Just sent this to all the commissioners who have email (i.e. not commissioners Jack Sharp and Robert M. Lobetti)

I also told them that I was posting this here on knoxviews and encouraged them to respond here.

Greetings Commissioners,

We, the undersigned, write to you regarding the proposed Midway Business Park. We have many concerns both for county taxpayers and for our own investment in this area (Thorngrove/Tuckahoe Creek watershed). Several years ago we as a family bought 70 acres off of Bales road with the intention of creating a sustainable neighborhood. Our plan is to push all available green development technologies to their limit, and to set aside the majority of the land as a nature preserve. For reasons outlined below we feel that our investment is threatened by the proposed uses (Midway Business Park or Town Center) of the land acquired by TDC at the Midway Rd interchange. We encourage MPC to consider the alternatives for the site proposed in the Ochs report, as well as the ideas promoted by Rikki Hall in his column for the Metropulse (use the site for a regional museum or “Museum of Appalachian Natural History”). Both of these uses capitalize on the tourism infrastructure being built at the next exit east on I-40 (exit 407).

Reasons we oppose the proposed Midway Business Park or Town Center:

1. The proposal to put a large on-site wastewater treatment system (septic tank with sand filter/membrane and drip irrigation field) threatens underground sources of drinking water in the area.

A) Because this area has Karst geology, with multiple sinkholes on the site acquired by TDC, the potential for groundwater contamination is high. Underground water flows in Karst areas are highly unpredictable, with potential contamination stretching for miles. Until a dye test is conducted, we have no idea how many people over how large an area might have their wells contaminated.

B) We have recently spoken with several regulators at EPA and TDEC, all of whom reaffirmed our suspicion that this large of a system (2200 person capacity) in a Karst area presents a serious threat to groundwater resources. Moreover, the system could well qualify as what EPA and TDEC define as a “Class IV Well” due to the possibility that it could introduce both pathogens and toxins into the water table. Class IV Wells have been banned since 2000.

For further reference please see the following websites:

http://www.epa.gov/ogwdw000/uic/wells_class4.html

http://www.epa.gov/waste/hazard/wastetypes/listed.htm

http://safewater.custhelp.com/cgi-bin/safewater.cfg/php/enduser/std_adp....

C) The potential illegality of the proposed system is especially relevant to the proposed use of the site as a business park where “light manufacturing”, truck washing, or vehicle maintenance of any kind would take place. On-site systems of this kind have very limited ability to deal with the kinds of waste that will enter the system even from, for example, a technician or maintenance person washing cleaning chemicals off of their hands or body, or from equipment cleaning. The introduction of these wastes into the system, even by accident, would result in them entering the water table, which would qualify the system as a legitimate target of lawsuits, based in part on arguments that the system is a banned “Class IV Well”.

For further reference please see the following website:

http://www.epa.gov/ogwdw000/uic/wells_class4.html#what_difference

D) Lawsuits over an on-site option for the proposed Midway Business Park are especially likely given the fact that members of the Thorngrove community have already gone to court in opposition to this project and won. The fact that the proposed system threatens the community’s groundwater resources makes a lawsuit almost a forgone conclusion. Should TDEC approve the system in question, such a suit could easily take the form of a citizen suit against TDEC, which could eventually make its way to the federal court system. This would result in a decade or more of legal uncertainty regarding the Midway exit, which would waste many more taxpayer dollars.

E) We might support such a lawsuit because our investment in the area depends in part on clean groundwater resources. The sustainable neighborhood we propose would primarily use rainwater harvesting off of roofs as a water source, but we would depend on groundwater as a backup in times of drought. Hence, any threat to groundwater resources in this area threatens our investment.

Incidentally, we looked at using a large scale on-site septic system, like the one proposed for the Midway Business Park, but decided it was a dangerous system for many of the same reasons outlined above. Even a residential system can easily release nitrates and other pollutants into nearby surface and groundwater resources. EPA recognized this in a study that concluded that areas with over 40 household septic systems per square mile using septic systems have potential groundwater contamination problems. Most parts of Knox County not yet served by sewer already have septic system densities far above this number. Is it responsible to make this problem any worse than it already is? The system we plan to use is the solar desiccating toilet system described below, in reference to a proposed Appalachian Museum of Natural History.

For the EPA study please see the following website:

http://books.google.com/books?printsec=frontcover&vid=ISBN0873710126&vid...

The “summary” section at the end refers to septic system density.

2. Business parks with on-site treatment like what is proposed for Midway are quite rare, mostly because they have a hard time attracting and keeping tenants.

A) Business park tenants prefer sanitary sewer connections because they pose fewer obstacles than septic systems. This is especially true for companies whose wastewater production may experience sudden spikes. For example, when a successful company hires a large number of new employees all at once they may overload a septic system with the sudden increase in wastewater. Similarly if a company wants to host a large number of visitors, their septic system can easily become overloaded. The costs of pumping out an overloaded septic tank can become a burden for a growing company.

For further reference please see the following article about a business park in Colorado that is experiencing an exodus of tenants due to its failing septic system.

http://www.sullivanseptic.net/articles_timescall_unknown.html

B) Business parks that use septic systems are rare. The TDEC and EPA officials I spoke with were unable to name a single industrial park in Tennessee or surrounding states that uses a septic system. Looking online, I was able to find a few parks that considered septic, but eventually opted for a sewer connection instead. Other than the one business park in Colorado mentioned above, I was able to find only one other business park with a septic system. This park is located off the coast of Africa on the island of Mauritius, hardly an industrial powerhouse that Knox County would want to emulate.

3. Knox County needs a vision for the development of the Midway Road exit that everyone can agree upon. Many workable alternative uses for this site have been proposed, and several could earn enough money to justify the millions of taxpayer dollars that TDC spent acquiring the land. Our personal favorite is Rikki Hall's suggestion of an Appalachian Museum of Natural History:

http://www.metropulse.com/news/2009/nov/11/development-corp-should-move-...

A good attraction like this could make millions a year, given the millions of tourists who drive by each year, many headed just one exit away!

If we could end up with something even half as successful as Chattanooga's aquarium, TDC would look like far sighted visionaries for acquiring this land, and the community would have a bold new centerpiece they could be proud of. MPC would have a use for this exit that doesn't conflict with what they have planned for the area immediately to the south of I-40 and the French Broad River Corridor.

TDEC and EPA would be much more likely to approve such a project because you CAN locate museums on septic-based systems, you just have to be really smart in how you do it. Probably the safest, and incidentally the cheapest, way to do it would be to reserve the septic system for grey water only, handling everything else (pee and poop) with solar desiccating toilets that can accommodate sudden surges in visitors.

Here’s an example of a model that is being used at state parks in Alabama: http://www.swsloo.com/

If we wanted to minimize impact even further we could use a “greywater greenhouse” to grow away the water used for handwashing or cleaning, giving us a “zero discharge” system. This kind of system would work especially well with a tourist attraction, because the system itself can serve as an exhibit on sustainable water management.

See this website for more.

http://www.ecological-engineering.com/solaraquatics.html

So how about it? In ten years time do we want to be right where we are now, or do we want something good to have come from all of this? Do we want to be locked in court, racking up legal bills, or do we want to have something we can all be proud of?

Finally, we will be posting this letter on the Knoxviews website, where your comments on this and other issues are more than welcome.

Sincerely,

Alex and Allison Pulsipher
Oakwood-Lincoln Park Neighborhood
Knoxville, TN

Lydia Pulsipher and Mac Goodwin
Holston Hills
Knoxville, TN

Anthony Pulsipher and Nancy Burke
Bushrod Neighborhood
Oakland, California