Mobile Baykeeper Submits Comments on Sewer Line Proposed to Go Under Fish River
Today Mobile Baykeeper submitted comments to the Corps on a plan to bore a sewer line under the beloved Fish River.
Baldwin County Sewer Service is proposing to put a 10” sewage line under the Fish River, a river utilized by many community members to fish, swim, and recreate in. Fish River ultimately flows into Weeks Bay, an area where many research and monitoring efforts occur. Mobile Baykeeper and our members have raised significant concerns with this project.
Allowing a sewage line under Fish River, would create the potential for a massive sewage spill. It is well noted that Fish River is a flashy waterway, flooding forcefully during large rains. The potential for erosion of the riverbed is enormous and the proposed line’s depth of ~10ft below the bottom of the river would create a dangerous risk of breaking during floods causing a sewage spill into Fish River. A large flood event, such as the ones that occurred on April 29, 2014, during Hurricane Danny, or during other major rain events has a very serious potential to expose and break or damage the sewage line.
This danger of rivers exposing buried pipelines through scour has been repeatedly demonstrated in spills such as:
- An Enterprise Products Partners LLP pipeline that was uncovered by river scouring and ruptured in August 2011. The line spilled more than 28,350 gallons of a gasoline additive into the Missouri River.
- In June 2012, a Plains Midstream Canada pipeline failed along the Red Deer River and released more than 122,000 gallons of light crude. The pipe was uncovered by scour during high flood waters and failed.
- The Poplar (Jan. 2015) and Silvertip (July 2011) pipeline failures on the Yellowstone River.
BCSS is planning to use a type of pipe known as HDPE; while we appreciate the use of a HDPE material for the pipe (it is better than some other materials commonly used for sewage pipes), the eventual failure of these pipes has been well documented. HDPE can catastrophically fail due to defects in the manufacturing process and they also pose a threat for premature failure when chemicals degrade the material, particularly in warmer environments. These issues are similar to ones faced by Mobile Area Water and Sewer Service (MAWSS) and the Emerald Coast Utility Authority (ECUA) who have both recently experienced pinhole leaks in HDPE lines due to chlorine degradation. Raw sewage may be high in chlorine content due to chlorination of municipal water supply and the use of common household bleaches. This makes it possible that if permitted, at some point in the future, this sewer line will have a leak, break, or rupture, causing significant and severe pollution to Fish River and Weeks Bay.
We feel the project is not in the interest of the community for the following reasons:
- A broken sewage line at this location would cause serious public health effects.
- Sewer spills could cause die-off of fish, bugs, and result in serious impacts to the food web in Fish River and Weeks Bay
- Chemicals in sewage have detrimental effects to fish and wildlife using Fish River & Weeks Bay.
- A sewage line rupture would result in increased presence of bacteria and viruses, decreased levels of oxygen, elevated levels of nutrients, accumulation of household chemicals (cleaners, pesticides, herbicides etc.), and algal blooms resulting from nutrients present in sewage.
- The project would impact the local economy through decreased property values from the presence of a sewage line under the river and the opportunity for a line rupture.
- The project would diminish the high recreational value that this area serves. The river is known as a popular source of recreation for the residents of Fish River and Baldwin County for hunting, fishing, boating, and swimming.
These effects would undo thousands of man-hours and millions of public and private dollars that have been expended by numerous federal, state, and local entities, Weeks Bay Reserve, and the Weeks Bay Foundation to improve and protect Fish River and Weeks Bay.
We think that this project is inappropriate for a nationwide permit. A nationwide permit is used to regulate activities having minimal adverse impact on the environment. The installation of a line at this location has the potential to directly cause more than minimal adverse effects on the environment due to:
- Direct impacts from the boring of the sewer line, including drilling mud and its additives polluting Fish River.
- Indirect impacts from a ruptured line to human health, fish and wildlife, and our ability to recreate (swim, fish, hunt, and boat);
We also have concerns about:
- The potential harm to threatened or endangered species;
Endangered species documented in the Fish River Watershed include: Gopher Tortoise (Gopherus polyphemus), Red Bellied Turtle (Pseudomys alabamensis), Mississippi Diamondback Terrapin (Malaclemys terrapin pileata), West Indian Manatee (Trichechus manatus), Eastern Indigo snake (Drymarchon corais couperi)
- Threats to historical and cultural resources;
- Known potential historical properties include the Marlow Ferry and Farragut’s Basin. Farragut’s Basin was the farthest north site on Fish River where ships would turn around during the Battle of Mobile Bay in the Civil War. Additionally, there were close to eight ferries and five landing locations, suggesting high possibility of civil war camps and other artifacts in the immediate vicinity.
Finally, and potentially most importantly, there are other reasonable alternatives available.
The Corps requires applicants to demonstrate that there is no practicable alternative and “provide detailed, clear and convincing information proving impracticability”.
Practicable alternatives include but are not limited to:
- It is our understanding that the City of Fairhope, which originally constructed the collection system, is open to buying the system back from BCSS if BCSS will sell it for a reasonable price. This would be the best solution as it keeps the sewage from crossing the river and Fairhope Utilities is already treating the collected sewage from the customers at stake.
- It is our understanding that the City of Fairhope would be amenable to entering into an agreement for long-term treatment of the collected sewage if BCSS will rengotiate the agreement to a reasonable cost.
- The sewer force main could be routed north, connecting to existing BCSS line along US Highway 181 or Highway 104 utilizing crossings of the Fish River that have already been bored.
- The sewer force main could cross over the County Road 32 Bridge across Fish River. It would then be visible and any sewage leakage could be immediately detected.
The information above shows that reasonable alternatives exist requiring rejection of the permit application.
If the project does go forward we want to see measures to minimize impacts and the potential for sewage line breaks or leaks. These include but are not limited to:
- BCSS paying for an independent audit of the plans and procedures that will be used to conduct the boring activities, prevent spills and leakage once installed, be aware of issues with the line, and operate the system in the vicinity of the newly installed line;
- Having an independent auditor review the installation of the line during execution of the project;
- Encasing the line in a larger diameter protective line as prescribed by best practices;
- Posting a bond in an amount exceeding the largest amount of damage that could potentially be done to Fish River if a rupture of this line were to occur;
- Install automatic remote shutoff valves at both ends of the line;
- Install high resolution SCADA to monitor flows in the area of the proposed activity;
Mobile Baykeeper and its members have requested a public hearing be held on this project. We feel this project proposal has generated enough concern and public interest to necessitate a public hearing. We encourage you to voice your comments and concerns about this project to the Corps.
If you would like to submit your own comments, you can use the form above or send an email and/or letter. If sending your own email or letter please reference the project code SAM-2017-00342-SBC (otherwise they will be lost). Comments must be received by April 21st.
Please feel free to use the information at the bottom of the page to construct your own written letter or you can submit a pre-constructed letter using the form above.
We have also included a copy of our full comments below. Since nationwide permits do not have public permit applications, unfortunately, we are unable to provide a copy of the permit application.
To send your own comments -
Mail to: U.S. Army Corps of Engineers
Mobile District, CESAM-RD-A/Crosson
P. O. Box 2288
Mobile, AL 36628-0001
Comments Must Reference: SAM-2017-00342-SBC
Only Written Comments Accepted