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I am one member of a five person board. The opinions I express on this forum are mine only, and do not necessarily reflect the views or opinions of the Escambia County Staff, Administrators, Employees, or anyone else associated with Escambia County Florida. I am interested in establishing this blog as a means of additional transparency to the public, outreach to the community, and information dissemination to all who choose to look. Feedback is welcome, but because public participation is equally encouraged, appropriate language and decorum is mandatory. Although this is not my campaign site for re-election--sometimes campaign related information will be discussed, therefore in an abundance of caution I add the following : Political Advertisement Paid for and Approved by Jeff Bergosh, Republican, for Escambia County Commissioner District 1








Saturday, October 5, 2019

An Afternoon With International Paper Part II---Presentations and a Tour of the Cantonment Plant And Beulah/Perdido Wetlands

I toured IP's facilities in Cantonment and Beulah yesterday--and I learned a lot about this company in the process...

My meeting with IP staff was very cordial yesterday afternoon.  It started with introductions around a large conference room table.  They knew me, so they wanted me to know THEM.

Scott Taylor is the mill's manager, has been with the company for 17 years, and moved to the area about two years ago.  Laurie Mclean is the mill's Environmental Health and Safety Manager. A chemical engineer by trade, she has been with the company for 19 years.  Randy McRae, a senior Regional Manager for Government Relations covering the states of Mississippi, Georgia, Alabama, and Florida has been with IP for 33 years.  Whitney Fike, the IP Internal and External Communications Officer, is a native of Escambia County's Cantonment area and has been with IP for the last three years.  This was the group that gave me a presentation, a mill tour, and a tour of IP's wetlands area.

The first part of my visit consisted of a discussion about IP's corporate culture, values, objectives, strategies, revenues, market segments, and corporate goals.  It was interesting.  

The company had over 52,000 employees in 24 countries around the world and they  produced $23 Billion in total revenue in 2018, with three core areas of specialty products.  Papers account for 19% of product revenue, Industrial packaging accounts for 69%, and Global cellulose fibers make up 12%. They create boxes for Tyson foods, Amazon, Little Caesars Pizza, and many other retailers.  Their cellulose fibers are used in Pampers Diapers and multiple brands of the fast growing market of adult incontinence products.  "That is a growing segment of our market, particularly overseas" said Mr. McRae.  "That's pretty depressing for those of us getting older." I quipped. 

As it pertains to IP's impact on Pensacola specifically-I was told that IP directly employs 500 personnel and another 100 contractor personnel.  The group provided information claiming a local economic impact of $250 Million yearly in the Pensacola area.

After the corporate information powerpoint, Laurie Mclean went through about twenty slides focused on the company's environmental compliance efforts.  This was interesting, and a lot of it was NEW information to me.  Several of the slides were extremely informative, so naturally I asked for a copy.  "Can you just send me this presentation?"  I asked.  "Unfortunately we cannot send this outside the company--as it contains proprietary information." was the response.  This was disappointing, like when I was told I could not take any pictures or videos on their property during my tour (as I mentioned in part I).  We went through many of the issues with which I was familiar:  the previous issues with obtaining their permit in 2010.  The re-routing of their effluent from 11-Mile Creek to their own private wetlands beginning in 2012 via a long pipeline they own jointly with ECUA, and the problems with their current permit--which has been administratively extended.  One slide in particular captured my interest:  "This is probably the most profound data I have seen yet." I told them.   It is one slide I certainly would have taken a picture of and spotlighted in this post if I would have been permitted to do so.  Essentially, it was a slide that depicted the health of Perdido Bay graphically, as measured by a number of key environmental metrics, from the late 1980s through 2019.  It looked like a bell curve, with the highest levels of contaminants in Perdido Bay representing the top of the "curve."  The bay was in the worst health of all in 2000--according to this chart.  "That's the year we took over this plant from Champion" mused Mr. McRae.  But the interesting thing to note was that from that point forward--this chart showed a straight downward trend line (with dramatic drops from 2012 forward) through 2018---with contaminant levels in 2018 back down to the levels of the late 1980's levels.

