Casino at Columbia Bottom in Spanish Lake

After 18 months of work by the Save the Confluence Coalition, on December 1, 2012 the Missouri Gaming Commission announced Cape Girardeau will get Missouri’s last casino license, ending plans for a casino at Columbia Bottom in Spanish Lake, at the Chain of Rocks in St. Louis and at Sugar Creek in Kansas City.

The newspapers reported: “Asked why St. Louis lost out, Mathewson [Gaming Commission Chair] said: “We received stacks and stacks of opposition, just baskets of it, from the area. We also had a lot of positives. And I think probably the biggest single concern there is, is that market is already well-covered with casinos.”

Thousands of Missourians told the Missouri Gaming Commission to look outside St. Louis for a home for the next casino.

The original site that sparked the controversy was 377 acres adjacent to the Columbia Bottom Conservation Area in north St. Louis County at Spanish Lake near the Confluence of the Missouri and Mississippi Rivers. The plan placed a casino and shopping complex in the Mississippi River floodplain in the heart of the Mississippi Flyway used by migratory birds.

The Save the Confluence Coalition began its advocacy work toward victory in August of 2009. By the time of the Gaming Commission’s decision, the Coalition  represented more than 100,000 Missourians. The casino developers met strong resistance from the Save the Confluence coalition at every turn. Organizations  whomunited with Save the Confluence included: Audubon Missouri, BOTT Radio Network, Chatham Bible Church, The Confluence Partnership, Conservation Federation of Missouri, Glasgow Village Improvement Association, Grace Baptist Church, Mississippi Valley Duck Hunters Association, Missouri Clergy Against Gambling Expansion, Missouri Coalition for the Environment, National Audubon Society, Old Jamestown Association, Riverview Drive Improvement Association, St. Louis Audubon Society, St. Louis Christian Chinese Community Service Center, St. Louis Metro Baptist Association—70 Churches in St. Louis County, St. Peter’s Lutheran Church, Sierra Club: Eastern Missouri, Spanish Lake Community Association, Webster Groves Nature Study Society, and West Side Missionary Baptist Church.

Between the unified opposition and the bad economics, the casino developers faced difficult odds. Save the Confluence commissioned an economic analysis of the casino developer’s plan. The analysis clearly illustrated the St. Louis market was saturated — any new casino would cannibalize existing casinos. The new River City Casino which opened in south St. Louis in May 2009 already demonstrated this negative impact on revenues compared to competing enterprises. Casino executives from St. Charles County testified against a St. Louis license because of this market impact. The Missouri Deppartment of Economic Development issued an Economic Analysis in late November that concluded that any benefits of a St. Louis casino would be offset by losses at existing area casinos.

Buildinga casino next to one of the most prized natural areas in the region likewise proved a failing. One of the driving factors in the defeat of the Columbia Bottom casino was how it would undermine the $170 million investment in natural areas, parks, museums and conservation areas in the Confluence region.

This David vs. Goliath struggle of the Save the Confluence coalition vs. the casino developers ultimately prevailed because the numbers were on our side. However, it was our job to shine a bright light on these facts by continually feeding this information to the press through press conferences, releases, and letters to the editor. The results were dozens of articles that consistently linked any stories about the casinos with the Save the Confluence opposition and the very real threat to this natural area. On a second front, we continually reiterated the bad economic facts to the gaming commission with the postcards mentioned above but also private letters, phone calls and comments made at public hearings from lawmakers and community leaders who were asked to and did speak out.

Some of the highlights of the campaign included nearly 50 people picketing the County Council when it made its rezoning decision, KETC’s production of a video about the Confluence area, a letter from filmmaker Ken Burns in support of the Confluence, and a tour of the site one morning with the herons gliding over its waters. And who could forget the eagle suit at Eagle Days?

The developers seeking the casino at Columbia Bottom fell out when they failed to submit a complete application by the Gaming Commission’s fall deadline. It was then that the Koman family’s proposal for a casino at the Chain of Rocks Bridge in north St. Louis became the top St. Louis candidate for the license. Riverview Drive Improvement Association, which had successfully fought other casino attempts, was joined by a second city neighborhood organization, the Chain of Rocks Community Association in opposition to the casino plan. As the only St. Louis city location, the Aldermen, the Mayor and other boosters joined with Koman. Nevertheless, the Gaming Commission’s December 1 decision eliminated that option as the final license was granted to Cape Girardeau.

More Good News

Great Rivers Greenway announced December 22 that it acquired 11.8 acres of the undeveloped property at the Chain of Rocks Bridge for $1.25 million from the Koman family, pursuant to a previous agreement. The newly acquired property, which has been used with the Koman Family’s permission for public functions in the past, will eventually be used to provide greater public access and additional amenities at the bridge and trailhead.


Save the Confluence supporters are still aware of threats to the Columbia Bottom area and are working to find ways to protect the floodplain for agriculture and low-density uses. 

