April 16, 2021

Dr. Catharine Varley

BRAC Environmental Coordinator
Air Force Civil Engineer Center
2261 Hughes Avenue, Suite 155
JBSA Lackland, TX 78236

Dear Dr. Varley,

On behalf of the Michiganders, businesses, organizations, and individuals and organizations from around
the nation, we are writing to provide comment on the Air Force’s proposed Interim Remedial Action
(IRA) plan for Clark’s Marsh.

While we acknowledge the work that has gone into producing the IRA, the alternatives proposed in the
plan fall short of the expectations of the community of Oscoda, and the Air Force’s resistance to include
community voices in the process when alternatives were being actively developed and evaluated has
resulted in a plan that does not center the concerns and local knowledge available in the Oscoda
community.

In short, the IRA plan being proposed does not provide an alternative that will adequately address the
full extent of the imminent and substantial threats to human health and the environment from PFAS
contamination coming into and out of the Clark’s Marsh area, falls short of acknowledging the full scale
of the problem, and will not do enough to protect the health of families in Oscoda. Specifically, the Air
Force has focused in on one narrow plume area, leaving out adjacent PFAS plumes for capture, and has
wrongly chosen to ignore Michigan’s PFAS clean-up standards as the standards for the project.

The Air Force must immediately and fully clean up the imminent and substantial threats to human
health, fish, wildlife and the environment from PFAS contamination in the Clark’s Marsh area,
including implementing additional interim actions to address all PFAS contamination plumes in the
area. While alternative 3 proposed in the Clark’s Marsh IRA plan should be implemented, the IRA for
Clark’s Marsh does not adequately address the imminent and substantial threats to human health,
wildlife and the environment from PFAS contamination in the Clark’s Marsh area. In short, the number
and the location of extraction wells do not capture the PFAS contamination in the Clark’s Marsh area to
adequately address the imminent threats. Therefore, we urge the Air Force to adopt the revisions to
alternative 3 being proposed in separate technical comments by community RAB members and
community voices.

Additionally, we urge the Air Force to comprehensively test and monitor the effectiveness of its clean up
system now and into the future. Any clean up system expanded or installed at the site must be able to
illustrate its effectiveness consistently in the removal of PFAS contamination from the
environment. Just as importantly, the remedial investigation must include a comprehensive accounting
of all PFAS contamination flowing into and out of the Clark’s Marsh area, and throughout the site, and
tangible steps for eliminating or treating future contamination.

It is clear, based solely on the comments during the Air Force’s town hall introduction to the plan on
March 24, 2021, that the community does not agree that what is being proposed for this site is
adequate to clean up the imminent and substantial threats to human health and the environment from
PFAS contamination in the Clark’s Marsh area. Perhaps most concerning is both the Air Force’s refusal to
comply with the state of Michigan’s new PFAS drinking water standards (which also serve as
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groundwater cleanup criteria) or the state’s longstanding surface water PFAS standards for this IRA. In
2017, the Air Force promised, in writing, to comply with Michigan’s groundwater surface water interface
(GSI) standards at Wurtsmith (and at Clark’s Marsh in particular) – with the release of the first interim
clean-up plan, the time has come to honor that promise and to honor the laws made to protect the
health of Michiganders.

The Air Force must comply with the PFAS drinking water standards recently set by the state of Michigan
and Michigan’s groundwater surface water standards when undertaking any clean up action at
Wurtsmith. As the Air Force stated in the March 24 town hall meeting, it “will probably” comply with
state law during the next phase of clean up and has the technology to currently meet Michigan’s
standards. With both the will and the means, there is no reason for delay as the longer we wait, the
more PFAS that leaches into the environment and threatens the community.

PFAS contamination flowing through Clark’s Marsh is a threat both to people and to the fish and wildlife
living in the area. Clark’s Marsh currently has in place three consumption advisories (for fish, deer, and
all other aquatic and semi-aquatic wildlife) the most, to our knowledge, of any area in the country for
PFAS contamination. PFAS contamination from the base is flowing through Clark’s Marsh and into the
Au Sable River - a renowned destination for fishing, the Huron Manistee National Forest - a crown jewel
of Michigan’s public lands system, and discharges into Lake Huron, a source of drinking water for
millions of people in the United States and Canada, as well as the drinking water source for Oscoda’s city
water.

These advisories and the clear impacts to drinking water and natural resources are another indicator
that we cannot delay in taking comprehensive clean up action – the longer we wait, the more PFAS will
be released into the environment, exposing people and wildlife. And most importantly, clean up actions
that do not address the full scope of the contamination will only compound the real time threats to
peoples’ health and the local economy.

