Ms. M.D. Onyemaechi
Wastewater Permits
Md. Dept. of Environment
1900 Washington Blvd.
Baltimore, Md. 21230
Dear Ms. Onyemaechi:
I have received your letters of July 14 and July 27 asking for public comments re Trappe’s wastewater discharge permit.
As a founding member of the now defunct Talbot River Protection Association (TRPA), I have knowledge of this specific topic going back to the 1990’s. Furthermore, I was a member of the Talbot County Planning Commission from 2005-2015, and its chairman from 2012-2015. Therefore, my personal experience gives me an informed perspective on the subject at hand.
As you should be aware, Trappe has had a somewhat checkered history concerning its wastewater treatment. In 1998 Trappe wished to increase its discharge into “an unnamed tributary of La Trappe Creek” (UTLTC). TRPA asked for a public hearing and asked MDE how they could consider increasing the nutrient load into UTLTC without first checking its present condition. TRPA, with the assistance of the Horn Point laboratory, had some water samples from Trappe Landing (public access) analyzed and found high levels of nitrogen (TN) and phosphorus (TP). This prompted MDE to conduct its own tests which confirmed TRPA’s belief that La Trappe Creek was grossly eutrophic. As a result, Trappe had to build a new wastewater plant.
In 2011 while I was on the planning commission, Talbot county was charged with coming up with a “Watershed Implementation Plan” (WIP) to meet the nutrient reduction requirements as prescribed in the Clean Water Act of 1972. One of the directives was for the county to “identify suitable receiving waters” for more wastewater and stormwater. At a public planning commission meeting with MDE staff, I
asked them how we were to identify any “suitable receiving waters” when all of Talbot county’s waters were already impaired (per federal 303d list) with too much nitrogen and phosphorus. They did not, and indeed could not, answer the question. This key question is still being ignored by MDE.
Now here we are in 2021 and Trappe wants to increase its discharge into UTLTC yet again. There have been reports in local media that Trappe has (again) been in violation of its permit. On July 14 I visited Trappe Landing where I first took water samples in
1998. It was a very hot and still day. I had not been there for a number of years, and was once again appalled at its appearance. It was still “the color of an army blanket and about as transparent” as I was quoted in the “Star-Democrat” back in 1998.
Absolutely nothing has changed. There was also an unpleasant and troubling odor, and it wasn’t the hydrogen sulfide smell associated with marshes with which I am quite familiar. About an hour after my 20 minute visit, I developed a bad headache which persisted until I woke up the next morning. I am not formally asserting any correlation, but given what I’ve learned over the years about the toxic organisms that are known to exist in eutrophic waters, it has caused me concern.
Not only does Trappe want to discharge an additional load from some new homes in the proposed “Lakeside” development into UTLTC, a wholly new wastewater plant is proposed to discharge its load from 2,500 new homes and stores into the upper Choptank (via Miles Creek). What is the present condition of the upper Choptank? It too is overloaded with too much nitrogen and phosphorus and is also still listed as “impaired”. There are ample U.S.G.S. data on the upper Choptank going back to the 1960’s. What do these data demonstrate? Frankly, if we had set out to kill the Choptank back in 1972 there are more data to support that thesis than us purporting to save it. The nitrogen, phosphorus, chlorophyll a, and dissolved oxygen data are all worse now than they were when we set out to save the bay. According to the most recent study of the Choptank in 2020 by T. Fisher et al., although there have been some recent minor very localized improvements in Choptank River water quality, overall there hasn’t been any improvement. In spite of all these known impairments, the MDE is considering adding yet more nutrients from a new source using archaic BNR technology into the upper Choptank.
At a minimum, the MDE must prohibit any more hookups to the existing Trappe wastewater plant. At a minimum, if the 2,500 unit plus retail “Lakeside” development is allowed to proceed, the MDE must require state of the art ENR technology at the proposed new plant. If allowed, the MDE should also require that a sufficient bond be posted to ensure that the plant gets properly built up front, and fully paid for by the developer. Neither the town, nor the county, should be put in potential financial jeopardy for such a large plant.