Alicia Claire Lloyd, Clean Water Policy Coordinator

"In an age when man has forgotten his origins and is blind even to his most essential needs for survival, water along with other resources has become the victim of his indifference." - Rachel Carson


TAKE ACTION NOW to join the Clean Water Movement



                                                                            Created by: Joe Mohr Toons,


We enjoy summer float trips, swimming, and canoeing Missouri's rivers. 

We like the craft beer produced by Missouri's breweries.

We care about the safety of the water we drink and the health of Missouri's wildlife - from blue catfish and paddlefish to river otters and the mallards that migrate along our rivers.

Natural resources and the ecosystem services they provide are publc goods. Access to clean drinking and bathing water is a human right - a right that is threatened by pollution and irresponsible development.

The environment does not have its own lobbyists or political influence to advocate for its protection. 


Because clean water is crucial to a healthy people and aquatic habitats, we advocate for the protection and restoration of our state's abundant and valuable water resources. Because we all need clean water, MCE works on behalf of Missouri's rivers, lakes, streams, and wetlands - resources all of us depend on and enjoy.




Rainscaping Story Map

Check out our interactive story map citing examples of green infrastructure and their benefit on urban water quality in St. Louis and on reducing the burden of stormwater on our sewer system!


The St. Louis Metropolitan Sewer District has provided grants for small and large-scale rainscaping, rain gardens, and rain barrel projects throughout the city. The City of St. Louis, MSD, East-West Gateway, and others are working to promote green infrastructure and urban renewal throughout the city and metro area. For more information on GI work in St. Louis, visit the City of St. Louis’ Urban Vitality website here

Rainscaping and Rain Gardens

A feasible and innovative way to collect the rainwater and beautify your garden at the same time is to build a rain garden! As an important and versatile tool towards stormwater management, a rain garden is a landscaped site that collects, absorbs, and filters stormwater runoff from roof tops, driveways, patios, and other hard surfaces that don't allow water to soak in.

Below is a diagram showing how a residential rain garden works in your yard.  A rain garden starts with a bowl-shaped bed of loose soil with plantations of deep-rooted trees, bushes, flowers and other plants that help absorb the rainwater. The plants serve as filters through layers of soil before the rain water enters the groundwater system or the stormwater system through the underdrain. Your rain garden is your personal contribution to cleaner water!                         


 If you are interested in building a rain garden in your yard or neighborhood, check out the resources below:

Ozark National Scenic Riverways at risk

In 2011, American Rivers designated the Ozark National Scenic Riverways one of the most endangered rivers in the country. Unfortunately, not much has changed since then and some things have gotten worse. MCE and Friends of Ozark Riverways want to protect the outstanding natural beauty, ecological vitality, and rich history of the Riverways. 

We have an opportunity to address degradation of the treasured Ozark National Scenic Riverways and protect the resource for generations through the National Park Service's upcoming Roads and Trails Plan.  And WE NEED YOUR HELP!

We stand to lose a lot over the next few years unless we keep the pressure on to protect our most precious resources. Any setback in the protection and maintenance of Missouri's premier National Park, Ozark National Scenic Riverways (ONSR) could take decades to restore. We must be vigilant in our protection. And we have the perfect opportunity in the upcoming Roads and Trails Plan. 
ONSR is one of Missouri's most treasured areas for biodiversity and outdoor adventure. It is a place of exquisite natural beauty and is unparalleled in the unique and remote recreational activities it offers visitors. 

In 2015, ONSR attracted 1.2 million visitors, with local economic benefits over $50-million.  It was the first park of its kind to protect a river system, the Current and Jacks Fork Rivers.

The General Management Plan was posted in December 2014.

See the latest maps on the Current River watershed developed by our former Clean Water Director Lorin Crandall.



The General Management Plan guides policies and practices in the Riverways for decades to come. It sets priorities for resources, staffing, and activities. The Roads and Trails Plan is a more specific plan and the Park Service is in the process of considering comments from recent open houses and drafting preliminary alternatives. The alternatives are scheduled to be released in February 2016 and we will need your help to advocate for the best alternative.

Stay tuned for more details!


MCE's comments on the 2015 General Management Plan

The draft plan presents three alternative approaches which are outlined below. 

 In the Riverways, unauthorized roads, overuse by all terrain vehicles and excessive equestrian use in sensitive areas have contributed to degradation including increased bank erosion, more sediment in the water, reduced habitat quality, and unsafe bacteria levels in certain river stretches. Re-directing high impact activities to areas where damage is minimized, establishing levels of use that enable the rivers to maintain quality, allowing damaged areas to heal, and organizing activities with respect for the natural resources are the keys to stewardship of the Ozark National Scenic Riverways. With your input, management of high impact activities can be integrated fairly into a GMP that preserves fishing, floating, hiking, boating, and wildlife habitat.


The Missouri Coalition for the Environment has supported policies that help restore and preserve outstanding water quality and habitat values, address threats to water quality, and maintain the quality of the Riverways for this and future generations. 

