On 9/16/09 12:39 PM, "Arlo Stockham" wrote:

Hi Metric and Board Members,

I would like to point out a procedural issue that may be worth discussing at our meeting tomorrow evening.

In the recently distributed e-newsletter, 2 "contentious" projects are prominently presented - the proposed Jungo Flat dump and Ruby natural gas pipeline.  A request for comment link is provided after negative summary statements for both projects.  In my business, we call this a "push-poll" (a form of advocacy).

While it is difficult for many of us to support projects that primarily benefit outside areas and primarily impact local areas, I question if Friends should effectively take a position of opposition without a prior discussion/vote by the board.  A comment link could have been provided without the leading intro.  Better yet, a link to more detailed information could have been provided.  If a board-level discussion has occurred, please disregard this.

I am not as familiar with the dump, but understand the local planning commission has voted in favor of it.  There must be some local benefit (ie jobs, tax revenue) that they saw prior to approval.

On the natural gas pipeline, a very detailed routing study with numerous alternatives was included in the EIS for the project.  This has been underway for years.  After looking at alternatives in great detail, I am not convinced that the proposed route is a bad one.  The comment period for the EIS may still be open - I reviewed the final EIS a couple of months ago and reviewed the draft in 2007 I believe.

If the position is one of outright opposition to utility projects crossing through Nevada, I do not support that.  Nevadan's use natural gas, just as residents of Oregon and Wyoming do.  The gas that heats many of our houses originates outside Nevada and passes through other states on route to Nevada.  If other states had blocked the Tuscarora gas pipeline as we seem to be suggesting for the Ruby Pipeline, many of us would likely be using electric heat (mostly from out-of-state coal) or heating oil (also from out of state). Both are much worse for the overall environment.

Similarly, if our country is serious about converting to renewable sources of energy, interstate transmission routes between major production areas (great plains for wind, southwest deserts for solar) and major population centers will be absolutely necessary.  Nevada will likely benefit from the conversion to renewable energy, but the transmission routes will negatively impact other areas.  I think interstate utility systems should be considered in a less parochial manner.  Additionally, there are benefits for the local area, primarily involving construction and operation jobs for the project and a new source of gas to support future economic development.

If we apply the same logic to Burning Man, similar opposition would likely result.  Is it right to impact and temporarily close a pristine desert to support the recreational interests of people who primarily live out of state?  Doesn't the event generate a huge amount of greenhouse gases from so many people driving old motor homes 6+ hours each way (in construction-related gridlock this year).  Shouldn't the SF Bay Area find a local place to host a ±50,000 person week-long event/party?  Maybe they would put it next to their new dump site.....

Don't get me wrong - I think burning man is a great event for the area and I'm not a fan of the dump.  I do, however, think Friends as a group should view activities from a broader perspective that considers the full range of benefits and impacts.  After all, BLM land management and much of the Friends budget comes from federal sources, not from the Black Rock region.  The whole country has a right to use and benefit from federal lands.  We're just lucky to be closer to many wonderful federal areas.

I'll get off my "high-horse" now - thanks for considering these thoughts.

Arlo Stockham

The original post did not intend to be interpreted as a clear policy decision of the Friends of Black Rock High Rock in favor of or opposed to any particular planned project. It was intended to spur discussion of the issue. I attempted to include the potential positive impacts of each project for balance. Also, I included several links for further research by the reader. In several months, no other comment has been put forward.

Jungo Flat is basically a "dry" lake much like the Black Rock. I indicate "dry" in quotes because both lakes are regularly filled with water. This should be a consideration when considering potential placement of toxic materials in the area.

http://www.rgj.com/article/20091222/OPED04/912220313/1098/OPED/Harry-Rei...

We come from different political parties and different parts of the state, but we have long shared the view that Nevada should not be a dumping ground for other people's waste. This is why we are deeply concerned about the proposed Jungo dump, which would import a mountain of trash and toxic materials from San Francisco and dump it 380 miles away, near Winnemucca.

Under the proposal, California would send a trainload of sewage sludge, asbestos and other trash into Nevada five days a week for the next 95 years. That equates to one million tons of waste annually. The resulting 20-story-high pile of California's trash would be with Nevada forever.

The proponents of the Jungo dump claim that it will be the safest of facilities, but the Nevada Division of Environmental Protection has determined that leachate from the site will pollute local groundwater. In addition, the proposed dump would have to get exemptions from two Nevada laws that we think make a great deal of sense.

First, without a special variance, state law does not allow a dump to be permitted if it will be less than 100 feet from the area's uppermost aquifer. The Jungo dump would be an average of 45 feet above the aquifer in Desert Valley, and as close as 29 feet. Second, existing state law exhorts against locating landfills in Seismic Impact Zones. The Jungo dump's location in a known Seismic Impact Zone threatens the long-term viability of any liners or other protective measures the company may put in place.

There are equally important economic concerns. We firmly support trading with our neighboring states to promote mutually beneficial economic growth and to create jobs, but this trash proposal is a one-way street. With Jungo, the recipient of the waste gets a minimal one-time payment and then assumes a permanent responsibility for the waste over the next many generations. Over time that waste leaches into local and regional water supplies and can pose substantial environmental and health risks.

There is also the considerable stigma that comes along with trash. In the future, when companies look at Northern Nevada, they will be far less inclined to put their dollars and jobs and families in an area that is known as a dumping ground for other people's waste.

California is a big state. They should have no problem finding a suitable location for their waste within their own borders. We recommend that the proponents of the Jungo dump restart their search closer to home and keep their California garbage in California. We also hope that Gov. Gibbons and the Nevada Division of Environmental Protection see the substantial risk involved in this proposal and reject the dump's permit. They would be within their authority to do so.

Additionally, we look forward to seeing the details of the governor's plan for a possible trash recycling mandate. It would be deeply unfortunate if that proposal led to dramatic increases in trash fees for Nevadans while also further opening the door for other states to leave their trash in our hands and on our lands.

Harry Reid is a U.S. senator representing Nevada. Dean Rhoads is a Nevada state senator representing Rural Senatorial District.

As to the substance of Arlo's remarks. Burning Man provides financial benefit to Nevada similar to the benefits of the proposed dump, but without long term ecological impacts. 40,000 people for one week is different than 20,000 tons PER WEEK of toxic garbage, which never goes back from whence it came. Desert Research Institute has yet to find any quantifiable ecological impacts to the Black Rock Desert-- not even the microscopic organisms.

Also, Nevada has long held itself up as the place to get away social activities not tolerated elsewhere. Burning Man fits that character. Do we want "NEVADA: we take your garbage" to be the character of our state?

Lastly, there are already state laws which prohibit the proposed dump because of its proximity to groundwater. The legislation for the NCA specifically includes large scale events as allowed, in a managed setting. So again, a false equivalency.