Saying no to F-35s is the least we can do in response to the spread of "forever chemicals" in Lake Monona and Starkweather Creek.

By now, most people will know that Starkweather Creek and Lake Monona have been contaminated with PFAS, a class of “forever chemicals” that persist in the environment (and in human bodies) for years. If consumed, PFAS have been linked to health problems including thyroid issues, low birth weights, fertility issues, and increased risk of certain types of cancer. Most people will also be aware that PFAS are in our drinking water, too, detectable at 14 out of Madison’s 23 drinking water wells.

You can spend a lot of time reading about PFAS: looking up the PFAS levels in the wells serving your home; figuring out how you, your children, and your pets can safely interact with Starkweather Creek and Lake Monona come summertime; and even determining which fish from the affected bodies of water you can eat and how often. Right now, it’s hard to imagine that PFAS contamination and exposure won’t be a public health issue for the rest of our lives. We should all take what precautions we can.

At the same time, it’s infuriating and unreasonable that individuals and families are being asked to shoulder this burden at all. Our water should be safe, whether it flows from our taps or through Starkweather Creek into Lake Monona and beyond. We’ve been wronged, and the fact that two bodies of water in our community are now so polluted that your dog shouldn’t drink the water or lick its coat after swimming in it is tragic.

The situation in Madison isn’t unique. PFAS have been detected in the drinking water in most major cities and most Americans already have PFAS in our blood. Communities all over the country are in the same boat. They have varying degrees of PFAS contamination and exposure and little guidance from the federal agencies that would, in an ideal world, set enforceable standards for everyone to follow. Instead, there’s frustration and fear as states and municipalities scramble to develop their own standards while non-scientific laypeople struggle to follow along with the science emerging before our eyes.

What sets Madison apart is that the entity that’s responsible for the brunt of the contamination—the Wisconsin Air National Guard—currently wants our community and our elected officials to cooperate with a scheme that might drive still more PFAS contamination. What also sets Madison apart is that we have an opportunity to act on the future of PFAS contamination and crack down on a PFAS polluter in our community.

The proposed basing of F-35 fighter jets at Truax Field is in its final stages of consideration. Given the severity of the contamination of Starkweather Creek and Lake Monona, the ongoing debate about the danger PFAS pose, the fact the individuals and families will very likely shoulder all PFAS-related healthcare costs on their own, and the historic failure of the Wisconsin Air National Guard to cooperate with the state agencies that are meant to keep us safe, our response at every level—from community groups to the Mayor and County Executive to Senator Tammy Baldwin—should be a big, loud, uncooperative no.

What are PFAS?

Per- and polyfluoroalkyl substances (PFAS) refers to a group of over 4,000 man-made chemicals used to produce all kinds of products, from non-stick pans to rain jackets to stain guard treatments for your couch and carpet. Eating a greasy chicken sandwich out of a cardboard container? It is entirely possible that the box has been treated with one of these chemicals to keep the grease from soaking through the cardboard and into your jeans.

In addition to being in food packaging and a plethora of household objects, PFAS are also a highly effective addition to fire-fighting foam, which brings us back to Madison. Fire-fighting foam used in training at Truax Field is the suspected source of the PFAS contamination of Starkweather Creek. Both civilian airports and military airfields keep PFAS-containing foam around to put out jet-fuel fires. The foam is also used to put out fires set for training exercises. The Wisconsin Department of Natural Resources first contacted the Wisconsin Air National Guard in April 2018 to notify the ANG that it is responsible for “investigating and restoring the environment” and noting that, “the longer contamination is left in the environment the further it can spread.”

Almost two years later, the contamination is still in the environment and it has indeed spread. Foam collected from Starkweather Creek was tested for PFAS and returned results between 80,000 and 92,000 ppt (parts per trillion) PFOS, one type of PFAS compound. Water from the creek returned results of 360 ppt of PFOS. Fish from Starkweather Creek and Lake Monona were found to have PFOS levels ranging from 21 to 120 ppb (parts per billion, i.e. 21,000 and 120,000 ppt).

