Barbara L. Rubin
1496 Teague Drive
McLean, VA 22101

September 14, 2007

L. Preston Bryant, Jr.

Office of the Secretary of Natural Resources
Patrick Henry Building
1111 East Broad Street
Richmond, VA 23219

Dear Secretary Bryant:

I consider myself a sludge victim. I had my initial exposure in August 2001
which resulted in an immediate virulent Mycoplasma pneumonia and lung
infection. It took a 5 day hospital stay, 4 months, and 8 courses of
antibiotics, to force the infections into remission. I have never gotten rid
of these infections and since that initial exposure my overall health has
steadily deteriorated resulting in numerous chronic illnesses.

Unfortunately, my health does not allow me to appear at the meeting on
September 18, 2007. I will be undergoing medical treatment at this time. I
would however like to register my objection to the list of panelists for the
"Expert Panel Studying Biosolids."

Often an agency or industry is forced to name a "Panel of Experts" to
appease an unhappy public. While authorities reluctantly "agree" to the
concept of "study," they carefully control it by stacking the panel with
members who will eventually reach predetermined conclusions which they hope
will quiet the public. The sludge industry has engaged in this maneuvering
numerous times before (Stakeholders Research, Sludge Summit.) None of these
carefully planned events have succeeded before. This new study panel has all
the ear markings of the past fiascos

In general the current panel list is stacked heavily with state government
representatives whose jobs depend on their defense of the sludge program
and/or representatives from institutions that depend on the sludge industry
for their functioning. In other words far to many panelists have financial
ties to the sludge industry. Why aren't there more people who have had their
lives shattered by this program on the panel? They are certainly expert on
sludge and its effects. Why do I only see one member (out of about 27) who
does not directly or indirectly have their job connected to sludge money,
represented on this panel?

Because of the grossly unbalanced nature of the "members," one must conclude
this is by no means an unbiased panel objectively looking at the sewage
sludge issue. Instead, it is a carefully planned and controlled response
which will whitewash the issue and claim there is no foundation to the
scores of valid complaints that have plagued the ill founded sludge program
in Virginia

In further attempt to control all data, I am told the many "citizen
representatives" who were carefully excluded from the "panel" may not even
be able to speak at these meetings. If they are allowed to speak they will
need to severely limit their input. This unfair control assures that the
citizens real concerns and issues will never be considered at these staged

The first of a number of examples of people who raise grave concerns on this
panel is Dr. Alan B. Rubin (no relation to me.) Dr. Rubin has recently
retired from the EPA where he was one of the original developers and
promoters of the sludge program. He was instrumental in "pushing through"
the 1992 Sludge Rule which had failed the peer-review process of the EPA's
own research department. Dr. Rubin's entire professional career has been
dependant on implementation and continuation of the 503 Sludge Rule. He is
currently employed as a consultant, reaping huge financial rewards from the
sludge industry. To include Dr. Rubin as "Citizen Representative" of the
people of Virginia is outrageous. His position of biased, unquestioning
support of sludge is already represented by almost all of the other members.

Virginia Tech has had a long close working relation with the VDH/DEQ in
forcing the unwanted Sludge program on counties all over Virginia. In
particular Dr. Greg Evanylo has traveled all over the state participating in
t he state/industry sponsored "staged "meetings" in which they blanket new
areas, which are fighting inclusion in the sludge program, with untrue
propaganda. Even though much of the propaganda has been proven factually
false, it is still repeated by these faithful promoters of sludge.

Chris Peot from the Blue Plains, Sewage Sludge Treatment Plant is another
member of the group that can hardly be seen as unbiased. He is a manager of
a sewage sludge plant that supplies much of Virginia's sewage sludge. Not
only would his position eliminate him from an "unbiased panel" but he too
travels around the country in staged "meetings" preaching that sewage sludge
is the best thing since sliced bread. Add to this the fact that Mr. Peot has
testified for the sludge industry at a wrongful death case, we begin to see
how this so called "unbiased panel" is predestined to endorse a very
dangerous and harmful program because it is stacked with "pro-sludge"

I would hope this panel is not in its final form. It needs to be
substantially adjusted to be more balanced and therefore more credible to
the citizens of Virginia. If it is not, the intended appeasement of citizen
concerns will never be attained.


Barbara L. Rubin

Loudoun Neighbors Against Toxic Sludge