Main Message: Strengthen the Management of the Ozark National Scenic Riverways through completion of a new General Management Plan (the current plan dates from 1989).

What the plan does:

The draft plan proposes management zones for land and water uses that vary in extent for each of three alternatives. The land-based zones are:

  • Developed
  • Resource-based recreation
  • Natural
  • Primitive
  • Mixed-use
  • Seasonal mixed-use
  • Non-motorized river-based

See maps of the zones for each alternative on pages 61, 67, 75 and 81 in the plan and a comparison of alternatives in Table 13 on pages 125-30 here.

This park’s problems have included the seemingly ever-expanding presence of motorized vehicles and their maze of eroded tracks in riparian areas and on gravel bars; the explosive growth of equestrian use and proliferation of undesignated trails and river crossings (many of which are in sensitive riverine areas or on steep, heavily-eroded slopes); overcrowding in certain reaches of the rivers and resulting conflicts among user groups, coupled with the rowdy behavior of some visitors; and inadequate monitoring and enforcement of scenic easements.

Though people will differ in their views of which alternative is best, we support the Friends of Ozark Riverways belief WarningOct-2005 007-webthat the National Park Service has provided a reasonable range of alternatives and deserves support for its commitment to dealing with serious problems that have developed over the years.

However, the Riverways has seen a 30% reduction in staff in the last decade, owing to decreases in funding, and there is no guarantee that funds will be enhanced to the levels anticipated by the plan alternatives. That is one reason to approach with caution higher cost alternatives that feature increased development and more intensive use like those presented in Alternative C. We favor maintaining visitation at approximately the current level while emphasizing improvements that are less demanding in terms of staff and more conducive to family recreation.


Each of the action alternatives provides for:

  • A mix of recreational and interpretive activities
  • More effective distribution of concession drop-off/pickup points for watercraft to reduce crowding
  • Year-round non-motorized watercraft use, motor-free zones, and zones for year-round or seasonal motorized watercraft use
  • Mountain biking on designated trails
  • Management of roads, river access points and land access to gravel bars by zones
  • Ecological restoration projects including restoration of undesignated roads, traces, trails, and river access points and crossings
  • Preparation of a horse use and trail management plan (and possible permit system), improving and adding more designated horse trails, and closing and restoring many informal trails
  • Increasing law enforcement for compliance
  • Restoration of historic structures and cultural landscapes
  • Allowing mountain biking on designated trails
  • Allowing for new concessions for overnight activities such as guided float trips and guided backcountry hiking trips
  • Partnering with state officials to enhance healthy game fish populations
  • Partnering with counties on road management and with state officials to enhance healthy fish and wildlife populations, organizing a national park advocacy group for the Riverways and various other partnerships
  • Construction of various new park operational facilities

Alternative A

The National Park Service identifies Alternative A as the environmental preferable alternative. It emphasizes traditional, non-mechanized recreation and visitor experiences that are quieter, less crowded and slower-paced. To reduce motorized intrusion it would close unauthorized roads, traces and river accesses, restore 50 miles of such roads to native vegetation, replace 15 miles of undesignated roads within primitive management zones with hiking trails, and no longer allow motor vehicles on gravel bars (walk-in or float-in day use and camping still allowed). To reduce equestrian overuse it would add 25 more miles of designated horse trails, close and restore 65 miles of undesignated horse trails, improve the design of the 23 miles of currently designated horse trails, and consider establishing a permit system for horse use within the park. To improve visitor experience and reduce conflicts among users, there would be more hiking trails, more motor-free zones, and redistribution or limit of commercial services. There are some staffing increases.

Alternative B

The National Park Service prefers this alternative. It would enhance opportunities for visitors to learn about the park’s natural and cultural resources, and provide a balance of diverse recreational opportunities with increased opportunities for education and appreciation of park resources. To reduce motorized intrusion it would close undesignated roads and access points, restore 45 miles of such roads to natural condition, convert 10 miles of roads in primitive zones to hiking trails and reduce and designate camp sites on gravel bars open to vehicles. To reduce equestrian overuse it would add 35 miles of designated horse trails, close and restore 65 miles of undesignated horse trails and unauthorized river crossings, improve the design of the 23-mile CurrentRvr04-05 008ONSRCabinWeblong designated horse trail system to avoid sensitive areas, establish a permit system for horse use within the park, and may allow for designated horse camping sites. To improve visitor experience, there would be a new learning center and visitor contact station at Powder Mill; two additional campgrounds at existing day use areas at Akers on the Current and Blue Spring on the Jack’s Fork; additional trails; a resumed oral history program, discovery sites, and enhancement of archive and museum collections; and strengthened monitoring, research, and preservation projects. The Cedar Grove low water crossing would be replaced with a high-water bridge. Waste systems in the park would be improved. There are staffing increases under this alternative.

