Testimony provided by the City of Akron, Patrick D. Gsellman, PE,
Manager, Environmental Division
Akron Engineering Bureau, City of Akron, Ohio
166 South High Street, Akron, Ohio 44308
330-375-2357
Committee on Environmental and Public Works
Wastewater Infrastructure Needs in Ohio
Monday, April 30, 2000, 9:30am
Columbus City Hall Chamber, 90 West Broad Street, Columbus, Ohio
Akron, Ohio is located on the Cuyahoga River, in northeast Ohio, approximately 30 miles upstream from the City of Cleveland. The Akron wastewater planning area covers approximately 167 square miles and includes most of the Akron metropolitan area. There is a population of 352,000 in the service area and includes all or a portion of 5 cities, 4 villages and 7 townships.
The sewer system includes approximately 1,165 miles of sewers consisting of 188 miles of combined sewers. There are 38 combined sewer overflows (CSO) within the City of Akron. Based on predictions from the hydraulic model typical annual CSO volume is 2,440 million gallons. Previous efforts by the City of Akron have resulted in the elimination of sanitary sewer overflows (SSO) in the City of Akron and the award of the Association of Metropolitan Sewer Association’s (AMSA) gold award for no effluent violations in 2000.
The City of Akron has proposed a Long Term Control Plan that will cost more than $248,000,000 to implement. This cost is in addition to the millions Akron has already spent to date to study, address and reduce CSO’s, and the $25 million spent to eliminate SSOs. Akron has seen a significant decline in its industrial base since the 1960s, requiring the residential users to carry the burden. Akron already carries one of the highest residential sewer rates in the State for communities of similar population.
The Akron Public Utilities Bureau is undergoing significant changes as result of the high water rates. The rates led to a Blue Ribbon Panel to study the Utility and the current Competitive Action Program. This program includes the water treatment facility, sewer maintenance, Water Pollution Control Station and Utilities Engineering. Significant reductions in operation costs are being realized and will allow the Utility to be competitive in the future. This will allow for the City to pay its fair share of needed improvements as long as the Federal government contributes its fair share.
As part of developing Akron’s Long Term Control Plan, several options to fund the projects were evaluated. Given the significant total cost of these projects, it is likely that funds will have to be obtained from multiple sources, i.e. grants, low interest loans and revenues obtained by sewer rates. Grants are essential to the fundability and feasibility of the program. Without outside funding, sewer rates will more than double due just to the CSO program. The impact of additional operation and maintenance costs, system repair and replacement and normal inflation will likely see the rates triple. Current monthly sewer charges for a typical residential customer are approximately $30.00 per month for sewer only. The rate increases to $60.00 or $90.00 per month will adversely affect a significant portion of ratepayers, including those who can barely afford their current utility bills.
The selected alternative for the City of Akron Integrated Plan incorporates storage conveyance tunnels, detention basins, treatment basins and sewer separations. A set of rating criteria was used to compare various alternatives. The criteria included storm water impacts, water quality improvements, operation and maintenance costs, public acceptance, community improvements and construction issues. The approach taken with the Long Term Control Plan (LTCP) was the “presumptive” approach. The annual percent capture after the LTCP is 94%.
In addition to the funding, the issues of wet weather standards, use designation and urban stream habitat need to be addressed.
The City of Akron Public Utility is also faced with rapidly rising costs associated with storm water, total maximum daily loads (TMDL), and drinking water regulation.
Akron continues to develop access to the receiving stream with bike paths, downtown development, Mustill Store restoration and Cascade Lock Park. Also, the National Heritage River designation and National Park will continue to attract people to the Cuyahoga River. We look forward to a solution that will cost-effectively address CSO issues while producing benefits to the Akron rate payers, enhance the parks and trails, show improvements in water quality and further the goals of the Clean Water Act.
The significance of the Cuyahoga Valley National Park, National Heritage River status, State Resource waters, Metropolitan Parks, and the Ohio & Erie Canal National Heritage Corridor should all be factors in the allocation of grant funding.
Proposals similar to the Water Infrastructure Network (WIN) are needed to provide for adequate funding now and in the future. Through water and sewer bills, local rate payers already pay about 90% of the total cost to build operate and maintain their water and wastewater systems. We need a long-term, sustainable, and reliable source of federal funding for clean water.
The advent of the CSO program and other wet weather control regulations has focused recent attention on the need for wet weather water quality standards. The focus of wet weather standards has been on attainment of the criteria for waterborne bacteria, generally measured as either fecal coliform bacteria or more recently as E. coli. Typically many urban and suburban streams do not meet the recreational use criteria for bacteria during wet weather. The bacteria counts in streams rise during storms due to bacteria from a variety of non-point and point sources.
Studies in any major population center have consistently shown non-attainment of the existing “dry weather” criteria during and following even moderate wet weather events. Bacteria enter the streams from surface runoff, from septic system leach fields, and from both separate and combined sewer systems. Even areas with no sewer overflow often have bacteria concentrations that exceed the existing standards. Non-point sources of bacteria include pet wastes and wildlife (particularly geese) wastes.
The issue of wet weather standards has been raised at the national level by the Water Environment Federation (WEF), AMSA and other organizations representing municipal sewer authorities.. The USEPA has thus far, been unwilling to derive a tiered water quality standard for wet weather recreational use. Fortunately the USEPA has typically not pursued enforcement cases where recreational use attainment is the primary.
There is no argument about the current standard being applicable and protective of human health during dry weather. The shift to the E. coli measure is also generally supported as being more representative of organisms that pose a risk to public health. The argument for a wet weather standard or variance has been put forward to provide a mechanism for avoiding consistent non-attainment where the source of that non-attainment is beyond the control of the municipal sewer authority. Also there is some question about the need for protection of contact recreational uses in urban areas where such contact does not typically occur during wet weather.
