Statement from Deputy Superintendent Tom Ulrich

The following was written in April, 2011, by Deputy Superintendent Tom Ulrich in an email to the Chairman of the Northern Michigan Environmental Action Committee (NMEAC). Tom has approved its use here as a statement of the Park’s position on the drift situation.

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. . . You’ll recall . . .  that the MDNRE permit requires the operator at the Homestead to monitor (at least every two hours) and adjust/shut down if drift is occurring – whether they detect it or someone else reports it.

To our knowledge they have done so on several occasions – although we do not know whether and how often drift has occurred without timely corrective action. Last year, we were able to increase the frequency of our inspections, but we hope to implement more consistent monitoring to ensure that drift does not occur – and to determine whether it is happening so regularly that the existing permit requirement is inadequate. It has been our experience that The Homestead operator, Shane Wyatt, is working in good faith to prevent drift, but we need to better determine what level of success he is having . . .

The NPS national offices for water resources and air resources agreed to provide us technical assistance to set up a monitoring protocol/equipment – hopefully something we can afford – but they failed to do so last year. They appear to be marshaling resources to do so for application season this year.

We share your concern about drift taking place, and continue to work with the MDNRE and The Homestead to prevent it. I’m not sure that we agree with Tom’s [Van Zoeren] opinions regarding the significance of the impacts, however. We do not believe that park resources or visitors have been impacted in any significant way by the drift that has occurred to date.

This should only become more true as we continue to reduce the occurrences in the future.

Thanks for your interest!

Tom Ulrich

Deputy Superintendent

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Drifters’ Response

We thank Tom U. for commenting on this issue, and for contributing to the discussion on this website! Following are a few response notes by TVZ:

–Regarding the every-two-hour monitoring checks that The Homestead is now required to make–This is an improvement; however, the spray fields extend over a large area, in two separate locations. Winds off Lake Michigan are erratic and gusty. Note that illegal drift was found both the times the area was checked by others that year  when the wind was blowing above 6 mph—suggesting that the monitoring program is not resolving the problem.

–Concerning the note that that The Homestead operator appears to be “working in good faith to prevent drift”–Yes, Shane seems quite capable and to be working in good faith. Unfortunately, he has been put in an impossible situation. “Good faith” is not enough here. In many things we only ask that people make a “good faith effort” and achieve “reasonable” success. However, we have to remember that here, The Homestead has no entitlement to this park land. They were advised before they built the system that they would be required to meet a “No Drift”  standard so it would not compromise surrounding park lands. It was suggested that they pursue alternatives other than spray. They chose to use spray; now they need to make it work to that standard. A good-faith effort by the field-level operator is not enough. So long as surrounding park lands are even occasionally unfit for entry and inhalation of the air, they must remain posted, and of no benefit to the owners—constituting illegal “nuisance conditions”.

–Regarding the statement that “We do not believe that park resources or visitors have been impacted in any significant way by the drift that has occurred to date”—We feel differently.

Note that in 2005, when the current system was being planned, Park Management wrote, “the need to contain drift within the easement is critical.” In 2006, Superintendent Shultz wrote, “Our goals in the area of the easements are to protect park resources as well as the safety of our visitors. Our primary concern remains the potential for sprayed effluent to travel outside the boundaries of the easement, which would jeopardize the health of both resources and visitors.” After the system was rebuilt, the NPS regional public health specialist inspected the site with the Chief Ranger and reported, “Spray mist was observed drifting (approximately 30 to 50 yards) into the wooded areas near parcel C. It was also evident that spray from the irrigation fields had killed some adjacent trees and also provided enough moisture and nutrients to grow plants [mostly invasive aliens] outside of the fenced areas.” After completing his study of the matter, he concluded that gas masks, goggles, and exposure suits should be required whenever there is a possibility that rangers could be exposed to drift while in that area. Blowing mist has been observed many times again since then. Surrounding park area has had to remain posted, depriving the public of its use. More area has been exposed, subjecting park users to the hazard.

Note that if people have been affected by exposure to drift on surrounding park land, the cause will likely never be known. One can really only conjecture that no one has been impacted in this way.

–Final Note: Regardless of how much park resources and visitors may have been or not been impacted to date–the important thing is that all are in agreement that there should be no drifting sewage spray in the air of Sleeping Bear. We appreciate the efforts that the Park Service has begun to make, and look forward to working together until this affront to our treasured National Lakeshore is completely resolved.