Alternative C

Alternative C would accommodate higher levels of park visitation and more intensive recreation while striving to maintain the scenic natural setting and protect cultural resources. To reduce motorized intrusion it would close undesignated roads and access points, restore 40 miles of such roads to natural conditions, replace five miles of roads in primitive zones with hiking trails, and allow vehicular access only to designated sites on gravel bars. To reduce equestrian overuse it would add 45 miles of designated horse trails, and close 65 miles of undesignated trails and river crossings; it might also develop a 25-unit horse camp along the Jacks Fork. Visitor experiences would include two additional campgrounds, possible more backcountry and primitive campsites, more interaction among visitors and higher resource impacts especially in higher use area. Staffing levels would increase the most under this alternative to provide for more use and more monitoring and mitigation of impacts to resources.102 0211Cave1web


The 1989 plan is due for an update in order to reverse the degradation of the Riverways. The Ozark National Scenic Riverways deserves an increased investment of staff and resources to ensure it retains its quality as Missouri's own 'Yellowstone'.

We prefer Alternative B, with some additions and qualifications, because it:

  • Addresses concession (floaters) drop off and pick up location overcrowding in certain areas by redistributing them to include 20 new designated access points while keeping the total designated access points constant. (Alternative C also does this.)
  • Provides a balance of diverse recreational opportunities;
  • Enhances opportunities for visitors to learn about the park’s natural and cultural resources including discovery sites, and expanded archive and museum collections;
  • Restores 45 miles of undesignated roads to natural condition while reopening some old roads for vehicular access to discovery sites;
  • Reduces gravel bars designated for vehicle access which helps reduce ecosystem damage and protect public safety;
  • Adds 35 miles of designated horse trails to the existing 23 miles of designated horse trails, while closing and restoring 65 miles of MeadowFlwrsONSR04-15-05 005webundesignated horse trails and unauthorized river crossings;
  • Improves the design of the 23-mile long designated horse trail system to avoid sensitive areas while keeping the seven designated stream crossings;
  • Establishes a permit system for horse use within the park as necessary in conjunction with development of a horse use and trail management plan;
  • Establishes a new learning center and visitor contact station at Powder Mill;
  • Builds two additional campgrounds at existing day use areas at Akers on the Current and Blue Spring on the Jack’s Fork;
  • Restores five additional cemeteries (Alternative C does this too);
  • Restores additional historic structures;
  • Enhances the Riverways’ role as an archeological curatorial hub for the region.
  • Adds trails;
  • Resumes an oral history program;
  • Strengthens monitoring, research, and preservation projects;
  • Replaces the Cedar Grove low water crossing with a high-water bridge;
  • Improves waste systems in the park;
  • Separates back country camping (which offers some facilities) from primitive zones (which offer no facilities).
  • Increases staffing.

Additionally, the Missouri Coalition for the Environment supports the following changes:

  • More hiking trails (each alternative offers 15 miles or fewer)
  • No horse campgrounds in the Riverways (25 sites are proposed for Alernatives B and C). We do not agree that the ONSR needs a designated horse camp in the park, preferring that this opportunity be developed by the private sector, on private land in proximity to the park. Instead of a new development of this magnitude, we ask that NPS work with existing local businesses to provide a concession horse camping operation outside the park that would have less impact on park resources within the narrow river corridor.
  • Minimal restrictions on motorized boats. We oppose year-round prohibitions on boats in certain stretches of the Riverways because such restrictions would eliminate opportunities for area residents to enjoy the Riverways. We think any restrictions on boats should be minimal and driven by evidence of a problem that only restrictions will solve. If better enforcement will solve the problem we prefer that to prohibitions.
  • Sensitive natural and cultural resource management that avoids new conversions of bottomland riparian forests to open fields, or artificial pasture for elk and other animals and focuses on restoration of upland meadows, woodlands, and glades with native vegetation.
  • The restoration of impaired riverbanks that avoids developed facilities along the rivers, which are screened from view from the river in any case, and low impact. We suggest that heavily engineered solutions be avoided (e.g. Rock and weirs) and instead NPS talent and experience be employed to bring natural landscape design and sustainable structures appropriate to the site.
  • Prioritization of solutions for problem areas that focuses on low-impacts in riparian zones. For example, the area across from Welch Spring should be restored where heavily rutted unauthorized roads mar an undeveloped bank. Damaged areas should not serve as opportunity to add new ‘hardened’ development where it does not belong and instead should receive restoration.

Additional ThoughtsPrairieHlw2SM

MCE urges the National Park Service to approach the designation of mountain bike trails with care for the vulnerabilities of the landscape so that erosion, impacts to biodiversity and water quality are minimized.

