“One Voice” government team tells Madison alders how to engage public on PFAS (The MLK Jr. Madison would prefer we forget, Part III)
The mission of the Common Council President’s Work Group on Environmental Justice (EJ Work Group) created in 2021 is to “provide policy recommendations to the council on how to mitigate the impacts of PFAS and F-35s on existing and future developments and to create a PFAS outreach strategy and a plan for the City’s role in addressing these environmental issues.”
In their first several meetings, the group listened to a parade of city attorneys and planners as they explored options for restricting housing developments near the F-35 flight path. These discussions and their unfortunate outcome—which give the go-ahead for low-income housing to proceed near the F-35 flight path—are described by Olivia Williams at Tone Madison.[1]
The EJ Work Group then shifted its focus to PFAS. As I described in the last post, alders didn’t invite community members affected by PFAS, subsistence anglers, and/or community advocates to share their grounded knowledge, research, and experiences to help inform their recommendations.
Instead, they invited managers and staff from city and county agencies (the Madison Water Utility, Public Health Madison Dane County, City Engineering) to frame the city’s PFAS issues for them and based on this, propose public education and outreach strategies.
How is this upside-down, anti-EJ approach playing out?
As expected, in their presentations to the EJ Work Group, city and county government agencies downplayed PFAS levels in our drinking water and touted their actions to address PFAS pollution. Given that the city and county are themselves responsible for some of the PFAS seeping into our drinking water, lakes and fish–and have protected corporate and military PFAS polluters here for decades–this is not particularly surprising. They are protecting themselves and avoiding responsibilities and liabilities. Same as always.
This government-led approach is public relations, not environmental justice.
The more troubling part is that many alders in the group—apparently believing that their roles as elected officials are to assist city staff and follow their directives—are tripping over each other to commend and applaud their efforts, with few to no critiques or questions.
In the first work group meeting focused on PFAS, on November 30, 2021, Madison Water Utility General Manager Krishna Kumar gave a presentation on PFAS in Madison’s drinking water wells. He provided misleading and incorrect information. Among other things, he gushed about how the Water Utility’s aggressive well testing in the last few years provided critical data for DNR—when in fact, community advocacy led to more comprehensive testing. (After reading my post about what really happened, Kumar corrected some of this misinformation, albeit in a general and token way).
But the most important message Kumar relayed to the work group—the same message reported to the Wisconsin State Journal in December—is that the PFAS levels in Madison’s drinking water wells (with the exception of Well 15) are perfectly fine, no problem. As Marcus Pearson, the MWU’s new “Public Information Officer,” told the State Journal, “our water is undeniably safe to drink.”
So somehow, PFAS levels that were a big deal from 2018-2020 (see here and here) are now “undeniably safe?” Did the PFAS magically go away? No. This is a misleading and disingenuous claim for a number of reasons (described here; see also Appendices 1 & 2).
Alders, having no clue of the long history of this issue, nor enough knowledge to engage with the Water Utility’s claims, said nothing.
Many agencies—“One Voice”
At the next meeting on January 10, 2022, John Hausbeck from Public Health Madison Dane County (PHMDC) described plans for informing and engaging the community about PFAS. Chair Grant Foster asked city staff about ways agencies could coordinate PFAS work and compile PFAS information for the public in one place.
Following from this, in the next three weeks, managers and staff from several government agencies collectively developed a draft “Guide to PFAS in Madison” that they presented at the January 31 meeting. (This draft guide was the focus of most of the discussion at the meeting, but meeting minutes–which don’t actually include any minutes–do not include a link to the draft guide. This is problematic, especially for a work group focused on public engagement…)
Mayoral Aide Christy Baumel and several agency officials stressed repeatedly, and proudly, that their “Guide” reflects “one voice” of the Water Utility, PHMDC, City Engineering, and the Department of Civil Rights. (Several other agencies—Dane County, Madison Metropolitan Sewerage District, the Air National Guard, and Department of Natural Resources—were also presumably consulted in developing the guide).
Having “one voice” was clearly something city and county agencies had agreed would be their central approach to public education and engagement.
“PFAS mitigation can only be effective,” the Water Utility’s PIO Marcus Pearson said, “if we have the community’s trust and buy in, only earned by keeping them informed and engaged in a transparent and inclusive fashion…What we want to have is one voice. We know that works best for the community, particularly the under-represented members of our community, they can’t be uninformed or misinformed, or have duplicative information or contradictory messaging, things like that. So we really just want to have one voice, and that’s really where all this collaboration stems from.”[2]
The Water Utility and Public Health “communication team,” he said, would use the “one voice” guide and also develop a larger “one voice” communication strategy. “We want to all be in one place, along the lines of the one voice.”
What will the “One Voice” say? Who will it speak to?
Government agencies and departments commonly coordinate communication strategies in attempt to relay consistent messages to the public—and this approach is nothing new here in regards to PFAS. In March 2019, the city, county and state held a multi-agency meeting where they relayed the same familiar message: Well 15 water is perfectly safe (even though it was shut down due to concerning PFAS levels).
It’s also no secret that the city, county, and military have been meeting behind closed doors for several years to discuss the egregious PFAS contamination at the airport, burn pits, military base and the rest of Truax Field (all owned by Dane County). This team, which includes some of the members in the recently formed “One Voice” PFAS team, also undoubtedly discusses what to tell—and more importantly, not tell– the public about the poison PFAS debacle at Truax Field, which they all share responsibilities for.