"Why are you all not putting this slide out in response to the attacks from the media and the Pensacola News Journal---did you not see last Sunday's cartoon and hit piece in the PNJ?" I asked.  There really was not a good response to my question, though.  The group just looked back at me with subdued, almost somber expressions.  I must surmise that IP's corporate offices prefer to not directly engage/challenge inaccurate information.  My personal feeling on that--seeing the way they are attacked unfairly almost weekly by our newspaper--is that this strategy is not working from a PR standpoint.  But that's their decision to make.....

Several other slides were presented, specifically on their wetlands project where they send their effluent.   According to the staff, the plant species that have been introduced out there have thrived over the last 7 years.  "We measure for biodiversity, we measure the growth of the trees we plant, and we spend about $300,000.00 yearly just on testing out there and in Perdido Bay," said Mrs. McLean.  I was shown a montage of pictures taken at the wetlands showing the flora and fauna.  "We have all kinds of animals out there--including threatened and endangered plant and animal species like the Pitcher Plant, the Bald Eagle, and the Gopher Tortoise. We have documented over 160 different bird species out there."  She continued "We have a former employee who is in the Audubon Society--and we let him go out and bird watch.  In exchange, he sends us photos like these." The screen then flashed multiple pictures of birds, plants, alligators, foxes, bobcats, and other wildlife from their wetlands and reserve property in Beulah just north of Perdido Bay.  As we finished going through the presentation in preparation  for our tour, several facts of note were presented that are worthy of mention here--to include the following:

-IP has spent $94 Million Dollars on their pipleine, wetlands, and water treatment facilities in Escambia County in an effort to achieve total compliance with their discharge permit to comply with the CWA.

-IP operates lawfully on an administratively extended permit from DEP.

-IP spends about $300K yearly on testing and monitoring for environmental compliance locally

-IP utilizes reclaimed water from ECUA for their processes, recaptures and re-uses much of this water on site, and burns off much of this water before discharging what remains through their pipeline.

-IP could utilize potable water from the area's aquifer for its production processes, however they chose to use treated ECUA water instead to ease the burden on the aquifer. 

-ECUA pumps millions of gallons of water through the pipe to IP's weltlands as well--as much as 5 Million Gallons Per Day (MGD)--in addition to what IP sends out.

-ECUA's treated water has consistently failed the same toxicity test (chronic) on the water flea.  

-ECUA stopped performing the toxicity tests last year on its treated water which it provides to IP for use in their production facilities.

-The nexus between IP's failure in the chronic toxicity test at the end of the pipe and the utilization of this reclaimed ECUA water (which also fails the same toxicity tests consistently) for their production processes has not been fully understood as of yet.

-IP successfully demonstrated their ability to pass the chronic and acute toxicity tests utilizing water from the second berm of their 3-berm polishing wetlands in 2013.

-Similar wetlands to IP's in the region and locally do not have this species of water flea (Ceriodaphnia dubia) naturally occurring--due to the pH levels that do not sustain this life form in these nearby waters.  Yet this is the species IP is mandated to utilize for this toxicity testing.

-The Water Flea survives in the 100% effluent; the reason the chronic toxicity test is considered a "fail" is that the water fleas in the effluent water do not reproduce at the same level as the control water sample--but the fleas live and reproduce in both the test and the control water.


Eventually, after we went through the very thorough environmental presentation, and an equally comprehensive safety presentation,  and got completely "geared-up" with Personal Protective Equipment (PPE)--including ear and eye protection, hard hat, and safety vest--I was given a tour of the mill's production facilities. The size of the machines that press and roll the paper was incredible!  Inside the production area, where I was given a tour, the temperature was over 115 degrees fahrenheit!

