COLORADO WATER PLAN

To Governor Hickenlooper and the Colorado Water Conservation Board,

My name is Crystal Edmunds, and I am currently a graduate student at the University of Denver, studying Global Finance, Trade and Economic Integration with a focus in environmental security. In my second year of school, I interned for Water for People in Denver, CO, mostly writing due diligence reports. The organization currently works in nine countries around the world: Honduras, Guatemala, Nicaragua, Bolivia, Peru, Malawi, Rwanda, Uganda, and India-- bringing together local entrepreneurs, civil society, governments and communities to establish creative, collaborative solutions that allow people to build and maintain their own reliable and safe water systems.

For the past two years, I have worked as an AmeriCorps volunteer through the Western Hardrock Watershed Team with the Coal Creek Watershed Coalition in Crested Butte, CO, primarily involved in capacity building. This summer, I started interning with the Upper Gunnison River Water Conservancy District in Gunnison, CO, focusing on community development. Perhaps it was growing up on the banks of the Maumee River in Ohio, but my life seems to be perpetually linked to water! The more I learn, the more I recognize the profound significance of this natural resource and how much more energy needs to be directed toward its protection.

In the following pages are my major concerns regarding Colorado's Water Plan: Water quality standards for arsenic, fluoride and nutrients Fracking, outdated mining laws, abandoned mines, rare earth element mining Pesticides in agriculture and noxious weed control Chemical Regulation Environmental Education Environmental Health

Thank you for your work! Sincerely,Crystal Edmunds

Water Quality Standards_____________________________________________________________

1 | P a g e

Arsenic

Perhaps my favorite part of working with the Coal Creek Watershed Coalition was researching, following

the process of and attending the April 2013 arsenic rulemaking at the Colorado Department of Public

Health and Environment. Crested Butte is impaired for arsenic, partly from historic mining and partly

because its geology. A major part of the work of the CCWC was to discern the contamination to the

watershed of arsenic from mining.

I had first learned of arsenic through interning at Water For People in Denver: Three decades ago,

health and development experts and local contractors dug millions of deep tube wells throughout

Bangladesh, encouraging the whole nation to drink well water because it was deemed to be safe, free of

the bacteria that causes water-borne diseases such as diarrhea and other intestinal maladies that have

long plagued the country. However, in switching from rivers and other surface sources of water, the

people of Bangladesh may have exchanged water-borne diseases for arsenic. In the 1970's public health

specialists and government policy-makers were unaware of the problem. It was only in 1993 that "clean"

well water was discovered to contain dangerous quantities of the metal. According to the World Health

Organization, estimates of contamination vary from a low of 28 to 35 million to a high of 77 million—

more than half the population of Bangladesh, one of the most crowded nations on the planet. It is

estimated that over a million Indians are also drinking arsenic-laced water. Newer cases of arsenic

poisoning in the Ganges Basin suggest that many of the region's 449 million residents are at risk.

Arsenic is the number one environmental health concern worldwide-- and is ranked number one on the

federal list of the top 275 most hazardous substances found at toxic waste sites. Exposure to high levels

of the metal can cause cancers of the skin, bladder, kidney, and lung, and diseases of the blood vessels

of the legs and feet, as well as possibly diabetes, high blood pressure, and reproductive disorders. It's

also linked to kidney, nasal, liver and prostate cancers. The predominant cancer risk is through drinking

water. Inconsistencies remain in the studies of arsenic carcinogenesis, but the main point is this: even

though much remains to be learned about how arsenic causes cancer, there is no doubt that it does. If

indeed arsenic is an endocrine disruptor as well as a silencer of cancer-protecting genes, then no safe

level of exposure may exist.

This is incredibly relevant with the development of transportation and tapping into groundwater

throughout the state-- as arsenic is found in bed rock, from which it can leach into groundwater or rise

2 | P a g e

to the surface when coal or metal ores are mined. As a result of irrigation, arsenic is brought from the

subsurface to the soil surface. An increase in arsenic concentration in the soil surface, as a result of

irrigation, can detrimentally impact crop growth and is a source of entry of arsenic to the food chain.