In 2016 the Environmental Protection Agency issued a non-enforceable, non-regulatory health advisory suggesting that combined levels of PFOA and PFOS (two specific PFAS compounds) should not exceed 70 ppt in drinking water. The EPA also said it would have more recommendations soon, but they've yet to come. In the interim, some states have been developing their own much more conservative standards based on newer science. For example, Vermont has set a standard for drinking water that limits the combined total of the levels of five specific PFAS compounds at 20 ppt, which of course makes the EPA's 70 ppt threshold seem absurd and dangerous. The Wisconsin Department of Health Services shared a similar recommendation with the DNR in June.

Of course groundwater (the source of our drinking water) and surface water (like lakes and creeks), aren’t the same, though they do interact. Good luck explaining that to small children, pets, and wildlife. But in the absence of any guidance on surface water from the EPA, we can look to Michigan to make sense of the PFOS levels in Starkweather Creek. Michigan’s water quality standards for surface water is just 12 ppt for PFOS. In other words, 360 ppt is very high. In that same light, the level of PFOS in the bright white foam floating in Starkweather Creek (again 80,000 to 92,000 ppt) is positively horrifying. Please just steer clear.

But it’s important to be aware that even these more conservative limits for drinking water and surface water might not be sufficient, according to some scientists. For example, Linda Birnbaum, former director of the National Institute for Environmental Health Sciences, suggested in June of 2019 that the threshold for PFOA alone should be 0.1 ppt. Some of Birnbaum’s assertions as well as disagreement about how PFAS compounds should be measured and regulated led to a contentious back and forth in Isthmus earlier this year, with a Madison Water Utility spokesperson chiming in to defend the steps the utility has taken and the standards local officials are using to keep our water safe. Far from inspiring confidence, it was a glimpse of the disagreement, debate, and understandable alarm still surrounding PFAS.

It is disingenuous to say that PFAS compounds are new, or even that they’re new to the EPA. They’re not. But it’s not inaccurate to say that the science around PFAS is still emerging and unclear. It is an absurd moment to give a green light to projects that could make PFAS contamination even worse.

The Wisconsin Air National Guard wants to begin construction at Truax Field in preparation for the basing of F-35 fighter jets at Truax. Disruption of this highly contaminated site could make the PFAS problem even worse. This is not speculation, but a real concern expressed in a letter that the Wisconsin Department of Natural Resources submitted towards the end of the public comment period for the Air National Guard’s draft environmental impact study. One day later, DNR sent a Notice of Violation letter to the Wisconsin Air National Guard for “failing to take the actions necessary to restore the environment to the extent practicable and minimize the harmful effects from the discharge at the property located at Truax Field.”

The DNR’s concerns about moving soil at Truax as well, as the agency's characterization of the Wisconsin Air National Guard’s inaction, were echoed in a statement from the Madison Water Utility Board, which also said, “The Air National Guard Base has been identified as a major source of [per- and polyfluoroalkyl substances, or PFAs] contamination. While an investigation is underway, steps required by the Wisconsin DNR to further investigate the extent of the contamination have not yet been taken, and the Department of Defense has not considered this a priority site for mitigation.”

On February 19, 2020, the Air National Guard released its final environmental impact study, which includes the following regarding concerns about PFAS contamination at Truax Field: “As applicable, the 115 FW would coordinate with the WDNR regarding proposed construction near ERP sites. The 115 FW will comply with Air Force Guidance Memorandum (AFGM2019-32-01) AFFF-Related Waste Management Guidance to manage waste streams containing PFOS/PFOA.”

To summarize, we are to rest assured that the 115th Fighter Wing of the Air National Guard will coordinate with Wisconsin Department of Natural Resources regarding any construction in the contaminated areas and that it will comply with the Air Force’s own internal guidelines for managing waste streams that contain PFOS/PFOA.

Given the historic failure of the Wisconsin Air National Guard to coordinate with the DNR, as documented by the DNR itself, this is pretty hard to choke down. Why should we believe that an organization that allowed known contamination to get worse and worse over the course of the last two years will willingly and responsively coordinate with environmental regulators in the future? We shouldn’t.

What if people get sick?