Though not a surprisingly novel development—just the same old top-down approach–the new multi-agency “One Voice” PFAS communications team raises some new questions:
1. What will the One Voice say? 2. Who will the One Voice speak to? 3. What will the One Voice NOT say, and who will it NOT speak to?
What will the One Voice say?
It’s very clear that the most critical and central mantra of the One Voice will be 1) PFAS levels in Madison’s drinking water are not of concern (well, except for Well 15, which is being addressed, so nothing to see there folks!!).
The other two core messages are: 2) All relevant government agencies are diligently taking actions to address the PFAS problems. So, no worries there either! 3) What can people do? Avoid consumer products with PFAS and follow fish advisories. In other words, individual behavioral choices are the most important ways to reduce exposures.
Hmmm. So what’s problematic about these messages?
One Voice message #1: PFAS levels in Madison’s drinking water are not of concern
Again, this One Voice message was unequivocal. Everyone agreed that it should be the top talking point.
That said, it was evident in discussions on January 31 that internally, the One Voice is not actually One Voice on what precise verbiage to use to assure the public that the drinking water is fine, nothing to worry about.
After Chair Foster stressed that the question “Is my drinking water safe?” should be at the front end of all written and online messaging from the One Voice,” an awkward discussion ensued that raises questions about the purity of the One Voice.
Presumably the Water Utility General Manager Krishna Kumar would like to tell people that “our water is undeniably safe to drink,” as he directed his PIO to say to the State Journal in December, and repeated again in EJ Work Group meetings in January.
On January 31,st Kumar also stressed that he wants a simple message for “average residents.” “We need to agree what the messaging should be,” he said. “We can say there is PFAS in the water…below standards. But is it safe to drink? Or not safe to drink? Cleaning up that message is key. We can debate the technical accuracy of such a statement, but the average resident wants a clean, simple answer.”
Water Utility PIO Pearson (whose job is to tell the public whatever Kumar directs him to) agreed. “I’m with you on that,” he responded. But he qualified it further. “This is when it gets “political” (with air quotes) so to speak. I’m new to the city and the politics, but…the first line on our PFAS webpage now is “Madison’s water meets all federal and state standards for drinking water, before we get into anything. Again, why I say it’s political is we did want to say hey, our drinking water is safe, we’ve seen it, we were researching and looking at other Water Utilities across the country, and some of their outreach materials just state outright, front and center, our drinking water is safe, you can trust our drinking water. And I know that there were discussions, I’m not trying to call anyone out or anything, or casting aspersions, but I know there were talks about why that may not be OK to say. But I’m all for it, with you, to just say “our drinking water is safe. That’s the one thing people want to know, is it safe, yes it is. But that gets hairy…” [3]
Alder Foster agreed with Pearson. “Yeah, it does get hairy,” and suggested that some audiences might not find simple assurances of “safety” satisfying. “I think one way to walk that line is to acknowledge on the front end that everybody has different risk tolerances and there’s still plenty we don’t know about it…” Still, he advised that they address the safety question “head on, even if the answer is qualified…”
Other alders were silent.
Disagreements aside about what specific “safety” verbiage should be used and how it should be qualified—none of the alders seemed particularly concerned about the accuracy of the statement.
Yet as explained in previous posts—see here and here: 1) a growing body of science is showing that levels far lower than those in many Madison wells can cause health problems (based on this science, EPA recently said protective levels for some PFAS should be “near zero”); 2) Vulnerable groups—pregnant women, fetuses, infants, etc—are particularly at risk to much lower levels; 3) For people exposed to a lot of PFAS from fish and/or consumer products, the existing PFAS standards may not be protective. Appendices 1 and 2 below elaborate further on these issues.
We’ve said all of this before—on posts and in comments to the Water Utility Board. But these alders don’t know this history, don’t read MEJO posts, and based on the discussions so far in the EJ work group meetings, aren’t willing to directly challenge the One Voice.
One Voice message #2: All relevant government agencies are diligently taking actions to address the PFAS problems
A significant amount of space on the draft One Voice “Guide to PFAS in Madison” was outlining the actions the city, Water Utility, Dane County, Air National Guard, the Metropolitan Sewerage District—and even the DNR!—are doing about PFAS here.
Here’s what the sections on that look like:
The One Voice team also obviously went to other agencies—Dane County Regional Airport, the Madison Metropolitan Sewerage District, the DNR, and the Air National Guard—to gather their talking points to include in the One Voice brochure.
Community activists know that many of the highlighted actions to address PFAS by city, county, and the military–such as “PFAS contaminated soil/groundwater is handled safely during the on-going Air National Guard (ANG) base construction upgrades”–are at best unsubstantiated, and at worst, false.
Moreover, several of the highlighted actions (such as DNR’s testing of water and fish in Starkweather Creek) were only prompted after years of difficult advocacy by the community.
Perhaps most problematically, many actions that we, other activists, and the community have been asking the city, county, MMSD, DNR and/or military to do for years–such as testing Starkweather Creek sediments, testing farmfields were MMSD’s PFAS-laden sludge has been spread, and many more–have never been done (or if they have the results aren’t public).
