For more than 20 years, I served as a member and chair of the Water Quality Oil and Gas Board, which is the state board responsible for overseeing water and wastewater policy, regulatory and permitting programs under the jurisdiction of the Tennessee Department of Environment and Conservation. It was an honor and privilege to serve the citizens of our state in this role.
As a result, I have a rare perspective on the Water Authority of Dickson County’s proposal to build a sewage treatment plant that would discharge 12 million gallons a day into Lick Creek, which flows directly into the Duck River.
I live in a rural section of Williamson County at the headwaters of South Lick Creek. I grew up catching minnows in Lick Creek and have appreciated its beauty all my life.
After reviewing the WADC application, I believe the permit should be denied. There are fundamental problems with the proposal.
My concerns with the WADC proposal are several fold:
— Another band-aid solution: The proposed plant purports to provide a long-term solution for wastewater needs in the region but it fails to do so.
In the early 2000s, the WADC was looking at long-term solutions for the projected growth in the Dickson, Hickman and Williamson county area. Its consultant, Brown and Caldwell, identified expanding their existing plants and directing wastewater to the Cumberland River as a potential solution.
That decision was not pursued and the WADC limped along with the existing plants discharging to Jones Creek and Trace Creek. Those plants are now under duress and operations are straining those waterways.
Now, recognizing the problems at the Jones Creek plant, it proposes to redirect flow and add additional growth to a new plant in Hickman County with a discharge to an exceptional Tennessee waterway.
That is not a long-term solution — that is just the proverbial “kicking the can down the road.” In a few years, the problems at Trace Creek and Jones Creek will show up on Lick Creek. It is time to find a real long-term solution, not just more band aids.
— Impacts on Lick Creek: The WADC wants to build a plant somewhere in Hickman County (it still will not say where) with a discharge into pristine Lick Creek. This will ruin the creek below the outfall as a fishing and recreational use destination and damage the creek in many additional ways.
The WADC has still not done a detailed analysis on the impacts to the creek. It simply asserts that as a truth in its application. That is not sufficient. The WADC’s director has said the water will be clean enough to drink below the outfall. Seriously?
Recently the Southern Environmental Law Center did an investigation of the outfall below the WADC plant on Trace Creek and found serious concerns and noncompliance with their permit. TDEC is investigating it.
— Not for benefit of Hickman County residents: Even by the WADC’s own admission, most of the waste to be discharged from this plant will come from outside Hickman County. The WADC has adjusted the numbers a bit on the exact percentage and tried to portray this project as one that is for the benefit of Hickman County. But that is just not the case.
This attempt to take sewage generated in wealthier communities and discharge into Lick Creek smacks of “environmental classism.” Is it a “benefit” to Hickman County to be the sewage dumping ground for wealthier Williamson and Dickson county waste?
Ask the residents of Murfreesboro about how they feel about the Middlepoint Landfill and what it has done to the community there.
Hickman County residents — even if they are not on the sewer — will bear the cost of higher taxes and higher housing prices and all the revenue from the plant will go to the WADC. We have seen, in areas like Spring Hill and other small communities around Nashville, how long-term residents are displaced by suburban sprawl. We are losing our rural way of life.
— Impact on the Duck River Watershed: If the WADC obtains a permit to discharge to Lick Creek, it means they will now be discharging to the Duck River watershed. That opens the door for the WADC to seek to take water from the Duck River.
The Duck River, which is the most biodiverse river in the world, is already strained due to the growth in Middle Tennessee south of Nashville. It does not need additional sewer discharges or water withdrawals.
No one is opposed to smart, well-planned growth. Even if you concede the projections for growth in Dickson and Williamson counties, and even Hickman County, the solution must be one that is viable for the long term, is equitable and just, does not threaten natural treasures like Lick Creek and the Duck Creek Watershed, and does not threaten the rural way of life of Hickman County residents. The WADC proposal fails on all these fronts.
I urge TDEC to reject the WADC permit application, and bring together environmental groups and citizens of the impacted areas to find a rationale path forward.
JAMES CAMERON
Brentwood
