The following letter was sent 5 years ago [Oct. 15, 2003] from the SC Council of Trout Unlimited in support of better 208 WASTE WATER PLANNING IN THE MIDLANDS of SC in response to the request from the Midlands Council of Governments for public input:

From: Malcolm Leaphart, Chair
SC Council Trout Unlimited
115 Conrad Circle
Columbia, SC 29212
October 15, 2003

To: Central Midlands Council of Governments
236 Stoneridge Drive
Columbia, SC 29210
Attention: Tiaa Booker
Re: Draft 208 Plan

Dear Ms. Booker:
Please accept this submission of comments on the 208 Plan draft as solicited on the Central Midlands web site. The SC Council of Trout Unlimited endorses the recommendations made by the Lower Saluda Scenic River Advisory Council which we have reviewed. Additionally we offer the following further comments, drafted with the experience and knowledge of the lower Saluda River by members with over 20 years of involvement and advocacy for science-based management of this significant natural resource, including several cooperative funding research projects with the SC DNR and SC DHEC. I am filing these statements on behalf of the SC Council of Trout Unlimited of which I am the current Chair because of support by all chapters in South Carolina; and, because I have also personally monitored conservation efforts on the lower Saluda for the Saluda River Chapter that I helped to found and served as its first president from 1982-1985. One of the main purposes of this chapter is to work for enhancement of the water quality of the lower Saluda so that it remains a viable trout fishery.

-- There is now a long term, but considerable undertaking being made by the SC Electric and Gas Company (SCE&G) at the urging of the SC Department of Health and Environmental Control (DHEC) to improve the water quality of the lower Saluda River below their Lake Murray hydro-electric operation. SCE&G has installed turbine venting to their generators to increase dissolved oxygen in the outflow to the Saluda, and are preparing for the addition to hub baffles for the same purpose. Earlier this year SCE&G funded a study of the trout in the Saluda at considerable expense to determine scientifically the requirements for dissolved oxygen. These requirements have been adopted by DHEC into a proposed upgrade of the dissolved oxygen requirement for the lower Saluda’s water quality standards. Also, the FERC re-licensing process is now underway and meeting the state dissolved oxygen requirements will be a requirement for SCE&G for the duration of the new license; and, to do that year round will probably mean the addition of expensive liquid oxygen injection equipment. All of these efforts represent a major expenditure in maintaining water quality in the lower Saluda by SCE&G. These efforts should be acknowledged in the 208 plan with the notation that the water quality of the discharges from Lake Murray must be maintained throughout the length of the river. In other words, the 208 plan should note that no discharges should degrade the enhanced water quality, including the critical dissolved oxygen levels, from what it is as discharged by SCE&G into the river.

-- The following statement found in Section 1, Introduction, under ‘Background’, ‘Since the 1983-84 Comprehensive Revision’, is misleading:
“This alternative, while cost effective, failed in the face of pressure by local environmental groups.”
As also explained in the next paragraph, the proposed Lorick’s Ferry wastewater plant not approved because DHEC had determined that the lower Saluda River had actually reached its maximum assimilative capacity during low flow periods. This determination came after years of research, especially on the dissolved oxygen dynamics of the river, so that the DHEC finally had enough data to produce meaningful results with their model. When first run, the model actually showed no significant degradation of the river because the input data was insufficient to provide defendable results. Trout Unlimited even contributed to the research by providing $2,000 in funds for a study of the ‘dissolved oxygen dynamics’ of the lower Saluda. While there was certainly pressure from local environmental groups against the Lorick’s Ferry plant, including the Saluda River Chapter of Trout Unlimited, those groups asked for science-based decisions to prove or disprove what common sense already told them - that the river simply does not have much assimilative capacity during the periods of low flows which often last for many days at a time. And the river flows are determined by electrical needs, lake storage, rainfall, and other factors all used by SCE&G to maximize electricity production – not to dilute wastewater.
In fact, after SCE&G finished rebuilding their generators and eliminating seepage at the Lake Murray dam in the early 1990’s, flows were recorded of less than 100 cfs during periods of no electrical generation – and this in a river which previously had a 7Q10 ‘drought’ flow figure of 260 cfs from the US Geological Survey. We respectfully request that more of the reasoning behind the rejected permit for the Lorick’s Ferry wastewater plant be provided in the 208 to not mislead readers to think the Lorick’s Ferry plant was not approved simply from an emotional outcry of citizens – rather than from the science-based decision that was made by DHEC.

