Reasons the IP wetland plan is bad

IP's Wetland Plan

IP wants to put its industrial waste in wetlands surrounding Perdido Bay. The area of 1,400 acres will be inundated with at least 0.5" of effluent. It will take the effluent 2 to 3 days to travel to Perdido Bay. 70% of the effluent will go through two small tidal lakes - Tee and Wicker Lakes.

Reasons the IP wetland plan should be rejected

The second permit is the basically unchanged from the first plan which was rejected by the judge.

The effluent is too dirty to be applied to wetlands without severly harming the wetland. The permit allows a BOD of 4,500 pounds per day. This is equivalent to 38,135 septic tanks going directly to the wetlands and Perdido Bay. This is also equivalent to a sewage treatment plant discharging wastes from 358,560 people to the wetland.
Click here for calculations

The permit allows 11,000 pounds per day of solids to be discharged to the wetland which will severely alter the hydrodynamics of the wetlands

The BOD and Total suspended solids (TSS) in the permit far exceed the concentrations allowed for domestic sewage in wetlands. Maximum allowable limits for domestic waste BOD and TSS in wetlands is 5 mg/l. The proposed BOD limit for IP's waste is 25 mg/l and a TSS limit of 58 mg/l.
Click here for graph

The amount of land is too small. According to DEP's wetland specialist, general treatment of wastewater effluent require 110 acres for every 1 million gallons per day (MGD) of effluent released. IP plans to release 23.5 MGD on the average. Hence the wetland should be 2585 acres instead of 1400 acres. For the maximum flow of 40 MGD, 4,400 acres would be required.

For treatment wetlands, DEP requires that the effluent stay on the wetlands for at least 14 days. IP's effluent will only remain on the site for about 3 days. Therefore, no or very little treatment of the effluent will occur.

The entire 1,400 acres of IP wetlands will be flooded with at least 0.5" of wastewater which will change the natural hydroperiod of the wetland.

Pilot wetland studies done by IP during the 1990's showed that only 2.5% of the trees survived for 5 years. The pilot wetlands turned into cattail ponds. We expect the wetland site to become a giant cattail pond.

1999 aerial photos of the wetland site show it had not been disturbed. In 2004, IP built logging roads and severly altered the hydrodynamics of the site.

Dr. Livingston (IP's biological consultant) testified that organic carbon from the mill caused low levels of dissolved oxygen in Eleven mile Creek. These low dissolved oxygen levels reduced fish populations. However Dr. Livingston did not even address the issue of low dissolved oxygen in the wetlands.

Diverting 70% of the effluent through the small Tee and Wicker Lakes will severly alter the habitat of the lakes

The lack of environmental enforcement by DEP in the past indicates that DEP will ignore any problems which are sure to occur. IP has been allowed to operate on an expired permit since 1995. No fines have been levied against the mill since 1999 for violations in the creek. Will the pipeline be removed if the bay and wetlands are harmed? No.
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