To: Livestock Producers

Re: National Bio- and Agro-Defense Facility (NBAF): new threat to U.S. livestock exports.

The Department of Homeland Security is ready to build a huge laboratory to study diseases that might threaten our livestock industry if they were imported. The most contagious would be Foot-and-Mouth-Disease (FMD).

During the site selection, Congress asked the General Accountability Office (GAO) to study the risks of permitting FMD research on mainland United States. The GAO released its conclusions in 2008 with the title “HIGH-CONTAINMENT BIOSAFETY LABORATORIES: DHS Lacks Evidence to Conclude That Foot-and-Mouth Disease Research Can Be Done Safely on the U.S. Mainland”. The location selected by the Department of Homeland Security (DHS) for this one-of-a-kind lab is Manhattan, KS.

Alarmed by the GAO’s report, members of the Appropriations Committee asked Homeland Security to do a more thorough study of the risks of building this facility in Manhattan -  before releasing money to build the lab. And they asked a committee of experts appointed by the National Academy of Sciences to review the methods used by DHS in this evaluation.  Last November, the Academy committee released its review with some conclusions which should concern all livestock operators.

• DHS Assumptions are over-optimistic partly because of huge differences between working under a sleeved isolation box, and working in direct contact with large animals and their excretions.

• In trying to meet a budget, safety shortcuts are being made in the lab’s designs that increase the probability of an FMD release. Examples are the cutting of redundant HEPA filters (Pg 52-53), or building the lab to withstand no more than an F2 tornado (Pg 33). Manhattan experienced an F4 tornado in 2008 which damaged buildings next to the NBAF site.  Furthermore, long term maintenance is critical. (Weathered gaskets and air filters will have to be replaced through all future administrations and budgets…without fail.)

• KSU Vet Medicine is next door and livestock research feedlots are less than two miles away. The NBAF site is directly cattycorner from football overflow parking. Large crowds leaving KSU events or games could very well carry the virus particles in dust or mud home. (Pg 21).

• Based on the DHS estimates, the reviewers calculated a cumulative risk of an outbreak as being a coin toss within 30 years of the lab’s completion and a 70% probability by the end of its life (Pg 30).  This is not a “low probability” event as presented by Homeland Security. Calculating the cumulative risk this way is often used by institutions in locating nuclear installations or by research scientists to determine probability of infectious disease outbreaks.

• Detection and destruction of infected herds will not be as rapid as DHS expects, so the duration and spread of an infection is likely to be much more extensive (Pg 38).

Probably only those with disposed of livestock will be compensated and then by whom?  Faced with billions of dollars in losses, will your insurance company consider this an “act of God”?   Operators of uninfected ranches and feedlots in every state will suffer a loss of both American and export markets with the overall toll projected to be in the $9 to 50 billion range (Pg 58).

Enclosed are the executive summaries of both the GAO and the National Academy of Sciences reports and a CD with both full reports, a list and contact information of the House and Senate Appropriation Subcommittee members.  If you believe that this could hurt your investments, look at the portions of the full report that apply to you.

Congress has yet to appropriate the actual construction money, but that could be done within the next two months.  This time period will be critical in determining whether the lab will be built. As area ranchers, scientists and Manhattan residents we ask that you:

1.   Have your family, friends in the business, and livestock organizations, call or email the members of the House and Senate Appropriations Committees to NOT release the construction funds.  Join us in calling for an injunction against further construction until the committee formed by the National Academies of Sciences amends their study to confirm that a BSL-3Ag and BSL-4 large animal laboratory can be safely placed at the Manhattan, KS site.  In the previous study, the committee was instructed by Congress not to include this in their scope of study.  Copy, cut, paste any and all of our material.

2.   Ask for repeal of the previous legislative language (inserted in the Senate) that requires DHS to sell Plum Island Animal Disease Center in the event another site is chosen for NBAF.  The Plum Island sale language forces an unnecessary urgency and requires the government to sell the island, liquidate its existing lab and apply all proceeds to NBAF. The Plum Island sale language creates an artificial timeline and makes this a “done deal.”

While this research may be important, it must only be done in the proper perspective of its risks.  We just ask that this it be kept on an island where the prevailing winds blow infections out to sea instead of over surrounding states …in Kansas, that’s from any direction the wind blows.  A release of FMD virus on an island will not have a chance to infect nearby cattle headed for sale barns and feed lots before it is even detected.

