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The assumption that present rates [for treatment at the
Detroit plant] will remain the same is questionable, given
the current litigation surrounding operation of the Detroit
Water Board. The essence of the litigation suggests that
higher charges will result; however that action is disposed
of in court.
In contrast, the former Director of the Wayne County DPW (T2)
indicated:
... if and when the Detroit Waste Water Treatment Plant
becomes an effectively operated facility, their service
charges in the Rouge Valley District will probably be
somewhat lower than those from the Huron Valley System.
Response; It is difficult to speculate about the future cost of
treatment at the Detroit WWTP. It is agreed that the cost will
continue to increase relative to the cost of service in 1979. Because
of the massive size of the Detroit plant (1,050 mgd), however, the cost
of treatment should be considerably less on a unit basis than for
treatment at a 22 mgd or 49 mgd Huron Valley WWTP (there are
significant economies of scale attained by increasing the size of a
WWTP).
Issue 5; Concern has been expressed (16,50,56,69) that the
availability of interceptor sewer capacity proposed in Alternative A-l
would result in the discontinuation of use of capacity owned in the
RVSDD by project area communities. The Detroit Water and Sewerage
Department (DWSD; 16) stated its objection to any decrease in the flows
entering the Detroit system via the Rouge Valley Interceptor. The DWSD
contends that the decrease in flows would result in a loss in revenues
and would create "financial problems in implementing its federally
mandated programs." The DWSD speculated that such action may force an
increase in user fees to the remaining customers.
Response; Part of the intent behind the previous selection of
Alternative D by USEPA was to ensure the continued maximum utilization
of existing regional interceptor sewers (the Middle Rouge, Lower Rouge,
and Downriver Interceptors). This, it was felt, would provide the most
efficient use of existing systems and would avoid the spending of
public money to provide duplicate capacity. The facilities planning
required for the central and northern sections of the project area (see
Section 5.O.), especially the study of the RVSDD, will consider other
potential uses of the capacity in the Rouge Valley interceptor system.
The effects to the Detroit system will continue to be considered
throughout the planning process.
Issue 6; A number of those commenting (16,27,28,56,69) believe
that the urbanization of the project area that would be stimulated by
the availability of interceptor sewer capacity would represent a
duplication of urban infrastructure capacity. The underutilization of
the existing urban service capacity in the Detroit urban area and the
subsequent loss of revenues could result in an inability to retire
existing debt on newer investments in these areas. The DWSD (16)
requested that the assumption of debt retirement on newer Detroit
6-22
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Interceptor and collection sewers should be considered as a cost of
implementing a regional system in the project area. Another (56) re-
quested that the amount of money that could be saved by not developing
the outlying project area and instead utilizing to the maximum extent
the existing systems be considered (i.e., what is the actual loss to
Detroit and the inner suburbs from outmigration to the project area?).
The DWSD also objected to the possibility of general obligation bonds
being used by Wayne County to finance the Huron Valley project. It
fears that if communities default in the repayment of their share of
the construction bonds that all Wayne County residents would have to
pay, resulting in double-jeopardy for Detroit residents. Somewhat in
contrast, the City of Novi has indicated (41) that its planning for
public services investments depends on steady growth and that without
regional interceptor service it cannot grow.
Response; The secondary impacts from the implementation of
Alternative A-l, including the stimulation of outmigration and the
duplication of urban infrastructure, were identified and discussed in
detail in Section 6.3. of the Draft EIS. Section 3.1.1. of the Draft
EIS also discussed the existing trend of outmigration from the Detroit
urban-core to the outlying parts of Wayne County. It was assumed in
the Draft EIS that provision of ample wastewater system capacity in the
project area would serve to support this trend and even to stimulate
the rate of outmigration. The relative amount of the outmigrating
population that would be attracted to the project area because of the
urban development associated with Alternative A-l cannot be determined.
Therefore, a specific economic analysis of the costs of such
outmigration is not feasible. It is acknowledged, however, that a
significant cost undoubtedly will exist. It also is conceivable,
however, that trends such as rapidly rising transportation costs and
the revitalization of downtown Detroit could alter the tendency for
outmigration and result in an increased demand for existing urban
services. These considerations are extremely difficult to project. An
effort by the communities in the southeastern Michigan region to
support and enforce the principles contained in the adopted SEMCOG Land
Use Policy is essential to the management of this problem.
Specifically, communities should enact land use controls in accordance
with the following SEMCOG policy statement:
Intensive residential development should take place in areas
presently served by public facilities with available excess
capacity before such development takes place in areas where
the construction of new facilities or the extension of
existing ones would be required or would be unduly costly.
Without adherence to such a policy, the fiscal impact resulting from
the duplication of existing services in new growth areas will be severe
to both those investing in new services and those left to pay for the
underutilized systems.
The concern that Wayne County residents may someday be responsible
for the retirement of debt for the Huron Valley system appears to have
little basis. The "double-jeopardy" that the DWSD suggested might
occur does not appear to be legally feasible. The concern by Novi that
it must continue to grow to maintain sound public investment planning
6-23
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is not entirely supportable. Novi already has invested in new public
facilities that are sized to accommodate and even attract new growth.
While this may be a necessary practice in high growth areas, it can
work in opposition to the established regional growth plan discussed
above. At the same time, however, Novi would have no way to cope with
growth already induced by the transportation system and other amenities
if it did not implement a progressive capital development plan for new
public services. In summary, it would be possible for Novi to continue
to exist as a viable community without significant additional growth
and despite its present state of indebtedness for new services.
Issue 7: Concern has been expressed (8,41) that the implemen-
tation of a regional WWTP also will result in significant induced
growth in Monroe County.
Response; Secondary impacts were discussed in Section 6.3. of the
Draft EIS. The potential for induced growth was considered exten-
sively. Section 6.4.3. dealt with the minimization of secondary
impacts. Although the situation in Monroe County was not addressed
directly, the discussion was intended to include areas adjacent to the
Huron Valley project area.
Issue 8; Several communities, the Wayne County DPW, and others
(12,15,18,30,33,34,42,43,48,51,75) observed that they could obtain
cheaper service by Alternative A-l than Alternative D.
Response; The economies of scale in operating a large system
would result in a lower unit operating cost than for operating a
smaller system (see response to Issue 4 in this section). The total
cost-effectiveness of the various systems must be considered, however,
and the cost vs. benefit to society as a whole compared. A larger
system, if it provides surplus capacity and results in secondary
impacts, may not be as cost-effective overall as a smaller system that
would avoid these problems. Alternative F, if implemented only for the
southern section of the project, would result in higher costs to the
user than would Alternative A-l but would result in one-third the
capital cost ($71 million compared to $207 million). A great deal of
alternative social benefits would be affordable with the difference.
