SUD Objects to Release of Funds to Grundy County

    The Sewanee Utility District (SUD) moved swiftly and decisively in reacting to  Grundy County Mayor LaDue Bouldin's attempt to break with those who favor  regional water planning. It was learned through a legal notice that appeared in a recent edition of the Grundy County Herald that Bouldin is applying  to Tennessee Department of Economic and Community Development (TECD) initially for one million dollars in Federal Funds for the much discussed pipeline from the Tennessee River to the South Cumberland Plateau. This "go it alone" move seems very much counter to the efforts by Tennessee Department of Environment and Conservation (TDEC) to move forward on regional water planning. TDEC's efforts have included SUD, Monteagle, Tracy City and Big Creek along with the Army Corps of Enigineers.

    The SUD objection is based on:

        1. Failure of Grundy County to provide an Environmental Assessment based on National Enviromental Policy Act of 1969 (NEPA)

        2. Failure of Grundy County to provide  a copy of the Environmental Review Record (ERR) referenced in the  legal notice, when requested by  the public

        3. Negative environmental impact of millions of gallons of additional effluent discharge on Monteagle's long failing sewer system.

        4. Failure to consider the the comprehensive and long term financial impact of the project.

    SUD's previous position on the pipeline was approved by the board on February 12, 2008. A copy of this will be found in the blog entry dated March 16, 2009.

    The complete and detailed text of the SUD objection is published below.

To:  Tennessee Department of Economic and Community Development (TECD) 

Office of Program Management 

William R. Snodgrass Tennessee Tower, 10th Floor 

312 Eight Avenue North 

Nashville, TN 37243-0405 

 

Tennessee Department of Environment & Conservation (TDEC) 

Division of Water Supply 

Attn: Robert L. Foster, Director 

6th Floor, L&C Tower 

401 Church Street 

Nashville, TN 37243-1549 

 

Grundy County Government 

Attn: LaDue Bouldin, County Mayor 

P.O. Box 177 

Altamont, TN 37301 

 

From:  The Board of Commissioners of the Sewanee Utility District of Franklin and 

Marion Counties 

 

Project Background & Known Facts: 

 

The proposed project is to build a 16-inch pipeline along TN 156 from South Pittsburg to 

Monteagle to deliver three million gallons per day of treated freshwater drawn from the 

Tennessee River. The final cost of this pipeline is estimated at approximately $20 

million, however; the long-term O&M costs have not been evaluated. The rationale for 

this pipeline is given as a water shortage on the southern Cumberland Plateau during the 

100-year drought experienced in 2007-08. 

 

Objections To Release of Funds: 

 

1. The certification by Grundy County that this project will have no significant impact 

on the human environment, to date is not supported by any documentation made 

available to the public.  We believe that this project requires an Environmental Impact 

Statement under the National Environmental Policy Act of 1969 (NEPA). 

 

• Currently, the Army Corps of Engineers, under the direction of TDEC, is 

conducting a regional water resources planning study in conjunction with the 

public utilities on the southern Cumberland Plateau, including the Tracy City 

and Monteagle water utilities serving customers in Grundy County and 

Marion County; the Big Creek water utility serving customers in Grundy 

County, Marion County and Sequatchie County.  This Regional Water Study 

is important because any water augmentation project initiated by one water 

utility could potentially produce an adverse environmental impact on the 

entire southern Cumberland Plateau and result in adverse financial impacts on 

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the other water districts in the region. The study has not yet concluded that a 

pipeline from South Pittsburg to Monteagle, transporting millions of gallons 

per day, is a responsible solution at this time or that it is environmentally 

benign, given the southern Cumberland Plateau’s environmental 

characteristics. 

 

• Presently, the number of perennial streams (year-round flow) on the southern 

Cumberland Plateau is inadequate to receive additional millions of gallons per 

day of effluent without impairing the environmental characteristics of the 

streams and producing potentially adverse affects on the surrounding human 

environment.   

