You can submit your comments to Robert Baker with the State of Tennessee by e-mailing them to: firstname.lastname@example.org. For background on permitting effort, go here, on the permit appeals, go here.
Here are a few of the issues involved that you can tell TDEC are important:
- The Harpeth River is too small to be a reliable source of drinking water. (see first chart below) It costs the city more money to produce water from the Harpeth than can be justified over the course of the year, when the City's drinking water plant provides only 30% of the City's drinking water and is only able to operate at about half capacity during summer months. (see second chart below)
- It is not cheaper for the City to produce drinking water from the Harpeth both at the current size of 2.1 million gallons a day (MGD) or at the proposed larger doubled capacity of 4 MGD.(see fourth chart below).
Dr. Bill Wade, a nationally recognized expert in water economics commissioned by HRWA to analyze drinking water options, commented at TDEC's public hearing that, according to his analysis using the City's consultants own numbers, the cost per 1000 gallons produced by Franklin in 2013 was $3.90. The cost per 1000 gallons from HVUD was $2.36 in 2013 (see third chart below).
- In contrast, the City claims that it costs $1.50 per 1000 gallons to produce drinking water at its plant, a figure Dr. Wade can not replicate.
- See Dr. Wade's comments to TDEC.
- The City of Franklin's economic development was founded on the city's connections to its primary provider, HVUD, which has been providing much of Franklin's drinking water since the 1980s. With HVUD's upgraded infrastructure, Franklin already has a reliable and economically efficient water source.
- The Harpeth is listed as impaired by the State of Tennessee for failing to meet water quality standards for Fish and Aquatic Life. TDEC also has determined that the city's current water withdrawal causes degradation because the current levels are "typically found to cause significant ecological change." Scientific understanding of the impact of water withdrawals and how to manage withdrawals has advanced since the permit was issued in 2007. HRWA believes that at the least, the State needs to:
- Reduce the current percentage of water the city is allowed to withdraw from 20% to 10% of the Harpeth's flow.
- Increase the minimum flow of the river required before the city can withdraw water from 10 cfs (cubic feet per second) to at least 20 cfs.
- The Harpeth is most stressed during the summer, when it has significantly lower flows than in the winter (see first chart below). If the City wants to withdraw water during the summer when the river is most stressed, it must provide TDEC with an adequate scientific analysisdemonstrating that proposed withdrawal rates and minimum flows do not contribute to the Harpeth's impairment. However, the city's proposal is to continue with its current withdrawal which the state determined causes degradation.
- TDEC has the obligation to ensure that any permitted water withdrawal supports fish and aquatic life. The City is not entitled to a permit, and the degradation currently allowed and proposed to continue can be avoided. The City has a reasonable alternative that is already providing a majority of the City's water supply and has provided 100% when the city could not produce its own. As a result, under the state regulations the City does not have an economic necessity for the degradation of the Harpeth caused by the current withdrawal conditions.
- There are significant river flows during the wet season (6 months) in the Harpeth for the City to consider water withdrawal options that focus on when the river can support it.
- If the City is permitted to withdrawal water from the Harpeth during the summer, it is imperative that the City must be required to measure the flow of the Harpeth immediately upstream from the water withdrawal intake in order to properly meet its permit limitations. The City has relied on downstream measurements since the permit was issued which do not provide accurate data at the location of the water withdrawal.
CHART ONE: When it comes to a river as a drinking water source: size does matter
Over the past 20 years, the lowest average daily flow in the Cumberland was 1,750 cfs. In the Harpeth it was 0.41 cfs.
The Harpeth is too small to support the small, existing, 2 million gallon a day (MGD) to produce at capacity year-round. During several months in the summer, production is only at HALF. For a chart based on City's information, go here.
CHART TWO: Where Franklin's drinking water comes from: The City's reliable source is the Harpeth Valley Utilities District.
CHART THREE: Dr. Wade's economic analysis concludes that operation of the City's drinking water plant costs much more than purchasing water from HVUD. Link here to Dr. Wade's public hearing comments.