The Butte-Silver Bow Health Department recently released the long awaited “work plan/design” for the Butte Health Study that would investigate whether or not Superfund was working in Butte to protect human health. This recently released plan belies and betrays the promises that EPA and Butte-Silver Bow made to the Butte community.
I would offer these comments regarding the relationship of the report to promises made to the public by Butte-Silver Bow and EPA:
1. We were promised an independent study. This is not an independent report. This report was produced by a firm under contract to Arco.
This report was not done by the Butte-Silver Bow Health Department or by EPA. All the health department did was attach its name to the Health Study. Is it reasonable to expect that a company responsible for most of the cleanup in Butte is going to produce a report that is critical of itself?
This repeats the constant problem regarding Butte Superfund that those responsible for the cleanup evaluate their own work. How fair is this?
2. We were promised that the Health Department would be the lead agency conducting the health study. Instead, we got an Arco-funded study. The Health Department must rely on Arco because it does not have the in-house competency to do such a study. The health department panel doing the study contains no one who is an expert in environmental risk assessment or environmental epidemiology and toxicology—areas vital for any valid Health Study.
While experts in risk assessment and environmental epidemiology and toxicology volunteered to be on the health department panel, the health department rejected these people as not “fitting in” and being “too volatile.”
It is obvious that the health department only wanted those who would not rock the Arco/EPA boat by asking difficult questions and who would “go along to get along.”
We were the loser. EPA knew this up front and tasked the health department to do this study because EPA knew that the health department would be a “rubber stamp” for a report actually prepared by Arco and EPA.
The EPA picked the health department to be a “cover” for the EPA and the health department acquiesced.
We have seen this already with the health department stating before the study was even done that cancer rates in Butte were not that unusual and that there was nothing abnormal going on here.
They have announced the results of the study before the study is even done. Why would they do such a thing? Is it because the Health Department wants a report that shows that Superfund is working no matter what the evidence?
3. We were promised that the Butte Health Study would seriously address environmental justice. The report released by the health department ignores environmental justice. The poor and low-income citizens are not even mentioned in the report.
Although uptown/central Butte has a disproportionately large number of low income citizens who live in substandard housing and who are disparately affected by exposure to the toxics of concern in Butte, EPA and the Health Department, contrary to the EPA mandate to promote environmental justice, have forgotten the poor.
4. We were promised full public participation in the development of the Health Study. The health department has excluded the public from this process. The health department meetings to develop this report were secret.
The advisory board was appointed in secret. The public was never notified of these meetings.
The public was never afforded an opportunity to participate in these meetings. It is as though the Health Department has never heard of the requirements of Montana’s open meetings and open government laws. It is as though the EPA has never heard of the federal Sunshine in Government Act.
Whether or not Superfund has been effective in Butte is a significant public policy question.
Citizens have a right to expect a fair and competent assessment of Superfund’s effectiveness.
So far all we have received is a whitewash. I can promise that there will be independent citizen review of this report by citizen experts who will make their voices heard. Wouldn’t it have been nice though, if government had done the right thing from the beginning.
John W. Ray
915 West Galena St.