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06/24/02 Clifford/Serious Concerns06/24/2002 15:41 4065425632 CLARK FORK COALITION PAGE 02 .£LARK FOOK OALITION Mayan Kennedy and City Council City. of lCalispelt . 112.1" Avenue .bast . Kalispell, MT 59901° June 24.2002 bcar.Mayor Kennedy and Council members: 0 behalf of the Clark Fork. Coalition, please accept'the following comrnents'regarding the proposed Glacier Mall amendment.. The. Coalition ,. �s a.member-supported group. of 1200 citizens, scientists,. business people, and recreationists dedicated.to protecting andrestonng water quality throughout the Clark Fork. River basin: • M have.serious concerns about the water quality iznpacts.of.the,proposed . project. In_.particular; w.e think the proposal to discharge large amounts of untreated stormwater runoff to afast moving aquifer that discharges directl ly. .. y. nto. Flathead Lake is.unacceptable.. Stormwater tunofftypically.contains harmful concentrations of petroleum products and other pollutants that are . harmful to aquatic life. Moreover, the particular aquifer in questiori.has: :. been shown to provide. important habitat for stoneflies and other macroirivertebrates that are a key part of the lake's ecosystem. We seriously doubt that this project could be approved in its present form, and still comply -with the non -degradation policy that protectssurface waters; or•the . constitutional right. to a clean environment, which protects all ecosystems . .from unnecessary, degradation. We are'also.concerned about the large amounts of nitrogen and phosphorous that the proposed mall would generate. We•seriously doubt these pollutants. could.be treated to. enyironriientally acceptable levels through an on=,site treatment system, We, in with with the'cities of Butte, Missoula; and Deer.Lodge and, the Stone Container Corporation., have invested a great- deal of time.and effort in reducingnutrient loading in the Clark Fork] Flathead/ Pend Oreille river basin. ,4nother aarge-scale;source of nutrients in the.basin would be a step in the wrong, direction, ,particularly when there are other . treatment options available. It,would also serve: to undercut the substantial gains that have been made by the above; -.named discharges in the. Clark. 'Fork basing P01ox 7593. WSW* YT S9d01 406/542-05 406/542-5632 (6) wwir.aork A.ag 06/24/2002 1.5:41 4065425632 CLARK FORK COALITION PAGE 03 In stun, we believe the proposed project, if built at the site in question, would create a serious threat to water quality in the basin. We do not think this project in its present form would be good for the watershed or its people, and we urge you to reject the amendment that would enable it to move forward. Sincerely, Matt Clifford Conservation Director/ Staff Attorney