Issue 9; The Sumpter Township Board (34) submitted a resolution
opposing Alternative D that stated in part:
Sumpter is an economically poor community which desperately
needs sanitary sewers for health reasons and for economic
development to provide job opportunities for its citizens.
The Board also indicated that the Increased cost of Alternative D
relative to Alternative A-l was too high for them to afford.
Response; The economic condition of Sumpter Township was identi-
fied and discussed in various sections of the Draft EIS. The high cost
of local collection sewers contained in the Sumpter Township Facilities
Plan combined with the cost of joining a regional system will have a
severe impact on residents of the service area. The Township Board
should investigate the availability of supplemental funding through the
6-24
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Farmers Home Administration, the Economic Development Administration,
and similar sources to assist in the financing of such facilities. The
availability of wastewater service and publLc water supply may
stimulate economic development in Sumpter Township, expanding the tax
base, providing jobs, and otherwise overcoming existing problems;
however, the large investments necessary do not necessarily guarantee
such an outcome.
Issue 10; The SEMCOG staff review of the Draft EIS (41) mentioned
the question of the economic value of contracts for capacity in the
RVSDD.
Response; It was assumed for purposes of analysis in the Draft
EIS that communities presently owning capacity in the RVSDD would
respond in an "ideal" manner and that capacities would be reallocated
based on the most efficient use of resources. Under this assumption,
communities would sell capacities for exactly what it would cost them
to purchase an equivalent amount of capacity in a new system. The un-
certainty about the future cost for new wastewater system capacity that
will exist until system design is completed, the potential lower
treatment costs at the Detroit WWTP than at the proposed Huron Valley
WWTP, and the possibility that capacities in a new system may be
constrained to limit the potential for secondary growth-related
impacts, prevent the establishment of a valid value for existing
interceptor capacity. The ultimate selling price for capacity in the
Rouge Valley interceptors undoubtedly will be established through
intercommunity negotations.
Issue 11; The City of Trenton (41) has objected to the fact that
cost estimates for regional wastewater systems contained in the Draft
EIS have not included reimbursement to Trenton for the abondonment of
its operable treatment works.
Response; The cost of abandonment was not included as a system
cost because there is no indication that anyone other than the City of
Trenton will bear this cost. The MDNR was contacted during the
preparation of the Draft EIS regarding allocations from the State fund
governed by Section 3. (5) of Michigan Act 329 (Public Acts of 1966, as
amended). The MDNR indicated that because of the age of the
facilities, the application of the established depreciation formula
indicated that no funds could be allocated from the fund for the
abandonment of the Trenton WWTP. No plan has been proposed by the
Wayne County DPW or by the City of Trenton for any alternative
mechanism to provide for the reimbursement of the public investment in
the WWTP.
Issue 12; One of the most frequently stated criticisms by the
participating communities was that Alternative D is not implementable
(1,2,4,9,11,12,15,18,22,23,29,30,33,34,40,41,43,47,48,75). The reasons
that were stated include:
• The disagreement with the population projections on which
interceptor capacity allocations were based (see Section
6.2.1.)
6-25
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• The unwillingness of Canton Township, Van Buren Township,
and other communities to relinquish their capacities in
the Middle Rouge and Downriver Interceptors (6,9,11,14,
18,22, 23,40,41,43,47,59,62,Tl)
• That Belleville is not interested in participating in any
new system (1,23,43,51,59,62)
• The inability to depend on septic systems to serve some
of the needs in Wayne County and in Oakland County (7,20,
21,26)
• The impracticality/undesirability of expanding the Walled
Lake WWTP (especially when SEMCOG policy recommends
against it; see Section 6.1.1.).
Response; USEPA has acknowledged these constraints and has deve-
loped Alternative F as a more workable solution to the needs of the
project area (see Section 5.1.).
Issue 13: The implications of the selection of an unimplementable
alternative by USEPA are of significant concern. The MDNR has urged
adoption of a system so that the unlawful discharges of wastewater can
be eliminated (19,32). Several of the WWTPs have been cited for permit
violation and the MDNR is threatening to impose new sewer hook-up bans
(12,33).
Response; The imposition of sewer-bans by the MDNR because of the
absence of new wastewater facilities would have a significant economic
impact on communities. USEPA has proposed Alternative F as a mechanism
to implement design work for the southern section of the project area
while allowing further study of the remaining area. This would allow
new wastewater facilities to be available at the earliest possible
time.
Issue 14; The appropriateness and/or legality of proposing new
system alternatives through the EIS process was questioned by several
individuals and agencies (61,62,T1). USEPA's action in selecting an
"in-house" alternative was seen as "bypassing" the grantee's role in
conducting facilities planning.
Response; The National Environmental Policy Act of 1969 (NEPA)
(P.L. 91-190) does not, by itself, provide specific guidance on how
EIS's are to be prepared but it does clearly indicate that EIS's are to
take a broad perspective in examining proposed Federal actions.
Section 102(2)(A) stresses "the integrated use of the natural and
social sciences and the environmental design acts in planning and in
decislonmaking." The specific requirement for EIS's in Section 102(2)
(C) clearly requires the evaluation of "alternatives to the proposed
action." Additionally, 102(2)(B) further states that the "Federal
Government shall study, develop, and describe appropriate alternatives
to recommended courses of action..."
The Council on Environmental Quality (CEQ) published guidelines
for preparing EIS's in the August 1, 1973, Federal Register (40 CFR
1500) which provide additional guidance, and serve as the basis for
6-26
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USEPA's NEPA regulations (40 CFR 6). Section 1520.8(2) (4) requires EIS's
to discuss alternatives to the proposed action, even to the extent that
alternatives "not within the existing authority of the responsible
agency" must not be excluded. Section 1500.8(a)(3)(ii) further
requires an analysis of secondary consequences of the proposed action,
especially those that "stimulate or induce secondary effects in the
form of associated investments and changed patterns of social and
economic activities."
USEPA's EIS regulations also indicate that an EIS must include "a
discussion of how socioeconomic activities and land use changes related
to the proposed action conform or conflict" with other plans for the
area. Section 6.304(b) requires USEPA to "develop, describe, and
objectively weigh feasible alternatives to any proposed action." NEPA
case law is replete with instances where agencies have been success-
fully challenged for failure to adequately consider Alternatives. See
e.g. Calvert Cliffs' Coordinating Committee v. NRG, 449 F.2d 1109
(D.C.Cir., 1971), NRDC v. Morton, 337 F. Supp. 165 (D.D.C., 1971),
Environmental Defense Fund v. Corps of Engineers, 331 F. Supp. 925
(D.D.C. 1971). An excellent source for further information regarding
judicial interpretations of NEPA is NEPA in the Courts by Frederick R.