Proponents of placing NBAF in Kansas responded to the NAS evaluation by saying that this facility is only in the planning stage, and that many of the National Academy of Sciences committee’s concerns are already being addressed. However the fundamental concerns are inherent in today’s economic times and its proposed location on the edge of a university town in the middle of cattle country. Budget deficits in Washington are out of Homeland Security’s control, and will require such cuts as the Academy fears. KSU will continue having football games across from the lab and draw crowds to University events.  And they will say that there is already a FMD vaccine – they won’t say for only three of the 77 different subtypes.

Don’t take our word for it. Look at the reports. We have nothing to gain personally from opposing this.  At least for the short term, our homes and land will lose value if the lab is built elsewhere. We know that in portions of our community, we will be ostracized for working to end a billion dollar gold rush. However, after a leak we won’t be able to give our property away.

NoNBAF in Kansas

Real BioSecurity for the Heartland

For more information go to:   http://nonbaf.wordpress.com/

NBAF will replace the Plum Island Animal Disease Center, on an island just off of Long Island, New York. This is the only place in the U. S. where Foot-and-Mouth Disease can be studied. The 9/11 attacks and the anthrax letters triggered a seemingly hysterical escalation of the domestic biodefense effort.  The expected $450 million lab propelled a contentious and highly politicized nation-wide competition to be the site for NBAF. The new facility would not only bring the risk for studying Foot and Mouth Disease onto the mainland, but would study agents that can infect both animals and humans and for which there is no cure or vaccine. These require the highest level of biosafety containment.

For the proponents it is all about economic development and fighting biological terrorism. The imposing list of proponents includes the U.S. DHS, K-State, and the Kansas Bioscience Authority, the entire Kansas congressional delegation, the Manhattan Chamber of Commerce, The Manhattan Mercury, the Kansas Farm Bureau, the Kansas Livestock Association, and the Manhattan City Commission.

For most of the opponents, it is about public safety. The principal critics are the Governmental Accountability Office (GAO), the National Academy of Sciences committee, a variety of national livestock organizations, Kansas Cattlemen’s Association and a loosely knit group of Manhattan concerned citizens and ranchers calling themselves No NBAF in Kansas

Homeland Security selected Manhattan as the site over the warning of the GAO, who reported to congress that DHS lacks evidence to conclude that Foot-and-Mouth Disease Research can be done safely on the U.S. mainland. This alarmed members of the House and Senate Appropriations Committee who called for DHS to complete a Site-Specific Risk Assessment (SSRA) to address GAO’s concerns, with the condition that DHS’ methodology would be reviewed by the National Academy of Sciences (NAS/NRC). However NAS was specifically told neither do an independent safety evaluation nor judge Manhattan’s selection.

Their November report concluded that there was a 70% chance that Foot-and-Mouth Disease would be accidentally released from the site during the facility’s lifespan. Millions of livestock would be slaughtered, as is happening now in Korea and U.S. beef exports would be embargoed worldwide. It would cost the nation between $9 and $50 billion.

The proponents tried to discredit the reports by characterizing this threat as “extremely low.” Sen. Brownback attached a $40 million earmark to the spending bill that would begin work on the Manhattan site. The earmark was cut in the final days of the 2010 session.

The National Academy acknowledged that the Plum Island facility is old and needs repair, but also that “further risk analysis” was needed to validate the site in Manhattan. The NAS committee concludes the only thing they were mandated to say, “Ultimately, policy makers will need to decide whether the risks of constructing the lab in Manhattan, Kansas, are acceptable.”

The No NBAF in Kansas is trying to rally an appeal to members of the House and Senate Appropriations Committees to not approve the funds, and to repeal language inserted by the Senate requiring DHS to sell Plum Island. This creates an artificial timeline and makes this a “done deal.”