 Friends of Ozark Riverways agrees with NPS that Alterative B provides the most balance among the three alternatives, though some of our organizations and members may favor the environmentally preferable Alternative A or a mix of elements from alternatives A and B. Alternative B would provide more staff for maintenance, monitoring and enforcement while substantially enhancing visitor experience of park resources. We believe that several improvements could strengthen the plan:

    • Scenic Easements. Although there are not changes to scenic easements proposed in this plan there are 9,257 acres of scenic easements that are intended to maintain the natural environment and scenery for the benefit of the visiting public. These easements are critical to the quality of the Riverways. They were acquired to add public value to the national park and need to be effectively monitored in a timely manner. Easement violations must be corrected promptly.
    • Annual Visitation and Economic Influence. Visitation is about 1.3-1.5 million people each year. A 2011 study estimated visitor spending at $55,445,000, more than 88% of which is by non-local visitors. This spending combined with NPS employment accounted for 845 jobs, or 16% of total employment in Shannon and Carter counties. We support this high-valued investment in the Ozark region of south-central Missouri, understanding that a well-managed park and the visitors it attracts may be the most important contributors to the long-term economic health of local communities.
    • Wilderness. The GMP review includes one small, undeveloped backcountry/wildland area of approximately 3,400 acres near Big Spring. The area, which was acquired as a state park in the 1920’s and later became part of the ONSR, has been continually managed as an undeveloped wild area and we support that approach. We also support the use of prescribed fire to manage wildland quality. The NPS is proposing in each alternative to recommend some portion of the Big Spring area as qualified for federal wilderness protection (Alternative C proposes 1,779 acres for Big Springs wilderness). Management would continue largely unchanged as it has been but with the recognition that it can provide a true wilderness experience, which would be an addition to riverways offerings we support the NPS-preferred Alternative B which recommends 3,430 acres for wilderness management , while recognizing that official designation as federal wilderness is beyond the scope of the ONSR GMP.
    • Horsepower Limit. Zoning for horsepower limits on boats have been part of existing regulations since the River Use Management Plan of 1989. FOR supports the balanced approach of motor-free zones for upper reaches of the Current and Jacks Fork rivers and seasonal or year-round provision for motors on other reaches as proposed in Alternative B. (NPS recognizes that the present and proposed 60/40 horsepower limit is in violation of the Code of Federal Regulations and is proposing a rule change process in order to continue allowing it.)




Phosphorus and nitrogen are necessary to sustain life, however, too much of a good thing can cause problems in our waterways.

Excess phosphorus in our streams and lakes causes algae blooms (which look like green gunk in the water), reduces water clarity, and saps water of dissolved oxygen. These effects make water bodies less appealing for human recreation and can cause fish kills and other ecosystem disruptions.

Nitrogen and phosphorus pollution comes from farm animals, fertilizers, human sewage, cars, and storm-water runoff from highways and parking lots. In general, runoff from farms and urban areas causes the greatest problem, although sewage treatment plants are significant contributors as well.

When excess nitrogen and phosphorus enter waters from discharges, fertilizer run off, and other sources, they cause an explosion of algae or phytoplankton in the water. The algae quickly deplete the dissolved oxygen in the water and then die themselves. Fish and other water creatures leave the polluted area, if they can, or die, if they cannot escape. The resulting dead zone is known as a hypoxic zone. These dead zones occur in lakes and even in streams.

Nitrogen pollution from Midwestern farms contributes to the massive annual “dead zone” in the Gulf of Mexico . In 2007, the dead zone covered 7,900 square miles, an area comparable to the size of New Jersey . At high levels, nitrogen in drinking water can even threaten human health, by interfering with the blood’s ability to transfer oxygen to cells. Nitrogen pollution of well water is responsible for “blue baby” syndrome, a life threatening condition present.

Technologies exist to remove nitrogen and phosphorus from sewage plant discharges, and best management practices such as buffer strips and wetland restoration can reduce pollution from farm runoff.

MCE has been working with the Mississippi River Collaborative and the Interdisciplinary Environmental Clinic at Washington University School of Law to secure the adoption of nitrogen and phosphorus pollution limits in our state.


MCE advocates for nutrient pollution protections on our lakes, rivers, and streams. MCE settled a lawsuit on 12/7/16 against the USEPA compelling the Agency to develop numeric water quality standards for Missouri lakes by 12/15/17. Read more here.

In a second suit, a US District Court decided on 12/15/16 that EPA's lack of resources and capacity renders it unable to adequately address nutrient pollution in Mississippi River basin states. MCE, the Gulf Resoration Network, and other environmental groups as part of the Mississippi River Collaborative lost their lawsuit demanding EPA step in to regulate nutrient pollution in light of decades of state inaction.  