Preventing PFAS migration from the base sooner rather than later will minimize the ongoing release of
these dangerous chemicals to the community and the environment. PFAS are migrating off-base at
levels above state criteria across nearly half of the base boundary. This contamination needs to be
hydraulically controlled as soon as possible through multiple IRA’s, and as new PFAS technologies
become available they can be implemented to further address the problem.

Finally, the Air Force must open its clean up development process at the front end to include input by
community voices. Specifically, community RAB members who are designated by the Air Force as
representatives of community voices must have access and a say in plans prior to being released to the
public for comment. These community RAB members provide invaluable local knowledge, experience
and input based on past history and present day conditions that would not be otherwise available to the
Air Force or it's sub-contractors. Only by doing this will the Air Force actually put together alternatives
that take community voices into the planning conversations. Impacted residents must have a seat at the
table in a process that has direct implications to their health, their livelihoods, their community and
their way of life.

The repercussions of the decisions made for the Clark’s Marsh IRA are a bellwether for future success at
Wurtsmith, and we urge the Air Force to listen to the straightforward and attainable requests from
Oscodians and Michiganders to take comprehensive, inclusive action for clean-up now.

Sincerely,

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NOW Need Our Water Leadership
Cathy Wusterbarth
NOW Co-Lead, Cedar Lake resident, Oscoda Township Planning Commission

Greg Cole
NOW Co-Lead, Coles Lakefront Cottages and homeowner on Van Etten Lake
Van Etten Lake Dam Operator

Anthony Spaniola
Attorney and Van Etten Lake homeowner

Dave Winn
Van Etten Lake homeowner

Robert Delaney
Geologist and veteran DEQ/EGLE specialist

Bill Palmer
Van Etten Lake homeowner, Oscoda Township Trustee

Wurtsmith AFB Restoration Advisory Board

Mark Henry
Arnie Leriche
Cathy Wusterbarth
Joe Maxwell
Dave Winn
Daniel Stock
Greg Schulz
Jerry Schmidt
Rex Vaughn
Scott Lingo
William Gaines
Ryan Mertz

Organizations

Joe Hemming Hope Grosse and Joanna Stanton

President Founders
Anglers of the Au Sable Buxmont Coalition for Safer Water

Emily Donovan Mary Brady-Enerson

Co-founder Michigan Director
Clean Cape Fear Clean Water Action

Laura Olah Shaina Kasper

Executive Director Water Program Director
Citizens for Safe Water Around Badger Community Action Works

3
Kyle Rorah Rebecca Meuninck, Ph.D.
Regional Director of Public Policy Deputy Director
Great Lakes/Atlantic Region Ecology Center
Ducks Unlimited
Stel Bailey
Howard A. Learner Executive Director
Executive Director Fight For Zero
Environmental Law & Policy Center
Liz Kirkwood
Scott Faber Executive Director
Vice President for Governmental Affairs For Love of Water (FLOW)
Environmental Working Group
Sue Phelan
Rebecca Fedewa Director
Executive Director GreenCAPE
Flint River Watershed Coalition
Edward L. Michael
Jill M. Ryan Government Affairs Chairman
Executive Director Illinois Council of Trout Unlimited
Freshwater Future
Cynthia Schwedler
Brad Jensen Communications Co-Chair and Trustee
Executive Director Iosco County Democratic Party
Huron Pines
Charlotte Jameson
Peggy Case Program Director- Legislative Affairs,
President Energy, and Drinking Water Policy
Michigan Citizens for Water Conservation Michigan Environmental Council

Lisa Wozniak Ian FitzGerald

Executive Director Policy and Special Events Coordinator
Michigan League of Conservation Voters Michigan United Conservation Clubs

Gene Kirvan
President
AuSable River Chapter
Michigan Salmon and Steelhead Association

Ayesha Khan Mike Shriberg

Co-founder Regional Executive Director
Nantucket PFAS Action Group Great Lakes Regional Center
National Wildlife Federation
Tim Kellstrom
Board Member Oscoda Township Board of Trustees
Oscoda Convention and Visitors Bureau
AuSable Township
A. J. Birkbeck
Managing Director Oscoda Rotary Club
4
PFAS Alliance

Russell Williams
Chairperson
Pine River Van Etten Lake Watershed

Andrea Amico Tammy Velten

Co-Founder Board of Directors
Testing for Pease Villages of Oscoda Homeowners Association