Ground-water resources currently supply approximately 18 percent of the state’s needs and ground-

water development is continuing at a fast pace. However, the technology does not exist to detect

arsenic levels that EPA officials are pushing to reduce the standard to.

Boulder is the first in the state to have an arsenic effluent standard in its discharge permit; it has the

in house capability to test for arsenic at low standards, while in prior years there were only two labs in

the United States they were able to use for testing.

SUGGESTIONS FOR THE PLAN REGARDING ARSENIC CONTAMINATION

Utilize Boulder's arsenic action plan as a model for the state: channel more funding to water

treatment research and development, including ion exchange, reverse osmosis, and electric

dialysis.

Analyze construction dewatering rules statewide.

Develop more methods of education on the Colorado Primary Drinking Water Regulations.

Collaborate with Water for People on outreach!

Get the public more involved in water quality stakeholder groups by the next rulemaking in

2016.

Determine if there is substantial bioconcentration of arsenic occurring in Colorado’s surface

waters, and if so, determine the extent of this bioconcentration.

Fluoridation

"We make the mistake in reasoning that the fluorine in the water is the cause of the better teeth, when

we should look to the presence of liberal amounts of the calcium-bearing and phosphorus-bearing

apatite putting more calcium and more phosphorus in the foods at the same time that by decomposition

it is putting fluorine into the water percolating down through the soil." - Dr. William A. Albrecht,

Fluoridation of Public Drinking Water

Fluoridation was first advanced in the US at the end of the second World War, and it is now in about two

thirds of the water supply in the US. Proponents argued that fluoride in water and toothpaste would

3 | P a g e

help to protect teeth and prevent decay. Over the following decades, fluoride was added to public water

supplies across the country. Fluoride is a key ingredient in industry used for making aluminum, steel,

high-octane gasoline, and for enriching uranium. The real issue was in "greenwashing" the pollution

from these industrial plants and pollution, as industries are responsible for potential damage for injuries

to workers. A medical study commissioned by industry at the University Of Cincinnati in the 1950s

showed that fluoride is profoundly injurious to lungs and lymph nodes in experimental animals. That

study was buried. Today the fluorides that goes in our drinking water is almost exclusively raw industrial

pollution from the Florida Phosphate Industry. It’s a waste that’s scrubbed from the smokestacks and

trucked in tankers and dumped into reservoirs.

While the benefits of fluoridation have been held to be unquestionable, accumulating evidence points to

a alternative prospect: that fluoride may have serious adverse health effects, including infant mortality,

congenital defects and decreasing IQ1. Fluoride poisons enzymes; the halogen inhibits many enzymes by

binding with the metal ions they require in order to function. It inhibits others by a direct poisoning

action of their protein content. Fluoride also has a toxic effect on genes and gene function; research at

the International Institute for the Study of Human Reproduction, Columbia University College of

Physicians and Surgeons, as well as at the University of Missouri, has proved that fluoride is mutagenic,

i.e. it damages genes in mammals at doses approximating those humans receive from artificial

fluoridation exposure.

Fluoride is used by the body in a desperate attempt to replace iodine if the body is deficient in iodine.

Any person without proper iodine levels invites fluoride mimicking iodine. The body then attempts to

utilize the fluoride as though it was iodine, always unsuccessfully. In the process, it shuts down all the

clinical pathways to the thyroid. Fully 71 pathways, or enzymes, thus become annihilated. Enzyme

construction and thyroxin utilization become the observed and measured results. Fluoride also has the

capacity to bind lithium in the brain2.

SUGGESTIONS FOR THE PLAN REGARDING FLUORIDATION

1 Democracy Now. "The Fluoride Deception: How a Nuclear Waste Byproduct Made Its Way Into the Nation’s Drinking Water."

<http://www.democracynow.org/2004/6/17/the_fluoride_deception_how_a_nuclear>.

2 Walters, Charles. "Minerals for the Genetic Code: An Exposition and Analysis of the Dr. Olree Standard Genetic Periodic Chart and the Physical, Chemical and Biological Connection."