We shouldn’t panic. But there is research linking PFAS to a number of health problems, science has not yet established the risks of years of moderate PFAS exposure on humans, and healthcare is notoriously expensive in the United States. What will happen if people do get sick from PFAS exposure? PFAS have been streaming into Starkweather Creek for a while. Signs warning people of the potential danger only went up in December. Let’s say you’ve been eating fish from Starkweather Creek, as well as serving it to your family, without knowing that it’s inadvisable to eat most species more than once a month due to the high levels of PFAS found in the fish. Is there any help for you at present? No, not really.

Blood testing for PFAS levels is not routine healthcare. You can talk to your doctor about it but you will likely need to get help from a special lab and testing could cost several hundred dollars. And at the end of the day, the only thing your expensive, special lab test will tell you is how much of what types of PFAS are in your blood, not whether PFAS are what’s making you sick.

Most of the health problems related to PFAS can also be caused by other factors which means It would be extremely difficult to definitively prove that your particular health problem is caused by PFAS contamination stemming back to Truax Field. Who would you prove it to, anyway? There is no healthcare fund for people who have been exposed to PFAS. If you’re struggling with infertility or thyroid problems or cancer, you will most likely pay all the associated healthcare costs yourself, no matter how certain you are that you’re sick because of PFAS.

It’s true that there have been successful lawsuits on behalf of individuals and communities subjected to extremely high levels of PFAS contamination. It seems entirely possible that someone or maybe a group of people will initiate legal action in Madison, too. But lawsuits are expensive, they take years, and there’s no guarantee of a positive outcome.

We will be dealing with the fallout from this contamination for the foreseeable future and it likely won’t be relegated to the North and East side. PFAS compounds move quickly through water. We’ll have a better idea of the extent of the contamination when more of our lakes are tested later this year.

But the people who will bear the greatest burden—the ones who are now expected to navigate fish consumption advisories and follow careful guidelines to safely enjoy a body of water near their homes, the folks whose well was shut down when it was found to contain high levels of PFOS and PFOA—are the same people who will bear the brunt of the harm if F-35 fighter jets are brought to Madison.

The F-35s are their own nightmare, creating a housing crisis for thousands of people who live under their proposed airspace. Some people will be displaced. Others will live with the noise, to the detriment of their own health and their families' health. People fortunate enough to own homes will have to navigate a lengthy process to receive financial assistance with noise mitigation, but they might not even be eligible to apply. Finding out if their home is subject to an “avigation easement” that could block them from requesting funding is an entirely different, equally byzantine quest through bureaucracy. It is unconscionable to inflict these tasks on people alongside a project that will also potentially worsen the PFAS contamination in the water running through their neighborhood and from their taps.

This is what it looks like when the government shrugs off its responsibility to protect the environment and allows it to become a complex to-do list for families instead.

But there’s still time to correct the course. Now that the Air Force has released the final environmental impact study, we have 30 days before it announces its final decision about where to base the F-35s. City and county leaders including Mayor Satya Rhodes-Conway and County Executive Joe Parisi should not only voice their opposition to F-35s but evaluate what powers the city and county can exercise to block the Wisconsin Air National Guard from beginning construction this year, as should the DNR. This is not a radical proposal. It’s common sense conservation. What purpose do the various government bodies, with all their attending red tape at the local and state levels, serve if not to prevent residents from being harmed?

Meanwhile, Senator Tammy Baldwin is pushing for PFAS regulation at the federal level, joining 30 others senators earlier this month to demand an updated timeline from the EPA. She has expressed concern about PFAS contamination in Wisconsin. She should go further and drop her support for the F-35 project, which will harm so many of her constituents and make PFAS contamination worse. Right now, in Wisconsin, she is standing on the side of the Wisconsin Air National Guard’s contamination and neglect, even as she champions regulations for PFAS. Without taking action in her own backyard, her support for PFAS regulation rings hollow.

On Saturday, February 29, Safe Skies, Clean Water, an all-volunteer community group fighting for the conservation of Madison’s North and East sides, is calling on concerned community members to join them for a parade to Truax Field to say no to F-35s and no the contamination of our water.