Anderson (Resources for the Future, Inc., 1973).
Issue 15; The institutional capability of the proposed regional
system management agency, the Wayne County DPW, was questioned. There
is general concern for the potential for mismanagement, as perceived to
be the case with the Detroit system by a number of individuals
(32,27,12). Fear was expressed that the outmigration of population
from the Detroit area to the suburbs would enhance the Wayne County
government's power base—that "super sewer" is a self-serving,
politically-motivated project (36).
Response; Speculation by USEPA about the political motivations of
the DPW's involvement in this project is not appropriate. The DPW
continues to be a manager of existing WWTPs in the project area and has
succeeded in gaining the support of 15 of the 22 communities in the
project area for Alternative A-l.
6.2.3. Land Use and Transportation
Issue 1; Some confusion apparently exists about the location of
the proposed regional WWTP site (8,41).
Response; The conceptual location of the proposed regional
wastewater treatment plant is adjacent to the existing wastewater
stabilization lagoons in southern Brownstown Township. The site is
located east of River Road and north of Lee Road. As noted in the
Draft EIS, detailed design of the proposed HVWWCS has not been
completed and the analyses presented were based on conceptual inter-
ceptor routes that terminate at a proposed regional treatment plant in
southeastern Brownstown Township. Utilization of the area adjacent to
the Brownstown Township wastewater treatment lagoons was based on
information available from the Wayne County Department of Public Works
and on the fact that land potentially is available at that location.
In addition, the site currently is used for wastewater treatment and
6-27
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would continue to serve that purpose if the proposed regional facility
were to be located there.
Issue 2; Concern has been expressed by the Huron-Clinton
Metropolitan Authority (35,64) about potential project impacts to the
three existing Metroparks adjacent to the Lower Huron River and to the
Lake Erie Metropark that is under development. Another (44) urged that
planning and design should include maximization of open space and
recreational opportunities, and that conversion of abandoned treatment
plant sites to parkland should be considered.
Response; The Lower Huron Metropark, the Willow Metropark, and
the Oakwoods Metropark, as well as the Wayne County Middle Rouge
Parkway, a section of the Lower Rouge Parkway, and the South
Metropolitan Parkway, potentially could be affected by construction of
a regional interceptor sewer. The types of impacts were discussed in
general terms in Section 6.1. of the Draft EIS.
Parklands and recreational areas should be avoided in the final
route design for the proposed interceptor sewer. Special care should
be taken to minimize disruption of access to parks and construction
should be scheduled to take place during "off-peak" use periods where
recreation areas cannot be avoided. The Wayne County DPW should work
closely with the agencies managing the parks to coordinate the route
selection and subsequent construction scheduling to minimize impacts to
parklands.
The proposed site of the regional WWTP is adjacent to the west
boundary of the 1,500-acre Lake Erie Metropark which presently is under
development. Careful control of odors at the WWTP would be essential
to avoid reducing the use and appreciation of the park. Similarly,
landscaping and a buffer area between the WWTP site and the park would
help to minimize any adverse effects to parkland aesthetics.
The Draft EIS recommended that comprehensive planning be
implemented as a means of managing secondary growth. This planning
should include measures for the protection and enhancement of open
space and parkland. It is agreed that conversion of abandoned treatment
plant sites to recreational use would be an appropriate use of public
land.
Issue 3 : The Regional Environmental Officer of the US Department
of the Interior (44) commented in part:
The project area contains many recreation areas which could
be affected by the proposal. Acquisition and/or development
of several of these recreation areas has been assisted by
the Land and Water Conservation Fund which Ls administered
by the Heritage Conservation and Recreation Service. If any
of the following list of recreation areas would be affected,
we suggest you coordinate closely with the Michigan
Department of Natural Resources concerning the implications
of project conflicts with Section 6(f) of the Land and Water
Conservation Fund Act:
6-28
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County Administrator Park
Oakland Commerce Township Bicentenniai Park
Wayne HCMA Woods Creek Picnic Area
Wayne County William P. Holiday
Wayne County Middle Rouge Bikeway
Gibraltar Gibraltar Park
Northville Northville Hatchery Park
Response; As discussed In the response to Issue 2, parklands and
recreational areas should be avoided In the Step 2 design of the re-
gional interceptor sewer, The Wayne County DPW and Its engineering
consultant must coordinate with MDNR concerning the final route of any
proposed interceptor sewer to ensure compliance with Section 6(f) of
the Land and Water Conservation Act.
Issue 4; It was stated (28) that transportation problems may
result for western suburb residents because of increased growth and
uncertain supplies of energy.
Response; The extensive highway network and the limited
availability of public transportation in the project area indicate a
dependence on private passenger automobiles by western suburb
commuters. Rapid growth in and adjacent to the project area will
increase demands on limited energy supplies such as gasoline.
Definitive statements on future problems are not possible because of
the uncertainties involved in growth projections and estimates of
energy supplies. It is likely that motor fuel prices will continue to
Increase and that supplies will be unable to meet the overall demand
completely. Provision of public wastewater treatment is only one
factor in this situation. Increased availability and use of public
transportation and a reduction in the use of private passenger vehicles
can help to reduce the impacts of fuel shortages. This should be
accompanied by comprehensive land use planning which includes energy
utilization as a major consideration. Alleviation of present and future
transportation problems will require a coordinated effort between
public agencies and private citizens.
Issue 5: A Township Supervisor (61) who also is a farmer in the
project area commented that the concern expressed in the Draft EIS
about the conversion of farmlands to developed uses is not realistic.
He stated "the only remaining land use you [USEPA] are promoting for
our area is a Big Recreational Belt for the City of Detroit." He
indicated that Huron Township now has 3,610 acres of recreational lands
instead of the 1,854 acres that is indicated in the Draft EIS (taken
from SEMCOG's 1975 Land Use Inventory—the most recent comprehensive
data), largely because of the development of a new Metropark adjacent
to the 1-275 freeway. He indicated that such developments that support
the expansion of urbanization into undeveloped areas such as Huron
Township force the community "to extend their municipal services beyond
their means in anticipation of future planned growth."
Reponse: Many people share the opinion that the expansion of
urbanization at the fringe of large metropolitan areas is inevitable.