"We have fans for the employees, and we take lots of hydration breaks, we have water stations stacked." said Scott Taylor.  I noted several buildings within buildings on the production floor, with tinted windows, lots of flat screen computers and control panels.  Each of these enclaves was air-conditioned and comfortable, and the ones I was shown had two or three personnel inside monitoring the production. 

At the end of the lines--huge, massive rolls of brown paper and white cellulose fibre roll off onto conveyor belts.  As I watched the  giant brown rolls of paper go by on the belt, I asked Scott if these ever "roll off..."   Not very often, but unfortunately sometimes they do.  You wouldn't believe how heavy these rolls are.  You never want to be between one of those rolls and any structure--because that's how very serious injuries occur," he stated.  After I was introduced to many of the personnel, we completed our mill tour and were off for our tour of IP's wetlands and conservation lands further south in Beulah.

THE WETLANDS

We caravaned from IP's Cantonment facility down Muscogee Road to Beulah road, where we made a left turn and traveled south to IP's conservation and wetlands property--where the 27 million gallons  of effluent flows daily from IP's mill and eventually into Perdido Bay.  It was a short drive, and upon our entry onto IP's Beulah property off of Hurst Hammock Road (through a locked gate), we were greeted by Mark, the forester who manages this property for IP.  I left my truck at the gate and we all jumped into the large SUV that IP personnel brought, and we drove through the conservation land and into the first berm area of the wetlands.  Along the way Mark pointed out numerous pitcher plant areas, sections of the forest where IP conducts controlled burns, and numerous Gopher Tortoise burrows.  "We started out and found two tortoise burrows--now we're up to 23.  These are a threatened species," he said.  We stopped and exited the vehicle at numerous points and Mark proudly pointed out areas where trees and other plants had been planted.  Areas that would eventually be inundated with water from the discharge were built up into a series of small round islands where 7-9 different species of plants and trees were planted on each little island according to mill manager Mark Taylor.  As we continued deeper into the woods, we came upon a clearing that subsequently led to the end of the discharge pipe.  "Here we are, let's get out and take a look around," Taylor said.  

As I walked up to the concrete structure and up to the top of the platform, I looked down and observed a torrent of water cascading out of the pipe, across a 20 foot concrete platform that has "stairs" stepping down on either side.  This water was somewhat murky, but the smell was not overwhelming to me--I expected it to be much worse.  As the water flowed down, it went into a large canal that runs parallel to the berm on one side.  The water was alive with bream and bluegill--I saw multiple bass swimming in the water from the bank.  As we traveled down the berm, Mark told us "There are hundreds of Alligators out here.  We actually see more of them in the winter.  They come out and lay on the road and soak up the sun in the middle of the day--sometimes a dozen or more at a time."  We drove the length of that berm, stopping from time to time to look at various things.  Mark told us about some of the wildlife that is out in this 1400 acre property "We have Bear, Deer, turkey, wild boar, bobcats, all kinds of animals out here," he exclaimed as we drove down the road along the berm.  I asked if I could take some photos of the pipe and the water, and Whitney Fike took some photos with her camera. "By Tuesday we should have the clearance to send you these," Scott Taylor said.

I had hoped to see much more of the wetlands, but much of it is inaccessible by car.  "In order to get down to the area adjacent to Perdido Bay-we would need to have a boat for that," the group explained.  But I felt like I saw a lot of the first stage of the polishing wetlands.  I was curious about all the green covering along much of the canal.  "Is that algae?" I asked.  Actually it is not algae I was told but rather a huge growth of a small plant called "Duckweed".  "It is abundant out here this time of year," said Mark.  Some takeaways I observed from travelling through this area:

-The IP Wetlands areas I looked at yesterday appeared healthy--with plants, trees, and shrubbery that seem to be thriving.  I'm definitely not a scientist, but this is what it looked like to me...