One Voice message #3: What can people do? Avoid consumer products with PFAS, follow fish advisories (change individual behaviors)
The One Voice team will assure the community that PFAS in drinking water is not a problem, so people should be more concerned about their exposures via consumer products and/or fish.
In other words, the One Voice government isn’t responsible for preventing your PFAS exposures—you are!!
“The good news for our community,” Hausbeck explained at the January 10 meeting, “is that currently the testing done by WU is suggesting that drinking water isn’t a main exposure source, so really our focus is on the fish consumption side of things, and quite honestly maybe even looking at informing people of the other consumer products in their lives that have PFAS and maybe those might be a way to reduce exposures.” So, he said, “our objective is to bring in other sources—consumer products, as well as where we currently stand with drinking water as a potential source.”
The suggestion that consumer products are more important sources of PFAS exposures than drinking water is over-simplified and scientifically incorrect. According to the Agency for Toxic Substances & Disease Registry (ATSDR): “Research has suggested that exposure to PFOA and PFOS from today’s consumer products is usually low, especially when compared to exposures to contaminated drinking water.”
Exposures to PFAS in drinking water, even below existing standards, can add up over time. The Interstate Technology Regulatory Council (ITRC), a leading scientific organization providing current summaries on the state of PFAS science, stated that: “Long-term ingestion of low levels of PFAS (including those below health values) in drinking water may result in exposures substantially higher than in the general population not consuming contaminated drinking water.”
Exposures should be considered together, not one by one. Drinking water is essential to live, people have no choice but to be “exposed to it” (drink it) many times daily. If PFAS is in the water, it can’t be avoided unless people filter their water or purchase alternate drinking water sources (which requires awareness of the PFAS and enough money to do purchase alternatives). Given this, drinking water PFAS exposures should be even lower for people exposed to many consumer products with PFAS in them and/or PFAS-contaminated fish.
Also, obviously, bottle-fed and breast-fed infants are generally not exposed to PFAS in consumer products. Most importantly, they take in much more water per body weight than adults–and with it, any contaminants in the water. In other words, their PFAS exposures are likely to be much higher than adult exposures. See Appendix 2 for a more detailed explanation.
“One Voice” consumer product PR is from “One Voice” municipal lobbying groups
This focus on consumer products is not new. “Before responding to your specific recommendations,” Mayor Rhodes-Conway opened up her letter to Sustainable Madison Committee in May 2021, “I want to ensure we are all starting with the same information. A significant but unquantified source of PFAS in Madison is from consumer products (such as carpet, non-stick cookware, waterproof clothing, and food packaging) that are purchased, used, and disposed of by residents. This is an international problem that requires national and international solutions, including action by consumers.”
This bizarre consumer product focus is not the creative brainchild of Madison’s One Voice. In fact, it comes from a bigger PR “One Voice”–the city’s lobbying group, the League of Wisconsin Municipalities “Municipal Water Coalition on PFAS.” This Coalition includes the League of Wisconsin Municipalities, Wisconsin Rural Water Association, Municipal Environmental Group – Wastewater Division, the Municipal Environmental Group – Water Division (which the Madison Water Utility is part of), and the Wisconsin Section of the American Water Works Association, “an alliance of groups representing municipal water and wastewater utilities.”
The Municipal Water Coalition website says clearly that one of the Coalition’s goals is: “To educate the public about the background presence of PFAS in our homes and environment from common household products and make clear that drinking water systems and wastewater treatment facilities are not producers or users of PFAS, but only recipients of the compounds.”
This claim is particularly disingenuous PR, since drinking water and waste water utilities are charged by law to remove many toxic chemicals from water they provide to our taps and/or discharge to waterways, no matter who created and used the chemicals in the first place. As ratepayers, we pay them to do this. Given this, complaining about being “recipients of the compounds” and blaming “producers and users” (particularly individual consumers), is a bit ridiculous.
Individual consumers should take actions, change consumption behaviors
The draft One Voice PFAS brochure includes a very short section titled “What actions can I take?” followed by DNR advice on fish consumption. Here’s what it said as of January 31:
Advising fish consumers, especially subsistence anglers, to follow DNR fish advisories, is a good recommended action, albeit fraught with cultural and political challenges and complications (MEJO was founded to work on this issue–I could write a book about it; see Appendix 3).
As for consumer products–there is nothing wrong in itself with teaching people about consumer products containing PFAS. People should learn about the plethora of consumer products with PFAS in them, why and how they should avoid them to reduce their exposures and lessen levels that eventually make their way into the environment.
But is this really local government agencies’ role? Numerous environmental groups, such as the Environmental Working Group, have published excellent information about PFAS in consumer products and how to avoid them.
The more fundamental problem with this is that the focus on consumer products is a deflection of local agencies’ own responsibilities to regulate and control PFAS spewing into our drinking water, lakes, air and fish. This is their job–not public education about toxic consumer products.
Just as problematically, while highlighting PFAS in consumer products, the state municipal lobbying group has been advocating against the Wisconsin DNR’s efforts to develop more protective PFAS standards for groundwater, drinking water, and other media. Why? It will cost too much to meet them.