4 | P a g e

End fluoridation of drinking water.

Mining____________________________________________________________________________

Outdated Mining Laws, Abandoned Mines

There are an estimated 500,000 abandoned hardrock mines in the West, according to Earthworks. The

US Bureau of Mines estimates that 12,000 miles of the waterways of the Western US, or about 40

percent, are contaminated by metals from acid mine drainage, mostly by abandoned mines, while

abandoned mine runoff continues to taint 180,000 acres of lakes. In Colorado, 2,751 abandoned mine

sites have possible impacts on water quality in 20 watersheds. All too often, no viable financially

responsible party exists for the abandoned mines. While the water quality in the vicinity of the mine

continues to be impaired, no one can be held responsible for cleaning it up. Further, the General Mining

Law of 1872 (GML) continues to regulate the extraction of hardrock minerals; according to Jane

Danowitz, public lands director for the Pew Environment Group, in a New York Times interview, "This is

a law that basically hasn't been changed in almost 140 years." As the GML allows mining companies to

take approximately $1 billion annually in metals from public lands without payment of a royalty, funds

for remediation efforts are not sufficient for the task.

While Superfund was developed to address abandoned hazardous waste sites when liable parties no

longer exist or either cannot or will not undertake a cleanup, it too lacks the necessary funds. Under the

Superfund law, the EPA was ordered to develop a list of more than 400 priority sites nationwide, at least

one in each state. The agency soon recognized that the scope of the problem was much larger,

estimating that 2,000 sites would ultimately be included on the National Priorities List. In 1985, as the

original legislation was about to expire, the now disbanded Office of Technology Assessment (OTA)

issued its report—Superfund Strategy—which concluded that the magnitude of the hazardous waste

problem was much larger than most lawmakers had envisioned. According to the OTA, the number of

sites could mushroom to more than 10,000, requiring cleanup efforts over a span of perhaps 50 years.

The report estimated that costs borne by Superfund could reach $100 billion and that overall costs to

the nation could total several times that amount. The Superfund program has in past received funding

from two sources: general funds from the Treasury and balances in the Superfund trust fund. In earlier

years, revenues for the trust fund came from three dedicated excise taxes and an environmental

corporate income tax. Those taxes expired in December 1995, and the amount of unobligated money in

5 | P a g e

the fund declined to zero by the end of FY2003. The program is currently charged with the cleanup of

nearly 1,300 hazardous waste sites across the country; one in four Americans live within three miles of a

contaminated site posing serious risks to human health and the environment, according to the EPA.

For those concerned with job creation, think of how many jobs we can create through environmental

remediation efforts from historic mining and beyond. The economic crash and crisis of the past years

can be transformed into a catalyst for a new economic paradigm-- an economy that is not based off of

70 percent consumption, but creative thought, the health of the environment and subsequent

biodiversity.

Fracking

Before fracking much of Colorado, we collectively need to analyze the environmental, economic and

social impacts from historic mining to understand fracking’s potential ramifications. Over half of all the

shale gas ever developed in the world has been produced in the last three years, which has resulted in

nearly all of the peer-reviewed scientific research on the environmental and public health consequences

of shale gas having been done in the last year and a half. Environmental regulation remains incomplete.

The hydraulic fracturing process itself is exempt from seven major federal regulations:

• The Clean Water Act and Safe Water Drinking Act: The Safe Drinking Water Act's Underground

Injection Control program protects underground sources of drinking water from contamination by

injected fluids. In 2005 the Energy Policy Act amended the Safe Drinking Water Act to exclude

hydraulic fracturing from the definition of "underground injection.";

• the Resource Conservation and Recovery Act, which has exempted all oil and gas exploration and

production wastes from federal regulations pertaining to hazardous waste since 1988;

• the Superfund law, which requires that polluters remediate for carcinogens like benzene released

into the environment, except if they come from oil or gas;

• the Comprehensive Environmental Response, Compensation, and Liability Act, which excludes

parties involved in oil or natural gas that have contributed to environmental mess from legal

responsibility for the cost of cleaning it up. CERCLA excludes oil and gas products and any chemicals

contained in them (unless otherwise regulated);

• the National Environmental Policy Act, which requires government agencies to consider the

environmental impact of their actions, and requires public comment and evaluation of alternatives

through an environmental impact statement process when a significant impact is likely. The 2005

6 | P a g e

Energy Policy Act created a categorical exclusion for some types of oil or gas well expansions,

allowing them to occur with limited review. The public now has to prove significant harm to

challenge anything on the basis of NEPA violations.

