As Missourians splash in our abundant waters to relieve the sweltering heat of summer, we should take note that our tax money is being spent to keep streams polluted, not to keep them clean and safe.
The Missouri Department of Natural Resources (MDNR) has spent nearly $300,000 this year on studies used to exempt streams from important clean water protections—and it’s poised to spend still more this summer and fall. This is the third year MDNR has either contracted for studies that downgrade stream protections—called Use Attainability Analyses (UAAs)—or conducted them using state employees, at an overall undisclosed cost.
Typically, a facility seeking UAA loopholes that exempt streams from protections would have to fund the UAA study themselves. By paying for the UAAs out of tax payer money, MDNR is encouraging sewage facilities to avoid disinfecting the wastewater they discharge into Missouri’s streams and all at our expense.
Your input can make a difference. Please join with the Missouri Coalition for the Environment in asking Doyle Childers, Director of the Missouri Department of Natural Resources, to end state-funded UAAs.
Dial Doyle today. 1-800-361-4827
Making water unsafe. If a stream is exempted through a UAA, sewer agencies and other facilities will be allowed to continue releasing bacteria-laden water into the stream. Sewage in our water means more viruses, parasites, and other pathogens that can make people sick. Pathogens such as fecal coli form and E. coli bacteria are indicators of poor water quality and contamination with human waste. Waters with elevated levels of fecal coliform and E. coli bacteria are unsafe to swim in or for children to play in.
Exemptions are often sought for Missouri’s small streams that feed the state’s larger rivers. These small streams often flow through public and private property, including schools and parks, where they may attract youngsters (See box, below).
Your tax dollars are being wasted. In some cases, the state is spending money to re-do UAAs conducted in previous years that the Environmental Protection Agency deemed insufficient to justify removing protections.
The Missouri Coalition for the Environment is calling for a moratorium on state-funded UAAs.
Pollution is not the solution.The solution is to provide technical assistance to help dischargers identify appropriate technologies, to provide financial assistance, and to establish reasonable time frames for compliance. Writing off Missouri streams indefinitely is not acceptable.
Honey Creek:
In 2005, MDNR conducted a UAA study on Honey Creek in Cole County. After measuring the depth of the stream at road crossings, MDNR recommended removing protections for the stream concluding that it was too shallow to attract swimmers. However, local residents who frequent swimming holes in areas between road crossings submitted evidence that, indeed, locals do swim in Honey Creek. The EPA rejected MDNR’s recommendation to remove protections. Rather than require the three dischargers who dump undisinfected waste water into the creek to disinfect, MDNR is now using public money to redo the UAA with the hope that this time, they’ll convince EPA that the stream need not be protected for swimming.
Similarly, MDNR is paying to redo a UAA on Bear Creek in Boone County, a stream that flows near a nature trail, attracts anglers, and is known to be used for wading. Like Honey Creek, the first UAA was rejected by the EPA. Again, rather than require Bear Creek’s 12 dischargers to make the water safe, MDNR is paying for a second UAA aimed at downgrading protections.
UAAs - Frequently Asked Questions
What is a Use Attainability Analysis?
A Use Attainability Analysis or UAA is a method of removing a designated use from a stream. In Missouri, we currently protect some of our streams by assigning or designating uses to them. We call these streams with designated uses “classified streams.” For example, the Meramec River is a classified stream and one of its designated uses is human recreation. In fact, according to the law, all classified streams must be designated for human recreational use.
Some other examples of designated uses are: irrigation, fisheries, drinking water, livestock watering, and fish consumption.
Once a designated use is assigned to a stream, the designated use must be protected by those who discharge wastewater into the stream. These “dischargers” must get a permit from the state that requires them to treat the wastewater before it is discharged. The level and type of treatment required is determined by the designated use in the receiving stream.
For instance, before the St. Louis Metropolitan Sewer District (MSD) can discharge wastewater into the Meramec River, it must first obtain a permit. Because human recreation is a designated use on the Meramec, the permit requires MSD to disinfect the wastewater before discharging it so that it will not harm people recreating in the river.