Next year will be the fiftieth anniversary of the Clean Water Act. All the waters of our bay are supposed to be “fishable and swimmable”. I first waded into Talbot’s waters in the 1950s, so I know what ”fishable and swimmable” should mean. In 1992 the Chesapeake Bay Agreement promised 40% nutrient reductions into the bay. Whatever became of that? Unless a miracle of Biblical magnitude occurs in the next four years, the MDE will have failed to produce any meaningful improvements (by empirical measure) in eastern shore water quality. After half a century of failure, I would hope that the state finds the courage to simply say no to Trappe’s current proposal, and tell them this time we are putting the bay first and we’re not going to kick the can down the road
anymore.
If you doubt the veracity of this letter, and are contemplating forging ahead with business as usual, I invite you to go to Trappe Landing and go for a swim. If you are unwilling to do so, and that would be the prudent decision for your own health and safety, please do not allow Trappe and the “Lakeside” developers to further pollute our already grossly impaired tributaries of the Choptank.
Thomas Hughes
Easton
Margot Miller says
So glad to see this. The Trappe Lakeside development boggles the mind. If I ever there was a project that succumbs to the lure of the immediate advantage (greed), this is it.
Alan Boisvert says
Agree, greed, just like the watermen who overfish our(not their) bay, leaving it largely lifeless.
Margot McConnel says
Thank you Tom Hughes for a clear and compelling letter. I hope the appropriate folks pay attention.
Rod Coleman says
Well said. Curious as to what, if any, response will be from MDE. If I were a gambler I’d bet on hearing crickets. Lakeside will happen and it will be a slow-motion train wreck for the Choptank.
David Lloyd says
Democratic or Republican administration — it makes no difference. The MDE has been consistently incompetent! It has the power to do good protection for the environment and yet rarely seems to care. Very sad considering how much we Marylanders depend on and relish the environmental benefits and opportunities we share.
Jane Bollman says
Thank you for this very clear letter explaining the enormous problem with Trappe sewage. Please consider sending it to Governor Hogan. Jane Bollman
John Briggs says
This is a depressing story. One can only hope that the MDE might in this instance live up to its name and it’s mission. It is the entire county that will be impaired too, not just Trappe.
Michael Davis says
This is a great letter.
I am sorry to read the Talbot River Protection Association is now defunct. Protecting our environment is a years-long effort. irresponsible developers want to make their money fast and then run before the damage they cause is evident. But in this case, we already know the damage they will do. Hopefully, the knowledge Mr. Huges and others can bring up will prevent our local politicians from enabling the destruction of the Choptank watershed.
Buck Waller says
Thank you Tom. Trappe Creek has been in appalling condition since the 1970’s…at least. A generation or two later, people think that what we have in 2021is normal. Now: 2,500 more homes and those responsible for enforcing the most basic rules are asleep at the switch.
Yes, appalling.
Barton M. Cockey, M.D., Trappe says
I strongly agree with Mr.Hughes.
Meg Olmert says
This is exactly the kind of expert, clearly laid out evidence all our lives depend on. Anyone with eyes can see the waters we adore are sick and devoid of the aquatic life that was always a thrill to see. If this death march doesn’t stop in Trappe, we must all publicly admit that we’ve given up and are just grabbing the final beauty and money that we can wring out of this once great bay. To hell with all life that depends on it. To hell with our grandkids and their’s. We must at least own up to the truth about how and why we decided to condemn them all. Profit over shame.
Jay Dayton says
Excellent letter Tom! Thank you for a clear & concise statement of the issues. The solution seems to be that if approved by MDE, they must require the most technologically advanced sewage treatment plant available, to be paid for by the developer! Miles Creek is an great example of a well balanced tributary but it too will be damaged & further contribute to the nutrient pollution issues already at a critical stage in the upper Choptank, if this permit is allowed to be approved without these additional requirements.
Jay Dayton says
Under no circumstances should additional homes be allowed to connect to the Trappe Creek sewage treatment plant. It too should be required to upgrade to the current ENR treatment standards immediately. As Tom Hughes pointed out, the upper waters of Trappe Creek are severely compromised by nutrient pollution!
Nicholas Fidis says
Thank you Tom for an excellent and informative letter. Let’s hope the Maryland Department of Environment will live up to its name and take action to prevent further pollution of our waters.
