DRAFT
ENVIRONMENTAL IMPACT STATEMENT
WATER QUALITY MANAGEMENT
PLANNING FOR THE HURON
RIVER BASIN PORTION OF
SOUTHEAST MICHIGAN
PREPARED BY U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION V, CHICAGO
FEBRUARY,1973
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DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR THE
HURON RIVER BASIN PORTION
OF THE
INTERIM WATER QUALITY MANAGEMENT PLAN FOR THE SOUTHEAST
MICHIGAN METROPOLITAN - REGIONAL AREA
PREPARED BY
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
proved by:
Regional Administrator
February 1973
. Protection A
- --,-•-'A o, Library (5PL-15)
-.'-• •:. Bcarborn St-eet, fiOOffl 1670
«<«-icago, 1L 60604
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SUMMARY SHEET
This Draft Environmental Impact Statement was prepared by the
United States Environmental Protection Agency, Region V.
1. This draft statement is submitted prior to federal
approval of the Huron River Basin portion of the Interim
Water Quality Management Plan for the Southeast Michigan
Water Resources Commission.
If the proposed plan is approved, a single wastewater
treatment plant will be built at the mouth of the Huron
river to serve the entire service area.
2. Brief Description of Proposed Plan
The proposed plan, identified as Plan II in the "Plans
for Water Quality Management - Phase I Southeastern Michigan
Area" provides for the construction of a major new secondary
wastewater treatment plant with 90% phosphorus removal at
the Huron River discharging to Lake Erie. The plan also
includes an interceptor system that would extend inland to
serve portions of Western Wayne, Eastern Washtenaw and
Southwestern Oakland Counties, Michigan. Under this plan,
existing treatment plants on the Huron River within the 1990
service area would be abandoned.
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3. Major Alternatives ConsjLdered
a. Plan IB - This plan provides for the Ann Arbor area
in Washtenaw County to be served by a terti; ry treatment
plant with phosphorus removal at Ann Arbor. The balance
of the 1990 service area, which is the same as that for
the proposed plan, will be served by a new secondary
treatment plant, with 90% phosphorus removal, at the mouth
of the Huron River discharging to Lake Erie. The inter-
ceptors provided for in this plan would extend along the
Huron River to the City of Ypsilanti and north through Wayne
County to White Lake Township in Oakland County.
b. Plan III - This plan provides for the abandonment of
the existing plants on the Huron River and the construction
of an interceptor extending from a new secondary wastewater
treatment plant at the mouth of the Huron River north-
westerly adjacent to the Huron River at Ann Arbor. An inter-
ceptors would transport the wastewater from the Washtenav
County area and the Wayne County area south of Plymouth
to the proposed Huron River Plant. The balance of the area
would be serviced by the existing Detroit Wastewater Treat-
ment Plant through an interceptor extending from the Detroit
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Plant northwesterly along the Rouge River to Plymouth
Road, westerly along Plymouth Road to Hannan Road and
then northerly to White Lake Township in Oakland County.
c. Plan IV - This plan proposes two interceptor systems
and two inland tertiary treatment plants with phosphate
removal within the service area - one at Ann Arbor and
one at Ypsilanti. The wastes from the balance of the
Washtenaw County area and the Wayne County area south of
Plymouth Township would be handled by the proposed Huron
River treatment plant. The remainder of the wastes in
the 1990 service area would be handled by the Detroit
Treatment Plant.
d. Plan V - This plan briefly explored two alternatives
to the possibility of disposing the treated sewage effluent
on land by spray irrigation. The first alternative would
provide land disposal for the entire service area. The
second alternative would provide land disposal for sewage
effluent generated from the Ann Arbor, Ypsilanti City and
Ypsilanti Township area. The remainder of the service area
would be treated at the proposed Huron River Treatment Plant.
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4. The following Federal, State, and local agencies are
being requested to comment on this Draft Environmental
Impact Statement:
Council on Environmental Quality
Department of Agriculture
U.S. Army Corps of Engineers, Detroit District
Department of Commerce
Department of Health, Education, and Welfare
Department of Housing and Urban Development
Department of the Interior
Department of Transportation
Governor of Michigan
Michigan Water Resources Commission
Michigan Department of Public Health
Southeastern Michigan Council of Governments
Oakland County Planning Commission
Washtenaw County Planning Commission
Wayne County Planning Commission
City of Detroit
City of Ann Arbor
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City of Y
Others
5. This Draft Environmental Impact Statement is being made
available to the public, to the Council on Environmental
Quality and to other agencies as noted above in February,
1973.
6. On the basis of the analysis and evaluation set forth in
this Statement, and after weighing the environmental,
economic, technical, and other benefits against environ-
mental costs and considering available alternatives it
is concluded that the action called for is the approval
by the U.S. Environmental Protection Agency of the
proposed Plan II.
The Interim Water Quality Management Plan for the South-
east Michigan Metropolitan - Regional Area, as proposed
by the Michigan Water Resources Commission and the South-
eastern Michigan Council of Governments, recommends
Plan II for the Huron River Basin portion of Southeast
Michigan.
Acknowledgement
Portions of this Environmental Impact Statement were
taken directly from the "Environmental Assessment - Phase I Plans
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for Water Quality Management, Southeastern Michigan Area," prepared
by the Michigan Water Resources Commission and dated February
1972.
Specifically, many of the cost figures, projected population and
waste loadings, and description of the proposed plan and major
alternatives were taken from the assessment.
VI
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vii
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WATER QUALITY MANAGEMENT PLANS
FOR THE
SOUTHEASTERN MICHIGAN AREA
PHASE I
0 3 6 9 12 15 18
-•*=
MILES
SERVICE AREA
LAKE
E K I f
FIGURE 2
MICMIGAN-OHfO STATE LINE *
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Table Of Contents
Summary Sheet i
Acknowledgement v
Service Area Map viii
I. Conclusions 1
II. Description of Proposed Action 2
III. Environmental Impact of Proposed Plan 15
IV. Adverse Impacts Which Cannot be Avoided
Should the Proposed Plan Be Implemented 28
V. Alternatives to the Proposed Action 37
VI. Comparison of Proposed Plan (Plan II) and
Major Alternatives (Plans IB, III & IV) 64
VII. Relationship Between Short-Term Beneficial Uses Versus
Long-Term Environmental Consequences for the Proposed Plan II. 71
VIII. Irreversible and Irretrievable Commitment of Resources 72
IX. Opportunity and Extent of Public Participation 72
Appendicies Following Page 73
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List Of Tables
Page
1. Cost Estimates for Proposed Plan II 14
2. Waste Loadings to Lake Erie from the Proposed
Huron River Treatment Plant 15
3. Phosphorus Discharges to Lake Erie in 1966-67 19
4. Average Waste Loadings to the Huron River 22
5. Average Waste Flows to the Huron River 28
6. Cost Estimates for Plan IB 38
7. Waste Loadings to Lake Erie from Plan IB
Huron River Treatment Plant 39
8. Waste Ladings from Ann Arbor Treatment Plant 42
9. Cost Estimates for Plan III 47
10. Waste Loadings to Lake Erie from Plan III Huron
River Treatment Plant 48
11. Waste Loadings to Detroit River from Plan III 49
12. Cost Estimates for Plan IV 54
13. Waste Loadings to Lake Erie from Plan IV
Huron River Treatment Plant 55
14. Average Waste Loads Removed from the Lower Huron 56
15. Waste Loadings from the Ann Arbor and
Ypsilanti Treatment Plants 57
16. Comparison of Costs and other environmental considerations
of Plans II, IB, III & IV 65
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List of Figures
Page
1. Huron River Basin Map vii
2. Service Area Map viii
3. Proposed Plan II System following page 13
4. Alternative Plan IB System following page 39
5. Alternative Plan III System following page 48
6. Alternative Plan IV System following page 53
7. Population Distribution Map Appendix A
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], CONCLUSIONS
Our evaluation of the proposed plan and the three major
alternatives indicated that the economic differences are so minimal
that they do not offer a decision on a cost effectiveness basis.
Also, the environmental consequences appear to be quite similar except
that the proposed plan will treat all the service area wastewaters at
one treatment plant and will provide maximum protection for the Huron
River and meet all water quality standards for Lake Erie. The
proposed Plan II has been endorsed by the Southeast Michigan Council
of Governments and the Michigan Water Resources Commission, and the
EPA has concluded that the proposed Plan II is the most environmen-
tally compatible solution to the wastewater management problems of
the Huron River Basin area. The proposed treatment system, when
built, will comply with all policies, guidelines, and permits issued
pursuant to the new Federal Water Pollution Control Act Amendments
of 1972. All interested Federal, State, and local government
agencies, as well as other interested parties will be given the
chance to review this Draft Environmental Impact Statement and we
welcone any further comments and views on the matter.
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II. DESCRIPTION OF PROPOSED ACTION
A. BACKGROUND
An interim water quality management plan for the Southeast
Michigan Metropolitan - Regional Area has been prepared by the
Michigan Water Resources Commision and approved by the HUD
designated area-wide planning organization, the Southeast
Michigan Council of Governments (SEMCOG), in accordance with the
40CFR35.150 planning requirements. The plan has already been
approved by Region V of the Environmental Protection Agency with
the exception of the Huron Basin area. The plan that has been
approved describes a system of major interceptors which, with a
few exceptions, carry all municipal sewage to a number of major
wastewater treatment plants on the St. Clair River, Detroit
River and Lake Erie. The Huron Basin portion of the plan, which
has not yet been approved by EPA, considers a number of alterna-
tive treatment systems to be discussed in the environmental
impact statement. Upon approval of a plan for the Huron Basin,
the entire Southeast Michigan area will have a plan for water
quality management.
B. HISTORY OF AREA
1. Population
The Southeastern Michigan area comprises the most intensely
urbanized and industrialized portion of Michigan. Some 4.7 million
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person resided in the area in 1970. Based on population
projections developed by the Southeast Michigan Council of
Governments, the Southeast Michigan area is projected to sustain
a 20 percent population increase by 1980, with an additional 25
percent increase in the following decade. By 1990, the area's
population is anticipated to beftialf again as large as the 1970
population.
2. Economy
The Southeastern Michigan region supports a highly developed
industrial complex. The Nation's automobile industry's fabricating
and assembling operations continue in the area. The chemical and
allied products industry and the food and kindred products
industry are also substantial. The economy of the region is now
shifting somewhat from its historically heavy emphasis on manu-
facturing toward a growth in trades and services. To some extent
this trend toward diversification may be an indication of
increasing stability of the Southeastern Michigan ecomomy, with
a resulting reduction in the large inflows and outflows of
population.
Tentative projections indicate that by 1990, manufacturing
activity in this region, as measured by employment, will increase
by roughly one-sixth beyond 1970 levels and that mining will grow
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by about one-eighth. Agricultural employment is expected to drop
by one-third as urbanization progresses and as production technol-
ogy continues to require less labor.
3. Land Use
The Southeastern Michigan area comprises a complex variety
of land uses for residential, commercial, industrial, agricultural
and recreational purposes. By the late 1960's over 21 percent of
the land in the region as a whole was urbanized? with the Detroit
Metropolitan counties of Wayne, Oakland and Macomb being 55 per-
cent, 38 percent and 28 percent urbanized, respectively. As of
1969, the long-prevailing trend toward fewer acres of farmland
harvested was still continuing. The major factor contributing to
this decrease in farmland appears to be the continued enlargement
of the Detroit Metropolitan Area.
For the entire Huron River Basin portion of the Southeastern
Michigan area, land use in 1965 was approximately 20% residential,
5% commercial and industrial, 10% public recreation, and 65%
undeveloped or vacant. SEMCOG has estimated that by 1990 these
land use categories may shift to 35% residential, 5% commercial
and industrial, 10% public recreation, and 50% undeveloped or
vacant.
C. PURPOSE OF PLAN
The portion of the Southeast Michigan Water Quality Management
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Plan which pertains to the Huron Basin Area has been a controver-
sial issue since its inception, and the purpose of this
environmental impact statement is to evaluate the impacts of the
alternatives considered so that a final plan for the Huron Basin
Area may be selected.
The Huron Basin Service Area includes portions of eastern
Washtenaw, southwestern Oakland and western Wayne counties, the
two largest cities being Ann Arbor and Ypsilanti, and involves a
major portion of the Huron River Basin and portions of the Rouge
River Basin. The Huron Basin Area is presently in need of new
and/or improved wastewater collection and treatment facilities in
order to comply with the water quality standards and implementation
schedules for the area and provide for the population growth of
the area as projected by SEMCOG for a minimum of the next two
decades.
The purpose of the plan for the Huron River Area is to
determine the most cost-effective, environmentally compatible
wastewater collection and treatment strategy for the Tri-County
area that will serve to the year 1990 and will best meet the water
quality standards for Southeast Michigan presented below.
D. WATER QUALITY
1. Water Quality Standards
The Federal Water Quality Act of 1965 (Public Law 89-234)
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provides that the state adopt water quality standards with
respect to interstate waters. The Water Resources Commission Act
(Act 245, P. A. of 1929, as amended) provides for establishing
pollution standards by the Michigan Water Resources Commission.
Based upon the latter statutory authority, the State Water
Resources Commission in January of 1968 adopted Water Quality
Standards for Michigan Intrastate Waters. Following is a listing
of the designated water uses and the stream reaches within the
Southeastern Michigan Metropolitan Area (St. Clair, Macomb, Wayne,
Washtenaw, Monroe and part of Livingston and Oakland Counties) to
which they apply.
(A-l) Domestic Water Supply - All existing public water intakes
in normal daily use will be protected for domestic water
supply at the point of intake.
Huron River at Ann Arbor - Washtenaw County
Huron River at Flat Rock - Wayne County
Huron River at Geddes Pond (Ypsilanti) - Washtenaw County
River Raisin at Dundee - Monroe County
(A-2) Industrial Water Supply - All public waters in the area
are protected for industrial water supply.
(B-l) Recreation, Total Body Contact. Natural lakes and the
designated reservoirs or portions of streams and
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artificial lakes on public waters in this area are pro-
tected for total body contact. The following reservoirs
and portions of streams are designated for total body
contact. Huron River at Belleville Lake-Wayne County-T
/to
35, R.8E, Sec. 34 Huron River at Ford Lake.
(B-2) Recreational, Partial Body Contact. All public waters
will be protected for partial body contact.
(C-l) Fish, Wildlife and other Aquatic Life - Intolerant Fish,
Cold Water Species: All waters designated under the
authority of P. A. of 1967 by the Director of the Michigan
Department of Natural Resources will be protected for
tolerant fish, cold-water species except that in those
instances below municipal and industrial discharges where
subsequent findings indicate that existing water quality
is below cold-water, intolerant fish standards.
(C-2) Fish, Wildlife and other Aquatic Life - Intolerant Fish,
Warm Fish Species: All waters not designated for
intolerant fish, cold-water species, tolerant fish,
warm water species or commercial and other uses will
be protected for intolerant fish, warm water species.
(C-3) Fish, Wildlife and other Aquatic Life - Tolerant Fish,
Warm Water Species:
River Raisin - from the first dam above the mouth to
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the west city limits of the City of Monroe.
(C-4) Fish, Wildlife and other Aquatic Life - Intolerant
Fish, Warm Water Fish, Anadromous: Waters protected
for intolerant fish, cold-water species will be
protected for anadromous fish.
(D) Agricultural - All public waters will be protected
for agricultural use except the following:
River Raisin from the first dam above the mouth to
the mouth - Monroe County.
Rouge River from the Michigan Avenue Bridge to the
mouth - Wayne County.
Willow Creek from 1-94 Bridge near Ypsilanti to its
confluence with Huron River (Belleville Lake)
(E) Commercial and Other Use - The following public waters
will be protected for commercial and other.
River Raisin from the first dam above the mouth to
the mouth.
Willow Creek from 1-94 Bridge near Ypsilanti to its
confluence with the Huron River (Belleville Lake).
Most waters in the area are protected for industrial
water supply and partial body contact.
2. Present Water Quality Problem Areas
The major water quality problems of the Huron River Basin
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and the Michigan waters of Lake Erie mainly result from municipal
discharges. There is little evidence of agricultural or indepen-
dent industrial sources of pollution. Below is a more detailed
discussion of the water quality problems in the area.
a) Lake Erie
Portions of the Michigan shore of Lake Erie are affected
by pollutional discharges from the Southeast Michigan area.
The western end of Lake Erie receives the discharges of the
Detroit, Huron, Raisin and Maumee Rivers. This produces a
large area west and south of the Detroit River mouth, which
is relatively rich in nutrients and contains increased levels
of other constituents. Nuisance algae conditions are
significant in the Michigan waters of Lake Erie. Nuisance
conditions arise when algae cells become so numerous as to
cause adverse tastes to water supplies, turbid and green-
brown water color, and depleted dissolved oxygen during algae
die-off.
The luxuriant growth of algae and other plants is
attributed to the increasing impact of fertilizing nutrients
from municipal and industrial wastes, and land drainage.*
As a result, extensive remedial programs have been implemented
in the Lake Erie Basin to remove phosphorus, the principal
*International Lake Erie Water Pollution Board. "Report to the
International Joint Commission on the Pollution of Lake Erie, Lake
Ontario and the International Section of the St. Lawrence River."
Vol. 2, Lake Erie, 1969.
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nutrient most amenable to control, from all municipal and
industrial waste discharges.
b) Middle Rouge River
Although the Middle River Rouge Valley has been largely
preserved for park and recreational uses, degradation of the
river has limited its full utilization for these purposes.
The causes of water quality degradation include combined
sewer diversions, trash accumulation, industrial waste
discharges, and soil erosion in the upper reaches from new
housing developments. In communities such as Westland,
Plymouth, Northville, Garden City, Dearborn Heights, Redford
Township, and others, combined sewer systems outlet into the
Rouge Valley Interceptor System. When heavy rains occur,
diversion gates allow a combination of stormwater and raw
sewage to overflow into the Middle Rouge River. In a 1966
survey* staff members of the Water Resources Commission
found the water quality of the Middle River Rouge to be
seriously degraded, particularly its lower reaches.
Indications of this degradation were: low dissolved
oxygen concentrations; high concentrations of oxygen demand-
ing substances, inorganic nutrients, and coliform bacteria;
and visible films of oil.
^Michigan Water Resources Commission, "Water Quality Evaluation
of the Middle River Rouge Basin," October 1967.
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c) Huron River Basin
The Huron River can be divided generally into two water
quality sections: The Upper Basin upstream of Ann Arbor,
and the Lower Basin downstream from Ann Arbor.
Water Quality in the Upper Basin is generally fair to
good except for isolated instances. The main water quality
problem in the Upper Basin is nutrient enrichment, partic-
ularly in lakes which form part of the mainstream of the
Huron River. Lakes that have experienced nuisance algal
conditions include Gallagher Lake, Brighton Lake, Ore Lake,
Strawberry Lake, Baseline Lake and Whitmore Lake. For
most of these lakes, upstream sewage treatment plant
discharges were regarded as major sources of nutrients.
Throughout the Upper Huron Basin, lakes are being
subjected to strong developmental pressures for residential
and other purposes. The bulk of the area's population
relies on septic tank-tile field wastewater disposal systems.
Substantial potential exists for environmental degradation
through groundwater and lake contamination from septic tank
disposal systems.
Water quality in the Lower Huron is affected by waste-
water discharges from the Ann Arbor, Ypsilanti, Ypsilanti
Township, Flat Rock and Rockwood municipal sewage treatment
plants, and by stormwater discharges and land runoff.
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Two major types of use impairments have been noted in
the Lower Huron River impoundments. Belleville Lake, a
designated total body contact recreation area, has been
closed to swimming at times by the Wayne County Health Depart-
ment because of elevated coliform levels. Both Belleville
and Ford Lakes have experienced intensive algal blooms during
summer periods. Certain of these algal blooms have been
followed with fish kills. One such incident was reported on
September 12, 1968 at Ford Lake. Investigators found that
there were several hundred dead fish along the north shore
from Bridge Road to Grove Road near David Avenue. Every
cove on the downwind side of the lake had an overabundance
of algae. In certain areas, the algae was so thick the water
had the consistency of thick pea soup. These impoundments
act in effect as settling ponds or final oxidation ponds,
especially during periods of summer drought flow when water
flows slowly through impoundments.
E. PROPOSED PLAN
The proposed plan, endorsed by the EPA, Michigan Water
Resources Commission, and SEMCOG, identified as Plan II in the
"Plans for Water Quality Management - Phase I Southeastern
Michigan Area," calls for a single major new sewage treatment
plant near the mouth of the Huron River discharging to Lake Erie
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about one mile offshore from Point Mouillee. The 1990 service
area for Plan II includes the following areas: Wayne County:
The Cities or Villages of Belleville, Flat Rock, Gibraltar,
Northville, Plymouth, Rockwood and South Rockwood, Trenton, Wood-
haven and portions or all of the following townships; Brownstown,
Huron, Sumpter, Van Buren, Romulus, Canton, Plymouth and North-
ville.
Oakland County: The Cities or Villages of Novi, Walled Lake,
Wolverine Lake, Orchard Lake,and Clarkston and portions or all
of the following townships; Commerce, White Lake, Springfield,
and Novi.
Washtenaw County: The Cities of Ann Arbor and Ypsilanti and
portions or all of the following townships; Augusta, Ypsilanti,
Superior, Salem, Pittsfield, Ann Arbor and Scio. Certain areas
in the proximity of the interceptor service area are not within
the 1990 project service area. The communities outside the
1990 service area are as follows:
1. West Bloomfield Township, Waterford Township,
Independence Township, Orion Township and Pontiac
Township. They will be served by the Clinton-
Oakland Interceptor System where they have
sufficient capacity to 1990.
2. Lyon Township, Milford Township, Highland Township,
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Milford, South Lyon and Wixom. These communities
will be served by the existing plants at South Lyon,
Milford and Wixom, improved and expanded as needed,
or by other new interim plants. This area's projected
population density for 1990 does not appear to warrant
extensive and expensive interceptor construction. The
remainder of the Huron River Watershed, located west
and outside of the service area boundaries, is primarily
rural and agricultural, with a few small towns.
The map, Fig. 3, outlines the 1990 service area. The proposed
plan calls for a major interceptor to be constructed from a proposed
Huron River Wastewater Treatment plant at Lake Erie northwesterly
parallel to the Huron River to Hannan Road. At Hannan Road the
system branches to the north and also to the west. The west branch
is the Van Buren Arm which picks up the existing Ypsilanti Township
plant. The extension westerly beyond the Ypsilanti Township plant
is known as the Ann Arbor Arm and picks up the City of Ypsilanti
and the City of Ann Arbor plants and their connecting service areas.
The Hannan Road Interceptor extends north from the Van Buren Arm
junction through Canton, Plymouth and Northville Townships and extends
through Oakland County in the North Arm to White Lake Township.
The predicted 1990 sewage flow to the treatment plant from the
service area is estimated to be 121 MGD, of which Ann Arbor, the
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the largest single contributor, will send 33 MGD to the plant. The
proposed plan will eliminate all municipal discharges to the Huron
River from Ann Arbor to the mouth. Cost estimates for the proposed
Plan II are shown in Table 1.
TABLE 1
Cost Estimates for the Proposed Plan II
North Arm
Van Buren Arm
Ann Arbor Arm
Huron River Plant
xceptor
xceptor
:ion Basin
tip Retention Basin
it
iron River Plant
rer Rouge Interceptor
i
>st
Millions of Dollars
37.55
21.98
20.49
23.66
14.35
5.00
5.00
32.80
160.83
59.11
4.31
$224.25
Redford Arm
Total Project Cost
Annual operation adn maintenance in 1990 = $2.14 Million
Annual amortization cost* =$17.54 Million
total annual cost in 1990 =$19.68 Million
* 25 year at 6%
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III. Environmental Impact of Proposed Plan
A. Impact of Proposed Plan on Lake Erie
By implementing the proposed plan, wastewater from the Lower
Huron Basin Study area would be conveyed to the proposed treatment
plant at the mouth of the Huron River, and would be discharged
after treatment to Lake Erie.
The projected waste loadings to Lake Erie from the proposed
treatment plant are shown in Table 2 below.
Table 2
Waste Loadings to Lake Erie from the Huron River Treatment Plant
Waste
Constituents
5-Day Biological Oxygen
Suspended Solids
Total Phosphorus
Ammonia Nitrogen (NH3-N)
Total Nitrogen
Flow (Mgd)
Effluent
Concentration
mg/1
20 mg/1
18.5 mg/1
0.67 mg/1
6.0 mg/1
1975
12,150
11,240
408
3,646
8,872
73
Pounds Per Day
1990
20,194
18,682
678
6,059
14,746
121
These figures represent gross waste discharges. The actual net
increased loadings to Lake Erie will be less because the Huron River
treatment plant will handle some wastes which are currently being
discharged to Lake Erie via the Detroit River by the Wayne County
Treatment Facilities located on the Detroit River and the Detroit
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Wastewater Treatment Plant. Also, some wastes currently being
discharged to the Huron River eventually reach and enter Lake Erie.
The proposed Huron River Treatment Plant will discharge daily
effluent containing carbonaceous material which will demand 20, 194
pounds of oxygen (as measured by the 5-day BOD test) and 14,746 pounds
of total nitrogenous oxygen demand to Lake Erie by 1990. This
discharge, however, is not expected to cause substandard dissolved
oxygen conditions if the following two conditions, which are provided
for in the plan, are met: (1) the suspended solids concentrations
in the effluent are kept low to minimize sedimentation of organic
materials; and (2) the effluent is well dispersed in the Detroit
River current.
The magnitude of the decrease in oxygen levels can be approxi-
mated. In 1990, the proposed Huron River plant will discharge an
estimated 121 mgd, or 187 cfs. The average flow of the Detroit River
is about 185,000 cfs. Previous studies of the Detroit River just
above the location of the proposed outfall show that about 10 percent
of the flow of the Detroit River passes between the Michigan shore
and a point one mile from the shore. Using this portion of the
River flow for assimilation, the wastewater effluent would be diluted
with river water by about a ratio of 1 to 100 (187 cfs versus
18,500 cfs). On this basis, the ultimate oxygen demand from the
effluent would deplete the dissolved oxygen demand of the river
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downstream from the discharge point by a maximum of 1.0 mgy/1. Under
the aegis of the International Joint Commission (IJC), water quality
data was collected from 22 river sampling ranges in the Detroit River,
including Range DT 3.9 located immediately upstream from the discharge
location of the proposed Huron River Treatment Plant. In 1970» the
average dissolved oxygen concentration at this range was 7.6 mg/1.
Therefore, the average dissolved oxygen content could be lowered from
7.6 mg/1 to 6.6 mg/1. This is well above the standard of 5.0 mg/1.
Consideration has also been given to the impact on Lake Erie
that would result from possible treatment plant malfunction, accident
or failure. Taking the worst possible situation where complete
failure of the treatment processes occurred, it is highly improbable
that any serious impact would occur at the Monroe water supply intake
located twelve miles away. Bacterial levels could, however, be
elevated along the Michigan shoreline of Lake Erie and thereby impair
water related recreational uses for a short time. The affect on
dissolved oxygen reduction in Lake Erie from treatment plant malfunc-
tion resulting in raw sewage entering the lake can be grossly estimated.
The average daily per capita discharge of oxygen-demanding substances
is 0.25 pounds ultimate carbonaceous BOD/capita-day and 0.20 pounds
ultimate nitrogenous BOD/capita-day. For a 1990 population of 695,000
people, the raw sewage would contain a total of 313,000 pounds
ultimate BOD/day.
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For a sewage flow rate of 121 MGD, the concentration of ultimate
BOD would be 310 mg/1, and when diluted in Lake Erie at a ratio of
100:1 the concentration is 3.1 mg/1. Using this figure of 3.1 mg/1,
the dissolved oxygen would theoretically drop from 7.6 mg/ 1 to
4.5 mg/1. Although this figure is below the standard of 5.0 mg/1,
it is improbable that dissolved oxygen could ever drop below the
standard because the above gross analysis did not consider that
ultimate oxygen demand is exerted over a period of 20 days or longer,
that natural re-oxygenation of the Lake water is constantly occuring,
and complete malfunction of the plant resulting in total discharge of
raw sewage is highly unrealistic.
The most serious water pollution problem in Lake Erie is the
increasing eutrophication of the Lake resulting from the increased
input of fertilizing nutrients from municipal sources, industrial
wastes and land drainage. Phosphorus and nitrogen are recognized
as the most important nutrients from municipal sources, industrial
wastes and land drainage. Phosphorus and nitrogen are recognized
as the most important nutrients responsible for the eutrophication
of Lake Erie. Experience shows that phosphorus is most often the
controlling material in stimulating algae growth.
i
According to a 1969 report by the International Joint Commission
(UC), the 1966-1967 loading of total nitrogen to Lake Erie was over
177,000 short tons, while the loading of total phosphorus to the
18
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Lake during the same period was about 30,000 short tons. Nitrogen
entering Lake Erie is contributed mostly from uncontrollable natural
sources, whereas over 70% of the total phosphorus is contributed from
controllable municipal and industrial sources.
The following Table 3 from the IJC report shows the inputs of
total phosphorus in short ton/year to Lake Erie in 1966-67. The table
shows thephosphorus input by source and also by basin.
Table 3
Phosphorus Discharges to Lake Erie in 1966-67
(Short tons/year)
Basin
West
Central
East
Total
Municipal
13,420
4,622
1,048
19,090
Industrial
1,212
331
480
2,023
Other
6,643
1,738
480
8,985
Total
21,275
6,691
2,132
30,098
It is apparent that the West Basin receives the majority of the
phosphorus load which includes 2,240 short tons per year in Lake Huron
outflow. The Huron River contributed only 430 short tons per year
during the 1966-67 period, or about 2 percent of the amount discharged
into the Western basin.
According to a 1969 report by the International Lake Erie Water
Pollution Board to the IJC, the current phosphorus loading to the
Western basin highly exceeds that level beyond which algae growth in
the Western basin of Lake Erie will be sustained.
19
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According to the report, the phosphorus load would have to be reduced
from 21,275 short tons to 550 short tons to arrest eutrophication.
The elimination of all municipal and industrial waste discharges,
however, would leave an annual phosphorus loading of 6,643 short tons
from other sources which would still result in Lake Erie remaining in
an eutrophic state. The Control Board report to the IJC suggests the
future possibility of removing all phosphorus from detergents and
achieving 95 percent removal of controllable phosphorus as a means of
striving to achieve a low concentration of phosphorus. This problem
is addressed further in the appendix under the terms of an interna-
tional agreement signed in April 1972. This international agreement
has set the allowable limit of phosphorus concentration in municipal
effluents at 1.0 mg/1.
The proposed plan for the Huron River area would result in
removing 90 percent of the phosphorus from the major waste sources to
the Huron River. The phosphorus concentration in the proposed plant
effluent will be 0.67 mg/1. Total phosphorus loadings from the Huron
River plant to Lake Erie are estimated to be 408 pounds per day in
1975 and 678 pounds per day in 1990. This is equivalent to 70 short
tons/year and 123 short tons/year, respectively. These levels of
phosphorus reduction exceed the required levels of reduction by the
United States=Canadian Great Lakes Water Quality Agreement. The
anticipated 1990 load of 123 short tons per year from the proposed
20
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plant is small compared to the total load of phosphorus being
discharged into the Western basin, and implementation of the
proposed plan will have little effect on the eutrophic condition of
the Western basin of Lake Erie. The limit oflmg/1 of phosphorus in
municipal waste treatment plant effluents to Lake Erie has been
deemed, by the international agreement, to be thedesireable Lake-wide
goal to be attained. Should future evidence show that higher levels
of phosphorus removal are necessary, the proposed plant would be
designed to meet such requirements.
B. Impact of Proposed Plan on the Detroit River
Under Plan II, no wastewater from the service area would be
discharged to the Detroit River. A small net decrease in wasteloads
to the Detroit River would result from the diversion of a small
volume of wastewater to the proposed Huron River Treatment Plant.
The effects of this diversion on the Detroit River would be positive
in nature, but in all likelihood would be negligible.
C. Impact of Proposed Plan on the Lower Huron
Under the proposed plan, wastewater from the existing municipal
wastewater treatment plants at Ann Arbor, Ypsilanti, Ypsilanti Town-
ship, Flat Rock and Rockwood would be transported via the proposed
Huron River interceptor to the treatment plant at the mouth of the
Huron River. Significnat reduction would be achieved in wastewater
discharges to the Lower Huron. The following Table 4 presents 1970-
71 wastewater flows from the six plants that would be eliminated.
21
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Table 4
Average Loadings to the Huron River
From 1970-71 Reports to Michigan Department
of Public Health
Plant
Ann Arbor
Ypsilanti
Ypsilanti TWP.l
Ypsilanti TOP. 2
Flat Rock
Rockwood
(MGD)
Flow
14.5
6,4
2.28
4.67
0.74
0.31
(Ibs/day)
BOD 5
2780
1388
244
432
271
309
(Ibs/day)
SS
5260
1533
314
605
267
176
(Ibs/day)
P
253
163
27
26
16
37
28.98 5424 8155] 522
Implementation of the proposed plan would satisfy current waste-
water treatment needs ,at Ann Arbor, Ypsilanti and Ypsilanti Township
and would improve water quality in the Lower Huron. Existing stream
concentrations of BOD, suspended and dissolved solids, and nutrients
would be lowered. In particular, water quality improvement is
anticipated in the stream impoundments of the Lower Huron. Algae
growth should decrease as the nutrient loads are reduced. This will
further more reduce diurnal dissolved oxygen variation and depletion.
Current water use impairments in Ford and Belleville Lakes due to
algal blooms and associated fish kills will also be reduced.
In addition to the removal of daily wastewater discharges, the
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Lower Huron River, under the proposed plan, would not be subject to
reduced water quality due to treatment plant upset, breakdown or
accident.
A few water quality problems will remain in the Huron River.