-Several areas of this wetland and conservation area are being thinned via controlled burns (these, I would assume, are the brown/dead looking areas of the woods from the satellite photos that have been making the rounds on social media)

--The "Islands" within the wetlands are dotted throughout the area, in almost a grid-like pattern; these have 7-9 different plant species each.  I believe these "islands" are the round circles in patterns that some drone footage pictures on social media have portrayed (that look like a grid or checker-board pattern).

-The water in the canal at the first stage of the pipe outfall is full of fish and insect activity.

-Much of the water is covered with Duckweed--which I am certain is the green in the water from the satellite pictures that have been displayed on social media (although I have no way of knowing if there is also algae present in the area)

-Paper mills in other areas of the country that discharge into bodies of water that flow (rivers and streams) have an easier time passing the toxicity test (s) because their test water can be diluted in a commensurate percentage with fresh water in an amount and in a proportion that aligns with the body of water in which the effluent will be discharged (e.g. if an effluent is to be discharged into a large river, as little as 20% of process water will be used as the "test" sample).  IP in Pensacola, however, must use 100% effluent for their test because the effluent goes into a wetland environment.

-The exact time it takes for the effluent discharge water, or "sheet flow" to travel from the end of the pipeline at the beginning of IP's 1400 acre wetlands area to the northern portion of Perdido Bay is not known precisely.  While on the tour, I was told by IP personnel it is estimated that it takes between 2- 4 days for this to occur.

Although I don't pretend to be an expert on any of this, because I am not, I did commit a significant amount of time and energy in reading about this issue, researching the history of this problem, meeting with FDEP, county personnel, and now with IP personnel.  My reasoning for doing this is/was to learn as much about the issues surrounding IP's permit process as I can.  I appreciate IP's time and willingness to show me their operations, I appreciate county staff's time and research, I appreciate the citizens that are passionate about the environment (I am too) and I appreciate the personnel from FDEP who met with me and answered my questions on this matter.  

I'll close this post by saying that of course I can be criticized by the PNJ cartoonist, that comes with the territory of being an elected official in Escambia County.  But I'll also say this:  I now know a lot more than the PNJ and Andy Marlette do about this process and the FACTS surrounding this whole evolution----- because I took the time and effort to learn about it firsthand from multiple sources and points of view.  Meanwhile, as PNJ hurls insults at us-- they, themselves-- remain unwilling to take the tour of IP's facilities in order to learn about these issues firsthand. 

I hope people that may disagree with me on this issue at least see this fact.


8 comments:

Mel Pino said...

Thank you for touring the plant and berm area, Commissioner Bergosh. I'm glad that you tried to hold them accountable, but I fear that effort wasn't entirely successful.

1. They wouldn't let you put the information in their glosses public. How strange.

2. They didn't take you to any areas by boat. Does IP not own a boat to manage its berm area?

3. They told you that the Ceriodaphnia dubia is not "indigenous" to the area. What a strange statement.

4. Did they inform you in times past that they used to provide their own photographer to take photos of what people wanted to share? Not sure when that practice fell off.

I hope you'll repoduce the email I sent on the "water flea" today to the BOCC, Ms. Gilley, Natural Resources management, and Ms. Rogers.

I'm looking forward to any corrections from the County scientists on this. I know there's not way I got it all right, but I think I have the gist.

I'll have to post that on a different comment, as it's over the limit for characters.

Best,

Melissa Pino

Mel Pino said...

Part 2 of my comments. I will have to break the email in half.

-----------------

Melissa Pino
4:35 PM (3 hours ago)
to Lumon, Jeff, Robert, District, Janice, Chips, Tim, Brent, Matt, Alison, me

Dear BOCC, Ms. Gilley, Natural Resources Manager, and Ms. Rogers,

Earlier I sent an email on water testing. With this second email I'd like to share my understanding of the water flea, with the goal of trying to better explain my concern--a concern many others share--than I can do with 2 minutes at the podium.

My grasp of this subject is of course not complete, but I hope I have gathered enough knowledge as a lay person to be correct about its importance in the context of IP testing.

