July 7, 2015

Commissioner N. Gunter Guy

Alabama Department of Conservation and Natural Resources
64 N. Union St.
Montgomery, AL 36130
RE: Oak Mountain State Park Plan for Hotel & Conference Center
Dear Commissioner Guy:
The Cahaba Riverkeeper (CRK) supports Keep Oak Mountain Wild in their opposition to
the States plan for a hotel and convention center inside Oak Mountain State Park.
Our objections to this proposed project stem from the significant potential for
1. adverse environmental impacts to the adjacent tributaries (specifically the Buck
Creek watershed) that feed into the Cahaba River
2. degradation of the natural splendor of the Park, which, we believe, will ultimately
adversely affect the experience of users of this magnificent State resource.
3. adverse financial/economic consequences for water and sewer ratepayers (details
below) as well as taxpayers (bond debt).
CRK questions the economic viability of this proposed project and believes the current
feasibility model as proposed has significant shortcomings that will cause Shelby County
taxpayers to bear the debt burden over the long term.
The following are the specifics of our objections that, we submit, must be included in any
consideration involving the hotel/convention center in Oak Mountain State Park
(OMSP, Oak Mtn, or the Park).
Waste Water (Sewage) Treatment
The States feasibility study included no mention of the current or projected sewage
treatment capacity. State Parks Director Greg Lein had no information on the subject at
the March 2015 public meeting at the Pelham Civic Complex. In no business model that
we can imagine would such a critical cost component--and public health factor--as
sewage treatment be omitted from a feasibility study. It must be noted that Jefferson
and Shelby County sewer expansions, as ratepayers are painfully aware, have resulted
(continued on p. 2)
in skyrocketing sewer rates.

Cahaba RIVERKEEPER. 4650 Old Looney Mill Road, Birmingham AL 35243

205-967-2600 Email: info@cahabariverkeeper.org www.cahabariverkeeper.org

Waterkeeper Alliance, 17 Battery Place, Suite 1329, New York, New York 10004

Cahaba Riverkeeper

page 2

Concerning OMSPs existing wastewater treatment plant (WWTP), a study is required to

determine how the proposed facilitys discharge will fit into the EPA-approved TMDLs
(Total Maximum Daily Load) for both pathogens and nutrients on the impaired Cahabas
stream segments. Construction of a new or expanded WWTP facility in OMSP will
require a closer look at Buck Creek, in particular, and its ability to handle increased
organic, pathogen, and nutrient loads.
If the existing WWTP facility at OMSP is not large enough to provide adequate
sewage treatment for the proposed hotel and conference center, what are the total
costs, including construction, maintenance, and staff for expansion or a future
plant(s)? How will new and/or expanded existing sewage treatment be funded?
Capital costs of ongoing sewage collection and treatment, including new sewage
collection systems, must be factored in. User charges must be included in this
calculation and consideration given to future growth. As it stands, we are
currently discussing a calculation of a project including a 175-room property with
conference facilities that can host how many people?
Environmental impacts must be documented and assessed. If federal funding is
involved, adequate National Environmental Policy Act (NEPA) review is
necessary.
If State of Alabama funding or property is involved, required State environmental
review is necessary and should be made available for public review.
The proposed facilitys National Pollutant Discharge Elimination System
(NPDES) permit will require review for adequacy.
Will extra capacity be built into the Parks WWTP that outside developers could
tie onto? If so, how much of the plants capacity will be for the park and how much
for outside development(s)?
Storm Water Concerns
The feasibility study did not report the square footage of the hotel, only the conference
center, so we cannot determine the exact percentage change in impervious cover in the
park. The proportion of vegetated ground to impervious surfaces (buildings, roads,
parking lots, etc.) is important to know and important to balance in order to avoid
compounding flooding even further. What might seem like a small increase in
impervious cover is nevertheless an accumulation of the total amount, which is already
contributing significantly to flooding.
An Environmental Impact Statement (EIS) or review will take into consideration the
impact of increased impervious surfaces both in quantity and quality of downstream
flows. Has an EIS been completed? If so, please share the results/conclusions with us.
We respectfully request (1) a CRK file review on the OMSP proposal before any further
decision is made and (2) responses to our questions/concerns by July 16, 2015.
Respectfully submitted,
Peggy Gargis, Board President

Debra C. Sharpe, Board Vice-President

205-967-8254

205-306-3678