While all classified streams must be protected for human recreation, dischargers can ask the state to remove this use by submitting a UAA. The UAA is supposed to be a carefully conducted scientific study that clearly shows that human recreation is not possible on the stream in question. The discharger is supposed to meet this burden before a use designation can be removed.
What is our objection to state-funded UAAs?
While UAAs are legal under the Clean Water Act, they were intended to be used in exceptional cases and not, as they are now in Missouri, on a routine basis every time a sewage discharge permit comes up for renewal.
Remarkably, in 2005, nearly 400 UAAs were done, almost all at taxpayer expense. After spending public money to conduct these hundreds of UAAs, the state then recommended removing recreational use protections from 142 of the streams. Upon review of the state’s UAAs, EPA decided that they were so poorly done, (some were even conducted on the wrong streams!) that they disapproved 99 of the state’s recommendations to remove recreational uses. While EPA disapproval of use removal may sound like a good thing, the state’s not giving up. Rather than requiring dischargers to protect recreational uses on these 99 streams and moving on to the important work of actually protecting water quality, the state has decided to redo these 99 UAAs! That is correct. You and I will be paying once again for a second round of UAAs on these same 99 streams, all designed to remove water quality protections.
In 2006, we saw another 145 state-produced UAAs and we are still waiting for the state’s recommendations regarding recreational use removal.
In just the first six months of this year alone, the state has committed nearly $300,000 of public money to UAAs. Some of this money has been spent on redoing the 99 UAAs from 2005 and some on new UAAs. The state intends to spend even more public money on yet more UAAs this summer and fall.
Wouldn’t it make more sense to use that money to make our streams safe? After all, the national goal of the Clean Water Act is to make our nation’s streams “fishable and swimmable.”
If a discharger wants to ask the state to remove a designated use so that it does not have to treat its wastewater to protect people swimming or playing in the stream, then the discharger should bear the burden of showing that human recreation is not possible in that stream, and not expect the state (or you and I) to foot the bill.
What happens if a UAA is not conducted or the UAA is disapproved?
If no UAA is prepared or the UAA that is submitted is disapproved by the state or the EPA, then the discharger must protect the stream for human recreation (and any other uses assigned to that stream). In the example given above regarding MSD and the Meramec River, if there is no UAA submitted and approved on the Meramec River, then MSD must protect for human recreation on the Meramec River. MSD would protect that use by disinfecting the wastewater from its treatment plant before that wastewater enters the river.
What is disinfection and why is it necessary?
Disinfection is a process of removing or killing disease-causing organisms that are present in wastewater discharges. Sewage that has not been disinfected may contain viruses, parasites, and other pathogens that can make people sick with ear infections, typhoid fever, hepatitis, gastroenteritis, dysentery, and other illnesses. Pathogens such as fecal coliform and E. coli bacteria are indicators of poor water quality and contamination with human waste. Waters with elevated levels of fecal coliform and E. coli bacteria are unsafe to swim in or for children to play in.
How much will disinfection cost?
The cost of disinfection varies depending upon the method of disinfection used and the amount and nature of the wastewater being treated at a particular plant. The most common methods of disinfection include chlorination (followed by dechlorination to protect aquatic life), ultraviolet radiation, and ozonation. Whichever method is chosen, the costs of disinfection represent a small part of the overall costs of operating a wastewater treatment facility.
Certainly, instead of spending our money to help dischargers avoid disinfection, the state should be putting its efforts into providing them with financial and technical assistance toward disinfection and helping to ensure that Missourians can enjoy cleaner, safer streams.
To check the UAAs for each county:
http://www.dnr.mo.gov/env/wpp/wqstandards/uaa/uaa_county.htm
To visit the sewer blog (SLOG) see:
http://www.healthyrivers.org/slog/2006/12/13/welcome-sewage-log-slog
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Missouri tax money is being spent to keep streams polluted, not to keep them clean and safe.