Balancing CSO affordability while maintaining existing water and sewer infrastructure

Joseph Superneau, P.E., Executive Director, Springfield, MA Water and Sewer Commission, and Chair, APWA Water Resources Management Committee; Robert Stoops, P.E., Chief Engineer, and Joshua Schimmel, Project Engineer, Springfield, MA Water and Sewer Commission

Introduction
The Springfield Water and Sewer Commission (Commission) is committed to improving the quality of life throughout the Pioneer Valley by providing critical water and wastewater services in support of public health protection, environmental stewardship and sustainable economic development. Currently, about one-third of the sewer system in the City of Springfield flows to a Combined Sewer Overflow (CSO) system. The Commission is under its third Administrative Consent Order (ACO) from the U.S. Environmental Protection Agency (EPA) to abate wet weather discharges from the CSOs. This article summarizes the Commission's significant efforts to meet ACO requirements while maintaining services, addressing the rate burdens of unfunded federal and state regulatory initiatives, and the resulting economic impacts to a struggling community in western Massachusetts. More importantly, it supports the necessity of achieving a balance between regulatory compliance, CSO affordability and sustainable infrastructure improvements for both water and wastewater systems. This balance can and must be attained through a partnership approach between regulatory agencies and local water and wastewater utilities.

Background
The Commission owns and maintains watershed land, dams, reservoirs, transmission mains, storage tanks, water and wastewater treatment plants, pumping stations, and more than 1,200 miles of water and sewer mains. The Commission recently completed a five-year $70 million capital improvement program that focused on redundancy and reliability through the replacement and repair of its aging infrastructure while concurrently meeting the ACOs. What lies ahead is hundreds of millions of dollars in capital improvements to repair and maintain acceptable water and wastewater service as well as meet CSO regulations.

Drinking Water
In Massachusetts, the Commission supplies drinking water to a population of approximately 250,000 in the communities of Springfield, Ludlow, Agawam, East Longmeadow, Longmeadow, Southwick and Westfield. The annual average water use is about 36 million gallons per day (MGD). The primary water sources are the Borden Brook and Cobble Mountain Reservoirs. The Borden Brook Reservoir, portions of the West Parish Filters Treatment Plant and many miles of large transmission main were constructed in 1908. The Cobble Mountain Dam and Reservoir were completed circa 1930.

Water flows from the treatment plant to the Provin Mountain storage facility where there are four 15-million-gallon concrete underground storage reservoirs. Tanks were constructed in 1909 and 1930, and two in the 1960s. Thirty-six miles of large transmission main carry water to the City of Springfield. These transmission mains vary in age from 60 years to 100 years old. The distribution system consists of 580 miles of piping dating back to the 1880s, with the majority of the pipe installed from the 1930s to the 1960s. In this system, there are hundreds of miles of unlined cast iron water pipe, which needs to be cleaned and lined or replaced.

Wastewater
The wastewater collection system in Springfield serves a population of about 260,000 and consists of approximately 600 miles of sanitary, combined and interceptor sewers; 12,000 manholes; and 30 sewage pumping stations (including seven flood control stations). Wastewater is conveyed to the Springfield Regional Wastewater Treatment Facility (SRWTF). The SRWTF treats wastewater from the households, businesses, and industries within Springfield and surrounding six member communities, including Agawam, East Longmeadow, Longmeadow, Ludlow, Wilbraham, and West Springfield. The SRWTF is one of the largest facilities in New England and provides treatment at an annual average of 40 MGD.

The Commission owns and is responsible for the 70-year-old flood control infrastructure that is directly connected to the combined wastewater collection system along the Connecticut River. The flood control system includes seven large flood control pumping stations, associated piping, valves, gates and appurtenances.

The Long Term Control Plan (LTCP)
In March 2000 the Commission completed a draft CSO Long Term Control Plan and Environmental Impact Report (LTCP). Projects delineated in the LTCP were evaluated based on effectiveness of CSO reduction vs. cost. The goal was to identify projects that were at the "knee of the CSO reduction vs. cost curve." At the conceptual level of planning, these projects would provide the Commission with the most cost-effective CSO control.

