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TDEC Holding Public Hearing on Franklin Withdrawal Permit Application on October 21st

10/13/2014

The Tennessee Department of Environment and Conservation (TDEC) will be holding a public hearing on the City of Franklin's application for a renewed water withdrawal permit.  The hearing will be held at 5:30 PM on Tuesday, October 21st, at the Police Department Community Room, 900 Columbia Avenue, Franklin, TN 37064.

 

Franklin has several economically viable options for water supply, but the City only has one Harpeth River flowing through the heart of downtown.

  • Last year, TDEC issued a permit to Franklin that reduced the rate at which the City can withdraw water from the Harpeth River from 20% to 15% of the river's flow at the water treatment plant intake.
  • TDEC found that:
    • withdrawals of 20% or more of a river's flow are "typically found to cause significant ecological change";
    • the City's "proposed reduction in flow could further degrade dissolved oxygen levels" (note that the Harpeth is already impaired due to low levels of dissolved oxygen); and
    • the "reduction in the allowable rate of withdrawal is necessary for the protection and recovery of the use support for aquatic life."
  • The City objected to the stricter withdrawal condition.  Even though the City met with TDEC officials to discuss this change more than four months before the permit was issued, Franklin appealed the permit on the grounds that the City received no notice of its own application and its "due process rights" were violated.  TDEC decided to avoid the appeals process and withdrew the permit in order to restart the permit application process.
  • The City of Franklin obtains the majority of its drinking water from the Harpeth Valley Utilities District (on the Cumberland River).  HVUD often and reliably supplies 100% of the City's water needs when the City's plant cannot be used.
  • In addition, the City's service area does not encompass the entire City of Franklin.  Many Franklin residents already receive all of their water needs from other sources.
  • There is no point in further degrading the Harpeth River in order to allow the City's drinking water plant to operate a few extra days in the summer.  These extra days of operation contribute a very small fraction of the City's overall water demand yet the State has said that they come at the cost of degrading the river.

Attend the October 21st public hearing and let TDEC know that the City's water withdrawals must not cause degradation of the Harpeth River!

 

Franklin is still seeking to expand the capacity of its drinking water plant, even though it is difficult to operate the current, smaller plant throughout much of the year without degrading the river.

  • Since 2003, Franklin has hired 4 different consulting firms to analyze rebuilding and doubling the size of the drinking water plant.
  • The City's plan -- based on its 2012 Integrated Water Resources Plan (IWRP) -- is to build a 4.0 MGD Production Capacity plant: nearly twice the size of the current 2.1 MGD Production Capacity plant.
  • As the low summer flow of the Harpeth allows the current plant to operate at only about half capacity during the summer, expanding the current plant is not economically viable.
  • In order to increase the drinking water plant's ability to produce water, the City's IWRP proposed a Toilet-to-Tap plan.  The City's future plans, according to the IWRP, are to build a second sewage plant upstream of the drinking water plant, which will add flow from treated sewage discharged into the river that will then be used to increase drinking water production.

 

Materials

HRWA comments to TDEC on Franklin Drinking Water, Nov. 3, 2014--  Does not include Economic Analysis report below.

Harpeth Valley Utilities District 10 year rate forecast, October, 2014.  

Harpeth Valley Utilities District average rate increase over last 10 years:   (2004-2014)

Franklin Drinking Water Economic Analysis by Dr. Wade, October, 31, 2014

Water withdrawal analysis for Dr. Wade's Economic Analysis, by AquAeTer, Nov. 3 2014.

Oral Remarks at TDEC public hearing by Dr. Wade, sent to Franklin BOMA.  

Sunday, October 13th, Tennessean article.

Map of the five different drinking water utilities that serve the city of Franklin.  

TDEC Public Notice for October 21st Public Hearing.

TDEC Public Notice for Franklin Permit Application.

Dr. Bill Wade op-ed, July 1 2014.

Dr. Bill Wade op-ed, August 5 2014.

Dr. Bill Wade op-ed, September 10 2014.

Size Comparison Graph: Cumberland vs. Harpeth River

Drinking Water Distribution Graph: Franklin's Service District 2013

Thursday, October 23rd, Williamson Herald Article: TDEC seeks public comment...

Sunday, October 26th, Tennessean article: Harpeth River's Future