Nutrients, such as nitrogen and phosphorus, are a natural part of the ecosystem. These elements are essential to the growth of plants. However, excess nutrients cause an overgrowth of algae in aquatic systems—more than the system can handle. As algae flourishes, it blocks the light entering the water that other plant life rely on to grow and thrive. When plants die, they consume oxygen as they decompose. When the overabundance of algae and the light-starved submerged vegetation die, they are no exception and cause massive depletion of dissolved oxygen. Excess nutrients are the perfect storm for an impaired, non-functioning river or lake. No life—fish, aquatic invertebrates (bugs), nor plant life—can survive in an oxygen-depleted ecosystem. Hypoxic conditions occur when there is little oxygen available for aquatic life resulting in fish kills and further ecosystem impairments. In cases of extreme nutrient pollution, known as anoxia, the oxygen levels are so low that all oxygen is eliminated from the aquatic system and all organisms die. The most prominent example of this is the 5,500+ square mile area in the Gulf of Mexico—also known as the Dead Zone—a result of nutrient-polluting human activity on land. Read more about nutrient pollution from the EPA

Nutrient Criteria

The Clean Water Act requires states to designate uses on waters in its boundaries and establish Water Quality Standards (WQS) including the development of numeric nutrient criteria. In December 2014, Missouri's Deparment of Natural Resources released a Nutrient Loss Reduction Strategy (NRS) for the state. The NRS is a first step in outlining the best management practices (BMP) and activities that reduce nutrient loading in our waters; however, numeric limits on allowable nutrient pollution, as required by law, are necessary to achieve and maintain water quality.

In 2011, EPA disapproved the state's proposed numeric nutrient criteria for lakes requiring Missouri to resubmit a new proposal. Several attempts at drafting revised versions were halted by special interests who fear regulation will hurt their bottom line. Four years later, the most recent draft developed by DNR and other stakeholders was proposed in the Nutrient Criteria Technical Subcommittee

On November 6, 2015, MCE sent a Notice of Intent to File Suit to EPA alleging violation of US EPA’s mandatory duty to issue effective standards when the state does not take action on its own.  MCE officially filed suit on February 24 following a 60-day waiting period.

Concurrently, Missouri is developing a Water Quality Trading (WQT) program. WQT is a market-based mechanism to achieve water quality goals at lower costs to permittees. Trading programs like this one rely on the fact that some polluters can reduce their discharge more easily than others.  In this case, farmers can undertake inexpensive projects to limit the amount of runoff from their fields to meet water quality standards while industrial polluters would have to construct costly changes to their facilities to reduce the same amount of nutrient pollution.  Those who reduce their discharge below their allotted quantity determined by the nutrient criteria can then sell the difference to buyers to whom purchasing nutrient pollution credits is more economical. 

When compared to the traditional command and control model of regulation where government authorities would simply mandate that each polluter limit their discharge to a specified amount, trading progams are much more flexible.  Trading programs allow for the water quality standards to be met in a manner than minimizes the negative economic impact of regulation.  Importantly, the program will need benchmarks such as numeric criteria to meaningfully set the caps for regulated entities.  MCE supports the implementation of water quality trading under the essential condition that water quality is ultimately improved.  Read more about Water Quality Trading


The consent decree agreement between the Metropolitan St. Louis Sewer District (MSD) and the Environmental Protection Agency requires $100 million to spent on “green infrastructure” to alleviate Combined Sewer Overflow (CSO) problems that much of the city is facing.

Read about Green Infrastructure below and then check out our interactive rainscaping story map!

What is Green Infrastructure?

Green infrastructure, commonly abbreviated as “GI”, is a form of water management that incorporates plants and landscaping practices to control the flow and direction of stormwater. Central to the design of all green infrastructure projects is a concave soil bed that absorbs water and reduces impervious surface area in an urban landscape. 

A bioswale in action on New York City's Streets. Similar bioswales can be found on South Grand in St. Louis

Green Infrastrucure has multiple benefits, helping to...

  • Reduce stormwater runoff which helps reduce erosion and flooding.
  • Increase the amount of water that soaks into the ground to recharge local groundwater.
  • Filter harmful pollutants such as oil and grease from driveways, pesticides and fertilizers from lawns, etc.
  • Increase biodiversity through providing habitat for beneficial insects and birds.
  • Enhance the landscaping and appearance of homes and yards.
  • Protect our streams and rivers.

NOTE: While the Venn Diagram above depicts the overlapping benefits of green infrastructure, MCE challenges the triple-bottom-line approach, generally, as insufficient for achieving long-lasting, equitable sustainability, and instead promotes the idea of "strong sustainability," emphasizing that the human sphere is embedded in a natural system with limits that ought to constrain our actions. For futher information, please read "Our Future" under MCE's publication page 


What is Grey Infrastructure?

GI’s plant-based design differs from conventional Grey Infrastructure, which uses traditional pipe-based systems to direct and collect water. The city of Saint Louis installed its first grey infrastructure system in the early 1850s, and today nearly 10,000 miles of pipes are used to transport wastewater across the city. 

Because grey infrastructure is such a well-established and standardized practice, it makes the design and construction of project relatively easy and timely when compared to other management practices. Additionally, the engineered design of grey infrastructure makes the practice easy to monitor and control (ex. computer control of sewer outflows, water flow)











In a combined sewer, excess rainfall can lead to overflows into waterways. Green infrastructure reduces the amount of stormwater that reaches sewers, reducing overflow events.