Rhodes-Conway’s May 2021 letter to the Sustainable Madison Committee, in line with this, deflected responsibility for PFAS at sites the city shares responsibility for, and also said (incorrectly) that this contamination is only “historic”—she wrote: “The PFAS contamination of the Airport, National Guard Base, Starkweather Creek, and the lakes, however, largely stems from the historic use of PFAS-containing firefighting foams. Even if we are able to mitigate this contamination, we will not be able to mitigate the background contamination from consumer products” (highlights added).[4]
Laughably, her language seems to suggest that PFAS from consumer products is somehow contaminating Starkweather Creek (are people throwing their pizza boxes into the creek?).
Relatedly, the draft One Voice brochure visuals don’t depict known PFAS sources that the city and county have significant responsibilities for—the fire training “burn pits,” the Truax Landfill, and former Burke sewage plant (all county-owned). The graphic seems to indicate that all of the PFAS comes from the military base, even though some of the highest PFAS levels to date have been found at the Darwin burn pit directly next to the creek on the airport land–which the city and county both used extensively for several decades. It’s hard to believe that this was an accidental oversight. Here’s what the map in the One Voice brochure looks like:
Who will the One Voice talk to??
Who is the One Voice communication strategy designed for? Who will the One Voice talk to?
The One Voice messages, Krishna Kumar indicated earlier in the meeting, are for “average citizens” who want “clear, simple answers.” (Who is an “average citizen” in Madison?) Marcus Pearson said the One Voice would work “best” for “underrepresented groups” who have often been “uninformed and misinformed and left to deal with consequences of decisions we make.” (What does “misinformed” mean in this context?) The fish consumption advice on the brochure indicates that the messages are also for subsistence anglers–those who eat their catch, usually low income and often people of color.
Apparently the One Voice messages are for also for anyone with the city who communicates with the public, and the media–and even elected officials!
PHMDC’s Hausbeck gushed about how “extremely pleased” and “incredibly excited”—he is about the communication materials and strategies developed by One Voice team, with help from a specialist with the Dane County extension office who was present (according to the minutes), but silent at the meeting.
In particular, Hausbeck was thrilled about the “message map” the team is creating based on the One Voice brochure. This message map, he said, would “provide information that can be shared in these public meetings to help give a foundation for individuals that may not be PFAS subject matter experts.” Presumably speaking to alders, he said, “if you find yourself in a position where you’re being asked a question…hopefully this message map will help to focus the communications” and provide a “consistent message.”
The One Voice “message map” will presumably be developed based on the “goals and objectives” and then be embedded into the “PFAS Community Outreach & Engagement Strategy,” depicted below. The intent is that the messages will be used with all audiences—neighborhood groups, media, alders, etc.
Alders, particularly Chair Foster, gushed with enthusiasm for the coordinated One Voice strategy. Foster recommended that all agencies host the One Voice brochure content. Pearson said this was the plan. “We want to be One Voice,” Pearson assured him, “we want the alders to be disseminating the same message that we are, as Public Health is, as they are. And at the top of the page, for every agency page should start with the same verbiage…and basically have the same consistent messaging at the front end.”
Mayoral aide Christy Baumel agreed that the goal is to “empower staff to represent all ranges of issues”—or in other words, to all be empowered to speak in the One Voice.
In line with this, the One Voice core messages will be hosted on the city website, even though Pearson at the Water Utility seems to be taking the lead on developing core brochure materials and will apparently be leading a lot of community outreach. “We want the city website to overshadow ours,” he said.
The One Voice will try to “meet people where they’re at”? Hmmm….
At the January 10 work group meeting, Kristi Kumar, Equity and Social Justice Manager from the Department of Civil Rights, shared wise advice with the group on engaging people.
She said often when engaging with communities “that have been harmed and are struggling,” we go in with agendas that don’t acknowledge these past harms. “We don’t have time for ‘can you tell us how this has impacted you and your family’ on the agenda,” she explained. She stressed the importance of giving community members “a chance to talk about how these systems have affected them” and suggested starting meetings “with acknowledgement and seeing what’s offered” first before going forward with an agenda.
In line with this, the main gist of her advice was “listen first” and “meet people where they are.”
Based on MEJO’s decades of work engaging diverse people in the community on toxic pollution issues, my family’s first-hand experiences with toxic pollution exposures, and my years of academic research and writing on citizen engagement, Kristi Kumar’s advice is wise and critical. I agree.
This message was incorporated into the the outreach approach. The One Voice team and alders seemed to take this advice to heart, repeating it several times during the meeting. This is good.
However, following this advice will raise some challenging paradoxes for the One Voice PR approach, which by definition does not start with listening to people, hearing their stories and experiences. It already has a clear agenda of quelling people’s concerns–which is not hearing and validating them. It is smug in touting its past and current actions to address PFAS problems here, and then places further responsibilities to avoid exposures on individuals themselves.
Also, diverse community members out there, from a variety of backgrounds and cultures, are not all in the same place and have not all had the same experiences. Will they all be down with the One Voice’s messages? What if they disagree with them? What if they have questions the One Voice can’t answer? What if they are angry at the One Voice, based on past experiences and harms done to them?
