The Gunpowder River is truly a gift of shared waters. As a 1977 Baltimore Sun article penned by Michael Wentzel and Michael Shultz once related; “The Gunpowder is the River you Drink.” So with that context in mind it’s important to relate that Baltimore County has 2,100 miles of streams a majority of which hold native brook trout and wild brown trout. Notably, over 1,000 miles of tributaries drain into the Reservoirs that providing drinking water for 1.8 million Baltimore-metro area residents.
In 2013, Gunpowder RIVERKEEPER saw the end of four commercial tubing shuttles along the upper Gunpowder River. By their own estimations the two vendors had claimed that they were renting up to 400 tubes a day each. The shuttles routinely dropped off patrons every 20 minutes in a 75 to 100 foot wide, 2.2 mile stretch of river between the catch and release section at the designated Wildlands Areas of Gunpowder State Park and the two fish a day section of stream to Monkton Station along the NCR (now Torrey Brown) trail. In the end, the county zoning ordinances failed to support the livery services that had put too much pressure on this vital resource to sustain shared uses like fishing, boating and traditional tubing by families.
As the River and its uses returned back to a more balanced state this spring, this shared waters perspective became even more revealing when Gunpowder RIVERKEEPER® began submitting environmental comments and intervening in the (Federal Energy Regulatory Commission (FERC) application for the Columbia Gas Transmission (CGT) Line-MB interstate gas pipeline project.
The CGT Line-MB is a 26” diameter, 21.1 mile long Interstate Natural Gas Transmission line from Owings Mills to Rutledge impacting 305.4 acres of land and 70 waterways with a temporary 75 to 100 foot wide construction right-of-way (ROW) resulting in a permanent 50 foot ROW across the Gunpowder Watershed in Baltimore and Harford counties, Maryland.
GRK identified that 39 of 70 waterways impacted by the natural gas transmission line project are designated as drinking water supply waters (USE III-P and IV-P). The project also crosses the Gunpowder Falls River that provides drinking water for 1.8 million Baltimore-Metro area residents.
The pipeline does not define our work but has shown just how connected the wild trout and drinking water are in this fragile upper watershed. If the land agents for Columbia Gas Transmission do not strike deals with the affected landowners along the proposed route for the new right of way the properties that the line would go through may be taken in the courts through eminent domain. GRK has asked for more public participation in the regulatory process, thorough environmental review including an Environmental Impact statement and full mitigation of environmental harms to protect the sensitive waterways crossed by the project.
GRK’s Advocacy:
GRK led 18 Conservation Organizations in urging the Army Corps of Engineers (CORPS) and Maryland Department of the Environment (MDE) to disclose waterway impacts of proposed Interstate Natural Gas Pipeline Project on Baltimore City Metro Area Drinking Water supply.
GRK Outreach:
Led the St. Francis Community Center Reservoir Hill Power Project group on a streamwalk and service project along the River to discuss the sources of City drinking water and the importance of wild trout; Credited as contributing author in a Poster at the International Didymo Conference in VT; Lead a panel discussion on Invasive Algae Didymo at the Waterkeeper ALLIANCE Annual Conference at Callaway Gardens, GA.; Led service projects with over 70 local scouts and brownies that included trash cleanups along the river as part of their merit badge requirements; Led a Juniata College Alumini service project; Took part in the MDDNR Stream Waders program and sampled the River and its tributaries with 8 volunteers that collected benthic macro-inverteb=rates that will be used to inform state water quality standards; Served as a public interest member of the State Water Quality Advisory Committee; Created awareness that current management protocols of Baltimore City DPW that manage Pretty Boy Reservoir at full pool impacts the River with widespread flooding during heavy rainfall events, is counter to the Baltimore City Watershed Agreement and the Loch Raven Total Maximum Daily Load (Pollution diet) and can be prevented with proactive management that allows the reservoir to fill rather than spill during Hurricane Season; Maintained 12 MDDNR Wader Wash Stations along the Gunpowder River to contain the spread of invasive algae Didymo; Worked with Maryland Park Service staff on trail closures and clean-ups; Informed Maryland Natural Resources Police on poaching complaints; Provided regulatory comments and gave testimony before Baltimore County and the MDE on the County Municipal Stormwater (MS4) permit; and added environmental comments to UMD Law letter on MDE Construction Stormwater regulations.
GRK Sign-Ons:
GRK supported important regulatory comment letters related to pesticides; manure and fertilizer application on farm fields; MS4 (Stormwater) permits; a Department of Energy application for the Cove Point Terminal to export Liquified Natural Gas (LNG); a public interest letter regarding disposal of coal ash, and a letter to the editor of Baltimore Sun regarding the environmental impacts of the export of “Fracked” natural gas.
GRK Testimony and Letters:
“The Baltimore County MS4 Permit should be framed in the context relating that it is protective of Clean Water Act (CWA) language, not simply ‘moving towards compliance’ and namely that deadlines for implementation are absent from the draft permit…Despite the Baltimore County Sanitary Sewer Consent Decree, overflows in dry conditions in March and April attributed to vandals accounted for hundreds of thousands of gallons of raw sewage entering the Gunpowder [River] and its tributaries. These events are illegal and must be prevented.”
— GRK on Baltimore County’s Municipal Stormwater (MS4) discharge permit
“The Public notice (PN#13-21) is deficient under the Clean Water Act (CWA) and National Environmental Policy Act (NEPA) as it is neither contains sufficient facts nor is informative enough to properly engage the public to allow them to comment meaningfully in this regulatory process.”
“The Corps must make permit decisions based on consideration of property interests and the needs and welfare of the people. By not providing the public information about surface water designated uses in the public notice; namely, drinking water supply, the regulatory process is subverted and the public is excluded from commenting on substantive environmental issues raised by the project.”
“Based on these deficiencies, we believe that the Corps and MDE must re-issue an amended notice to include impacts to drinking water supply waterways and provide for an additional public meeting to properly engage the public in this regulatory process.”
–GRK on the legally deficient Maryland Department of the Environment (MDE) and Baltimore District U.S. Army Corps of Engineers (CORPS) Joint Public Notice, PN#13-21 for the 404 (Wetland and Waterways) / 401 (State Water Quality Certification) permit for the Columbia Gas Transmission Line-MB Extension Pipeline Project.
Our projects, outreach and advocacy is strengthened by your support. Please consider a donation at our website via PAYPAL to become a supporter and further the cause of protecting the Gunpowder River for future generations. When mailing a donation please send it to: Gunpowder RIVERKEEPER, P.O. Box 156, Monkton, MD 21111
The protection of the Gunpowder River is a gift worthy of your support.
Theaux M. Le Gardeur
Gunpowder RIVERKEEPER
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Gunpowder RIVERKEEPER YEar End Wrap up for 2012