• the Toxic Release Inventory under the Emergency Planning and Community Right-to-Know Act,

which the oil and gas industry is exempt from reporting releases of toxic materials in the Toxic

Release Inventory.

• the Clean Air Act, which requires the EPA to list major and clustered minor categories of sources of

air pollution, but has not included wells or fields allowing operators to avoid emissions controls

standards.

In the past year, Colorado, Texas and Pennsylvania have moved to tighten state regulations and require

mandatory disclosure of what's in the fracking fluids, but loopholes still remain. "We don't know the

chemicals that are involved," Vikas Kapil, chief medical officer at the National Center for Environmental

Health, admitted at a recent conference.

"We don't have a great handle on the toxicology of fracking chemicals." Dr. Theo Colburn of the

Endocrine Disruption Exchange has spearheaded research on the toxicology of fracking chemicals,

paying particular mindfulness to endocrine disruption. Endocrine-driven disorders include ADD and

autism. She noted in a 2010 Democracy Now interview that 944 chemicals are used in natural gas

extraction, and that we know between 95 and 100 percent of about 14 percent of the chemicals that are

being used, and nothing is known about 43 percent of the products in use. Shale gas development has

already caused significant surface water pollution. Fracking fluids extract chemical substances from

shales, including toxic and carcinogenic aromatic hydrocarbons, toxic metals, and radioactive materials.

Some of these materials are released to the environment when blowouts and other accidents occur. A

greater route of release and exposure comes from disposal of frac-return fluids. Approximately 20

percent of the material used in hydraulic fracturing flows back to the surface in the first few weeks after

fracturing with all of the added and extracted chemical substances.

Rare Earth Elements

US Rare Earths said in a release that it has staked additional claims in the area beyond its 4,000-acre

holding Colorado's Powderhorn mineral belts. Thorium has been found since 1949 in at least 33 deposits

in an area six miles wide and 20 miles long in the Powderhorn district, Gunnison, CO; the district has

7 | P a g e

long been known for its alkalic igneous rocks, of which the best known are those of the Iron Hill

composite stock. The district is drained by three northward-flowing tributaries of the Gunnison River:

Willow Creek, Cebolla Creek, and the Lake Fork of the Gunnison.

US Representative Hank Johnson reintroduced the Resource Assessment of Rare Earths (RARE) Act of

2013 to Congress in March 2013. It is a bill aimed at securing rare earth supplies and reducing China’s

monopoly on the market. RARE directs the United States Geological Survey (USGS) to conduct a three-

year, comprehensive global mineral assessment of rare earth elements (REEs). The USGS global

assessment, conducted with geological surveys of partner nations around the world, will identify and

quantify individual rare earth elements in known deposits, improve understanding of the distribution

and formation of rare earth element deposits, assess likely undiscovered deposits worldwide, analyze

the state of the complete rare earths supply chain from mining to manufacturing, and recommend

further research and steps to improve our understanding and ensure access.

SUGGESTIONS FOR THE PLAN REGARDING FRACKING, ABANDONED MINES, OUTDATED MINING

LEGISLATION AND THE MINING OF RARE EARTH ELEMENTS

Clarify potential disposal options for wastewater and other wastes containing radioactivity.

Encourage congressional members to pass General Mining Law reform, the Good Samaritan

Law, the federal budget with the hardrock mining language intact, reinstating Superfund taxes--

and demanding parallel regulations and taxation for the hydraulic fracturing industry.

