Shelli DiFranco
The Watershed Center Grand Traverse Bay
231.935.1514 ext. 5





TRAVERSE CITY, Michigan – September 10, 2018 – The Watershed Center Grand Traverse Bay issued a Notice of Intent to Sue under the Clean Water Act to Cordia at Grand Traverse Commons for its continued unlawful discharge of hot, chlorinated water into Tributary AA of Kids Creek. Following four summers of Cordia discharging noncontact cooling water into Tributary AA, The Watershed Center is demanding the facility meet Michigan water quality standards or face legal action.

The Watershed Center also submitted recommendations to the Michigan Department of Environmental Quality (DEQ) concerning Cordia’s draft National Pollutant Discharge Elimination System permit to discharge the facility’s cooling water to a wetland network contiguous to Kids Creek. The Watershed Center has concerns with water quality standards and monitoring requirements outlined in the draft permit. The Watershed Center also requested the DEQ hold a public hearing to allow more voices to be heard in support of Kids Creek.

During the warmer months, Cordia circulates municipal water through an open-loop system to cool their facility. As a result, the water discharged from the cooling system is hot and chlorinated. Starting in 2015, Cordia’s cooling water was discharged to a stormwater pipe that led directly into Tributary AA of Kids Creek. In the summer of 2018, Cordia installed a system that diverted its cooling system discharge to a wetland network contiguous to Kids Creek, with an overflow that intermittently discharges directly into Tributary AA.

Water quality data collected by The Watershed Center in recent months illustrates that both the wetland network and Tributary AA are negatively impacted by Cordia’s current discharge system. Discharge water leaving Cordia’s facility has reached nearly 93°F and far exceeds Michigan’s Aquatic Maximum Value Criteria for chlorine. The wetland network naturally sustains water temperatures in the 60s and 70s (°F), while Cordia’s discharge entering the wetland network is consistently in the 80s (°F). Previous direct discharge and current overflow discharge to Tributary AA has warmed downstream reaches of the creek by more than 20°F, producing a section of Tributary AA unsuitable for aquatic life that has led to fish deaths.

Since discovering the illegal discharge into Tributary AA in 2015, The Watershed Center has been in frequent contact with the owners of Cordia and DEQ staff and has been hopeful these discussions would result in positive action. Those advocacy efforts eventually led Cordia to pursue an alternative discharge location for their cooling water that would eliminate harmful impacts to Kids Creek. However, Cordia’s newly constructed system still poses a threat to wetland health as the discharge is highly chlorinated and hot when it enters the wetland network. Further, the current system is designed to overflow into Tributary AA, which is resulting in pulses of hot, chlorinated water into this coldwater creek.

“We are extremely disheartened that Cordia continues to jeopardize the health of the Kids Creek watershed,” said Christine Crissman, executive director of The Watershed Center. “For the last four years, we continually offered Cordia our expertise and resources to find a solution. To see them continuing this harmful behavior despite our efforts is disappointing.”

Cordia’s actions are in violation of the Clean Water Act and the Michigan Environmental Protection Act. The Watershed Center believes this discharge has likely had, and will continue to have, adverse impacts on water quality and aquatic life in the Kids Creek watershed, including the state fish of Michigan, brook trout.

“The Watershed Center has been working for 15 years to restore Kids Creek and its tributaries, investing more than $5.3 million to improve water quality,” said Crissman. “As the nonprofit that advocates for clean water in the Grand Traverse Bay watershed, we will be the voice for Kids Creek.”

The DEQ will accept comments on the permit request through midnight on Wednesday, September 12 to Daniel Schwanik, Permits Section, Water Resources Department, Michigan Department of Environmental Quality, PO Box 30458, Lansing, MI 48909 or via email to

During the 60-day notice period, The Watershed Center is willing to discuss effective remedies for the violations. The full notice and additional documentation is available below:

Notice of Intent to Sue

Comments to the Michigan Department of Environmental Quality on draft National Pollutant Discharge Elimination System permit

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The Watershed Center is a non-profit organization that advocates for clean water in Grand Traverse Bay and acts to protect and preserve its 1,000-square mile watershed, which covers portions of Grand Traverse, Leelanau, Antrim, and Kalkaska counties. Learn more at

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