Humanity is at a crossroads and world history is being made in Maryland right now. This is the most important issue of our generation and definitely the most important thing happening in our state because it effects the whole world and the future of life on earth. The Bush administration has chosen one of two roads to follow with regard to biological weapons development. They have chosen to turn their backs on international treaties and take a pre-emptive, unilateral approach toward germ warfare. As a result, they will be launching a new biological arms race, resulting in worldwide proliferation of the most hideous of diseases, many of then genetically engineered in a brave new world of insanity. This cannot end in anything but calamity for life on earth. It cannot result in a balance of terror like the nuclear arms standoff because any one of thousands of laboratory workers can get access to a doomsday disease and sell it or use it. As the anthrax attacks show, once it is out, there is no control.
The "Manhattan Project" of germ warfare in Maryland is to be so big that the new buildings would comprise 75 football fields. Or, if put side by side, it would make a building one mile long and 250 feet wide, big enough to take an hour to walk around it. Ft. Detrick already uses a quarter of Frederick's public water from the Monoacy River filtration plant, which is overtaxed. Drilling new wells will be a hardship on everyone who depends on the aquifer, which is descending. It costs $10,000 to drill a 550 foot well and nearby Middletown had to drill 25 of them before striking water. Frederick is forced to consider taking water from the Potomac, 30 miles away , which is contaminated with the waste of 900,000 chickens in the Shenadoah Valley. Several years ago, DC issued a health advisory to boil water because of it. The new facilities will hire 1300 new employees, whose families will need new housing and water. Bioweapons contractors are expected to build nearby and draw in even more population.
VIA email and fax to:
Caree Vander Linden
USAMRIID Public Affairs
1425 Porter St.
Fort Detrick, MD
fax (301) 619-4625; e-mail Caree.Vanderlinden@us.army.mil.
Re: Comment to Scoping for Environmental Impact Statement on the proposed expansion of Fort Detrick's USAMRIID facilities.
I am submitting this comment in compliance with the notice of intent (NOI) of Feb. 3, 2006 sent by Addison D. Davis IV, Deputy Assistant Secretary of the Army.
I oppose the construction of the proposed new USAMRIID facilities at Fort Detrick in Frederick, MD. Below are 7 pages, signed at the end.
According to Supplemental Information, "The Army does not conduct offensive chemical or biological weapon research in any way." This is not true. According to Dr. Milton Leitenberg, a veteran arms control advocate and senior scholar at the University of Maryland's Center for International and Security Studies, germ warfare agents can be genetically modified and each modification may require a different vaccine or countermeasure. Since Fort Detrick's mission is to anticipate biological threats, USAMRIID plans to genetically modify diseases on which to test vaccines. This is a slippery slope to a bottomless pit of unlimited new diseases with no known cures, which could plague the earth till the end of time if they escaped containment by accident, smuggling or terror attack.
Also according to Supplemental Information, USAMRIID claims to be "firmly committed to compliance with both international and domestic law. This also is not true. In May of 2003, it was reported that the United States Army has developed and patented a new grenade that it says can be used to wage biowarfare. This is in explicit violation of the BTWC, which explicitly prohibits all development of bioweapons delivery devices. US Patent #6,523,478, granted on February 25th 2003, covers a "rifle launched non lethal cargo dispenser" that is designed to deliver aerosols, including, according to the patent's claims, "crowd control agents, biological agents, [and] chemical agents..."
In addition, there are strong indications that the strain of anthrax used in letter murders in 2001 originated at Fort Detrick. The investigation brought to light the secret U.S. program to produce weapons-grade anthrax. When in December of 2001, the U.S. Army admitted that it had manufactured "weapons-grade" anthrax, this was the first acknowledgement that the government had weaponized anthrax since the United States committed to banning biological weapons in 1969.
In 2001, the Bush administration rejected an effort by other BTWC signatories to conclude a protocol that would provide verification measures. At the time, the U.S.A. was the only country to favor terminating efforts to create a legally binding verification mechanism to strengthen the BTWC. As a result, USAMRIID's claim of compliance remains unverified.