CSO control technologies were evaluated for each of three rivers that receive CSO discharge—the Mill River, the Chicopee River, and the Connecticut River. This effort resulted in a massing of CSO-related information under one umbrella. Each of the CSOs could now be assessed in terms of how they functioned as a system vs. individually. Based on the existing sewer system information and the skeletal flow metering data gathered, a simple hydraulic model was developed to aid in analyzing the effectiveness of the various CSO abatement strategies. The end result was an overall recommended plan for CSO abatement that resided at the "knee of the curve," with an estimated total cost of $140 million. In accordance with EPA requirements, the LTCP also included a chapter on affordability. The affordability analysis results showed that Springfield ratepayers could only afford approximately 1/10 of the proposed CSO program cost.

CSO Abatement
In November 2000, the Commission entered into negotiations with EPA and the Massachusetts Department of Environmental Protection (DEP) to develop an affordable phased CSO program. An ACO would define the initial phase of work. The information provided in the LTCP was used as the basis for the specific projects associated with the ACO. The initial ACO identified Interceptor Relief and Storage for the abatement of the Mill River CSOs. The Commission proceeded to comply with the ACO schedule by rapidly moving through the project design and bidding process. From the perspective of the regulators, the pace of the response to the ACO was good. Projects designed to abate CSOs were progressing. The Commission was content because the ACO included a specific project that was affordable (at $5.2 million) and capable of being implemented.

Aggressive deadlines specified in the ACO required a compressed design schedule. Additional information was gathered through the design phase; however, because of the short schedule, the recommendations from the LTCP were the guiding principles for design and construction. As the project moved through construction the Commission realized that although compliance with the ACO was maintained, there were some fundamental flaws with the approach. Evidence indicated that the LTCP was more of a planning tool than a guide for final design. Lack of time to thoroughly investigate existing infrastructure resulted in a litany of changed conditions and utility conflicts in the field.

Lessons Learned
Given the condensed project schedule, Commission staff and the consulting engineers worked together throughout construction to produce a functional CSO project. Schedule drove the Mill River Project to the detriment of proper planning and design. Field changes during construction were the norm and not the exception. Upon completion, the project was considered a success by the regulators and the Commission because deadlines were met, the costs contained and the annual CSOs to the Mill River were reduced to meet the regulatory requirements.

The project team performed a post-project review to look at how to reduce change orders and address other contract changes. The outstanding factor was scheduling adequate time for the engineer to completely field verify and evaluate all critical pipe and CSO regulators, and to perform detailed flow monitoring to validate the design criteria. To rush forth to meet an artificial schedule was counterproductive and resulted in multiple change orders.

Moving Forward
The next focus was the Chicopee River CSO project and Commission staff negotiated an ACO with the regulatory agencies. The ACO included specific projects from the LTCP and provided sufficient time for adequate field investigation, flow monitoring and design. The final ACO specified the design and construction of a series of three CSO storage tanks or an equivalent project. The storage project was originally selected because the LTCP estimated optimum CSO discharge reduction in relation to the capital cost.

In moving from the conceptual plan of a LTCP to the reality of final design, the engineer needs to provide a more involved study and investigation of existing conditions, in addition to analyses of various control strategies and options, prior to final design. It is a serious mistake for regulators and utilities to apply the conceptual information provided in a LTCP as the basis for a final design without proper field verification. To do so potentially results in spending millions of dollars on a project that may not perform or accomplish what was intended.

The preliminary design for the Chicopee River CSO Project included 21 new flow monitoring locations for this stormwater basin, inspection and measurement of every regulator, and the inspection and assessment of all sewer pipes. Because of this level of effort, it became evident that the flow requirements significantly changed from the minimal flow monitoring performed at the planning stage (13 flow meters citywide) to the new monitoring program.

The new hydraulic model indicated that the predicted storage tanks, based on the preliminary data from the LTCP, were incorrect in number and undersized. Due to the increase in size and number of storage tanks predicted by the updated model, additional knowledge of subsurface conditions, and identification of many utility conflicts, the estimated construction cost jumped from $14 million to almost $50 million. This cost did not include the annual operating and maintenance cost for the storage tanks, which would have been substantial.

Several alternative approaches were quickly identified that served the dual purpose of improvements to the existing infrastructure while controlling CSOs. A hybrid project was developed that included targeted separation, new sanitary sewer, limited storage, and pumping station improvements. The new project also addressed infrastructure upgrades; such as replacement of deteriorated sewer and drain pipes, appurtenances, creating added pipe capacity and pump station improvements that the Commission would have ultimately completed regardless of an ACO.

