February 1, 2018
My name is Krista Magaw. I’m the Executive Director of the Tecumseh Land Trust. Our land trust’s mission is to protect local farmland, water and natural areas forever. We have protected 42 stream miles and over 26,000 acres in the Clark and Greene County area, by collaborating with private landowners and local governments to establish permanent conservation easements. These easements restrict practices that diminish water and soil quality.
I speak to oppose the granting of a permit to discharge wastewater by Enon Sand and Gravel into the Mud Run and its tributaries. Within 3 miles of the proposed mining area, we have conservation easements on 4,377 acres; within the Mad River township we have preserved 1,986 acres and 4 stream miles.
One of those properties is immediately downstream of the proposed mining area, and contains a fen, in which numerous rare native animals and plants depend on consistent flows of cool ground water. Inevitably the discharge from the proposed operation would cripple or destroy this specialized habitat.
Overall, I oppose this permit on the basis that it has a good potential to contaminate ground water. In 2012, ODNR identified two karst formations along the Mud Run in this area. The porous nature and connectivity of the land and water table of karst terrain increases the possibility of ground water contamination in the larger area. In fact, this area of the Mad River watershed has a ground water pollution potential of 180-199, the 2nd highest rating in the entire watershed.
I further oppose this permit because the discharge of wastewater has a high potential to degrade the surface water quality. The lower branch of the Mad River which runs below Buck Creek, is designated by the EPA as Warm Water Habitat. The addition of wastewater could impair the creek to the point of violating ORC 3745-1-04 (A), which states surface water must be free from suspended solids or other substances that enter the waters as a result of human activity and that will settle to form putrescent or otherwise objectionable sludge deposits, or that will adversely affect aquatic life.
Ohio EPA released Mad River TMDL Report in 2010 as a “tool to help improve and maintain water quality and habitat in the watershed.” The Report recommended “stable stream morphology and watershed hydrology that approximates natural conditions… in all areas of the watershed.” A Watershed Action Plan to improve and safeguard water quality in the Lower Mad watershed was also written. I was surprised when I read in OhioEPA’s Citizen Advisory on tonight’s hearing that the proposed project “cannot violate Ohio’s water quality standards that protect human health and the environment.” If this is true, it seems apparent that the discharge permit should be denied.
Thanks for the opportunity to testify.