YOUR ATTENDANCE AT THE AUGUST 30, 2022 PUBLIC HEARING AND WRITTEN COMMENTS TO TDEC ARE CRITICAL!
THE HARPETH RIVER IS STILL IMPAIRED, BUT THE DRAFT PERMIT DOES NOT REQUIRE REDUCTION OF POLLUTANT DISCHARGES
POLLUTION REDUCTION PLAN IS NOWHERE NEAR FINISHED AFTER SEVEN (7) YEARS!!
Use our Petition Tool to submit comments about the draft permit by September 9th at 4:00 pm. We encourage you to add your own comments or experiences on the Harpeth by following the instructions.
On June 30, 2022, Harpeth Conservancy (HC) filed comments on the draft permit issued by the Tennessee Department of Environment & Conservation (TDEC) to the City of Franklin for the Franklin Sewage Treatment Plant (Franklin STP). The permit establishes limits on the amount of pollutants that the Franklin STP can discharge into the Harpeth River.
Harpeth Conservancy is particularly concerned with the amount of nutrients – nitrogen and phosphorus – that can be dumped into the river. Excessive nutrient pollution can cause harmful algal blooms, that can harm people and animals. The Harpeth River is already at or beyond a tipping point for the production of such harmful algae blooms. HC opposes the Draft Permit in its current form – it must be substantially revised. We want to take this opportunity to highlight some of our concerns.
Why Harpeth Conservancy Opposes the Draft Permit in its Current Form
The Harpeth River is Impaired!
HC opposes the Draft Permit in its Current Form because it fails to recognize that the river is impaired for nutrient pollution and reduce the amount of pollutants that can be discharged into the river by the Franklin STP.
The Franklin STP currently discharges about 62 pounds of phosphorus into the river every day (this is less than the current permit requires and we appreciate Franklin’s efforts, but it still is not nearly enough). Under the current discharge levels the river is still impaired. When a river is impaired, it means that TDEC has determined it is not meeting the uses (like recreation and for fish & aquatic life) that TDEC has established it should.
The Draft Permit not only does not reduce the amount of pollution discharge allowed, it allows the Franklin STP to discharge 174 pound of phosphorus per day, ALMOST THREE (3) TIMES the 62 pounds per day it currently discharges!! This violates the US Clean Water Act and Tennessee law.
TDEC Does NOT Require the Franklin STP to Use Pollution Reduction Systems TN Taxpayers Have Paid For to Try to Reduce Pollution Levels
The new Franklin STP (expanded so it can discharge up to 16 million gallons per day) is built largely with public money, approximately $130 million in money from the TN State Revolving Loan Fund. Included in this money were funds for a biological nutrient reduction system and a chemical nutrient reduction system. The Franklin STP has the capability to restore the Harpeth to meet its water quality standards. But, TDEC’s Draft Permit does not require the Franklin STP to use this equipment to try to reduce pollution levels in the river.
The Pollution Reduction Plan for the Harpeth River is Nowhere Near Complete Seven (7) Years After it Was Announced
In 2015, TDEC, HC, and Franklin jointly announced that a new pollution reduction study and plan (formally called a “Total Maximum Daily Load” or “TMDL”) was needed for the Harpeth River (a TMDL is required by the Clean Water Act when a river is impaired). Yet, seven (7) years later, the TMDL is nowhere near complete, and there is no plan or schedule for its completion!
HC appealed a nearly identical permit issued in 2017. HC agreed to dismiss its appeal in 2019 on the expectation that TDEC and other stakeholders would work seriously and diligently toward the completion of the TMDL. That hasn’t happened even though the data exists to establish reasonable permit limits.
TDEC Knows What the Pollution Limits Must Be
TDEC must not wait on the completion of a TMDL to set discharge limits for the Franklin STP that will clean up the river (called “water quality-based effluent limits” or “WQBELS”). TDEC has known for some time – and all calculations agree – on what that discharge level must be, thus TDEC is obligated under federal law to require discharges be reduced to the appropriate level. HC must oppose the Draft Permit in its current form, unless and until an appropriate discharge level is required.
Turn Out for the Public Hearing on August 30, 2022 And Send Written Comments to TDEC
Join us to fill the room and make your voice heard at the public information session and hearing on the Draft Permit on August 30, 2022, beginning at 5:30 pm CT, at the Franklin High School, Room 102, 810 Hillsboro Road, Franklin, TN 37064. (You can also attend by video conference at the following link: https://www.tn.gov/environment/ppo-public-participation/ppo-public-participation/ppo-water.html, Meeting ID: 289 549 672 654, Passcode swDikN.)
Please send written comments to TDEC’s permit writer Wade Murphy at firstname.lastname@example.org.
Under Tennessee law, we have the RIGHT to unpolluted waters. Please plan to attend the August 30th session to request TDEC change the draft permit to effectuate real progress NOW to clean up the Harpeth River.