Push legislation that would allow western states to tap federal funds earmarked for coal mine

clean-up and use them to address safety and environmental issues at abandoned hard rock

mining sites instead.

o In Colorado, the law’s passage would mean that the Division of Reclamation, Mining

and Safety would be able to afford to take on approximately 100 additional projects

annually for the next few years.

Support further studies on radioactivity before allowing rare earth element and uranium mining.

Regulate the hydraulic fracturing process under the follows laws and acts:

o The Clean Water Act and Safe Water Drinking Act;

o the Resource Conservation and Recovery Act;

o the Superfund law;

o the Comprehensive Environmental Response, Compensation, and Liability Act;

8 | P a g e

o the National Environmental Policy Act;

o the Toxic Release Inventory under the Emergency Planning and Community Right-to-

Know Act;

o and the Clean Air Act.

Agriculture________________________________________________________________________

Fertilizers & Pesticides in Agriculture and Weed Control

The recent algal bloom crisis in Toledo warms us of the harms of excess nitrogen and fertilizer-- it also

debunks the no-till, nitrogen and phosphorus fertilizer-heavy, mono-culture agricultural paradigms

perpetuated by Cargill, Monsanto and the like.

Nutrients

Nutrient pollution from fertilizers is a leading cause of degradation of U.S. water quality, and nitrogen

and phosphorus are the nutrient culprits. While it has been discussed at the national and state levels for

many years, nutrient pollution is difficult to define and address because of the widespread use of

fertilizers in agriculture and landscaping. According to the National Academy of Sciences, even though

farmers use pesticides more widely, homeowners use 10 times more fertilizer per acre. Treated sewage

is also a major contributor of nutrient pollution.

Nitrogen and phosphorus together support the growth of algae and aquatic plants, which provide food

and habitat for aquatic life. However, excess nitrogen and phosphorus in aquatic systems can stimulate

over- production of biomass, leading to changes in biological integrity. Harmful algal blooms negatively

impact the food web by decreasing the amount of nutritious, edible phytoplankton that zooplankton

and other primary consumers need to survive. These organisms may then starve, leading to decreased

food for higher order consumers such as fish. Harmful algal blooms can block sunlight from

phytoplankton under the water’s surface, leading to decreased food and oxygen levels. When harmful

algal blooms begin to break down and die, they can decrease dissolved oxygen levels, a change that

can be lethal to other aquatic organisms and cause fish kills. The toxins produced by harmful algal

blooms are a concern for human health-- they are possible carcinogens to humans, and current

research is studying the link between certain cyanobacterial toxins and neurological diseases such as

Lou Gehrig’s disease. The most common toxin is called microcystins. There are at least 60 different

9 | P a g e

types of microcystins, and their toxicity can vary significantly. The WHO standard for microcystin-LR in

drinking water is 1.0µg/L, but there are no similar standards for waters in the United States.

Toxins of mycrocystins:

Toxin Types Examples Effects

NeurotoxinsAnatoxin-a, anatoxin-a(s), saxitoxin,

neosaxitoxin

Affects central nervous system, causes

seizures, paralysis, respiratory failure,

and death

HepatotoxinsMicrocystins, nodularins,

cylindrospermopsin

Affects liver, causes hemorrhaging,

tissue damage, tumors, liver cancer,

and death

Dermatotoxins and

Gastrointestinal toxins

Aplysiatoxins, lyngbyatoxin-a,

lipopolysaccharide endotoxins

Affects skin and mucous membranes,

causes rashes, respiratory illness,

headache, and stomach upset

Cytotoxins Cylindrospermopsin

Affects liver and other organs; causes

chromosome loss, DNA strand

breakage, and organ damage

I am thankful that in March 2012, Colorado passed new rules to tackle nutrient pollution, yet

disappointed that agriculture is not be regulated. Agriculture remains the main source of nutrients; it

would be very wise for Colorado's Water Plan to make this amendment.

