.
Hardly what victims and those opposed to sludge would call a "citizen representative."

Please note the early activity of certain members in the initial meeting and letters generated
by the above referenced panel members, make it clear the agenda is being hijacked by 
pro-sludge propagandists. The "private" meeting between the above two members was probably
a rules violation. The panel appears to be ignoring the most important facts while being
"steered" to focus on manipulated materials controlled by those intent to force this heinous
program on unwilling citizens. Panel members themselves admit they have no allotted funds
and "limited resources and time" to produce credible results. 

The work product of this panel will be questioned by most citizens.
As examples, I for one strongly dispute the premise in H. Staudingerís posted letter:
"From the perspective of the public, it is hoped that the panelís report will lead to
better protection for health, the environment and quality of life when biosolids are 
land applied."(emphasis added) 

This statement assumes that the program should continue because there is a way to spread 
sewage sludge so that the stench and airborne toxic particles will be safe for the health
of neighbors. This is false propaganda that the EPA/sludge industry wants us to believe.
I have researched sewage sludge and the exposure of neighbors for 5 years and have found
no evidence of safe usage when regulations are followed.
We know regulations are rarely followed, however, even the EPA Inspector General admits
that if all regulations are followed there is NO ASSURANCE sewage sludge is safe for public health.
One only has to visit Helane Shieldís website, http://www.sludgevictims.net to find 
that neighbors all over the US exposed to sewage sludge suffer from similar illnesses.
There are also deaths linked to sludge exposure.
Therefore, the only strategy that will provide citizens assurance that they are safe from
the horrific health and environmental consequences of sludge exposure is to call a moratorium
on the sludge program.

Similarly the following statement in A. Rubinís posted letter erroneously assumes citizens
should be responsible for providing scientific data. 

"The publicís inability to scientifically document the exposureís relationship to biosolids
that are in close proximity to their residence due to lack of information as to the 
constituents in biosolids has been particularly troubling." (Emphasis added.) 

This is an outrageous assumption and should be condemned immediately.
As to documentation, there is no documentation because the EPA/industry/local governments chose
not to document, and they chose to ignore doctors' letters and scientific studies linking illness
and deaths to sludge exposure. Victims and citizens are not responsible for scientific evidence.
EPA/local governments/industry are responsible for scientific evidence proving sludge safe
for public health. 

I would also like to take this opportunity to express my full support for the 10/23/07 letter
from Mary Carwile. She rightly points out the infuriating lack of attention to health survey
and exposure studies by independent scientists. This inattention is in spite of citizens
repeated requests for these studies. Perhaps the sludge supporters know the results would
support the citizens contention that sludge exposure is linked to numerous health problems
and even deaths.

Mary also correctly points out that the panel seems to be ignoring the only peer-reviewed study
(which has never been refuted) ever done on health effects of sludge. She goes on to say:
"the constituents in land applied sludge have long since been proven to be so complex
and so unpredictable that a reliable health risk assessment of land applied sludge based
solely on trying to identify contaminants in sludge, without considering interactions of
chemicals and the effect of breakdown products will never be possible."

Why is the Panel ignoring these crucial facts? A. Rubin suggests in his letter working on
"adequate" buffers would be an acceptable substitute. There is not a shred of scientific evidence
dealing with the matter of safe buffers. The original "guess" on buffers has been a disaster.
Why should citizens have any more faith in a second guess by unresponsive promoters of this
dangerous program?

So far, this panel has verified citizens worst fears and will never have credibility
with the public until our real concerns are addressed, our unfiltered views are included,
and we are represented in adequate numbers. Why arenít the sludge propagandists
forced to present credible scientific evidence by independent scientists that
sludge exposure is safe for public health, instead of false propaganda?