Much of the project area constitutes an urban fringe for the Detroit
6-29
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Metropolitan Area. Growth pressures are extreme because of the lower
cost of land relative to areas closer to the urban core, the highway
system that has been constructed through sections of this area, and
because of the amenities such as open space, clean air, and other
perceived benefits of a non-urban environment. However, comprehensive
planning, especially growth management planning, can be an effective
means of channeling growth so as to protect certain amenities and
natural resources, such as high quality farmlands. The concern over
the issue of secondary growth in the project area by USEPA and others
is that Federal spending should not be used to promote growth in an
area if it will cause additional problems that the Agency is chartered
by law to avert. This incudes consumption of prime farmlands,
destruction of wetlands, deterioration of air, noise, and water
quality, and similar concerns. Similarly, secondary growth can create
serious impacts for local governments related to the need for expansion
of public services, as discussed in the Draft EIS and as indicated by
the Huron Township Supervisor.
Issue 6; The Monroe County Board of Commissioners (54) expressed
concern that no potential sites for the disposal of residuals from
sludge incineration were identified in the Draft EIS.
Response; Availability of landfill capacity in the area adjacent
to the project area was identified as a major issue during the environ-
mental review. It was assumed that residuals from sludge incineration
would be disposed of in accordance with applicable State and local
regulations and ordinances at approved landfill sites. The amount of
incinerator ash resulting from the operation of a regional wastewater
treatment plant would be small in comparison to the total amount of
solid waste and refuse generated in the project area. Such ash
normally is compatible with conventional landfill operations. Accep-
tance or refusal of residuals from the proposed treatment plant by
various landfills is beyond the scope of the present study.
It it probable that an alternative sludge management plan will be
developed during the Step 2 facilities design process. The rising cost
of the necessary supplemental incinerator fuel and the air pollution
control requirements indicate that an alternative WWTP sludge
processing program such as sludge digesting, dewatering, and land
spreading, may be more cost-effective than incineration.
Issue 7; Representatives of both Wayne County (51,T2) and Oakland
County (26) have indicated difficulty in attempting to control urban
development and to delineate the areas for future growth as well as for
agriculture and open space in the project area without "a
well-coordinated and developed sewer system ... as the basic framework
from which to implement these plans." Representatives of the Oakland
County Health Division stated that "it must also be pointed out that
the lack of public sewer service has not stopped the development of
outmigration into this area [Oakland County section of the project
area] when soil conditions on proposed developments or lots have
complied with the criteria established in the [County] Sanitary Code."
They added that they have received "mandamus orders requiring the
issuance of permits to install septic systems on lots that have been
denied [permits] because of unsuitable soil conditions ... systems
which we [The Health Division] believe are doomed to early failure."
6-30
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Response; USEPA is well aware of the role of sewer service in
implementing local growth management planning and of its potential to
stimulate unplanned growth. The migration to, and the development
presently occurring in, the project area would be at a much lower rate
than it would occur if sewer service were available. Although the
problem of failing on-site septic systems is of concern to USEPA, this
concern must be balanced against the effects of proliferated local
growth facilitated by the presence of sewer service. Sewer service
cannot be relied on as a failsafe means for channeling growth. Local
land use controls must be implemented and enforced Lf real growth
management is to occur.
Issue 8; The Wayne County DPW (51) has indicated that Alternative
A-l has been approved by the Regional Clearinghouse Review Committee of
SMCOG as being in compliance with the SEMCOG programs and policies.
Another (3) questioned whether the proposed project is consistent with
Michigan's Coastal Zone Management Plan.
Response; The most recent action approved by the SEMCOG Regional
Clearinghouse Review Committee (RC2) is contained in a 12 January 1979
letter to USEPA from SEMCOG (41). This letter indicates that the RC2
passed the following motion relative to this project:
That planning (Step 2-Design) for Alternative A-l should be
allowed to proceed immediately, on a modular basis, while
studies of interceptor and treatment facilities needed for
the middle and northern segments of the Huron Valley System
continue as a part of the Detroit Wastewater Treatment
System Planning effort.
The letter further states that:
The phrase "on a modular basis" was Intended by the Regional
Clearinghouse Review Committee to convey their desire to see
that the preliminary design and engineering work necessary
to implement Alternative A-l proceed immediately, e.g.,
Trenton Arm Interceptor, Interceptor right-of-ways, site
plan for treatment plant, etc., while the capacity of the
Detroit treatment facility is finalized. With proper
coordination between the Detroit Planning work and the Huron
Valley Planning work, the two plans can proceed simulta-
neously, thus saving time. The Committee felt that undue
delay in the planning of the Huron Valley System would be
extremely costly and that any "cost-effective" analysis
should consider the effects of inflation on the proposed
wastewater treatment system caused by such delays.
Thus, Alternative A-l has received only conditional approval from the
Regional Clearinghouse Review Committee. The RC2 has supported the
need for further study of the northern section of the project area.
The State of Michigan has delegated responsibility for adminis-
tration of the Coastal Zone Management Program in southeastern Michigan
to SEMCOG. Action by the Regional Clearinghouse Review Committee will
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reflect conformance with all regional plans, programs, and policies,
including the Coastal Zone Management Plan.
Issue 9; It was recommended (3) that there be further
coordination between the Wayne County DPW and the Michigan Department
of State Highways and Transportation (MDSH&T) and local highway
agencies concerning the proposed crossing of Interstate and Federal-aid
highway routes by the proposed regional interceptor. It was noted that
the location of possible M-275 alternatives by MDSH&T may be affected
by the proposed route of the regional interceptor in the northern
section of the project area. The Wayne County DPW would be required to
obtain permits for the road crossings before construction could
commence.
Response: The MDSH&T should be contacted by the Applicant for a
preliminary review of proposed Interstate and State highway crossings
prior to its filing for authorization permit #2205. Local highway
departments similarly should be contacted during Step 2 system design.
The Draft EIS (Section 6.3.) discussed the potential secondary impacts
in the northern section of the project area from the availability of
interceptor sewer capacity. This section of the Draft EIS also
indicated that the availability of highway systems is a significant
factor for secondary growth. Future planning of highways for this
area, such as the M-275 proposal, should be coordinated with planning
for other major public services, such as the proposed regional inter-
ceptor. This would ensure that adverse effects avoided by the final
design of one such system are not created by another.
6.2.4. Cultural Resources
Issue 1; One respondent (14) referred to the discussion of
potential archaeological sites and historic buildings Ln the Draft EIS
as being "truly of minimal consequence in the service area." He felt
that this information was presented "with no attention devoted to the
relationship of any such (sites) to proposed interceptor routes."