Recommended Reading:

Kenneth King, Germs Gone Wild, 2010 (Pegasus Books, LLC)

Michael Christopher Carroll, Lab 257, 2004 (Harper Books)

Congressional Contacts – NBAF

When the the Department of Homeland Security (DHS) selected Manhattan as the site for the NBAF there was little this group could do until the funding process worked its way through Congress.  Because of the concerns raised by the Government Accountability Office (GAO) Congress instructed DHS to complete a “site-specific biosafety and biosecurity risk assessment (SSRA)”.  They also directed the National Research Council to conduct an independent evaluation of this SSRA to determine its adequacy and validity.  Congress would not release construction funds until these were completed and evaluated. We had to wait for the outcome of these even though the DHS/KSU/Kansas Bioscience Authority (KBA) started site preparation on the KSU campus using Kansas State and local funding.  These documents were released last month.  But Congress has not appropriated any funds for construction.  This can still be stopped.

The NRC evaluation found many serious faults in the DHS plans that call into question the decision to build the NBAF in Manhattan.  The composition of the NRC commission included leading experts in most, if not all, of the fields relevant to this incredibly complicated project.  Their 11 findings echoed the objections opponents to the NBAF (including us) had raised, which were based on the concerns raised by the GAO more than two years ago.  These findings reinforce our resolve that it is simply unacceptable for this facility to be built on the KSU campus in Manhattan. The findings concerning the risk of release of the Foot and Mouth Disease virus (FMDv) further reinforce our resolve that it is unacceptable to study this disease in large animals on the mainland of the United States.

To address these issues and work toward the goal of persuading Congress to refuse to fund this project, we have regrouped under a new name, but with the same objectives.  We will now identify our goal to be Biosecurity For the Heartland. We will soon move these efforts to a new web site under that name.  The only weapon we have at our disposal is information.  We can shine light on the facts that are a matter of public record and on the efforts by the proponents of this project to obscure those facts that challenge the project’s safety.

Because of the urgency of preventing the funding of this project, we will focus our efforts on the members of Congress who will be making this decision:  the members of the House and Senate Appropriation Committees, starting with the members of those committees who serve on their Homeland Security subcommittees.  To get our message to these members of Congress we will do our best to recruit those people who have the most to lose in the event of an FMD catastrophe:  the livestock growers and the organizations that represent them.  But Foot and Mouth Disease isn’t the only threat from this facility.  This germ lab is designed to study the most deadly diseases that infect both animals and people.  These are diseases that are deadly to people and for which there is no known vaccine or cure.  Every person who lives in the long shadow of this facility must understand  the risks.

Biosecurity For the Heartland is a coalition  of area residents who want to stop this madness by honest, rational information sharing and discourse.  None of us have anything to gain by the defeat of NBAF except a safer place to live and raise our families.

NBAF Risk Assessment Report

The text of the 146 page report can be purchased or read online at http://nap.edu/catalog.php?record_id=13031

We have abstracted the major findings here:

OVERALL ASSESSMENT

The committee evaluated the SSRA’s methods, facility design plans, and mitigation strategies. The committee found that the models used in performing the SSRA appear to be appropriate and that many of the SSRA’s general conclusions are valid. The SSRA has considered the major release pathways (aerosols, fomites, liquid waste, and solid waste), as recommended in the committee’s preliminary letter report (see Appendix B), and has addressed mitigation strategies for each. DHS has also appropriately responded to GAO’s prior criticism that it had inappropriately dealt with a potential plume from an airborne release of foot-and- mouth disease virus (FMDv); the SSRA uses a state-of-the-art puff dispersion model to simulate the aerosol transport of pathogens, which turned out to be a less critical pathway of FMDv spread than the near-site exposure of cattle. However, as described in the findings below, the committee found that the SSRA had several major shortcomings with respect to potential risks and impact scenarios, and there are some critical limitations in the SSRA’s execution and analysis.

The committee found that the SSRA has many legitimate conclusions, but the SSRA is not entirely adequate or valid. The SSRA does not account for the overall risks associated with operating the NBAF and conducting FMDv work in Manhattan, Kansas. The inputs and assumptions for the models are inadequate because they do not fully account for how a biosafety level 3 agriculture (BSL-3Ag) and BSL-4 facility would operate, how pathogens might be released, and which animal populations might be exposed. The SSRA sometimes used arbitrary assumptions and did not account for uncertainties, some of which require experimental data that are currently not available but that could greatly alter the outputs. Consequently, the committee is concerned about the validity of the actual risk and impact levels determined by the SSRA’s outcomes from the models.