Lisa Patrell Kristen Mello

Co-Founder Director
WASHTENAW350 Westfield Residents Advocating For Themselves
WRAFT

Monica Lewis-Patrick Diane Lembck

President and CEO President
We The People Of Detroit Wisconsin Metro Audubon Society

Mark Henry HealthQuest Oscoda Michigan

WAFB C-RAB co-chair
Wurtsmith Community Restoration Advisory Board

Madeleine Foote
Deputy Legislative Director
League of Conservation Voters

Cyndi Roper
Michigan Senior Policy Advocate
Natural Resources Defense Council

Businesses

Aaron Peterson Vince Iler

Owner Ausable Hardware Store
Aaron Peterson Studios

Ian Bund Beth Price

Angell Farm LLC Owner
Beth Price Photography
Joe Maxwell
Oscoda Business Owner Richard Dinnon
Cathy’s Hallmark Dinon Law, PLLC.

David Kranker Matthew Desmond, Principal

Owner Zachary Liggett, Principal
David Kranker Creative Desmond Liggett Wealth Advisors

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Ryan Enderle, CEO Jim Dennis, PGA
Infinity Operations LLC Resident and Owner
Jim Dennis Golf Shop, Inc.
Gene Kirvan
President Peter Laing
Lake Huron Sportfishing Inc. Managing Member
MAWBY Vineyards and Winery

Elizabeth McNicholas, AIA

Principal Robert Kerr
McNicholas Architects | MGLM President
Metro Group Architects
Ken Pargulski
Owner
M-36 Coffee Roasters

Gary and Tess Nelkie Juliette King McAvoy

Owners Kind Orchards
Nordic Sports

Victor Pytko Keith W. Cooley

Owner CEO
One-Eyed Bear Productions Principia, LLC

Beryl Skrocki Jimmy Banish

Owner Partner, Chief Operations Officer
Sleeping Bear Surf and Kayak The Bear Factory

Karen Tracey Mark Constance

President and Creative Director Publisher
The Image Shoppe Up North Voice

Pete Kirkwood Larry Bell

Founder Bell’s Brewery
Workshop Brewing Company

Individuals
Affiliations listed for identification purposes only

Denise M. Bryan, MPA

Health Officer
District Health Department No. 2

Donna Tingley
Resident
Van Etten Lake, Oscoda Township

6
Janis Bobrin
Board Member and Immediate Past President,
Michigan League of Conservation Voters

Leanne Chadwick
Great Lakes Regional Director of Philanthropy and Partnerships
National Wildlife Federation

Michael Bristow
Resident
Bay County Bangor Township

John F. Holly
Colonel USAF (retired)

Arnold Leriche (Retired)

USEPA Environmental Engineer and Army Veteran
Resident of Oscoda, Michigan

Catherine Gavin-Larive,
Realtor and Community Member
Zoning Board of Appeals Chair Oscoda Township
Northeast Michigan Board of Realtors Director

Kory L Larive
Community Member and Retired GM

Laurence Curley
Former Resident

Thomas W Ponder CMSGT [Retired}

Seasonal Resident 40 Years

Rex Vaughn
Local Residential Property Owner

Marjorie Harrison
UM retiree
AuSable Homeowner

Robert Delaney
PFAS Alliance, Need our Water

Kathy Hough
Resident

Amanda Bergeron
Community member, Oscoda, MI

7
Chris Coulon
NOW member
Board Member of Oscoda Citizens for Clean Water

Lt Paul Cotter (ret)

Worcester, MA Fire Department

Diane Cotter
NPCC Leadership Team, Firefighter PFAS Advocates
Founder, Your Turnout Gear and PFOA

Robert Kennedy
Resident, Harrisville, MI

Denise Trabbic-Pointer
CHMM Emeritus
Sierra Club - Michigan Chapter
Volunteer: Toxics and Remediation Specialist

Scott Moore, Ph.D., Ed.S., MPA

Oscoda, MI Resident

Thomas A. Buhr
Resident

Kathleen Lawrence, MPH

Clinical Research Coordinator
Michigan Medicine

Stephen C. Brown, PhD

Chairman, Ann Arbor Environmental Commission
Chairman, Conservation Committee of the Huron Valley Group, Michigan Chapter, Sierra Club

Elizabeth Collins
Resident of Ann Arbor
Secretary of Coalition for Action and Remediation of Dioxane

Kathryn McKenzie
Member
Douglas County Land Conservation Committee

Katie Moriarty, PhD, CNM, CAFCI, FACNM

Faculty
Frontier Nursing University

Shelly Asiala, PharmD

McCann Health Medical Communications

Sarah Hendricks BSN, RN

University of Michigan
8
Elaine G. Chottiner, M.D.
Health Leaders Fellow
The Ecology Center

