A lot of presentations this month and more on Trump Tower
I spoke to the Illinois State Bar Association Environmental Law conference yesterday and I present at the River Rally next week in Grand Rapids. I will put the presentations on this site as soon as I figure out how. Meanwhile, the facts against 401 N. Wabash (Trump Tower on the Chicago River) only get worse as it now appears that Trump Tower has not been measuring its water intake property. To summarize, Trump Tower:
Began operating in 2008 without a necessary NPDES water permit,
After getting caught discharging without a permit, Trump Tower got a permit to discharge 1/1000th as much water as it would discharge. Further, the permit it got was for facilities that were built before 2003 although it needed a much more stringent permit because the building was built later and could have a state of the art intake structure that would not kill aquatic life without having retrofit costs,
After (partially) correcting the amount of water it would be taking from the Chicago River and discharging (but not the fact it had the wrong kind of permit), got a revised permit in 2013, but violated that permit by failing to comply with the conditions,
failed to apply for a renewal on time,
misrepresented the volume of water its gage showed it was taking by reporting the average amount of water it was taking per minute and multiplying by 1000 and reporting that amount as the total amount per day. Of course, there are 60 minutes in an hour and 24 hours in a day, so they should have reported by 1440, not 1000, and now we learn,
their gage is under reporting by about 20%. So they are reporting something under 60% of the amount of water that they are actually taking and the amount of fish and other aquatic life that they are actually killing.
