Your Comments to DEQ


To read the Virginia Department of Environmental Quality's response to public comments on their draft plan for addressing pollution beow the Lake Merriweather Dam, click here.
DEQ sent this TMDL document to US EPA for approval.

Request to Rockbridge County

At the January 25th meeting, concerned citizens submitted a request to the Board of Supervisors asking for answers to questions about the Lake Merriweather Dam.

The dam has been declared high hazard, there was a gate failure on January 4th of this year, and it is not clear what is being done to address this dangerous situation or what will be done if and when there is another failure.

Goshen Dam Documents


Rockbridge County has posted the Executive Summary of the Army Corps of Engineers' Dam Safety Report on the county web site, without explanation. There was a flurry of activity - but no progress - in 2006, as indicated by these emails.


Here is an Environmental Assessment conducted by the Corps in 1999. Needless to say, it is out of date after 11 years. There is no indication that anything has been done to address the environmental and safety concerns in the past decade and more.
The 1998 Dam Operation Manual is the latest that is available through agencies responsible for dam safety. It is out of date & inadequate.

What Happens When A Dam Fails?


Taccoa Falls Dam Failure - November 6, 1977, the Kelly Barnes Dam failed, releasing 176 million gallons of water just above Toccoa Falls College campus in northern Georgia

Teton Dam Collapse - The Teton Dam was a federally built earthen dam in Idaho, which when filling for the first time suffered a catastrophic failure on June 5, 1976.

Baldwin Hills Dam Disaster and Flood - On December 14th 1963 in the hills about Los Angeles, the Baldwin Hills Reservoir suddenly cracked and eventually failed flooding the neighborhood below

St Francis Dam Disaster - North of Los Angeles on March 12, 1928, the dam catastrophically failed, and the resulting flood killed more than 600 people

Dead Fish from Lake Merriweather




IRRESPONSIBLE

Evidence of dead fish in the Maury caused by irresponsible operation of Lake Merriweather Dam. This photograph was taken Friday, January 15th. A gate failed at the "high hazard" dam on January 7th.

This incident highlighted 2 problems with this dam:
1) it is unsafe, jeopardizes the safety of downstream users and residents - and all levels of government have dropped the ball to enforce the law or prepare for the probable emergency.

2) the silt-filled lake with a poorly designed and maintained dam has causes environmental damage - and will continue to do so - until the owners of the dam are forced to act responsibly.

Your Public Comments Needed

SAMPLE COMMENT LETTER (Word doc) - due 12/18/09 before midnight
The Maury is formed by the Little Calfpasture River and the Calfpasture River. Just above the confluence, the Little Calfpasture has been dammed [Lake Merriweather Dam] since the mid-1960s. Because of the way the dam was constructed and how it has been operated, pollution plagues the river between the dam & the confluence. Pollution flows into the Maury and has caused major problems periodically over the years.
The Clean Water Act requires that states designate sections of streams and rivers that are too polluted to meet minimum standards - and come up with a plan to clean them up. This process is known as TMDL (Total Maximum Daily Load). The Virginia Department of Environmental Quality (DEQ) is nearing the end of the TMDL process for the section of the Little Calfpasture River that immediately flows into the Maury at the upper end of Goshen Pass. DEQ is accepting comments from the public ONLY UNTIL DECEMBER 18th.

Those of us who have followed the process have grave concerns about the method of developing and content of the TMDL. The DEQ has made assumptions and changed the rules in order to accommodate a defective dam. While we understand that they think this approach is necessary, we believe that it is a violation of the Clean Water Act.

Our primary concerns with the TMDL development process are:

  • There is insufficient real data used to “fuel” the model
  • The combination of models types is inappropriate
  • The decision to seek a change of water quality standard for the degraded stream section is an inappropriate use of the Use Attainability Analysis process under the Clean Water Act.
  • The TMDL document significantly understates the role of Lake Merriweather and its current management in the continuing problem of sediment pollution in the Little Calfpasture and the Maury Rivers.
    Please Review Important Documents in post immediately below this one
Take the time to submit comments to the Virginia DEQ asking them to substantially revise the TMDL in order to provide for improved and the required level of clean water in Goshen Pass. Your comments do not need to be long or technical - the number of comments will make a big difference. Comments should be emailed (or mailed) to:

Tara Sieber, Department of Environmental Quality, 4411 Early Road, PO Box 3000, Harrisonburg, VA 22801, telephone (540) 574-7870, fax (540) 574-7878,
or e-mail tara.sieber@deq.virginia.gov

If you are willing to, please send a copy of your comments to us at maurygoshen@gmail.com

Important Documents from the TMDL Process

To see a Plain-English explanation of why & how TMDL is improtant:

Information from VA Department of Environmental Quality on TMDL:

Conservationists Letters submitted to VA DEQ and US EPA:

We Won!!

Update 11/09: The Boy Scouts of America announced last week that the Jamboree will be held in Fayette Co. WV. This result is good for all and West Virginians seem ecstatic over the news (the WE WON comes from way out there.......)

Coverage and Reaction from Gov. Kaine

Hooray!

Believe it or not, today the Boy Scouts announced that they are no longer considering the Goshen Pass site for their scouting center and Jamboree. This makes sense for BSA (it appears they have an appropriate & desirable site in Fayette Co., WV) and is wonderful news for all who love Goshen Pass. Here's the BSA Press Release

Selling Us A Bill of Goods?

The BSA National Council and other supporters of locating the Jamboree in Goshen have touted economic benefits to the surrounding area as the most compelling reason to support this project. E-mails obtained through the Freedom of Information Act reveal quite the opposite. Since the secret phase of their plan, the BSA and their supporters have scrambled to find believable exaggerations to gloss over the reality that any net economic benefit to Goshen and Rockbridge County has not been shown…
· Email from Robin Sullenberger (Shenandoah Valley Partnership) to Dominion Power notes: “Obviously we can’t make a strong case for job creation, taxes or any of the normal parameters…” September 10, 2008
· In May 2009, Mike Kaestner, Legislative Coordinator of VEDP asked Jay Langston of VEDP: “By some odd chance did we run an ROI [return on investment analysis] for Jamboree based on the few jobs and capital investment they’ll be making? I didn’t see anything in the ROI folders. [T]rying to grasp for straws and see about playing up some of the positive impacts of this project.” Reply from Langston: “….The Boy Scouts provided an economic impact statement,* but Ann looked at it and said it wasn’t worth the paper to print it because their assumptions were so erroneous as to render it meaningless.” May 1, 2009

Take a look at a longer summary (with links to documents) of this stunning lack of valid data and analysis. Those who supported this project on the basis of economic benefit and jobs creation were sold a bill of goods.
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