Stormwater runoff contributes pollutants to the Lower Huron. This
problem is not addressed by any of the alternative plans. However,
studies are being carried out to determine the measures needed for
alleviating the stormwater runoff problem and recommendations are
expected to be forthcoming in the near future. No definite system for
stormwater runoff control can be recommended until final approval of
the water quality management plan is made. In addition, previously
existing sludge deposits might provide sources of BOD and nutrients
for some time. Overall, while some water quality problems will
persist, considerable improvement in the water quality of the Lower
Huron will be realized.
Since implementation of the proposed plan would satisfy presently
determined needs for improved treatment and would bring about
considerable improvement in the quality of the Lower Huron, the exist-
ing and prospective uses of the Lower Huron River would be enhanced.
With regard to fish management opportunities in the Huron Basin,
there has been a growing interest within the last two years in
rehabilitating the warm water fisheries of the Huron River System.
Above the present effluent outfalls of Ann Arbor and Ypsilanti
City and Township the water quality in the Huron River is relatively
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good, and capable of supporting a game fishery. Accordingly, on
October 3, 1972 the Michigan Department of Natural Resources, Division
of Fis teries treated approximately 23 miles of the Huron River between
Delhi Mills and Superior Dam with rotenone, a fish toxicant, to
remove the present fish population with the purpose of restocking
this reach of the river with game fish. Prior to the treatment of
the river, a list of the species of fish living in the river between
Dexter and Ypsilanti was compiled (see appendix). After toxification
of the reach of river, the most numerous fish removed were Carp (75%)
which constituted approximately 90% of the weight of the fish removed.
It is anticipated that this reach of the river will be restocked with
largemouth and smallmouth bass, hybrid sunfish, walleye, and tiger
muskellunge. After improvement of water quality in the Huron River
below Superior Dam, it is anticipated that a similar project could
be implemented between the Superior Dam and the Flatrock Dam. Below
the Flatrock Dam, the Huron River flows freely to Lake Erie offering
no barrier to the Carp and other species of fish living in Lake Erie.
From the standpoint of fish management potential, the Division of
Fisheries* of the Michigan Department of Natural Resources, believes
that alternative wastewater management proposals which remove the
effluents from the river system for disposal on land or directly
into Lake Erie would be superior.
The recreational use of the waters of the Lower Huron Basin have
also created considerable public interest. Improved water quality
^November 15, 1971 memo from Fisheries Division Michigan Department of
Natural Resources.
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would enhance the recreational prospects of the Lower Huron.
Local communities have proposed increased recreational use of
the river by boaters, swimmers and fishermen. The Joint Ypsilanti
Recreational Organization (JYRO) has proposed the use of State Recre-
ation Bond Funds for the acquisition of park property on Ford Lake.
JYRO has prepared plans for some 400 acres of park development
abutting Ford Lake. Downstream between Belleville Lake Dam and river's
mouth, the Huron-Clinton Metropolitan Authority maintains a large
amount of recreational land. The Authority's Lower Huron Metropolitan
Park encompasses approximately 1,000 acres. A second major facility,
Willow Metro Park, is located just downstream. It is partially
developed and offers picnic and playground facilities. The Aurhority
is also engaged in developing a third major facility in this area,
the Oakwoods Metro Park. A one-half million dollar development
program is phased for the 1970-1974 period for this park, including
the construction of a nature interpretative center. Finally, a
further major park is planned for the mouth of the Huron, the proposed
Pointe Mouillee Metropolitan Park. Up to 1986, this area is proposed
for use as a dredge spoil disposal site for the U. S. Army Corps of
Engineers. Thereafter, the Huron-Clinton Authority would develop the
site as a major park.
Development of the above mentioned recreation areas and parks,
and water quality improvement in the Huron River should result in
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increased recreational activities in and along the Huron River.
Although intense use of recreational facilities has the potential of
causing environmental degradation (motorboat noise and gasoline spill,
picnic trash, smoke, etc.), this would probably be insignificant.
D. Impact of Proposed Plan on the Middle River Rouge
Presently, there are seventeen sewer diversions to the Middle
River Rouge, seven of which are located west of Hannan Road. During
dry weather periods, all waste flows are picked up by the interceptor.
However, during periods of moderate or heavy precipitation, the
interceptor's capacity is exceeded and a combination of stormwater and
untreated wastes is diverted into the Middle River Rouge.
The Rouge Valley Interceptor was originally designed on the basis
of intercepting 0.5 cfs flow per 1,000 population for combined sewer
areas and criteria has proved to be substantially inadequate. The
interceptor system proposed by Plan II is designed to collect all
existing flows originating west of Hannan Road which are now collected
by the Rouge Valley Interceptor. By providing relief to the Rouge
Valley Interceptor System at Hannan Road, it will be possible to
intercept 1.0 cfs flow per 1,000 population for combined sewer areas
in the remainder of the Rouge Valley Interceptor's service area.
The net effect anticipated is that existing overflows to the
west of Hannan Road would be handled by the new Huron River Interceptor
System and, secondly, increased performance of the Rouge Valley
26
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Interceptor System in the area east of Hannan Road. In general, the
following values were used in the design of the proposed Huron River
Interceptor System: flows equal to 0,40 cfs per 1,000 people for
areas with separate sanitary sewers, and flows equal to 1.00 cfs per
1,000 people for areas with combined sewers. The amount and frequency
of wastewater diversion to the Middle Rouge River, and to a lesser
extent to the Lower Rouge River, would be reduced. The quality of
these streams would be improved as would the value, utility and
aesthetics of the numerous streamside recreational areas.
E. Impact of Proposed Plan on the Upper Huron Watershed
The proposed plan will provide service to a four-township area
in southwestern Oakland County, of which the bulk of the population
is currently served by septic tank wastewater disposal systems.
This area is extensively endowed with natural lakes. As a result of
the area's relative proximity to the Detroit urban area, these lakes
are being subjected to strong developmental pressures for residential
and other purposes. In 1970, this service area contained a population
of 41,245. By 1990, the population is expected to reach 120,000.
Considering the present population levels and recent growth rates,
substantial potential exists for environmental degradation through
groundwater and lake contamination from septic tank disposal systems.
The proposed interceptor system is designed to alleviate the existing
potential for groundwater and lake pollution, and will also lessen the
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need to build additional was-fcewater treatment plants on the Upper
Huron in the future.
IV. ADVERSE IMPACTS WHICH CANNOT BE AVOIDED SHOULD THE PROPOSED PLAN
BE IMPLEMENTED
Implementation of Plan II will result in decreased flows in the
Lower Huron. Using 1970 data on municipal wastewater treatment plant
discharges, about 45 cfs of wastewater which is currently discharged
to the Huron River would be diverted to the interceptor as illustrated
in the follox^ing Table 5.
Table 5
Average Flows to the Huron River from
1970-71 Reports to Michigan Department of Public Health
(mgd)
Plant Flow
Ann Arbor 14.5
Ypsilanti 6.48
Ypsilanti Twp. #1 2,28
Ypsilanti Twp. #2 4.67
Flat Rock 0.74
Rockwood 0.31
28.98
(45 CFS)
The diversion will only be significant in the Ann Arbor-Ypsilanti
Area.
Both Ann Arbor and Ypsilanti currently obtain part of their water
supply from the Lower Huron. Ann Arbor currently obtains about 85
28
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percent of its water supply from the Huron River at Barton Pond which
is on the upstream side of Ann Arbor. Its wastewater outfall is
situated downstream of Ann Arbor, a distance of about 3.5 miles below
Barton Pondt Ann Arbor, therefore, currently reduces the flow of the
river within this 3.5 mile reach by the amount of its withdrawals.
For nearly all of this 3.5 mile reach, water levels are maintained by
the Argo, Geddes and Superior Dams.
The U. S. Geological Survey stream gauging station at Ann Arbor
is located within the 3.5 mile reach which is affected by Ann Arbor's
diversion. The 7-day, 10-year low flow estimated for this location
is 54 cfs. It is estimated that without Ann Arbor's diversion, 7-day,
10-year low flows would be roughly 70 cfs above Ann Arbor.
Ypsilanti currently withdraws about 20 percent, about 2 cfs, of
its annual water supply from the Huron River at Geddes Pond, Immedi-
ately following implementation of the interceptor system, 7-day, 10--
year low flows in the Lower Huron below Ann Arbor would be expected
to be reduced from roughly 52 cfs by the diversion of Ann Arbor's
and Ypsilanti's wastewater from the river.
Low flows could be further reduced in the future depending on
future water supply withdrawals by Ann Arbor and Ypsilanti. The
maximum withdrawal rate of the Ypsilanti Huron River water intake is
7.5 cfs. For Ann Arbor, the peak daily water demand for 1990 has
been projected at 58 cfs. Using this figure as a basis, the peak
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monthly demand for 1990 is estimated at 33 cfs. The peak 7-day demand
is then roughly estimated at 45 cfs. Ann Arbor's present groundwater
capability is 10 cfs. Thus, 35 cfs of the peak 7-day demand will have
to come from the Huron River or from other sources.
Assuming that Ypsilanti would withdraw 7.5 cfs and Ann Arbor 35
cfs for a total of 42.5 cfs, the 7-day, 10-year low flow in the Lower
Huron would be reduced from 70 to around 27.5 cfs. Should Ann Arbor
and Ypsilanti decide to obtain their water from a Great Lakes source,
low flows would not be a problem.
Ann Arbor does have the capability, however, to augment low flows
to some extent through use of the Barton, Argo and Geddes Impoundments.
The City of Ann Arbor developed its present water supply program in
1964 on the ability to withdraw sufficient water from the river to
meet the City's projected water supply needs to 1980 and still bypass
50 cfs or more over the Geddes Dam "during a recurrence of the minimum
recorded flow in the Huron River." The 50 cfs stream flow value was
agreed upon by the City and the State as a basis for approval of the
Ann Arbor wastewater treatment program established in 1961.
If it is assumed that Barton Pond would be drawn down one foot,
Argo Pond 2.5 feet and Geddes Pond 2.5 feet, low flow augmentation of
18.3 cfs for 30 days could be provided. With such augmentation, the
1990 7-day, 10-year low flow would be (27.5 cfs +18.3 cfs) roughly
45.8 cfs.
30
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(The reader is referred to Appendix D, to letters to Mr. Jerome
Maslowski dated December 27, 1971, and to Mr. Ralph Purdy dated
August 1, 1972, regarding water diversion from the Huron River.)
The Water Resources Commission's engineering consultants
recommended that consideration be given to flow augmentation for
th^ Huron River. Cost data were developed for three flow augmen-
tation alternatives which are fully presented in the appendix of the
report titled Plans for Water Quality Management Phase I Southeastern
Michigan Area.
These cost estimates have not been fully refined since the
necessity of low flow augmentation has not been established. For
example, the alternative of purchasing Detroit water assumes that
Ann Arbor's and Ypsilanti's total supply would be purchased from
Detroit. It might be more economical to purchase only a portion of
the total supply needed and to retain the Huron source as well as
groundwater sources. There is also the possibility that further
grou dwater sources can be developed. The U. S. Geological Survey
is presently studying the groundwater p otential of the Washtenaw
County area. When these studies are completed, Ann Arbor plans to
further investigate groundwater sources. Greater use of groundwater
would lessen Ann Arbor's dependence on the Huron River and would
therefore lessen the amount of river water subject to diversion to
the interceptor system.
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The Lower Huron from Ann Arbor to Lake Erie is 33.6 miles long.
About one-half of this distance is free-flowing and the remainder is
influenced by back water from impoundments or Lake Erie. In reaches
with backwater influence, the effects of low flow for short periods
would be minimized.
In. summary, the need for low flow augmentation in the Lower
Huron under Plan II has not been established and is not endorsed by
the proposed plan. The essential question is whether the reduction
of the 7-day, 10-year low flow from about 70 cfs to somewhere around
45.8 cfs (the flow that could be maintained with the use of flow
augmentation from the Barton, Argo and Geddes Impoundments) is of
such significance to warrant further low flow augmentation. If any
environmental degradation could occur from reduced flows it is
unknown at this time. If justification for further low flow augmenta-
tion is documented, solutions are available to satisfy such needs
and the alternatives considered should be refined to obtain the most
cost-effactive solution. Legal implications may also arise due to
the reduced low flows. In that event, the cost of compensating
damaged riparians should also be evaluated as an alternative to
further flow augmentation through structural means.
The proposed plan will result in the discharge of increased
amounts of treated wastewater volumes and constituents directly to
Lake Erie as the population of the service area grows. By 1990, for
example, the plant would be discharging 20,194 pounds/day of oxygen
consuming substances, 18,682 pounds per day of suspended solids, and
32
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678 pounds per day of total phosphorus. Any adverse effects are
anticipated to be minimal. However, lower loadings may be required in
the future.
The discharge point of the Huron River Treatment Plant proposed
under Plan II is to be located on the bottom of Lake Erie one mile
from shore. Plans for the proposed Pointe Mouillee Metropolitan Park
call for extending the existing shoreline through contained dredge
spoil disposal about one-half mile into the lake. It is anticipated
that the proposed park site would be used for spoil disposal purposes
until 1986 and that park development would occur after that date. It
may be possible that the plant's discharge could adversely affect
water quality along the shoreline of the proposed park under certain
weather conditions. The probability of this occurring has not been
determined. It should be subject to detailed evaluation, and warranted
modifications, if any, should be incorporated into the final design
of the plant's outfall.lt is not anticipated that there will be any
substantial cost increase for any waarranted outfall modifications
above the etimate included in the total cost for the outfall.
The land area proposed to be used as the site of the Huron
River Treatment Plant is presently undeveloped. Plantings of trees
are anticipated to enhance the site^s aesthetics. The proposed treat-
ment plant site is separated from and will not pre-empt the proposed
site of the Pointe Mouillee Metropolitan Park. No land use conflicts
33
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are anticipated nor will any relocations be necessary.
The proposed plan includes provision for sludge disposal through
incineration, temporary storage in ash lagoons and ultimate deposit.
At this stage of planning, a definite site for ash disposal from the
proposed Huron River Plant has not been selected, although it most
likely will be landfilled. The entire matter remains under study for
possible change to another method such as cropland disposal of sludge
or chemical jelling. Considerable latitude remains available until
the water quality management plan is approved, and all alternatives
for sludge disposal have been examined. If incinerators are used,
they will be designed ".to meet all air quality standards. Construction
of the interceptor system will result in some unavoidable environ-
mental degradation on a temporary basis. The project involves
approximately 89 miles of principal interceptor lines, a considerable
portion of which will parallel streams cr roads. Interceptor construc-
tion may result in temporary increased erosion and siltation, and
elevated turbidity levels in the area's streams. A certain amount
of vegetation would also have to be removed. Depending upon the final
location of the interceptor routes, some existing recreational lands
may be needed. The above effects resulting from construction
activities would also apply to any new collecting sewer systems
initiated in conjunction with the interceptor system.
Detailed route selections for the interceptors have not yet
34
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been determined. Completion of the detailed plans are awaiting
adoption of the regional plan. Upon adoption of the plan, consider-
able effort will be made to coordinate the final route determinations
with interested park and other local officials so as to minimize any
environmental or other disturbances. In addition, all proper construc-
tion techniques will be utilized to prevent or minimize adverse effects
that could occur during construction of the interceptor system.
The interceptor system will be contracted through and adjacent
to areas that are presently urbanized, with no portions of the system
extending into undeveloped outlying areas. The interceptors will be
sized to serve these developed areas plus the growth expected to occur
in the service area as predicted by SEMCOG. SEMCOG has based its
prediction for areas of development and population density through
the use of its computer model, with the acronym SEMOD. This model
predicts the area and location of dev elopment and population density
based, among other things, on the general population growth rate for
the Southeast Michigan area, and the past and present experience of
land use planning policies as practiced by the local units of governr
ment. Representative members from local areas familiar with the land
use planning policies of their areas, assisted in programming SEMOD
so that the local experience, wants and requirements would be reflected
in the prediction of new development areas and population densities.
Current State regulations place la nd use planning responsibility
35
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at the local government level. SEMCOG has predicted areas of develop-
ment and population density for 1990 through consideration of these
local land use policies. Given the predictions of land use, SEMCOG
has proposed a Regional Recreation and Open Space Plan which is offered
as a guide to local planning agencies. This plan suggests the delinea-
tion and preservation of regional public recreation and open space
land, and agricultural reservations.
As land use planning continues at the local government level, it
seems likely that urban sprawl may continue at a somewhat faster rate
than if land use planning was dictated at a regional level. While it
is]lpossible to foresee, implementation of the proposed interceptor
system will probably not affect planned land use, however, it may
accelerate current growth rates. Such growth, while in accordance
with land use plans for the area, may result in the need for additional
public expenditures for public services such as schools, stores, and
power supplies.
Admittedly, the availability of new sewer service can result in
pressures on local governments to allow growth and development to occur
at a faster pace and with increased density, contrary to what had been
previously planned and deemed desireable. It will be the responsibility
of lecal land use planners to guide expected urban development through
a smooth and proper transition of growth outward from presently
developed areas. The alternative is scattered, haphazard, leap-frog
36
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type development which inevitably puts a terrific strain and
expense on public services of all types. It is the obligation of the
public to be assured that their local governments have the necessary
power to establish and enforce wise land use controls, and that their
local governments are willing to control development.
Pro and Con of Proposed Plan II
Plan II has the advantage of providing maximum protection for the
Huron River, as well as meeting water quality standards in Lake Erie.
Even the possibility of temporary treatment plant malfunction will
not significantly degrade any waters. The planned location site is
in a relatively isolated area. The need for sewage treatment plants
and sludge incinerators in urban areas will be eliminated.
The negative side of Plan II is that flow rates in the Huron
River will be decreased. The environmental consequences of decreased
flow are, at this time, unknown. Also, the City of Ann Arbor is
opposed to being part of Plan II. If Ann Arbor were to remain alone,
their per capita costs would be somewhat lowered, but the remaining
service area population would have increased per capita costs.
V. ALTERNATIVES TO THE PROPOSED ACTION
Many alternatives were considered before arriving at the proposed
plan. The most feasible alternatives considered along with the
proposed plan are presented below. The 1990 service area for the
alternatives is the same as that for the proposed plan.
37
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A. Alternative Plan IB
Plan IB would consist of two major wastewater treatment plants
within the service area. A new major wastewater treatment plant,
capable of handling an average 1990 flow of 88 MGD, would be constru-
cted at the mouth of the Huron River with the discharge to Lake Erie.
In addition, the existing treatment plant at Ann Arbor would be
expanded to serve the projected 1990 flow of 33 MGD and would be up-
graded to provide tertiary treatment. With the exception of the Ann
Arbor area, wastewater from the service area would be conveyed to the
Huron River plant by the same interceptor system included in Plan II.
Both the Ann Arbor plant and the Huron River plant would provide 90%
phosphorus removal. (See Fig. 4)
1. Cost Estimates
Table 6 is a summary of Alternative Plan IB project costs.
Table 6
Millions of Dollars
Huron River Interceptor 30.36
Hannan Road Interceptor 21.98
North Arm 20.49
Van Buren Arm 15.47
City-Township of Ypsilanti Interceptor 5.06
Township of Ypsilanti Retention Basin 5.00
Huron River Plant 26.00
Total to Huron River Plant 124.36 ,
Ann Arbor Plant 18.34
Ann Arbor Retention Basin 5.00
Total to Ann Arbor Plant 23.34
Detroit River Rouge Interceptor 59.11
Redford Arm 4.31
TOTAL PROJECT COST 211.12
Annual operations and maintenance cost in 1990 equals $ 2.78 million
38
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Annual amortization cost" equals $16.52 million
Total annual cost in 1990 equals $19.30 million
*25 years at 6%
2. Impact on Lake Erie
The impact of alternative Plan IB on Lake Erie does
not differ significantly from the proposed plan. The pro-
jected direct gross waste loadings to Lake Erie from the
Huron River Treatment Plant under Plan IB are as shown in
the following Table 7.
Table 7
PLAN IB
Waste Loadings to Lake Erie
From the Huron River Treatment Plant
Waste Effluent Pounds Per Day
Constituents Concentration 1975 1990
(mg/1)
BOD 5 20 8,545 14,687
SS 18.5 7,905 13,587
TP 0.67 287 493
NH3-N 6.0 2,564 4,407
TN 14.6 6,240 10,727
Flow:
(MGD) 51.2 88
As with the proposed plan, alternative Plan IB would discharge
a large amount of oxygen consuming substances to Lake Erie. This
discharge would reduce the amount of pollutants discharged directly to
Lake Erie by about 25 percent as compared to Plan II and, thus, should
39
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not cause substandard dissolved oxygen conditions as long as the
following two conditions, set forth in the plan, are met: first, the
suspended solids concentration in the effluent should' be kept low to
minimize sedimentation of organic materials. Second, the effluent
should be well dispersed in the Detroit River current.
As in Plan II, the magnitude of the decrease in oxygen levels
under Plan IB can be approximated. Using 10 percent of the flow of
the Detroit River for assimilation, the discharge of 88 MGD (136 cfs)
from the Huron River Treatment Plant would result in a calculated
dissolved oxygen depletion of about 0.7 mg/1. This would lower the
average dissolved oxygen content of the receiving waters of Lake Erie
to a minimum of 6.9 mg/1, as compared with the reduction to 6.6 mg/1
under the proposed plan. The reduction in the dissolved oxygen content
of the receiving waters of Lake Erie resulting from alternative Plan
IB or from the proposed plan will meet water quality standards.
As with the proposed plan, consideration has also been given to
the impact on Lake Erie that could result from treatment plant mal-
function, accident or failure. Taking the worst possible situation
where complete failure of the treatment processes occurred, it is
highly improbable that any serious impact would occur at the Monroe
water supply intake located 12 miles away. Bacterial levels could be
elevated along the Michigan^shoreline of Lake Erie and thereby impair
water related recreational uses. The dissolved oxygen content, however,
40
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_ - ,.,.., ...p. , — - ., , . _-j 03 QNV1>(VO ] 1
: * i "I "• o I ° 1 o .
1 1 *" t--! 5 '1 . 1 ™ ! 10! 3! •„
'•' i ? i "» x, , [ "; ,•-"-• Cl • a.' •
'-; , " ! 5! /,^)'. : '• '«• 5
-------
I".II ••
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would not be reduced to less than 5.3 mg/1.
As stated in the discussion of the proposed Plan II, the primary
water quality problem in Lake Erie is generally considered to be
accelerated eutrophication brought about chiefly by high plant .. •
nutrients. Under Plan IB, total direct phosphorus loadings from the
Huron River Treatment Plant are estimated at 285 pounds per day in 1975
and 490 pounds per day in 1990. This is equivalent to 52 short tons/
year and 90 short tons/year, respectively. Although these direct
loadings are approximately 30% less than the phosphorus loadings that
would be discharged directly to Lake Erie from the Huron Plant
proposed under Plan II, most of the phosphorus discharged into the
Huron River at Ann Arbor would eventually be discharged into the
Detroit River. Thus, the total phosphorus loading to Lake Erie with
Plan IB would be nearly identical as with Plan II.
3. Impact on the Detroit River
Under Plan IB, no wastewater from the service area would be
discharged to the Detroit River. A small net decrease in waste loads
to the Detroit River would result from the diversion of a small volume
of wastewater to the proposed Huron River Treatment Plant. The effects
of this diversion on the Detroit River would be positive in nature,
but in all likelihood would be negligible.
4. Impact on the Lower Huron River
Under Plan IB, wastewater from the existing municipal waste1-
41
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water treatment plants at Ypsilanti, Ypsilanti Township, Flat Rock
and Rockwood would be transported via the proposed Huron River Inter-
ceptor to a new treatment plant at the mouth of the Huron River. (See
Table 5, p. 28. The Ann Arbor Service area would then be the only
remaining area discharging municipal wastes to the Lower Huron River.
The waste loadings anticipated at the Ann Arbor plant are shown in
Table 8.
Table 8
Waste Loadings from the Ann Arbor
Treatment Plant in 1970-71 and Projected
for 1975 and 1990
1970-71* 1975** 1990**
Average Flow (MGD): 14.5 21.6 33.0
Wastes Constituents: Pounds Per Day
1,102
2,754
185
137
4,022
* Secondary treatment provided
** Assumes Tertiary treatment (nitrification, sand filtration and
phosphorus removal).
As a result of the tertiary treatment plant at Ann Arbor, however,
waste loadings to the Lower Huron would be reduced (but not totally
eliminated) and the resultant water quality would be improved due to
the reduction of BOD, suspended and dissolved solids and nutrients.
Algae growths should decrease as the nutrient loads are reduced.
42
BODS
SS
TP
NH3-N
TN
2,644
2,895
828
721
1,803
121
90
2,632
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This will reduce diurnal dissolved oxygen variation and depletion which
would alleviate algal growth conditions and associated fish kills in
Ford and Belleville Lakes.
Nutrients could still cause a serious problem in these downstream
impoundments. By 1990, approximately one-half of the strearnflow below
the proposed Ann Arbor treatment plant would consist of treated waste-
water during drought conditions. Even with tertiary treatment included
in this plan, nutrient concentrations could cause a problem in the
slackwaters of the impoundments. However, the reduced oxygen consuming
demand and ammonia concentrations in the effluent should permit
compliance with the downstream dissolved oxygen standards. While it
is possible to minimize the risk of treatment plant breakdowns,
accidents or similar malfunctions, through duplicate components and
other means, such risks cannot be completely anticipated or eliminated.
Plan IB would reduce the 7-day, 10-year low flow from 70 cfs to
approximately 63 cfs. Such a reduction could have only a minimal
effect on the downstream environment and would be in compliance with
the minimum flow of 50 cfs as established for the Lower Huron River.
5. Impact on the Middle River Rouge
As in the proposed Plan II, alternative Plan IB would provide
relief to the Rouge Valley Interceptor System. The new Huron River
Interceptor System will handle the existing overflows to the west of
Hannan Road, thereby resulting in improved performance of the Rouge
Valley Interceptor System in the area east of Hannan Road. As a
43
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result, the amount and frequency of wastewater to the Middle Rouge
River and the Lower Rouge River would be reduced and the quality of
these streams would be improved. In addition, the value, utility
and aesthetics of the numerous streamside recreational areas would be
increased.
6. Impact on the Upper Huron Watershed
This area is close to the Detroit urban area and is being
subjected to strong developmental pressures. At present, the area
is served by septic tank disposal systems which will be unable to
handle future growth and will, therefore, contribute to contamination
of the lake and groundwater as the population increases. As in Plan
II an interceptor system is provided for under alternative Plan IB,
which is expected to alleviate this potential environmental degradation.
7. Overall Impacts
The overall impacts of alternative Plan IB are similar to the
proposed plan.
Provision for sludge disposal is included for both the Ann Arbor
and Huron River Treatment Plants under Alternative Plan IB. The
sludge handling process would probably include incineration, temporary
storage in ash lagoons and ultimate deposit. Ann Arbor would mix the
ash with sanitary landfill cover material in its landfill. A definite
site for ash disposal from the Huron River Plant has not been selected,
although it most likely will also be landfilled. The entire matter
remains under study for possible change to another method such as
44
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cropland disposal of sludge or chemical jelling. Incinerators would
be designed to meet all air quality standards.
Construction of the interceptor system will entail unavoidable
environmental degradation on a temporary basis. The project involves
approximately 84 miles of principal interceptor lines. Interceptor
construction is expected to result in increased erosion and siltation,
and elevated turbidity levels in the area's streams. A certain amount
of vegetation would also have to be removed. Depending upon the final
location of the interceptor routes, some existing recreational lands
may be needed. The above effects resulting from construction activ-
ities would also apply to any new collecting sewer sysgems initiated
in conjunction with the interceptor system.
While it is impossible to foresee, implementation of Plan IB could
also accelerate current growth rates in portions of the service area.
Such growth, while in accordance with the regional land use plans for
the area, may result in the need for additional public expenditures
for various public services.
Pro and Con of Alternative Plan IB
The advantages of Plan IB are that there would be only a minor
decrease in the flow of the Huron River since Ann Arbor would return
treated effluent to the river, and the Ann Arbor tertiary treatment
plant would remove a substantial amount of pollutants. Water quality
standards would be met for the Huron River, as well as Lake Erie.
45
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However, there would be a relatively large concentration of phosphorus
discharged to the Huron River during low flows, most of which would
eventually reach Lake Erie, anyway.
Treated sewage effluent from an Ann Arbor tertiary treatment
plant cauld reach such volumes by 1990 as to become a substantial
portion of the river flow during low flow periods of the Huron River.
Any treatment plant malfunction during these times could have serious
detrimental effects on the water quality of the river. Although it
appears that only Ann Arbor supports Plan IB, it is conceivable that
other communities may wish to retain their own treatment plants on
the Huron River if Ann Arbor is allowed to do so, rather than finance
the interceptors without Ann Arbor's support.
B. Alternative Plan III
This plan proposes the abandonment of the existing plants on the Huron
River and the construction of an interceptor extending from a new
wastewater treatment plant on the Huron River to Ann Arbor. Also
included is an interceptor in Hannan Road from the Huron River north
to Canton Township. This system of interceptors would transport the
wastewater for treatment to the proposed new Huron River Plant.
The balance of the area would be serviced by the existing Detroit
Wastewater Plant through an interceptor extending from the Detroit
Plant northwesterly along the Rouge River to Plymouth Road; thence
westerly along Plymouth Road to Hannan Road; thence northerly to
46
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White Lake Township in Oakland County. (See Map, Fig. 5)
The service area involving the Detroit Rouge River and Plymouth
Road Interceptors encompasses considerable area outside the study area.
The proposed Detroit Rouge River Interceptor is planned for early
construction to relieve the existing Detroit Rouge Interceptor and
provide a more suitable outlet for the Evergreen and Farmington Inter-
ceptor districts in Oakland County. Therefore, the timing for
providing for the joint service area would coincide.
The 1990 design flow of the Huron River Wastewater Treatment
Plant is 91.5 MGD and the secondary treatment process is oxygen
activated sludge with phosphate removal. This design flow provides
for the estimated 1990 population within the service area. Table 9
shows the cost estimates for this plan.
Table 9
Cost Estimates Millions of Dollars
Alternative Plan III
Huron River Interceptor 32.00
Hannan Road Interceptor 10.23
Van Buren Arm 23.66
Ann Arbor Arm 14.35
Huron River Plant 26.75
Ann Arbor Retention Basin 5.00
Township of Ypsilanti Retention Basin 5.00
Total to Huron River Plant 116.99
Detroit River Rouge Interceptor 62.36
Plymouth Road Interceptor 12.02
North Arm 20.49
Total to Detroit Plant 94.87
TOTAL PROJECT COST 211.86
Annual operation & maintenance costs in 1990 = $ 2.69 million
47
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Annual amortization cost*
Total annual cost in 1990
= $16.57 million
= $19.26 million
* 25 years at 6%
2. Impact on Lake Erie
The probable impact on Lake Erie would be nearly identical to the
impacts already discussed for the proposed plan and for alternative
plan IB. The projected flows and waste loadings from this plant would
be as follows:
Table 10
Plan III
Waste Loadings to Lake Erie
From the Huron River Treatment Plant
Waste
Constituents
BOD 5
SS
TP
NH3-N
TN
Flow=
Effluent
Concentration
(me/D
Pounds per Day
1975
1990
20
18.5
0.67
6.0
14.6
9,296
8,600
312
2,790
6,788
15,267
14,128
512
4,582
11,151
55.7
91.5
The impact of this discharge would be largely identical to that
identified for Plan IB. As there is only a small difference between
waste flows and loadings to Lake Erie under Plans IB and III, dissolved
oxygen depletion in the receiving waters under Plan III should
approximate that calculated for Plan IB, or around 0.7 mg/1.
48
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All of the other impact considerations previously discussed for Plans
IB and II relative to Lake Erie would also apply to Plan III.
3. Impact on the Detroit River
Under Plan III, wastewater from Plymouth and Northville
Townships in western Wayne County would be treated at the Detroit
Wastewater Plant with discharge to the Detroit River near the mouth
of the Rouge River.
The waste loadings to the Detroit River from this wastewater
flow would be as shown in Table 11.
Table 11
Plan III
Waste Loadings to the Detroit River
Effluent
Waste Concentration Pounds per day
Constituents (mg/1) 1975 1990
BOD 5
SS
TP
NH-N
TN 3
Flow
MGD 17.1 29.5
The Detroit Wastewater Plant now serves about three million people in
Detroit and surrounding communities. The average flow is presently at
the rate of 760 MGD. The present hydraulic capacity of the plant is
1300 MGD. This will be increased to 2600 MGD with completion of the
planned additions. Construction now in progress and planned will
49
20
18.5
0.67
6.0
14.6
2,855
2,641
96
856
2,084
4,927
4,554
165
1,477
3,595
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provide an effluent quality in accordance with stipulated water quality
standards. Facilities will be provided for treating up to 1800 MGD
by the activated sludge process with an additional 800 MGD given primary
treatment during peak storm flow periods.
The projected flow from the portion of the study service area
proposed for treatment at the Detroit facility under Plan III repre-
sent only a very minor portion of the total flows being provided for.
The projected 1990 flow of 29.5 MGD represents about 1.6 percent of
the plant's planned secondary treatment capacity of 1800 MGD. No
significant water quality effects are anticipated for the Detroit
River as a result of this additional flow.
The Detroit Wastewater Treatment Plant, as with all other treat-
ment facilities in this area, may be required to institute higher
levels of treatment in the future due to changes in national policy or
other considerations. Also, higher phosphorus removal levels may be
necessary in the future.
Future flexibility may also be limited at the Detroit Plant in
comparison with other options. Expansion of treatment facilities and
interceptors to the plant would likely be costly due to the size of
the plant site, the scale of the facilities existing and planned, and
the highly developed nature of the area.
4. Impact on the Lower Huron
The impact of Alternative Plan III on the Lower Huron would
50
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be identical to that identified for Plan II. In brief, all existing
municipal wastewater discharges would be removed from the Lower Huron;
considerable improvement would be expected in water quality, particu-
larly in the impoundments of the Lower Huron; some water quality
problems will remain, particularly those due to stormwater runoff;
flows would be reduced as a result of wastewater diversions; and
present and prospective water uses would be enhanced.
