27 April 2007

Mr. O. Ray Bourland
Executive Secretary
Maryland Public Service Commission
William D. Schaefer Tower
6 St. Paul Street, 12th Floor
Baltimore, MD  21202

Dear Secretary Bourland,

The Maryland Department of the Environment, Water Management Administration (MDE WMA) recommended that ground water from both the Lower Patapsco and Patuxent aquifers be used for an interim period of one year with a one year extension for good cause to supplement Mirant’s water needs while it constructs a pipeline to convey treated effluent to the Morgantown Power Plant from the LaPlata waste water treatment plant.  The recommended groundwater withdrawal between the two aquifers would result in as much as 1.3 million gallons per day from the Lower Patapsco aquifer. This appears to be contradictory to a Maryland Geological Survey Report of June 2005, and as presented to the Charles County Commissioners in September 2005.

The Report “Water-Supply Potential of the Coastal Plain Aquifers in Calvert, Charles, and St. Mary’s Counties, Maryland, with Emphasis on the Upper Patapsco and Lower Patapsco Aquifers” by David Drummond (June 2005), indicates…

~ “the LOWER Patapsco aquifer is pumped heavily by major users in central and northwestern Charles County”
~ “A cone of depression nearly 200 ft below sea level has formed in the Waldorf/LaPlata area”. 
~ “Future pumpage may also cause significant drawdown near the outcrop/recharge areas of the Upper Patapsco and LOWER Patapsco aquifers in northwestern Charles County.” (emphasis added)

The Report further states “Water levels in the Upper Patapsco aquifer have declined steadily in all three counties, even though it is used extensively only in Charles County” and summarizes that “Charles County, however, CANNOT supply the required water in 2030…without drawdowns EXCEEDING 80-percent management levels at some locations.” (emphasis added)

In addition, the Executive Summary of another report,  “Optimization of Ground-Water Withdrawals in the Lower Patapsco Aquifer, Waldorf, Maryland” by David Andreasen (Sept 2004),  states:

“The greatest amount of drawdown has occurred in the LOWER PATAPSCO aquifer with water levels as deep as 170 feet below sea level.” (emphasis added)

The foregoing is indicative of how CURRENT withdrawals have affected the Patapsco aquifer(s).  Additional withdrawals as requested for Mirant could further exacerbate water level declines in the Lower Patapsco aquifer.

Furthermore, U.S. Geological Survey Fact Sheet FS 2006-3009 states –

“The current rate of decline in many of the confined aquifers is about 2 feet per year. The declines are especially large in SOUTHERN MARYLAND and parts of the Eastern Shore, where ground-water pumpage is projected to increase by more than 20 percent between the years 2000 and 2030…Continued water-level declines AT CURRENT RATES could affect the long-term sustainability of ground-water resources in Maryland’s heavily populated Coastal Plain communities and the agricultural areas of the Eastern Shore.” (emphasis added)

The Governor’s Advisory Committee on the Protection of the State’s Water Resources of May 28