Hausbeck’s comments suggest that someone (perhaps Kristi Kumar) may have warned him of this potential problem. After he described how the “message map” would provide handy “consistent messages” for any and all communicators, he admitted that “]t]here will always be the questions that we get from listening first that maybe we’re not ready to answer yet, that we don’t have an answer for…”
Some alders recognized that audiences might not all be in the same place. Alder Foster suggested that there would be “two primary groups for this messaging”—people that already “have questions and concerns regarding PFAS and would want more info to understand the relative risks” and others, like people who fish, who “might not know anything about it” and should be informed of the risks.
Alder Benford questioned how the One Voice message would be received by shoreline anglers such as his Milwaukee family members who have challenging, stressful lives and come to Madison to fish as a respite of sorts. He envisioned someone approaching his “uncle Herbert, smoking Kools” while fishing at Monona Terrace. He predicted that upon hearing that he shouldn’t eat certain fish, his uncle would likely think “Tell me something else, ruin my world even more…”
Based on my experiences talking with countless shoreline anglers in Madison over the last 24 years, Benford is right–many anglers of color go to Monona Terrace and other Madison shoreline locations to catch fish for food, and also for a break from stressful lives in Milwaukee, Racine, Beloit, etc. Many do not want to hear about the pollution while enjoying something they love; some want someone to do something about the pollution rather than being told they should change what they are doing. See more in Appendix 3.[5]
What is the One Voice NOT saying? Who is the One Voice trying to counter?
It’s good that alders understand that the One Voice might not work with all audiences. But a few important questions were not asked, and obvious problems not anticipated.
First and foremost, the One Voice appears to be designed to speak primarily to “innocent” or naïve audiences—in other words, people who know little or nothing about PFAS already or what agencies have done (or not done) about it.
Yet these alders know very well that—as Alder Tag Evers said on January 10—there are community advocates here (MEJO, Safe Skies Clean Water, and several others) as well as many individuals who know quite a lot about PFAS in our drinking water, creeks, lakes, and fish, and know what government agencies have been doing (and not doing) about it. There are many highly educated people in this community. For years, MEJO and other advocates have been demanding that government agencies who are part of the One Voice do more to protect people and the environment from PFAS and other toxic chemical exposures (mostly to no avail).
The One Voice outreach strategy is obviously not designed for these audiences. The One Voice team clearly does not want to engage with activists. In fact, it appears to be designed to counteract us and our messages, to assure naïve people here or “average citizens” (who the One Voice team expects to know little or nothing about PFAS?) that everything is A-OK—to bolster these average people against the information they might hear from experienced community activists.
It’s not surprising. This is the expected government PR. It is designed to protect these government agencies—all involved in the One Voice team—and to counter any critics in the community.
But what will the One Voice team do when it encounters people who have heard alternatives to the One Voice information from community advocates or elsewhere—such as the national Environmental Working Group’s analysis of Madison’s drinking water, which isn’t particularly rosy?
Moreover, once people learn about PFAS problems, and how they and their families are affected, some people will be interested in learning about more than just how to change their own consumption habits. Some will, understandably, want responsible parties—the One Voice—to do something about the PFAS spewing into their community, Starkweather Creek, the lakes, and the fish. Some might even want to have a voice in the matter.
For example, these women at Darbo Worthington (in photo below), recently interviewed by Isaac Wasserman for Wisconsin Watch, clearly want the government to do something, as the title of the article attests: “‘Something has to be done’ about Starkweather Creek, one of Wisconsin’s most polluted waterways”–Wisconsin Watch
Caption from Wisconsin Watch: “Melody Homesly, left, and Carnetta Galvin stand on a bridge that crosses Starkweather Creek near Galvin’s home of 16 years in the Darbo-Worthington neighborhood of Madison, Wis. Galvin says she was not initially aware that the creek contained high levels of PFAS, the group of hazardous, human-made chemicals that are drawing concerns across Wisconsin. “I feel disappointed and sad about not knowing what is affecting our health,” Galvin says. Homesly, Galvin’s longtime friend, says government leaders and those responsible for the pollution should clean it up. “Treat it like they would treat it if it was in their neighborhood and in their family and their kids’ health,” Homesly says. “Since it is right around poor and low-income —they are just sweeping it under the rug. Something has to be done immediately.” Photo taken on Aug. 3, 2021. Isaac Wasserman / Wisconsin Watch”
As far as we could tell (we couldn’t see the whole brochure), the One Voice guide says nothing about how Melody and Carnetta, and other Darbo-Worthingon residents can engage further in public discussions and decisions about PFAS, or even who to contact to express their views. Perhaps the One Voice communicators will tell these women and their neighbors to avoid Teflon pans and McDonald’s food wrapped in PFAS? To avoid pizza in PFAS-coated boxes?
The One Voice wants to impress upon its audiences that all relevant government agencies are doing everything possible to clean up Starkweather Creek. Will Melody and Carnetta believe these assurances?
And what about the low income families who drank PFAS-contaminated water from Well 15 for decades –until community advocacy pushed government agencies to do more extensive testing, which finally shut the well down? What contaminant levels are in their tapwater now–coming from a changing combination of several Madison wells, with varying levels of PFAS and other contaminants? Has anyone tested these levels and informed them of the results?
What will the One Voice say to the group of teens from Truax/East Madison Community Center who worked with MEJO to gather Starkweather Creek sediment data because the city, county, and military refused to do so after we asked for years? And then the teens and their PFAS results were ignored?
