Environmental Engineering Reference
In-Depth Information
the Federal Register on January 12, 2004 and also in the “Project Introduction
and Description of Proposed Action and Alternatives” (prepared in May
2004) which was a primary supporting document for the scoping process
and ultimately preparation of the EIS. In summary, the purpose and need
were stated as:
r Achieve complete compliance with the reissued NPDES permit and
all other federal and local regulations.
r Do not compromise the current or future production of safe and suf-
ficient drinking water for Washington Aqueduct customers.
r If possible, reduce the quantities of solids generated by the water
treatment process.
r Minimize, if possible, impacts on various local and regional stake-
holders and minimize impacts on the environment.
r Implement a solids management process that is cost-effective.
The purpose and need statement successfully precluded the need to con-
sider alternatives in the EIS that were not reasonable or practical. Of partic-
ular concern was avoidance of the time- and resource-consuming effort of
identification and evaluation of a new raw water source. Engineering analy-
sis done over 100 years prior and periodically revisited conclusively demon-
strated that the Potomac River was the only viable source of potable water
for metropolitan Washington, D.C. Any attempt to find another source that
would result in fewer water treatment residuals would not only be fruit-
less but it could engage numerous stakeholders (i.e., those associated with
new possible but unrealistic raw water sources) and thus dilute and dis-
tract the focus of the EIS. Also, development of a different raw water source
would likely require treatment facilities at additional or new locations and
a significant reconfiguration of the distribution system. Consideration of a
new raw water source could be immediately dismissed because it would not
meet the purpose and need and these distracting issues could be avoided.
Specifically because of the development of new intakes, protection of a
new source, new treatment facilities, and modification of the distribution
system, the cost-effective condition in the purpose and need would not be
satisfied. Similarly, construction and operation of a new treatment facility
and disruptions caused by major system modifications would not conform
to the purpose and need to minimize stakeholder impacts. Also, any new
unproven sources of water may not conform with the criterion of continued
adequate and safe supply of water to Washington Aqueduct customers and
thus would not be consistent with this provision in the purpose and need
statement. For these reasons a new water supply and other unreasonable
alternatives were dismissed without even a cursory examination and the
EIS was able to focus on the critical issues, stakeholder concerns, and miti-
gation of impacts.
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