Given more time, the SSRA may have progressed further and may have better addressed some of the concerns expressed in this report. The committee thus views this as a notable first step in an iterative process aimed at identifying and minimizing risk and determining actions that will need to be taken.

FINDINGS

The SSRA shows that constructing the NBAF in Manhattan, Kansas, carries a number of risks and that the impact of an FMDv release could potentially have significant economic, health, and national security impacts. Some risks and impacts are generic to any high-containment large- animal facility, whereas others are specific to the Manhattan, Kansas, site. The risk of release is primarily a generic concern, whereas the risk of infection, spread, and impact is largely related to the site. The SSRA’s estimates indicate that the probability of an infection resulting from a laboratory release of FMDv from the NBAF in Manhattan, Kansas approaches 70% over 50 years (see Figure 3-1) with an economic impact of $9-50 billion. The committee finds that the risks and costs could well be significantly higher than that, and elaborates on those findings below.

Finding 1: The SSRA lacks evidence to support the conclusion that the risk of release that results in infection is very low relative to the risk of infection introduced from an external source.

…

Finding 2: The SSRA overlooks some critical issues, both site-specific and non-site-specific, that could significantly elevate the risk of accidental release and spread of pathogens.

…

Finding 3: The SSRA has several methodological flaws related to dispersion modeling, tornado assessment, and epidemiological modeling. Thus the committee believes that questions remain about the validity of the overall risk estimates. Finding 3: The SSRA has several methodological flaws related to dispersion modeling, tornado assessment, and epidemiological modeling. Thus the committee believes that questions remain about the validity of the overall risk estimates.

…

Finding 4: The committee agrees with the SSRA’s conclusion that for FMDv, long-distance plume transport will likely be less important than the near-site exposure of cattle.

…

Finding 5: Substantial gaps in knowledge make predicting the course of an FMD outbreak very difficult, which led to weaknesses in the SSRA.

…

Finding 6: Although the economic modeling was conducted with appropriate methods, the epidemiological estimates used as inputs to the SSRA were flawed.

…

Finding 7: The committee agrees with the SSRA’s conclusion that early detection and rapid response can limit the impact of an FMDv release from the NBAF, but is concerned that the SSRA does not describe how the NBAF could rapidly detect such a release.

…

Finding 8: The SSRA lacks a comprehensive mitigation strategy developed with stakeholder input for addressing major issues related to a pathogen release. The mitigation strategies that are provided do not realistically demonstrate current or foreseen capacity for how federal, state, and local authorities would effectively respond to and control a pathogen release.

…

Finding 9: The committee agrees with the SSRA’s conclusion that human error will be the most likely cause of an accidental pathogen release, and fomite carriage is the most likely way that a pathogen would escape the facility’s outer biocontainment and biosecurity envelope.

…

Finding 10: The committee agrees with the SSRA’s conclusion that investment in biosafety and biosecurity engineering and the training of personnel and responders can reduce the risks, but is concerned about current design plans that potentially compromise safety measures.

…

Finding 11: The SSRA’s qualitative risk assessment of work with BSL-4 pathogens in large animals was inadequate.

ADDITIONAL REMARKS

The SSRA team should be applauded for its effort in conducting an extensive risk assessment in such a short period of time. Although the committee’s findings express major concerns about the validity of some of the SSRA’s conclusions, the work that was completed constitutes a huge step forward compared with previous risk assessments of its kind and should be viewed as a solid starting point.

The nation clearly needs an institution to support comprehensive research programs for the study of foreign animal and zoonotic diseases, including detection, diagnosis, and means of mitigation (drugs, vaccines, and genomic forensics). Such activities require a capability to work with all known threat agents (not just the eight infectious agents listed in the SSRA), multiple pathogen introductions, and emerging and unknown disease threats. For these reasons, the committee agrees that there is a need for a facility like the NBAF to be constructed and operated in the United States.

Constructing a BSL-3Ag and BSL-4 facility of the magnitude planned for the NBAF, one that is capable of large animal work on a scale greater than other high-containment laboratories, undoubtedly presents new and unknown risks that could not be accounted for in the SSRA because of a lack of data and experience. Given the constraints of the design framework and the short timeframe available for data collection and analysis, the committee finds that the limitations of the data, facility design details, and operating practices may have limited the scope that the SSRA could adequately address at this time. As more data, facility designs, and operational plans emerge, updated analyses may be appropriate to better evaluate the risks posed by a BSL-3Ag and BSL-4 large animal facility in Manhattan, Kansas.

