In December 2021, the Water Authority of Dickson County (WADC) submitted a permit application to the Tennessee Department of Environment and Conservation (TDEC) to build a sewer plant in Hickman County that would discharge 12 million gallons a day of sewage effluent into Lick Creek, our exceptional Tennessee waterway.
They did it with no outreach to the citizens of Hickman County. Fortunately, someone noticed a small sign stuck to a bridge along Highway 7 and raised the red flag.
Last spring, hundreds of citizens mobilized and voiced their opposition. Fortunately, TDEC listened and also found the application lacking. TDEC asked the WADC for additional information. Months passed, and still no effort was made by the WADC to reach out to the citizens of Hickman County about its plans. In fact, efforts made by our mayor and several commissioners to engage the WADC about this proposal were also rejected. Hickman County citizens should have a voice in this matter.
This past December, they submitted additional information to TDEC. The Friends of Lick Creek, with the help of lawyers, scientists, water quality and regulatory experts, have evaluated the latest information as well as the earlier submittal. After our thorough review, the result is the same:
The WADC’s latest submission does not address the fundamental flaws in its proposal to build a treatment plant in Hickman County that would discharge up to 12 million gallons a day into Hickman County’s waterways, Lick Creek and the Duck River.
The WADC proposal is defective for many technical and legal reasons that are complex but can be broken into several main points:
— First, a plant discharging to Lick Creek is not a valid, long-term, regional solution. Instead, it is a band-aid approach; creating new infrastructure and adversely impacting community streams. These community streams face negative consequences as evidenced by the sewer slime (Sphaerotilus) prevalent in Trace Creek.
— The WADC proposal allows sewage from the plant to enter the Duck River watershed, one of the most biologically diverse waterways in the United States.
— The WADC failed to evaluate all reasonable alternatives, including a no-action alternative. Its analysis was purely a “straw man” exercise with a predetermined outcome in mind.
— The WADC failed to consider the inherent economic value of conservation and preserving Lick Creek as a pristine waterway.
— The WADC’s economic growth claims are false.
— The WADC failed to consider the negative “costs” of growth in its analysis: higher cost of living, increased traffic, overcrowding, strained infrastructure and reduction of vital natural resources.
— The WADC could not show that the plant would not adversely impact the Coppercheek Darter, a state listed (threatened) species.
This issue is not a win-or-lose situation. The Cumberland River is the regional answer for sewage effluent discharge. The WADC needs to expand its capacity and address problems with its existing plant at Jones Creek.
Combining the Cumberland opportunity and the Jones Creek plant expansion with additional measures such as reclamation, reuse and infiltration repair to the Jones Creek plant, would significantly expand the WADC’s capacity. This alternative would protect East Hickman County, Lick Creek and the Duck River, while still accommodating any and all growth that may occur.
The permit application to build a plant to discharge to Lick Creek must be denied.
and RODES HART
Friends of Lick Creek