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: Susan Heathcote<mailto:[log in to unmask]> 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 [log in to unmask]<mailto:[log in to unmask]> http://www.iaenvironment.org<http://www.iaenvironment.org/> - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 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