Barbara L. Rubin

Loudoun Neighbors Against Toxic Sludge 

www.LoudounNATS.org


Barbara L. Rubin 1496 Teague Drive McLean, VA 22101 September 14, 2007 L. Preston Bryant, Jr. Office of the Secretary of Natural Resources Patrick Henry Building 1111 East Broad Street Richmond, VA 23219 Dear Secretary Bryant: I consider myself a sludge victim. I had my initial exposure in August 2001 which resulted in an immediate virulent Mycoplasma pneumonia and lung infection. It took a 5 day hospital stay, 4 months, and 8 courses of antibiotics, to force the infections into remission. I have never gotten rid of these infections and since that initial exposure my overall health has steadily deteriorated resulting in numerous chronic illnesses. Unfortunately, my health does not allow me to appear at the meeting on September 18, 2007. I will be undergoing medical treatment at this time. I would however like to register my objection to the list of panelists for the "Expert Panel Studying Biosolids." Often an agency or industry is forced to name a "Panel of Experts" to appease an unhappy public. While authorities reluctantly "agree" to the concept of "study," they carefully control it by stacking the panel with members who will eventually reach predetermined conclusions which they hope will quiet the public. The sludge industry has engaged in this maneuvering numerous times before (Stakeholders Research, Sludge Summit.) None of these carefully planned events have succeeded before. This new study panel has all the ear markings of the past fiascos In general the current panel list is stacked heavily with state government representatives whose jobs depend on their defense of the sludge program and/or representatives from institutions that depend on the sludge industry for their functioning. In other words far to many panelists have financial ties to the sludge industry. Why arenít there more people who have had their lives shattered by this program on the panel? They are certainly expert on sludge and its effects. Why do I only see one member (out of about 27) who does not directly or indirectly have their job connected to sludge money, represented on this panel? Because of the grossly unbalanced nature of the "members," one must conclude this is by no means an unbiased panel objectively looking at the sewage sludge issue. Instead, it is a carefully planned and controlled response which will whitewash the issue and claim there is no foundation to the scores of valid complaints that have plagued the ill founded sludge program in Virginia In further attempt to control all data, I am told the many "citizen representatives" who were carefully excluded from the "panel" may not even be able to speak at these meetings. If they are allowed to speak they will need to severely limit their input. This unfair control assures that the citizens real concerns and issues will never be considered at these staged meetings. The first of a number of examples of people who raise grave concerns on this panel is Dr. Alan B. Rubin (no relation to me.) Dr. Rubin has recently retired from the EPA where he was one of the original developers and promoters of the sludge program. He was instrumental in "pushing through" the 1992 Sludge Rule which had failed the peer-review process of the EPAís own research department. Dr. Rubinís entire professional career has been dependant on implementation and continuation of the 503 Sludge Rule. He is currently employed as a consultant, reaping huge financial rewards from the sludge industry. To include Dr. Rubin as "Citizen Representative" of the people of Virginia is outrageous. His position of biased, unquestioning support of sludge is already represented by almost all of the other members. Virginia Tech has had a long close working relation with the VDH/DEQ in forcing the unwanted Sludge program on counties all over Virginia. In particular Dr. Greg Evanylo has traveled all over the state participating in the state/industry sponsored "staged "meetings" in which they blanket new areas, which are fighting inclusion in the sludge program, with untrue propaganda. Even though much of the propaganda has been proven factually false, it is still repeated by these faithful promoters of sludge. Chris Peot from the Blue Plains, Sewage Sludge Treatment Plant is another member of the group that can hardly be seen as unbiased. He is a manager of a sewage sludge plant that supplies much of Virginiaís sewage sludge. Not only would his position eliminate him from an "unbiased panel" but he too travels around the country in staged "meetings" preaching that sewage sludge is the best thing since sliced bread. Add to this the fact that Mr. Peot has testified for the sludge industry at a wrongful death case, we begin to see how this so called "unbiased panel" is predestined to endorse a very dangerous and harmful program because it is stacked with "pro-sludge" individuals. I would hope this panel is not in its final form. It needs to be substantially adjusted to be more balanced and therefore more credible to the citizens of Virginia. If it is not, the intended appeasement of citizen concerns will never be attained. Sincerely, Barbara L. Rubin Loudoun Neighbors Against Toxic Sludge www.LoudounNATS.org