OT...MS4s: A Potential Municipal Budgetary Albatross

[toobadface]

For those of you not familiar with the acronym, "MS4" is short for "municipal separate storm sewer system." Approximately 14 years ago, many municipalities within Pennsylvania (based on population densities) were required to obtain Nation Pollutant Elimination Discharge System (NPDES) Permits to formally authorize stormwater discharges from existing and future municipal storm sewer systems. Past and current permit requirements essentially entailed/entail public education/outreach relative to the importance of pollutant free stormwater, mapping of municipal storm sewer systems, monitoring of storm sewer systems & elimination of illicit discharges (e.g. illegal sewer connections), proper management of construction and post-construction stormwater runoff, and employing best management practices in municipal operations to mitigate potential stormwater pollution sources.

For most municipalities, the next permit cycle begins in March 2018 and with it come significant additional requirements in many cases. In addition to continuing efforts to address the requirements described above, under the requirements of the 2018 permit, many municipalities will also need to prepare/execute plans to address pollutant reductions within local streams to eliminate existing impairments caused by pollutants such as sediment, phosphorus and nitrogen. Plans to address the required pollutant reductions will likely propose things such as: construction of new stormwater management facilities, retrofit of existing facilities, stream restoration projects, riparian buffer restoration, etc. In other words, municipalities that are subject to the requirements of MS4 permits are going to have to begin (if they have not already) budgeting significant funds to finance projects similar to those referenced above.

In most cases, applications for the 2018 permit renewal are due to DEP in September of this year. Any municipality subject to the requirements of the pollutant reduction plans described above is required to advertise a draft version of the plan for public review no later than early August of this year. Considering the significant costs associated with the permit requirements, it is very likely that municipalities will need to raise taxes, in one form or another, as financing projects related to stormwater pollutant removal will be rather costly in many cases.

For the record,I'm a professional engineer that is currently handling this permit work for a number of municipalities in southeast PA. While some municipalities have been very proactive about educating their respective communities regarding MS4 requirements and implications (taxes and otherwise), other municipalities are not giving the matter the attention it probably deserves. If the program continues in its current trajectory, within several years many municipalities will be struggling to shoehorn the financial obligations of this program into their already, presumably lean budgets.

Although my company has benefited financially from the MS4 program, I am not fan of it. Since its inception, I cannot name a single thing, in my experience, that has been done as a result of the program to significantly clean up stormwater discharges and ultimately improve stream quality. But I will leave my opinion commentary at that, as this post is not intended to have any political slant. I simply wanted to provide this heads-up to any PA residents that may be interested in a matter that could potentially impact their local taxes at some point in the relatively near future.

Happy Independence Day!

 

[interrobang]

One of the more random OT posts on this board...

 

[Fox Chapel Lion II]

For those of you not familiar with the acronym, "MS4" is short for "municipal separate storm sewer system." Approximately 14 years ago, many municipalities within Pennsylvania (based on population densities) were required to obtain Nation Pollutant Elimination Discharge System (NPDES) Permits to formally authorize stormwater discharges from existing and future municipal storm sewer systems. Past and current permit requirements essentially entailed/entail public education/outreach relative to the importance of pollutant free stormwater, mapping of municipal storm sewer systems, monitoring of storm sewer systems & elimination of illicit discharges (e.g. illegal sewer connections), proper management of construction and post-construction stormwater runoff, and employing best management practices in municipal operations to mitigate potential stormwater pollution sources.

For most municipalities, the next permit cycle begins in March 2018 and with it come significant additional requirements in many cases. In addition to continuing efforts to address the requirements described above, under the requirements of the 2018 permit, many municipalities will also need to prepare/execute plans to address pollutant reductions within local streams to eliminate existing impairments caused by pollutants such as sediment, phosphorus and nitrogen. Plans to address the required pollutant reductions will likely propose things such as: construction of new stormwater management facilities, retrofit of existing facilities, stream restoration projects, riparian buffer restoration, etc. In other words, municipalities that are subject to the requirements of MS4 permits are going to have to begin (if they have not already) budgeting significant funds to finance projects similar to those referenced above.

In most cases, applications for the 2018 permit renewal are due to DEP in September of this year. Any municipality subject to the requirements of the pollutant reduction plans described above is required to advertise a draft version of the plan for public review no later than early August of this year. Considering the significant costs associated with the permit requirements, it is very likely that municipalities will need to raise taxes, in one form or another, as financing projects related to stormwater pollutant removal will be rather costly in many cases.

For the record,I'm a professional engineer that is currently handling this permit work for a number of municipalities in southeast PA. While some municipalities have been very proactive about educating their respective communities regarding MS4 requirements and implications (taxes and otherwise), other municipalities are not giving the matter the attention it probably deserves. If the program continues in its current trajectory, within several years many municipalities will be struggling to shoehorn the financial obligations of this program into their already, presumably lean budgets.