**I may make mistakes or lack enough understanding, so I am relying on the scientists copied on this string to make the necessary corrections or additions where my understanding is insufficient. At the very least, I hope this will demonstrate that there are many citizens who are honestly trying to grasp the environmental situation of the IP effluent and berms.

--The "water flea" used for the mandated effluent testing is Ceriodaphnia dubia, of the Clodocera order (small crustaceans). Clodocerans are sensitive to salinity, and are found in freshwater systems all over the world.

--In a healthy ecosystem, clodocerans thrive in the quietwaters of freshwater systems. They should exist in abundance in those freshwaters in and around the effluent source pipe and throughout the berm project and surrounding waters, including 11-Mile Creek.

--The ceriodaphnia dubia is used as a "surrogate" per the effluent testing, much like a white mouse/lab rat.

This should not be confused with the question of whether they are invasive or indigenous. Nonetheless some environmental consultants have argued that "The scientific community has raised concerns regarding the use of a test species that does not inhabit the receiving water under investigation (Chapman, 2000)" ("Toxicological Assessment of Mannville Formation Water," Shore Gold Inc., July 27 2012)

--In the case of the ecosystem within and without IP's berm system, however, Ceriodaphnia dubia "can live in low oxygen conditions typical of wetlands (less than 1 mg/L) and are tolerant of pHs from 6.5 to 8.5" [_Treatment Wetlands_, Kadlec, Robert H. and Knight, CRC press (Boca Raton: 1996)]. Therefore this particular species of Clodocera is considered ideal for testing effluent where treatment wetlands are the receiving area.

--Although some species of clodocera have adapted to marine waters with high salinities, ceriodaphnia dubia is sensitive to it. Therefore, its inability to reproduce in either the IP effluent or the ECUA non-potable waters indicates that their are contaminants and/or nutrient imbalances that are contributing to salinity and ionization levels outside the parameters for the ceriodaphnia to complete its reproductive cycle.

--It therefore stands to reason that this same impact might be occurring in the entire berm area, and in any area that receives overflow from the spillways or any possible seepage from the berms themselves. The impact would not be limited to the ceriodaphnia dubia, which is actually far more tolerant than many other micro-organisms that the ecosystem needs to be able to sustain the food chain.

--I'm not knowledgable about what clodocerans might have been able to adapt to conditions in the quietwaters of the Perdido Bay, other than to note that at least one species has been identified there in times past, the Moinodaphnia macleayi (King, 1853).

[con.]

Mel Pino said...

Part 3 of 3. My email continued.
------------------

I hope I have at least demonstrated why many citizens are extremely concerned about the possibility of DEP awarding IP (and along with them, ECUA) a site-specific exception for their next round of permitting. It is a fact that over multiple years of testing on a clodoceran that the effluent fails to sustain that order of life, and badly. As Barbara Albrecht has stated, any disturbance of that order on the food chain can create a "cascading" effect all the way up the chain.

While I do understand that the County does not have the authority over this, the citizens concerned are merely requesting that of our local elected officials

(1) familiarize themselves with the parameters of the problem;
(2) recognize the potential severity of the issue;
(3) keep an open mind as citizens and scientists voice their concerns;

and

(4) partake in a candid dialogue about how IP--as one of the biggest economic development recipients in our County--can be encouraged to improve this situation to come into compliance with the Clean Water Act, rather than resting content to be in compliance with a DEP consent order.

And, as there seems to exist a very healthy relationship between the BOCC and our delegation in Tallahassee, perhaps the commission can work with those who represent us on a State level to meet this challenge and to resolve it.

Best,

Melissa Pino
413 SE Baublits

Richard Allison said...

Commissioner,
I wrote previously on your FB page but I want to say again I worked mostly in the large integrated steel industry all over the country but mostly in the Birmingham mills for U.S.Steel and Republic Steel. It is not uncommon for companies to not allow photos taken on their private property due to advice of company lawyers. It is for numerous reasons, not necessarily to hide something but sometimes for confidential or proprietary reasons.