Madeline Mehall
Health Leaders Fellow
Ecology Center

Teresa Kay
Resident, Cedar Lake

Gary and Tess Nelkie

Residents

Michael Burns
Cedar Lake Association Member

Gary Drainville
Resident

Larry Carpenter
Lead at Cedar Lake Next Door

Marguerite Adelman
Team Leader
Women's International League for Peace and Freedom (WILPF) Burlington, VT Branch

Charles Kowalski
Resident
Cedar Lake, Oscoda Michigan

Becky Johnson Himes, DNP, RN

Assistant Professor
Ferris State University

Bryan Casey
Cedar Lake Association Member

Michael Leither
Home owner Cedar Lake

Dr. Donald Ellis III and Danielle Ellis

Residents

Tom and Mary Coulon

Ausable resident
9
Matt and Connie Cleary
Oscoda Resident

Gwen Thayer Handelman

Member, Wolfpack Leadership Team
Ann Arbor MI

Stephen Foy
Cedar Lake Association (AICLA)

Shane & Roxanne Ratliff

Members of Cedar Lake Assoc.

Mark Biggers
Retired resident

Judy Biggers
Real Estate One

Ann Victoria Hopcroft

Attorney at Law, HOPCROFT LAW PLC
Oscoda resident

John A Novak
Colonel, USAF, Ret

Greg Laube
Member of Cedar lake association

Kathy Elliott
Cannon Air Force Base

Annette Dennis
Resident
Oscoda MI

Mary Mertz
Oscoda Resident

Celeste Creger
3rd generation Van Etten Lake, Oscoda MI.

Bill Palmer
Oscoda Township Trustee
Oscoda Township Board

10
David Slaggert
Resident

dona John
Resident

Jennifer & Jason Hill

Homeowners & Seasonal Residents
AuSable Point Road, AuSable Township

Tony Wesenberg
Cedar Lake Association Member

Deb Wesenberg
Cedar Lake Association Member

Elyssa Steward
NOW member, Treasurer for Oscoda Citizens for Clean Water
Miss Mermaid Michigan 2021

Amber L. Brewer
U of M School of Public Health
Accelerated Master of Science Candidate- Environmental Health Sciences

Art Schaap
Clean Water Partnership-Cannon Air Force Base (New Mexico)
Highland Dairy

Christopher Wayne Clark

Westfield Residents Advocating for Themselves

Jeffrey Matthews
Choice M Canoe Racing

Lisa Sikoski
Educator
Cedar Lake Association Member

Victoria Targosz
Van Etten Lake homeowner

Michael E. Hye
K.I. Sawyer-Hazardous and Toxic Exposure group

11
Alex and Sarah Coulon
Michigan residents

Parker Cleary
Oscoda High School Senior

Rozanne Curley
Daughter of Harry Curley "Mr. Ausable Canoe Race"

Mark Bigham
Veterans and Civilians Clean Water Alliance

Mark Claeys
Veterans and Civilians Clean Water Alliance

Imse Ockey
Van Etten Lake resident

Scott Somers

Casey Reitler

Jennifer Otterness Humphreys

Teresa Landino-Edelman

Robin Savage
Oscoda resident

Kelly Brown
Cedar Lake resident

Cari Travis

Kelly Jones

Robert and Devon Tasior

Oscoda residents

Jeffery Linderman

Jessica Hansen

Carley Rae Powroznik

12
Steve Burrows

Sarah Wusterbarth

Sandy Wynn-Stelt

Dave Iller

Justin Griffith
Ausable River canoe marathon volunteer

Vicki Quint

Jodi Breault

James Michael Bussey, Retired Sr Airman

Veterans and Civilians Clean Water Alliance

Jazmin Fulkersin

Jane Adams

Tim Cummings

Damon Lilley

Carole Bleau

Lora Greene

Laurene Allen

Andy Laporte

Renee Marchwinski
Cedar Lake resident

Helen A. Mailloux

Joe Davio

Ruben Flores
Cedar Lake resident

Craig Minor (Ret Lt Col USAF)

Author Mitchell’s Memoir and Wurtsmith Water

13
Carrie Minor

Grace Minor Becknell

Julie Aragon

Jacob Aragon

Siearra Wright

Jeff Gottlieb

Martha Gottlieb

John Roach

Kristina Waldmann

Elaine Grejda

Beth Wallace

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