Nicholas Fidis
Jamie H Garner says
I admire Tom Hughes’ steadfast belief that the MDE will come to their senses with regard to the w/w treatment plant planning for the “Lakeside” development in Trappe. I have watched for nearly 20 years the struggle of the Town of Trappe and the developers of “Lakeside”, to make sense of this development for the little Town of Trappe. Throughout, I have witnessed the repeated failure of MDE to take any meaningful steps to curb the myriad plans for w/w treatment that the project has proposed. The addition of 2501 new homes in “Lakeside” will not improve our already impaired waterways.
Please, if anyone is listening at MDE, will you take a stand on (an interest in?)the quality of our rivers before this project is permitted to go forward?
Rebecca Ellison says
Yes, by all means do ask the governor about MDE inserting itself into Talbot County’s custom of using the award of sewer and water priority upgrades as a zoning tool. Also read the Center for Public Integrity’s 2009 expose of the MDE/Trappe relationship and the unheeded calls for investigation of MDE’s involvement and interference. https://publicintegrity.org/environment/town-bypasses-normal-channels-to-aid-major-development/ As recently as the Resolution 281 hearings, pivotal County officials claimed to be unaware. Yet Resolution 281 itself was the codification of MDE’s demands for highest priority sewer and water status for the Trappe developers, the culmination of years of involvement on behalf of the developer.
Steve Shimko says
Thanks for the background, Mr. Hughes. The sad part is that it’s not surprising that none of this history seems to be acknowledged by the current Talbot County Council. And I agree that the MDE seems to be shirking its responsibility.
Elizabeth K. Dawkins says
Dear Tom, THANK YOU ! I agree ! Keep up your GOOD WORK ! Sincerely, Libby ( Amy Elizabeth Kelley Dawkins )
Patrick Russell says
Very well stated sir but unfortunately it will more than likely fall in deaf ears. Money is the only motivation these developers have!!!
Mike McConnel says
As a former elected steward of my community, Commisioner of Lower Merion Township, Pennsylvania, I salute you for your service to Talbot County. I salute you as well for your continuing faithful caring for this community! Thank-you. Your letter has brought you out of “retirement” and our citizenry is in your debt regardless of the outcome. I am sure that the people who know you well rightfully hold you in high esteem. You have set a standard date we all should aspire to reach.
Mike McConnel
Doug Firth says
Thank you Tom for bringing up the past history of the Trappe waste water issue.
Having lived on Trappe Creek for the past 60 plus years, I have not seen any improvement in the water quality even after several homes including mine have upgraded to a BAT septic system.
This fragile creek cannot handle any more @*&$% pollution.
Rebecca Ellison says
In addition to the anticipated pollution of Miles Creek, LaTrappe Creek and the Choptank with effluent from Trappe East’s 2,500 homes and 550,000 sq.ft. of retail, Talbot citizens should be also be aware that there are four additional existing or proposed sources of sewage effluent for the Choptank. Three are existing or proposed developments … “Fearins Crossing” in Denton (Caroline County) and two recently announced ‘waterfront development opportunities’ adjacent to the Hyatt in Cambridge (Dorchester County). For details, go to http://www.hogancompanies.com and click on ‘featured properties’. The fourth new potential sewage threat to the Choptank will be from the Talbot side. The Talbot County Council has just OK’d putting ANOTHER standalone sewage treatment plant on the Choptank. It will be located at at Rt. 50 and Marina Drive (for the benefit of Ferry Point Marina etc. (see Talbot County Resolution 300, March 23, 2021). That’s a total of FIVE. Remember that the Choptank got to its present level of pollution without those five …. If there is to be any change, it seems clear there needs to be more than hand-wringing.
Rebecca Ellison says
For 17 pages of detail about the planned Choptank waterfront development(s) at the Hyatt in Cambridge, click here https://www.hogancompanies.com/resources/Chesapeake%20Communities%20OM.pdf
Keeley Diggs says
“Remember that the Choptank got to its present level of pollution without those five …”
This hits hard. Thanks for sharing!!!
Willard Engelskirchen says
Well said
Keeley Diggs says
I hope this opens the eyes to many, as it did mine. Thank you for getting the word out there about this selfish community proposed to be built (and Gov Hogan is also behind the scenes on this, who will profit off the many people it will attract). I’m not sure how the fields of Trappe will handle an additional 540,000 gal/day of waste water when it can barely hold the saturation from a heavy rain fall. Guess it will be a “live and learn” experience if it goes through. Anyone up for a swim in some poop today at the river?
Lets listen to the experts before it’s too late.