Although my company has benefited financially from the MS4 program, I am not fan of it. Since its inception, I cannot name a single thing, in my experience, that has been done as a result of the program to significantly clean up stormwater discharges and ultimately improve stream quality. But I will leave my opinion commentary at that, as this post is not intended to have any political slant. I simply wanted to provide this heads-up to any PA residents that may be interested in a matter that could potentially impact their local taxes at some point in the relatively near future.

Happy Independence Day!

Hi TBF. We have similar issues in Allegheny County. The Allegheny County Sanitary Authority (ALCOSAN) is going to have to spend a fortune separating storm water and sanitary water. They are talking 3 billion - personally I believe it will be more like 10 bill before all is said and done.

However it probably needs to happen. Right now we have combined storm and sanitary mains headed to the ALCOSAN plant on the north side. Get some water moving (which happens all the time with the hills out here) and the overflow goes straight to the rivers with no treatment. There are all kinds of advisories when the overflow is going - this is pretty primitive and obviously it needs to stop.

Paying for it is another story. I get a combined water and sewer bill once a quarter. Our water is manufactured and purchased from the City of Pittsburgh but is delivered by the Fox Chapel Authority - FCA owns and operates all the water mains. The water source is the Allegheny River; IMO our tap water is excellent, I know it has won awards. Our annual test report came in a few weeks ago, it's great, as usual. The sewer is on the same bill, the money goes to ALCOSAN. I live by myself so I consider the bill to be dirt cheap, others may differ.

They have been telling us that our bills are going to jump to pay for the storm water improvements, but I use so little water that I haven't noticed. But if I had a houseful of kids, washer and dishwasher going all the time, 10 showers a day, might be singing a different tune.

All of this goes back to the infrastructure issue. We built all this great stuff in the 50's and 60's. Time flies. Now it's at it's design life and needs beefed up/rebuilt/renewed. People have no appreciation for how expensive things are and what construction labor costs. Answer = plenty. PLENTY.

Now a question for you since you're a water/ww kind of guy. What makes a sewerage treatment plant malodorous? I don't mean a whiff - I mean enough to knock you over, and it goes on for weeks. Are the bacteria not doing well, aeration not working, too much input, or what? The plants were obviously NOT designed to be like that, so something is out of whack. If our plant stenched out the neighborhood like that, the Plant Manager and Environmental Manager would be sharing a cell.

 

[toobadface]

FCL, unfortunately, my areas of expertise are primarily stormwater and land development; however, I am very familiar with the obvious problems associated with combined sewer systems. It is my understanding that municipalities or authorities that continue to operate combined systems have a different set of rules relative to MS4 compliance. While I am skeptical of the effectiveness of the MS4 program, I am entirely in favor phasing out antiquated combined sewer systems. Most plants receiving flows from combined systems were drastically ill-equipped to process the volumes generated from even moderate storm events (i.e. 1-2+" rainfalls). So, in other words, when it isn't raining, the plants may be adequate, but any time a decent amount of rainfall occurs, the systems overflow, untreated into surface waters, which is everyone probably agrees is nasty.

I apologize because I do not have a good answer to your question as I am not an expert in municipal sewage treatment. Other than covering certain components of the treatment process, I am not certain what options exist to mitigate odor. Additionally, I am not sure exactly why plants stink worse at certain times but not as much at others. Intuitively, I could come up with some possibilities, but I would be speculating. I am sure that there are folks on this board better suited to answer your question.

Good luck though with your situation in Allegheny County. As you note, separating an existing system is not cheap. My company was involved in a relatively small separation project several years ago for a relatively small authority plant (served approx. 10,000 people) that cost about $30 million. Retrofit projects are always a bastard especially on the scale of the project that you reference.

 

[ram511]

As the administrator of a local township in NE PA I know exactly what the surrounding municipalities are going through and the money they're spending to comply with these mandates. And the penalties/fines are incredible such that even they could cause serious financial difficulties for those running afoul of the law ...even record keeping is being scrutinized....the EPA is taking no prisoners. Fortunately for me, we are 100 percent on lot disposal, have no storm water facilities and are exempt from these draconian measures. I still have started to maintain level 1 and 2 documentation for impervious surfaces on any new construction.

 

[toobadface]

RAM, your Township is fortunate, and I agree with your tone. The requirements are ridiculous. I'm all for clean streams, but the thinking behind the guts of the MS4 program is pie in the sky horseshit. The fact of the matter is, if all municipal storm sewer systems were eliminated tomorrow, 10 years from now nearly all of the streams that are currently impaired would still be impaired in the absence of other remediation measures. This "wolf" has been cried in the past, and it made some noise but it was premature, so the collective concern has somewhat lessened. Unfortunately, this next permit cycle is the real deal and many PA municipalities are going to be shelling out tons of money to fund MS4 related projects within the next five or six years. I do not think that many of the residents in the municipalities that are going to be affected realize the implications of this yet. Currently, there are a number of storm sewer authorities that exist in the state, but I think that you are going to see this number skyrocket within the next 10 years provided the MS4 program continues in its current form.

 

[SmithtonLion]

What happens to our streams when deer crap and urinate in them?

