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		Letter to the Editor January 24, 2002 Name Withheld, Printed with Permission

What price to lower our area's water quality?

By Tom Paine (pseudonym for a Keweenaw resident who wishes to remain anonymous)

KEWEENAW -- February 6, 2002, is an important day because this is the close of the public comment period for the Mt. Bohemia ski hill's request to modify their Part 31 wastewater discharge permit. Black Bear is requesting to increase their annual discharge of phosphorus to Lac La Belle, and this increase may adversely impact the lake's water quality.

What price would you pay for potentially initiating the degradation of one of our most valuable resources, our water quality? Our water quality is the basis for many of the positive experiences we have with our families -- including fishing, boating, swimming and simply gazing onto a lake or stream. And now the state will soon make a decision that may potentially lower the quality of one of the special gifts we have in the Keweenaw Peninsula. This so our children can attend an annual "bikini contest" and have access to "Mardi Gras" drink specials that are coordinated by the ski hill. I don't know about you but I prefer to maintain our water quality.

The Mt. Bohemia ski hill currently has state authorization to discharge a specific amount of wastewater (845,000 gallons of wastewater every year) to a septic tank and drainfield. This treatment method does not remove significant phosphorus nor do the soils located underneath the drainfield. Thus, much of the phosphorus in the wastewater will eventually find its way to Lac La Belle. Phosphorus can lower water quality by increasing growth of nuisance plants and also increasing algal levels that subsequently result in lowered dissolved oxygen levels and reduced water clarity. At this time any noticeable effect will probably be localized, near the area where the septic discharge is hydrologically connected to the lake. However, if the ski hill develops a permanent lodge and housing, adverse effects might then be observed over a larger part of the lake.

Black Bear could construct a system to chemically remove phosphorus from the wastewater discharge; however, they are instead requesting to increase, by ten-fold, their discharge of phosphorus to the environment (see Editor's Note, below). A phosphorus treatment system would require additional funds for construction, operation, and maintenance. However, the Mt. Bohemia ski hill business venture has publicly stated it has lost a tremendous amount of money. It is well known that downhill skiing is a hugely competitive business environment; and, according to the National Sporting Goods Association, there has been a steady decrease in downhill ski participation in the United States over the past ten years.

The Michigan Department of Environmental Quality (DEQ) required that the ski hill submit an "anti-degradation" statement under Rule 1098(4). See the Keweenaw Liberty Library (Click on Correspondence) for a copy of the anti-degradation statement submitted by Black Bear. The reason for this anti-degradation statement is the DEQ wants to ensure that new sources of pollutants to a Lake Superior watershed -- pollutants that will potentially have an adverse impact on water quality -- demonstrate a social or economic benefit to the area.

The specific factors to be addressed in the anti-degradation statement may include any of the following seven items:

• employment increases; 
• production level increases;
• employment reductions avoidance;
• efficiency increases;
• industrial, commercial, or residential growth;
• environmental or public health problem corrections; and
• economic or social benefits to the community.

I encourage you to read the anti-degradation statement submitted by Black Bear. It is a one-page document full of general statements. It hardly appears to be a well thought out discussion of the tradeoffs between a controversial business venture and the water quality many of us enjoy on a daily or seasonal basis. Black Bear's anti-degradation statement also ignores the many social and economic benefits that we currently have that are a direct result of the high water quality of our lakes and streams. After you read the statement, I encourage you to write the DEQ and let them know your thoughts on this matter. Public comments will only be accepted until February 6, 2002.

Submit comments to:

Groundwater Program Section
Waste Management Division,
Department of Environmental Quality
P.O. Box 30241
Lansing, Michigan 48909
Phone: 517-373-2730
Fax: 517-373-4797

and to:

Marquette District Office
Waste Management Division
Department of Environmental Quality
1990 US 41 South
Marquette, Michigan 49855
Phone: 906-228-6568
Fax: 906-228-5245

Editor's note: Black Bear presently holds a permit allowing a total annual discharge of 3.6 lb. of phosphorus, or one tenth of the annual amount they are requesting (36 lb.) According to the DEQ Surface Water Quality Division, Rule 1098  requires an anti-degradation statement for this amount. Somehow this was left out of the septic discharge permit when it was applied for. Because it was left out, there was no public comment period on this document, and the DEQ could not grant the applicant the 36 lbs/yr. phosphorus discharge. However, Rule 1098 has a provision in it that states that if the discharge is less than 10% of the allowable limit, an anti-degradation statement is not required. Black Bear presently has a permit for 3.6 lbs/yr (i.e., 10% of allowed limit) and has now filed an anti-degradation statement with DEQ. The Public Notice for the anti-degradation statement was posted in early January and has a 30-day comment period. See the Dec. 11, 2001, article, Black Bear awaits DEQ septic permit, for background on this issue. See the Keweenaw Liberty Library for documents and correspondence related to the permit application. To read the Rule 323.1098 (4) anti-degradation statement, see  page 48 of the DEQ Surface Water Quality Division rules in pdf format.

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