Tip of the Mitt Watershed Council has taken criticism from other environmental groups in the region for not opposing a plan to dispose of contaminated groundwater from the Bay Harbor development by pumping it into a 2,000-foot-deep well near Alba. Below is an opinion piece in which policy specialist Jennifer McKay defends her organization’s position.
At the recent public forum held in Alba to discuss the deep injection well, many individuals stated that the cement kiln dust (CKD) contamination and cleanup along Little Traverse Bay is not a Petoskey or Alba issue but is a Northern Michigan issue. Tip of the Mitt Watershed Council couldn’t agree more. Little Traverse Bay and Star Township are both located within the Watershed Council’s service area and therefore, we are dedicated to ensuring the protection of the water resources in both areas and throughout Northern Michigan. With that in mind, we would like to further explain our position and role with respect to the injection well proposed for Alba and the cleanup efforts at Bay Harbor properties and East Park.
Tip of the Mitt Watershed Council has been actively involved with the CKD contamination and cleanup efforts along Little Traverse Bay for almost 20 years. During the course of those twenty years, we have learned that the issue is highly complex and intricate and with no easy solution to address the contamination. Over the past 2 1/2 years, our level of engagement and action has been greater than ever before with meetings with involved parties on a regular basis, reviewing thousands of pages of documentation on the extent of contamination and potential remedies, educational efforts to build public awareness, and participation in state and federal permitting processes.
During the permitting process for the deep injection well, the Watershed Council has been present at all public meetings taking all of the concerns expressed into consideration. Some concerns have not fully been addressed with respect to both the injection well and the ongoing cleanup efforts. The Watershed Council also shared concerns with the injection well and we provided recommendations to the regulators to address those concerns. We are pleased that the permit for the deep injection well was modified based upon our recommendation to include additional monitoring and reporting of the fluids to be injected into the well. However, the EPA and DEQ did not include other recommendations made by the Watershed Council that would have further minimized the potential adverse impacts associated with the deep injection well. While the Watershed Council would have preferred to have all of our recommendations included as part of the permit conditions, we do not feel that the appeals process will result in the outcome we desire. This is due to the limitations in the current regulatory process for injection wells. The current regulations have an extremely narrow scope and do not require factors beyond technical integrity of the well and geology to be taken into consideration during the decision process.
Given these limitations in the regulatory process, the Watershed Council has been concentrating on more effective means to come up with the best solution for the natural resources and citizens of Northern Michigan. The Watershed Council has been actively working with the involved parties to ensure the cleanup is done properly and thoroughly to protect public health and environmental quality. We have been evaluating all the proposed solutions and potential alternatives such as removal of the CKD, upgrading existing wastewater treatment plants, reducing the volume of leachate collected through groundwater diversion, and researching mercury treatment options and other emerging technologies. By evaluating all the possibilities, it may be possible to come up with a remedy that may not require use of the deep injection well or discharge to Lake Michigan.
Given the complexities associated with the contamination and cleanup, we recognize that the final solution will not be a one-size-fit-all answer. Rather we believe the solution will have to be a multifaceted approach incorporating a combination of activities. The Watershed Council has and continues to take a long-term and holistic approach to ensure the protection of Northern Michigan’s waters for generations to come. This approach requires that we must always keep the big picture in mind, recognizing the entire breadth of the issue and the difficulties such a large-scale endeavor will face.
We will continue to work in this context in coordination with all of the parties as we feel it provides a way to achieve the outcome we all want – protecting our Northern Michigan environment, economy, and way of life.