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The City and County of Honolulu hand delivered its response to the U.S. Environmental Protection Agency today regarding its tentative decision to deny continuation of the city’s 301(h) waiver excluding Sand Island Wastewater Treatment Plant (SIWWTP) from secondary treatment.

“The tentative decision by the EPA is not only unreasonable and unnecessary, but it would place a huge financial burden on our taxpayers,” Mayor Mufi Hannemann said.  “A global settlement has been my goal, focusing on our aging and neglected collection system.”

The city received its first waiver in 1991, and the EPA granted the city its current waiver in 1998.  The EPA has reversed its position even though the reliability of the SIWWTP today has improved since 1998 to meet the waiver conditions and more than a decade of monitoring the environment at and around the outfall as well as reference stations confirms no detrimental impact from the discharge.

The city provided significant data and information in support of its position for continuing the waiver. 

Part I of the response provides a brief overview of the City’s analysis of EPA’s TD, and the bases for the City’s conclusion that the TD is arbitrary and unreasonable.  The EPA granted the City its current waiver in 1998, and now reverses itself even though (1) the reliability of the SIWWTP today to meet the waiver conditions has improved since 1998 and, (2) more than a decade of monitoring the environment at and around the outfall and at reference stations confirms no detrimental impact from the SIWWTP discharge.

In Part II, the City discusses in detail the nine criteria that the EPA must consider in its decision, pursuant to the Clean Water Act.  It specifically refutes the three bases for the EPA’s decision:  (1) pesticides chlordane & dieldrin, (2) ammonia, (3) whole effluent toxicity (WET) tests.

First, pesticide levels are either within EPA’s own recommended criteria for the protection of human health or are false positives.  Second, the allegedly high levels of ammonia are based on an erroneous application of the applicable water quality standards and are contradicted by real-world evidence from the marine environment.  Third, the species identified

by EPA for determination of existing SIWWTP Permit and water quality standard compliance, Ceriodaphnia dubia, consistently passes WET evaluations. In contrast, the species relied upon by EPA’s denial – T. gratilla – has not been approved by EPA as the basis for water quality standard compliance determinations.

            Part III, discusses the economic impact of the costs of secondary treatment, in light of the financial hardships that Oahu’s citizens already face.  It urges the EPA to evaluate Oahu holistically, and to consider the commitment the City has made to upgrading its collection system.

“The city made an extremely strong case for continuing the waiver that has been in place since 1998,” Mayor Mufi Hannemann said.  “I want to personally thank the more than 60 scientists, researchers and wastewater engineers that testified earlier this month.”



Markus Owens, 768-3454

Monday, April 21, 2008

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