Another respondent (3) similarly indicated that the level of detail
presented in the Draft EIS is considered inadequate to properly assess
the significance of the impact on the . .. cultural features along the
route of the interceptor sewer." In contrast, the State Historic
Preservation Officer (65) protested the publication of site
information, considering it unnecessary at this stage of project
development.
Response; The potential for archaeological sites to exist in the
project area, especially in the interceptor sewer corridor, is great,
as discussed in Sections 3.3., 6.1., and 6.3. of the Draft EIS.
Numerous historical structures also exist (Section 3.3.). Because the
exact route of the proposed interceptor sewer has not been finalized,
no specific relationships between the interceptor route and known sites
are possible. Possibly of more significance, however, would be the
potential for disturbance of unidentified archaeological sites and/or
of historical buildings by the secondary growth and development within
the project area.
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It is standard practice to limit archaeological site descriptions
to only a township and section identification. USEPA regrets the
publication of the more exact locations. The specific references to
site locations contained in the first printing of the Draft EIS have
been deleted in the reprinted document.
Detailed archaeological surveys of the interceptor route and the
site of proposed WWTP should be conducted as part of the Step 2 design
work as suggested by the US Department of the Interior (44) and the
State Historic Preservation Officer (SHPO; 65). This *ould help to
minimize the disturbance of potential sites during construction. It
also would help to avoid possible delays during construction if a site
was encountered and had to be salvaged.
Issue 2; The SHPO indicated that the "undocumented" statement "no
historic or archaeological sites are known to exist at the Brownstown
Township WWTP" that was contained in Table 25, Section 6.1., of the
Draft EIS is premature.
Response; The final determination of whether an archaeological
site may exist can only be made once a detailed on-foot survey is
conducted. The statement nevertheless is correct based on existing
information.
6.3. Engineering/Conceptual Design Concerns
Issue 1; The Wayne County and Oakland County Health Departments
and many communities and individuals (2,6,7,11,13,14,20,21,26,40,53,
T2) objected to the concept of continued utilization of on-site systems
in certain areas that was incorporated in Alternative D. Information
was presented, especially by the Health Department, about the
unsuitability of soils in the project area for sustaining operating
septic systems.
Response; The facilities planning that will be initiated for the
Van Buren Township to Commerce Township section of the project area
must assess the need for new collection sewers. This analysis will
provide the type of analysis necessary to make a final determination on
the most cost-effective and technically feasible type of wastewater
management system for the area. Such an analysis is beyond the scope
of an EIS. The information presented by the Wayne County Health
Department about septic system problems in northwestern Wayne County
was requested by the USEPA's EIS consultant more than a year earlier.
Timely provision of such information would have improved the quality of
the alternatives analysis presented in the Draft EIS.
Issue 2; Money should be spent only for wastewater sludge
composting and land application in compliance with the SEMCOG Areawide
Plan instead of for sludge incineration (4).
Response; USEPA will require that the Wayne County DPW further
analyze the WWTP sludge management system. Because of rapidly in-
creasing cost and reduced availability of the supplemental fuel needed
for sludge incineration, such an option may no longer be
cost-effective. USEPA and MDNR recommend that the design of the system
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proceed as outlined in Alternative F (Section 5.0.) without an approved
sludge management plan. Such a plan would be required to be developed
as part of the concurrent facilities planning activities. A Step 3
grant for system construction could not be awarded until an approvable
sludge management system was developed.
Issue 3; The proposed regional treatment plant should be designed
to facilitate an active environmental education program with area
schools (44).
Response; While it is beyond the scope of this EIS to determine
educational issues, it is recognized that public understanding of
wastewater treatment is an important concern. It is suggested that
consideration be given in plant design to maximization of public access
consistent with safety. Coordination of this issue between the
treatment plant management authority and local educational agencies is
recommended. SEMCOG has taken leadership in environmental education
programs in recent years and should consider coordinating such a
program in southeast Michigan.
Issue 4; Significant issues were raised (2,6,51,55,59,75,12) con-
cerning the adequacy of total capacity and the reallocation of commu-
nity-owned capacity in the RVSDD that was proposed in Alternative D.
It was stated that the existing discharges by communities to the
interceptors in excess of contract capacities only are possible because
eastern district communities are not utilizing their maximum capacity.
Individual community contributions presented in Section 3.4.2. of the
Draft EIS were questioned. The idea that I/I removal in the RVSDD
interceptor system would provide additional capacity was considered to
be highly questionable. Communities indicated that they would require
significantly more capacity than proposed.
Response; The assumptions on which interceptors capacity deter-
minations for Alternative D were based include:
• "Ideal" reallocation of contract capacities in the RVSDD
among communities to afford optimum utilization of
available capacity
• Sewered population estimates for communities that were
based on SEMCOG's population forecasts and projections of
the number of sewered vs. unsewered households
• Per capita flow values as presented in the Facilities
Plan for the HVWWCS
• That 3.0 cfs of the total 5.0 cfs capacity owned by
public institutions with facilities located in Northville
Township would be available to Northville Township
• That the flow equalization basins at Novi would double
its effective capacity in the Middle Rouge Interceptor
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• That the physical capacity of the Middle Rouge Intercep-
tor east of Plymouth could convey more than the 37.48 cfs
combined contract capacity.
Assumptions about the cost-effective removal of I/I were not entered
into the analysis (i.e., flow values used were those provided in the
Facilities Plan).
Local facilities planning for the project area communities
presently served by the RVSDD, and for the Rouge Valley System as a
whole is essential to provide a basis for properly assessing future
capacity needs (see Section 5.0). The alternatives analysis presented
in the Draft EIS is based on a much less exhaustive study of
engineering factors than is achievable through the facilities planning
process.
Issue 5; Concern was expressed (10,41) about the differneces in
the estimation of project costs for Alternative A-l between the HVWWCS
Facility Plan and the Draft EIS.
Response: As indicated in the Draft EIS, the unit costs for
interceptor construction and the operational costs for treatment were
based on information provided in the HVWWCS Facilities Plan (Hubbell,
Roth & Clark, Inc. 1976). These values were updated based on
appropriate USEPA and Engineering News Record inflation indexes.
Because USEPA and the EIS consultant believed that the costs of pro-
posed treatment facilities may have been somewhat underestimated in the
Facility Plan relative to present day experience, newly published cost
curves (USEPA 1978) were utilized to develop new costs for treatment
systems.
Issue 6; Several residents of southeast Brownstown Township and
others (24,32,50,52) expressed concern that soil problems, frost
heaving in areas of high water table, the high water level of Lake
Erie, and the blasting operations at the Ottawa Silica quarry would
cause breaks in the regional interceptor sewer and interfere with the
operation of the WWTP if constructed in that area.