Despite its benefits, traditional wastewater systems can fall into disarray when they are not properly maintained. For years, much of St. Louis’ grey infrastructure was improperly cared for. Sewage and stormwater flow through an aging shared pipe system (combined sewers), and heavy rainfall combined with imprevious surfaces causes too much stormwater to enter the sewers. This leads to regular sewer backups and overflows, many of which happen in low-income minority areas of the city.




How can GI fix St. Louis’ Aging Sewers?

GI helps to increase the amount of storm water that can be reabsorbed into the watershed, reducing the occurrence of raw sewage overflows into streets and waterways. St. Louis is one of many cities that are looking to green infrastructure to alleviate the burden on aging grey infrastructure systems. In 2012, Kansas City completed its Middle Blue River Basin Project, helping to reduce annual combined sewer overflows by 76% (292,000 gallons at one outflow).  

MCE supports MSD's efforts to use green infrastructure in order to:

  1. Reduce overflows and strains on grey infrastructure
  2. Promote community wellness through education and outreach

MSD's full GI implementation plan

Are you a committed to protecting your watershed? Welcome to Watershed 101 where you can learn the basics of watershed function, how you can improve the health of yours, and pledge to be a Watershed Warrior!

Watersheds are extremely important to the environment as well as the surrounding community.  They include the water we use for recration as well as the water we use for everyday life like drinking and bathing.  By pledging to become a Watershed Warrior, you are committing to make an effort to be concious of how your decisions affect your watershed, as well as making an effort to reduce those impacts. Do you want to join our army of warriors fighting for clean, healthy watersheds??

1. Click Start Prezi below to learn 'What every Watershed Warrior needs to know" starting with what a watershed is, water pollution threats, and what can be done to reduce water pollution in our communities and neighborhoods.

2. Before you take the quiz and pledge, you can find your watershed on our interactive watershed map! Maps of both the St. Louis and Kansas City areas will allow you to find your watershed, as well as where it is in relation to other features such as rivers and parks. 

3. Let's see what you learned! Scroll down to test your watershed knowledge on the short quiz! Select Next after the Hellbender image to begin and progress through the questions. You can do it!!

You're ready to become a Watershed Warrior! Take the quiz and pledge!


Everyone lives in a watershed

Image created by: Joe Mohr Toons,

What is a watershed? Why is what we do on land crucial to clean water?

A watershed includes all of the life-sustaining connections and interconnection that provide us with clean, useable water. The most fundamental of these connections is the mutual relationship between land and water.  Every land area drains into a water source which means land activities are inextricably tied to the health and quality of our water supply. Also known as a "drainage basin" or "catchment" - a watershed is the area of land that drains into a river, wetland, or creek from the land surrounding it. The land in every watershed is drained by creeks and streams- each with its own small watershed - land draining to it. Collectively, the waters merge into the larger watershed of a river. Small or large, all watersheds share similarities in form and function, and each watershed is ecologically unique. 

The connection between water and land connect human beings' activities to the health of our water resources. Animals and plant life all impact their immediate environment, but the fluid, mobile nature of water introduces the complexity of movement. The impacts of these activities include the introduction of pollutants and sediment literally carried by surface and underground flow to the next lowest point on and on until discharging into bigger rivers and ultimately, the ocean. 

Be a WATERSHED WARRIOR!! Take the pledge to reduce your impact and improve the health of your watershed.


Watershed Projects and Resources:

Check out Watershed Cairns to see art connect with water! Cairns are stracks of rocks used to demarcate trails. These beautiful glass sculptures are displayed in places of signifcance to watershed functioning in outdoor locations in Illinois and Missouri. The locations denote areas where land collects water - places that conduct water to creeks, streams, and rivers to ultimately arrive in the Mississippi River. The Cairns are photographed and removed due to their fragility. See the Watershed Cairns website here.

The Our Missouri Waters Initiative is a Missouri Department of Natural Resources effort to engage citizens and sound science to develop watershed-specific strategies to collaborate on common goals to address challenges in each basin. 

MCE's involvement in the Kiefer Creek Watershed began in 2009 when dogs were becoming ill after coming in contact with the creek in Castlewood State Park. Thus began the Kiefer Creek Watershed Restroation Project. The long term project engaged local watershed residents in the development of a watershed management plan to address bacteria (e.Coli) and chloride pollution impairing the water supply.


What's up with all the sewer infrastructure work throughout St. Louis? Read about the EPA v. MSD Consent Decree below:

The St. Louis metro area is in the process of undergoing major upgrades to its sewer system. Like many systems across the country that were constructed before separate storm and sewage transport, during heavy rain and storm events in St. Louis, (see Sewer Systems and Wastewater for information on combined sewer systems), stormwater and wastewater from the sewage system discharge untreated into the local waterways from combined segments of the sewer system. According to EPA, untreated sewage discharges account for thousands of cases of gastrointestinal illnesses each year in the U.S. In order to address the sewer overflow conditions as well as to improve the sewer system infrastructure in our community, a Consent Decree between the Environmental Protection Agency, the Missouri Coalition for the Environment, and the Metropolitan St. Louis Sewer District in The United States et al v. The Metropolitan St. Louis Sewer District, No. 4:07-CV-1120 (E.D. Mo.) was entered with an Effective Date of April 27, 2012 (EPA, St. Louis' Clean Water Act Settlement).

