Below find a letter to the trustees of the Urbana Champaign Sanitary District outlining our position on water sales by the district. This letter was precipitated by UCSD’s consideration of water sales to two different proposed facilities – the Cronus fertilizer plant near Tuscola, IL and Sunrise Coal’s “Bulldog” coal mine in Vermilion County, IL. PRN believes that it is necessary for UCSD to adopt a formal policy to help guide considerations of water sales.
For background information on the water sales currently being considered, go here. The UCSD draft policy statement, to which this letter is a response, can be found here.
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Dear Trustees Lenik, Lyke and Putman:
Thank you for presenting the District’s draft policy on effluent sales for public review and comment. The sale of effluent by the District is a new and serious consideration with long term implications for the Champaign Urbana community. As I stated at the public meeting on May 8th, it appears that the contemplated sale to Cronus is being made without due consideration of the potential ramifications and long term consequences. Likewise, the policy reads as if it has been hastily drafted to facilitate the sale. We hope you will use the invitation from Cronus as an opportunity to develop a policy for the future, rather than feel compelled to act quickly, according to a timeline set by Cronus. We need a policy that helps protect our water supply and promotes the health of local, cherished streams. The comments we heard on May 8 demonstrated overwhelming interest in protecting these streams and in planning for the future.
To that end, we offer the following comments on the draft policy. The numbered paragraphs correspond to those in the draft.
Paragraph 1. The meaning of “financially beneficial” is unknown, as is the meaning of “influences.” Although policy statements tend to be more general in nature, if the document is too vague or overbroad how is the public, or the board for that matter, to determine whether a contemplated sale is consistent with the policy? Please provide some clarification as to the meaning of these terms. The policy should require the sale price to be commensurate with market value in a comparable market, and reflect the opportunity cost of foreclosing the option to meet unforeseen local needs.
Paragraph 2. Likewise, there is no indication what a “substantial contract” is. Is the potential Cronus contract substantial? What about the Bulldog Mine proposal? We suggest that the policy clarify which proposals will be subject to public input and that the policy require the Board to seek public input and to strongly encourage and facilitate such input. A public meeting and public comment period should be required elements of sale proposal considerations. Moreover, public comments should be sought after the public has been provided with a credible analysis of the impacts of the choices to be presented to the board for decision. {Continue Reading »}