Response; These potentially problematic aspects will be addressed
during Step 2 facilities design. Engineering design should compensate
for these conditions. These constraints are not expected to preclude
construction; however, their potential effect must be taken into
consideration in system design.
Issue 7; One respondent (16) requested that the annual operation
costs that were presented on an average year basis in the Draft EIS be
revised to reflect the effect of inflation.
Response; Estimation of O&M costs was based on USEPA regulations
governing the estimation of costs for treatment facilities (FR Vol. 39,
No. 29, Appendix A) and USEPA's Guidance for Preparing a Facility Plan
(1975). This method assumes that O&M costs inflate at close to the
rate that prices in general would inflate, so that the effects of
inflation could be ignored in the overall analysis. New USEPA re-
gulations (FR Vol. 43, No. 188) now require that energy costs be
considered independently from the remainder of O&M costs as a means of
6-35
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better reflecting possible future increases in O&M costs relative to
that of other goods.
Issue 8; The fact that the implementation of a regional system
would preclude the impetus to explore the feasibility and implemen-
tation of innovative/alternative treatment options for communities in
the project area was criticized (27,50,T2). These respondents proposed
that the decentralized service concept offers flexibility for future
innovation. They criticized that land treatment was not given more
consideration and several (27,55,57,Tl) proposed that innovative
alternatives would be available for the section of the project area
that was proposed in Alternative D to be served by an enlarged Walled
Lake WWTP.
Response; A discussion of why land treatment was not considered a
viable option for a regional system was discussed in Section 5.2.3.2.4.
of the Draft EIS. Consideration must be given to innovative and
alternative wastewater management technologies in the local facilities
planning that is to be conducted for the Van Buren Township to Commerce
Township section of the project area. Any further consideration of
expansion of the Walled Lake WWTP would require that alternatives to a
surface water discharge be explored under the terms of USEPA's new
construction grants regulations (40 CFR 35.900). As discussed in
Section 2.7. of this document, however, there are numerous constraints
to the implementation of such alternatives; they are best suited for
small flows.
Issue 9; The abandonment of the Walled Lake WWTP and of the
Trenton WWTP, as proposed in several of the regional alternatives, was
questioned (27,50) in light of the position that these plants are
capable of meeting discharge standards with only minor upgrading.
Response; Decisions about the potential for abandonment of the
Walled Lake WWTP and the Trenton WWTP must be based on a cost-effec-
tiveness decision by the participating community. As of June 1979, the
communities served by these two facilities have not signed the
cost-sharing agreement for regional system design with the Wayne County
DPW. This indicates that they have not reached such a determination.
The future cost for service by the regional system potentially could be
lower than provided by their own WWTP because of the economies of
scale. The uncertainty about the final size and costs of the regional
system have made difficult this decision for these communities.
Issue 10; One respondent (27) disagreed with the idea presented
in the Draft EIS that Alternative E is not readily comparable to the
regional alternatives.
Response; The Draft EIS indicated that a direct comparison of
Alternative E with the regional alternatives was not feasible because
of the significantly lower population served by Alternative E.
Alternative E (Modified) has been developed (Section 2.7.) to better
display this comparison.
Issue 11; One respondent (41) requested that the amount of flow
that was assumed to be contributed to the regional system by each
community be shown.
6-36
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Response; Table 5-1 (page 5-5) of this document displays the
capacity assumed for each community in Alternative A-l. The 1995
average design flow for each community served by Alternative D is:
Community
Whitelake Twp.
Commerce Twp.
Walled Lake
Wolverine Lake
Novi
Northville
Northville Twp.*
Plymouth
Pymouth Twp.
Canton Twp.
Van Buren Twp.
2.46
0.96
4.48
Community
Belleville 0.94
Sumpter Twp. 1.74
Romulus 0.26
Huron Twp. 2.07
Flat Rock 2.52
Rockwood 2.07
South Rockwood 0.28
Browns town Twp. 4.29
Woodhaven 1.63
Gibraltar 0.92
Trenton 5.61
*Includes flow for an equivalent of 5,000 persons at public
institutions within Northville Township.
Flows from White Lake Township, Commerce Township, Walled Lake,
Wolverine Lake, and northern Novi (0.42 mgd) were proposed for costing
purposes to be treated by expanding the Walled Lake WWTP to 4.8 mgd.
Flows from the remainder of Novi, Northville, Northville Township,
Plymouth, and Plymouth Township, totaling 10.9 mgd, were proposed to
continue to be conveyed to the Detroit WWTP via the Middle Rouge
Interceptor. Flows from the remaining communities were proposed to be
conveyed via new regional interceptors to a new, 32-mgd regional WWTP.
Issue 12; Concern was expressed (44) that planning for new sewer
facilities should address the proper abandonment of septic systems that
would be replaced by hook-ups to new collection sewers. Problem
aspects related to septic systems which presently exist should be
ameliorated to ensure the success of project goals and to enhance water
quality.
Response; USEPA agrees with this observation. This aspect of the
wastewater management program should be addressed through the local
facilities planning for collection sewers.
Issue 13; Several of those (55,63,70) opposing the regional
concept of wastewater management expressed the opinion that it is
better done on a river basin basis. At that level, hydrologic balance
could be maintained and the natural assimilative capacity of the rivers
could be utilized.
Response; This comment is addressed by the various related re-
sponses in Section 6.1.1.
Issue 14; One respondent (56) suggested that the solution to the
lack of land availability for expansion of the Flat Rock WWTP would be
to construct a new primary treatment system for Huron Township flows
6-37
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west of Flat Rock, use the existing plant site for final treatment, and
require the Ford Motor plant to pretreat its wastes.
Response; Alternative treatment plant sites were considered early
in the conceptual alternatives development stage of the project. It
would not be cost-effective, relative to the cost of providing new
service with a regional system, to provide split treatment facilities
at Flat Rock. If the City of Flat Rock were left with no alternative
but to expand and upgrade its existing facilities, at whatever cost,
then this proposal might warrant further consideration, Pretreatment
of industrial flows would be required if the wastewater would interfere
with treatment plant operations.
Issue 15: The basis of design and the estimation of operation
costs for the expansion and upgrading of the Walled Lake WWTP that was
considered in Alternative D were questioned (51,62). It also was
questioned whether an expanded/upgraded facility would be able to meet
the more stringent effluent limitations that would apply if the
existing plant is not in compliance with the conditions of its NPDES
discharge permit.
