Sec. Tom Vilsack, Sec. Ken Salazar,Corbin Newman: Stop the use of sewage effluent for snowmaking on the San Francisco Peaks
The San Francisco Peaks are a special area near Flagstaff, AZ. The peaks are located on land that the National Forest Service manages. The unique habitat includes special plants such as the federally threatened San Francisco Peaks Groundsel which is protected by Section 7 of the Endangered Species Act. These mountain peaks are also held sacred by 13 Indigenous Nations in the surrounding region. A privately owned ski resort located there wants to use 100% treated sewage effluent to make artificial snow for the resort (Use of 100% treated sewage efflluent has never been attempted before.).
The use of the sewage effluent on the Peaks will cause environmental damage for plants and animals and may even effect human health. Treated sewage effluent (reclaimed wastewater) has been scientifically proven to contain: endocrine disruptors, pharmaceuticals, personal care product chemicals, viable but non-culturable bacteria and using viral metagenomics researchers found that some 60% of the DNA viral sequences in treated sewage effluent was from unknown viruses. What this means is that we do not fully understand the impacts or know what else is in treated sewage effluent. This leaves the treated sewage effluent option as environmentally unsound in addition to having potential negative impacts on the health of skiers, snowboarders and residents of the surrounding area.
We are starting this petitions to protect the San Francisco Groundsel and the natural environment of the San Francisco Peaks from preventable corporate-made ecological disaster.
Dear Secretary Vilsack, Secretary Salazar and Corbin Newman:
We support the environmental study conducted by SWCA Environmental Consultants and Sonoma Technology, Inc. which was authorized by the Hopi Tribe and submitted on August 24, 2012 to the U.S. Forest Service and U.S. Fish and Wildlife Service. This extensive study provides the only snow transport modeling and analysis report on record which establishes its data as the “best available science”. This study makes evident that a substantial amount of nitrogen-enriched treated sewage effluent overspray and drift was not accounted for in the proposed snowmaking plan at Arizona Snowbowl. The omission of snow dispersion by wind is a gross oversight that imminently threatens the critical habitat and long term existence of the federally threatened San Francisco Peaks Groundsel. The actions by the Federal Government in failing to perform adequate due diligence and protect this federally threatened species is a violation of Federal Law.
· The San Francisco Peaks Groundsel is protected by Section 7 of the Endangered Species Act. All government agencies have an obligation under Section 7 of the Endangered Species Act to conserve endangered and threatened species and not approve actions that would harm the continued existence of a listed species including adversely affecting its critical habitat. Based on this new finding, which is the best available science, we insist that President Barack Obama, the Department of Agriculture and the Department of Interior disallow the use of treated sewage effluent (reclaimed wastewater) for snowmaking on the San Francisco Peaks.
· The new forest planning rule clearly states the responsible official shall determine whether or not the plan components provide the ecological conditions necessary to contribute to the recover of federally listed threatened and endangered species and to maintain a viable population of each species of conservation concern within the plan area (section 219.9 Diversity of plant and animal communities). Allowing snowmaking with nitrogen-enriched treated sewage does not contribute to maintaining a viable population or promote recovery of the San Francisco Groundsel.
· We insist that all Indigenous Peoples and Nations be informed and consulted on the findings from this new study in accordance with both domestic and international law such as stated in Article 19 of the United Nations Declaration on the Rights of Indigenous Peoples.
The forest planning rule was established to ensure the protection of species diversity, forest restoration and conservation rather than promoting the degradation of the ecosystem. Again, we strongly urge your Agency to comply with the Endangered Species Act by stopping the use of treated sewage effluent for snowmaking on the San Francisco Peaks. The higher public purpose and interest is better served by not allowing irreversible damage to the critical habitat of the federally protected San Francisco Peaks Groundsel (Packera franciscana).