5. Impact on the Middle River Rouge
The impact of Alternative Plan III on the Middle Rouge River would
be identical to the impact of Plans IB and II. The Plymouth Intercep-
tor would provide relief to the existing Rouge Valley Interceptor
System. This relief would reduce the frequency and magnitude of over-
flows to the Middle River Rouge.
6. Impact on the Upper Huron Watershed
The impact of Alternative Plan III on the Upper Huron Watershed
would also be identical to that of Plans IB and II.
7. Overall Impacts
The Huron River and Detroit Treatment Plants will discharge
increasing amounts of wastewater volumes and constituents to Lake
Erie and the Detroit River as the population of the service area grows.
By 1990, for example, the two plants will be discharging 20,194
pounds/day of oxygen consuming substances, 18,682 pounds/day of suspended
solids, and 677 pounds/day of total phosphorus (contributed from the
51
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Huron Basin service area). No significant adverse effects of these
loadings are anticipated, however, lower phosphorus loadings may be
required in the future.
Construction of the Plan III would likely entail some unavoidable
environmental degradation on a temporary basis. The project involves
approximately 92 miles of principal interceptor lines, a considerable
portion of which will parallel streams. Interceptor construction could
result in increased erosion and siltation, and elevated turbidity
levels in the area's streams. A certain amount of vegetation would
also have to be removed. Depending upon the final location of the
interceptor routes, some existing recreational lands may be needed.
The above effects resulting from construction activities would also
apply to any new collecting sewer systems initiated in conjunction
with the interceptor system.
While it is impossible to foresee, implementation of the inter-
ceptor system may also accelerate current growth rates in portions of
the service area. Such growth while in accordance with the regional
land use plans for the area, may result in the need for additional
public expenditures for various public services such as schools,
stores and power supplies.
Pro and Con of Alternative Plan III
The ecological affects of Plan III would be largely identical
to Plan II. Water quality standards in Lake Erie would be met,
5-2
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maximum protection for the Huron River would be provided, however,
flows in the Huron River would be decreased.
The major difference between Alternative Plan III and Proposed
Plan II is that wastewater from the Upper Huron River service area
would be sent to the Detroit Treatment Plant which is scheduled to be
expanded to a capacity of 1^800 MGD. There appears to be no support
for Alternative Plan III.
C, Alternative Plan IV
Alternative Plan IV proposes two interceptor systems and two
inland tertiary treatment plants within the service area. The Huron
River Interceptor would extend from a new plant on Lake Erie along
the Huron River to the present Ypsilanti Township Treatment Plant. A
North arm would follow Hannan Road from the Huron River to Canton
Township. Tertiary treatment plants would be constructed at Ypsilanti
and Ann Arbor using nitrification of the sewage with rapid sand
filtration and phosphate removal for a 1990 projected average flow of
10 MGD at Ypsilanti. The balance of the service area would be served
by the existing Detroit wastewater plant through an interceptor
extending from the Detroit Plant westward to Plymouth Township and
then northerly to White Lake Township in Oakland County. (See Map,
Fig. 6)
The 1990 service area involving the Detroit Rouge River and
Plymouth Road Interceptors encompasses considerable areas outside the
53
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study service area. The proposed Detroit Rouge River Interceptor to
relieve the existing Detroit Rouge Interceptor and provide a more suit-
able outlet for the Evergreen and Farmington Interceptor districts in
Oakland County is planned for early construction. Therefore, the
timing for providing for the joint service areas would coincide.
The Huron River Wastewater Treatment Plant's design 1990
average flow is 48.5 MGD and the secondary treatment process is oxygen
activated sludge with phosphate removal. This design flow provides
for the estimated 1990 population within the service area.
1. Cost Estimates
A summary of the selected project cost and the total 1990 and 2020
project costs are as shown in Table 12.
Table 12
Alternative Plan IV Millions of Dollars
Huron River Interceptor 24.58
Hannan Road Interceptor 10.23
Van Buren Arm 14.11
Huron River Plant 17.20
Township of Ypsilanti Retention Basin 5.00
Total to Huron River Plant 71.12
Detroit Rouge River Interceptor 62.36
Plymouth Road Interceptor 12.02
North Arm 20.49
Total to Detroit Plant 94.87
City of Ann Arbor Plant 18.34
Ann Arbor Retention Basin 5.00
Total to Ann Arbor Plant 23.34
City of Ypsilanti Plant 7.02
TOTAL PROJECT COST 196.35
Annual operation and maintenance
cost in 1990 3.66
54
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r
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Annual amortization cost* 15.35
Total annual cost in 1990 19.02
A Z": %e
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of Lake Erie would be 0.39 mg/1 in 1990, which would theoretically
lower the existing average dissolved oxygen level of the receiving
waters of Lake Erie from 7.60 mg/1 to 7.21 mg/1.
3. Impact on the Detroit River
The impact of Alternative Plan IV on the Detroit River would be
completely identical to the impact of Plan III. There are no differ-
ences between Plans III and IV on the population to be served, waste-
water flows or waste loadings to the Detroit River.
4. Impact on the Lower Huron
The impact of Plan IV on the Lower Huron will be similar to that
of Plan IB although there would be tertiary treatment plants at both
Ann Arbor and Ypsilanti. Waste loadings to the river would be reduced
by the elimination of four treatment plants from the river and the
provision of higher levels of treatment at Ann Arbor and Ypsilanti.
Table 14 shows the waste discharges that would be removed from the
river and transferred to the Interceptor System.
Table 14
Plan IV
Average Waste Loads Removed from the
Lower Huron from 1970-1971
Reports to the Michigan Depart-
ment of Public Health
Flow Pounds per day
Plant (MGD) BOD5 _SS P_
Ypsilanti Township #1 2.28 244 314 27
Ypsilanti Township #2 4.67 432 605 26
56
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Average Waste Loads(continued)
Flat Rock 0.74 271 267 16
Rockwood 0.31 309 176 _37
TOTAL 8.00 1,256 1,362 106
The following Table 15 compares existing waste loads from the Ann
Arbor and Ypsilanti Plants and projected loads for 1975 and 1980.
Table 15.
Waste Loadings from the Ann Arbor and Ypsilanti Treatment
Plants in 1970-71 and Projected for 1975 and 1990
ANN ARBOR 1970-71 1975 1990
Average flow (MGD) 14.5 21.6 33.0
BOD 5 (pounds/day) 2,644 721 1,102
SS 2,895 1,803 2,754
YPSILANTI
Average flow (MGD) 6.48 8.5 10
BOD 5 (pounds/day) 1,388 284 334
SS 1,533 709 834
As a result of reduced waste loads to the Lower Huron, water quality
would be improved. The degree of improvement should closely approxi-
mate that expected through implementation of Plan IB. In summary,
existing stream concentrations of BOD, suspended and dissolved solids
and nutrients would be lowered; higher dissolved oxygen levels would
be expected. Particular water quality improvement would be anticipated
in the stream impoundments of the Lower Huron. Algal growths should
be decreased and diurnal dissolved oxygen variation reduced.
By 1990, stream flow below the Ann Arbor-Ypsilanti area would
consist of a significant portion of treated wastewater during drought
periods. Nutrients, particularly nitrogen and phosphorus, could
57
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become a serious problem in the plant's effluents. However, the low
limit set for BOD 5 and ammonia concentrations should preclude any
dissolved oxygen standards violation from occurring downstream; also,
suspended solids, bacteria and toxicant limits should prevent any
standards violation. Of course, these predictions assume adequate
and continually reliable performance of the treatment plants to
produce effluents that will fully meet the specified effluent restric-
tions .
As with all of the plants considered for this service area, these
plants may have to provide increased levels of treatment in the future
due to changes in national policy or other considerations. Increased
phosphorus removal may be required in the future.
Some water quality problems will remain. Stormwater runoff is
regarded as a significant water quality problem in this area. This
need is not addressed by Plan IV nor by any of the other plans.
Previously existing sludge deposits might provide sources of BOD
and nutrients for some time. Overall, however, considerable
improvement in the water quality of the Lower Huron should be achieved.
While daily waste loads to the Lower Huron would be drastically
reduced, the river would still be subject to risks of water quality
deterioration resulting from treatment plant breakdowns, accidents or
other misfortunes. Some degree of uncertainty must also be attached
to the ability of the treatment plants to maintain high performance
58
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levels on a continuous basis so as to coniiriv co the stringent effluent
requirements specified. These subjects have beer di"trustee under the
impact of Plan IB. They are equally applicable here and, in fact, are
more significant as Plan IV proposes two inland tertiary treatment
plants. Moreover, the Ypsilanti Vlant would discharge its treated
effluent directly into Ford Lake, a body of water designated for total
body contact recreational use.
One additional positive feature of Plan IV is that treated
effluent would be returned to the river at Ann Arbor and Ypsilanti,
low flows would not be decreased and, therefore, low flow augmentation
need not be considered.
The expected water quality improvement would enhance present
and prospective use of the Lower Huron particularly for fishery and
recreational uses. The discussion of use enhancement presented under
the probable impact of Plans IB and II is applicable to Plan IV.
The present Ypsilanti wastewater treatment plant is located on
Ford Lake. There is little available area at this site for expansion.
Additional area would likely have to be created through filling of
low lying shoreland or lake area. This could create localized adverse
environmental effects.
"i. Impact on the Middle River Rouge
Under Plan IV, the impact on the Middle River Rouge would be
identical to that of Plans IB, II and III.
59
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6. Impact on the Upper Huron
The impact of Plan IV on the Upper Huron would be identical to
the impacts previously identified for Plans IB, II and III. The plan
would enable the southwestern Oakland County area to meet present and
future wastewater management needs.
7. Overall Impacts
Plan IV would provide for the largest removal of wastewater
constituents of the four plans considered. In 1990, treatment facili-
ties proposed in Plan IV would discharge substances consuming some
14,456 pounds of oxygen, 15,631 pounds of suspended solids, and 678
pounds of phosphorus. No adverse effects would be anticipated from
Plan IVs discharge although higher phosphorus removal levels may be
required in the future.
Construction resulting from implementation of Plan IV would
likely entail some unavoidable environmental degradation on a temporary
basis. The project involves approximately 82 miles of principal
interceptor lines, a considerable portion of which will parallel
streams. Interceptor construction could result in increased erosion
and siltation, and elevated turbidity levels in the area's streams.
A certain amount of vegetation would also have to re removed. Depend-
ing upon the final location of the interceptor routes, some existing
recreational lands may be needed. The above effects resulting from
construction activities would also apply to any new collecting sewer
systems initiated in conjunction with the interceptor system.
60
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Wliile is is impossible to foresee, implementation of Plan IV may also
accelerate current growth rates in portions of the service area. Such
growth while in accordance with the regional land use plans for the
area, rnay result in the need for additional, public expenditures for
various public services such as schools, stores, and power supplies.
Pro and Con of Alternative Plan IV
The advantages of Alternative Plan IV are that it would provide
the lowest volume of treated effluent discharged directly to Lake Erie,
and there would be no decrease in flow in the Huron River.
This alternative would, however, discharge the greatest volume
of effluent to the Huron River. There appears to be no support for
Alt ernative Plan IV.
D. Land Disposal Alternative
Consideration was also given to the following two land disposal
alternatives:
1. Land disposal for the entire interceptor service area,
and;
2. Land disposal for the Ann Arbor, Ypsilanti and Ypsilanti
Township service area.
These land disposal alternatives, if feasible, could provide a great
reduction of waste constituents from reaching the surface waters of
the area. The general practice of land disposal involves removing the
majority of waste constituents in the sewage by standard treatment
methods, followed by land application whereby the effluent filters
61
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through the soil. The water filtering through the soil then enters
the groundwater regime or is intercepted by underground drainage systems
and sent to surface waters.
The first alternative calls for collecting all the wastewater in »
the service area for treatment, and rather than discharging to the
Huron River or Lake Erie, is discharged to land disposal areas. The
second alternative calls for collecting wastewater from the Ann Arbor,
Ypsilanti and Ypsilanti Township service areas for ultimate land disposal.
The remainder of the service area would send its wastewater for treat-
ment at the Huron River treatment plant with discharge to Lake Erie.
The first alternative would require sufficient land area to
spray irrigate a total of 121 MGD by the year 1990. Using the Corps
of Engineers recommended application rate of 2 inches per week for 43
weeks per year,* the area of land needed for irrigation would be about
20,000 acres, without considering any land needs for a buffer zone.
The Corps of Engineers estimates the cost of purchasing the land at
$2,200/acre; cost of underdrains at $4,300/acre; and cost of land
leveling at $350/acre for a total of $6,850/acre. For a total of
20,000 acres, the total land cost is $137 million. To this cost must
be added $118 million for the interceptors as proposed under Plan II,
plus the cost of a 3-stage lagoon treatment plant, plus added pumping
and interceptor costs to convey the lagoon effluent to the spray
''"Alternatives for Managing Wastewater for Southeastern Michigan—
Report." Prepared by the U. S. Army Corps of Engineers - Detroit
District. July 1971.
62
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irrigation area and additional interceptors from the irrigation site
to the receiving water courses.
The second alternative, land disposal for wastewater from Ann
Arbor, Ypsilanti and Ypsilanti Township, would require sufficient
land area to spray irrigate a total of 68 MGD by 1990. Using an
application rate of 2 inches per week for 43 weeks per year, the area
of land needed for irrigation would be about 11,000 acres for a total
land cost of about $75 million. To this cost must be added the costs
of secondary treatment, pumping and piping to the spray irrigation
siteand from the site to the receiving water course. This total cost
would greatly exceed $63 million, the estimated total cost of providing
advanced waste treatment for Ann Arbor and for Ypsilanti City-
Township, and would also greatly exceed the total cost of the proposed
Plan II.
In addition to being undesirable due to high costs, socio-
economic disruption to the area could be substantial. Although
specific areas have not been delineated as spray irrigation sites, the
minimum land area requirements for the alternatives of 20,000 acres
and 11,000 acres (30 square miles and 17 square miles) would probably
require the removal of homes and families, and the disruption of
transportation and communication facilities. This alternative would
lock the area into a long-term solution. Should technological advance-
ments occur which might substantially reduce the cost of conventional
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treatment, this alternative would have difficulty adjusting to take
advantage of such lower cost treatment.
Pro and Con of Land Disposal Alternative
The advantage of this alternative would be the great decrease of
pollutants to surface waters, thereby offering the greatest protection
of the surface waters.
The disadvantages are the great increase in costs, miles of
interceptors, and amount of land needed and resulting displacement of
people and public and private facilities. There is also a problem of
management of so extensive a method of pollution control. There
appears to be no support for this alternative.
E. No Action Alternative
The alternative of no action is not feasible, since water quality
standards for the Huron River Basin Area will not be met.
VI. Comparison of Proposed Plan (Plan II) and Major Alternatives
(Plans IB, III and IV)
Table 16 is a comparison of costs and environmental considerations
for the proposed plan and the major alternatives. Capital costs
and operation and maintenance costs were derived from standardized
cost curves. The total annual capital costs were derived by amortizing
the total capital costs, assuming a 25-year bond life at 6% interest
per year. The 0 & M costs as presented in the table are based on
wastewater flows for the years 1975 and 1990.
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Table 16
Comparison of Costs & Other Factors
1. Capital Costs of Selected Projects Cost in $ Millions
IB II III IV
T,
Total Capital Costs ** $211.12 $224.25 $211.86* $196.35*
Total Detroit - Rouge
Interceptor Costs ** 63.42 63.42 63.42 63.42
Total Capital Cost
Excluding Detroit - Rouge
Interceptor 147.70 160.83 148.44 132.93
Total Annual Amortization
Cost (25 years @ 6%) 11.55 12.58 11.61 10.40
Annual Operation and M
Maintenance Costs
1975 2.07 1.56 1.90 2.53
1990 2.78 2.14 2.69 3.66
Total Annual Costs
1975 13.62 14.14 13.51 12.93
1990 14.33 14.72 14.30 14.06
* The total capital costs for Plans III and IV do not include the
capital cost of all of the treatment facilities required since that
portion of the Detroit Wastewater Treatment Plan required to provide
for the service area is not included.
** The Detroit Rouge Interceptor is planned for early construction to
relieve the existing Detroit Rouge Interceptor and provide a more
suitable outlet for the Evergreen and Farmington Interceptor Districts
in Oakland County. This interceptor is a necessary link in Plans III
and IV. It was, therefore, included in all four alternative plans so
that a total cost comparison could be made.
65
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Table 16 (continued)
2. Design Capacities (1990), MGD
Huron River Plant
Ann Arbor Plant
Ypsilanti Plant
Detroit Plant Portion
* Initial (1975 demand on
3. Level of Treatment
Huron River Plant
Ann Arbor Plant
Ypsilanti Plant
Detroit Plant
4. Effluent Discharge
IB II III
88 121 92
33
_
- - 29
these facilities would be 73 mgd.
IB II III
secondary secondary secondary
advanced - -
_
secondary
a. Discharge to Lower Huron River in pounds/day
IB II III
BOD 5
SS
TP
TN
b. Discharge to Lake
BOD 5
SS
TP
TN
1,102 0 0
2,754 0 0
185 0 0
4,022 0 0
Erie
IB II III
14,687 20,194 15,267
13,587 18,682 14,128
493 678 512
10,724 14,762 11,151
IV
49
33
10
29
IV
secondary
advanced
advanced
secondary
IV
1,436
3,588
IV*
8,097
7,489
272
5,910
Does not consider waste discharges to Detroit River from
service area.
66
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Table 16 (continued)
Reliability of Protection
15. IL
i. Huron River adequate maximum
III
IV
adequate
maximum
ii. Lake Erie adequate adequate adequate adequate
* All alternatives will meet Water Quality Standards.
Stream Flow
IB
6.
% reduction in 7-day, 10-year
low flow below Ann Arbor
10%
Land
a. Regional Growth
Patterns Conformance
with regional land
use plans Conforms
II
36%
III
36%
IV
Interceptors
Length (miles)
i.
84
Conforms
89
Conforms Conforms
92
ii. Adverse Impacts* moderate moderate moderate
*Effects will be most severe during construction.
7. Pro and Con
a. Proposed Plan II
i. Pro
- Will meet Lake Erie Water Quality Standards
- Maximum protection for Huron River
- Single treatment plant provides maximum opportunity
for efficient management
- Isolated plant location, no treatment plants or
sludge incinerators in urban areas
82
moderate
67
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- Temporary treatment plant malfunction will not
violate water quality standards
- All service area residents will share costs of
interceptors
- Supported by SEMCOG and MWRC
ii. Con
- Decrease flows in Huron River
- Opposed by Ann Arbor
Alternative Plan IB
i. Pro
-• '/\' 1 meet Lake Erie water quality standards
- Will meet Huron River water quality standards
- Ann Arbor tertiary plant will increase removal
of pollutant materials from surface waters, with
exception of phosphorus.
- Only a minor decrease in Huron River flows
- Supported by Ann Arbor
ii. Con
- Discharges relatively large concentrations of
phosphorus to Huron River, most of which would
reach Lake Erie
- Temporary treatment plant malfunction at Ann Arbor
would probably violate water 'quality standards in
Huron River
- Withdraws Ann Arbor's financial support of the
interceptors
- Opposed by SEMCOG and MWRC
68
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c. Alternative Plan III
i. Pro
- Will meet Lake Erie water quality standards
Maximum protection for Huron River
ii. Con
- Decrease flows in Huron River
- Future flexibility for expansion or treatment
levels at the Detroit plant is decreased due
to size and urban location.
- No support
d. Alternative Plan IV
i. Pro
- Will meet Lake Erie water quality standards
- Will meet Huron River water, quality standards
- No decrease in flows of Huron River
- Will remove the most pollutant materials, with
exception of phosphorus
ii. Con
- Greatest volume of sewage effluent discharged
to Huron River
- Temporary treatment plant malfunction at Ann
Arbor or Ypsilanti wuuld probably violate water
quality standards in Huron River
- No support
e. Alternative Land Disposal Plan
i. Pro
- No direct discharge of pollutants to surface waters,
69
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ii. Con
- High Cost
- Large amount of needed land
- Displacement of people, homes, public facilities,
etc.
- Large increase in interceptor length
- Difficulty of managing extensive spray irrigation
sites.
- No support
After extensive consideration, the EPA has concluded that Pro-
posed Plan II is the most environmentally compatible and manageable
water quality management plan. This plan offers the best alternative
of protecting all waters involved enabling water quality standards to
be met on a continuous basis. The Huron River and Lake Erie should
not be considered as separate entities, for they are both part of the
same hydrologic system. The proposal to discharge the total amount
of treated effluent into the larger portion of the system is, in this
situation, not only more environmentally compatible, but also prudent
management.
The environmental cost of this system is decreased flows in the
Huron River, possibly up to a 36% decrease in the 7-day 10-year low
flow by 1990. It is not known at this time if such a decrease in flow
would cause any environmental degradation. Should Ann Arbor and
Ypsilanti supply their future increased water demands from sources
other than the Huron River, the problem of decreased flows will not
arise.
70
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VII. Relationship between short-term beneficial uses vs. long-term
environmental consequences for the proposed Plan II.
upon completion of the wastewater treatment system proposed in
Plan II, presently developed areas in southwestern Oakland County,
eastern Washtenaw County and western Wayne County will divert their
wastewater to the Huron River treatment plant. The lake area of south-
western Oakland County is experiencing sewage disposal problems
primarily in the form of numerous nutrient-rich sewage treatment plant
effluents which are causing nuisance algae conditions in the lakes.
Removal of these effluents will preserve these lakes for recreation
use. The proposed system will also remove all treatment plant effluents
currently discharged to the Lower Huron River to protect the river
for recreational use.
In addition to removing present wastewater discharges from the
service area so that water quality standards can be met, the system
will be sized to handle future wastewater problems expected to be
generated by the predicted rapid population increase in the service
area.
The collected wastes from the service area (121 MGD by the year
1990) will be treated at a single plant and discharged to Lake Erie.
The degree of treatment will be adequate to meet the current water
quality standards for Lake Erie. The proposed system, with one
regional treatment plant, will establish a policy of a large regional
wastewater treatment system for many years to come. As a result, the
71
-------
sites used for the Huron River treatment plant and the locations of
the interceptors will be committed for waste treatment purposes for
the foreseeable future, Further, this system will help to establish
the environmentally-sound policy of utilizing the connecting Great
Lakes waters in the southeastern Michigan area to assimilate the
effluents of wastewater treatment plants, rather than discharging to
inland waterways.
The interceptors will be sized to handle future wastewater flows
from the predicted growth of population and urbanization. It is under-
stood that urbanization will occur in portions of the service area
which are currently rural. If wise land use controls are established
and adhered to, the availability of sewer service, after implementation
of the proposed plan, should not generate undesirable urban growth
patterns.
VIII. Irreversible and Irretrievable Commitment of Resources
Except for the materials of construction for the waste treatment
system, there will be no irreversible or irretrievable commitment of
resources. It is possible to remove interceptor sewers and treat-
ment plants, and revert the land areas back to their natural state.
Realistically, however, the proposed system will commit the intercep-
tor sites and treatment plant site for wastewater treatment purposes
for the foreseeable future.
IX. Opportunity & Extent of Public Participation
During 1971, fourteen meetings, conferences &nd hearings were
72
-------
held by the State of Michigan concerning the wastewater management
needs for the Huron River Basin Area. These meetings were attended by
Federal, State and local agencies. The City of Ann Arbor was
represented at about eight of the meetings. Other local units within
the study area were broadly represented. Based upon information
provided by the State of Michigan resulting from these meetings, it
appears that Ann Arbor and portions of Washtenaw County support Plan
IB. The other municipalities in the study area either support the
proposed Plan II or appear neutral.
The Michigan Water Resources Commission prepared an Environmental
Assessment on the proposed plan. The assessment also covered the
major alternatives considered. The Commission distributed copies • of
the assessment to interested agencies and individuals. In addition,
the Region V Office of EPA distributed copies of the assessment to
any interested parties and requested their comments. Appended to
this report are copies of representative comments received on the
assessment as well as on the plan. All views concerning the proposed
plan were considered during the preparation of the draft environmental
impact statement.
73
-------
LIST OF APPENDICIES
Appendix A Coats
Appendix B Agreement Between Canada and the
United States of America on Great
Lakes Water Quality
Appendix C Fisheries Renovation Project for
Huron River
Appendix D Letters of Comment
-------
APPENDIX A
COSTS
The following is a presentation of costs complied by the staff of
the Michigan Water Resources Commission reflecting the local share
of the costs for the proposed Plan II and major alternatives.
This cost comparison was done prior to the new Federal Water
Pollution Control Act Amendments of 1972, which raises the Federal
share of construction grants from 55% to 75%.
-------
Average Annual Costs of Selected Projects*
(millions of dollars)
Plan
Average Annual Amor- IB II III IV
tization Cost** 2.89 3.14 2.90 2.60
Annual Operation and
Maintenance Costs
1975 2.07 1.56 1.90 2.53
1990 2.78 2.14 2.69 3.66
Total Annual Costs
1975 4.96 4.70 4.80 5.13
1990 5.66 5.28 5.59 6.25
* Average annual costs are based only on the local share of capital
costs.
** Based on 25 years bond at 6 percent interest.
These average annual costs can be further subdivided into average
annual per capita costs for the respective service areas. Thus, while
there would be only one treatment plant and one service area under
Plan II, Plan IV would have four treatment plants and service areas.
Average Annual Per Capita
Costs of Alternative Selected Projects by Service Areas
Plan and Service Area Average Annual Per
Service Area Population Capita Cost
1975 1990 1975 1990
279,723
134,547
414,270
489,591
205,470
695,061
13.30
9.21
11.97*
8.48
7.36
8.16
Plan IB
Huron River
Ann Arbor
TOTAL
Plan II
TOTAL 414,275 695,061 11.35* 7.60*
-------
301,733
112,542
414,275
32,138
112,542
135,038
134,547
414,275
498,728
196,333
695,061
38,000
196,333
255,258
205,470
695,061
12.06
10.30
11.59"
15.75
10.40
16.44
9.21
12.38*
8 . 10
7.89
8.04*
14.77
7.89
10 . 30
7.36
8.99
Plan III
Huron River
Detroit
Plan IV
Ypsilanti
Detroit
Huron River
Ann Arbor
*Indicates Avg. cost per capita average
From the data presented above, it can be seen that:
a) The plan with the lowest capital cost is Plan IV; Plan II
has the highest capital cost.
b) Plan II has the lowest average annual cost and average
annual per capita cost (for local costs).
c) While Plan II offers the lowest per capita cost to the
region, the Ann Arbor service area would be afforded a signi-
ficant cost advantage under Plan IB in 1975. A similar cost
advantage would exist in 1990 although at a lower magnitude.
The cost advantage provided to the Ann Arbor service area
under Plan IB, as opposed to Plan II, would be offset by a
cost disadvantage to the remainder of the region.
d) Under Plan IV, the Ypsilanti City service area would incur a
significant cost disadvantage relative to the other alterna-
tive plans.
e) Under Plans III and IV, th re would be a short-term cost
advantage to Oakland County to have its wastex^ater handled by
Detroit, as opposed to the Huron River Treatment Plant under
Plan II. This cost advantage would reverse itself by 1990.
-------
f) Finally, it should be noted that these per capita and
average annual costs are only valid during the life of the
bond issue. After the debt is amortized, operation and
maintenance costs of the treatment plants become the princi-
pal economic consideration. At that point, the plan with
the least number of plants and the least costly treatment
processes (which adequately meet water quality standards
and other applicable requirements) would be the most
economical.
1990 Project Costs
In comparing the costs of the selected project for the four
alternative plans, it should be recognized that all of the treatment
plans have been designed to meet 1990 needs while portions of the
interceptor systems are designed for 2020 needs to avoid costly
future relief. Thus, a valid comparison of the costs of the alterna-
tive plans can be made by comparing the 1990 design project rather than
the selected project. Costs for the 1990 project would be as follows:
Costs of 1990 Project
Plan
LB II_ III TV_
Total Capital Costs 196.39 201.99 190.02 182.04
Total Capital Costs •-
excluding Detroit
Rougallntetceptor 139.34 144.94 133.65 125.67
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Average Annual Costs of 1990 Project
Plan
IB, II_ III IV
Average Annual Amor-
tization Cost** 2.73 2.84 2.62 2.46
Annual Operation and
Maintenance costs
1975 2.07 1.56 1.90 2.53
1990 2.78 2.14 2.69 3.66
Total Annual Costs
1975 4.80 4.40 4.52 4.99
1990 5.5. 4.98 5.31 6.12
*Based on 25 percent local share only, financial at 6 percent for
25 years.
Average Annual Per Capita Cost of
Alternative 1990 Projects by Service Areas
Plan and Service Average Annual Per Capita Cost
Area 1975 1990
Plan IB
Huron River 12.73 9.14
Ann Arbor 9.21 7.36
TOTAL 11.59* 7.93*
Plan II TOTAL 10.62 7.16
Plan III
Huron River 11.33 7.65
Detroit 9.77 7.58
TOTAL 10 ."91* 7.64*
Plan IV
Ypsilanti 15.75 14.77
Detroit 9.77 7.58
Huron River 15.92 10.02
Ann Arbor 9.21 7.36
TOTAL 12.05* 8.80*
* Indicates Average cost per capita average.
-------
Using the cost data for the 1990 project as opposed to the
selected project does not alter any of the conclusions previously
stated regarding the four alternatives. It does, however, reinforce
a number of such conclusions and increase the spread among certain
cost estimates.
-------
-------
APPENDIX B
Agreement Between Canada and the United States of America on
Great Lakes Water Quality. Annex 2
-------
ANNEX 2
CONTROL OF PHOSPHORUS
-*-• Programs. Programs shall be developed and implemented to
reduce inputs of phosphorus to the Great Lakes System. These
programs shall include:
(a) Construction and operation of waste treatment
facilities to remove phosphorus from municipal sewage;
(b) Regulatory measures to require industrial
dischargers to remove phosphorus from wastes to
discharged into the Great Lakes System;
(c) Regulatory and advisory measures to control inputs
of phosphorus through reduction of waste discharges
attributable to animal husbandry operations.
In addition, programs may include regulations limiting or eliminating
phosphorus from detergents sold for use within the basin of the Great
Lakes System.
2. Effluent Requirements. The phosphorus concentrations in effluent
from municipal waste treatment plants discharging in excess of one
million gallons per day, and from smaller plants as required by
regulatory agencies, shall not exceed a daily average of one milligram
per litre in Lake Erie, Lake Ontario and the International section of
the St. Lawrence River.
3. Industrial Discharges. Waste treatment or control requirements
for all industrial plants discharging wastes into the Great Lakes
\
-------
System shall be designed to achieve maximum practicable reduction
of phosphorus discharges to Lake Erie, Lake Ontario and the Inter-
national Section of "the St. Lawrence River.
4. Reductions for Lower Lakes. These programs are designed to attain
reductions in gross inputs of phosphorus to Lake Erie and Lake
Ontario of the quantities indicated in the following table for the
years indicated.
5. Reservation. The above net discharge figures do not constitute
allocations to the two countries, but represent anticipated results
of municipal and industrial waste reduction and detergent phosphorus
control programs.
6. Refinement of Data. The above net discharge figures are based
upon best available data. The parties in cooperation with the State
and Provincial Governments and the International Joint Commission,
shall continue to refine these estimates to ensure a comparable data
base. The estimates are subject to revision upon agreement by the
parties to reflect future refinement of the data.
7. Objective of Programs. The objective of the foregoing programs
is to minimize eutrophication problems in the Great lakes System. It
is anticipated that successful implementation of these programs will
accomplish the following results, which are of critical importance
to the success of the joint undertaking to preserve and enhance the
quality of the waters of the Great Lakes System.
-------
(a) Restoration of year-round aerobic conditions in the
bottom waters of the central basin of Lake Erie.
(b) Reduction in present levels of algal growth in Lake
Erie.
(c) Reduction in present levels of algal growth in Lake
Ontario, including the International Section of the
St. Lawrence River.
(d) Stablization of Lakes Huron and Superior in their
present oligotrophic state.
It is nevertheless recognized that additional measures and programs
may be required to minimize eutrophication problems in the future.
Available evidence suggests that reductions in phosphorus loadings to
achieve a net discharge to Lake Erie in the range of 8,000 to 11,000
tons may be required to bring about mesotrophic conditions in this
lake.
9. Commission Recommendations. The Parties will take into account,
as soon as available, the recommendations of the International Joint
Commission made pursuant to its study of pollution from agricultural,
forestry and other land use activities, in order to develop and
implement appropriate programs for control of inputs of phosphorus
from these sources.
10. Monitoring. The Parties, in cooperation with the International
Joint Commission and State and Provincial Governments, shall continue
to monitor the extent of eutrophication in the Great Lakes System
-------
and the progress being made in reducing or preventing eutrophication.
They will consult periodically to exchange the results of research
and to pursue proposals for additional programs to control eutrophica-
tion.
11. Submission of Information. The International Joint Commission
will be furnished at least annually, in accordance with the Parties,
information concerning:
(a) Total reductions in gross inputs of phosphorus
achieved as a result of the programs implemented
pursuant to this Annex;
(b) Anticipated reductions in gross inputs of phosphorus
for the succeeding twelve months.
12. Review and Modification. In connection with the first compre-
hensive joint review of the operation and effectiveness of the
Agreement conducted in accordance with Paragraph 3 of Article IX
thereof, the effects of phosphorus control programs on the Great Lakes
System shall be reviewed and further modifications in the programs
undertaken pursuant to this Annex shall be considered.
-------
APPENDIX C
Fisheries Renovation Project for the Huron River; and Fish
Species of the Huron River.