Response; Generalized cost curves (USEPA 1978) were utilized to
obtain costs for construction and treatment of the expanded/upgraded
Walled Lake WWTP considered in Alternatives C and D. No formal design
specifications were prepared. Because of the limited experience
nationally with state of the art phosphorus removal facilities, limited
data is available on its costs. It is conceivable that cost esti-
mations for this facility are low.
The Oakland County DPW, the operators of the Walled Lake WWTP,
were issued a Notice of Noncompliance and Order to Comply by MDNR in
January 1979. Cited violations included failure to monitor the
effluent as required in the permit and violations of effluent DO, fecal
coliform, and phosphorus limitations. An upgraded/expanded plant would
be designed to meet the more stringent effluent standards. The
engineering design would be thoroughly reviewed by MDNR and USEPA prior
to approval of construction; however, although the plant may be
designed properly, the potential still would exist for occasional
operational problems to develop that might degrade effluent quality at
times.
Issue 16; The method that was used to estimate the cost of
interest during construction for the costing of alternatives was
questioned (60). Similarly, the interest rates, cost indexes, and
other assumptions related to cost calculations was requested to be
shown (T2).
Response; The method used to calculate interest during
construction was based on the method suggested in USEPA regulations (40
CFR 35.900). As a result of the Wayne County DPW's objection to this
methodology, an alternative means to incorporate this factor was used
in the costing of Alternative E (Modified) and of Alternative F.
Instead of using a 25% service factor and calculating interest during
construction independently, as was done in the Draft EIS, a 27% service
6-38
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factor that includes interest during construction has been utilized.
This represents standard engineering practice for facilities planning
during 1979.
The interest rate for wastewater facilities projects is estab-
lished by law. The US Water Resources Council publishes a value on an
annual basis. Because January 1978 price levels were established as
the base price for standardizing costs for all alternatives, the
applicable Federal interest rate was 6.625%. Published USEPA waste-
water facilities and O&M cost indexes and the Engineering News Record
Construction Cost Index were utilized to adjust prices to the January
1978 level.
Issue 17; A question was posed about what alternatives would
remain for the northern communities if service was not provided by the
HVWWCS (T2).
Response; As discussed in the Conclusions and Recommendations
section of the Draft EIS (Section 7.0.) and in Section 5.0. of this
document, a variety of options potentially could be considered as
alternatives to service for the northern area. These include indepen-
dent solutions for communities that involve dependence on decentralized
systems, especially innovative technologies such as upgrading septic
systems, clustering on-site systems, septic tank effluent pumps and
low-pressure sewers; land treatment; wetlands treatment; conveyance to
the Detroit system; and various combinations of these.
6-39
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7.0. LITERATURE CONSULTED
Applegate, V., and H. Van Meter. 1970. A brief history of commercial
fishing in Lake Erie. Fishery Leaflet 630. US Department of the
Interior, Fish and Wildlife Service, Washington DC.
Binkley, C., and others. 1975. Interceptor sewers and urban sprawl-
Lexington Books, Lexington MA.
Burt, W.H. 1957. Mammals of the Great Lakes region. The University of
Michigan Press, Ann Arbor MI, 246 pp.
Commonwealth Associates Inc. 1974. 1-275 archaeological and historical
survey. Prepared for the Michigan Department of State Highways and
Transportation and the Michigan History Division, Lansing MI.
Conant, R. 1975. A field guide to reptiles and amphibians of eastern and
central North America, 2nd ed. Houghton Mifflin Company, Boston MA,
429 pp.
Elliott, A.M. 1968. Zoology. Appleton-Century-Crofts, Division of
Meredith Corporation, New York NY, 799 pp.
Enviro Control, Inc. 1976. Environmental impact assessment of alternative
concepts for water quality management of the Huron River Basin. Volume
10 of the Facility Plan for the Huron Valley wastewater control system,
Rockville MD, variously paged, 428 pp. and appendices.
Environmental Consultants, Inc. 1977. Technical feasibility of land
application of domestic wastewater treatment plant residues in
southeast Michigan. Southeast Michigan Council of Governments,
Detroit MI, 130 pp.
Federal Highway Administration. 1973. Noise standards and procedures.
Policy and procedure memorandum 90-2. US Department of Transportation,
Washington DC.
Fitting, J.E. 1970. The archaeology of Michigan. The Natural History Press,
Garden City NY.
Fitzpatrick, M., J. Willson, D. Ericson, G. Fox, and D. Wood. 1978.
Manual for evaluating secondary impacts of wastewater treatment
facilities. US Environmental Protection Agency (EPA-600/5-78-003),
Office of Air, Land, and Water Use, Washington DC, 175 pp.
Giffels/Black & Veatch. 1977a. Land. Interim report (DOA-101). Overview
plan with environmental assessment. Prepared for the Detroit Water and
Sewerage Department. Giffels/Black & Veatch. Detroit MI, 13 pp.
Giffels/Black & Veatch. 1977b. Living organisms. Interim report (DOA-104).
Overview plan with environmental assessment. Prepared for the Detroit
Water and Sewerage Department. Giffels/Black & Veatch, Detroit MI,
33 pp. and appendices.
7-1
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Giffels/Black & Veatch. 1977c. Segmented facilities plan. Volume 1. Over-
view plan with environmental assessment. Prepared for the Detroit Water
and Sewerage Department. Giffels/Black & Veatch, Detroit MI, 195 pp.
Giffels/Black & Veatch. 1977d. Summary report. Overview plan with environ-
mental assessment. Book 1 - Part 2 of 2. Prepared for the Detroit
Water and Sewerage Department. Giffels/Black & Veatch, Detroit MI,
variously paged.
Giffels/Black & Veatch. 1977e. Sludge disposal. Interim report (WCT-119).
Overview plan with environmental assessment. Prepared for the Detroit
Water and Sewerage Department. Giffels/Black & Veatch, Detroit MI,
162 pp.
GLBC. 1975a. Great Lakes Basin framework study. Appendix 17 - wildlife.
Great Lakes Basin Commission, Ann Arbor MI, 140 pp.
GLBC. 1975b. Great Lakes Basin framework study. Appendix 14 - floodplains.
Great Lakes Basin Commission, Ann Arbor MI, 288 pp.
GLBC. 1975c. Great Lakes Basin framework study. Appendix 11 - levels and
flows. Great Lakes Basin Commission, Ann Arbor MI, 206 pp.
GLBC. 1975d. Great Lakes Basin framework study. Appendix 4 - limnology of
lakes and embayments. Great Lakes Basin Commission, Ann Arbor MI,
441 pp.