The SSRA and the committee identify some sources of risk that can be addressed as part of the design, preparation, and long-term operation of the NBAF to reduce risk wherever it is located. Though the SSRA and the committee offer several points for consideration to reduce the risk of a pathogen release and its consequences, further risk analysis is needed to determine the extent to which these measures would reduce risk. Ultimately, policymakers will need to decide whether the risks are acceptable related to constructing and operating the NBAF in Manhattan, Kansas, and DHS will need to determine steps to minimize risk and impact if construction and operation should proceed as planned.

…

CONCLUDING REMARKS

The SSRA team should be applauded for its effort in conducting an extensive risk assessment in such a short period of time. Although the committee’s findings express major concerns about the validity of some of the SSRA’s conclusions, the work that was completed constitutes a huge step forward compared with previous risk assessments of its kind and should be viewed as a solid starting point.

The nation clearly needs an institution to support comprehensive research programs for the study of foreign animal and zoonotic diseases, including detection, diagnosis, and means of mitigation (drugs, vaccines, and genomic forensics). Such activities require a capability to work with all known threat agents (not just the eight infectious agents listed in the SSRA), multiple pathogen introductions, and emerging and unknown disease threats. For these reasons, the committee agrees that there is a need for a facility like the NBAF to be constructed and operated in the United States.

Constructing a BSL-3Ag and BSL-4 facility of the magnitude planned for the NBAF, one that is capable of large animal work on a scale greater than other high-containment laboratories, undoubtedly presents new and unknown risks that could not be accounted for in the SSRA because of a lack of data and experience. Given the constraints of the design framework and the short timeframe available for data collection and analysis, the committee finds that the limitations of the data, facility design details, and operating practices may have limited the scope that the SSRA could adequately address at this time. As more data, facility designs, and operational plans emerge, updated analyses may be appropriate to better evaluate the risks posed by a BSL-3Ag and BSL-4 large animal facility in Manhattan, Kansas.

The SSRA and the committee identify some sources of risk that can be addressed as part of the design, preparation, and long-term operation of the NBAF to reduce risk wherever it is located. Though the SSRA and the committee offer several points for consideration to reduce the risk of a pathogen release and its consequences, further risk analysis is needed to determine the extent to which these measures would reduce risk. Ultimately, policymakers will need to decide whether the risks are acceptable related to constructing and operating the NBAF in Manhattan, Kansas, and DHS will need to determine steps to minimize risk and impact if construction and operation should proceed as planned.

After scrolling through many slides on the risks to oil and gas facilities and military missions in Iraq (one sees here the nation’s priority when it comes to protecting the US from terrorists), one reaches on the 12th of 27 slides a discussion of threats to the “homeland.” At the 15th slide, the discussion turns toward risks to food and agriculture.

The first statement on the topic is

DHS lacks credible information to indicate planning for an attack against the Food and Agriculture sector, but continues to pay great attention to this threat

which seems to be something of a mild smoking gun with regard to NBAF. Much has been made by its supporters of the threat, which is typically described as imminent and real, while perhaps not using those terms. Is is really worth the expense and the risks to build an NBAF when even the DHS cannot present any credible information pointing to a threat?

Perhaps even more disturbingly, the next slide analyzes the danger represented by domestic “animal rights extremists” and “environmental extremists.” While I find the tactics of groups such as PETA and Greenpeace (and smaller groups with similar and perhaps more action-oriented agendas) off-putting, I think we have room in our nation to tolerate a bit of antisocial behavior. If they commit criminal acts, which some do, we have laws against such acts (theft, wanton destruction of property, disturbing the peace, etc.), so why the need to label them extremists and terrorists? Unless something has been hidden from the public, the only “extreme” domestic acts one reads about in the paper are fairly frequent shooter incidents and, of course, the Oklahoma City bombing, none of which have anything remotely to do with animal rights nor the environment.

