GUEST OPINION by Manuel Parada
The following is a letter that was sent to Sen. Martha Bark (R-8th) by Manuel Parada of Parada & Associates, Columbus, regarding legislation concerning private well testing.
I am writing you today to alert you to a potential legislative move on the part of Acting Governor (Richard) Codey that can have devastating effects on a large number of your constituents.
You may be aware of possible legislative revisions to the law commonly referred to as the "Private Well Testing Act". I urge you and Assemblymen Chatzidakis and Bodine to strongly oppose theses legislative changes before they even make it to the State House floor.
These changes are attempting to force all private well owners into expensive ($650 per test in 2002 dollars according to NJDEP) testing and treatment and is based on a very weak scientific basis. This is an unfunded mandate from Trenton with potentially devastating fines if a homeowner does not fully comply.
I have been a water industry professional for nearly 20 years, having served the industry as a regulator, utility operator and as a consulting engineer. In our industry, we take the quality of water delivered to the public in the highest regard. We spend hundreds of millions of hours and dollars on research to determine the acceptable levels of drinking water standards that have become the envy of the rest of the world. As an industry, we develop a series of water quality standards that are based on these millions of research hours. This research is extremely meticulous and meets the highest standards of peer review before being published and set into our drinking water regulations.
To put the research into lay man’s terms, we are charged with determining how much of a particular contaminate is considered unhealthy. To establish these levels in any given contaminant, we establish a minimum threshold that must be met by the contaminant.
For example, a common degreasing agent known as Tri-chloro ethylene (TCE) is found in many ground water supplies throughout the state of New Jersey. TCE is known to cause cancer in some people at a certain amount of exposure to the chemical. In some people that level of exposure is very small, in others, massive quantities of the chemical have no harmful effects at all.
The water industry tackles this issue by taking a very large sample size, usually one million people, and determining at what exposure level will this chemical increase a small portion of the population’s risk of developing cancer by a set percentage over a long period of exposure. The threshold might ultimately read that 70 people out of one million can have a one in 1,000 increased chance of developing cancer over a 70 year exposure at a concentration of 1 part per billion of TCE.
This research led to the development of a series of federal and state drinking water regulations, mostly notably the Clean Water Act of 1972, and its amendments in 1986. The regulations are based on hard science and research and are applicable to all public drinking water supplies. The reason is that a single utility may serve millions of people with essentially the same water supply, and therefore the size of the population is similar to the sample size selected in the research.
The rules and regulations do not apply to a private well owner because there is no scientific basis to apply the drinking water research to a sample size of one family. The sample size is simply too small to make an effective judgment on the water quality parameters. This would be akin to selecting one person to poll prior to an election and predicting the winner of the election based on the one person’s opinion. The statistical sample size is just too small to make a prediction.
New Jersey took it upon itself to pass the Private Well Testing Act in 2002 that regulated the sampling requirements for a private well only when a real estate transaction is completed that involves a private well. Now, Acting Gov. Codey has made some initial inquires into re-vamping this Private Well Testing Act, despite it having no scientific basis. These revisions to the Act, if passed, will require that all private well owners, (there are approximately 255,000 private wells in New Jersey, mostly in rural areas) test their water supplies regularly and then be forced into treatment if the testing results are not on par with the large water utilities that serve the vast majority of the state.
This requirement will not only force a good portion of your constituency into expensive and unnecessary testing, it may also result in the spending of thousands of dollars to clean up a problem that doesn’t exist or can otherwise be dealt with. The fact is that the private well owner has choices. If you do not like the quality of your well water, purchase bottled water (which by the way remains mostly unregulated in its quality standards).
Why is the government once again interfering with my quality of life? I live in an area that does not have public water and sewer, and I openly chose to live there. I wanted an area that does not have public water or sewer. Now a new layer of government wants to impose unscientific standards on my well water and force me into expensive testing and even more expensive treatment and fines of $1,000 a day if I don’t comply.
A wise man once said, "Just be happy you don’t get all the government you pay for". Well, this is one government bureaucracy that we definitely don’t need or want. Please keep Acting Gov. Codey and his henchmen at the NJDEP out of my house. I think I might have a better idea what is good for me and my family than they do.