Comments on the Draft Environmental Impact Statement for the US Department of Homeland Security National Bio and Agro-Defense Facility.
Logic Flaws in Determining the Worst-Case Scenario
The methodology of limiting the study to three pathogens in order to determine the worst-case scenario is invalid for these reasons:
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It presumes that the answer is known in order to determine the answer. While it is plausible that professionals have an intuitive knowledge of “hardest” pathogen to handle, they cannot know the full consequences of the escape of any pathogen in order to determine, a priori, which has the worst consequences. In particular, they cannot know the result a priori for each of the possible sites in order to differentiate the relative merits of the possible sites. For example, Hendra may have worse consequences that Nipah where there is a high population of horses, since the former is transmitted from equines to humans. To say (DEIS Page 3-371) “HV raises no concerns that are not present for the Nipah virus”, ignores the fact that the equine density surrounding the possible sites is markedly different. It is possible, for example, that high equine density around the NC site, compared to Plum Island, combined with the higher risk to humans in contact with equines that Hendra represents could be the determining decision factor in site selection. Yet the issue has not been studied. The EIS is not complete unless the potential effect of each of the pathogens that may be present at the NBAF has been considered in the relation to the specific environmental situation at each possible site.
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The logic of the DEIS is that the worst-case consequence of the release of pathogens from the NBAF is the consequence of the single worst-case pathogen. This logic is flawed. There is no reason to be certain an escape from NBAF would be limited to a single pathogen. On the contrary, there is every reason to believe that an intentional release (by hostile interests) would be a simultaneous release of as many pathogens as possible, particularly if a simultaneous release has not been studied and mitigated against. There is no a prior reason to believe that all consequences of the second and subsequent pathogens would be subsumed in the consequences of the first. While it is only necessary to kill an animal once, even for two pathogens, there is no a prior reason to believe that it would be the same animal that needed to be killed for all pathogens. There is a possibility that some consequences will be additive or worse. Response personal may not be available to handle the response to the second pathogen because they are occupied performing the (different) action required by the first. In the absence of a specification of, and study of, the response plan for each pathogen it is not possible to determine if the actions interact positively or negatively. In the worst case the response actions for one pathogen may be prohibited by the actual or possible presence of a second pathogen. Perhaps hunters would be unable to de-populate deer to control FMD because of actual or perceived personal danger from one of the other pathogens simultaneously released. History shows that many real unmitigated disasters stem from the failure to plan against a combination of factors. The combination of the consequences of all pathogens present at NBAF must be studied and evaluated.
Understatement of the Consequences of the Worst-case Scenario
The DEIS presumes that the worst-case consequences are completely determined and described by a dollar figure for US loses. This omits the consequences on the (unspecified) party that takes the loss, consequences that are not reversible by financial compensation, and the consequences of the actions on the world outside the US.
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Losses borne by “the local county” or local farmers could cause hardships or other consequences that add to the worst-case consequences. For example, it may cause a permanent decrease of the scale of the agriculture industry or the inability of the local county to maintain essential services.
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If, as many might assume but is not stated in the DEIS, the costs a borne by the federal government, which is already massively in deficient, it is likely that the consequences of increasing that deficit would be more than simply an increase the size of the national debt..
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The consequences, even if fully financially compensated for, are not necessarily reversible. The genes of a bloodline wiped out by a de-population response action are gone forever, and cannot be recovered by financial compensation.
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The consequences do not stop at the US border. Most of the consequences noted constitute a decrease in the food supply exported from the US. There is already insufficient food to feed the world’s population. As with the redirection of corn from food to bio-fuel, a reduction in the food exports from the US translates into starvation somewhere in the world. A 2003 Pentagon report documented the causal connection from deprivation and starvation to political and economic de-stabilization, that leads to regional wars and increased terrorism. Thus the worst-case scenario may be spiraling up in terrorism.
Understatement of the Probability of the Worst-Case Scenario
The DEIS significantly understates the probability of a pathogen escape, particularly the intentional simultaneous escape of many or all of the pathogens present. By creating the NBAF on mainland of the US with a “treasure trove” of 50+ of the worst pathogens, the DHS is creating a prime terrorist target, that could be attacked by means that completely bypass the protections presumed in the DEIS. Terrorists have as much time to plan how to defeat the protections as the DHS has to create them. Consider, for example, the consequences of terrorist sympathizers infiltrating the staff that designs, constructs or operates the NBAF. We may, unknowingly, have a bio-containment with a “back-door” or an intentional weakness that terrorists know how to exploit and plan to do so. Personnel who are rigorously trained in the procedure they must follow for safety are implicitly trained in a procedure to follow to create danger. A “sleeper” terrorist sympathizer could become a pilot for American Airlines who could crash a 767 fully fueled for the flight to London into the NBAF just seconds after takeoff from RDU 20 miles away, without the possibility of intervention by passengers or the Air Force.