Later in my career I worked at R.N.Pyle Mechanical Contractors here in Pensacola as sometimes a night Superintendent or Occupational Health and Safety Supervisor at the Cantonment Plant from 1992-2000. I am retired now so I have no interest in the mill now. I worked around the paper machine on the mechanical portions and on the hoods and ventilation systems above the paper machine. Champion and later IP were very strict on whether we had any environmental or safety issues. If a contractor had a history or more than a couple incidents, they would be thrown off the property forever. I also did work around the two large recovery boilers and power boilers that burn most of the black liquor and other liquid pollutants. The boilers had many environmental controls on discharge into the air. Back then, the Cantonment Plant was recycling almost 98% of pollutants and discharging about 2%. Almost any discharge into the air is either steam or just water vapor from water being evaporated off the paper machine. I agree when the plant was discharging into the creek there were problems with effluent going into Perdido Bay and I lived on the water in Lillian, Alabama at the time, now I live in Escambia District 1. I also agree since I fished the bay that the condition of the bay improved after 2000 and is improving all the time. I hear from people that the mill needs to be closed but much of the damage left in Perdido is from years past and trapped under the sand in the bottom of the bay. I have not kept up with the water quality numbers but I would guess that the water is much cleaner now.

It might be that if IP got it's water from the aquifer, it possibly would not need the permit extensions but I don't think it is to our interests to do so and taking water from ECUA was a win for everyone. It's too bad that IP is not able to take pristine water from ECUA. Too many people are fixated that the IP mill is like it was when water effluent was discharged into the creek and that the problems back then are still occurring. IP has done a wonderful job building on improving water discharge from the old Champion Paper through wetlands.

Page 1
Richard Allison

Richard Allison said...

I would also guess that the paper mill is not the largest polluter of the bay but the residents and farms that fertilize their lawns and crops carry fertilizer residue by rainwater runoff to the bay not to mention illegal septic tanks, especially on the Alabama side. The only way for Perdido to become pristine is for everyone living in the watershed to demolish their homes and move away, which is not a logical answer and closing the mill is also not a logical answer. What puzzles me is that many of the homes that were built around Perdido Bay were built after the paper mill so homebuyers bought homes on a polluted bay when they could have bought elsewhere. It is like moving into a neighborhood and buying a house next to someone that lives in a blighted house and after you move in, you expect them to clean it up. I bet people were glad to move on the bay because of it's beauty and had no problem with the paper mill until someone with nothing to do found a cause to pursue. The people calling for the mills closure need to remember their are hundreds of people that depend on that paycheck from IP to live.

I have eaten crabs, Redfish, Flounder and Mullet in the Bay and I am not afraid to eat anything I catch now. Pensacola is in need of good jobs and IP does that. We need more, not less good paying jobs and God knows we have plenty of low paying jobs from tourism.

What I think is a shame is that I have three daughters and because of the low number of good paying jobs in Pensacola, most people who send their kids to college here have to relocate away from Pensacola after graduation. There are many people that live in Pensacola commute to Mobile to work. In the last twenty years, Mobile lost IP and Kimberly-Clark on the Mobile River that made paper but from losing those plants, Mobile County attracted two state-of-the-art steel mills on Hwy 43. At their old airport they attracted three plants from Airbus that assembles planes and makes parts for their aircraft. Austal Shipbuilding moved to Mobile and currently builds Litterol Combat Ships for the U.S.Navy. Many people don't know there are currently about 25 chemical plants located in a line from Theodore, Alabama to McIntosh while Pensacola sits on the sidelines of industrial jobs. Mobile is awaiting for Amazon and Walmart to build large distribution centers soon.