These teens and their families, Melody and Carnetta, and others in the Truax and Darbo-Worthington neighborhoods might want to know: What impacts have these PFAS exposures had on their health? (Alder Charles Myadze asked this question in one of the EJ Work Group meetings, but was ignored).
Is the One Voice prepared for these audiences? For their anger and frustration, their questions? Before rolling out their key messages, will the One Voice acknowledge (as Equity & Social Justice Manager Kristi Kumar advised) the harms from the toxic pollution that communities like Darbo and Truax have already experienced due to government agencies’ lack of actions, and because they didn’t hold polluters accountable for the last several decades? What explanations will the One Voice give for their inaction?
Even if the One Voice does acknowledge these harms (and it’s very hard to envision them doing so), how will its risk denial messages then be received by those harmed? Will they trust the One Voice?
Here’s what that might look like:
What about many voices? Diverse public deliberation & engagement?
As Krishna Kumar and Marcus Pearson recognized at the January 31 meeting, Madison’s PFAS situation is fraught with complexities and uncertainties. The science and analytical methods are also changing rapidly. Given this, there is no one simple way to communicate with and engage the public–and there is no one clear solution to address the PFAS pollution.
But instead of encouraging engagement and decisionmaking processes that embrace uncertanties by bringing in diverse multiple voices and perspectives, publicly discussing/debating multiple solutions, the government team is proposing the opposite: The One Voice.
Why? Again, whether they will admit it or not, the goals of these agencies are to downplay risks, protect themselves and avoid responsibilities/liabilities. They are also protecting each other. In this context, they want to take coordinated, multi-agency control over the public relations and provide consistent messaging in line with these goals. Inter-agency debates about what public messaging should include and how to best engage the public are happening–but mostly behind closed doors.
What might a more democratic process look like? What might government agencies do to address PFAS here?
In 2019, after working with the Truax and Darbo neighborhoods for two years on Starkweather Creek issues, MEJO wrote an extensive report outlining what we learned from these communities, and our recommendations on what could be done to engage people there and address pollution in the creek. The report was dismissed–and then completely ignored–by government agencies here.
Community members and advocates have also been asking for a meaningful place at the table in PFAS decisionmaking since 2018. In 2019, MEJO proposed that the city create a community-based PFAS Task Force– a public process in which community members and activists could have a place at the table, alongside alders and government agencies, in discussing PFAS pollution and possible solutions to protect the community.
We worked with Alders David Ahrens and Marsha Rummel over many months to draft a city resolution to create the PFAS Task Force.
Why didn’t it happen? Read about its sad demise here. With active community support, four city/county committees unanimously approved it, but then alders on the Common Council Executive Committee killed it. Regardless of publicly stated reasons for its demise, the deeper reason it failed is that government agencies and other powers-that-be don’t really want input from affected citizens—and they certainly don’t want them to be able to actually engage in decisions about PFAS here (at least not in ways that could have real impacts). It was clear that they would rather make decisions from the top-down, on their terms, and as much as possible, behind closed doors–for reasons we have repeated ad nauseam above.
Obviously things have not changed. In April 2021, in a letter to Mayor Rhodes-Conway, the Sustainable Madison Committee (made up mostly of volunteer citizens) demanded more engagement with local communities affected by PFAS—and asked specifically that the PFAS Task Force be revived. Again, in May 2021, the Mayor dismissed this recommendation.
She did agree with their recommendation that the city find ways to inform the community on PFAS issues. In 2021, the city and county carved out $50,000 from American Rescue Plan Act (ARPA) funds for Public Health Madison Dane County (a city-county agency) for this.
Allotting $50,000 over one year for these extremely challenging and complex engagement processes (which should be ongoing, not just one year) shows clearly what a low priority this is for the city and county. This funding is .03% of the the city and county’s $156 million ARPA funds.
Would the city and/or county even have allotted this laughably token sum if the ARPA money wasn’t available? If the Sustainable Madison Committee hadn’t demanded more engagement?
How much outreach and engagement can the One Voice do with this pathetically tiny amount of funding? Is all the talking at the EJ Work Group meetings anything more than lip service? How much community outreach and engagement on PFAS will the One Voice actually do?
Based on decades of experience here, our guess is–very little. As sad as this is to say, maybe this is a good thing?
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Appendix 1: Just because PFAS levels are below standards doesn’t mean they pose no risks
Recently, according to DNR, the EPA admitted that the levels at which PFAS can cause harm are “near zero.”
At the December 8, 2021 Natural Resources Board meeting Darsi Foss, the agency’s Administrator of Environmental Management” said this: “Just last month, EPA transmitted to the National Science Advisory Board information on the health effects of PFOA and PFOS, and noted two things. First, that these studies indicate that the level at which negative health effects could occur are much lower than EPA previously understood, including near zero for certain health effects, especially PFOA, which they suspect is a carcinogen. Previous studies have shown that exposures to PFOA and PFOS may lead to reduced vaccine response, particularly in children.”
This is far from brand-new scientific information. Internationally-renowned scientists who study the toxicology of PFAS compounds have argued for years that levels much lower than the proposed DHS/DNR standards can cause serious health problems, especially in vulnerable people–pregnant women, fetuses, infants, young children, elderly, and those with existing health problems. Also, PFAS can cross over the placental barrier into fetuses, and infants ingest far more water (and any PFAS in it) per body weight than adults, so protective limits for pregnant women and infants need to make adjustments for that.
