Protect Valley Creek and the St. Croix River from Pollution!
Protect Native American Cultural Resources from Destruction!
The sewage project is located just 300 feet from Valley Creek!
No spill plan is in place and there is no plan for endangered species!
February 16th, 2017 is the last day comments will be accepted by the Minnesota Pollution Control Agency (MPCA) and will be our last chance to have any say as to what happens at the Valley Creek sewage treatment site. We believe this is truly a special place and are guided and committed to protect it. Please find MPCA contact details and suggested bullet points at the bottom of this letter.
The Rattlesnake Mound was a main source of concern in the initial stages of this campaign, as Afton’s plans showed several sewage pipes being drilled through its outline. Following tribal consultation, Afton recently announced that it would be avoiding any construction near the main body of the mound, rerouting pipes away from the mound, and having a smaller stormwater pond! Victory! Focus now turns to the proposed sewage treatment facility near Valley Creek.
In response to one of our data requests, Citizens for Valley Creek obtained a briefing by the Minnesota Pollution Control Agency (MPCA) to the Governor of Minnesota. In the briefing, the MPCA revealed that in June 2014, after very heavy rains, 84 similarly-designed sewage treatment facilities across Minnesota failed. During that same period, the City of Mound dumped raw sewage into Lake Minnetonka to avoid residential sewer systems backing up. The lake became unswimmable and, two years later in 2016, E. Coli was detected (transmitted via feces). Were a similar event to happen in Afton, the ecology of nearby Valley Creek and the Saint Croix River would be decimated. Polluted wells could poison the local aquifer system.
Even without a catastrophic event, the facility is slated to impact nearby bodies of water. Many new pollutants will be introduced into the groundwater, including chemicals poured down drains by businesses and restaurants, and pharmaceuticals, narcotics, and hormones flushed or secreted by residents into home toilets.
The Afton project, even during normal operation, is expected to increase nitrogen levels in the water to the maximum permitted by law, 10 mg/L. Even before we consider the impact of heavy rains washing additional fertilizers off farm fields into the creek, or the impact of heavy rains on the proposed facility, Afton’s plan is to pollute the creek to the maximum level permitted by law.
The City of Afton’s project proposal avoids addressing major issues. The sewage drainage field is located within 300 feet of Valley Creek, officially designated protected “shoreland”. No explanation has been given by Afton as to what will be done to comply with shoreline ordinances, or how the groundwater wells—also just 300 feet away from the drainage field—will be protected from chemical and other hazardous waste. Hydrologist Stu Grub from Oakdale-based environmental consulting and water resources engineering firm Emmons & Olivier Resources states that that the 300-foot setbacks from wells still aren’t enough to guarantee the safety of the drinking water.
In a February 2015 letter from sewage project engineers Wenck Associates, Inc., in response to questions posed by the Minnesota Pollution Control Agency (MPCA), it became clear that Wenck Associates did not consider the tributary which feeds into Valley Creek—just 300 feet from the proposed sewage drainage field—to be “nearby surface water”:
MPCA: “Please identify the nearest surface water to the proposed LSTS, its direction and distance.”
Wenck Associates’ response: “The nearest surface water is Valley Creek which is located 1,550 ft. southerly of the proposed LSTS.”
Of course, any sewage spill from the field into the nearby tributary will end up in Valley Creek just 1,200 ft. further downstream and, beyond that, in the St. Croix River.
In the same letter, the MPCA had asked Wenck to detail the spill prevention plan. Wenck’s response was that “A Spill Prevention, Control and Countermeasure (SPCC) plan is not required for the LSTS facility.“
The Valley Creek watershed is home to more than twenty already-endangered, threatened, and special concern species, including wolves, the Red-shouldered Hawk, Bald Eagle, Peregrine Falcon, Common Snapping Turtle, Blanding’s Turtle, Louisiana Waterthrush, Eastern Hognose Snake, Karner Blue Butterfly, and the American Brook Lamprey. Valley Creek itself is recognized as one of the best trout streams in the United States.
From the same letter:
“The design lacks any plan to survey for endangered birds. Henslow’s sparrows, and endangered species, reading nearby Afton State Park. The grasslands habitat of the site may be attractive to these birds during the breeding season. The presence of any state or federal threatened and endangered species within the proposed site will impact construction and operations.”
The St. Croix River has been known for thousands of years by the Dakota people as Hogan Wanke Kin, or “the place where the fish lies”. The presence of a known quartet of natural and man-made spiritual markers–Catfish Bar, the Rattlesnake Mound, the mouth of Valley Creek, the pointing trees, and other areas likely within and immediately adjacent to the proposed treatment facility–suggests this section of the river is as potentially significant to the Dakota people as Jerusalem is to Christians, Muslims, and Jews. Without a full archaeological survey of the Native American presence in the area, there is a danger that an important cultural history will be destroyed irrevocably.
An archaeological survey of an adjacent location to the proposed sewage drainage field by Rothaus in 2008 reported an unusually high concentration of Native American cultural artifacts. Construction will result in the destruction of cultural resources potentially equivalent to ‘a museum on a hill’.
Afton did not adequately address alternative site locations. The existing site was selected primarily because there was a willing seller, which does not constitute adequate research for the project from an environmental perspective.
There are other options available. Afton could move the planned septic site to a location that does not cross three streams with sewage pipes, a location far from drinking wells, and which cannot spill and overflow into Valley Creek in the event of heavy rains. A decentralized solution would be safer. There are many simple, cheap, environmentally sound alternatives that will not have a negative impact on our water.
The Valley Creek sewage septic site is arguably the worst possible location to have chosen. The sewage lines run almost two miles upstream and cross three healthy and clean streams. The location is a ticking time bomb that—when it explodes—will create an environmental and economic disaster that will persist for generations.
By February 16th, 2017, please contact Corey Mathisen at the Minnesota Pollution Control Agency (MPCA) via firstname.lastname@example.org and demand that the City find an alternative location for the sewage drainage field or explore alternative systems.
Mistakes in the original May 2013 plan for the sewage drainage field, which ignored some of the existing wells, have resulted in an even less viable site, with less margin for error, where even more fresh water wells are threatened. Due to this remote location, the pipes to the sewage drainage field needlessly run two miles uphill and cross three streams before reaching the field.
Remind the MPCA that, according to its own briefing to the Governor of Minnesota, 84 similarly-designed plants failed during the June 2014 heavy rains in Minnesota. Please ask for further investigation into human drinking well water setbacks from the sewage plant, note the plant is located just 300 feet of Valley Creek posing a threat to the Creek, the St. Croix River, and the endangered species present in the area are all too important to jeopardize.
Decentralized, modern, ecologically-friendly alternatives exist. A solution is needed that does not expose the waterways to danger from contamination and pollution.
Express concern about the loss of Native American cultural resources during the construction process. Ask that the City of Afton follow the Traditional Cultural Properties (TCPs) guidelines set by the National Register of Historic Places to conduct a full archaeological survey of the 25-acre sewage drainage field to preserve cultural artifacts, in consultation with tribes.