German scientist Justus Von Liebig was responsible for the theory that Nitrogen, Phosphorous, and

Potassium levels are the basis for determining healthy plant growth. However, this theory, which dates

to the 1800s, doesn't take into account the dozens of other nutrients and elements that are essential to

plant growth such as sulfur, hydrogen, oxygen, carbon, magnesium, etc. Nor does the theory talk about

the importance of beneficial soil organisms that help plants fight off pests and diseases3. In fact,

elements such as carbon, hydrogen, oxygen, sulfur, magnesium, copper, cobalt, sodium, boron,

molybdenum, and zinc are just as important to plant development as N-P-K4.

3 Explanation of NPK and fertilizers. <http://www.cleanairgardening.com/npkexplanation.html>. 4 Garrett, Howard. “Plants for Texas.” <http://www.utexas.edu/utpress/excerpts/exgarhow.html>.

10 | P a g e

o People who depend on rural, private wells for their water source have one of the higher rates of a

condition called Methemoglobinemia, aka Blue Baby Syndrome, which damages blood cells and is

traced to high Nitrates5.

o Reactive nitrogen increases atmospheric ozone levels, causing respiratory diseases and hurting crop

yields and produces acid rain. To top it off, oceanic nitrogen is converted to nitrous oxide, a

greenhouse gas6.

o The kind of nitrogen typically found in chemical fertilizers dissolves very quickly in water. This means

that excess nitrogen may find its way into groundwater and freshwater sources and contaminate the

water. Additionally, many chemical fertilizers are now using phosphoric acid to create a high

phosphorous content quickly and cheaply; this kind of phosphorous essentially neutralizes other

important trace minerals from the soil that plants need.

According to Sandra Steinberger's "Raising Elijah," in 2009, nitrogen fertilizer was used on nearly all

conventionally grown durum wheat, 94 percent of other spring wheat, and 83 percent of winter

wheat. In 2009, 2,968,000,000 pounds of nitrogen fertilizer were used to grow America's wheat in

2009. Almost all of these nearly three billion pounds were created from natural gas. Five percent of

global natural gas reserves is turned into nitrogen fertilizer-- all by itself, the United States consumes

2.2 billion pounds of nitrogen fertilizer a year. Do we really want the whole world's agricultural system

to ride a tandem bicycle with the oil and gas industry? Further, a 2010 health ranking study undertaken

by the Robert Wood Johnson Foundation showed that some of the least healthy counties in the US are

located in bumper crop regions. And yet, for many of these counties, the list of their underlying

problems include the phrase: "lacks access to healthy, affordable food."

Pesticides

The first systematic comparison of pesticide residues in organic and nonorganic foods was carried out in

2002. Examining the data from more than 90,000 samples of produce, the authors of this study found

that nearly three-quarters conventionally grown foods had detectable pesticide residues. Three quarters

of organic crops had none. Organophosphates block the action of an enzyme that regulates a

neurotransmitter and are thus brain poisons. Assessing the power of pesticides to influence children's

5 Keim, Brandon. “Reactive Nitrogen: The Next Big Pollution Problem.” Wired Science. May 15, 2008. <www.blog.wired.com/wiredscience/2008/05/reactive-nitrog.html>. 6 Keim, Brandon. “Reactive Nitrogen: The Next Big Pollution Problem.” Wired Science. May 15, 2008. <www.blog.wired.com/wiredscience/2008/05/reactive-nitrog.html>.

11 | P a g e

hormones is the part of the job mandated by the Food Quality Protection Act-- though it is not yet done,

even though the EPA was originally given a 1999 deadline.

2, 4-D is an herbicide that has been linked with birth defects.

Chlorpyrifos is an organophosphate that has been linked to cognitive deficits in children.

Emerging evidence also links it to autism. Organophosphate pesticides in particular can induce

spasms in bronchial tubes and contribute to airway hyperactivity by altering the functioning of

nerves that supply the muscles of the airways. Organophosphates interfere with the recycling of

the neurotransmitter acetylcholine, one of the messaging signals that flow between neurons.