What happens when deer die next to streams? Bear? Groundhogs?

How is that pollutant kept from our rivers and streams?

 

[Fox Chapel Lion II]

What happens to our streams when deer crap and urinate in them?

What happens when deer die next to streams? Bear? Groundhogs?

How is that pollutant kept from our rivers and streams?

SL you heard the old rule of thumb, right? The solution to pollution is dilution. The waterway can handle bear urine and groundhog carcass. Millions of gallons of untreated into the Allegheny is a horse of a different story.

 

[Achowalogan]

“Agriculture hugely undermines the success of the Clean Water Act,” said environmental law professor Oliver Houck of Tulane University. “The Clean Water Act was spectacularly successful –- but like all great successes, there’s a huge flaw, and the flaw is agriculture.”

Agriculture is the single largest source of nutrient and sediment pollution entering the Chesapeake Bay. According to 2015 estimates from the Bay Program, agriculture contributes 42 percent of the nitrogen, 55 percent of the phosphorous and 60 percent of the sediment entering the Bay.

Agriculture is the nation's leading cause of impaired water quality, according to the U.S. Environmental Protection Agency.

 

[cment]

“Agriculture hugely undermines the success of the Clean Water Act,” said environmental law professor Oliver Houck of Tulane University. “The Clean Water Act was spectacularly successful –- but like all great successes, there’s a huge flaw, and the flaw is agriculture.”

Agriculture is the single largest source of nutrient and sediment pollution entering the Chesapeake Bay. According to 2015 estimates from the Bay Program, agriculture contributes 42 percent of the nitrogen, 55 percent of the phosphorous and 60 percent of the sediment entering the Bay.

Agriculture is the nation's leading cause of impaired water quality, according to the U.S. Environmental Protection Agency.

I will not disagree that ag is a contributor to sediment run off. I will add the sediment capacity of the Conowingo pool (the lake behing the Conowingo Dam in MD) is near 100% and is no longer trapping sediment as it was designed to. It would cost billions to dredge it. Conowingo is owned by Excelon and has "hinted" that they would consider shuttering the dam, before they would pay to dredge it.

 

[tboyer]

A lot of these are communities with very little or tenuous tax base. And they're already underwater in most cases on their employee pension programs. So yeah, adding multi-billion-dollar requirements to build secondary/tertiary water treatment plus separate storm sewer networks -- it's just not going to happen. You could take every last penny from every taxpayer in some of these communities and there still wouldn't be enough.

On this subject, Philadelphia is doing something interesting (and probably other cities too). Building an entire separate sewer system to handle stormwater is ridiculously expensive and doesn't provide any other benefits.

So the city is using money raised for storm water to do surface level improvements that also help improve the city. Every time you can replace asphalt with a permeable surface, you can claim substantial reduction in storm runoff. So eliminate a parking lot with a building that has a roof garden. Or eliminate a concrete median with a permeable grassy median. In one case the city's planning to widen a median, plant it and run a bike lane through the greenery (Spring Garden Street). So you get to beautify a corridor with money that otherwise would gone into additional underground pipes.

 

[Obliviax]

locally, the community ignored this issue. They have combined storm and regular sewer issues for decades. They recently put in a grandfathered system so that if you applied for any kind of sewer permit, you had to separate storm (which runs into the lake) and sewer. It was hastened, two years ago, when a big storm flooded several basements and a class action lawsuit was filed against the city.

 

[kgilbert78]

In my old neighborhood (built in the 1920s), they ran together--which created a real mess when ever there was an extremely heavy rain and the sewer backed up into the basement. But I got around that by adding a 4ft high standpipe in my basement (along with upgrading the sump pump I already had). That meant it had to be at least 4 ft high in everyone else's basement before it affected mine.

 

[Fox Chapel Lion II]

A lot of these are communities with very little or tenuous tax base. And they're already underwater in most cases on their employee pension programs. So yeah, adding multi-billion-dollar requirements to build secondary/tertiary water treatment plus separate storm sewer networks -- it's just not going to happen. You could take every last penny from every taxpayer in some of these communities and there still wouldn't be enough.

On this subject, Philadelphia is doing something interesting (and probably other cities too). Building an entire separate sewer system to handle stormwater is ridiculously expensive and doesn't provide any other benefits.

So the city is using money raised for storm water to do surface level improvements that also help improve the city. Every time you can replace asphalt with a permeable surface, you can claim substantial reduction in storm runoff. So eliminate a parking lot with a building that has a roof garden. Or eliminate a concrete median with a permeable grassy median. In one case the city's planning to widen a median, plant it and run a bike lane through the greenery (Spring Garden Street). So you get to beautify a corridor with money that otherwise would gone into additional underground pipes.

See, this is the kind of environmental improvements that everybody can get behind. You can do permeable parking lots too which is a tremendous idea. Imagine the parking lots at Citizens Bank Park, say 200 acres. You get one inch of rain. With permeable parking it percolates into the ground, impervious - five million gallons that the storm sewer has to handle. And that is for just one rinky-dink rain event. It adds up quick.