Herdendorf, C.E. 1969. Water masses and their movements in western Lake
Erie. State of Ohio, Department of Natural Resources, Division of
Geologic Survey Report of Investigations No. 74, Columbus OH.
Hubbell, Roth & Clark, Inc. 1976. Facility Plan for the Huron Valley
Wastewater Control System. Volume 1. Prepared for the Board of Wayne
County Road Commissioners. Hubbell, Roth & Clark, Inc., Detroit MI,
variously paged and appendices.
Knutilla, R.L. 1971. Water resources of the River Rouge Basin, southeastern
Michigan. US Geological Survey, Hydrologic Investigations Atlas
HA-356, Washington DC.
Knutilla, R.L. 1972a. Gazetteer of hydrologic data for the Huron River
Basin, southeastern Michigan. Technical paper No. 7, southeastern
Michigan water resources study, US Army Engineer District, Detroit
Corps of Engineers, Detroit MI.
Knutilla, R.L. 1972b. Gazetteer of hydrologic data for the River Rouge
Basin, southeastern Michigan. Technical paper No. ]., southeastern
Michigan water resources study, US Army Engineer District, Detroit
Corps of Engineers, Detroit MI.
Larson, R.W., W.B. Allen, and S.D. Hanson. 1975. Water resources of the
Huron River Basin, southeastern Michigan. US Geological Survey,
Hydrologic Investigations Atlas HA-514, Washington DC.
7-2
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McNamee, Porter, and Seeley. 1975. Drought flows of the Huron River in the
Ann Arbor-Ypsilanti area. Preliminary draft of 15 May 1975. McNamee,
Porter, and Seeley, Ann Arbor MI.
May, G.S. 1967. Pictorial atlas of Michigan. W.B. Eerdmans Publishing Co.,
Grand Rapids MI.
Metcalf & Eddy, Inc. 1972. Wastewater engineering: collection, treatment,
disposal. McGraw-Hill Book Co., New York NY, 782 pp.
MDNR. 1974. General water quality survey and storm water survey, June-
September 1973. Michigan Department of Natural Resources, Michigan
Water Resources Commission, Bureau of Water Management, Lansing MI.
MDNR. 1977a. Michigan's natural rivers report - Huron River, May 1977.
Michigan Department of Natural Resources, Lansing MI.
MDNR. 1977b. The Detroit River 1966-1976 — A progress report. Publication
No. 4833-9438. Michigan Department of Natural Resources, Environmental
Protection Bureau, Comprehensive Studies Section, Lansing MI, 59 pp.
Michigan Department of Commerce. 1975. Growing with Michigan, Volume 3,
Number 6. State of Michigan, Department of Commerce, Lansing MI.
Michigan Department of State Highways. 1976. Corridor/alignment environ-
mental section 4(f) statement for the proposed location of the M-275
freeway, from 1-96 north to M-59, Oakland County, Michigan. Michigan
Department of State Highways and Transportation, Lansing MI,
variously paged, 162 pp. & appendices.
Moak, L.L., and A.M. Hillhouse. 1975. Concepts and practices in local
government finance. Municipal Finance Officers Association of the
US and Canada, Chicago IL, 454 pp.
Mozola, A.J. 1969. Geology for land and groundwater development in Wayne
County, Michigan. Michigan Department of Natural Resources, Geological
Survey Report of Investigation 3, Lansing MI.
MWRC. 1975. A biological investigation of the Rouge River, Wayne and Oak-
land Counties, May 17 to October 19, 1973. Michigan Water Resources
Commission, Bureau of Water Management, Department of Natural Resources,
Environmental Protection Branch, Lansing MI.
Noyce, R.W. 1974. Environmental geologic study. In Corridor/alignment
environmental section 4(f) statement for the proposed location of the
M-275 freeway, from 1-96 north to M-59, Oakland County, Michigan.
Michigan Department of State Highways and Transportation, Lansing MI.
1976.
Oakland County DPW. 1975. Infiltration/inflow analysis-Walled Lake-Novi
sewage disposal system, Oakland County, Michigan. Facility plan for
the Huron Valley wastewater control system, Volume 5. Oakland County
Department of Public Works, Pontiac MI, 6 pp.
7-3
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Parkhurst, B. 1972. Thermal discharge. Part V: the distribution and growth
of the fish populations along the western shore of Lake Erie at Monroe,
Michigan, during 1970. Technical report No. 17, Thermal Discharge Series.
Institute of Water Research, Michigan State University, East Lansing, MI.
Parkins, A.E. 1918. The historical geography of Detroit. Kennikat Press,
Port Washington NY.
Say, E.W., and O. Jansson. 1976. The Huron River and its watershed. Huron
River Watershed Council, Ann Arbor MI., 34 pp.
Secretary of the State of Michigan. 1893. Michigan and its resources.
Robert Smith and Co., Lansing MI.
SEMCOG. No date. Soil management groups - Wayne County (map). Prepared
by Resource Management Associates, West Chester PA. Southeast Michigan
Council of Governments, Detroit MI.
SEMCOG. 1968. A profile of southeastern Michigan, TALUS data. Southeast
Michigan Council of Governments, Detroit MI, not paged.
SEMCOG. 1976a. Precipitation in southeast Michigan. Southeast Michigan
Council of Governments, Detroit MI, 31 pp. and index.
SEMCOG. 1976b. Surface geology (map). Southeast Michigan Council of
Governments, Detroit MI.
SEMCOG. 1976c. Land use patterns in southeast Michigan. Southeast Michigan
Council of Governments, Detroit MI.
SEMCOG. 1976d. Population and occupied dwelling units in southeast Michigan,
1975. Southeast Michigan Council of Governments, Detroit MI, not paged.
SEMCOG. 1976e. Interim sewer service areas map. (Part of the amendments to
the sewer, water, storm drainage plan adopted by the SEMCOG General
Assembly.) Southeast Michigan Council of Governments, Detroit MI,
1 sheet.
SEMCOG. 1977a. Inland lake management concerns for southeast Michigan.
Southeast Michigan Council of Governments, Detroit MI, 78 pp.
SEMCOG. 1978a. Water quality in southeast Michigan: the Huron River Basin.
Southeast Michigan Council of Governments, Detroit MI, 156 pp.
SEMCOG. 1978b. Water quality in southeast Michigan: the River Rouge Basin.
Southeast Michigan Council of Governments, Detroit MI, 121 pp.
Twenter, F.R. 1975. Southeastern Michigan water resources study - ground-
water and geology. US Geological Survey and US Army Corps of Engineers,
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7-4
-------
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7-5
-------
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7-6
-------
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LETTERS OF COMMENT
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