These are clearly divisive times for American health and environmental initiatives.  Just look at how politicized public health is in the face of a pandemic and the approval process of potential drugs and vaccines. 

Waldo County has struggled with the divisiveness associated with the placement of the second largest land based salmon rearing/processing plant in the world in a shallow bay adjacent to a pristine previously protected natural habitat.  One thing that I had hoped for was an objective scientific evaluation of the permit, including verified models that provide answers to the divisive concerns raised in public hearings.

The taste of money to politicians and to corporations that lobby for construction projects is a formidable challenge to those seeking objective scientific review of a permit.  My scientific expertise is in the area of water quality and water testing with degrees in chemical engineering from MIT and some 32 years of leadership experience in state government, including DEP Division Director of Licensing and Enforcement and Director of the State Health and Environmental Testing Laboratory. 

 I support the use of good science to create the best permit possible to protect our environment. I had hoped that the largely LePage appointed Board of Environmental Protection members would not influence scientific findings in making a final decision.

In this article I only wish to focus on a portion of the draft Waste Water Discharge Permit.  This is the permit needed to approve the 7.7 million gallons/day of effluent to Penobscot Bay.  Essentially Maine has only two water quality “standards” for our newly developing aquaculture industry.

1.  One is the state’s anti-degradation policy that takes into account factors that could predict what concentration of nitrogen in the effluent would be harmful to the marine environment.  For here, I will refer to this as the nitrogen level.

2.   The other is a state regulation that provides limits on allowed temperature rise in the discharge mixing zone.

The acceptable nitrogen level was calculated based on predicted data from unverified models that considered only tides.  The model predicts the dilution factor to be used in the nitrogen calculation. 

Using the dilution factor submitted under oath by Nordic consultants, the DEP staff determined that Nordic exceeded the recommended limit for nitrogen concentration in the effluent by almost a factor of two. 

This would mean that the size of the Nordic facility is twice the size that protects the marine environment. 

The BEP then allowed Nordic to cherry pick the submitted data after the closed hearings and provided Nordic an additional variance by almost a factor of two. 

Even with this large variance, Nordic’s anticipated nitrogen discharge in the application still would not meet the recommended limit. 

The BEP next altered the application, putting the discharge exactly at the limit for environmental risk to the Bay, leaving no room for error.  The BEP further allows verification of the important modeling of effluent flow to be limited to an after-the-fact dye test.

The draft permit provides no consequences to unacceptable effluent discharges or data that contradicts early modeling.

In the case of temperature and the calculation of temperature rise, the DEP again accepted an unverified model of mixing zone dilution and allowed the base June temperature to be the surface temperature used in their calculations. 

Using these calculations, Nordic would just barely meet the temperature limit by just 0.1 degree F.  We all know that the temperature is highest at the surface in June. 

If the June bay base temperature used in the calculation was from lower depths and just 2 degrees less than the surface temperature provided, the Nordic effluent would not pass the temperature standard.

In the draft permit the BEP makes the following statement: Where a discharge will result in lowering the existing water quality of any waterbody, the Department has made the finding, following opportunity for public participation, that this action is necessary to achieve important economic or social benefits to the state.
 
Clearly the need for objectivity in a very divisive permit application is being tainted with considerable subjectivity.   

The most offensive part is that a large corporation has come to Maine and persuaded our elected politicians, and the board that is supposed to protect our environment, to put the corporation’s interests above our regulatory standards.

The media has benefited with payment for large full page ads, but are now being threatened to follow the bias of Nordic or lose that revenue. 

Linked with Nordic’s recent aggression towards the press, Nordic has also made every effort from the beginning of the permitting process to label third party scientific observations as “fake news”.  Sound familiar?

John Krueger lives in Northport