Hello, If you have additional questions about the issues with this permit, please don't hesitate to contact me to discuss it. Thanks. Steve Veysey Conservation Co-chair 515-232-4635 (home) 515-294-5805 (work) At 02:53 PM 2/5/2007, you wrote: >Story County members may be interested in this message from the Iowa >Environmental Council. The hearing is this Thursday at 7 p.m. at the >Story City City Hall Council Chambers. > > > >PUBLIC HEARING > >Story City Wastewater Discharge Permit > >7:00 pm, Thursday Feb. 8, 2007 > > > >The Iowa Environmental Council provided comments to DNR on the draft NPDES >permit for the City of Cedar Rapids Wastewater treatment plant in a letter >dated November 20, 2006. As part of our comments we requested that DNR >hold a public hearing to discuss this permit. The hearing is scheduled >for 7:00 pm on Thursday February 8th at the Story City, City Hall, 504 >Broad Street, in the Council Chambers. > > >The South Skunk River in Story County is designated for primary contact >recreation (class A1) and significant resource warm water (class >B(WW-1)). The segment of the South Skunk River that receives the Story >City discharge is also listed on Iowa's 2004 Impaired Waters List or the >303(d) list as impaired by bacteria. The proposed permit includes a >compliance schedule for preparation and testing of the plant's existing UV >disinfection equipment and the fecal coliform bacteria limits in the >permit must be met by the beginning of the 2007 recreation season on March >15, 2007. > >The Council supports this compliance schedule and is glad to see that the >fecal bacteria contamination from the Story City wastewater will no longer >be allowed to contribute to the impairment of recreation uses in the South >Skunk River. However, the Council has serious concerns about the proposed >increased limits in the permit for biochemical oxygen demand and ammonia >and the impact these increase may have on the aquatic life in the South >Skunk River. > > > >Following is a summary of our major concerns with the permit: > >1. The proposed permit would allow substantial increases >in permit limits without complying with antidegradation or >anti-backsliding requirements of the Clean Water Act. Increases in the >biochemical oxygen demand may lower the amount of oxygen in the water that >fish and other aquatic life need to survive and increases in ammonia could >be toxic to sensitive aquatic life downstream of the discharge. These >increases are proposed without explanation as to why they are necessary or >whether alternatives are available. The proposed effluent limits would >allow the City of Story City to more then triple their daily maximum >ammonia discharge for the months of March through December and nearly >double allowable ammonia discharge in January and February. The 30-day >average limit for Carbonaceous Biolochemical Oxygen Demand (CBOD) for July >and August is proposed to be increased from 13 parts per million to 20 >parts per million. Ammonia is toxic to many species of aquatic life and >is particularly toxic to freshwater mussels. In fact, the U.S >Environmental Protection Agency is currently re-evaluating its ammonia >criteria because new research shows that the existing criteria are not >protective of mussels.1 > >2. The DNR must ensure that the Story City permit >protects mussels and other aquatic life in the South Skunk River >downstream of the discharge. The South Skunk River and other rivers in >Iowa once supported a healthy population of freshwater mussels, but recent >surveys have shown that mussel populations in Iowa rivers are in serious >decline. As noted on the DNR website "A dozen of the 50 or more known >mussel species are gone; extirpated from Iowa waters. Another 15 are on >the endangered or threatened species lists. The rest are not far >behind."2 State and federal agencies and concerned citizens are taking >urgent measures to document and protect any remaining species in Iowa >rivers such as the South Skunk River before they disappear.3 Locally, the >"Skunk River Navy," comprised of ISU students and faculty, regularly >conduct water quality assessments and monitor populations of freshwater >mussels in the Skunk River.4 > >3. DNR must improve their permit process to adequately >account for uncertainties and a margin of safety and to prevent further >degradation of water quality. The DNR's policy appears to be that the >most defensible permits are those that calculate the maximum quantity of >pollutants and toxics that could theoretically be discharged, with no >margin of safety. This approach ignores important factors or >uncertainties that could lead to acute and chronic toxicity in the South >Skunk River and does not take into consideration protection of sensitive >species such as freshwater mussels. The DNR is currently working with the >Council to improve the antidegradation rules and implementation >procedure. These rules are currently scheduled to be finalized in January >to March of 2008. The Council appreciates DNRs efforts to correct these >procedures, however, we are not prepared to stand by and allow clearly >deficient permits such as the Story City permit to go into effect before >Iowa's program is fixed. > > >References: >1 U.S. EPA Ammonia Criteria Re-evaluation ><http://www.epa.gov/waterscience/criteria/ammonia>http://www.epa.gov/waterscience/criteria/ammonia > >2 Joe Wilkinson, Search for Endangered Mussels (Sept. 26, 2006 ><http://www.iowadnr.com/news/06sep/mussels.html>http://www.iowadnr.com/news/06sep/mussels.html > >3 U.S. Fish and Wildlife Service ><http://www.fws.gov/midwest/mussel/index.html>http://www.fws.gov/midwest/mussel/index.html > >4 Skunk River Navy ><http://www.las.iastate.edu/newnews/skunkriver0925.shtml>http://www.las.iastate.edu/newnews/skunkriver0925.shtml > >From: <mailto:[log in to unmask]>Susan Heathcote >Sent: Monday, February 05, 2007 2:33 PM >Subject: Story City Public Hearing > >Attached is a fact sheet on the Story City permit hearing scheduled for >this Thursday evening Feb. 8th at 7:00 pm. The hearing will be held in >the Story City, City Hall, in the Council Chamber. Please spread the word >to others who you think would be interested in attending. > >*Please note new email address below* >After Dec. 1st, email will no longer be forwarded from my old >earthweshare.org address > >Susan Heathcote >Water Program Director >Iowa Environmental Council >711 East Locust St. >Des Moines, IA 50309 >phone: 515/244-1194 ext. 12 >fax: 515/244-7856 ><mailto:[log in to unmask]>[log in to unmask] >http://www.iaenvironment.org > > >- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - To >unsubsribe from the IOWA-TOPICS list, send any message to: >[log in to unmask] Check out our Listserv >Lists support site for more information: >http://www.sierraclub.org/lists/faq.asp - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - To unsubscribe from the IOWA-TOPICS list, send any message to: [log in to unmask] Check out our Listserv Lists support site for more information: http://www.sierraclub.org/lists/faq.asp