MEJO cited some of this science in comments to the Water Utility Board in early 2019, almost three years ago–in part, to counter arguments by Water Utility Technical Advisory Committee members that the Utility should “wait for EPA” to come up with standards (and in the meantime should follow the 70 ppt standard).
The science showing serious health effects from PFOS and PFOA at levels well under 20 ppt has been out there for years. In 2018 Professor of Environmental Health at Harvard University, Dr. Philippe Grandjean, reported that a safe level of PFAS in drinking water would be 1 ppt. This was informed in part by a 2013 study showing that PFAS exposures diminished immune responses in children, along with other research. As Grandjean aptly notes: “The existing research on PFOS and PFOA clearly shows that, with time, these chemicals are much more toxic than we originally thought.”
Other top scientists have proposed even lower levels. In 2019, Dr. Linda Birnbaum, former director of the National Institute for Environmental Health Sciences, told Sharon Lerner with the Intercept that based on recent studies, the standard for PFOA alone should be as low as 0.1 ppt, based on its association with pancreatic cancer.
Appendix 2: Discounting drinking water PFAS exposures is scientifically inaccurate and does not protect public health
As discussed above, dismissing drinking water PFAS exposures as irrelevant compared to consumer product exposures is a well-worn PR talking point offered by water and municipal lobbying groups to defect responsibility away from utilities.
It is another familiar argument from PHMDC and the Water Utility. It also scientifically incorrect. According to the Agency for Toxic Substances & Disease Registry (ATSDR): “Research has suggested that exposure to PFOA and PFOS from today’s consumer products is usually low, especially when compared to exposures to contaminated drinking water.”
In 2019, in an effort to downplay the seriousness of the PFAS in Well 15 and other Madison wells, PHMDC and the Water Utility repeatedly publicly claimed that only 20% of people’s PFAS exposures comes from drinking water. Where did this number come from? Apparently, PHMDC health experts misinterpreted exposure assessment assumptions used by federal agencies. The 20% estimate of the contribution of drinking water versus other sources (called the “relative source contribution”) is a default assumption used in federal risk assessment formulas to ensure that an individual’s total exposures don’t exceed the reference dose and calculate protective health advisory levels.
This number was not meant to be used as a PR strategy to allay public concerns about risks from PFAS-contaminated drinking water. Moreover, the argument that Madison’s drinking water is a small proportion of people’s overall PFAS exposures compared to consumer products exposures is unsubstantiated, because the city has no data on PFAS exposures from sources such as nonstick pans, stain resistant fabrics, food packaging, etc. So it has no basis on which to argue that these are the main sources of exposures.
Ironically, this ill-informed downplaying argument may justify exposures that are far too high, especially for groups that are exposed to more PFAS via consumer products and/or fish. The 20% default is used in this formula to provide a safety factor—if people are exposed to many other (usually unquantified) sources of PFAS exposures, this lower default level is used so that the calculated health advisory level for drinking water accounts for exposures via background sources.
For instance, the Michigan Science Advisory Group, under “Relative Source Contribution –Subtraction method” says “Subtract all non-drinking water exposures (i.e. background) from the Toxicity value to determine the amount of the Toxicity value available for drinking water exposure.”
In other words, if people are exposed to a lot of PFAS via consumer products, or fish, their drinking water exposures should be even lower.
Perhaps most importantly, the broad claim that our drinking water here is perfectly fine for everyone also completely ignores the fact that some groups of people—e.g., nursing infants, bottle-fed infants—ingest a lot more water per body weight than adults. Babies get most or all of their exposures via breast milk or formula made with tapwater. They are also not typically exposed to Teflon pans, water- resistant sporting clothes, dental floss, or other consumer products the water utility is trying to direct our attention to downplay concerns about PFAS in our drinking water.
Several scientific experts and published papers argue that even at levels well below the 70 ppt EPA HAL, people can build up significant levels of PFAS in their bodies. The Interstate Technology Regulatory Council (ITRC), a leading scientific organization providing current summaries on the state of PFAS science, states that: “Long-term ingestion of low levels of PFAS (including those below health values) in drinking water may result in exposures substantially higher than in the general population not consuming contaminated drinking water.”
More specifically, Dr. Gloria Post and her colleagues wrote: “While general population exposure to PFAAs and precursors comes from sources including diet and consumer products, studies of exposed communities and predictions based on toxicokinetic factors show that low levels of PFAAs in drinking water (i.e., well below 100 ng/L [parts per trillion]) substantially increase blood serum levels. These empirical observations and toxicokinetic models (Fig 2) consistently demonstrate that serum PFOA levels in adults increase on average by more than 100 times the drinking water concentration [8,28], with greater predicted increases for PFOS and PFNA. Notably, serum PFOA and PFOS were significantly higher among individuals residing in zip codes with UCMR3 detections than in other zip codes, although the study design tended to minimize differences between these two groups [29].” (Post et al., 2018)
In other words, even if the levels of PFAS compounds in Madison wells are below various standards and guidelines, the fact that they are there at detectable levels means that those of us drinking it have significantly higher levels in our blood than people living in areas without detectable levels—even if we are exposed to the same amounts of PFAS as them from our Teflon pans, water-resistant sporting gear, dental floss, etc.
