Full Text
Resolution No. 97-20 A RESOLUTION OF THE CITY OF MOSCOW, A MUNICIPAL CORPORATION OF THE STATE OF IDAHO, STATING THE CITYS CONCERNS REGARDING TOTAL MAXIMUM DAILY LOADINGS FOR PARADISE CREEK AS PROPOSED BY THE STATE OF IDAHO DIVISION OF ENVIRONMENTAL QUALITY WHEREAS, the State of Idaho has been directed by federal court to establish Total Maximum Daily Loads (TMDL) for a number of waterways within the State including Paradise Creek; and WHEREAS, the City of Moscow Wastewater Treatment Plant discharges treated effluent into Paradise Creek; and WHEREAS, the State of Idaho Division of Environmental Quality (IDEQ) has proposed a TMDL for the City of Moscow Wastewater Treatment Plant effluent; and WHEREAS, the TMDL sets the effluent limits for total suspended solids, total phosphorus and discharge time, fecal coliform, temperature, and ammonia; and WHEREAS, the City of Moscow has deemed it to be in the public's interest to object to the proposed TMDL limits for total suspended solids, total phosphorus and discharge time, and temperature. NOW, THEREFORE, BE IT RESOLVED BY THE MAYOR At"'D CITY COUNCIL OF THE CITY OF MOSCOW AS FOLLOWS l. The City of Moscow objects to the TMDL limits proposed for the City of Moscow Wastewater Treatment Plant effluent relating to total suspended solids, total phosphorus and discharge time, and temperature. 2. The City of Moscow believes the IDEQ's concern for phosphorus in the City of Moscow Wastewater Treatment Plant effluent should be addressed by utilizing a phased approach to mitigation rather than the DEQ's proposed set target of 98% removaL Phasing considerations should include planting to shade Paradise Creek to exclude sunlight, use of wetlands, and land application of effluent. 3. The City of Moscow believes the time frame for discharge of effluent containing phosphorus should be May 15 through September rather than the proposed target of April through October. April and October are not part of the vigorous growing season, including the vigorous growing season for algae, at our latitude, and the extended growing season proposed by DEQ has contributed little to inhibit algae growth while coupled with extemely increased costs. 4. The City believes the proposed temperature limits should be measured at the Idaho/Washington state border rather than imposed on the effluent at the City of Moscow Wastewater Treatment Plant This would allow consideration for the use of natural cooling ---PAGE BREAK--- and temperature mitigation methods and techniques, including the planting of shade trees and shrubs to shade Paradise Creek before it reaches the state border rather than constructing costly cooling devices at WWTP. 5. The City believes a TMDL limit of 15 milligrams per liter for suspended solids in the City of Moscow Wastewater Treatment Plant eftluent is more realistic than the I 0 milligrams per liter proposed by DEQ, particularly since the proposed TMDL upstream limits are 50 milligrams per liter. Fifteen Milligrams per liter will be attainable with planned improvements to the existing City of Moscow Wastewater Treatment Plant 6. The City of Moscow recommends that the IDEQ and the Environmental Protection Agency encourages the Washington Department of Ecology to review the current classification of Paradise Creek including beneficial uses to establish the proper classification, which is viable for both the environment and the area's economy. 7. The City of Moscow believes that the commitment to economic sensitivity articulated in the IDEQ Mission Statement obliges that agency to consider costs of meeting targets in the TMDL in light of anticipated benefits. Therefore, the City of Moscow encourages the EPA and DEQ to conduct a cost-benefit analysis of the proposed TMDL limits for Paradise Creek in order to determine the benefits of such TMDL limits in light of the cost of obtaining those limits. Passed by the City Council and APPROVED by the Mayor this_.£_ 1997. Gil.bert F. City Clerk day of December, 2