The second most common pesticide used in the US, atrazine, enhances the production of an

enzyme called aromatase, which is used by the body to convert testosterone into estrogen. The

end result is higher estrogen levels. Like children, amphibians are uniquely sensitive to

pesticides. Trace exposure to the weed killer atrazine has been found to emasculate male

tadpoles-- in a recent study, male frogs exposed to atrazine turned into fully functional females

that mated with males and produced eggs. According to researchers at the National Institute for

Environmental Health Sciences, 60 percent of Americans are exposed, mostly through drinking

water, to atrazine. In 2006, in spite of the remaining uncertainties of atrazine's health effects,

atrazine was banned for use in the European Union. Along with phthalates, PCBs, and air

pollution, atrazine appears on the list of chemicals with demonstrable links to shorter pregnancy

and lower birth weights.

There is no national pesticide registry in the US. Farmers are not required-- as are manufacturers-- to

report their chemical releases.

In a 2007 study, a team of biologists at the University of Michigan concluded that legumaceous cover

crops could fix enough nitrogen to replace all the fossil-fuel derived fertilizer now in use. Thus, they

dispute the idea that organic agriculture is constrained by lack of nitrogen. More centrally, the same

research team disputes the evidence that organic farming suffers from lower yields. In a review of 293

studies that compared yields of organic and conventional farms in both developed and developing

nations, researchers found parity. In the US, yields on organic farms were about 92 percent of the yields

produced by conventional agriculture, whereas in developing countries, yields were actually higher.

Organic farming prohibits the use of synthetic pesticides. Organic acres still only account for 0.7 percent

of total US crop acreage. Of US cows, 2.7 percent are raised organically. Of US egg-laying hens, 1.5

12 | P a g e

percent are raised organically. In essence, organic agriculture is a form of farming that replaces synthetic

chemicals with ecosystem services. Organic agriculture sows the seeds of its own preservation.

Weed Control

I am calling for an alternative approach to noxious weed management; the new field of ecology, invasion

biology, sprang forth from Charles Eton in just 1958. Seen from a different perspective, the development

termed "invasion" could also be described as vegetation dynamic or successional change that is a

natural process of plant species and ecosystems to deal with disruptions and openings. In addition to

widespread physical alterations to landscapes, massive upheavals to ecosystems occur from

contamination by numerous invisible pollutants that have leached into the water, soil, and air. In such

disturbed ecosystems, many of the native plants are poisoned and are less able to deal with upheaval,

but the weedy, invasive plants cope well and even flourish in the toxic surroundings. For example,

Canada thistle, bindweed, leafy spurge, sowthistle, knapweed, and yellow star thistle displayed a

significant growth response (110 percent) to increasing CO2 levels during the twentieth century, with

the growth anticipated to be an additional 46 percent over the next 100 years. Overused and depleted

rangelands are the areas most in need of thistle; it keeps foraging cattle from such lands and

discourages farmers with its virulence. Thistle's roots aerate the generally hard soil of improperly

managed rangeland, and over time, the plant increases biomass to restore and conserve the topsoil

from blowing away.

By the dawn of the twentieth century, laws were passed by the US Congress to control the plants that

impeded the progress of the great agricultural machine. The regulations started with the Lacey Act of

1900, follow by the Plant Pest Act, the Plant Quarantine Act, and the General Noxious Weed Act of

1974, in which were targeted plants that "can directly or indirectly injure crops, other useful plants,

livestock, poultry, or other interests of agriculture, including irrigation, navigation, fish and wildlife

resources, or the public health. Cornell University claims that each year the US spends 34.7 billion

dollars in fighting noxious weeds7.

SUGGESTIONS FOR THE PLAN REGARDING AGRICULTURE, NUTRIENT POLLUTION & PESTICIDE USE

Support organic agriculture.

Support perennial grain production.

7 Lee Scott, Timothy. "Invasive Plant Medicine: The Ecological benefits and healing abilities of invasives."

13 | P a g e

Regulate agriculture for nutrient pollution, eventually discontinuing use of synthetic fertilizers as

well as nitrogen and phosphorus rich fertilizers-- -- opting instead for legumaceous cover crops

to fix nitrogen.

Support studies of growing hemp to absorb excess nutrients.

Support research of mycrocystins.

Develop a standard for microcystin-LR in drinking water.