This is, put simply, making enemies out of thin air. The mindset behind this slideshow frightens me, frankly, as a citizen of a democratic nation. I am not much of a conspiracy theorist, but if PETA et al. already rank as “terrorists” and “extremists,” who will be next?

BRI/NBAF Site across from KSU Stadium (right click for full image)

K-State Bio-Lab;

photos of vector animals across the street… downwind.

Kansas wind can carry aerosolized Foot and Mouth virus 30 miles. An infected hog can exhale 400 million viruses a day. It takes as few as 10 virus particles to infect an animal. Just a reality check, attached are seven pictures showing large numbers of vector animals within a  mile of  KSU’s NBAF site.

Imagine what would happen if an accidental release coincided with perhaps All University Open House or a KSU/Nebraska football game? How would you quarantine the surrounding area? An accident doesn’t have to happen on the hour but within the period of days before the release is recognized. With sheep that could be 10 to 15 days.

The KSU sheep pastures, used as overflow parking on game days, are just cattycorner from the proposed site. One of the several accidental FMD disease releases at Pirbright BSL-4 lab started when a tree root caused a leak in a lab sewer pipe and a truck carried contaminated mud to neighboring farms. KSU already has a $250 million backlog of deferred maintenance.

A tornado or for that matter, severe straight line winds don’t have to cause structural damage to disrupt the air pressure balance inside the lab. It only has to overwhelm the rubber air lock gaskets, or air filter seals around garage-size doors needed to bring in hay or other feed. Improbable as it may be, the prospect of an earthquake has the Corps of Engineers spending millions of dollars stabilizing Tuttle Creek Dam, a geologically insignificant distance from NBAF (Humboldt Fault Line <http://www.nwk.usace.army.mil/projects/tcdam/documents/ks-legislature-report.pdf>

Ranchers in Riley and adjacent counties own about 450,000 livestock. Now picture the sheep pasture “parking lot” emptying, with KSU and Nebraska fans driving in all directions …back to their farms.

Government funded Project Crimson calculated that a release would reach 35 states in 10 days.

Bill Dorsett

1715 Leavenworth

Manhattan, KS

785/564-2583

KSU sheep pastures in football overflow cattycorner from NBAF (right click for full image)

KSU Beef Cattle Research Center, 1.5 miles from NBAF site (right click for full image)

KSU beef, swine and dairy research 1.5 miles downwind from NBAF site  (right click for full image)

As The Mercury helpfully pointed out the other day, this can only happen if the EIS is issued by December 21st, since Jay Cohen and the rest of the Bush appointees are out of a job on January 20th. What this means is that there will certainly be a pell mell rush to get the EIS out (meaning we’ll likely see as many glaring errors as we saw in the draft EIS) so that Cohen can make his selection.

Is it just me, or does this all seem simply ceremonial at this point? Can anyone really imagine that this monstrosity will move forward under an Obama administration? The whole war on terror, as we now know, is largely a ploy by the Bush administration to consolidate its power and enrich its groupies. Anyone who feels safer today than he or she did on September 10, 2001 is really living under the delusion that military might, applied indiscriminately, equals security. What we most certainly are today compared to then is a whole lot poorer as a nation.

Last I read, we’re something like $10 trillion in debt, are issuing checks to bank and auto dealers like it’s grand fun, and yet no one really seems to have a plan for stabilizing the economy other than some tired trickle-down shenanigans. We’ve also spent hundreds of billions of dollars on the actions in Afghanistan and Iraq, something that has been consistently downplayed, not least in the recent election. These expenses will likely cripple our government for years to come. In that fiscal climate, coupled with the fact that someone was just elected president who is not beholden (at least not entirely) to the military industrial complex, do we seriously think that the federal government is going to drop what would likely end up being billions to build a lab of this nature, anywhere? Even if they wanted to proceed, the environmental lawsuits that will surely spring up regardless of the site selected will deter even the most convinced or co-opted government bureaucrat.

What amazes and truly disappoints me is that these financial considerations will likely be the downfall of the NBAF. That’s a comforting thought, but it remains puzzling to me why anyone thinks it’s a good idea to build such facilities in populated areas, and in the case of Manhattan, within a stone’s throw of at least three existing or planned daycare facilities. That would seem to require a margin of error of absolute zero, something even the most pro-NBAF scientists cannot claim to be a realizable goal.