Montgomery County Group

 

 

Dear Delegate :

 

Very soon Montgomery County's Clean Water Act MS4 permit will be renewed, and those of other counties will follow.  The Sierra Club is one of about 20 civic and environmental organizations that have joined forces to try to make Montgomery County's MS4 permit the meaningful instrument the Clean Water Act intended it to be.  Please see below the letter I mailed to Secretary Philbrick on Monday (via paper mail).   We look forward to any insights and help you can provide.   A strengthened Montgomery County permit will set a precedent for the other Maryland counties. One great beneficiary will be the Chesapeake Bay, of course, but Montgomery County will also directly benefit through savings on water filtration and stream remediation and improvement of quality of life for all those who seek recreation or renewal in our stream valley parks.  I can be reached at 301-946-5599 or by e-mail.

 

Sincerely,

 

Anne Ambler, Chair

 

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October 16, 2006

 

The Honorable Kendl P. Philbrick

Secretary

Department of the Environment

1800 Washington Blvd.

Baltimore, MD  21230

 

Dear Secretary Philbrick:

 

I am writing to you on behalf of the more than 6500 members of the Sierra Club in Montgomery County, who value their water resource as a critical element in short-term quality of life and long-term sustainability of the county.    As I’m sure you are aware, Montgomery County has many major streams originating within it that empty eventually into the Chesapeake Bay.  The county established parks along many of these streams, affording them some measure of protection.  However, one has only to look at the murkiness of the water and t he speed at which the level rises during the slightest rain to realize that this protection is not nearly enough.

 

As we have sprawled across the landscape, building ever more roads and shopping malls to serve outlying areas, we have covered far more land with impervious surfaces than our waterways can survive.  While urban stormwater pollution has become the fastest growing source of pollution to the Chesapeake Bay, it has few controls to limit its damage.  The result is that two-thirds of our waters are too contaminated to drink or swim in.  Fish, if they can survive in them at all, are covered with sores and risky to eat. This is a disgrace.

 

The Sierra Club has been working with some 20 other environmental and civic organizations alarmed at the lack of progress we have been making in fulfilling the intent of the Clean Water Act. Why do we stand for leaking an estimated 5 million gallons of oil and grease into the Bay each year? Why do we put up with construction sites that send over 100 times more dirt per acre into the Bay than typical farms, which themselves could be improved.  Why do we subject rowers on the Anacostia to bacterial infections  from feces?  Why do we allow trash to periodically cover portions of the lower Anacostia River from shore to shore? Why do we continue to bui ld in such a way that water, unable to infiltrate, rushes into streams at such high velocity that banks are scoured away, fish cannot breed, and good soil is permanently removed?

 

You have the power and the authority to set us on a different track, one that will mesh well with other changes we must make in the face of rising sea levels that threaten the agricultural viability and very existence of low lying areas of our state. 

 

We must start by taking advantage of the Clean Water Act MS4 permit renewals to set clear, measurable pollution limits with timed intermediate goals.  When the realization that the Nation’s waterways were severely degraded was new, a work program that spoke of encouragement and effort may have been appropriate; it has now ceased to be appropriate.  Now we need a different kind of permit, one that addresses stormwater pollution control on each site.  It is ultimately fruitless, as well as fiscally irresponsible, to stick taxpayers with endless ripwrap “remediation” and costly new mid-river intakes and filtration plants when changes in building design and placement, forested buffers, widespread raingardens, and other infiltration techniques can produce a better result .

 

We are seeking five key changes to the permit:

 

            1.  Incorporate numeric, watershed-based pollution caps known as “Total Maximum Daily Loads,” along with action and monitoring plans to meet them.

 

            2.  Require a set of code changes to ensure that new greenfield developments and all redevelopment projects use what is known as “Environmentally Sound Design.”

 

            3.  Require that 25% of the county’s degraded subwatersheds be restored through on-site Low Impact Development (LID) techniques during each 5-year permit term.

 

            4.  Honor MDE’s (and the counties’) commitment to a trash-free Potomac by 2013 through required annual trash reductions of 15% per year from baseline, using such means as recycling enforcement and trash traps.

 

            5.  Require adequate flow gauging and monitoring countywide to a) track and limit stormwater flow volume and velocity, flood frequency, and baseflow impacts; and b) track the benefits of on-site LID controls for entire subwatersheds.

 

We members of the Sierra Club in Montgomery County have come to the firm conclusion that business as usual is simply not good enough.  I hope you will share our excitement  at the now rising public demand for state and local U.S. governments to address the significant challenges our society faces in the 21^st Century.   Luckily, the strategic elements align rather than conflict.  We look forward to your help in making the Clean Water Act permit the effective clean water instrument it was intended to be. 

 

Sincerely,

  

Anne Ambler, Chair

Sierra Club, Montgomery County Group