Also a wet weather standard provides alternatives for control of CSO that will reduce costs and remain protective of water quality. Many remedies selected for control of CSO include chlorination in an attempt to meet recreational use standards for bacteria. The addition of chlorine has been shown to have detrimental effects on aquatic life use so dechlorination of CSO is also considered. If a wet weather standard were established it could effectively reduce the amount of chlorine used and reduce those risks and the cost of the chlor-dechlor process.
The proposed standards that have been discussed with (but not accepted by) the USEPA include provisions for an increase in the allowable concentration during wet weather and mechanisms for determining what is a qualifying wet weather condition.
ATTACHMENT for
Testimony provide for the City of Akron by:
Patrick D.
Gsellman, PE, Manager, Environmental Division
Akron
Engineering Bureau, City of Akron, Ohio
166 South High
Street, Akron, Ohio 44308
330-375-2357
During the early years of implementation of the Clean Water Act, States were tasked to develop use designations for all streams. The initial designations were often made without any detailed information about the existing use attained or attainable in a particular stream. Many streams were designated to meet a standard higher than what was “existing” at the time of the designation. These “default” designations have resulted in conditions where streams are prevented from meeting a designated use by conditions that cannot be controlled by pollution control technologies alone. Habitat alteration, flow modification, and dams are some examples of conditions that occur commonly in streams where those factors alone might prevent attainment of an aquatic life use designation even absent and significant point or non-point sources of pollution.
Subsequent re-designation has been difficult for State agencies because of the anti-backsliding provisions of the Clean Water Act. Citizens Groups often view a re-designation as a “degradation” of water quality, even if the existing water quality does not meet the existing designation.
The implementation of TMDLs and the ongoing implementation of CSO controls, highlights the difficulties with current designations. The difference between use attainment, in different states, depends more on the process used for designation than it does on causes and sources of non-attainment. Many streams change from non-attainment to attainment as they cross state boundaries because of the variation in use designation. Since TMDLs are now required in many States for all waters that are in non-attainment as a result of point source pollution, many States have additional incentive to review the designation process. These incentives do not remove the difficulties involved with a perceived “lowering” of a designated use.
Even within States the use designation process is often administered differently in different jurisdictions. On the Scioto River an impounded areas less than a mile long was re-designated as “modified warmwater habitat”; in the Cuyahoga River the sewer authority was told that a two mile long impounded area was “too short” and would unnecessarily “segment” the stream. In the Hocking River more than 3 miles of urban stream was re-designated as modified warmwater habitat “channelized” where the stream was straightened and had earthen banks of trapezoidal shape for a few stretches of about a mile with intervening stretches of natural stream banks and meandering channel shape. In the Little Cuyahoga River a variance (not a re-designation) was requested for a stream where a stretch of over 3 miles is straightened, predominantly in a rectangular concrete channel and contains no significant stretches of natural channel. That variance was refused by Ohio EPA on the grounds again that this would segment the stream and discourage the municipality from attempting to improve the existing use which had never met the existing designated use since many years prior to the inception of the Clean Water Act.
The cost of comprehensive use designation for streams is in the tens to hundreds of thousands of dollars depending on the size of the project. Clearly this expenditure can help to prioritize expenditure of further pollution controls to streams where use is appropriately designated and attainable.
ATTACHMENT for
Testimony provide for the City of Akron by:
Akron
Engineering Bureau, City of Akron, Ohio
166 South High
Street, Akron, Ohio 44308
330-375-2357
Urban settings provide unique conditions for stream habitat. Streams in urban areas have typically been extensively modified. The goal of storm water management in urban areas has always been to provide drainage and avoid any surface retention of water in cities. That goal creates habitat conditions dominated by runoff hydraulics. In wet weather these streams have high peak flows and velocities that create scour and destabilize existing conditions. In dry weather these streams may have flows lower than would be expected in a stream not dominated by a storm drainage system. These two stage systems (low base flow, high peak flow) are not well suited for maintaining aquatic life.
Typically the property owners, the USACOE and City authorities have devoted a significant amount of engineering resources to stabilize these streams and prevent flooding during peak events. Most aquatic life use designations are developed based on habitat standards determined by “natural” streams with moderate change from pre-Columbian drainage and land use. Urban streams represent an extreme condition where most first order (the smallest) many second order and some third order streams have been replaced by pipes. In areas where these streams have not been entirely culverted they are often straightened and regularly dredged to promote drainage and prevent flooding. The remaining streams of fourth order and higher are often disconnected from areas where populations of fish and macroinvertebrates can find conditions suitable for propagation or other functions essential to supporting the broad range of species that would be supported in a more diverse ecosystem. Often the larger streams are also extensively modified to provide other functions such as riverfront recreation or commercial navigation. In New York City as the most extreme example the “streams” in Central Park are entirely artificial and are fed primarily by tap water and drain into the combined sewer system.
While Ohio has much less extreme modification to the natural environment than New York City, the condition of the streams in urbanized and even in many suburban areas is highly modified. Those modifications prevent adequate colonization of fish species that would be necessary to support a warmwater habitat aquatic life use. Given the importance of the aquatic life use as an indicator of good water quality, as developed in Ohio Water Quality standards, it is important that the standards recognize habitat conditions that would prevent attainment even if all urban pollution sources were completely controlled.
Discussions have been initiated by several entities to develop an appropriate “urban” stream designation to address these conditions that prevent attainment of aquatic life uses. To date, the Ohio EPA has not been particularly open to developing an alternative to the existing designation system.