So instead of violating international law as described above, I suggest that the U.S. obey the 1972 Convention on Biological Weapons and ratify the International Protocol on Inspection and Verification. That would be a better defense than creating offensive biological weapons.
Recall that the strain of anthrax used in the anthrax letters of 2001 was traced to U.S. government laboratories by the FBI, whose suspects have been employees of such labs. Because this was the only bioattack in our history, the proliferation of such labs does not logically portend to prevent biological attacks or increase national security. On the contrary, increasing the size and quantity of such labs logically increases the possibility of the only type of biological attack the U.S. has ever suffered.
Furthermore, labs containing pathogens for which there is no known vaccine or cure are a possible terrorist target. The claim by the Department of Homeland Security that dangerous pathogens would, in the event of an attack, be consumed in fire and therefore destroyed, rendering them harmless, is scientifically unsubstantiated. One can easily envision many scenarios of attack which would allow escape of virulent pathogens. For example, an explosive could cause a leak in containment without causing a large fire or a damaged container could continue to leak after a fire was extinguished. Damaged superstructure could collapse, causing leaks, after fires were put out. There are too many scenarios and variables for anyone to claim a failsafe containment for these doomsday agents in the event of an attack or accident. The safest plan is to reduce the size and quantity of such labs, not increase them.
An honest Environmental Impact Statement must address the above concerns or be in violation of EPA law. True homeland security requires this project to be suspended pending resolution of the following regulatory deficiencies.
The security of pathogens is an environmental issue. Insecure biological agents are the main threat to the environment.. I see 4 kinds of security issues:
1. How does USAMRIID plan to prevent the kind of mistakes that allowed anthrax to get into non-secure areas at Fort Detrick in April, 2002 and live anthrax to get mailed to California this year from a private lab in Frederick? If USAMRIID doesn't know how these things happened, how can the USAMRIID design countermeasures?
2. How does USAMRIID plan to prevent the kind of deliberate theft, murder and political extortion, like the anthrax mailings of 2001? Again, if the USAMRIID doesn't know how it happened, how can countermeasures be designed?
3. How does USAMRIID plan to prevent the kind of attacks that are commonplace in other places, that is, explosions from mortars, rockets, car bombs or suitcase bombs? Food and delivery trucks enter Ft.Detrick every day and are not searched. Employees' cars and ID's can be highjack and used to gain illicit entrance.
4. How does USAMRIID plan to prevent catastrophic accidents and calamities like typhoons, hurricanes, power failures, back-up power failures, natural gas explosions, fires or accidental plane crashes into the lab?
The pathways of agent escape are multiple and risky. The more labs, the greater the risk. Since the stated mission of the labs is biodefense, as described in the Supplementary Information, the insecurity presented by the mere existence of these labs may outweigh any presumed security benefits.
In the Supplementary Information sheet, USAMRIID claims "expertise to safely conduct critical biomedical research." How can USAMRIID claim that in light of the anthrax release into the halls and administrative areas at Fort Detrick on April 2002? The cause has not yet been explained. Where are the results of the investigation? This release happened after the procedures were tightened up since the anthrax letters of 2001, which does not elicit confidence in USAMRIID's claims of safety expertise. A prudent procedure would require that the present process of planning be put on hold until past errors are analyzed and methods to prevent repeated errors are developed.
The Supplementary Information estimates that 1,300 people will be employed upon completion of Stage 2. If far fewer employees were not able to prevent the April 2002 anthrax release or the smuggling of the anthrax strain used to attack Congress and the media in October of 2001, why should we have any confidence in the abilities of even more employees?
1. Will all personnel with access to high security areas, including management, and their relatives be required to divest themselves of all stocks in pharmaceutical companies to avoid conflict of interest? After the anthrax letters of October 2001, millions in profits were garnered from vaccine sales. The motives of the perpetrator(s) have never been determined, but criminal profiteering is one of the theories.
