The Hanover County Board of Supervisors proposes to construct a wastewater treatment plant and Pamunkey River discharge for an initial capacity of five million gallons per day and an ultimate capacity of thirty million gallons per day.
The Pamunkey River already fails to meet minimum water quality standards, and the proposed discharge will make this situation worse.
In its review of the project, the Virginia Institute of Marine Science expressed concerns about discharging more than five million gallons per day into the Pamunkey.
The proposed discharge would contain large quantities of additional, oxygen-consuming pollutants and fecal coliform, even though the River is already officially "impaired" for those pollutants.
In 1999 the U.S. EPA officially designated the Pamunkey River as "impaired," owing to its persistent failure to meet minimum levels of dissolved oxygen.
The Virginia Department of Environmental Quality acknowledged that the project will contribute to the dissolved oxygen problem in the Pamunkey.
In 2001 the U.S. Geological Survey released a report that determined the Pamunkey River leads all tributaries of the Chesapeake Bay as having shown the greatest increase in point source pollution from discharges (a 457% increase).
In its July, 2002 report entitled "Water Quality Assessment and Impaired Waters Reports," the Virginia Department of Environmental Quality designated the Pamunkey River as impaired for the presence of Fecal Coliform.
An American Shad Fish Hatchery operated by the Pamunkey Indian Tribe (approximately 10 miles downriver from the proposed discharge site) could be threatened. The hatchery is the oldest of its kind in the nation.
The Corps has not yet been advised of and has not yet examined all of the discharges of fill and destruction of wetlands that will be needed to convert the County's wastewater system from part of an integrated, regional system into an independent, stand-alone operation.
The County proposes to divert wastewater flows currently collected near the banks of the Chickahominy River and pumped to Henrico County by pumping them back to Hanover County instead.
Construction of the planned Lower Chickahominy Gravity Sewer alone will cause several acres of wetland destruction.
Better alternatives exist and have not been explored adequately.
Cooperation with neighboring localities to expand and improve existing treatment minimizes both the cost to taxpayers and the impact on the environment.
Construction of the proposed discharge may harm historic resources.
The potential impacts on fish and wildlife that depend on the river have not been examined sufficiently.
"The arc of the universe is long, but it bends toward justice." --MLK, Jr.