Such possibilities are easy to conceive – by us and our enemies – but impossible to estimate as probabilities. There is no a priori reason to believe the probability is low or consistent with the DEIS conclusion of a “Moderate” environment effect for biological, sociological or human.health and safety. The justification for the participation of the DHS is based on the likelihood of terrorists using these pathogens, which suggests that if DHS is justified in doing the project at all, the likelihood that terrorists would attack the treasure trove of pathogens should be considered high. The magnitude of the 9/11 disaster was amplified by the failure of the World Trade Center architects to conceive of the form of the attack, particularly as the weapon – a fully-fueled jet airliner of a size that did not exist when the buildings were designed. The buildings’ structure collapsed not because the creators did something wrong but because they did not attempt to defend against a problem they did not think of. To believe that we now know the probability of such an omission is foolish and dangerous.
The two major points above, the magnitude of the consequences and the likelihood of release caused by terrorists have a multiplicative effect on the differentiation between sites, particularly between the Plum Island site and mainland sites. The higher the possible negative consequences of a release, the more likely terrorists are to try to cause that release. Therefore the Plum Island site benefits twice: the consequences of a release are smaller because of the water separation from livestock and wildlife and the cooler climate reducing the transmission by mosquito. Because the consequences are smaller, it is a less enticing target for terrorists, and favorability of the island site over any mainland site increases quadratically.
Omission by pre-condition of potentially better options
Because of this quadratic benefit of island sites, the DHS should re-consider the pre-condition set on site selection that requires NBAF to be in the proximity of people (researchers and other workers), particularly if for some reason the Plum Island site is eliminated. “Proximity to research “ and “proximity to workers” are site variables that should be considered and evaluated along with other variables. Including them as pre-conditions eliminates consideration of more remote islands – which gain from the quadratic benefit described above. There are plenty of examples, from offshore drilling rigs, to the prison camp at Guantanamo Bay that demonstrate the feasibility of moving the resources to the desired location rather than locating where the resources are. There are equally good examples of research collaboration across distant locations, and indeed across the world. There are costs to isolation, but they should be evaluated and compared against the cost, severity and likelihood of the potential disaster scenarios, rather that taken as a predetermine stipulation biased against the security that the DHS was created to attain.
Omission of Environmental Impact of Collateral Development
The NC Consortium argues that the hosting community will benefit (economically) by collateral development, including further development required to fulfill DHS and USDA’s mission, and specifically a FMD vaccine manufacturing plant. Currently any FMD vaccine required in the event of an outbreak in the US would be manufactured in the UK at the plant that is immediately adjacent to the UK’s equivalent of NBAF. The cycle time for shipping the vaccine strain, once identified by NBAF, to the UK and shipping the vaccine back to the US is considered unacceptable, even assuming that the US’s need is the UK’s top priority.
Once the NBAF has been built in the US the argument that an associated vaccine manufacturing plant should be collocated with NBAF will be made and will be undeniable. Therefore for all practical purposes the site decision for NBAF is the same as the decision to site the associated vaccine plant. Therefore the environmental impact of the vaccine plant and all other reasonably predictable collateral development must be included as part of the Environmental Impact Statement for the NBAF.
It makes no sense for the NC Consortium to justify the development and the costs to be borne by the hosting community on the basis of both the NABF and its collateral development, but to balance it against the environmental impact of only the first part of the development.
In particular, the NC Consortium argues that the quantities of pathogens at NBAF are too small to constitute an attractive terrorist target. However the quantities of live vaccine handled by the manufacturing plant are vastly greater, and therefore make the vaccine plant a significantly more attractive terrorist target, and well as a much more likely source of pathogen escape. It is suspected that the FMD escape in the UK came from their vaccine plant and not their NBAF equivalent.
In effect a decision to site NBAF on mainland US is a backdoor method of introducing large quantities of FMD virus into mainland US via a collocated vaccine plant, and therefore the decision to do so should be weighed against the significantly safer alternative of locating both NBAF and the vaccine plant on Plum Island or some even more remote island.
The above comments were submitted to the DHS as part of the Opportunity for Public Comment period for the draft EIS. I wonder if they will actually listen?