From Post et al., 2018
The above graph is for PFOA only and considers adult exposures. What about infants? Vermont used a water ingestion rate (from EPA guidelines) for infants of 0.175 L/kgBW-d. This is about six times the level (0.029) used to calculate the yellow bars in the above graph. So for infants the yellow bars in the above graph would be much higher (if you can directly extrapolate, presumably they would be six times higher?).
Reflecting this, the Michigan Science Advisory Group notes that “Infants are the population likely to have the highest water intake in relation to their body weight.”
Appendix 3: MEJO and engaging shoreline anglers
The focus on subsistence fish consumption is near and dear to me, and to MEJO. I grew up swimming in and eating fish from the Fox River and Green Bay, heavily contaminated with PCBs, but didn’t know about the contamination till I was well into my 20s. This is one core reason I have focused on this issue for decades. After I finished an MS and PhD focused on fish consumption risks and related risk communication, MEJO was created with a multi-cultural group of subsistence anglers and community center leaders on Madison’s north side, specifically to collectively work to build capacities to improve communications and engagement with diverse anglers about fish contamination. I have talked to literally hundreds of shoreline anglers in Madison over the years—mostly anglers of color– as well as shoreline anglers in Milwaukee and Cleveland.
MEJO members and subsistence anglers engaged with PHMDC to design fish advisory signs that made sense to anglers, were in locations they identified as popular for shoreline fishing, and were in three languages. We surveyed shoreline anglers about fish consumption and advisory signs, published several public reports on that work (see here and here) and a peer-reviewed chapter in an MIT-published academic book on environmental justice.
As we wrote at the end of this chapter, published in 2011, “For now, though, MEJO has at least a tentative “place at the table” in community decisions about environmental health and justice. As to whether the evidence we gathered encourages public health or other government agencies to advocate for more signs or further work to address fish consumption risk disparities, as this book went to press the jury was still out.”
That was over ten years ago. We and our subsistence anglers collaborators were never invited by local decisionmakers to have a “place at the table” again.
Not long after “Invisible Risks, Invisible People” was published, we decided we no longer wanted to our work to focus on telling shoreline anglers what fish to eat or not eat, knowing that fishing was something they loved, was culturally important, and that provided needed food. (Several of our board members and staff were subsistence anglers themselves). Many anglers we talked with said fishing provided joy in their difficult lives, in addition to food. They asked why the government doesn’t do more to clean up the pollution. One guy I regularly talked to while he fished at Monona Terrace pointed to the Capitol and said “They don’t care about us! Why don’t they do something about this pollution?”
After hearing this many times, we decided to focus our work on reducing/stopping sources of toxic pollution into the lakes rather than telling anglers what to eat or not eat. This work–focused on corporate polluters (Madison Kipp, Oscar Mayer, etc.) and the military–made us much more threatening to polluting industries and their protectors (government agencies) than fish advisory work did. From that point on, government agencies’ willingness to work with us and address our questions, concerns, and recommendations went down to pretty much nil. We were (and are) treated as enemies of the state, apparently because we question corporations, the military and the state (who are all in bed together).
We still think getting advisory information to anglers, especially subsistence anglers, is important. Responsible government agencies should be putting far more resources into this than they are. This should be an ongoing, systemic effort–not one-off events and short-term outreach. But agencies should be putting far more time and resources into assuring that polluters follow their own laws, and using their own authorities to stop sources of toxic pollution into the lakes, so that future generations can catch and eat fish without having to worry about poisoning themselves and their families.
Unfortunately, it seems our government agencies would rather spend time and resources (albeit token) on public relations intended to downplay concerns about the pollution.
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[1] This development is indeed going forward. Alder Syed Abbas wrote in a recent update: “Wisconsin Housing Preservation Corp. (WHPC), a non-profit affordable housing organization based in Madison, is under contract to purchase the former Bimbo Bakery site at the corner of E. Washington Avenue and N. Fair Oaks Avenue. WHPC has been working on concept plans to redevelop the site into approximately 250 affordable apartments.”
[2] It’s not clear how the Water Utility knows what is “best” for under-represented communities, given that Pearson then said “We’ve been doing a lot of outreach and a lot of learning about PFAS, however we’ve not really made a concerted effort to connect with communities of color…our efforts are part of a larger communication strategy which hinges on a concerted effort to reach and engage under-represented groups, especially communities of color. Oftentimes they’re uninformed or misinformed and left to deal with consequences of decisions we make…”
[3] Clearly, someone on the One Voice team did not feel comfortable saying explicitly that the drinking water is “safe.” Perhaps this person (or people) understand(s) that at this point scientists and the EPA are already saying that PFAS levels pose risks to health at levels far lower than existing standards. Perhaps this person understands that the word “safe” is a subjective term, and is subject to change as PFAS standards change, which they will in time (likely going down). Given this, embedding the claim “safe” into public messaging could indeed “get hairy” in time as “average residents” deconstruct the Water Utility’s assurances.
[4] The airport and military base still store and use PFAS-based firefighting foams.
[5] Alder Charles Myadze also honed in on the “meeting people where they’re at” message, and suggested that they dedicate time, “an hour a day or a week” to go out and hand out fliers to people in person.