-------
STATE Of MICHIGAN
in r«ply reier to
File No. 8006.1
NATURAL RESOURCES COMMISSION
HARRY H. WHITELEY
Chairman
CARL T. JOHNSON
E M LAITALA
HILARY r. SNELL
CHARLES G. YOUNGIOVE
WILLIAM G. MILLIKEN, Governor
DEPARTMENT OF NATURAL RESOURCES
RALPH A. MACMULLAN, Director
3335 Lansing Avenue
Jackson, Michigan 49202
October 5, 1972
#175
Mr. Thomas Windau
E. P. A.
1 Northwacker Drive
Chicago, Illinois 60606
Dear Mr. Windau:
Enclosed, copies of the data you requested during our telephone
conversation on October 5. As noted, you will receive a copy of our
final report when it has been completed.
If you have need for other data relating to this or other
similar projects in this portion of southeastern Michigan, please feel
free to request copies.
Very truly yours,
Edward H. Bacon
District Fisheries Biologist
EHB/vrt
Encl:
cc: Tom Doyle/encl.
Dave Weaver/encl.
ENV,PC-.
E I V E 0
y;r c is?/
PLANWJSG
TM€
GREAT
LAKE
STATE
-------
77
FISHERIES RENOVATION PROJECT PLANNED FOR IMPOUNDMENTS OX HURON RIVZR
Ann Arbor's Department of Parks and Recreation has requested the Department
of Natural Resources to renovate the fisheries in the Barton, Argo, Geddes and
Superior impoundments. The project would be initiated shortly after the Geddes Pond
aam is rebuilt — which is slated for completion in mid-August of this year. The
proposal includes plans for treating the above waters with rotenone to remove the
present fishery, primarily carp, and restocking with largemouth and smailmcuth bass,
'hybrid ftunfish, channel catfish, tiger muskallunge, and walleyes.
The proposal to improve the fishery in the Huron River has been under
consideration for several years. The abnormally-high rain fall in June, 196S,
caused the Geddes Pond dam to wash out which proved to be the catalyst that precipi-
tated the present plans for this portion of the river.
A meeting on December 16, 1971, at Ann Arbor's City Hall, resulted ^a
conformation of the present plans. In attendance were Messrs. Overs and ~arr;.s,
Ann Arbor; Mr, David L. Weaver, Regional Fisheries Executive, Lansing; Dr. Carl -atta,
I:. Charge, Institute for Fisheries Research, Ann Arbor; and Messrs. Shepherd and
i>acon, Distra.ee #13, fisheries personnel. It was agreed that the city of Ann Arbor
would purchase the necessary rotenone. The Department of Natural Resources would
apply the fish toxicant, provide and stock the fish.
It is anticipated that the water will detoxify quickly after treatment
because of the river currents as opposed to a lake where the waters tend to ba more
sedentary.
-------
Tfe
-------
October 5, ~9?2
Approximately 23 miT -r o" t1-" YTur^n P.iv-r ' r. '..ra^v.t^r.aw Co T.^V vor-- •„ -
rot,enor.c (?ro-nox"ls-.) or. October 3, "'fv'2. ;.r-^ trc--,toj ir.jl f>,o •"- ^r i.c,;r , .'.•.-••
Carp wero fha mor>t numero'is (?.5''y 0A t.'"- "i.s^»'> rrir.ovod ar/: cor.ctLt oV
approximately 90^ o^ the weirht o* tho "lrv r^nrvr.d.
A Tnore detailed report iri.11 Vo a •bT.itt.oc ;it a later d-tte,
-------
80
7is> TQ". ~^sted 'or restock r_<- tre^z,ed Tjrrt* on c" va^r. .-civ. „••
^r^o
Pond
o.noo ^^ 0'~'0 ?<.oro o,o"p e:,t'
xy -^ > * s -^ *
yr.r-.c s-r.-":sh" ^6JC"C 151*000 130*^r H-6,5"" 25,'
-lleye 1,000
C ;r s-rly request 'or a s t'-"
-------
81
Lisa of Fishes iieeorcitict fros the Suron RivcisafiisWwiiAf»ii ~ filCSS
SSgQji gr.^i^rAea^us. varsicylauus, Lesueur
CYPIiii\ii£I//«I;I ~ wJ
___
o3<5 clace - P.hj. r: 1 cl^tVLy o "- -.7^'-'^!;} ^^:-^:"r
TO *. *£2iT "™ r^ cl~ ;.) C S i> O j .^ ". C^t"iO' ?'C..'.l'- , ^^K*^* w ^.fc»'».i^C m*&J
chub - NoCOJ.'iiS ;:i;lp££''n-":i;^v"/'-::
'7 s^^r^cir •• ^jo^^opj.3 ^roi'-C''
.CS! Sciii*iC;5r "* I^O Cl;.''Op XC ;.^T? DO „•. .^.U.C ^'.>^'***^ •-^'^
i shiniiir - K'otropj.s ehvy£ocof7haj}.;.::_sr (iUifinesque)
-------
,LJ/,i*^wi''C£»tw*44t ij*«'.vi.^x-J^ "* " O '.-TC * 'L'.£i tpl'Lii"/, ?C" Oi*) i^od --C,'^.
xg'g^'?;o;.cg -:pt:ai::is (Rafir-.^s
Ctt l*.",^JC'r'^"-^ ""'^ • T< _ « ,.» /"
C*±\JlJ xO*«J. A/A'AA^ *>
Lal:u ehubsuckar - Sriay^on c^c^.tg. (Lac
Goldar* ireihorsa - Mgyga^goy,^ _<• ;jr/>h j ^u rug. (S.af
wii«>. J.kliiiiCi •• T.C \^'d, .">. V\^T\13 Ov> L;'.A. I-.S !^J*c:£^i
a - Hqi:u.;.'y,3 gyrir.us v'^tchlll
I asdkca • Koj;urv.s Tilurv.fi. Jordan
A2 - killif isliws
trips to^aianow ,- p-.ndul'js notptus (;cj.^:i.ei::J. lacipe
-------
o~*\.A.*Wu.v'^*,.wv— ii« *° oOVi».«.r*UC
.
clc J^o2 - /• ' , < j. o p 1 :L j: c\;j_ rv.v;3.; ^ric :TV." .33 1~':'.". {^.d.cliiCiS
«cl\ civ^pio - ?o:i;j::j.s n :?. iff: cm y ; -. " \ gu •; (Lcaucur)
Yellow perch - P^rca ^lar^sc^rv^ ^-Sitehill)
I>iuci-:sida da^vC:* - ;?er^;ii^a y.;c:c^".at:?^ ^Ciira'.'u)
Los-jureii - P'-rr.lnn en w.- s cu . gt s^^/r^^gj.:^^. ^cl
Gveuusidci darter - F.;:hcos>: 07^:1 £i£^.^2i(i^£, liiiir'i.-asq
£.«>w* A-wJ^OW Ctciir fc^*—*T *• ^i UI'A OcJ CC..." CD''' ..'(-.. A O-_' -"^ ii* wO^.s..*
- CptSus. ba^.vdli Givrirc
-------
APPENDIX D
The following is a selection of representative comments on the
Michigan Water Resources Commission document "Environmental
Assessment, Phase I Plans for Water Quality Management, South-
eastern Michigan Area," and other general comments on the issue
of wastewater management in the Huron River Basin service area.
-------
^tu -'"V
UNITED STATES
\ ENVIRONMENTAL PROTECTION AGENCY
C RCGION V
£• 1 NORTH WACKS.R DRIVE
£0- CHICAGO, ILLiNOiS 606O6
This Regional Office of the U. S. Environmental Protection Agency may
soon be preparing a draft environmental impact statement on the proposed
Phase I Plans for Water Quality Management, Southeastern Michigan Area.
The report includes information on Plans IB and II involving a large
interceptor sewer and a wastewater treatment plant at the mouth of the
Huron River at Lake Erie, and also includes information on other plans
originally considered by the state.
It is our understanding that you have attended one or more meetings
regarding the Phase I Plans. Because we feel that agency and citizen
participation in environmental assessment review is important, your
review of the Environmental Assessment Report is invited. Your comments,
or those of your agency, submitted to us will be carefully considered and
will greatly assist us in evaluating the environmental impact of the
major proposals included in the Phase I Plans.
If you wish to participate in this environmental assessment review and
want a copy of the report, please contact us and we will send you a copy
as soon as possible. If you already have a copy and wish to participate,
please send your comments to us at your earliest convenience.
We thank you for your interest in this important matter.
Sincerely yours,
Water Programs Divi
Air
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CITY OF ANN ARBOR MICHIGAN
OFFICE OF THE CITY ADMINISTRATOR
CITY HALL. IOO NORTH FIFTH A V E.. 481OS
May 30, 1972 'r __
» -
Mr. R. J. Schneider, Director r o.
Air and Water Programs Division "
Environmental Protection Agency . j-
Region V "^~
1 North Wacker Drive _ —
Chicago, Illinois 60606 *•
F ff
Dear Mr. Schneider:
I have delayed answering your letter of April 18 regarding the Michigan
Water Resources Commission Environmental Assessment Report because I hoped
to have available the findings of a special committee set up by the
Southeastern Michigan Council of Governments to analyze the feasibility of
financing the Plan II interceptor, single plant solution as endorsed by
the Water Resources Commission. Wayne, Oakland and Washtenaw Counties
are represented by their engineers on this committee as is the Detroit
Water Board. SEMCOG and the City of Ann Arbor are also members. The
intent of the committee was to determine whether the proposed 1990-2020
system at a cost of about $200 million could actually be met within the
legal and fiscal constraints on revenue bonding and ad valorem taxing by
today's population.
All prior engineering reports and the Water Resources Commission Environ-
mental Assessment Report use a flat per capita basis of cost distribution
throughout the proposed Plan II Oakland, Wayne and Washtenaw areas neglect-
ing a) the fact that a uniform charge basis without regard to benefit would
be unique in Michigan and b) the fact that the cost to taxpayers in semi-
rural areas currently without service would be prohibitive.
A sound and legal basis would be for each area, or county, in the system
to pay that portion of the cost of the interceptor and plant that it would
be using, thus Ann Arbor and Washtenaw County charged for the Ann Arbor
and Van Buren Arms, a portion of the Huron Interceptor and of the plant at
the mouth of the Huron. Oakland would pay its share of the plant, Huron
Interceptor, Hannan Road and North Arm sewers. This poses extreme problems
for Oakland County because a substantial investment required to serve
the Oakland area in relation to the present relatively small population.
Failure to look at this costing problem in the original Plan studies was
unrealistic even if the assumptions regarding the benefits of the total
Interceptor single-plant system were valid.
ESEARCH CENTER OF THE MIDWEST
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2- Mr. R. J. Schneider May 30, 1972
We are now reviewing this problem with the bond attorneys through SEMCOG
and hopefully will have some legal and fiscal answers which EPA will want
for its final analysis and impact statement. Mr. Joseph Price, the Acting
Director of the Washtenaw County Department of Public Works, referred to
this issue in his comments to you. This whole matter is not touched on at
all by the Water Resources Commission Report.
To a considerable degree the Report itself is not an Environmental Assess-
ment as such but a review, repeat and summary of the reports and engineering
data previously prepared. The whole question of a new, large single treat-
ment plant at the mouth of the Huron, its relation to the Ft. Mouille
natural wildlife area, the filling contemplated by the Corps of Engineers
and the ultimate impact on that recreation area is not really examined as
an environmental issue and possible contamination and conflicts in use are
readilly dismissed. Although a number of pages of text relate to the impact
on Lake Erie, it is not clear that the standards of the International Joint
Commission are being met, that future standards will remain the same and
that this plant's impact meets the intent of the President's recent agree-
ment with Canada and has the approval of the Canadian constituencies.
The possibility of plant failure on Lake Erie is minimized; it is maximized
for the plants on the Huron River although the record shows such occurrences
as rare for the Ann Arbor plant. The value of tertiary treatment is played
down although it is clear that final filtration is the answer to the final
effluent problems of the Ann Arbor plant as detailed in the Report.
Although there are several pages analyzing Huron River water quality, the
data is superficial and inadequate with insufficient samplings. The only
extensive analysis was the original Borchardt report mentioned in the
Environmental Assessment. The question of low flow periods for the Huron
River has received increasing attention and an evaluation has to be made
between the quality of the River and amount of flow with all effluent
diverted downriver and the quality with the effluent returned. The impact
of storm water on River quality is mentioned but not dealt with. The ex-
tensive impact of farm run-off and septic dilution in the areas up river
from Ann Arbor in both Washtenaw and Livingston counties will be increasingly
apparent even if the Ann Arbor plant is discontinued.
I do not think there is much disagreement over the need for a regional
pollution control plan and ultimately a regional authority and most agencies
are willing to work in this direction. The Plan II approach of eliminating
a number of local plants for a single large plant of Lake Erie has to be
appraised in relation to all of the other plants in Southeastern Michigan
already draining into Lake St. Clair, the Detroit River and Lake Erie and
whether this is the long range approach this country wants to take. The
alternative of regional or area plants replacing the multiple small plants
with effluent discharging into flowing rivers rather than concentrated at
points on Lake Erie and its waters has not been fully explored. The costing
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3- Mr. R. J. Schneider
May 30, 1972
of the partial regional system presented in Plan II and the distribution
of capital costs of the large interceptor system we do not believe will
stand up in fiscal or legal fact and we believe that interim less costly
installations will have to precede any ultimate plan.
Si
City
GCL /da
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CrfY OF AKM AR^OK ;/. , C i H v, ,• i,:
o F t I c L or v H r MA v r> r;
V': /•'-.•._.:/• | Juno ?0, 1972
Mr. u. J. Schneider, Director
A i r ; • n J ^ u i. o ;. I' r on r :• nr> Division
United Stores Environmental protection
Agency, Region V
1 North \vsckcr Drive
Oh i '""'go . - ^ — -- J - - 60606
R,. _* ~. » • v- o - ' — - - A • • - - .
\. ^ i. i-l i • vj •*_ j i i >\. j u '- .;. ;
The Region V office of EP/i is in rocoipt ^f ti:o Mich^qan Water
Rerource? Con-rai ssi on ' c document, "En.vi roninonls 1 /.nscssuieni , Phase-
I Plcns for Water Quality Management, Southeastern Michirjan Area",
which pertains to plc-.ns for wastev/atci Irectn.ent in the ,f;oul hrr.st
Michigan area.
You also hLve the TO'TRC recommendation of "1'lan II" as tiii.- Ltist
pl;.ri for th.-ic nrrQ. RoutheasL "i chi^c-.' Co-uci] of Gov^vi:!- nf R , a?
yo" kric--, h-r: c-nncu--"ccl in r^c t i^:. :-ndii!^ rl;-:1 7f, :u5;;!^ci lo furuhc
str.:."^' Cj ' i-li". cos t-shr. ring
J'y rity h.ic previously e-:-:prar, seel to you both (1) our t.-1 • j^c
to H<--n ID: (as being inferior to Plan 'Jl;) ?na (2) our COM' I'i'ii that
none of tlic p]Mis the- r;.-?RC studied protect L?J/':O Eric ydoqriite ly .
On the letter point I pvevj ous,ly add re. ".?»(•?•;] ir.ysolf to t}io f-,ct th«t
in c'. i i thi plutis the new plant propo.^co c.o be bvilt ori L.-i ;•,;.-> n^-ie
provider- only secondary treatment, whcr:jns tertiary i icatr,,., nt would
seen to }i;i i)-2c-«" scary fox* the protection c>T Lr.i.e F.r.ic.
The present letter concert'" itself with n differo;1.'- PI.I • ul : that
in all the pinna, including Pl^n II, LI:'.; phosphorus rer.invr 1 rtandnrd
is 90',.i rerrioval, although 90% roi.iova) i r; in.'nif f ici c-nt to i^top rapid
eutro/.})i ration of Lake Eric. This i-a parv i cu i;-.r 1 y true: in thin in
stanci: sjnce the proposed no,- plnnt v;i j ) j-i-^ la) go ^.u.! will r.- K>r<. •
ted at one of the not;t eutrophic, pho.<-;p?v-, -us- l-.K-.c1.-d :-v'-^'r' or: the
Lake.'' I Ji^vc, roisc.-d i/h5n ir::u.,' of p>u ' ; -he- --u;- control ) ,:•/•. UK-
MWr;C, but dxd not moke esxi:<"'ii ".-•t'! rct.i;:i > ;• c-. ,1 rlic yubicct f . • "p unt ; '
vci.y xecently I did not uncr r M ,-r.c] thr i 'i-por tone* • of t i;- .' : : r.c'.
Than1;.c: to your help in blinking to lay attention th-:1 197'J Inte^'-
R L- s n A r; c H c i; i: T t R o r 7 H
f»t i r> w i. r T
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,.,- l-ior.; 1 Joint Co-.iiisu.ion Keport nnd th..- !']«rd of 90^
phosphorus r€srnova1 should be stiffefieJ «t 5:0:110 future d.Me. I at-
tended the neeting of the M.'-TcC v.'lien they approved plan ]"r and voted
to fon-.'ard that recoiT',;nen^;,t i cm io yon. Staff ran do it very, very
clear to the cop.ois&ionerj on the occasion of that vole that tiie
recor\viT,c-ndat ion ;.',\s contingent on your ^ppr-.r/al of thv; ft ;.• ndcj.- Ci >•.,,-
treatment contained in Plan II: only scconJrjiy treatp.-nt and only
90% removal of phosphor'.:::. In privr.te conferences \.'i<-li Ann Arhor
officitv^s tin.- I'.l'.C staff e 1 i ' ^..-.-.-:. ",
dard vouln ;jf"L. i ir:;,_-n^ely Lo L'i • r.p^
event, Plan 12 v.'ould lose, its ope1.. ' i n<; corl superior \\ ove: r 1 f :i
IB and other pl.M.s, and ,'iVrRC pro;-:,^ly •L'O^'IC.' pri fer LO. rj other s^^n--
probably opting for a more deeer-l re, lir.cd col nt i on, \--j'_ji three- or
four plants, rather than one big plrnt.
The crux of v.'hat follows can be Kumrori-v d as folio.-'S:
-The Lake Erie Board and the IJC teelin? a: 1 people- were pointing
towards a phosj-horus loading siandajd for ],;;!;e Erie of either 0.13
grams per square metre (persni.sn ible loading) or 0.23 (dangev ->ur,
loading);
-The ultim;xe recoinrnend.vtion of the Boi.rd and IJC was a atai.lord
of 0. 39---v.-hich is all thrt can be achieved by the two control i-cr.-
surr.-s they dec:.-.-d feasible;
-The first control rr>i--.'.'-rc r t r or-'-en-.^-.; \'C(cr,iber
31, 1972, and looi.^d to US-Gun ~-d ien e--gi ei. ;,it- r, L to i r-ipl nr.enL ;
-The second -,-ontro" !;--".sure v/c-r, o rc-qu -' j c i,,ont of f;'J% phosphor UK;
removal at all ir.oustri<- 1 and riiunieipal pl^n'i; on Lake LJrie or its
tributary strear,.;;
-------
-The first control measure was not adopter;, the U£-CVi:;rd tan ciijifo-
rnent leaving this matter to the individual stater,, and the Mithiqan
Legislature having enacted a law that goes only a short way { owordr.
eliminating phosphorus from detergents;
-The second control measure will be floutec! if EPA approves Plan
II, which calls for only 90% phosphorus removal, net 95%;
-Plan II is particularly aggravating because it calls for a new
big plant with only 90% phosphorus removal to be located on the
western basin of Lake Erie (where eutrophication is much worse than
in the rest of the Lake) , and to make matters worse, it en 11s for
locating that plant at the mouth of the Detroit River wht?re eutro-
phication and phosphorus loading is many times worse than in most
of thevestern basin.
The_ILEW?B's 1969 Report
The "Report" is part of three volumes. Volume Two is from the
ILEWPB, and deals with Lake Erie. Volume Three is from the compan-
ion board that concerned itself with Lake Ontario. Volume One is
a summary of the two main volumes. All page references in my let-
ter are to Volume Two.
"Eutrophication" is defined thus: "an acceleration in the rate
of addition of plant nutrients to natural waters results in increased
biological populations and production" (page 65). The Reporl ex-
plains that "lakes are generally classified as ol igotrophic, meso-
trophic, 01 eutrophic, depending on their degree of plant nutrient-
enrichment and biological productivity.„..If the supply of nutrients
to an oligotrophic lake is progressively increased, the lake will
become more mesotrophic in character; with further continuing en-
richment it will eventually become eutrophic and finally extreme-
ly eutrophic." (page 66)
"Sewage effluents, certain industrial wastes and the runoff from
agricultural land are all extremely rich in a number of plant nutri-
ents. Of these nutrients, compounds of phosphorus and nitrogen arc
generally considered to be the most significant and their key role
in eutrophication has long been recognized. Experience in many
lakes has shown that of these two, phosphorus is most often the
easier to control." (page 67)
The Report goes on to define its terms: "In this report all
concentrations of phosphorus compounds are expressed in terms of
the element phosphorus. Orthophosphate-phosphorus (PO/j-P) refers
to the phosphorus that occurs as orthophosphate ions (such as
H2P04« HPO4• PO4' NaHPO4, CaHPO^ in a filtered sample of water;
total phosphorus (total-P) refers to the phosphorus present as
orthophosphate ions after acid digestion of an unfiItered sample
-------
of lake water and includes boLa the inorganic orthophoisph^te and
the phosphorus present in orq« nic substances. The terms soluble
phosphate-P and reactive phosp;iat.e-P are treated here as equivalents
of orthophocphate-P ." (pjiut (>r:) .
With terms defined, tlio pi-port c&-~< then proceed to discuss the
present phosphorus loading of Lake F,rio, treating western, central,
and eastern basins separately. "With reference to the recent years,
1963 to 1967, all data shov fch.-'r iver^c;a of onr'y dct'i on La'ce: Krie with
the most recent information c.voi 1 ,?:blc- (Trble 2.3,1) suggests t'nat
the concentration of PO^-P in "_l>o v/c-,7 ti-r n banin of Lr.ke Eri? in--
creased approximately f^ur to ten tiiuss between the periods 1942-
1951 and 1963-1967." (pr.ge 71).
The Report also shows that Hummer time is not the worse season:
"The concentrations of both FO./,-? £>id total-P tend to be highest
in late winter and early spring (Chancier and V7eeks, 1945) , conform-
ing to the usual pattern observed in most north temperate lakes.
This is the result of re;';uceu h: •? logic?], activity in winter." (page
71). Hence the currc.-nt loadings in the vest^rn be*:in, particularly
in late winter and errl'1 f.prino, '.vill b? ev<~-n highor than the 17 sur-
face and 18 bottom rc-;\d inos record" d in the sum mar of 1967.
But this, so fi".r, has assumed th?t the entire v-cntern basin is
homogenous. In fact, Certain ^'.rtr, of the bo^in are ^'orse than oth.-
er parts. "It is clear iron d?': ?• \ !• vrl inf ormc't j on in f. • atudic.-j
cited in T-blec 2.3,1 ?r>d .? . 3 .. .'• thr-' "JocrJly high c. ... -ontrcrt ions
of PO/j-P and toc,r;l.~p i\\-<» ohso; v.:d Qdi
-------
HI can rdjscent to Me". r op r>' •• t- r. r, not'rot, 'I'D] '-;'-j, ar-'l Ci *ve la.i^ . .
surer,,cr.J. -• by OW"C and t> " FWPCA -h^--,5 that !'C] • P concent re.'- i : n:?
the mouth of the Detroit River arc h?ghor on the I'mrf-l Stater, ^i
than on the Canadian sicje,," (Fac5e 71). This j «, important bocau.se
the proposed new plant is precisely ? ril o
the western basin, adjacent to o mi* jor center, of population!
The sources, characteristics and effects of material inputs are
discussed starting on page 189. "Municipal wastes may seriously
degrade water quality in the vicinity of an effluent discharge...
Municipal effluents contc;in large amounts of the nutrients, nitro-
gen and phosphornr.." (page 109), Table 3.1.1 shows that in the
year 1966-7 municipalities discharged a totPl of 38 short tons of
total phosphorus into thevcestern b;-;r.iu of LaV.o Erie by direct d?s-
charge—not into tributaries. Table 3.1.2 shows that industry
that year contributed another 10 snort tons by direct Oischarcje.
The heavy discharge of phosphorus comes not from direct discharge
into the Lake but from the tributaries into which municipal plants
discharge. This is shown in Table 3,1.4. "As this Table shows,
the Detroit River is by far the Isrgcst contributor for most con-
stituents." (page 201). in 1966-7 the total phosphorus discharged
into the western basin by tributary on was 21,227 short tons per
year. (page 202). The Detroit River contributed 17,600 shore
tons of that western basin total of 21,227. The total Lake re-
ceived 27,342 short tonn from all rourceo. (page 205).
There may bo some difficulty in roIf cinq tots! phosphorus to
orthophosphnte-phocphoruf;, The Report indicates "the r-tio of
total-P to PO4~P has been reporter re ranqirr; from 1:1 (F^derf. 1
Water Pollution Control Administration, 1968b) to 3:1 (Chandler
and Weeks, 194b)." (page 71).
So the eutrophication of Lake Erie is closely related to the
phosphorus being discharged into th - Y.ak^; the eut rophicat ion is
worst in the western basin, which CP-^S most of the initinl phosphor-
us discharge (from the De^troic Ri\«vr) . There renuiinr; the question:
how much of the Detroit River's ph^suhorus lo.ic'l cornes from munici-
pal wastes? "63 percent of tho phosphorus inputn from nil sources
comes froia municipal wastes." (page 206).
The Report mentions th^t the avcLi.gp c^nrent r.~t .i on of t ot r-> 1 phos-
phorus in the western bacin is hig/i-^st (160 ug/1) rt the mouth of
the Detroit River (page ?2.i) --prec: ::-r\y \'h"ro the ne\- rlent in to
be built with only 90% pli.-^r.phfjto venovfi; 9
In Table 3.3.1 the Report dr?v;, up a m^terialr; boJemrc for I,:ske
Erie, shov;ing thc-.'c of the 30.1 short tons of Lota] phosphorus put
into the Lake in 1966-7, 25.4 tons, or 84% of it., was retained.
The same table pinpoints the Detroit River municipal contribution
of total phosphorus to Lake Erie at 11,510 sihort tons per yenr in
1966-7.
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On r>aqe 236 the Report d 3 SCU.SSPS t iu< i, I , 1 ^ of c\'t rophi ct j vely shrsllr.v body
of water (mean depth 18 m~\res o-.s corop;.;} .-ci to IM metres for T.t.l-o On-
tario) Lake Erie is moi piv.-rrc'trico ) " y p. -,-•£ "> i:;;; ."-eel toward outrophy.
This js. particularly the case f'^r M^: •.'•->:-•'. r m by pin (r-.->?.n depth
6.7 metres) where the v.-rtrrr. arc i :;othr; r.i:i 1 nnd circulate freely to
the bottom during icc-rrr? seasons." (pacy.- 2^V) .
"The three interconnected basinn of L;;t:? JJrie differ in their
trophic states. The western basin : r, clearly cutrophic." (page 237)
"In nearshorc environments, particularly iii the vicinity of pop-
ulation and industrial centres and ?t the mouths of rivers draining
agricultural regions, there is clearly a greater degree of eutrcphi-
cation than that of the m^in boriy op I/r.kc1 Erie.... Pronounced eut-
rophication at nearshore sites: in Lake Eric occurs at the mouth
of the Detroit...River ..." (page 237).
"Vollenveider (1968) hno proponed criteria to evaluate the state
of eutrophication of lakes based on a knovledge of the loadings of
total-P and total-N delivered from both pruu). al and cultural sources.
In order to permit a co'uprrison of l^k.'-p v/ith differerf areas and
volumes, the annual loadings are expressed i\'> grams of total-P or
total-N per square metre of lake surface. Predicted effects are
then evaluated as a function of rnzL-n depth of the lake.7 in question,
thus bringing all coitipfr;. faous to " sl.nnd?rf>> volume of lekc vciter.
"Table 3.3.3 lists tbi* ^dwirssiblG and dcMioarous loading limits
proposed by Vollenweidsr (iOG8), F-crni drl,.- p.^c.-ented in Section
3.1 of this Volume, the annual lor.^i.n^s of to\-^l-P and totM-N for
Lake Erie are 30,000 and 194,000 short tons per year respectively.
Converted to a unit ares of lake Furfec^ those corrnspond to 1,1 g
total-P/m2. yr and 6.8 g total-N/n2. yr. The admissible and danger-
ous loading limits for a lake of 20 metre:* moan depth (versus 10
metres mean depth for Lake Erie) from Fig. 3.3.1 are 0.15 and 0.30
g/m2. yr, respectively for total-P." (pages 237-9).
The statement is important ar,-i boars rr pt-i i t ion: t he _ ad IT; i s s i b _\e_
loading limit for all of Lake Eric i r, lc;;r; 1 han 0.15 g/m2. yr.
The dangerous loading limit is rr.'ichr. d ;-,r>f(^:e the loi-ci reacher 0.30
g/m2. yr. We shall have occasion to rcf'-T to t lie so standards igain
later.
"The actual lake loadings for both elennnl's (phorphorus and ni-
trogen) are thus well a)->ovc the ' dc.ngeroun ' liioits proposed by
Vollenweider." (page 239).
"The loading for t o_t s_l__-r_ _ j_n _t h • '•'""_'-j'^"n >> ••_:-n _o f_T"2]_££_ _Kri_e_
(21, 000 short v ons nor Yf;''.':* ) ^n_/-'! ^--'<-^-'' ^-i.^_'cir ngcr_')u^'_}J in2_i_ ^hcjn
expressed on a uiiit area be ? t;> j nr \-\-\? we;.:i •-•v"n__ ) > \s_i_n . " (page 23C^)
(italics mine).
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"It must be stressed th;.t these qr.-iph.ic re-1/,i_ j onsl. ipu are pri-
marily based upon empirical observations ra'.her than thonrot icn I re-
lationships. For those reasons they provide a solid framework for
comparison, largely free of assumptions. They do not, however, fully
take into account the varying rates of replacement of water in the
lakes shown." (page 239).
"The complete elimination of nutrient loading from municipal and
industrial sources will thu^ never create oligotrophic conditions
comparable to those in the upper Grent Lakes. At present the com-
bined nutrient loading from municipal and industrial sources accounts
for 30 to 40 percent of the total nitrogen and 70 percent of the
total phosphorus from all sources. At best there would be a return
to conditions existing in the early part of the 20th Century. If,
on the other hand, control by nutrient removal is not practiced, end
the projected loadings for 1986 are realized, there is every reason
to expect further pronounced biological changes that will result in
a deterioration of overall water quality," (page 239).
Page 241 contains a striking chart plotting mean depth of lakes
along the horizontal dimension and total phosphorus grams per square
metre per year along the vertical dimension. A diagonal bar of grey
runs from the lower left corner up and to the right. Its top bor-
der marks "dangerous limits" and its bottom border marks admissible
limits. Lake Tahoe and two other lakes are shown clearly within
the area of admissible loadings. Five lakes are shown with loadings
between "admissible" and "dangerous". Many lakes ere shown in the
area where loadings are beyond "dangerous limitc;", including Lake
Erie. But the lake that is shown in the worst shape of ell is
"W. Erie"—the western basin of Lake Erie—with a loading of about
7 grams per square metre per year; for a L?.ke of that mean depth
the "dangerous limit" is reached with a loading, according to this
chart, of less than 0.20 grams. The chart is based on Vollenweider's
work, as is the table on page 240, which says the same thing in
another form.
The Report then goes on to project what is expected to happen
by 1986. "The contributions from the forecasted populations are
based on an expected phosphorus wastage ratio of 3.5 pounds per
capita per year of which 2.5 pounds por person will originate from
detergent phosphorus." (page 245) (italics mine).
"At present it is estimated that 50 to 70 percent of the total
input of phosphorus from all municipal and industrial wastes in the
lower Great Lakes basin comes from detergents. The increases in
phosphorus sources will account for a doubling of the quantities
now supplied to the lake to a level of 45,000 tons per year by 1986.
"Reference to Fig. 5.1.1 illustrates the significance of this
total phosphorus loading on Lake Erie, When expressed as an an-
nual loading rate, per unit of surface area, the 1986 input of
-------
phosphorus indicates that a considerable advance in the degree of
eutrophication in the lake can bp expected." (page 245) Figure
5.1.1 predicts that without controls the total phosphorus loading
of Lake Erie will be 44,610 short tons per year by 1986, of which
29,150 tons will be from municipal plants. The Detroit River mun-
icipal plant loading, without controls, is predicted at 16,050
short tons per year, (page 260).
On page 257 the Report begins its "Conclusions and Summary."
"The most serious water pollution problem_in the lower GreatLakes
having .long term inte_rnati onsJL .ci g n i f .leanee , j s the increasing eu-
trophi cat ion of the- lakes. . . . With the present state of knowledge
and technology,. the only feasible approach to the problem in the
lower Great Lakes is the removal of specific nutrients from wastes...
The experience in many lakes indicates that phosphorus is most of-
ten the controlling material." (page 257) (italics mine)
The Report then goes on to compare its 1986 projections without
controls with a new projection for 1986: "if by then all phosphorus
is eliminated from detergents and 95 percent of the phosphorus is
removed from all municipal and industrial wastes." (italics mine)
It's worth interrupting the narrative to note what happens at
this point in the Report. To this point everything was scientific
and descriptive. There was no effort to prescribe what the law
should or could do. The scientific description was leading to
the conclusion that society should seel; to retard the process of
eutrophi ct't ion, presumably by reducing phosphorus loadings .below
what Voile rweidcr had indicated to be the point of "dangerous
loading". For the. v/estern basin of Lake Erie that would mean a
concentration less than 0.20 grams o£ total phosphorus par square
metre per year, which translates to about 531 short tons per year.
(page 204 shows the western basin receiving 21,227 tons per year
and page 239 shows the present loading to be 40 times the "danger-
ous limit"). Since loadings were much more severe at the mouth of
the Detroit River, presumably the standards there would be even
more restrictive--compelling the 531 tons to the western basin to
enter, insofar as possible, at other points.
