Hit the Pause Button
From time to time projects come up that threaten areas and places having special historic, community, architectural, or aesthetic value. This is happening in Baltimore. In 2006 the Environmental Protection Agency (EPA) declared an unfunded federal mandate to physically cover reservoirs across the country. In Baltimore, there are three potentially impacted reservoirs: Guilford, Druid Lake and Ashburton. This EPA Rule or LT2 "requires drinking water systems to choose between covering their finished water reservoirs or treating the water leaving uncovered reservoirs before distributing it to consumers.
How Baltimore has responded to this mandate has led to mounting concerns, especially about the future of Druid Hill Park and Druid Lake. The Department of Public Works has proposed removing the reservoir from the drinking water system, initiating a massive multi-million dollar, disruptive construction project at tax-payer expense. The project would decommission the lake and remove it from the city drinking water system while storing the water in new underground tanks. This would dramatically impact the aesthetic and architectural integrity of the park. As citizens, we seek a water system that maintains our superb water quality, minimizes rate impacts, and also values reservoirs as part of our parks and public spaces. The Druid Hill Reservoir, the oldest of the three, has been delivering safe, clean drinking water for over a century without a single major health incident. The intention of the mandate is "to protect against the potential for re-contamination of treated drinking water in uncovered finished water reservoirs with disease-causing organisms, specifically Cryptosporidium, Giardia and viruses." Some questions arise: Are there increased levels of the parasite cryptosporidium in our drinking water reservoirs and if so, how much? As for giardia, isn't it true that water treatment is not always necessary as the infection usually resolves by itself?
These are all questions that deserve a proper public airing. City officials in Baltimore have severely limited public involvement in the decision-making and review process related to implementation of the mandate. Why did citizens concerned about the impact on Druid Hill Park have to file formal Freedom of Information requests before the Department of Public Works released proposal documents? What are the levels of cryptosporidium in our reservoirs? Do they pose serious public health risks? In fact, is the cap or treat program actually necessary?
Metropolitan areas across the country have been raising questions about the real need and costs to bury open drinking water reservoirs underground or to add a new level of treatment. It has been suggested by researchers in Oregon that the LT2 rule-making process was corrupted by consultants and lobbyists with vested financial stakes in construction contracts which would flow from implementation of the rule. See background at http://www.friendsofreservoirs.org/ In New York, the EPA was requiring the City to build a concrete cover over Hillview Reservoir, located just north of the City. This would likely add a 3% increase in water rates for New York City residents on top of a 90% increase over the last five years. New York City Department of Health estimates there are only 100 cases of cryptosporidium reported each year, in a City of over 8 million residents, and in a recent study of the Hillview Reservoir, did not find it to be a source of concern for these pathogens. New York officials sought to hit the pause button. U.S. Senator Charles Schumer wrote to the EPA about the federally unfunded mandate cap or treat rule urging "the EPA to partner with the City to find alternative common sense strategies that will protect public health in a more cost-effective manner." NYC Environmental Protection Commissioner Caswell Holloway wrote EPA Administrator Lisa Jackson: "New York and other cities need a true partner in the federal government. EPA should promote urban areas as one of the most efficient ways to combat sprawl, air pollution, habitat degradation, and carbon emissions. Unfortunately, uncoordinated mandates have driven up the costs of living in cities. Consent orders imposed by the EPA, the Department of Justice at EPA's request, or states implementing EPA-delegated programs, often seek compliance with specific regulatory requirement without regard for a project's comparative public health benefit, competing water system priorities, or likely impact on consumers who pay the bills."
Protecting the quality of our drinking water, protecting our city expenditures, protecting the aesthetic and architectural integrity of historic, iconic Druid Lake in Druid Hill Park requires an informed public. It requires participation in the decision-making process. Before Baltimore City implements the unfunded federal mandate threatening the future of our drinking water, our lakes and our parks, there needs to be public forums addressing many serious unanswered questions about this project as well as ensuring citizens and other stakeholders are offered opportunities to direct and shape decisions by city agencies and officials. We all want clean safe drinking water and we know we need to pay for it; but don't we deserve to be involved in deciding how this gets done? Perhaps after hitting the pause button, we can all take a closer look at unfunded federal mandates, consent decrees and local compliance proposals in open public hearings.
Joe Stewart, president, for and on behalf of Baltimore City Historical Society
Tom Orth, Friends of Druid Hill Park member and past president
David Carroll, Baltimore City resident and a past Secretary of the MD Department of the Environment