 

• Based on experience during the 2007-08 hundred-year drought and known 

demand forecasts for the southern Cumberland Plateau, there may be no need 

for additional water supplies for fifty-years or so beyond those contemplated 

by Tracy City and Big Creek and presently held by SUD.   All these utilities 

are connected to Monteagle via existing distribution pipes.  Until regional 

water supply planning is completed, it will not be known if this assessment is 

correct or if additional water supply augmentation is necessary. 

 

2. Grundy County has failed to make an accurate and defensible decision of Finding of 

No Significant Impact. After repeated attempts, we have been unable to obtain a copy 

of the Environmental Review Record as referenced in the February 26, 2009 notice in 

support of this position. 

  

• The ERR should include an adequate analysis of long-term demand forecasts 

and safe yield requirements for each utility district so as to determine 

withdrawal needs for each utility to assist in determining the fair 

apportionment of the capital costs of the pipeline, as well as the ongoing 

operating and maintenance costs over the life of the pipeline. 

 

• The ERR should include an adequate analysis of the final cost of the Southern 

Cumberland Plateau Permanent Water Source Development Project and its 

costs/benefits relative to other options for obtaining new supply.  The 

engineering costs of those options must be adequately studied to determine the 

final cost and the ongoing operating and maintenance costs of those 

infrastructure improvements, including the pipeline, necessary water treatment 

facilities at South Pittsburg, and wastewater treatment infrastructure at 

Monteagle.  It should evaluate whether these construction, and operating and 

maintenance costs are affordable by Grundy County, Monteagle, and the other 

water utilities on the Plateau in order to meet ongoing environmental 

permitting requirements to prevent endangering the environment of the 

Plateau. 

 

• The ERR should have a determination from TDEC that the transfer of water 

from the Tennessee River to the southern Cumberland Plateau does not                                                        

(Page 3) 

constitute water use outside a "redline" basin that requires an additional 

permit from the State of Tennessee beyond ARAP & 401 certification. This 

pipeline may require an additional permit if parts of the counties to be served 

fall on the other side of these red lines, which, if that is the case, will require 

such permits before any pipeline can be contemplated. 

 

• The ERR should have a determination from the Tennessee Valley Authority 

(TVA) that the long-term potential to withdraw 3MGD from the Tennessee 

River exists and that TVA would grant a permit for these withdrawals. During 

the recent drought, the river flow has been inadequate to cool TVA’s twelve 

coal-fired plants and five nuclear plants.  

 

3. The United States Environmental Protection Agency (USEPA) may decide to provide 

a written finding pursuant to 40 CFR Part 1504 that the project is unsatisfactory from 

the standpoint of environmental quality due to the failure of the City of Monteagle to 

meet its existing permit restrictions for effluent discharge from its two wastewater 

treatment plants over an extended number of years. 

 

• Presently, there are no year-round streams on the southern Cumberland 

Plateau into which additional millions of gallons per day of effluent may be 

discharged without impairing the environmental characteristics of the streams 

and producing potentially adverse affects on the environment. 

 

• Tracy City relies on wastewater treatment by Monteagle.  Monteagle is 

currently under a TDEC-mandated moratorium that prohibits new connections 

to its two wastewater treatment plants, and the Sewanee Utility District is 

under a TDEC-mandated moratorium that prohibits new connections to its 

wastewater plant. 

 

4. The financial impact of this project will be shared by all the water utilities in the 

region. We do not believe that our customers would tolerate incurring these costs 

without studying the alternatives.  

 

We, the Commissioners of the Sewanee Utility District, believe the most prudent path to 

true regional water planning would be to continue to pursue the resolution as passed by 

our board on February 12, 2008. (Attached)  As our resolution states, we need a Regional 

Water Plan.  A pipeline is one possible solution, but we must examine all alternatives for 

the region before moving forward with any one solution.