However, when the authors of the Report reached the "Conclusions"
chapter and had to face the implications for government action, they
ignored where the prior chapters' logic was leading them and approached
the problem from a nev; direction, asking, What measures are politi-
cally feasible? Their answer, obviously, was (1) ban all phosphorus
from detergents; and (2) require all industrial and municipal plsnts
to remove 95% of the remaining phosphorus from their influents,
Before going further it is worth noting just how far these two
measures would tske us in protecting the env i ronmep/.:, Table 5.1.1
states that for Lake Erie as a whole tl.-o phosphorus loading in 1986
with these two controls would be 11,160 rhort tons per year, or
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0.39 g/m2. yr. (page 260). This would still leave Lake Erie as, a
whole with loadings above the "dangerous limits", albeit the load-
ings would be.lower than they were in 1967.
The most troublesome thing about the "Conclusions" chapter is
that it does not discuss the difference between the western basin
and the whole of Lake Erie nor does it discuss the difference be-
tween the area around the mouth of the Detroit River and the rest
of the western basin. It is clear that the two legal steps being
recommended would reduce phosphorus loadings to about one fourth
of what they otherwise would be, as appears from Table 5.1.1. It
is also clear that the total loading for all of Lake Erie otherwise
would be about 44,610 short tons per year. If the ratio of load-
ings western basin to whole Lake stayed the same in 1986 as it was
in 1967 (21/27, or 77%), the loading of the western basin, after
these two control measures were introduced, would be about 8,600
short tons per year. If 530 short tons per year marks the "danger-
ous limit", the two control measures would still leave us in a
state of affairs in which we put more than 1.6 times as much phos-
phorus into the western bnsin as the Report suggested we should
put if we would heed the "dangerous limit." (Of course, if we
wanted to heed the "admissible limit", we would need even more
strict controls.)
Granted, it is better to exceed the limit by 16 times rather than
by 40 times. But the public should know that the measures being pro-
posed are still very far from what it takes to slow down eutrophica-
tion—our biggest pollution problem, according to the Report.
This still doesn't come to grips with the fact that the eutro-
phication around the mouth of the Detroit River is worse than in
the rest of the western basin, presumably, adopting these two
measures would leave us with loadings at the mouth of the Detroit-
River much more than 16 times greater than the danger limit.
To return to the Report itself. At this point it tries to come
to grips with the fact that it is about to recommend measures which
will not bring loadings below Vollenweider's "dangerous limits".
The Report first repeats its earlier praise for Vollenweider's as-
sumption-free criterion, but then goes on thus: "However, as Voll-
enweider points out, mean depth is the only parameter considered
here in relation to phosphorus loading, and other factors (flushing
time, geographic location, etc.) must be considered." (page 259-263).
The Report does not, unfortunately, discuss either the flushing
time or the geographic location of Lake Erie to indicate whether
these factors would make one set the "dangerous limits" for Lake
Erie higher or lower.
The Report continues: "Also, the added effects of other nutri-
ent substances and growth factors may be involved." However, aqriin
unfortunately, the Report does not discuss whether they are involved
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or in what direction they cut as regards i.ako Erie, (page 263)
The Report, still sniping at Vollenweidcr, points out that
according to Vollenweider' s chart, Lake Washington would be expected
to be more eutrophic than cither Lake Zurichseo or Lake Kendota,
whereas in fact it is less eutrophic thrn either of those lakes.
(page263) We are not told whether the di ."ference in eutrophica-
tion between Lake Washington and those other two lakes is great or
small. On Vollenweider' s chcsrt Lake Wnshington is only shown to
be a trifle more eutrophic than the other two, whereas the western
basin of Lake Erie is shown as vastly more eutrophic than any of
the three lakes or any others on the chart. Hence, one who is not
determined to discredit Vollenweider completely must wonder wheth-
er his chart is not subject to minor degrees of error—but still
is accurate enough in its basic statement about Lake Erie's west-
ern basin: that it cannot tolerate anything approaching the phos-
phorus loadings that will occur even if phosphates arc removed
from detergents and the industrial and municipal plants are held
to a standard of 95% removal of phosphorus.
The Report, after a discussion of Lake Ontario (which the two
proposed legal measures would bring to loadings well within the
Vollenweider "admissible limits"), finally comes face to face with
the Vollenweider data and proceeds thus: "Lake Erie...it is sug-
gested. . .would still be well within the eutrophic range after elim-
ination of phosphorus from detergents plus 95 percent of control-
lable phosphorus in 1986. As was found for Lake Ontario, the ear-
lier examination of various criteria indicated that Lake Eric is
considerably less eutrophic than (Vollonweidcr's chart) suggests."
(page 263)
This statement is troublesome because it suggests that Vollen-
weider, having been "wrong" about Leke Ontario, may well be "wrong"
about Lake Erie, too. The data about his being "wrong" on Lake
Ontario consists of his data placing Lake Ontario, as of 1967, in
the range between admissible and dangerous limits, close to the
latter. This location on his chart classifies Lake Ontario as be-
tween mesotrophic and eutrophic. Obseivntion places Lake Ontario
a little better off—between oligot.cophic and mesotrophic. How-
ever, only a very small adjustment of his chart is needed to make
it correspond to observation. To put it another way, he is a
bit pessimistic.
Lake Erie, on the other hand, classifies as eutrophic on his
chart and classifies the same way on every count when observed.
(page 238) Vollenweider puts Lake Erie so far into * » range of
eutrophy that even if he made the same pessimistic eiror about
Lake Erie that he made about Lake Ontario, it only means that
-------
Lake Brie, with the *rvo lerj« 1 measure 3 taken and the pessimism cor-
rected, would be in the range between eutrophy and rnesotrohpy in
1986.
Vo lie nv;g j dc r ' s error i s not grer>t enough to affect the argument
that the wontem bacin of T.r/.:^ Erie v;il 1 be far into the area of
eutrophy-'-F^r bo'voTi'd the dang Ticms rjjTu.t--by 1986 even if the two
control measures wre adopted.
The authors of this chapter of the Report duck the question of
the western basin completely. Their statement is: "This assessment
of Lake Erie is for the lake as a whole; regardless of phosphorus
control the western basin will continue to be more eutrophic than
the central and eastern basins." (page 263) But the point is not
that the western basin will be more eutrophic than the other. two
basins; the important point is that even allowing for Vollenweider ' s
pessimism, the two proposed controls will leave phosphorus loadings
in the western basin so high that we can guarantee fairly rapid
eutrophication.
The Report goes on to touch on a new aspect of the phosphorus
problem: "A good deal of concern is expressed about the regeneration
of nutrients from the sediments of enriched lakes after the nutri-
ent supply from controllable sources is cut off. Once a lake has
become so productive that oxygen is exhausted from deep water dur-
ing summer, chemical changes at the mud-water interface cause a
release of nutrients into the water from the surface sediments.
This has been estimated as 8 percent of the total phosphorus load
for one small eutrophic lake (Vollenweider, 1968) . Large lakes
are believed to be proportionately less affected than small lakes,
but Lake Erie, which already -shows considerable oxygen depletion
in the hypolimnion, is approaching this dangerous point in eutro-
phication. Prevention of this state would serve to delay the re-
generation of another source of nutrient enrichment." (page 264).
This paragraph is important as regards how fast steps must be taken
to remove phosphorus from detergents snd to achieve 95% removal of
phosphorus at industrial and municipal plants — if those are the on-
ly two measures that are going to be taken. It is not clear how
important this is for the shallow western basin, which has no hypo-
limnion
The Report went on to recommend an 80% phophorias removal stand-
ard for municipal plants for now, to be increased to a 95% standard
by 1986. (page 266) . There was no discussion as to whether the
move to the 95% standard would be too late if it was -" 'layed until
almost 1986, in view of the eairlier expressed concern * 'jout phosphor-
us being released from the mud-water interface once a lake becomes
very productive.
The final part of the Report goes on to explain why the recommen-
dation is for both 95% removal at treatment plants and elimination
-------
from detergents: "it will be economically and physically impracti-
cal to have full facilities completed for Lake Erie and its tribu-
taries before 1975....If the technology for phosphate removal can
be quickly developed, an almost immediate elimination of a substan-
tial proportion of the phosphorus loading to Lake Erie and Lake On-
tario could be achieved to prevent further deterioration of these
lakes while sewage treatment facilities are being built.
"Secondly, the requirement of phosphorus removal would in many
cases impose undue financial burdens on small municipalities, indiv-
idual homes, and industries in the drainage basins....
"Thirdly, it is estimated that treatment costs for phosphate re-
moval at sewage treatment plants would be reduced by a half to two-
thirds by removal of phosphates from detergents. At the present
time 70 percent of the phosphorus in municipal sewage in the United
States and 50 percent in Canada arises from phosphate-based deter-
gents, the overall basin average lying close to that of the United
States.... To achieve the same effluent concentration without re-
placement of phosphates in detergents would require more than 95
percent removal at the sewage treatment plant yith two to three
times the overall cost, largely due to the additional chemicals
needed and solid wastes produced. Since the solution of the combined
sewer overflow problem will take a number of years to accomplish,
an early reduction in phosphorus inputs to the lakes frora this source
could be achieved by detergent reformulation." (page 267) (italics
mine)
The IJC Report of_ 1970
The IJC Report is rather similar"to the ILEWPB Report, both in
its ultimate recommendations and in its internal inconsistency—dis-
agreement between the early technical chapters and the later norma-
tive chapters.
The IJC Report follows the earlier report in stressing eutrophi-
cation as a leading pollution problem (pages 35-6) ; identifying
phosphorus as the most feasible place to attack the eutrophication
problem (page 37); spotting municipalities as the source of the
bulk of total phosphorus contribution to Lake Erie (page 83); attri-
buting 35,000,000 pounds of current total phosphorus input per year
to Lake Erie to the Detroit River (page 80); repeating the statement
that 70% of the phosphorus in United States sewage comes from de-
tergents (page 82) ; pointing out: that the western basin of Lake Erie
was particularly prone to eutrophic conditions because "its mean
depth is only 23 feet" (page 05); noting that the mean summer con-
centration of phosphorus in the western Basin of Lake Erie was 60
micrograms/1 (page 85); and concluding "Based on these data the
Western Basin is classified as being clearly eutrophic and the rest
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of L,a!;e Erie and ;. th*?
criteria endorsed by the Board is 0.13 g/m^/yr. (grams per square
metre per year) for Lake Erie and 0.37 for Lake Ontario. Beyond
this the loadings are critical and become dangerous at 0.28 g/m2xyr.
for Lake Erie and 0.75 for Lake Ontario. The actual tota ; phosphor-
us loading converted to a unit of surface area for Lake Erie was
1.1 g/m^/yr. and for Lake Ontario 0.7 g/m^'yr. These nutrient load-
ings produce advanced eutrophic conditions in Lake Erie and serious
mesotrophic conditions in Lake Ontario." (page 86)
This is precisely the result one comes to if he adopts Vollen-
weider's chart and table. At this point in its Report the IJC ap-
peared to be accepting precisely the standards proposed by Vollen-
weider, with no discount for pessimism.
However, in Chapter XII, beginning on page 112, the IJC Report
shifted gears. When it came time to state "Specific Objectives,"
the one concerning phosphorus was stated thus: "Concentrations
limited to the extent necessary to prevent nuisance growth of algae,
weeds and slimes which are or may become injurious to any benefic-
ial water use. (Meeting this objective will require that the phos-
phorus loading to Lnke Erie be limited to 0.39 g/m^/yr. and the
phosphorus loading to Lake Ontario be limited to 0.17 g/ro?/yr.)"
(page 119). (matter in parentheses is in IJC Report text).
At first glance it is impossible to understand why the standard
for Lake Erie is set at 0.39 when the prior discussion indicated
that the permissible limit is 0.13 and the danger point is 0.28.
Why is a number picked at random—0.39—when the number is ttto
high to satisfy either criteria suggested by the earlier discus-
sion? Not much help comes from the "Discussion of Specific Objec-
tives" (pages 120-122), where ths only reference to the phosphorus
standard reads: "The objective for phosphorus is based on Chapter
VI where it is explained that phosphorus will, under certain con-
ditions stimulate nuisance growths of algae, weeds and slimes. Al-
though a maximum acceptable concentration in the Lakes cannot be
specified at all times, it has been found that algal blooms can be
expected to follow in years when the concentrations of inorganic
phosphorus and inorganic nitrogen exceed 10 and 300 micrograms/1,
respectively, at the time of the spring turnover." (pages 121-2).
The real explanation for the 0.39 standard comes on pages 123-4:
0.39 is the standard reached if two legal measures are compelled—
elimination of all phosphorus from detergents and 95% removal of. the
predicted 1986 load of phosphorus at municipal and industrial waste
treatment plants.
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So in the IJC Report, za in the ILEWPB Report on which it WRS
based, the ultimate determination of the phosphate loading standard
bears no resemblance to tho conclusion the earlier discussion was
leading towards; the standard—0.39 g/mVyr.—is too high, but it
is the best you csn reach if you limit your control efforts to the
two measures being endorsed.
The IJC Report v: = a disingenuous in the way it embraced the 0.39
standard, implying that the prior Report hod embraced that standard
for less pragmatic reasons. The IJC Report reads thus: "The Commis-
sion is convinced that the reduction of phosphorus input into Lake
Erie, Lake Ontario and the International Section of the St. Lawrence
River will significantly delsy further eul.rophication and will al-
low the recovery of the Lakea to begin through natural processes.
All feasible approaches to the phosphorus removal problem must be
implemented. The Boards' report stressed that Lake Erie cs a whole
might well return to a mesotrophic state if the phosphorus loading
were reduced to 0.39 g/m^/yr. and that Luke Ontario might well re-
turn to an oligotrophic state if the phosphorus loading were reduced
-to 0.17 g/m^/yr. This con bo achieved if nil phosphorus is elimin-
ated from detergents plus a 95% removcjl of the predicted 1986 load
of phosphorus at municipal and industrial waste treatment plants...
It must be emphasized thst Lake Erie prior to World V7ar II was prob-
ably a mesotrophic loke and that even more stringent phosphorus
control measures would not result in it becoming oligotrophic."
(pages 123-5).
The IJC Report thuc travelled the rr-.i :- route as the earlier
Report, and like its predecessor, when i'_ came time to draw con-
clusions, it not only ignored Vollenweidcr's data, but also ignored
(a) the need for different standards for the western basin of Lake
Erie and (b) the need for different standards for the mouth of the
Detroit River.
The IJC Report j3_id go one step beyond the earlier Report. It
proposed a US-Canadian agreement on a three-pronged program of
phosphorus control. One prong would be "the reduction of phosphor-^
us discharged to these waters from agricultural activities." (page
150). This would be a new line of attack on the problem. The sec-
ond prong was the reduction "as a matter of urgency, of the remain-
ing phosphorus in municipal and industrial waste effluents dischar-
ging to Lake Erie (etc.), with a v.£ew to achieving at least an 80%
reduction by 1975 and thereafter additional reduction to the maxi-
mum extent possible by economically feasible processes." (page 150).
This is the same as in the earlier report--80% removal as an interim
target—but now the 95% removal target for 1986 is replaced by the
more flexible standard of "maximum extent possible by economically
feasible processes", which read alone, could mean more or less than
95% removal. Read together with the Specific Objective of 0.39
g/m2/yr., however, it requires at least 95% removal.
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The third prong concerned tn;; big problem of phosphorus in deter-
gents. The US-Canada agreement was to achieve tlis: "Tho immediate
reduction to a minimum practicable level of the phosphorus content
of detergents and the total quantities of phosphorus-based detergents
discharged into the Great Lakes System with the aim of complete re-
placement of a 1 ^phosphorus in det ergcnj_s with environment a 1 l.y le_ss
harmful materials by December 31, 19.7_2_._" {page 150) (italics mine)
Summing up, the IJC Report of 1970 reached these conclusions con-
cerning the reduction of phosphorus loading of Lake Erie: (1) it
called for adherence to the Commission's General and Specific Objec-
tives—including the one limiting loading to 0.39 g/m2/yr.--''as a
matter of urgency" (page 137); (2) it called for this standard to
"be recognized as the minimal basis for the establishment of stan-
dards for these waters by the States of Michigan, Ohio. .. (etc.)". .."
(page 149); (3) it recommended US-Canadian agreement with the aim
of complete replacement of all phosphorus in detergents with envir-
onmentally less harmful materials by December 31, 1972 (page 150).
Control of Phosphorus in Detergents Since the IJC Report
Michigan has passed legislation imposing limits on the phosphor-
us in detergents. But the Michigan legislation is a far cry from
the recommended total ban on phosphorus. Michigan now prohibits
sale of cleaning agents which contain phosphorus in any form in ex-
cess of 8.7% by weight expressed as elemental phosphorus. (Act #226,
Public Acts of 1971, approved by the Governor January 3, 1972).
According to Professor Daniel Longone of the University of Michigan
Chemistry Department, the most widely used phosphate in laundry de-
tergents is sodium tripolyphosphate, STPP. STPP contains 25.26 phos-
phorus by weight. Thus a standard of 8.7% elemental phosphorus trans-
lates into a standard of 34.44% STPP. A 34.44% standard represents
a reduction of one third to three fifths for most dishwasher deter-
gents, of the standard phosphate sort. For example, in 1970 we saw
Tide at 49.8%, Bold at 45.4%, Cold Water All at 45.4%, DUZ at 38.3%,
FAB at 38.8%, and Cheer at 36.3%. For only two of the twenty-two
high phosphate detergents (Blue Rain Drops, Salvo) would a 34.44%
STPP standard represent a reduction of more than one third of the
j.970 phosphate level. The information about the detergents was
published by the United States Department of the Interior (FWQA) on
September 5, 1970, and appeared in the New York Times of the follow-
ing day.
Since the IJC Report of 1970 the United States and Canada have
negotiated an agreement concerning control of phosphorus entering
the Great Lakes. But the agreement, signed on April 15, 1972, by
President Nixon and Prime Minister Trudeau, does not require a par-
tial or a total ban on phosphorus in detergents—by the end of 1972
or by any other date. Rather, according to the "Great Lakes Water
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Quality Agreement Fact Sheet" issued by the Ottawa Office of the
White House Press Secretary on April 15, 1972, "the parties agree
to take remedial measures to reduce the gross input of phosphorus
into Lake Erie and Lake Ontario by agreed amounts over the next
five years, (page 3)....The U. S. announced last September a number
of conclusions on the health and environmental problems associated
with detergents. The announcement noted unresolved questions con-
cerning the possible long-term health effects of NTA, the most pro-
mising substitute for phosphorus in detergents and the consumer
hazards associated with certain detergent ingredients, such as
caustic soda. As a result, EPA announced an increased effort to
deal with phosphate-caused eutrophication by removing phosphates
at municipal treatment plants. State and municipal governments
will continue to make their own decisions on the phosphate removal
strategies they believe will best meet their own situations." (page
4) (italics mine).
In short, the tfnited States did not agree to compel even reduc-
tion of phosphorus in detergents, let alone elimination of phosphor-
us; the matter was left to the states; Michigan has decided to com-
pel a slight reduction in the amount of phosphorus. Optimists
might hope the theory behind the US-Canada agreement is that fail-
ure on the detergent front is not too serious since stricter stan-
dards than 95% removal can be required at the municipal treatment
plants. But if the theory behind the US-Canada agreement is not
a shift to standards stiffer than 95% removal at the municipal and
industrial treatment plants, then it will be impossible to meet
even the 0.39 g/m^/yr. standard IJC set after making its compromise
with political expediency.
In assessing how much more than 95% removal will be needed now
that detergents are to be allowed to contain almost as much phosphor-
us as befoE, one must recall the enormous role detergents play in
adding phosphorus to Lake Erie: The 1969 and 1970 Reports indicated
that between 50 and 70 percent of the phosphorus from municipal and
industrial wastes comes from detergents.
These Reports also stressed how expensive it is to remove more
than 95% of phosphorus at the plant. So the failure of the US-Can-
ada talks to achieve a ban on phosphorus in detergents and the fail-
ure of the state legislation to reach the IJC goal of total ban by
the end of 1972 were momentous twin failures.
The Michigan Water Resources Commission's Standards for removal
of Phosphorus at municipal treatment plants
In its Environmental Assessment the MWRC indicates that the
Commission requires 80 percent phosphate removal at all city treat-
ment plants in the Lake Erie basin. (page 1-41) .
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It also indicates* i.^at j.r: all the plans it conr.ured and consid-
ered for the Lower Huron River Basin it required 90 percent phos-
phorus removal, (page ;U-4)
Lest there be any misunderstanding of this, the 90 percent phos-
phorus removal standard is not contemplated as a temporary standard,
to be raised later. It 3 contemplated as the permanent standard.
This becomes clear when one notes (1) the MWRC based its decision
to approve Plan II in large part on the consulting engineers' study
of the estimated 19"5 and 1990 costs of operation of the various
plans; and (2) that operating costs would be much higher if more
phosphorus removal ware required than 90%.
In short, MWRC is recommending Plan II to EPA for approval and
for federal funding of more than $80,000,000 on the assumption that
One Big Plant will be built on Lake Erie at the mouth of the Detroit
River; that all the sewage in this area will be transported to that
plane by interceptor? and that the plant will remove only 90% of
the phosphorus it receives—when the plant is first built and in
operation in 1.990.
It is isnpossible to square this 90% removal standard, (which
will run in tandem with the Michigan legislation requiring only
limited cleanup of detergents), with the IJC standard of 95% re-
moval, (which was to run tandem with a total ban on phosphorus in
detergents),
Nowhere in the MWRC's Environmental Assessment is there any
discussion of (1) whether Plan II, which they recommend for federal
funding, ia consistent with the objective of 0.39 g/m^/yr. phos-
phorus; (2) whether the standard of .0.39 g/rr»2/yr. is too lax a
standard to protect Lake Erie; (3) whether standards higher than
0.39 should be imposed on plants whose effluent reaches the western
basin of Lake Erie; or (4) whether still higher standards should
be imposed on plants located at places such as the mouth of the
Detroit River, where existing eutrophication is much greater than
in most places in the western basin and existing phosphorus load-
ings are much higher than in most parts of the western basin.
The MWRC's Environmental Assessment avoids all these questions
by simply stating its 90% removal standard and assuming it is satis-
factory, without attempting to examine, criticize, or justify that
standard. The bulk of the Assessment is comparison of various
plans—all of which use this same 90% removal standard for all their
plants.
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Conclusions
#1. If EPA has not already decided to order an Environmental
Impact Statement, may I again request, demand, and beseech you to
order one?
#2, I think the EPA Environmental Impact Statement should go
into the questions MWRC avoided: (1) is an 0.39 phosphorus removal
standard adequate for Lake Erie if all phosphorus is removed from
detergents? (2) is an 0.39 standard adequate for Lahe Erie in view
of the twin facts that (a) the US-Cantidian agreement does not com-
pel elimination of phosphorus from detergents and (b) Michigan's
new law requires only a limited reduction of phosphates in deter-
gents? (3) if an 0.39 standard is adequate for the rest of Lake
Erie, is it adequate for the western basin? (4) if an 0.39 stan-
dard is adequate for the rest of the western basin, is it adequate
for places, such as the mouth of the Detroit River, that already
have advanced eutrophication, high levels of phosphorus in the
water, and are slated for continuing high loadings from sources
other than new treatment plants? (5) will 90% phosphorus removal
at the proposed new plant at the mouth of the DehroJt River imple-
ment the IJC plan to reduce the loading to 0.39?
#3. Whether or not an Environmental Impact Statement is pre -
pared, Plan II should be rejected and EPA should take the position
that you want no plant j(or the smallest possible plant) at that
particular place on Lake Erie. Riverside plants will protect Lake
Erie better than lakeside plants. If you are confined to picking
among the several plans already reviewed by the MWRC, you should
favor one of theplans which creates a smaller plant at that De-
troit River-Lake Erie spot--such as Plan"IB. If you are free to
send MWRC back to the drawing board, you should indicate that the
appropriate plan would contemplate three or four decentralized
plants, rather than one Big Plant at that Lake Erie location.
#4. In any event, you should require at least 95% phosphorus
removal at any plant on Lake Erie or on any tributary flowing in-
to Lake Erie.
#5. In any event, you should face the question of the phosphor-
us removal standards at all plants, new or old, on Lake Erie and
on Lake Ontario or on tributaries of those Lakes, whether the
plants are located in Michigan or in other states. You should as-
sess whether our failures to date on the detergent-control front
require you to insist on more than 95% phosphorus removal at all
these municipal and industrial treatment plants. ^
I write this letter realizing full well that if I am success-
ful in my argument, the City of Ann Arbor will wind up being held
to standard of at least 95% phosphorus removal at our own plant.
We currently remove only 80%; that is a recent development and io
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proving expensive to us. We can reach 95% removal, but it will
cost us t'. lot to operate at that level. I realize those increased
operating costs will come entirely from local taxpayers, since
there is no state or federal assistance for non-capital costs.
Nonetheless, I urge this 95% standard. I believe the vast majority
of Ann Arborites support me in urging this, because we support
real protection of Lake Erie and we are willing to pay our fair
share of the cost of providing that protection.
Please give these matters your very serious consideration and
show the courage we expect from the nation's chief environment
protection agency.
Sin
Robert JKHarris, Mayor
RJHgc
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CiTY OF ANN ARBOR MICHIGAN
OFFICE OF THE MAYOR
June 30, 1972
Mr. Francis Mayo
Director, EPA Region V
1 North wacker Drive .
Chicago, Illinois 60606
Dear Mr. Mayo:
I attach a letter addressed to Congressman Dingell which
he shared with the Huron River Watershed Council who shared it
with me. When I received the copy from the Council I tried to
reach you by phon^ but you were busy and Mr. Thomas Windau of
your office spoke with me. He indicated that the MWRC proposal
for the Huron River Basin was not "disapproved" but rather was
neither approved nor disapproved pending an environmental impact
statement's preparation. He indicated he would write the City
of Ann Arbor confirming this fact and would give us the names
of people to whom the MWRC's Environmental Assessment was being
sent so that the City could write them our criticisms of the
Assessment and other data relevant to environmental impact. He
also indicated he would try to let us know the practical dead-
line we are under for furnishing that information. I hope to
receive that communication soon.
I also wanted to mention to you, for whatever relevance it
has on the environmental impact statement or on EPA's general
decision concerning sewerage of the Huron River Basin, a recent
action of the SEMCOG Executive Committee. At its last meeting
the Committee adopted a resolution recognizing that the pro-
jections of future population on which SEMCOG (and MWRC) based
Plan II are in error. SEMCOG1s more recent small area forecasts
reveal that the population forecasts undergirding the water,
storm, and sewer plan overstate future population. The Execu-
tive Committee passed a resolution recognizing this and instruc-
ting staff to revise the plan accordingly in time for the 1973
HUD certification. (There is insufficient time to accomplish
this revision before the 1972 certification date.) The Execu-
tive Committee, by resolution, also instructed staff to do what-
ever was necessary to see that the small area forecasts are re-
RESEARCH CENTER OF THE MIDWEST
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- 2 -
Mr. Mayo
vised on a continuing basin as new data are obtained. These
Executive Committee decisions ware reported to the SEMCOG Gener-
al Assembly at its Jane 23rd meeting with the explanation by the
Acting Executive Director that no General Assembly action was
needed to carry out these steps.
I am in the process of assembling the data—in addition to
that contained in the MWRC's Environmental Assessment—that the
City of Ann Arbor wants taken into consideration in EPA'a prepar-
ation of an environmental impact statement. I am not familiar
with the procedure for preparing such a statement and would ap-
preciate hearing from you concerning what opportunities the City
will have to present information orally and what substantive or
procedural rights the City may have in that process.
Sincerely yours,
> \
'nu^j
Robert 3. Harris, Mayor
RJHgc
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SOUTHEAST MICHIGAN
COUNCIL OF GOVERNMENTS
July 25, 1972
Mr. Francis Mayo
Director
EPA Region V
1 North Wacker Drive
Chicago, Illinois 60606
Dear Mr. Mayo:
ENVIRONMENTAL PROJECTION AGENCY
R F r F I V E D
Al'G 3 1972
PLANNLM? uKAixCH. - Region V
FltC NO — i-
c:.
In a letter to you dated June 30, 1972, Mayor Robert Harris of
Ann Arbor made several statements regarding recent actions of
the SEMCOG Executive Committee. Since these comments are
somewhat misleading, I would like to attempt to put them into per-
spective.
First of all, the discussion pertaining to the small area forecasts
and the water, sewer, storm drainage plan was only a small part
of a much broader issue. At the time, the Executive Committee
was considering the adoption of a Housing needs study. In the
resolution adopting the housing study, the following statement is
made:
"(2) that the Executive Committee recognizes that
the Water and Sewage Element of the Compre-
hensive Regional Plan must be evaluated and
revised to correspond with the population pro-
jections of the Small Area Forecasts, before
certification on July 1, 1973, and that sufficient
staff and policy review time must be allocated
in order to accomplish this task;"
The problem is that, in development of the Water, Sewer, and Storm
Drainage plan for Southeast Michigan, prime reliance was placed on
County plans. Consolidation of these plans demonstrated the existence
of excess planned service area around the periphery of the region.
ROBERT E FITZPATRICKCfcwman
ROBERT J HARRIS 1st Vice Chairman HOMER CASE2nd Vire Chairman
JAMES L. JRMNORActing Director
8th FLOOR. BOOK BLDG.-1249 WASHINGTON BLVD.-DETROIT, MICHIGAN 48226-Tel.(313)961-4266
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Mr. Francis Mayo
July 25, 1972
Page 2
Concurrently, SEMCOG revised its estimates of Regional population,
based on new census information. It now appears that the regional
(7-county) 1990 population will be approximately 6. 1 million people
as opposed to an earlier estimate of 6. 9 million. These regional
control totals were then used to estimate population on a small area
basis. Again, the tentative results show less population increase
around the periphery of the region.
The staff at SEMCOG is now seeking to refine and to shape the urban-
ized area of Southeast Michigan for 1990. In turn, this effort will
more accurately define sanitary sewer service areas. Again, it should
be emphasized that these are marginal refinements, along the periphery
of the region.
To illustrate this point, a preliminary analysis of the area to be served
by the Huron River Interceptor shows a variance of only three percent
between the old and new population estimates.
I would hope that this letter will be helpful in EPA's environmental
assessment of the Huron River project. Since both the SEMCOG Execu-
tive Committee and its General Assembly have both strongly endorsed
the regional interceptor, I would hope EPA would see the advantages
of an areawide solution to this important wastewater management problem.
If SEMCOG can be of any assistance to EPA in its deliberations, I would
like to offer the full cooperation of this office. Also, we would like to
offer such information as may be appropriate to your analysis.
Sincerely,
>*?*****"
X^ames L. T/ainor
/y Acting Executive Director
JLT/tb
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SOUTHEAST MICHIGAN
COUNCIL OF GOVERNMENTS
July 27, 1972
Councilman Mel Ravitz
President
Common Council
City of Detroit
1340 City County Building
Detroit, Michigan 48226
Dear Councilman Ravitz:
I want to thank you for the opportunity, presented in your letter
of July 11, to reply to the recent statements of the Mayor of Ann Arbor.
In his letter of June 20, 1972, the Mayor alleges that MSEMCOG has been
conned into the unhappy position of supporting a water quality control plan
that is quite unsound." Further, the Mayor asserts "The Executive Com-
mittee was stampeded into endorsing 'Plan n1 " These statements
are puzzling considering the extended discussions which took place at all
levels within SEMCOG last Fall.
First of all, the matter of the Huron River interceptor was the
most thoroughly debated issue ever brought before the SEMCOG Executive
Committee. The City of Ann Arbor had every opportunity to present its
case, and it availed itself of those opportunities over the course of three
Executive Committee meetings and one General Assembly meeting. After
listening to all of their arguments, most of which are resurrected again
in the Mayor's June 20 letter, the Executive Committee voted 19-2 in
favor of Plan II the Huron River Interceptor.
The General Assembly also adopted this plan, only allowing the
City of Ann Arbor the courtesy of a task force to examine any relevant
facts that might cause the General Assembly to alter its position. (Sig-
nificantly, this task force has met nine times over the last six months,
and has failed to discover any reason for reversing the Huron River
Interceptor decision of SEMCOG. This, in spite of the fact that two mem-
bers of that task force have raised every possible objection to the Huron
River decision,,) It would appear from the history of this debate that
SEMCOG has been neither "conned" nor "stampeded."
ROBERT E FIT7PATRICK«wr ROBERT J HARRIS 1st Viri' Chdirntjn HOMER CASE2m/ Vtrr Ch.iirtiuit
JAMES L TRAINORxV tiny nirntur
8th FLOOR, BOOK BLDG.-1249 WASHINGTON BLVD.-DETROIT, MICHIGAN 48226-Tel.(313)961-4266
\
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Councilman Mel Ravitz
July 27, 1972
Page 2
Rather than being "quite unsound", the water quality control
plan offers the prospect of almost immediate improvement of the Huron
River, and significant improvement in the receiving waters of Lake Erie
•when this interceptor is considered as part of the total wastewater manage-
ment system of Southeast Michigan.
To reinforce this point, I would like to quote from the draft
Environmental Assessment of the Michigan Water Resources Commission,
dated December 29, 1971: "Plan II would improve the quality of the Lower
Huron. Existing stream concentrations of BOD, suspended and dissolved
solids, and nutrients would be lowered. Higher dissolved oxygen levels
would be expected. In particular, water quality improvement is anticipated
in the stream impoundments of the Lower Huron. Algae growths should
decrease as the nutrient loads are reduced. This will furthermore reduce
diurnal dissolved oxygen variation and dissolved oxygen depletion. Current
water quality impairments in Ford and Belleville Lakes due to algae blooms
and associated fish kills should be reduced to an as yet undetermined extent.1
Again addressing the issue of "unsoundness" not only was Plan n
recommended by SEMCOG it was also the choice of the Michigan Water
Resources Commission. Again, Ann Arbor had every opportunity to pre-
sent its objections. Further, the elimination of treatment plants on the
Huron River in favor of the regional interceptor was recommended by the
1964 National Sanitation Foundation report prepared for the Supervisors
Inter-County Committee, the 1968 Lake Erie Report by the Federal Water
Pollution Control Administration and the 1971 Water Quality Management
study by Hubbell, Roth and Clark and McNammee, Porter and Seeley for
the Water Resources Commission. Thus, for almost a decade, the inter-
ceptor approach to the Lower Huron River basin has not been considered
an "unsound" idea, but rather the converse. The interceptor plan has
been viewed as the soundest approach in improving water quality in the
lower Huron River.