-- The lower Saluda River below Lake Murray often flows for extended periods at a rate as low as 200 cfs. That level of flow is only reached due to the agreement made between DHEC and SCE&G to keep downstream dischargers in compliance after the reduced flow noted above in the early 1990’s. During peak power generation intervals, the flows may exceed 20,000 cfs which certainly skew upwards any mean or average flow figures. The assimilative capacity of the river during the low flow periods is the defining factor in setting wastewater discharge limits into the river – not the high flows, means, or average flows. SC DHEC took this into account when they determined after evaluation of the request for the ‘Loricks Ferry’ sewer plant in the late 1980’s that not only could the Saluda not assimilate any more wastewater discharges, but that all of the current dischargers should be removed from the river – that is, the assimilative capacity was already exceeded during the low flow periods. Based on this evaluation, the Lower Saluda Scenic River Advisory Council adopted the recommendation in their ‘corridor’ plan that all discharges be removed and that wastewater be piped further downstream to a regional plant for processing and discharge into the Congaree River where the greater flow and assimilative capacity was deemed adequate. The Joint Water and Sewer Authority for Lexington County was formed and has been building regional lines to the Cayce plant to accomplish this goal of cleaning up this state designated wild and scenic river. The 208 plan should clearly state the goal for the lower Saluda of having the regional sewer lines completed, the Cayce plant expanded adequately, and all current dischargers connecting into the regional lines as soon as those are available to them and the Cayce plant is ready for the additional wastewater load. And citizens would certainly not object to the regional lines going to the Columbia sewer plant if there were compelling reasons why that would be a better alternative to completing a regional system. Please refer to the attached Saluda River Chapter Action Alert of April 9, 2001 for further information on the chapter’s long term support of this overdue cleanup of the lower Saluda to better support its current uses.

-- The “208 Plan Update of 1996” and the “2001 Addendum” sections should both contain a full listing of the updates and addendums of those years. This is recommended because there were proposals supported by the COG that were not in support of the regional sewer system and this non-support needs to be documented so that the 208 plan accurately reflects the history that this section of the plan attempts to summarize.

-- There is overwhelming public support in the Columbia metro area for the lower Saluda to be cleaned up by removing dischargers and protected for future generations as appropriate for a state designated wild and scenic river. This support has been proven by the building of the new Saluda Shoals Park, the addition of the Botanical Gardens, including a bridge across the Saluda to the Riverbanks Zoo, and the new riverfront greenways at the mouth of the river by Columbia, West Columbia, and Cayce. None of these significant public river access areas were created with the idea that they would be built along a river whose water quality was several degraded by being overloaded from wastewater discharges. It is very unlikely that any of the entities would have built these facilities unless they envisioned a Saluda River that would be further cleaned up and made even safer for public use and enjoyment as a result of the completion of the regional lines. In light of the Saluda’s state wild and scenic status and these significant new major public areas along the river, it should be clear that the community’s wishes are not for a river to flow by these facilities that is filled with the maximum amount of wastewater it can assimilate; but, for a river cleaned up of wastewater dischargers and kept that way as insured by a 208 plan that clearly states these objectives.

--The 208 plan should clearly state for the lower Saluda River that no existing dischargers should be given any extensions in current permit ‘expiration’ dates; and, that no further expansion of existing plants should be allowed that would subsequently postpone connection to regional lines and complete shut down. It has been disturbing to learn of attempts to allow small wastewater plants that have consistently violated their discharge permits to be allowed to not only continue running, but to be granted time extensions for improvements and operation. And it is also disturbing that improvements and expansion of other existing dischargers have been linked to corrective measures at out of compliance plants. And it has been the most disturbing that the COG has not moderated factions better to have all entities embrace the goal of a regional system run by the Joint Water and Sewer Commission of Lexington County using the Cayce plant. It is perplexing that the city of Cayce still does not have approval for the needed expansion, and that other proposals as entertained in past 208 amendments that would essentially reject or ‘side track’ this regional system during the very time it is being built is certainly not the type of coordination of efforts expected of the COG to insure a sewer infrastructure for the midlands that is protective of water quality – which really means protective of our ‘quality of life’ in the midlands. There is no reason the infrastructure cannot be built without destroying the water quality of the lower Saluda which is in the best overall interest of the community – in fact, is even clamored for as the above new facilities along its riverbank prove.

Sincerely,

Malcolm Leaphart