Develop mandatory testing of algal-bloom heavy areas for mycrocystins. Thus, support new

technologies to monitor pollution levels in the environment. EPA is studying innovative

technologies that will measure nutrient pollution in the air and water using satellites, portable

and ground remote sensors as well as measurement and model data. These technologies

enhance current monitoring activities and also provide cheaper and faster information on

nutrients and other pollutants.

Oregon and Washington in the U. S. have fertilizer registration programs with on-line databases

listing chemical analyses of fertilizers-- create the same in Colorado.

Create a functioning endocrine-screening program, with validated protocols, as mandated by

the 1996 legislation.

Chemical Regulation_________________________________________________________________

According to Sandra Steinberger's "Raising Elijah: Protecting our children in the age of environmental

crisis," only 200 of the more than 80,000 synthetic chemicals used in the United States have been tested

under the Toxic Control Substances Act of 1976, and exactly none of them are regulated on the basis of

their potential to affect infant or child development. Current laws do not require the screening of

chemicals for their ability to damage or alter pathways of brain growth, and only about 20 percent of

the 3,000 chemicals produced in high volume in the US have been tested for developmental or pediatric

effects. Further, of the 300-odd chemicals that are presumed ingredients of fracking fluid, 40 percent

are endocrine disruptors and a third are suspected carcinogens. A third are developmental toxicants.

Over 60 percent can harm the brain and nervous system.

SUGGESTIONS FOR THE PLAN REGARDING CHEMICAL REGULATION

Provide support for the Toxic Chemical Safety Act. Chemical reform should be based on the

precautionary principle.

14 | P a g e

Education_________________________________________________________________________

According to the National Environmental Education Foundation, the average American adult,

regardless of age, income, or level of education, mostly fails to grasp essential aspects of

environmental science, important cause/effect relationships, or even basic concepts such as runoff

pollution, power generation and fuel use, or water flow patterns. For example, about 80 percent of

Americans are heavily influenced by incorrect or outdated environmental myths; just 12 percent of

American can pass a basic quiz on awareness of energy topics.

Further, NEEF asserts that national studies indicate that 47 percent of all natural resource agency field

staff and 77 percent of all leadership staff are expected to retire by 2015, leaving a void in outdoor

and science positions in Colorado and across the nation. Nearly one third of children in Colorado live

in neighborhoods without a park, playground, recreation center, trail, or other safe place to play.

Thus, in addition to environmental literacy, Colorado schools and community providers must promote

outdoor recreation, such as hunting, fishing, archery and adventure education, to ensure all

Coloradoan students have the opportunity to foster connections and routines in the outdoors.

Colorado teachers and students have worked on wetland creations, xeriscaping, windbreaks, nature

trails and urban wildfire habitat projects around their schools.

Professional environmental educators often give short shrift to the media. But children get more

environmental information (83 percent) from the media than from any other source. For most adults,

the media is the only steady source of environmental information.

SUGGESTIONS FOR THE PLAN REGARDING ENVIRONMENTAL EDUCATION

Set a goal that a greater number of Colorado Schools become U.S. Department of Education

Green Ribbon Schools (ED-GRS) in Colorado. Typical characteristics of these award-winning

schools is that they exercise a comprehensive approach to creating “green” environments

through reducing environmental impact, promoting health, and ensuring a high-quality

environmental and outdoor education to prepare students with the 21st century skills and

sustainability concepts needed in the growing global economy.

Encourage environmental education partnerships with the media.

Support experiential learning and school gardens.

15 | P a g e

APPENDICES In 1860, humanity produced 15 metric tons of reactive nitrogen. By 1995, that number stood at 156 tons, and swelled to 185 tons by 2005. Those numbers are small in comparison to global CO2 emissions — 27 billion tons annually — but the impacts are magnified by what James Galloway, a University of Virginia biogeochemist and co-author of the review, calls the nitrogen cascade8.

8 Keim, Brandon. “Reactive Nitrogen: The Next Big Pollution Problem.” Wired Science. May 15, 2008. <www.blog.wired.com/wiredscience/2008/05/reactive-nitrog.html>.

16 | P a g e