All of this, of course, was thoroughly discussed before policy
bodies of SEMCOG before these officials recommended Plan n over-
whelmingly. Again, the City of Ann Arbor was vocal in presenting its
arguments.
However, there is a complete mis-statement of fact in the Mayor's
letter of June 20. The SEMCOG staff never recommended expansion and
continuation of the Ann Arbor plant independent of the regional system.
-------
Councilman Mel Ravitz
July 27, 1972
Pa
-------
Councilman Mel Ravitz
July 27, 1972
Page 4
Finally, "tertiary" is one of the most used words in waste-
water management, and is almost always defined to mean what the
user intends it to mean. Actually, it has no clear definition, and
usually connotes something beyond accepted secondary wastewater
treatment. Because it is so imprecise, it is not used at SEMCOG,
but rather the more accurately-ambiguous term, ''Advanced Wastewater
Treatment" is used. This always requires a definition, just as a defini-
tion should be demanded of anyone who uses the word "Tertiary."
In the Ann Arbor case, "Tertiary" appears to mean 90 percent
phosphorus removal with nitrification and sand filtration. Even if an
assumption were made that the Ann Arbor plant would perform as designed,
a comparison between the Huron River "Secondary" Plant and the Ann
Arbor "Tertiary" plant for 1990 shows that the effluent concentration is
identical from both plants. Further, the Phosphorus loading to Lake
Erie which so concerns the City of Ann Arbor in 1990 is estimated at
1,010 pounds per day as opposed to the average daily loadings to the
Huron River in 1971 from the existing six plants of 1602.6 pounds per
day. Significantly, Huron River plant would be serving three times as
many people in 1990 as do the six plants on the Huron River today.
It should be emphasized, as strongly as possible, that nothing
has been discovered to date that should prompt SEMCOG, Water Resources
Commission, or the Environmental Protection Agency to reconsider the
decision that the most cost/effective solution to the wastewater manage-
ment problem in the Lower Huron River basin is the regional interceptor
with a major treatment plant at the mouth of the river.
To close, the project is technically feasible, financially practical,
and immediately needed. It is to the detriment of the Region and partic-
ularly to communities on the Lower Huron River (especially Ann Arbor)
to continue this argument. The issue has been decided.
To verify, if necessary, the statements in this letter, I would
urge every member of SEMCOG's Executive Committee and General Assembly
to review the minutes of the Executive Committee meetings for November,
December and January, as well as the minutes of the January General
Assembly meeting.
Sincerely,
>—••—»""p^
'James L. T/fainor
Acting Executive Director
JLT/tb
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MCWftttL MNRY
Cfceinmi
I»MIUP J, NEUOKCK
Imrii of
r-KBDOtf. C. BURTON
Cwmi»ioncr
HCMMY 3. GALECKI
S*cr«t«ry t, CUrk o! lh« Board
p.
I'
7Tf*)ri,Qa« CITY-COUNTY Bt-DO.
, MICHIGAN 4«22«
August 3, 1972
JAW* U. DAVCV
OttMtw
MTCHCLL J. ZOUK
JOHN P». CUSMMAN
G«i«nl Coawl
JO8SPH K. HANTMANN
Director of
WALTEM !>. MKYCM
Catintir Mickwiy Ea|i
Councilman Mel Ravitz
1340 City-County Building
Detroit, Michigan 48226
Dear Councilman Ravitz:
Your letter of July 11, 1972 requests our analysis and comment
of Ann Arbor Mayor Robert Harris' June 20 letters addressed to
you and to Mr. R.J. Schneider, Director of Air and Water programs
in the Environmental Protection Agency, Region V, in Chicago.
In his letter addressed to you we feel that Mayor Harris, in his
"stampede" accusation, discredits the member - representatives of
SEMCOG and imputes to the Wayne County Road Commission a power
which it does not have and a credit which it does not deserve.
His letter recites several reasons for suggesting that the Plan II
project might not be built, but he apparently feels that the strong-
est opposition can be generated by bringing everyone with an inter-
est in Lake Erie into the issues on Ann Arbor' s side by presenting
a 19-page assessment of the "phospate problem".
Much of this document is a re-hash of previous comments concerning
out-dated reports on the subject. The only relevant material con-
cerns the recent U.S.-Canada treaty conference where it was generally
agreed that the total phosphate content of wastewater treatment
plant effluent should be limited to 1.0 milligrams per liter (1 p.p.m.
which level can be achieved. Since the average incoming waste to be
treated contains about 10 p.p.m., this would call for 90% removal.
Also, it was agreed by the U.S. and Canada conferees that a total
phosphate loading of Lake Erie amounting to 0.13 grams per square
meter per year is a tolerable level and that 0.28 grams per square
meter per year is a dangerous loading. The 1970 loading was 1.1
grams, or about four times the dangerous level. Applying the
factors to a situation closer to home, the Ann Arbor plant has a
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2 of 2 councilman Mel Reviltz Aug 3,
of Wayne County RoaJ Commissioners
capacity of approximately 16 million gallons per day and with
the 95% phosphate removal proposed by Mayor Harris a loading r»n
Ford Lake, in Washtenaw County downstream from Ann Arbor, of
approximately 3 grams per square Meter per year results. This
is ten times the dangerous level established for the larger body,
Lake Erie, and is the type of situation regarding the operation
of the Ann Arbor plant that has caused the concern of all munici-
palities on the Huron downstream from Ann Arbor. The city wants
to continue this type of operation because it is cheaper for
Ann Arbor in the short range term and because it prefers local
autonomy to the regional solution for these matters.
We feel that regional and particularly watershed solutions must
take precedence over local ones, and have proposed the Huron System
project because the problems and the needs are critical in Wash-
tenaw County at this moment. We have stated that Wayne and Oakland
do not need this project at this particular time, but because the
problems in Washtenaw are approaching the crisis stage, we have
said that if there is ever 'going to be a regional system, it has
to be agreed to now. We further believe that water quality stand-
ards and treatment level requirements should be established by the
appropriate federal and state agencies having responsibility and
should be determined by ecological and limnological rather than
political considerations. Ann Arbor has supported Plan I-B which
puts everyone else in the Huron Valley System, but leaves Ann Arbor
to continue to degrade the Huron downstream, while hypocritically
building parks and recreational facilities along the river within
the city, upstream from the city's treatment plant.
Mayor Harris closes his letter with the implication that if E.P.A.
supports the project as the Michigan Water Resources Commission
and SEMCOG have, their final resort will be to the courts. We feel
that Ann Arbor stands alone, and that this is not the position of
the rest of Washtenaw County. If such a course is followed, then
we feel Wayne County should file counter litigation to stop any
further connections to the Ann Arbor sewerage system and treatment
plant until the courts have resolved the matter.
ery truly
James M. Davey //
Managing Director •/
cc: Mr. J. Trainer
Mr. G. Remus /
Mr. R. Schneider1^ *
Mayor R. Harris
Mich Water Resources Comm
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1 " I?
Minister Mmistre
Environment Canada Environnernerti Canada
Ottawa , Ontario ,
K1A OH3
AUS17 1972
His Worship Mayor Robert J. Harris^ ;' _0
City Hall, * =
Ann Arbor, Michigan 48108, J"*-
U.S.A. C. 7? i "•"]
> ro r— j
Dear Mayor Harris : C- -*=
Further to the reply by Mr. Lawless of July 5t
1972, to your letter to Prime Minister Trudeau of
June 22, we would advise that we share your deep
concern for the eutrophication problems of Lake Erie.
In your attached letter to Mr. Schneider, your outline
and analysis of the phosphorus control measures in the
various reports leading up to and including the Canada-
United States Agreement on Great Lakes Water Quality was
very ably presented.
With respect to Canada's position, I would
refer you to the Canada-United States Agreement and,
particularly, those sections dealing with control of
eutrophication, Article V, l(c) and Annex 2.
Specifically, the phosphorus content of effluents from
sewage treatment plants is to be limited to 1 mg/1
which corresponds to approximately 90 per cent removal
from sewage where there is no detergent phosphorus
control, or 80 per cent removal from sewage where there
is detergent regulation to the 5 per cent P2°5 level.
This limit was agreed to between the two countries as
being based on the best available technology which could
be attained consistently in plant operations at this
time and was considered more meaningful than a per cent
removal criterion. I would point out, further, that
within Annex 2 of the Agreement it was recognized that
the residual phosphorus loading that would be attained
with these control measures may not be adequate to
completely eliminate the problem of eutrophication and
that additional measures may be required later. The
Agreement is a dynamic instrument which calls for a
\
V
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review of phosphorus control programs, lake loadings,
and monitoring of the degree of eutrophication, with a
view to ensuring that problems are eliminated as soon as
practicable. Compliance with the Agreement in its
present form would ensure that phosphorus loadings to
the lakes are reduced to below those which first began
to produce extensive anoxic conditions in the central
basin of Lake Erie in 1959-60, and will undoubtedly
greatly reduce algal growth (see attached report).
With respect to detergent phosphate control,
we would advise that the Minister of the Environment has
announced that as of January 1, 1973, the phosphate
content of detergents is to be limited to 5 per cent
PO^C in Canada, and we would hope that other concerned
jurisdictions on the Great Lakes system would consider
following a similar course, as New York State has
already indicated it will do.
We are pleased to have drawn to our attention
your specific concern about the adequacy of Detroit
River sewage treatment plants, and will seek clarifi-^
cation of this matter through the Advisory Boa'rcts_J£>j:_
International Joint Commrssion_establisned to oversee
implementation of the Agreement".
Should you require further specific informa-
tion, from a Canadian point of view, on some of the
points which you raised with Mr. Schneider, I would
suggest that you contact directly Mr. J.P. Bruce,
Director of the Canada Centre for Inland Waters,
Burlington, Ontario.
Yours sincerely,
ofen-M*h
J5xeeutive-~As-&i&ta*vW
Enclosure
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House of Representatives
LANSING, MICHIGAN 4B9O1
53RD DISTRICT
RAYMOND J. SMIT
BOX 119
LANSING, MICHIGAN 4B9D1
PHONE:
AREA 517-373-1793
MEMBER OF COMMITTEES ON
CONSERVATION AND RECREATION
ROADS AND BRIDGES
TOWNS AND COUNTIES
August 18, 1972
Environmental Protection Agency
Region V
1 N. Wacker Drive
Chicago, Illinois 60606
Attention:
Dear Sir:
R. J. Schneider, Director
Air and Water Programs Division
Your invitation to comment on the sewerage problem in Southeast Michigan is
appreciated. I am pleased to learn that your agency is undertaking a complete
review of environmental considerations.
I regret the delay in my responding to your request for comments, but the
press of our legislative schedule has delayed ray review of the voluminous
background material submitted to you by the Michigan Water Resources Com-
mission and the City of Ann Arbor.
In general Ann Arbor has adequately documented the aspects of cost as affects
the city and I will not dwell on these items. However, there are certain
other implications to the sewerage problems that I wish to bring to your
attention.
Appended to the Michigan Water Resources Commission documents of February, 1972
entitled, "Environmental Assessment, Phase I Plan, for Water Quality Management,
Southeast Michigan Area", is my letter of November 10, 1971 expressing my dis-
agreement with the decision of the Water Resources Commission for adopting their
Plan II. After careful review of the February, 1972 Water Resources Commission
document, I continue to believe that the Commission has made the wrong decision
in opting for Plan II. Please refer to my prior letter for the basic arguments
as to why Plan II is not sound financially, imposes the most severe pollution
load on Lake Erie, robs the Huron River of an important water resource and is
inconsistent with wise land use planning policies for the region.
During their preparation of the environmental assessment document, the Water
Resources Commission staff extended to me the courtesy of reviewing preliminary
drafts. At that time I offered criticism that the environmental assessment
seemed more a document to rationalize the decision which their agency
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had reached rather "han provide an objective assessment of environmental
impact aiH while many of th*2 problems have been removed, many remain in th«
i Envi roniaental AssesKmsat. While such a bias is understandable by the ag« ty
which made the original decision, it is assumed that your environmental
assessment will correct these comments in the state agency assessment, wit. L.-b
reflect bias.
i
i More specifically "sn -•?.-ipoiiS»e to the conclusions stated in the Water Resources
j f ConciliasI'. :i study, I offer these additional comments:
i
A. Clarification is needed in the reference on Page II-5 relative to the
Flat Rock water supply, for that supply has been planned to be phased
out for several years with water being furnished from the Detroit-Metro-
politan Water System.
B. Under conclusions and recommendations (Page V-l) it is stated that there
are "no significant differences among the four alternatives in regard to
Lake Erie." However, a comparison tabulated on page IV-16 and IV-17 shows
significantly leas BOD, suspended solids and asaraonia nitrogen under plans
I-B and IV than under Plans II and III (the difference is on the order of
about 25%). Further there is some evidence that biological processes and
sedimentation will reduce much of the phosphorus in the Huron River prior
to reaching Lake Erie, further improving water quality at Lake Erie and
the effect of these nutrients will be more severe in quiescent Lake Erie
than in the flowing streams.
C. Under conclusions (Page V-l) .it is stated that there is no significant
difference in per capita costs, these being within 10% of each other.
The members of the Water Resources Commission have stated that their
decision in favor of Plan II was made on the basis of that being least
expensive and if further study shows this not to be the case, a re-evaluation
of that decision may be in order. I believe a thorough understanding of
the cost comparison question should lead to a conclusion that Plan II is
not the best proposal for the entire area. There are errors in computing
per capita costs which need to be clarified:
1. Per capita costs include only 25% of capital cost on the assumption
that 75% would be state and federal grants and 25% borne locally.
All grants are in public money from the taxpayers and must be in-
cluded in reaching decisions on expenditures of public funds. Plan
II is by far the most expensive in capital costs and when all factors
are included, the final comparison of total per capita costs for
Plan II (Page IV-9) now appears to be more expensive to the local
citizen also.
2. Cost comparisons assume only high rate secondary treatment at Lake
Erie. I am told that your agency agrees with me that treatment ob-
jectives at Lake Erie must be higher than such treatment will provide.
Therefore, the only valid comparison in costs should be that which
includes comparable tertiary treatment at Lake Erie.
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—3~
3. Operating cost comparisons give exaggerated lower costs for Plan II
based on the assumption of only secondary treatment costs at Lake
Erie and a disproportionate recognition of economies of scale. These
operating expenses need further explanation and documentation for these
figures do not seem comparable with experience at other plants.
4. Costs of retiring existing plants are incomplete, including only the
state grant share and not the local coat of abandoning local plants
(See page IV-6 and IV-7).
5. Final cost comparisons are made for the 1990 project. Some sewers are
proposed to be built for 2020 needs, while others for 1990. The present
population, however, will have to pay for present construction and costs
they will have to actually pay should be compared, not costs for a 1990
hypothetical project that is not going to be built.
Furthermore, as I stated in my previous letter, sewers should be de-
signed to serve population growth beyond 15 to 16 years, particularly
in view of their high replacement cost. Treatment works, on the other
hand, can be more readily expanded and thus can be built for a shorter
design period. Design standards and cost comparisons to the taxpayer
should be revised to reflect this more appropriate basis for engineering
design.
6. Under Plan II a time lag in construction requires building interim
treatment improvements at Ann Arbor which later are to be abandoned.
These costs have not been included in the cost comparison.
7. In what seems to be a change in position for the Water Resources Com-
mission, that agency now chooses to minimize the importance of flow
augmentation for the Huron River while all of their prior studies have
emphasized that need. I believe the need for flow augmentation under
Plan I-B could be questioned, but under Plan II, with over half of the
dry weather flow being taken for water supply at Ann Arbor and Ypsilanti
and diverted out of the river through interceptor sewers to Lake Erie,
it should be clear that restoration of low stream flows is essential
to the implementation of the plan.
Furthermore, legal authorities question if water withdrawals could con-
tinue at such a level at Ann Arbor and Ypsilanti without running into
conflict with existing Michigan law. This legal issue is summarily
dismissed in the Environmental Assessment but has broad implications
to the region. If such diversion is curtailed by the courts it would
force early abandonment of existing water treatment facilities at these
cities.
In comparing costs, the lowest cost alternative for flow augmentation was
selected and that project included a reservoir upstream from Ann Arbor.
However, more recent studies have shown that adverse effects on water
quality in the Huron River would result from the impoundment that had
been proposed and practical difficulties and conflicts with other
planned land uses mitigate against constructing an augmentation reservoir
on the site that had been considered. Truly the only viable alternative,
-------
if the quality of water supplied at Ann Arbor is to be protected,
and if diversion from the Huron River is not to be permitted,
would be the purchase of water from a Detroit-Lake Huron Supply.
Such a purchase and abandonment of existing water treatment facilities
would increase costs substantially above those used in the Environ-
mental Assessment study, and further there is no indication as to
how such costs are to be apportioned.
D. The logic used to justify selection of Plan II is very weak. As noted
originally, the decision in favor of Plan II was made on the basis of
cost advantage, but now, as stated in the Environmental Assessment report,
is apparently based almost entirely on risks of accident or malfunction
of a plant on the Huron River (Page V-l). The results of such an
accident appear very remote and adequate redundancy can be constructed
into new facilities to make risk of accidental spill insignificant. It
is further suggested that spreading of such risks among several treatment
plants will further minimize the possibility of serious damage from such
an accident.
However, if accident or malfunction is to be the compelling basis for a
decision against construction of a treatment plant on the Huron River,
then such risks could be completely eliminated by simply enlarging pro-
posed retention basin capacity and standby pumping to eliminate that
problem. Such protection would be possible at a plant the size of Ann
Arbor's, but becomes much more difficult at the mammoth plant proposed
at Lake Erie. For example, the 33 million gallon per day flow anticipated
at-Ann Arbor could be stored for the maximum time contemplated in the
Environmental Review of five days in a pond twenty feet deep by twenty
five acres in area. After the crisis period had passed, flows could
then be taken back through the treatment plant.
Such a facility would not just protect to the extent of preventing
tolerable damage but would insure against any accidental spill of waste
water from Ann Arbor to either the Huron River or Lake Erie.
It must be added parenthetically that the justification given in the
Environmental Assessment for accident spill into Lake Erie seems weak
and supported only by a conclusion that there would be dilution of 100
to 1 (Page V-l).
While an impoundment to catch accidental spills may not be justified to
satisfy the very infrequent potential of such a spill, if experience
shows such protection to be necessary it can obviously be provided with
added cost below that which would significantly alter the economic
advantages of Plan I-B.
E. Institutional arrangements for financing Plan II do not exist at the
present time and the possibility of creating suitable means of financing
is in doubt. I am advised that there is disagreement between the units of
government as to how the costs for-the intercepting sewer project is to
be allocated. Oakland County is now seeking to establish a lower population
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-5-
potential than that used in the designed study and environmental review.
Such an adjustment would have the effect of shifting financial burden
from Oakland County to Washtenaw and Western Wayne County and gives aspect
to the fears ennunciated in my prior letter that Plan II is supported by
Oakland County on the assumption that its share of a sewerage system
could be financed by others until its population base increases to justify
that expense.
A review of the cost figures on Page IV-12 makes it clear that a signifi-
cant subsidy of Oakland County is already inherent in any of the regional
plans studied and the requirement that other areas pick up even greater
portions of its share is unconscionable. With 5.4 billion dollars
equalized valuation, Oakland County does not qualify for poverty aid
from its neighbors.
F. From a regional planning standpoint, Plan II is destined to promote urban
sprawl throughout Eastern Washtenaw, Southwestern Oakland and Western
Wayne Counties. Presently Western Wayne County is reported to be only
55% developed, so promotion of instant urbanization throughout Oakland
and Washtenaw County would not seem prudent planning. Pressures for out-
migration are strong in Wayne County due to economic factors, threat of
court ordered school bussing and excellent freeway connections between
Detroit and surrounding counties. However, to foster broad expansion
and rapid growth in outlying areas has adverse social implications, will
result in furthering undesirable land use patterns in the Detroit Metro-
politan area and promote unnecessary local tax increases.
You may wish to review the experience of independence of action which
has occurred in Ypsilanti Township and which has been independent of
planning considerations for the balance of Washtenaw County. Fostered
by a federal gift of water and sewerage systems following the Second
World War, developments have proceeded rapidly in Ypsilanti Township,
promoting sprawl throughout that community. More recently political
developments have seen Ypsilanti Township contracting with five or six
nearby townships to extend utility services into the presently unde-
veloped areas and the recent availability of Detroit and Wayne County
water and sewer services to that township is being used as a basis for
such contracts.
Such a growth syndrome is now seen to be desirable by many local govern-
mental officials in the townships involved, for they expect it will enhance
local esteem and reduce property taxes. Experience elsewhere in the metro-
politan area has shown that expectations of such benefits are deceiving
and short lived and such sprawled communities end up with significantly
greater tax burden than those which have carefully planned and confined
the pressures of the land developer. There are other townships in the
area which are also eyeing the availability of sewer service being pro-
vided to them directly through the interceptor to open the door to land
development in their area. But most important, once utilities are in
population growth must be fostered to pay for the systems.
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-6-
While I have found that some of the restraints imposed by some core
cities against sewer extensions into surrounding townships have caused
unnecessary hardships in some cases, I also believe that the possibility
of unrestrained development pressures in newly sewered rural townships
will be irresistible locally and result in serious distortion of current
plans for controlling utfban development of Eastern Washtenaw County.
The Environmental Assessment says that all plans are generally irrevers-
ible. While it is true that Plan II might be irreversible, I disagree
that Plan I-B is such. At the time of the 1990 expansion of the inter-
cepting sewer system as planned in the Environmental Review, a suitable
situation would be present for expansion of any sewer service area that
might be desired. However it is very unlikely that reversal of the
decisions from adoption of I-B would become necessary, for more probably
a reduction in service area, not an expansion, would be desirable in the
future if emerging technology is successful.
A final point, the Water Resources Commission Environmental Review dis-
cusses waste water disposal in the Upper Huron and the Lower Huron but
does not review any Implications on the reach of the Huron River between
Ann Arbor and the Oakland County line. This portion of the river also
includes a number of treatment plants in growing urban centers. The
omission is significant for these discharges will also affect downstream
water uses.
For example, accidental spill or malfunction at these eight proposed and
existing treatment plants in the middle reach of the river would compound
the concern for accident significantly. If policy were to be consistent
the interceptor would have to be extended to collect sewage from these
additional plants and indeed some preliminary decisions have already been
made to extend the interceptor farther upstream from Ann Arbor. Several
of the plants, however, are to be improved but retained in service to the
apparent satisfaction of state agencies.
Cost comparisons in the Environmental Assessment Review include no con-
sideration for interceptor extension above Ann Arbor. Yet once transpor-
tation to Lake Erie is the adopted policy, there is very little option
available.
There has been political support generated along the lower reach of the
Huron for Plan II on the basis that it would better protect the river
for swimming. Any illusion of such a benefit should be dispelled for,
as pointed out in the Environmental Assessment, waste water effluent
should be of quality superior to that of the river.
The public should not be deceived into believing that removal of this
well treated effluent from the stream will protect water for body con-
tact uses. Urban run off problems alone from the downstream portions
of the basin should mitigate against swimming because of the danger
of illegal or accidental waste water cross connections and pollution
from storm water run off. And even if known point sources were corrected,
swimming in a stream whose waters are largely derived from draining
an urban area is of questionable wisdom.
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-7-
In years past health authorities have ruled against swimming at the
Huron even upstream from the Ann Arbor Waste Treatment Works, and very
recent tests by the United States Geological Survey of the river above
Ann Arbor shows that the water does not normally nor consistently meet
bacteriological standards for body contact use. It is therefore de-
ceiving to the public aspiration for more recreational pursuit to pro-
claim that Ford Lake and Belleville Lake (Page 1-18) are protected
for body contact recreational use either now or after the interceptor
is built. Reduction in low flows in the river proposed under Plan II
raerely intensify any such problem.
J. It is noted that the Environmental Review tries to make an issue of
performance of treatment by the Ann Arbor plant (Page 111-25 and
appendix) and we have been told in the past by the state agencies that
the Ann Arbor plant has had exemplary performance and only recently
have fully loaded conditions caused operational problems.
Obviously this effort to discredit Ann Arbor's plant is inappropriate
in the Environmental Review for any newly designed facilities should
eliminate the operating difficulty. If, however, plant operation is
to be an issue you will wish to review the operating experience at
Detroit and other major treatment plants in the area to determine the
effects of comparable operating experience and the expected problems
of effective operation at the proposed Lake Erie plant.
There are many other points to be made in criticism of the Environmental
Review but this letter is already too long. However it is hoped that after
you have carefully reviewed these and other issues you will take early action
to permit Ann Arbor to construct urgently needed improvements to its waste
water treatment facilities.
The need to give complete and adequate protection to the river is pressing
and any delay merely compounds the imminent danger to the river.
Very truly your
RAYMOND J. SMIT,
State Representative
RJS/w
CC - Governor William Milliken
Congressman Marvin Esch
Mayor Robert Harris
Washtenaw County Department of Public Works
Michigan Water Resources Commission
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THE UNIVERSITY OF MICHIGAN • COLLEGE OF ENGINEERING
ANN ARBOR 48104
DEPARTMENT OF CIVIL ENGINEERING 22 AUCfUSt 1972
Mr. R.J. Schneider, Director
Air and Water Program Division
United States Environmental Protection Agency
Region V
1 North Wacker Drive
Chicago, Illinois 60606
Dear Mr. Schneider:
Please find enclosed herewith my response to your letter
of 23 May 1972. Given the nature of the problem under
investigation, it is my hope that the Environmental Protection
Agency will produce an Environmental Impact Statement regarding
the several alternatives which are available for wastewater
treatment in Southeastern Michigan.
The document which has been prepared -
"Environmental Assessment, Phase I Plans for
Water Quality Management, Southeastern Michigan
Area"
is certainly not satisfactory for the reasons cited in my
enclosure. Certain portions of the report are misleading
and consequently, the entire report in my view lacks
creditability.
If I can be of further assistance, please let me know.
Also, I would appreciate being kept informed of EPA's actions
in this matter.
Very truly yours, ^
Jonathan W. Bulkley r.,
Associate Professor c~n
ENVIRONMENTS PRO! tCIIGN At-ENCYV,
RECEIVED - £
AUQ281972
PLANiMING BKAiV.il Region V
RLE NO..
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ENVIRONMENTAL ASSESSMENT
PHASE I PLANS
FOR
WATER QUALITY MANAGEMENT
SOUTHEASTERN MICHIGAN AREA
MICHIGAN WATER RESOURCE COMMISSION
OBSERVATIONS
A. General Observations
1. Population Projections - rather than a single figure as
presented, it is more appropriate today to calculate a
range of likely projections - i.e., high growth, slight
growth, no growth, and negative growth. In this way
one can observe what affect - if any - an error in
population projections is likely to have upon project
evaluation.
2. Costing - The assessment does this upon a per capita
basis within a service area. If service area crosses
established political boundaries the analysis assumes
uniform charges; however, current Michigan legislation
may preclude implementation of uniform charges. If the
decision is to be based upon economic analysis, it is
important to recognize that what appear to be lower
costs/capita when taken for an entire service region
may in fact be forced subsidization of one area for
another.
3. Recreational Developments - Especially Ford Lake/Belleville
Lake - more information on public access and alternatives
such as swimming pools in the recreations area is needed.
-------
The River and cerv.ain man-made lakes can be extremely
dangerous for swiioning. One must ascertain whether or
not it is in the public interest to provide swimming in
areas which may be biologically safe but physically
hazardous because of swift currents (river) or sharp
bottom drop-off (Ford Lake).
4. Lack of Analysis - Impact of storm water runoff on water
quality is not considered. This fact limits the usefulness
of the report. Dr. R.P. Canale of the University of Michigan
has applied mathematical modeling to the Huron River and
Ford Lake. His work'clearly indicates that storm water
runoff is far more serious for water quality than the sewage
treatment plants.
B. Specific Observations
1. On pages I-25/I-26 Huron River Water Quality Data - one
isolated sample of data for dissolved oxygen (DO) con-
centration in the Huron River is used. No indication of
when it was taken, i.e., 3 am in the middle of summer or
2 pm on the same day. The time of day can have a significant
effect upon the DO. The assessment gives emphasis to
isolated samples, i.e., 1 sample. The bi-weekly FWPCA
data effort provides max-min-average figures for parameters.
However, the assessment chooses not to utilize these data
but rather the single data value cited above. Note the
bi-weekly annual data - minimum never went below 4 mg/1
and that the mean value is above 9 mg/1 throughout the
river.
2. Page 1-46 - Given the detailed criticism which is provided
-------
of the operation of the Ann Arbor and Ypsilanti sewage
treatment plants - the report should examine the operation
of the Detroit Wastewater Treatment Plant - while this can
only demonstrate primary treatment plus phosphate removal -
it should serve as an indicator of the reliability of
that plant.- This information coupled with specification
of the desired objectives for enhanced operation is
necessary for evaluation of alternatives.
3. Page II-5 - Plan IA and IVA were dropped on the recommendation
of the Michigan Department of Public Health. These
Alternatives proposed a major treatment plant outfall up-
stream of the City of Flat Rock's municipal water supply
intake. Such an outfall was felt to be inconsistant with
downstream use of the river for water supply purpose.
This statement does diservice to the entire analysis.
The fact of the matter is that while the City of Flatrock
currently takes .75 mgd from the Huron River, the Detroit
Metro Water Service has service mains which deliver water
to the contiguous area (Brownstown Township). A new
automotive casting plant in Flatrock is on Detroit Metro
Water Service - in fact water service by DMWS was a
condition for location of this new industrial plant. The
primary mains serving Brownstown Township have been
designed and built with sufficient capacity to serve
Flatrock as well. In fact, the only issue which appears
to be delaying provision of DMWS water to Flatrock is a
local dispute between Brownstown Township and the City
of Flatrock over ownership of water mains in an area of
-------
The River and certain man-made lakes can be extremely
dangerous for swimming. One must ascertain whether or
not it is in the public interest to provide swimming in
areas which may be biologically safe but physically
hazardous because of swift currents (river) or sharp
bottom drop-off (Ford Lake).
4. Lack of Analysis - Impact of storm water runoff on water
quality is not considered. This fact limits the usefulness
of the report. Dr. R.P. Canale of the University of Michigan
has applied mathematical modeling to the Huron River and
Ford Lake. His work clearly indicates that storm water
runoff is far more serious for water quality than the sewage
treatment plants.
B. Specific Observations
1. On pages I-25/I-26 Huron River Water Quality Data - one
isolated sample of data for dissolved oxygen (DO) con-
centration in the Huron River is used. No indication of
when it was taken, i.e., 3 am in the middle of summer or
2 pm on the same day. The time of day can have a significant
effect upon the DO. The assessment gives emphasis to
isolated samples, i.e., 1 sample. The bi-weekly FWPCA
data effort provides max-min-average figures for parameters.
However, the assessment chooses not to utilize these data
but rather the single data value cited above. Note the
bi-weekly annual data - minimum never went below 4 mg/1
and that the mean value is above 9 mg/1 throughout the
river.
2. Page 1-46 - Given the detailed criticism which is provided
-------
of the operation of the Ann Arbor and Ypsilanti sewage
treatment plants - the report should examine the operation
of the Detroit Wastewater Treatment Plant - while this can
only demonstrate primary treatment plus phosphate removal -
it should serve as an indicator of the reliability of
that plant.. This information coupled with specification
of the desired objectives for enhanced operation is
necessary for evaluation of alternatives.
3. Page II-5 - Plan IA and IVA were dropped on the recommendation
of the Michigan Department of Public Health. These
Alternatives proposed a major treatment plant outfall up-
stream of the City of Flat Rock's municipal water supply
intake. Such an outfall was felt to be inconsistant with
downstream use of the river for water supply purpose.
This statement does diservice to the entire analysis.
The fact of the matter is that while the City of Flatrock
currently takes .75 mgd from the Huron River, the Detroit
Metro Water Service has service mains which deliver water
to the contiguous area (Brownstown Township). A new
automotive casting plant in Flatrock is on Detroit Metro
Water Service - in fact water service by DMWS was a
condition for location of this new industrial plant. The
primary mains serving Brownstown Township have been
designed and built with sufficient capacity to serve
Flatrock as well. In fact, the only issue which appears
to be delaying provision of DMWS water to Flatrock is a
local dispute between Brownstown Township and the City
of Flatrock over ownership of water mains in an area of
-------
4
the township which has been annexed to Flatrock.
At least two alternatives have been dismissed because
of an aledged threat to public water supply. The facts
do not support the action by the State Health Department.
This misrepresentation causes the entire document to be
suspect. Clearly a whole family of alternative solutions
have been dismissed which should in fact be considered
and evaluated in detail - namely the provision of high
order waste water treatment plants located in Western
Wayne County as well as in Washtenaw County.
4. Treatment requirmentS specified in II-3 and III-4 are
different for effluents going into Huron River and
effluents discharged directly to Great Lakes - Lake
Erie. This fact is not well known by the public.
Accordingly, it is recommended that cost figures be
developed which show the cost per Ib of pollutant
removal from the waste water. This type of cost
figure coupled with the information on treatment levels
would assist the evaluation of alternative treatment
plants.
