HomeMy Public PortalAboutPollution Trading MemoPAYETTE LAKES RECREATIONAL WATER AND SEWER DISTRICT
201 Jacob Street • McCall, Idaho 83638
office 208-634-4111 • fax 208-634-7613
email: plrwsd@citlink.net
April 24, 2009
The Payette Lakes Recreational Water and Sewer District has been working with the City in good
faith to resolve the sewer issues facing the community.
Since November of 2008, key facility planning assumptions have been modified and both the
City and the District have worked closely with DEQ to further investigate pollution trading
within Valley County and obtaining a waste load allocation into the North Fork of the Payette
River. These investigations have determined that the costs and feasibility of a successful
pollution trading program or successfully obtaining a waste load allocation by 2017 are
unknown and contain a high amount of risk. An additional unknown amount of funds would
need to be expended to further quantify the feasibility of these disposal options without any
certainty of success.
We understand the city has every right to continue to investigate the feasibility of any options it
chooses. However, we also believe it is not fiscally prudent to spend additional money to
continue to investigate alternatives with unknown risks and costs that are unproven in Valley
County. We cannot participate in the continued feasibility analysis of alternatives for disposal
methods that rely on pollution trading or obtaining a waste load allocation until the certainty of
success is proven, hard data on actual costs are obtained, and impacts to the environment are
quantified with certainty to ensure that we are not increasing the amount of phosphorous in
the North Fork of the Payette River or Cascade Reservoir.
We think any discussion of a new mechanical plant is premature and not warranted until a
disposal method is proven and then only when the economic costs justify abandoning the
currently underutilized lagoon treatment plant.
Our cost analysis shows that replacing the J-Ditch non -permitted contracted land with DEQ
permitted land for the slow rate land application through agronomic application of Class C
treated effluent on cropland is the lowest cost option. It is also the least risky, most reliable and
only proven option for our ratepayers.
The land application approach as we have outlined in prior joint meetings is the most feasible
and responsible approach to address the immediate sewer issues facing our community. We
have come to this decision in a responsible manner and our engineering consultants have
worked closely with DEQ to obtain 'approved' planning design parameters to use in conjunction
with the current NDPES permit emergency discharge conditions. We see no benefit to further
re -analyzing this or other alternatives nor can we find any reason to alter the design parameters
and data we have used.
Board of Directors, Payette Lakes Recreational Water and Sewer District
Jerry Vevig, Carolyn Johnson, Ed Catlett, Bill Weida, Ross Mayfield