2. Will the process of "revolving doors" be abolished? No less a conflict of interest than stock incentives is the process similar to Dick Chaney going from Holliburton to government and then possibly back to Holliburton again. When I raised this concern at the open meeting called by Col. John Ball, Commander at Fort Detrick, on October 26, 2005, he and other employees dismissed my suggestion, saying "How can you deny peoples' right to change jobs?" My answer is, yes, for the national interest (if not human survival) some freedoms must be limited. Doesn't the Patriot Act limit some of our freedoms (with far less of a cause, in my opinion) for presumed security? The person who released the anthrax letters may well have taken pathogen strains from Fort Detrick to a private pharmaceutical lab, where it was grown, perfected and released, creating a scare which profited them millions. If USAMRIID is not willing to abolish "revolving doors," these labs should not be built. Insecure germ war labs are a threat to homeland security, not to speak of human survival.
3. Will personnel screening reject those, including management, with duel citizenship, indicating divided loyalties and possibly hidden agendas? Such individuals should be prohibited access to high security areas, even if they are given clearance from the White House. Political criterion should be prohibited from influencing which country might have access to weapons of mass destruction for temporary political advantage, but which will threaten human security in the long run by allowing pathogens to be sold or given to yet other countries, causing proliferation and instigating a biological arms race. In a regime change, such weapons may come back to haunt us, if not the whole world. Don't forget that the chemical weapons Saddam Hussein used on Kurds and Iranians were given to him by the United States when the latter was helping Iraq against Iran. It must be made illegal and physically impossible for even any U.S. president to "look the other way," while an agent of an ally steals pathogens from a U.S. germ war lab. Even the president can be prosecuted for law breaking. If the USAMRIID is not willing to recommend such an ironclad bill to Congress and see it pass, these labs should not be built.
5. Will personnel screening reject religious zealots? If not, the level 3 and 4 biolabs should not be built and the existing ones be shut down. Whether religious fundamentalists are Muslim, Jewish, Christian, Hindu or something else, it is lunacy to allow their access to weapons of mass destruction. While Islamic fanatics are getting the most attention right now, Zionist zealots are equally dangerous. Zionist "sleepers" working in the United States may feel it their duty to give biological weapons to Israel or to Zionist vigilantes, under the belief that God gave Palestinian land to the Jews. Thousands of US citizens fall in this category. Defining who is sufficiently Zionist may be an impossible task, indicating once more that the mere existence of these labs is dangerous. The U.S. can be stampeded into ill-advised war by a foreign agent blaming a biological attack on their enemy.
Of all the religious zealots to fear, the Christians are the worst without a doubt. Why? Because while the Muslims, Jews and Hindus are fighting merely over territory, tens of thousands of Christian fundamentalists believe in the biblical prophesy of Revelations. They believe it is God's prophesy that the Anti-Christ will attack the Jews at Armageddon, bringing "tribulation" and the "end times," when all humanity will be exterminated, except for the born-again Christians, who will ascend into heaven on the day of "rapture" and witness the second coming of Jesus. If you think these are just a few kooks, you have not been paying attention. President Ronald Reagan was such a believer and ironically we may owe our survival to Mikhail Gorbechev. But it is getting worse. There are a dozen volumes of the "Left Behind" series promoting the "end times," which has sold over 60,000,000 copies around the world. Can you imagine someone at Fort Detrick who may believe it is his God-given duty to help bring on the second coming of Jesus?
The question arises: will USAMRIID screen out all religious fundamentalists from every level 3 and 4 biolab under US control? How would we define who is fundamentalist enough? How could we identify existing personnel who later converted to the Revelations belief? I submit that not only is it illegal to discriminate by religion, requiring a Constitutional amendment to change, but it is impossible to police. This is yet another reason not to proliferate level 4 biolabs.
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At the open meeting called by Col. John Ball, Commander at Fort Detrick, on October 26, 2005, he described "assess control, agent accountability, biosurity, and security." His description of these procedures were not adequate to guarantee that pathogens cannot be smuggled out of the laboratories. Even though personnel may be within the view of cameras, and required to leave work clothes and walk through a shower in the nude before changing into street clothes, there was no procedure described to prevent the smuggling of agent in containers hidden in body cavities. This is a no-brainer. There are thousands of baggies of illegal drugs being transported in this country every day by this method. A biolab smuggler would only have to take a dose of Cipro to protect himself from infection if a baggie leaked. Unless the USAMRIID is prepared to do daily body cavity searches on every person, management included, leaving a level 3 or 4 biolab, these labs should not be built.