5. The dilution assumption based upon 10% of the flow of the
Detroit River - see pp. 111-17, 111-36, 111-37 and 111-38- is used
throughout the report where the Huron River plant is
investigated. The analysis neglects to calculate the
mixing zone required to achieve the type of dilution
assumed. It is of particular"importance since the location
of the proposed Huron River plant is at the mouth of the
Detroit River - in fact the effluent will be discharged
-------
5
directly into Lake Erie. A very real question is what is
the size and shape of this mixing zone under various wind
conditions. It is inappropriate - in my judgment - to
assume complete mixing without providing information on
the nature of and characteristics of the mixing zone
required to.achieve the assumed dilution of the massive
waste load being dumped into Lake Erie.
6. Furthermore, the authors of the assessment have emphasized
data which is particularly favorable to the State's position.
This fact has already been demonstrated in the dissolved
oxygen situation in the Huron River. The Public Health
Service Report cited by the State as the source for the 10%
flow of the Detroit River (above) also has the following
information:
"A Second area of relatively low DO (dissolved oxygen) was
found immediately below the mouth of the Detroit River
in a finger extending southward for a distance of 4 to 6
miles. Average values here were under 85% saturation;
the minimum value was 4.8 mg/1, just off Pointe Mouille",
(emphasis added). There is no reason to assume that the
DO levels have become more favorable since publication
of these findings. Given the scanty reference provided
on 111-17 and 111-18 to water quality data collected in
1970, it is impossible to evaluate the figure of 7.6 mg/1
for DO as chosed by the Water Resources Commission.
However, in view of the Flatrock case and the selection
of the DO of 2.0 mg/1 as an example, it would appear that
this figure of 7.6 mg/1 is certainly questionable -
-------
especially in light of the USPHS findings.*
7. A major shortcoming of this entire analysis is its lack
of attention to stormwater runoff (page 111-23). A
decision which if taken today - will direct subsequent
sewage treatment activities for the next 50 years should
not and indeed must not be made without consideration of
this important contribution to surface water quality. As
an example, on page 111-26, it is stated that a complete
treatment plant breakdown on the Huron River would
constitute a significant threat to recreation uses near
and downstream of the outfall. In reality, stormwater
runoff constitutes a greater source of coliform than
even complete failure of the sewage treatment plant in
the River, yet, this whole dimension of the problem
is ignored.
8. On page 111-33, the report makes the following statement:
"While it is impossible to forsee, implementation of Plan IB
may also accelerate current growth rates in portion of the
service area. Such accelerated growth may bring about
adverse environmental side effects and the generation of
accelerated needs for additional public expenditures for
various public services". This statement has been added
to balance a similar statement which appears on pages
III-50/III-51 related to Plan II. Clearly, any solution
which utilizes the "Super Sewer" concept is going to
generate strip development along the pipe. This adverse
situation may be lessened by location of a number of
*U.S. Public Health Report, "Report on Pollution of the Detroit River,
Michigan Waters of Lake Erie and their Tributaries", p. 281
-------
very high order treatment plants located within the
interior of the region. Unfortunately as pointed out
in paragraph 3, this type of solution has been ruled
out by the State Health Department for reasons which
are not supported by fact.
9. The waste loadings to Lake Erie from the Huron River
Treatment Plant are shown on page 111-35. It is
understood that np_ sewage treatment plant operates
at constant efficiency of removal. Indeed the output
of a sewage treatment plant is a random variable.
Also, since secondary 'treatment plants of the size
proposed for the Huron River Plant have not yet
become operational in Michigan, it may be more
desirable to carefully monitor the performance, i.e.,
operational characteristics in comparison with
design parameters - of the existing Detroit Sewage
Treatment Plants which are currenlty being upgraded
from primary to secondary treatment facilities. If
these existing plants perform at consistantly lower
levels of treatment than the design levels, adjustments
should be made in the anticipated operating characteristics
of the Huron,River plant.
10. On pages 111-36 and 111-38, the assessment attempts to
justify the discharge of massive amounts of partially
treated sewage into Lake Erie. This effort is misleading
since it is based upon the following assumptions:
A. Complete and instant mixing since no mixing
zone is indicated.
-------
B. A very optimistic value of 7.6 ir.g/1 DO for
Lake Erie. Any average value chor.en may be
extremely misleading since two or three days
of calm days nay cause the DO to go to zero
in the western basin.
Accordingly, the dissolved oxygen analysis presented
in the assessment should be considered as one more
attempt of environmental "justification" instead of
environmental assessment.
11. On page 111-40, the assessment includes an estimate of
the cost of tertiary'filtering facilities. In order to
assist the public in comparing the performance of such
facilities, the assessment should specify the anticipated
effluent to be produced from such a facility. For example,
the requirement for the Ann Arbor Treatment Plant is to
produce an effluent of 4 mg/1 BOD. For the massive
Huron River Plant, the tertiary filtering facilities
appear to be capable of 95% removal which from previous
data would indicate an effluent of 10 mg/1 BOD which
is 2-1/2 times the effluent from the Ann Arbor Plant.
These factors need to be clarified for a complete
understanding of the alternatives.
12. On pages 111-44 and 111-45, the assessment addresses
the question of flow augmentation. The findings by
the Water Resources Commission - namely that the need
for low flow augmentation in the lower Huron under
Plan II has not been established - is simply not correct.
The engineering consultants the Water Resoruces
-------
Commission recommended that flow augmentation be considered.
The assessment itself speculates in the following fashion:
"... the alternative of purchasing Detroit water assumes
that Ann Arbor and Ypsilanti's total supply would be
purchased from Detroit. It might be more economical to
purchase only a portion of the total supply needed and
to retain the Huron source as well as ground water
sources. There is also the possibility that further
ground water sources can be developed." All of this
information uncovers aspects of the problem of waste
water management that' certainly need exploration prior
to any final decision on the Super Sewer. What is suggested
is some sort of optimization problem using three sources
for water - namely the Huron River, Ground water, and
Detroit Metropolitan Water. Until this issue of flow
augmentation has been examined and data provided
regarding cost and environmental impacts associated
with the alternatives, any decision would reflect partial
analysis.
13. Chapter IV contains 21 pages of economic cost comparisons
based on per capita costs of the several alternatives.
As previously stated, these cost comparisons are misleading
since uniform charges are not possible under current law.
Secondly, the cost analysis should be placed on an
effectiveness basin - namely pounds of BOD (etc) removed
per $ invested. Finally, the cost data indicates that at
present one cannot choose on the basis of cost. What is
needed is an additional study to demonstrate the sensitivity
-------
10
of the analysis to changes in projected population.
14. In my opinion, there is a significant difference among
the alternatives investigated. The Water Resources
Commission is anxious to transfer the risk of malfunction
to Lake Erie. As one aggegates wastes into a single
facility, the probability of failure increases. The
size of Lake Erie is no justification for transferring
such a risk of failure. By locating smaller plants on
interior rivers, the incentives will exist to implement
systems and techniques that truly minimize the likelihood
of plant failure.
Jonathan W. Bulkley
Associate Professor
The University of Michigan
Ann Arbor, Michigan
-------
STATE: OF MICHIGAN
TJI? v1. RE-SOURCES COMMISSION
HAHMY H WHITELKY
Cl'.n. man
CAHL 1 . JOHfJSON
C. M LAITALA
HILARY f SNELL
CHARLES G. YOUNGLOVE
WILLIAM G MILLlKEN. Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON BUILDING, LANSING, MICHIGAN 18926
RALPH A. MAC MULLAN, Director
August 24, 1972
WATER RESOURCES
JOHN P. WOODI:ORD
Chairman
ALVIN R. iiALDLN
V tcp Chtiirrnjn
CHARLES O HARRIS
JOHN E. VOGT
STANLEY QUACKENBUSH
THOMAS r JAMES
JOHN H. KITCHEL. MO
Mr. Robert. J. Harris, Mayor
City of Ann Arbor
100 N. 5th Avenue
Ann Arbor, Michigan 48108
Dear Mayor Harris:
ENVIRONMENTAL PRO' EC/iOfi AGENCY
R F n F. I V E D
AUG281972
t'l.AiS.\l:\<- ;,KANUH - Region V
FILE NO
Your June 20, 1972, letter relative to Plan I and Plan II for the
Lower Huron River Basin was discussed at the August 17-18, 1972, meeting
of the Water Resources Commission. It was the decision of the members
that I would transmit our comments to you concerning this letter on behalf
of the Commission.
JCtiif-
INI / /..
MIAT ( /J
u.i ] 4
««i J.—^Jr
At the onset let me correct your misapprehension that our staff may
not have kept us properly informed on communications relating to this
matter. It is our position that staff are scrupulously conscientious
and objective in apprising the members of all germane information and
views on the subjects requiring our attention and that there was no
departure from that policy in this case.
As to the substance of your extremely long letter; in essence, you
argued that none of the alternative wastewater management plans studied by
the Water Resources Commission for portions of western Wayne, eastern
Washtenaw and southwestern Oakland Counties would adequately protect Lake
Erie.
Your position was based on the premise that 90 percent phosphate
removal is insufficient to stop rapid eutrophication in Lake Erie,
particularly under Plan II since the proposed new treatment plant near the
mouth of the Huron River will be large and will be situated at one of the
most eutrophic, phosphorus-laden spots on the lake.
Your letter concluded with the-requests that the EPA:
1. prepare an Environmental Impact Statement which would re-examine
the matter of phosphorus loadings to Lake Erie;
2. reject Plan II and endorse the concept of "Riverside" plants
rather than "Lakeside" plants;
3. require at least 95 percent phosphorus removal at any plant
regardless of location.
-------
Mr. Harris »2- August 24, 1972
We. believe there are several basic deficiencies and omissions in
your arguments.
1. You erroneously consider technical recommendations of outdated
reports dealing with Lake Erie as being valid today. New data
are available which presents a more optimistic picture regarding
enhancement of water quality in Lake Erie through phosphorus
control programs. ;
The latest guideline for Federal agencies, states and provinces
is, of course, the new International Agreement between the United
States and Canada. The Agreement establishes target phosphorus
reductions for the next six years from both countries and
specifies an effluent restriction not to exceed a daily discharge
of 1 mg/1 for municipal waste treatment plants discharging more
than 1 million gallons per day into Lake Erie, Lake Ontario and
the international section of the St. Lawrence River.
2. You do not recognize the basic assumption that phosphorus is
transported by the tributaries to the Great Lakes System in
essentially undiminished quantity. While reason and speculation
would indicate that some reduction in phosphorus loading might
take place in river impoundments, data are not available to
substantiate this speculation nor to quantify such reduction.
Therefore, it must be assumed that the phosphorus does reach the
Great Lakes system from inland sources. Consequently, we fail
to see any significant difference in phosphorus loadings to
Lake Erie under any of the alternative plans studied.
3. You fail to give any consideration to protecting the Huron River
lakes and impoundments from eutrophication by nutrient discharges
from inland treatment plants. Downstream from the Ann Arbor
wastewater treatment plant, both Ford and Belleville Lakes have
been the subject of extreme concern by residents and users in
regard to their eutrophic state. These water resources must also
be protected, along with Lake Erie. You cite a number of loading
values from various study reports on Lake Erie. Three of those
values taken from the 1970 IJC report dealing with Lake Erie,
Lake Ontario and the international section of the St. Lawrence
River are as follows:
Permissible loading to Lake Erie. . . 0.13 gm/m2/yr
Dangerous loading to Lake Erie. . . .0.28 gm/m^/yr
1970 loading to Lake Erie 1.10 gm/m2/yr
If one were to assume that: (a) Plan IB was adopted, leaving only
Ann Arbor discharging to the Huron River with its present discharge
of 15.A million gallons per day, and (b) 95 percent phosphorus
removal was achieved by the Ann Arbor plant, the discharge to Ford
Lake in terms of phosphorus loadings would be 2.8 gm/m^/yr.
-------
Mr. Harris -2- August 24, 1972
A. Your letter underscored the tact that the Water Resources
Commission's approval of Plan II was contingent upon EPA's
approval of the proposed treatment levels at the Lake Erie
wastewater treatment plant. The proposed treatment level is
secondary treatment and 90 percent phosphorus removal. You
noted that the underlying reasoning was that if higher treatment
levels were required, the operating costs of Plan II would
increase greatly and that Plan might not, therefore, be the
best alternative.
It should be made perfectly clear that the Commission's concern
about higher treatment levels was not related to phosphorus
removal but specifically to levels of BOD removal.
If, as may well be, higher levels of phosphorus removal are
to be required, they will be required at all of the treatment
plants considered in the alternative plans. Correspondingly,
the operating costs of all the alternative plans will increase
and there is no reason to expect any change in the cost ranking
of the alternative plans. Actually, some economy could possibly
be achieved at large plants in comparison with smaller plants.
It is the conclusion of the Commission that correspondence on this
matter has fully examined all valid representations as to the respective
merits of the several plans.
Very truly yours,
WATER RESOURCES COMMISSION
'John P. Woodford
Chairman
cc: Environmental Protection Agency
-------
Mr. Ralph W. Purdy, Executive Secretary
Michigan Water Resources Commission
Department of Natural Resources
Stevens T. Mason Building
Lansing, Michigan 4S926
Dear Mr. Purdyi
As you are aware, this region of the Environmental Protection Agency
is currently making a study of the Environmental Impacts of the
various Wastewater Management Alternatives considered in the Phase I
Plans for Hater Quality Hanagecent, Southeastern Michigan Area.
We ere anxious to complete our study which is prerequisite to our
tasking a decision regarding vrhich alternative is the least damaging
to the environnent and the most cost effective.
Accordingly, \re are in need of additional information as follow*i
1. What are the methods and costs involved in sludge disposal
under Plans IB and II? Inhere will disposal facilities be
located? If incineration is used, where will ash be deposited! '
2. It appears that flow augmentation below the city of Ann i
Arbor nay become necessary, under Flan II. . If augmentation
is needed, how will it ba accomplished, what will the costs
be, aad what will be the effect on the cost effectiveness !
of Plan II? ,:
i
3. Kou vill Plans IB or II affect the proposed recreation i
complex at Pte. Ilouillee, especially in regard to possible ,
contamination of the vater adjacent to the park due to j
effluent discharge? Under what conditions could contamination |
occur, and how often would contamination be expected to :
occur?
4. What, if anything, could ba done *- either the design of
the treatment plant outfall v-r ttis recreation complex to
prevent contamination or xecreation water*? '
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5. V.liat effects would the interceptor and its construction have
on the natural environment, residential areas, transportation
routes, parks, and other existing and planned land uses?
Is detailed data available on the route locations of the
interceptors described in Plans IB and II?
Ue anticipate that ve nrsy find it necessary to request additional
information frca you as our study progresses, and we appreciate
any assistance you may provide.
Sincerely yours.
R.J. Schneider, Director
Air end Water Programs Division
J-ETStenson:cb
8-24-72
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STATE OF MICHIGAN
NATURAL RESOURCES COMMISSiON
HARRY H WHITELEY
Chairman
CS.RL T JOHNSON
E M LAITALA
HILARY F SNELL
CHARLES G YOUNGLOVE
WILLIAM G. MILLIKEN, Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS T MASON BUILDING, LANSING, MICHIGAN 48926
RALPH A MAC MULLAN, Director
August 31, 1972
WATER RESOURCES COMM'SSION
JOHN P WOODFORD
Chairman
ALVIN R BALDEN
Vice Cha'rman
CHARLES D HARRIS
JOHN E VOGT
STANLEY QUACKENBUSH
THOMAS F JAMES
JOHN H KITCHEL, M D
Mr. R. J. Schneider, Director
Air and Water Programs Division I L
Environmental Protection Agency
I North Wacker Drive ;__
Chicago, IL 60606
i-^,
i
Dear Mr. Schneider: -
t; ~~~
\ have received your letter of August 28, 1972 in which you request additional
information about the wastewater management alternatives considered in the
Phase I Plans for Water Quality Management, Southeastern Michigan Area.
No one is more interested in arriving at a decision on this matter and getting
on with the implementation of an effective water quality management plan than
the Michigan Water Resources Commission. In responding to your letter, however,
I must point out that your inquiries fail to indicate an understanding of the
nature and effort that has been undertaken in the Southeast Michigan Area. In
our study of engineering alternatives, our consultants examined seven alternative
regional wastewater management plans in considerable detail. As requested by
your agency, our environmental assessment addressed four of these alternatives
with significant depth.
It was never contemplated, however, that detailed engineering plans and detailed
cost calculations would be developed for all of the alternative plans. Further,
it does not seem prudent to require such costly engineering studies until there
is at least a likelihood that the proposed plan will be approved. I find it
impossible to satisfactorily answer your inquiries without such detailed infor-
mation.
With these thoughts in mind, we have attempted to offer some comments on your
inquiries using the information available to us.
Ques t i on 1
In the engineering study of the alternative plans, the Commission's consultants
employed standardized cost curves to determine capital and operation and main-
tenance costs for treatment plants. No cost breakdown for sludge handling is
available.
ITATI
-------
Mr. R. J. Schneider page 2 August 31, 1372
Identical sludge handling processes will be used at all of the treatment plants
included in Plans IB and II. This will include incineration, followed by drying
and temporary storage in ash lagoons, and ultimate deposit. Ann Arbor will mix
the ash with sanitary landfill cover material in its landfill. A definitive
site for ash disposal from the proposed Huron River Plant has not been selected,
although it most likely will also be landfilled.
This entire matter remains under study for possible change to a better method
such as cropland disposal of sludge or chemical jelling. Considerable latitude
remains available until the final engineering is completed.
Question 2
The matter of flows in the Huron River below Ann Arbor under Plan II is discussed
in the Environmental Assessment. It was pointed out that there is some existing
capability to supplement low flows through the use of the Barton, Argo, and Geddes
Impoundments. The Environmental Assessment concluded that the need for further
flow augmentation in the Lower Huron under Plan II has not been established. The
Water Resources Commission is unaware of any further information which would
warrant a change in this position. For your information, we are attaching a
recently received opinion from the Michigan Attorney General's Office which lends
support to this position.
Questions 3 and 4
It is our opinion that the discharge from the proposed Huron River Treatment Plant
under both Plans IB and II will have negligible, if any, effect upon the proposed
Pointe Mouillee Recreation Complex. The only exception to this is in the event of
serious treatment plant malfunction or failure. The probability of such a serious
malfunction or failure is unknown, but is considered to be remote.
It should be clearly understood that detailed engineering of the location and de-
sign of the outfall has not been done. Moreover, until a plan for the area is
finally selected and firm commitments secure, such detailed engineering cannot
prudently be undertaken. At this point in time, there is considerable latitude
regarding the location, length, design, and other characteristics of the outfall.
It is anticipated that comprehensive studies will be undertaken with due exami-
nation of flows, currents, etc., to locate and design an outfall structure which
will have absolute minimum environmental impact.
Question 5
General effects of constructing the interceptor system under both Plans IB and II
were outlined in the Environmental Assessment. The regional planning agency, the
Southeastern Michigan Council of Governments, made the determination that both
Plans IB and II conform to its comprehensive planning program and have subsequently
endorsed Plan II as the preferred alternative.
-------
Mr. R. J. Schneider page 3 August >1, 197?-
In regard to detail route locations for the interceptor, we have asked trre wayne
County Board of County Road Commissioners to forward directly to you ?uch reports
as are available on detailed route locations. Again in this instance, completion
of detailed plans are awaiting final action in the adoption of a regional plan.
It is anticipated that considerable effort will be directed at coordinating final
route determinations with interested park and other local officials so as to mini-
mize any environmental or other disturbances.
! hope these responses will assist you in your efforts.
Very truly yours,
WATER RESOURCES COMMISSION
Ralph W. Purdy '
Executive Secretary
RWP:JPD/jeh
Enclosure
-------
December 27, 1971
Mr. Jerome Maslowsk±
Assistant Attorney General
Seven Story Office Building
Lansing, Michigan 48926
Dear lix. Maslovskl:
Growing out of questions recently raised before the Water Resources Commission
relative to the discharge of wtstewater effluent into another watercourse tft\an the
water's source, tiie Cocnalssion has directed fee to seek your advice on just what
the Commission's legal position is in such matters.
As you know, in the current consideration of Official Plans for Southeastern
Michigan, required by the Federal EPA as a basis for Federal water pollution control
construction grants, the Conanisslon has favored a plan that would take Ann_Arbor'£
waatewater into an interceptor sewer outletting in Lake Erie, thus reducing the flow
of the Huron River, from Ann Arbor to Its mouth, by the volume that the city takes
froa the river for its municipal supply.
.. . , .,,.. ~ *-»_
Also, in another example, Packaging Corporation of America takes some 10 million
gallons per day from the upper end of Manistee Lake and discharges its wastewater
effluent by pipeline directly to Lake Michigan, thus reducing flow-through in Manistee
Lake and the Lover Hanlstee River by that much. This diversion is proceeding under
Stipulation with the Commission.
In the Ann Arbor case, opponents of the Commission's favored plan charge that
.the reduction in Huron River flow will seriously affect the river's downstream
usefulness. In the Manistee Lake case, no possible detriment to the lake or lower
river can be seen.
These two cases illustrate situations where discharge of properly treated effluent
to another watercourse can be desirable from the standpoint of effective water pollution
control. Although these situations are not numerous they still are not uncommon.
I have considered developing a set of specific questions to pose to you, but am
inclined to think you can conceive of the legal issues raised by these situations much
better than I can as a technician, if you are willing to approach it on that basis.
What the Commission needs to know is where it stands in issuing orders that either
specify another watercourse for discharge, or simply agree to it as an alternative
selected by the waste dlccharger in the face of a Commission Order that drastically
limits discharge to the source watercourse.
-------
Mr. Maslovski -2- December 27, 1971
If this request is too general, I shall try to develop a set of precise
questions.
Very truly yours,
WATER RESOURCES COMMISSION
Ralph V. Purely
Executive Secretary
RWP/NB:clp
-------
RECEIVED
STATE OF MICHIGAN
DEPARTMENT OF ATTORNEY GENERAL
WATER MANAGEMENT
LEON S. COHAN
Deputy Attorney General ^jSw^fe^y r f
^P*"ir*—-z^Ky - * '
FRANK J. KELLEY
ATTORNEY GENERAL
LANSING
48913
August 1, 1972
Ralph W. Purdy, Executive Secretary
Water Resources Commission
Stevens T. Mason Building, 8th Floor
Lansing, Michigan 48926
Dear Mr. Purdy:
By letter dated December 27, 1971, you have requested
advice from the Attorney General concerning orders of the
Water Resources Commission which limit discharges to a source
watercourse. Specifically, you mention opposition to a Pro-
posed Order of the Commission requiring discharge to Lake
Erie of water from Huron River which will affect the downstream
usefulness of that river and also you speak to ongoing diversions
of water by the Packaging Corporation of America which reduces
flow through Manistee Lake and the lower Manistee River and
which water will flow to Lake Michigan.
Initially it may be pointed out that the Michigan Supreme
Court has held that public or private riparian owners may, by
virtue of ownership of part of the shoreline, take and divert
water supplies as long as the withdrawal is reasonable and
does not injure other riparian owners. City of Battle Creek v.
•Goguac Resort Association (1914) 181 Mich 241. Thus in con-
sidering diversionary uses from a stream and the resulting
effect on the source watercourse, the crucial test in determining
lawfulness is whether the diversion constitutes a "reasonable
use."
•
In determining reasonableness of use, the courts, while looking
to the need for the purpose of the diversion, have, nevertheless,
up to this point in time placed the greater emphasis on the affect
of the diversion on downstream riparians and the gree of damage
sustained. In construing the reasonableness of a taking, the
Michigan Supreme Court has, however, held that a taking may be
reasonable even though the quantity of water remaining in the
watercourse is somewhat diminished. Kennedy v. Niles Water Supply
Company (1913) 173 Mich 474.
1-L
-------
Ralph W. Purdy
August 1, -1972
Page 2
In a related recent Pennsylvania case, Belin v. Department
of Environmental Resources, 4 ERC 1238, the Court considered the
effect of a State permit to discharge waters drawn from a source
watercourse as respects riparians on the receiving watercourse.
The Court concluded the State permit to be lawful in the absence
of convincing evidence that the riparians on the receiving water-
course would be injured thereby. In its opinion, the Pennsylvania
Court stated as follows:
"In summary, we hold that the Department is
empowered to issue permits allowing for the
discharge of waste waters in instances where
such discharge results from a diversion of
waters from one watershed to another. This
right is strictly qualified by the requirement
that all conditions and criteria of the statutes
and regulations be satisfied. The Department
did not abuse its discretion, nor did it commit
an error of law. The Adjudication and Order
of the Department is hereby affirmed."
The foregoing case is consistent with Michigan case law insofar
as the need to show damaging affect. In this regard the Commission,
however, should be aware of the possible application of Act 127,
PA 1970 (Michigan Environmental Protection Act) which does not
require allegations or proof of personal damage or injury.
In summary, you are advised that diversions by a riparian owner
under Commission order from a source watercourse may be considered
lawful in the absence of unreasonable diminution of downstream flow
which demonstrably injures lower riparians. It would appear that in
entering orders providing for diversions from source watercourses
and. for discharge into other waters that it is in the interest of
•the Commission to consider and insure that such orders will not cause
unreasonable downstream riparian injury and will not give rise to
adverse environmental affects.
ferv truly yours,
s?r
Jerome Maslowski
Assistant Attorney General
.JM/jp
-------
VI'-*- ,'].'• l~lv '4**.
FREDDIE G. 6UR1 ON
Si •[''•ar*
*AYNE G. RICE
D?putir Spcrrlrtrr
BOARD OF PUBLIC WORKS
Wayne County
7TH FLOOR CITY-COUNTY BLDG.
DETROIT, MICHIGAN 48226
September 5, 1972
JAMES M.
Managing Director
MITCHELL J. ZOLIK
JOHN P. C.USHMAN
frrnfrEil f-ounip|
JOSEPH N. HARTMANN
DirffUir of A '1m in I *"r il i
WALTER P. MEYERS
( oun tv H i yh v\ .u ! n i(i n '
GEORGE R. BINGMAM
Dirrrtor, !>!•«
ENVIRONMENTAL "RCV ACTION AGENCY
R r -- r '•••• 0
SF.P 8 1972
M.NG hK \v H
FILE NO
Mr. R.J. Schneider, Director
Air and Water Programs Division
U.S. Environmental Protection
Agency, Region V
1 North Wacker Drive
Chicago, Illinois 60606
Dear Mr. Schneider:
Re: Huron Valley Wastewater "
Control System l- (~
In response to the request of Mr. James Dooley of the Michigan Water Resources
Commission we have transmitted the following described documents to you under
separate cover.
1. "Hannan Road Arm of the Huron River Sanitary Interceptor System",
November, 1967.
2. "Huron Valley Wastewater Control System, Report on Regional Plan vs. Local
Plan!'February, 1971.
3. "Huron Valley Wastewater Control System, Report on Costs and Cost Allocation",
April, 1971.
4. "Report on Ann Arbor's Case Against SEMCOG Endorsement of Plan II, Huron
Valley Wastewater Control System", January, 1972.
Document No. 1 contains plans and profiles of the Hannan Road Arm (Main Arm)
and the North Arm (East Arm) referred to in the 'Water Quality Management
Phase I" report prepared for the Water Resources Commission in September, 1971.
Document No. 3 contains plans and profiles of the Huron River Interceptor (Huron
River Trunk), the Van Buren Arm (Van Buren Arm), and the Ann Arbor Arm
(Ypsilanti Arm), referred to in the Phase I report.
Documents 2 and 3 set forth Wayne County's position of full support of and commit-
ment to the regional wastewater management system proposed by the office, which
system is the model after which Plan II of the Phase I report was patterned.
A FUNCTION OF THE BOARD OF WAYNE COUNTY ROAD COMMISSIONERS
-------
Page 2
Board of PubHc Works
Mr. R.J. Schneider, Director
Air & Water Programs Div.
U.S. Environmental Protection
Agency, Region V
9-5-7Z
Re: Huron Valley Watstewater
Control System
Document No. 4 was prepared in rebuttal to the City of Ann Arbor's criticism of
Plan II. It contains Wayne County's estimates of the cost of adding tertiary treat-
ment to the Huron River Treatment. Plant, of the cost of including flow augment-
ation facilities on the project, and of the cost of including existing debt retirement
in the project, concluding that such costs would not be significant factors in a
project of this size and scope.
Regarding sludge disposal, this Department and the City of Detroit presently incin-
erate sludge and dispose of the ash on land. Since this is the current practice in
the area, it was used as the basis of estimating the cost of the Huron Plant.
However, this office is very actively investigating alternate means of sludge dis-
posal including land disposal of liquid sludge, heat treatment, chemical treatment
and processing for disposal as a dry soil conditioner. Any one of these methods
or a combination of them may be employed at the Huron Plant.
The design of the proposed plant outfall is of prime concern to this office. Our
investigations indicate that an outfall could be designed which would not only elim-
inate shoreline degradation, but could also conceivable disperse the plant effluent
into lake currents so that the residual nutrient resources in the effluent would be
utilized to promote the growth of controlled and harvestable crops of desireable
species of fish.
If we can be of further service to you in your deliberations on this subject, please
do not hesitate to call on us.
Very truly yours,
DEPARTMENT OF PUBLIC WORKS
COUNTY OF WAYNE
DUANE R. EGEI£A*JD, Chief Engineer
DREtrh
cc: Michigan Water Resources Comm.
Attn: James Dooley
-------
Report on
Ann Arbor's Case Against SEMCOG Endorsing "Plan II"
Huron Valley Wastewater Control System
1. Background
The SEMCOG has been deluged with correspondence, reports, "expert opinions"
etc. , ostensibly supporting the City of Ann Arbor's position that SEMCOG
should not concur in its staff's recommendation that Plan II of the Michigan Water
Resources Commission's report on Water Quality Management, be adopted as
the official plan for the Huron Valley area.
The documentation presented by Ann Arbor, while voluminous is largely repet-
itive. Nine specific arguments have been identified and responded to in the sum-
mary at the end of this report, but Ann Arbor's basic position can be capulized
in the following three statements:
Statement I
Ann Arbor contends that the cost of Plan II will be 39 million dollars
more than the cost of Plan IB (preferred by Ann Arbor).
Statement II
Ann Arbor contends that the quality of the Huron River will not be
improved by implementing Plan II.
Statement III
Ann Arbor contends that implementation of Plan II would, in effect,
close future options of local treatment if and when there are tech-
nological breakthroughs.
2. Discussion of Statement I
Ann Arbor claims that the Water Resources Commission did not take into con-
sideration the cost,s of certain items in arriving at its decision to adopt Plan II
as the official plan for the Huron River area. A discussion of each of these
items follows:
A. Tertiary Treatment
Ann Arbor contends that tertiary treatment is necessary at the Huron River
Plant In support of this contention Ann Arbor submits the personal opinion
of a planner employed by the Great Lakes Basin Commission, whose corn-
merits are typical of the other expert opinions solicited by Ann Arbor. In
his letter to Mayor Harris, this planner correctly identifies the problem
-------
of I,ake Erie as excessive phosphates, but recommends tertiary treatment
because "the plant design does not appear to include a high level of phos-
phate removal". The fact of the matter is that the total phosphate removal
will be exactly the same whether Plan II or Plan IB is implemented.
For comparison purposes, however, let us include tertiary treatment facil-
ities at the Huron Plant in the form of a mixed media filtering system.
According to recent bids received at the Warren Michigan Plant, the cost
of such facilities for a 121 MGD plant (Plan II) would be 6. 2 million dollars
and the cost for a 88 MGD plant (Plan IB) would be 4. 8 million dollars.
According to figure 8 of the Water Resources Commission report, it will
cost approximately 10% more for operation and maintenance of a tertiary
plant. These costs are included in tables B and C.
B. Flow Augmentation
Arm Arbor contends that taking the Ann Arbor Plant off the river may create
nuisance or hazardous conditions during periods of low flow in the river,
and that provisions must be made to augment flow during these periods.
While it is difficult to understand why the entire area should subsidize the
presumably already profitable Ann Arbor Water Supply System, again for
comparison purposes, let us include the cost of flow augmentation in the
project.
City Manager Guy C. Larcom, Jr. , has stated that all the city's attempts
to store water upstream from Ann Arbor have been unsuccessful and has
stated that it is impossible for a single city to secure such storage rights.
Since the city was motivated by economic gain we can understand the reluc-
tance of upstream communities to assist the city in this matter.
We are optimistic that an authority representing the entire area and moti-
vated by environmental concerns would have more success than the City
of Ann Arbor in making storage arrangements, but for the purpose of
establishing costs, let us assume that a new storage area must be con-
structed as described in the appendix of the Water Resources Commission
report. The qost of the alternate is estimated at 4.6 million dollars and is
included in Table B .
C. Retirement of Existing Treatment Facilities
While there is a question as to whether the new system should be respons-
ible for the payment of unretired debt on existing plants, it is recognized
that such debts represent an unusual burden on the communities whose
plants must be abandoned. Accordingly, this debt has been included in
the overall capital costs of the project shown on Table B.
-------
3
Prior to finalization of the Water Resources Commission report, the Wayne
County DPW advised the Water Resources Commission and its consultants
that the cost estimates contained certain discrepancies and request that these
errors be corrected.
The Water Resources Commission and the consultants acknowledged that these
discrepancies did occur in the report, but that due to tight time requirements,
the report could not be corrected. The Water Resources Commission argued
that while the changes were fairly large, thej affected all plans and would not
significantly change the cost differences between plans. It was also noted that
the cost of flow augmentation and existing debt retirement had not been included
in the cost tabulations and these costs would offset the errors.
The DPW accepted the Water Resources Commission's explanation and did not
dispute the cost figures contained in the report. However, since Ann Arbor is
now contesting the cost figures, the basic costs should be revised to reflect an
accurate estimate. The changes are detailed in the DPW letter to the Water
Resources Commission dated September 16, 1971 (copy attached) and are tabu-
lated in Table A.
3. Conclusions Concerning Statement I
Conclusion 1A. Tertiary Treatment
The need for tertiary treatment at plants discharging directly into Great Lakes
waters has never been substantiated, and it is evidently the position of state and
federal pollution control officials that such treatment is not necessary at this
point in time.