Under the Concent Decree, MSD is committed to infrastructure improvement projects for work in both the Sanitary and Combined collection systems (as introduced in the Sewer System and Wastewater page) and in the wastewater treatment plants (WWTPs) with a total estimated cost of $4.7 billion over the next 23 year period. 200 or more SSOs will be eliminated, CSO control measures implemented, and the capacity of the District's WWTPs will be expanded to reduce pollutant discharges throughout the system. The objective of the improvement projects will be to eliminate and mitigate overflows of untreated raw sewage prioritizing known problematic areas and to reduce contaminants entering the system from stormwater with green infrastructure projects (MSD's Project Clear). MSD is required to take the following actions:
  • Remedial measures and schedules for Sanitary Sewer System include:
    • Sanitary Sewer System Characterization Report: Identification and mapping of all constructed SSO outfalls, signage establishments of all streams, creeks, drainage ditches, and swales receiving Constructed SSO discharges, monthly inspections of Constructed SSO locations and all downstream signs.
    • Elimination of constructed SSOs throughout the system over the duration of the Consent Decree with the majority eliminated in the first 12 years:
      • Since the Consent Decree was finalized, MSD has completed early elimination projects according to schedule for constructed SSOs through December 31, 2012 identified in the map below. MSD has also employed $30 million in applicable and accepted engineering methods for reducing inflow and infiltration through December 31, 2013 for other system improvements.

Explore the interactive map below to see where and when SSO elimination projects may be scheduled to occur near you. Select 'Layers' to show/hide information of interest.

Additional requirements for Consent Decree compliance include:

  • Sanitary System:
    •   Sewer System Evaluation Survey: Elements include data management, quality control, data review, rainfall gauges, flow monitoring equipment, rainfall and flow monitoring, and also investigative activities; results shall be used to develop Sanitary Sewer Overflow Control Master Plan as well as develop remedial measures in the plan.
    • Hydraulic Model: MSD shall use the model to assess the hydraulic capacity of the SSOs and shall use its best effort to produce the most adequate and accurate results.
    • Capacity Assurance Evaluation: Identification of peak flow capacities within the Sanitary Sewer System.
    • Sanitary Sewer Overflow Control Master Plan: No later than December 31, 2013, MSD shall submit the Plan to EPA, with a copy to MCE. The Plan shall address remedial measures, a flow metering plan, a schedule of specific projects for the Elimination of Constructed SSO Outfalls, and estimated capital and costs for each identified project.
    • Capacity, Management, Operations, and Maintenance Program Plan: MSD shall submit to the State, the EPA, with a copy to MCE for review no later than six months from the Effective Date by MSD. The Plan shall includes procedures for inspecting and cleaning Gravity Sewer Lines, procedures for inspection, repair, rehabilitation, and replacement of Sewer System manholes, procedures for ensuring that permanent repair, rehabilitation, and/or replacement of sewer pipes are properly designed and constructed to prevent overflows and reduce sources of infiltration and inflow.
    • Fats, Oil and Grease Control (FOG) Program Plan: No later than three months from the Effective Date, MSD shall submit to EPA and the state for review and for EPA’s approval, with a copy to MCE. Performance and maintenance guidelines for FOG shall be included.
    • Private Infiltration and Inflow Reduction Program: No later than six months from the Effective Date, MSD shall submit to EPA and the state, with a copy to MCE, a plan describing proposed remedial actions regarding reduction of storm water discharge, surface waters, ground waters, roof runoff, excessive I/I to the Sanitary Sewer System.
    • Certification of Legal Authority
    • Revised Non-Capacity Related SSO Response Plan: No later than three months from the Effective Date, MSD shall provide to EPA and the State for review and for EPA’s approval, with a copy to MCE a revised plan responding non-capacity related SSOs and minimizing the environmental impact and potential human health risk from contact with sewage.
    • Building Backup Response Plan: No later than three months from the Effective Date, MSD shall submit the plan to address Building Backup recurrence.
    • Cityshed Mitigation Program: MSD shall continue its Cityshed Mitigation Program to mitigate the effect of wet weather surcharging and overland flooding of the combined sewer system (Citysheds).
  • Implementation of Combined Sewer Overflow Control Measures and Post-Construction Monitoring
    • Implementation of CSO Control Measures
    • Post-Construction Monitoring Program
    • Achievement of Performance Criteria
    • Compliance with MSD’s Missouri State Operating Permits
    • Supplemental Remedial Measures Plan

 Read the full Consent Decree.

Login Form