Hopefully the rules will require 2 people to be present at every access to pathogens. Such a "buddy system," however, cannot be counted on to be operational every minute of the work day. In spite of the rules, they are sure to be broken when a partner needs to go to the rest room, answer a phone or attend another diversion. Rush jobs, under staffing from absence, or accidents will occasionally require personnel to be alone with pathogens. That is when they can be stolen and smuggled out. Since several persons are to be cleared for access, any missing agent cannot be proven to be the action of a particular person.
The buddy system must absolutely be engaged whenever a freezer or refrigerator is accessed. However, an "up-to-date" inventory is still not failsafe. A lone person, while not observed, could switch containers or contents, and put the decoy back in the cooler and smuggle the real stuff out. Missing agent can be grown and replaced so a theft may not be noticed. Would complete inventories be carried out every day, complete with virulence testing? If so, that would take all day and nothing else would get done. Regardless of elaborate procedures, it is impossible to guarantee that a rogue person could not repeat something like the anthrax attacks of October 2001 or much, much worse.
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Concepts of Security and Environmental Risk at Ft.Detrick
Security in general, and at Ft.Detrick in particular, is partially and necessarily an environmental issue. Any attempt to separate security from an environmental analysis is disingenuous, unscientific, illogical, cynical, undemocratic and potentially a threat to total security, including its public health and the environmental aspects.
According to the Random House College Dictionary, "security" is defined as "freedom from danger, risk, etc.; safety." and "environmentalism" is defined as "protect[ing] the air, water, animals, plants and other natural resources from pollution or its effects."
Philosophically and practically, there is both a harmony and antagonism between security and environmentalism. That is because security has two aspects, one harmonious to the environment and the other antagonistic. The military aspect of security, both defensive and offensive, is almost always antagonistic to the health of the environment in one way or another, even if it may be a lesser of evils, the greater evil being potentially hostile threats, usually but not necessarily by a foreign enemy. It is possible, however, that security measures can be more of a risk than the hostile threat. In any event, the "freedom from danger, risk" aspect of security is harmonious to environmental concerns and cannot be logically separated from them.
The public is correct to repudiate any definition of "security" which would ignore the environmental impact of terrorism, either domestic or foreign, from analysis in an EIS (environmental impact statement). Likewise, the public is justified in participating in a comprehensive analysis of the procurement, modification, containment and security of biological agents at Ft. Detrick.
As the Dubai Ports World and Dundalk LNG (liquefied natural gas) terminal controversies indicate, the public may have a better idea of national security and local security than elected officials. Just as in those examples, it is important that economic pressures do not overwhelm the need for real security, both national and local. Too often, corporate and bureaucratic power trumps the peoples' will. Democracy demands the opposite.
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In summary and conclusion:
Whereas, the anthrax letters of 2001 were the only biological attacks against non-native Americans in US history, and
Whereas, there are economic and political incentives for employees to repeat similar attacks or to sell pathogens, and
Whereas, there are military incentives for zealots and misguided "patriots" to give pathogens to other partisans, and
Whereas, it is impossible to screen and control biolab personnel adequately, and
Whereas, these labs will incite proliferation and a biological arms race, and
Whereas, several pathogens have no vaccine or cure, and
Whereas, said pathogens can kill millions of people, and
Whereas, the only germ attack in the U.S. was an "inside job" and
Whereas, an explosion, deliberate or accidental, cannot be proven to destroy pathogens, and
Whereas, the USAMRIID biolabs have been in violation of the 1972 Convention on Biological Weapons, and
Whereas, the Environmental Impact Statement must address each and every point above or be in violation of EPA requirements, USAMRIID is challenged to prove all the above statements to be absolutely false or be derelict in their duty to protect the homeland, not to speak of promoting human survival.
Accordingly, I recommend that the proposed expansion of biological research labs at Fort Detrick be denied as the most protective plan for public health and homeland security.
Richard J. Ochs