The City of Ann Arbor's "experts" on Lake Erie correctly identify the problem
of Lake Erie as phosphate enrichment but then seem to make the erroneous assump-
tion that tertiary treatment is required to remove the phosphates. The fact is,
that the same degree of phosphate removal is required under either Plan IB or
Plan II and that tertiary treatment would be of no value in reducing the phosphate
content of Lake Erie.
It should be obvious to anyone that tertiary treatment is better than secondary
treatment, and, for that matter, that quarternery treatment would be better than
tertiary treatment. The question is, will the benefits derived from tertiary treat-
ment warrant its extra cost or might that extra cost be better utilized by imple-
menting other programs such as physical removal of accumulated bottom deposits
or research in marine husbandry to develop aquatic food chains which would pro-
ductively assimilate the nutrients which are now unbalancing the natural marine
ecosyE'.ems. We submit that organizations such as the Wayne County Road
Commission, the City of Ann Arbor or SEMCOG are in no way qualified to make
such judgements and should not attempt to do so.
-------
of Lake Erie as excessive phosphates, but recommends tertiary treatment
because ''the plunt design does not appear to include a high It ye] of phc., ••
phate removal". The fact of the matter is that the total phosphate removaJ
will be exactly the same whether Plan II or Plan IB is implemented,
For comparison purposes, however, let us include tertiary treatment facil-
ities at the Huron Plant, in the form of a inixed media filtering system.
According to recent bids received at the Warren Michigan Plant, the cost
of such facilities for a 121 MGD plant (Plan II) would be 6.2 million dollars
and the cost for a 88 MGD plant (Plan IB) would be 4. 8 million dollars.
According to figure 8 of the Water Resources Commission report, it will
cost approximately ] 0% more for operation and maintenance of a tertiary
plant. These costs are included in tables B and C.
B. Flow Augmentation
Ann Arbor contends that taking the Ann Arbor Plant off the river may create
nuisance or hazardous conditions during periods of low flow in the river,
and that provisions must be made to augment flow during these periods.
While it is difficult to understand why the entire area should subsidize the
presumably already profitable Ann Arbor Water Supply System, again for
comparison purposes, let us include the cost of flow augmentation in the
project.
City Manager Guy C. Larcom, Jr. , has stated that all the city's attempts
to store water upstream from Ann Arbor have been unsuccessful and has
stated that it is impossible for a single city to secure such storage rights.
Since the city was motivated by economic gain we can understand the reluc-
tance of upstream communities to assist the city in this matter.
We are optimistic that an authority representing the entire area and moti-
vated by environmental concerns would have more success than the City
of Ann Arbor in making storage arrangements, but for the purpose of
establishing costs, let us assume that a new storage area must be con-
structed as described in the appendix of the Water Resources Commission
report. The post of the alternate is estimated at 4.6 million dollars and is
included in Table B .
C. Retirement of Existing Treatment Facilities
While there is a question as to whether the new system should be respons-
ible for the payment of unretired debt on existing plants, it is recognized
that such debts represent an unusual burden on the communities whose
plants must be abandoned. Accordingly, this debt has been included in
the overall capital costs of the project shown on Table B.
-------
- 3 -
Prior to finalization of the Water Resources Commission report, the Wayne
County DPW advised the "Water Resources Commission and its consultants
that the cost estimates contained certain discrepancies and request that these
errors be corrected.
The Water Resources Commission and the consultants acknowledged that these
discrepancies did occur in the report, but that due to tight time requirements,
the report, could not be corrected. The Water Resources Commission argued
that while the changes were fairly large, thej affected all plans and would not
significantly change the cost differences between plans. It was also noted that
the cost of flow augmentation and existing debt retirement had not been included
in the cost tabulations and these costs would offset the errors.
The DPW accepted the Water Resources Commission's explanation and did not
dispute the cost figures contained in the report. However, since Ann Arbor is
now contesting the cost figures, the basic costs should be revised to reflect an
accurate estimate. The changes are detailed in the DPW letter to the Water
Resources Commission dated September 16, 1971 (copy attached) and are tabu-
lated in Table A.
3. Conclusions Concerning Statement I
Conclusion 1A. Tertiary Treatment
The need for tertiary treatment at plants discharging directly into Great Lakes
waters has never been substantiated, and it is evidently the position of state and
federal pollution control officials that such treatment is not necessary at this
point in time.
The City of Ann Arbor's "experts" on Lake Erie correctly identify the problem
of Lake Erie as phosphate enrichment but then seem to make the erroneous assump-
tion that tertiary treatment is required to remove the phosphates. The fact is,
that the same degree of phosphate removal is required under either Plan IB or
Plan II and that tertiary treatment would be of no value in reducing the phosphate
content of Lake Erie.
It should be obvious to anyone that tertiary treatment is better than secondary
treatment, and, for that matter, that quarternery treatment would be better than
tertiary treatment. The question is, will the benefits derived from tertiary treat-
ment warrant its extra cost or might that extra cost be better utilized by imple-
menting other programs such as physical removal of accumulated bottom deposits
or research in marine husbandry to develop aquatic food chains which would pro-
ductively assimilate the nutrients which are now unbalancing the natural marine
ecosys ems. We submit that organizations such as the Wayne County Road
Commission, the City of Ann Arbor or SEMCOG are in no way qualified to make
such judgements and should not attempt to do so.
-------
-4-
Table A
Adjustments to Water Resources Commission Basic Capital Costs of Huron Valley
Wastewater Control System
(Figures in Millions of Dollars)
Plan IB
Huron Rive:
Ann Arbor
Total
Plan II
Huron River 160.83 -12.93 -15.89 -10.00 122.01
1. Adjustment changing Huron River Interceptor from tunnel to open cut
construction.
2. Adjustment changing all interceptors to 1990 design size.
3. Adjustment eliminating retention basins from interceptor cost.
Table B
WRC
Basic Cost
124.36
23.34
147.70
1
-10. 58
0
-10.58
2
-8.36
0
-8.36
3
-5.0
0
-5.0
Adjusted
Basic Cost
100.42
23.34
123.76
Additional Costs of Huron Valley Wastewater Control System as Suggested by
Ann Arbor
(Figures in Millions of Dollars)
Adjusted Tertiary Flow Debt Total
Basic Cost Treatment Aug. Retirement Cost
Plan IB
Huron River 100.42 +4.8 0 +0.75 105.97
Ann Arbor 23.34 0 23.34
Total 123.76 +4.8 0 +0.75 129.31
Plan II
Huron River 122.01 +6.2 +4.6 +2.22 135.03
-------
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-------
Conclusion IB. Cost Differences Between Plan II and IB
The difference -.n annual per capita costs between Plan IB and Plan II, (inc.! icbng
tertiary treatment, flow augmentation and debt retirement costs) favors Plan II
and became increasingly more favorable as time goes on. The difference in
capital costs between Pl?-,n IB and Plan II is so small that it is questionable as
to which plan will actually be more expensive. Accordingly, we can only reaffirm
our position that, "-the final decision to approve - Plan IB or Plan II - be based
solely on the long range ecological and environmental effect of that decision. "*
4. Discussion Concerning Statement No. 2
Ann Arbor's contention that the water quality of the Huron River will not be im-
proved by implementing Plan II is apparently based on a pilot plant study which
indicated "that water reaching Ann Arbor from upstream is more polluted than
water being discharged into the river by Ann Arbor's pilot tertiary treatment
plant".
Such a statement has little meaning unless qualified. Pollution can not be de-
fined in relative terms such as "more, " "equally" or "less" polluted, but rather
must be measured in terms of a growing list of parameters which make up the
overall pollution profile. Thus, even though water may not be "polluted" in
terms of biological oxygen demand or suspended solids, it could be grossly pol-
luted in terms of PCB, chromium or mercury.
5. Conclusion Concerning Statement No. 2
There is, of course, little, likelihood that the apparently very good performiince
of the tightly controlled and skillfully operated pilot plant will be duplicated on
full scale day to day operating conditions. An examination of any treatment
plant operation records will bear this out.
However, even if the full scale operation did produce a consistently high quality
effluent, there is the ever present danger of inadvertent plant bypassing. Wayne
County's position on this matter is summarized in the following two paragraphs
taken from the Road Commission's Resume' of Reports on Regional Plan vs.
Local Plan "and C6sts and Cost Allocation" (copy attached).
"It is pointed out that since there are no one hundred percent effective fail
safe means of guarding against factors such as human error, mechanical
failure, power disruption or natural phenomenon, all plants occasionally
discharge raw or partially treated wastes to the receiving stream, and
that even though such accidental discharges may be of infrequent occur-
rence or short duration, they c uld result in long range or possibly irre-
pairable damange to the ecology of the watershed. "
*Report on Regional Plan vs. Local Plan, 2-71.
-------
_ 7 -
"Projects involving river flow management, errosion control, chloride
control and improved storm sewer and street cleaning operations will be
important steps in the overall pollution abatement program, but it is em-
phasized that the most urgent need at this time is implementation of the
proposed "Huron Valley Wastewater Control System". This system, de-
signed to accommodate the domestic, commercial and industrial sanitary
wastewater disposal requirements of a residential population of 1,8Z7,000
persons, would export all "sanitary" and other "hard" wastes from the
watershed to one plant at the mouth of the river where treatment opera-
tions can be economically performed and effectively controlled. "
6. Discussion Concerning Statement No. 3
Ann Arbor contends that if Plan II is implemented, the option of constructing ad-
vanced treatment plants along the river in the future will no longer be available.
Future options will be effected regardless of which plan is implemented because
of the large financial committments which are involved, but the implementation
of Plan II will adually enhance the option of constructing local plants along the
river in the future, whereas implementation of Plan IB would probably forever
close out the option of constructing an interceptor system to serve the area.
In the preceding section, it was pointed out that the principal objection to local
plants is that accidental discharges could result in long range and possibly irre-
pairable ecological damage to the watershed. If, however, an interceptor were
available into which wastewater could be diverted in emergencies, it would be-
come entirely feasible to expand the system by constructing local treatment
facilities as improved treatment methods become available. On the other hand,
if Ann Arbor is permitted to continue to operate a plant on the Huron River, be-
cause of financial expediency, it is logical to assume that Oakland County and
Wayne County will request permission to build two new major plants on the
Huron River. When there are three major plants on the Huron River the total
capital investment in plant facilities will probably preclude any possibility of
implementing an interceptor system for the Huron Valley.
With the breakdown of the interceptor system plan, many more plants will be
constructed along fhe river. As more and more plants are constructed, acci-
dental discharges will increase and the river will deteriorate accordingly.
7. Conclusions Concerning Statement No. 3
We are at a point in time at which the future course of wastewater management
in the Huron Valley must be decided.
If Plan II is adopted all interceptor system and local treatment options will be
held open. If Plan II is not adopted it is unlikely that an interceptor system will
ever be installed, and local treatment plants will be constructed along the entire
-------
length of the river. Such a development would result in the accellerated dete-
rioration of the Huron River, ultimately destroying it as a recreational facility.
8. Summary
The City of Ann Arbor has criticized Plan II which has been approved and/or en-
dorsed by the Michigan Water Resources Commission, the Wayne County Board
of Commissioners, the Oakland County Department of Public Works and the staff
of the SEMCOG, to name only a few.
A. Ann Arbor's Position
Ann Arbor's criticism of Plan II is based on numerous contentions which are
listed as follows:
1. Plan II does not require tertiary treatment at the Huron River Plant.
In support of the contention, Ann Arbor presents the testimony of
"experts".
2. Plan II does not provide for flow augmentation of the Huron River to
make up for the water currently being discharged to the river from the
Ann Arbor Plant.
3. Plan II does not provide for full reimbursement of outstanding debts on
treatment facilities which must be abandoned under Plan II.
4. If the cost of the provisions of items 1, 2 & 3 (above) were included in
the cost estimates, the capital cost of Plan II (one plant plan) would be
$39, 000, 000 higher than for Plan IB (two plant plan) and the annual per
capita costs $3.63 (1975) to $2.28 (1990) more for Plan II than for
Plan IB.
5. There would be no environmental improvement experienced by abandon-
ing the Ann Arbor Treatment Plant because the river water reaching
Ann Arbor from upstream is more polluted than the water being dis-
charged into the river from Ann Arbor's pilot treatment plant.
Ann Arbor contends that its full scale plant will produce an effluent of
equal quality as that of the pilot plant.
6. One-plant systems are obsolete as is proven by the fact that Los Angeles
and San Antonio have gone to decentralized plant schemes.
7. Since the/Wayne County Road Commission supports Plan II, Wayne
County must be planning to set rates which will discriminate against
Oakland and Washtenaw Counties.
8. A decision to implement Plan II would have the effect of irrevocably
closing out the option of constructing local plants if and when techno-
logical breakthroughs make the perfect fail safe plant possible.
9. Ann Arbor contends that it is important that the SEMCOG staff's recom-
mendation be supported so that the staff's ability to influence environ-
mental decisions will not be undercut and so that the staff's reputation
among the smaller members, for seeking to have SEMCOG's power
exercised fairly will not be diminished.
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- 9 -
B. Wayne County's Response
The following are the responses of Wayne County to the positions taken by
Ann Arbor:
1. Wayne County does not consider itself, Ann Arbor, or SEMCOG quali-
fied to determine whether or not tertiary treatment should be required
at plants discharging directly to the Great Lakes Waters. A close re-
view of the "expert" opinions presented by Ann Arbor indicate that
these so-called experts have correctly identified the Lake Erie problem
as phosphate enrichment but seem to feel that tertiary treatment will
reduce the phosphates in plant effluents. This is an erroneous assump-
tion, the fact of the matter being that the exact same degree of phosphate
removal is required at all plants.
2. Flow augmentation was not included in the proposed project because it
was felt that flow augmentation was properly a function of the water sup-
ply operation which was causing the flow depletion. A properly managed
water supply system should be obligated to provide sufficient storage
to conduct its operations without interfering with critical flows in the
source of supply.
It would appear that the cost of flow augmentation has been somewhat
exaggerated by Ann Arbor, since the cost of providing additional stor-
age facilities was estimated in the Water Resources Commission report
at only $4, 600, 000.
3. Ann Arbor's contention that unretired debt on existing treatment facil-
ities which would be abandoned, should be paid for by the system has
some merit and would undoubtedly be given consideration by the pro-
posed authority.
4. If costs are to be challenged, the basic costs contained in the Water
Resources Commission report should be corrected to reflect the errors
and inconsistencies noted by the Wayne County Road Commission prior
to the release of the report.
If the basic costs are ^o corrected and the costs of tertiary treatment,
flow augmentation and debt retirement included in Plan II, the capital
cost of Plan II would be $5, 720, 000 more than for Plan IB, but the
annual pejr capita costs of Plan II would be $0. 05 (1975) and $0.21 (1990)
less than for Plan IB.
Since estimates could vary by 10% or more either way, costs should
not be a factor in the decision to impl3ment Plan II or Plan IB, partic-
ularly since normal controlled inflation is raising the cost of the project
at a rate of approximately 1. 5 million dollars per month.
5. Ann Arbor's claim that the day to day operations of a full scale plant
will produce an effluent equal to that of the pilot plant, and its conten-
tion that tertiary treated wastewater will be less polluted than the natu-
ral river water, must be seriously contested.
-------
A cursory review of airy treatment plant operating records will quicldy
disclose the logical ,"aot that average annual removal efficiencies are
well below the maximum efficiencies attained during the year, axici that
pilot plant performance is usually substantially better than tbat oc the
prototype counterpart.
The claim that pilot plant effluents are less polluted than tie natural
river water is based on comparisons of relatively few pollution param-
eters, and (to paraphrase the Anr- Arbor paper} is apparently -"bottomed
on a deep pessimissm about-" the effectiveness of surface runoff control
programs such as errcsion control and chloride control ordinances, and
improved storm sewer and street cleaning operations, " in improving
the quality of the ratural river water.
Pollution cannot be defined in terms of suspended solids, biochemical
oxygen demand, bacteriological counts, and phosphate removal, but
should be considered in relation to all of the numerous parameters
which make up the pollution profile.
A pollution profile has not been universally established, but the Corps
of Engineers has identified 65 such parameters and the proposed Wayne
County Sewer Use Regulation specifies over 30 parameters which should
be considered in defining pollution with the list growing as the environ-
mental effects of various elements and compounds are more fully under-
stood.
Of the pollution parameters currently identified in the proposed Wayne
County Regulations, over one-half will pass through the tertiary treat-
ment process unaffected. The potentially hazardous effect of these
parameters, which include mercury chromium and lead, can be count-
ered only by dilution in the sewage itself or in the receiving waters.
It should be apparent that Plan II, which would treat 121, 000, 000 gallons
of wastewater a day and discharge the treated effluent into a body of
water flowing at a minimum rate of 100, 000, 000, 000 gallons per day
(1:830 dilution) will be infinitely better able to cope with these problems
than could Plan IB, under which the Ann Arbor Plant would treat
33, 000, 00,0 gallons of wastewater per day and discharge into a body of
water flowing at a minimum rate of 50, 000, 000 gallons per day (1:1. 5
dilution).
Wayne County's basic concern, however, is for the fate of the river
after those inevitable periods when due to human error, mechanical
failure, power disruptions or natural phenomenon, the plant inadver-
tently or by necessity discharges raw or partially treated wastes to
the river. Such discharges will probably be of infrequent occurrence
and short duration but because of the low dilution factor, their effect
-------
- 13 -
or; the ecology of the river could be extremely long range arid possibly
irrepairable.
The question that must be asked is why should such chances be taken
if a reasonable alternate solution is available?
To compare the wastewater disposal problems of Los Angeles with
its normally dry riverbeds and where ocean disposal, with the compli-
cation of reversing tides is involved, or of San Antonio which is not
located on a major watercourse and where there is a critical water
shortage, with the wastewater disposal problems of Southeast Michigan
is unrealistic and any meaningful conclusions could not possibly be
drawn from such comparisons.
The apparent fear that Ann Arbor will be discriminated against by Wayne
County in the establishment of rates can have no rational basis. The
Board of Wayne County Commissioners has gone on record that it sup-
ports a Regional System managed by a board composed of representatives
of Wayne, Oakland and Washtenaw Counties. It seems highly improb-
able that such a board would establish discriminatory rates. It should
also be recognized that since the State and Federal Governments will
be providing 75 to 80% of the capital cost of the project they could have
a strong influence on how the balance of the cost will be distributed.
Contrary to Ann Arbor's contention that implementation of Plan II would
close out future options of treating wastewater at diversified local facil-
ities, implementation of Plan II will, in fact, keep that option open.
An interceptor connecting local treatment facilities would provide the
fail safe mechanism which is necessary if such a system of wastewater
management is ever to be feasible.
Failure to adopt Plan II, on the other hand, would result in the construc-
tion of two new major plants on the Huron River, one in Oakland County
and one in Wayne County. This would be the financially expedient
solution to Oakland and Wayne Counties' sewerage problems, because
the construction of the plants could be deferred until existing treatment
capacities are fully utilized and until populations have increased so as
to provide a better financing base. The additional capital investments
and compounded problems of reorganization and relocation of personnel
would then provide the reasons to further delay, or more likely, to com-
pletely abandon any interceptor plan.
It can be predicted, therefore, that the practical effect of failure to
adopt Plan II as the official area plan at this time will be a prolifera-
tion of treatment plants along the Huron River and the rapid deterior-
ation of the river as a recreational facility.
We quite agree that the SEMCOG staff's recommendation to adopt Plan II
should be supported. As stated in item 2, however, we must seriously
question the technical qualification of the staff to make judgements re-
garding the specific degrees of treatment necessary at the Huron Plant
or at any other plant.
3rd draft 1-1Z-72
DRE/rh
-------
Septetrier 16 1971
an Y.'ater I-iccourccs Commisokm
£tcveu3 T. Mason B
Attention: Mr. William Marks Planning Division
Gentle me a:
We have reviewed the draft of the report o£.the consultants to the Commission,
and banco upon th«s report aad discussions at recent meetings have the
comment:
1. It is recognised that the assignment to the cou3uis.ar.t3 v;a3 to
data and analyses which would males il possible to compare en
interceptor ochcrno with a plan previously cubmkicd by the City oi
•Ana -Arbor for trcalmsnt plant c-rpA^sion to the yor.r 19*50, Coascquen'.l*/,
tiie interceptors are c^njiuned for thafc population aad flow, excoct for
some tunnci desi^r^d soy 2020. A3 a practical matter would noi ha
deoi^ced for a 15 year load a.nd iir-anc-ici over a 25 year period. We have
x-eviseu come of the data to reflect the. interceptors as &ll being &i::c;cl for
1990, tor purposes of comparison crtljr.
Plan
I B Kui'on Hiver
Systeai
Ana Arbor
Total 139.34 104.50 34.84 11.56 7.91
Project
Cost
116. 00
23.34
.75?;
87. CO
17.50
JiSft
29.0
5.84
1975 Coat
Per Capita
12. &9
9.21
1990 Cost
T^V. *• /""* rv « ' *. j^
1C* -v. Ct J - v (J
8.13
7.26
IX Huron River
Syatcra 144.94 1C3.70 36.24 10.60 7,15
2. We understand that in order to submit o.a aceepl£>,ble treat cncat plant
it was necessary to provide retention bars in facilities at both Ypsilanti and
Ana Arbo? Trcat.-icnt Plants, eatirviated to cost 5 i-.Iillion Dollars each.
This cooi v;as reflected and charged to the interceptor project v-hich wo
feel is not rsaliatic in that thio would either be a part of the local cystai-n
"" expense or could be provided for in the interceptor capacity allocation.
-------
\Ve have therefore cosn'v«teci an allocation of cost for the interceptor system
•without retention, brains.
Project 1975 Ccs5 1990 Cost
Plan Con* T\ 2. '* Pcr^nit
12 Keren fcivsr \v/o Rot. lo* -102.20 33.74 10 6. £3
Easias
3. V»~e fec-l that too inJc.rccplbr ccass bsf.veen French Land Ing arid the rcouili cf
the rivc-i arc iilga. Ihs estimate includes extensive amounts o* tuan^S .
construction ~.va;ch v/c issci may not be ncceseazry aiid which v/ooic! repr
extra cocfc o* vviU o/ca- 10 Million
The in'orniatioa set fovth above io not iiitencsd to nuggast fhiv the ti4eiiriai<;d induced
in tho rcrort; be changed but arc only aiontio^ed to ia-dicata that tlilicrcnces in
conatruciioji cosio ox' this nx-a^-iiSijcIc havo very li:tlo euect cu the overall per capita coat,
and tkii. li-.-3 opwr^Uor. aad u»iiiuia«arico cost v.hica v/iil tcr^Liue i:ito the iv.lare afc a
dccUuhi;! ii.?.o havo a :.-so*e si^isiiicaat effect oa the psr capita cooi.
As soou as tlio ofiicial pl&a hao received ail iieccaoavy appi-O'.'Ciis ccziStrtiction
be echccii'ied fc-r tlju c-iriic:ji pur.aiblc viatc, b-wcausc of ihs cc«"';i;udn^ ri-c i»i llis
co.Ti3ti-r.i.:tion cc-^tt, Vho J-zi/jiaoc-ring iScvvs iiccorci isccx chowo a niai-tlis* SO'/v. ju:np
Irom .Vlai-ch c*" i';?0 to Jiij;e a 19 VI ior L'aa Petrol: Area.
V.'e lool; forward to tho Cor.ir^i^oioa meeting set /or i'epicrcbor 23*cl and 2'Ith and
toward ths coiiiiica tj iAt:c.c &il;"icult, perpio;;ia^ ar^d tficpcnc..vc co.'i;*i--ci'to.£ioac.
Very trxtly >x>urs,
' DSPARTJ.-S'WT OF PUBLIC Y/ORKS
COUUTV or \,A7:;i;
i: K. E2i;Gii,i:.l. Director
cc: Mr. Furdy, \Vater .Resources Co:nm.
Mr. Zoiik, V'"3.y£2 County I\d. Com:».
Mac Nanjce Porter anc! Seeley
HLbbel Ivoih €-.nci Clark
-------
HUPvGl-1 VALLEY WASTEWATER CONTROL SYSTEM
Resume1 of Reports
on
"Regional Plan vs. Local Plan"
and
"Costs and Cost Allocation"
Because of concern over the increasing pollution of the Huron River, the
Board of Commissioners of Wayne County has vigorously opposed expansion of
treatment plants at Ann Arbor and Ypsilanti in Washtenaw County.
These reports^composed of 145 pages of text, charts, graphs and plans,
were prepared by the Waste Control Division of the Wayne County Road Commission
to support the Commissioners' position and to set forth a feasible plan for the
immediate implementation of a Regional System which is generally acknowledged
to be the ultimate solution to the problem.
The reports express doubt as to the ability of the proposed Ann Arbor and
Ypsilanti treatment facilities to render effluents of high enough quality to permit
swimming downstream from the plants, which is the official goal established by
the State Water Resources Commission.
It is pointed out that since there are no one hundred percent effective fail
safe means of guarding against factors such as human error, mechanical failure,
power disruption or natural phenomenon, all plants occasionally discharge raw
or untreated wastes to the receiving stream, and that even though such accidental
discharges may be of infrequent occurrence or short duration^ they could result
in long range or possibly irrepairable damage to the ecology of the watershed.
Projects involving river flow management, errosion control, chloride con-
trol and improved storm sewer and street cleaning operations will be important
steps in the overall pollution abatement program, but it is emphasized that the
most urgent need at this time is implementation of the proposed "Huron Valley
Wastewater Control System". This system, designed to accommodate the domes-
tic, commercial and industrial sanitary wastewater disposal requirements of a
residential population of 1,827,000 persons, would export all "sanitary" and
other "hard" wastes from the watershed to one plant at the mouth of the river where
treatment operations can be economically performed and effectively controlled.
The effluent from the plant would be carefully dispersed into Lake Erie at
selected points where normal fluctuations in effluent quality will not have the cri-
tical ecological effects that such fluctuation would have on the relatively low flow
of the river.
The facilities of the proposed System include a 130 million gallons per day
treatment plant and 100 miles of sanitary sewers ranging in size from 11 feet
six inches to 10 inches in diameter.
-------
Ily^on Valley "Wastewater Control System
Resume1 of Reports (continued)
The capital cost of the project is estimated at $134, 000, 000 and the initial
cost of operation is estimated at $65.40 per million gallons of wastewater treated.
Assuming that Federal and State grants will finance 80% of the capital cost and
that the balance will be paid off in equal annual payment at a 5. 5% interest rate,
the monthly cost to an average family would be as follows:
Cost per Family per Month
County
Year
Capital Cost
Op. Cost
Total Cost
Oakland
1972
$0.45
0.60
1.05
2022
$0.16
0.38
0.54
Washtenaw
1972
$0,53
0.'60
1. 13
2022
$0. 15
0.38
0.53
Wayne
1972
$1.75
0.60
2.35
2022
$0. 18
0.38
0.56
The total capital cost of the Regional System will be considerably less than
the total capital cost of several sub-systems providing equivalent capacity, although
in certain instances the capital cost of the Regional System could be higher than the
capital cost of a sub-system. In all cases, however, the lower operating costs of
the larger Regional System will offset any capital cost difference so that the total
cost over a period of years will always be less for the Regional System.
The reports conclude with recommendation that: 1. , Federal and State pol-
lution control funds should be used in such a way as to discourage local plant expan-
sions and encourage a Regional Plan System; 2. , The Regional System should be
managed by a Regional Board composed of representative of Wayne, Oakland and
Macomb Counties; 3., The Boards of Public Works of the three counties should be
authorized to proceed with negotiations for capacities and allocations in the system;
and 4. , The Board of Public Works of Wayne County should be designated as the
coordinating agency for the overall project.
DRE/rh 5-7-71
R-2
-------
CITY OF ANN ARBOR MICHIGAN
OFFICE OF THE MAYOR
October 31, 1972
Mr. R. J. Schneider, Director
Air and Water Division
Environmental Protection Agency
Region V
1 Wacker Drive
Chicago, Illinois 60606
Dear Mr. Schneider:
In recent correspondence with the Michigan Water
Resources Commission concerning the proposed plan for
treatment of sewage in the Huron River Basin in southeast
Michigan, the statement was made that there is new data
"which present a more optimistic picture regarding en-
hancement of water quality in Lake Erie through phosphorus
control programs." I wrote Chairman Woodford of the
Michigan Water Resources Commission to learn what that
new data might be and received a response from Assistant
Division Chief Turney dated September 28, which I attach.
I have asked Professor Bulkley at the University of
Michigan School of Natural Resources to comment on the
letter of September 28, and I attach his letter of
October 16.
I forward both pieces of information to you to be taken
into account in the preparation of the Environmental
Impact Statement concerning this project.
Sincerely yours,
Robert J. Harris, Mayor
RJHmp
Enclosures
RESEARCH
CENTER
O F
THE
M
D W E S T
-------
STATE OF MI
NATURAL RESOURCES COMMISSION WATER RESOURCES COMMISSION
HARBY H WHITEL.EY / P""""A, > JOHN ?' W°OaFORD
Chairman
CARL T. JOHNSON ^r-i-^ ALVINR BALDEN
V ice ChTirman
£ M LAITALA WILLIAM G. MILLIKEN, Governor ' CHARLES D HARRIS
DEPARTMENT OF NATUR AL RESOURCES
CHARLES c, YOUNGLOVE STEVENS T. MASON BUI LDING, LANSING, MICHIGAN 48926 STANLEY QUACKENBUSH
RALPH A. MAC MULLAN, Director THOMAS F JAMES
JOHN H. KITCHEL, M.D.
September 28, 1972
Mayor Robert J. Harris /
City of Ann Arbor
100 H. 5th Street
Ann Arbor, Michigan 48108
Dear Mayor Harris:
Chairman John Woodford has asked that we respond to your August 29, 1972
letter requesting clarification on new data "which present a more optimistic
picture regarding enhancement of water quality in Lake Erie through phosphorus
control programs".
The new data to which Mr. Woodford's letter refers consists of studies conducted
primarily by the Canadian Centre for Inland Waters and which form the basis for
the new international agreement. Scientists and officials concerned with water
pollution control in the Great Lakes area now believe that phosphorus control
programs presently in effect will result in Lake Erie imput reductions; from
point sources, below the 12,000 tons/year level during 1972 and a further decline
to about 3,000 tons/year by 1975. The studies indicate that when point sources
are below 12,000 tons/year the lake will be relieved of the threat of anoxic
conditions and the recycling of nutrients from the sediment bank.
There will still remain a non-point source imput to Lake Erie of some 12,000
tons/year, 60% of which will be from land drainage sources. The non-point source
discharges would then be about 4 times the municipal loading. Control over this
comparatively much larger source will be of greater import to Lake Erie than
striving for a 95% removal rate rather than a 90% rate at sewage treatment plants.
It is the recognition of the non-point source loading and a general interest in
developing programs to attack this problem that makes us and others optimistic
that something can and will be done in this area to the relief of point source
dischargers.
-------
Mr. Robert J. Harris
September 28, 1972
Page 2
Legislation such as Michigan's proposed House Bill 4709 authorizing land use
control has been enacted or is under consideration in most of the Lake Erie
states and should aid in reducing the total discharge below the 11,000 tons/
year, still considered to be the level at which nuisance growths of algae and
weeds are expected to subside.
Very truly yours,
WATER RESOURCES COMMISSION
Uilliam G. Turn
-------
X*
X
SCHOOL OF NATURAL RESOURCES
104.'' Natural Res.'-urcLS Bii'ldmt;
Ann Arbor, Michigan 48104
VH 7^4-1404
UNIVERSITY OF MICHIGAN
October 16, 1972
Mayor Robert J. Harris
City of Ann Arbor
100 North 5th Street
Ann Arbor, MI 48108
Dear Mayor Harris:
Thank you very much for forwarding a copy of the recent letter
which you received from the Water Resources Commission. I gather that
the WRC is attempting to justify a 90% phosphate removal at certain
point sources in place of the more strigent 95% removal level.
The following conclusion is useful to this issue:
Phosphorus input to Lake Erie must be reduced immediately; if this is
done, a quick improvement in the condition of the lake can be expected;
if it is not done, the rate of deterioration of the lake will be much
greater than it has been in recent years.•*•
In order to achieve the objective of immediate reduction of phosphate
input into Lake Erie, one may envision several alternatives. One is
to ban phosphate detergents; another is to provide for high order
phosphate removal at points where such removal is feasible - i.e. at
point source locations. There is general agreement that the increase
in point service discharges of phosphate is the primary factor which
has contributed algae blows and subsequent severe oxygen depletion in
Lake Erie during the critical summer months.
The Project Hypo Report indicates that while the percentage of
phosphate loadings from non-point sources has probably increased over
time, the pattern of this percentage increase and the pattern of in-
crease of non-municipal sources is not yet absolutely known.^ Given
1. "Project Hypo - An Intensive Study of the Lake Erie Central Basin.
Hypolimnion and Related Surface Water Phenomena," Canada Center
for Inland Waters, Paper #6, U.S. Environmental Protection Agency,
TR TS-05-71-208-24, February 1972.
2. Project Hypo Report (Previous Citation), p. 144.
-------
Mayor Robert J. Harris Page 2 October 16, 1972
the lack of data upon these non-point contributions, it is commendable
that the state is taking action to reduce these loadings. However, in
my view, the uncertainties which exist regarding these sources do not
justify the policy of 90% removal of phosphates from municipal sources.
Rather, the critical condition of Lake Erie as documented in the joint
U.S. -Canada Project Hypo demonstrates the necessity for removal of
phosphates at the 95% level. If future research clearly establishes
that lesser removal rates for point sources can be tolerated, then the
95% removal policy could be relaxed. This action would result in a
reduction in operating costs in the future. For the presant, it is my
view that the immediate objective is to implement decisive removal
processes at point sources at the 95% level in order to minimize the
probability of Lake Erie reaching complete anoxic conditions during
the critical months of August and September.
If I can provide further information, please let me know.
Very truly yours,
^Jonathan W. Bulkley
Associate Professor
S/S.
1
r U. S. GOVERNMENT PRINTING OFFICE • 1973 752 943 REG 5
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