At one time Pensacola and Mobile were like sister cities but then Mobile just took off and we are not much different other than we have improved our downtown and we did attract Navy Federal and we have International Paper, Ascend Materials, Gulf Power-Crist Plant and military bases. I expect that there will be a noisy minority that will go after Crist Plant but I also worked there too and they have a state-of-the-art coal burning facility that is environmentally responsible and the latest technology. I dread the day the Navy one day closes or further shrinks NAS Pensacola and we will be in trouble. Anyway, we need jobs and we need more middle class jobs that manufacture. If we don't have them in Pensacola, we certainly have the room in rural Escambia County.

Richard Allison

Jeff Bergosh said...

Melissa,

Thanks for that information. I feel like after the last several months of meeting with FDEP, County, and IP staff--along with reading what is being put out on social media--I see what's happening. And I stand by what I have said. If folks like Andy Marlette and PNJ don't like this process--they really need to take their grievances to the US Congress. This is all driven by processes and procedures stemming from Federal Legislation (Clean Water Act) with enforcement delegated to the states. Doing cartoons about us (disingenuous and dishonest ones, I might add) will do nothing to reform these processes. Meanwhile-I believe what I am hearing and seeing and reading. The bay is improving compared to where it was a few decades back. And I believe we will see continued improvement going forward.

Jeff Bergosh said...

Richard Allison-

Thanks for your reasoned and intelligent perspective (that comes from actual experience apparently). I believe you are spot-on with respect to your assessment about the CRITICAL importance of the greater Pensacola area creating GOOD manufacturing jobs to insulate us from the cyclical ups and downs of national and regional economy. Of course our tourism sector and military sectors are both of VITAL importance...but as we see with military mission changes the impacts of changing missions have HUGE positive and negative economic consequences. And we all witnessed the downturn in 2010 when the economy bottomed-out after the BP oil spill. We have continued to work this issue of jobs and industry segment diversity, and ST Engineering is going to significantly increase their footprint at Pensacola's airport and that will be a good thing. I believe we are headed in the right direction with the health of Perdido Bay, and I think closing that mill would be disastrous and unnecessary. They are working hard to dial in their processes (as you alluded to in your post) and I think we will see continued improvements going forward. Thank you for being attenuated to these issues in our community--I think this is great!

Mel Pino said...

Commissioner Bergosh, I very much appreciate your response, but don't see what Andy Marlette has to do with my email about the statement that the water flea isn't indigenous.

My email was to dispute that claim, and to try to underline how important it is that their reproductive cycle goes kaput in IP effluent, which uses ECUA "grey" water. I do very much appreciate that you visited the site, and took the tour. I find it ridiculous, however, that these tours don't include visiting the *entire* berm area by boat. That's not your fault, however, that they don't do that.

Richard Allison, I learned a lot from your posts--thank you.

I want to make clear that I, personally, have never said that "IP needs to be shut down."

What many people would like to see happen is that they simply purchase the technology that would mitigate this situation. It was available 20 years ago. That was the original reason for the consent order, as I understand it. And it was only supposed to be for a few years. Which has turned into 20. My feeling is that if IP is going to be awarded with at least a couple hundred million dollars of EDATES, they could do our community a good turn by purchasing the technology that would reduce the effluent problems to negligible.

You mention that you're not current on the water quality testing. They are failing, and have been failing.

What many of us are concerned about is that they will convince DEP to give them a site specific exemption that simply allows them to keep dumping this problematic effluent due to some sort of reclassification. That's not a solution to the problem for anyone but IP.

Again, thank you for your posts. I am a proponent of smart economic development such as Navy Federal and ST. But if we're going to be successful in our job efforts, it shouldn't come at the expense of our health and the health of our environment. Escambia County is the 11th worst polluted County in the country, and IP is one of the areas biggest polluters. They would instantly become community heroes if they would simply fix the problem, rather than continuing to try to find regulatory workarounds. *That's* the solution I personally am after. I don't want to see those jobs and the economic benefits to go away. I just want the pollution to go away.

Best,

Melissa Pino

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