The alternative approach would clearly provide a tremendous benefit to our ratepayers. The remaining hurdle was to demonstrate to EPA and DEP that this approach achieved the original goals for CSO control set forth in the ACO. The Commission used the design level hydraulic model to demonstrate project equality with respect to the estimated annual CSO overflows. With the model results in hand, demonstrating the proposed change went smoothly because the Commission had continually maintained contact with the local regulatory staff throughout the process.

The goal should be to negotiate an ACO that did not identify specific projects, but rather identified achievable goals for CSO control based on overall system needs. The flexibility to consider cost benefit and affordability should be factored into this process.

EPA Affordability Guidance Definition
EPA has established affordability guidance to assess the economic burden of CSO abatement in terms of annual cost and the long-term impacts upon residents and businesses. EPA acknowledges that the determination of substantial impact on the wider community depends on both the cost of pollution control and the general financial and economic health of the community.

One of the most critical indicators of economic health is measured by the median household income. The median household income for Springfield residents has hovered around $30,000 per year (2005 dollars). This is almost half of the state median of $57,000 (2005 dollars). The EPA substantial impact preliminary screener looks at the project cost to achieve policy compliance as a percent of median household income. For the City of Springfield, this value has been estimated to be approximately 1.5% through the updated Preliminary CSO Controls. This value indicates that the economic burden for Springfield is already excessive. And, the Commission's water and wastewater systems still require hundreds of millions of dollars for capital improvements over the next twenty years.

During the preparation of the LTCP, costs for the Mill River, Chicopee River and Connecticut River CSO abatement programs were estimated at $6.1 million, $15.9 million and $117.6 million, respectively. At that time, the LTCP affordability analysis prepared by Metcalf & Eddy, Inc. concluded that, "Springfield will incur widespread social and economic impact as the result of implementing preliminary CSO controls." The preliminary CSO costs for the Mill River, Chicopee River and the Phase I Connecticut River Projects were estimated at $35 million through the year 2011.

Since that estimate was prepared, the Mill River Project has been completed within budget. The Chicopee River Project is under construction with an estimated project cost of $30 million. The Washburn Street CSO Project, which resulted from structural failure of a CSO regulator, was completed for approximately $8 million and the Clinton Street Project was replaced with a sewer separation project due to escalating costs. The Connecticut River Phase I Project cost is now estimated at $15 million.

What was estimated to cost $35 million in year 2000 and was determined to exceed the affordability thresholds and cause widespread social and economic impact, will actually cost approximately $60 million. And it does not end there. The balance of the proposed CSO work is now estimated at more than $180 million. Since 2000, Springfield's actual median household income has decreased to less than $30,000 per year. Given the tenuous economic plight of Springfield residents and businesses, the increased burden of the Updated Preliminary CSO Control projects alone presents an unreasonable impact to the community.

What does affordability really mean to our customers?
In 2005 Springfield's median household annual income was $29,922, down 1.6% from 2000. A household with a gross income of $30,000, after payroll deductions of federal and state taxes, health insurance, retirement and other mandatory deductions, brings home a net income of about $20,000. To the median-income family, this means budgeting about $10,000 for mortgage or rent payments; $5,000 must be budgeted for heat, electricity and telephone payments, and the remaining $5,000 for food. There is no money for other expenses such as clothing, transportation, cable television, pets, entertainment, medical care co-payments, or water and sewer bills.

How do we justify asking people to make real-life choices between heat, food, medicine, and reducing CSOs to a river they cannot swim in? Springfield is a poor city where the crime rate has escalated, public education needs have increased, and medical issues have worsened. Springfield ranked sixth worst in the nation for the percentage of its children living in poverty in 2006, according to the U.S. Census Bureau's American Community Survey. This climate further hinders support for rate increases and funding of CSO projects with little or no benefit to the community.

Cost/Benefit
Money is a critical factor when developing and implementing any environmental project and lines must be drawn somewhere. If a project costs $10 million to reach a 95% solution and $20 million to reach a 99% solution, with minimum environmental benefit gained, is this sound public investment? It should be the obligation of both the environmental regulator and the public works official to work together and find this line. For every dollar spent on limited environmental gain there is one less dollar to invest in other projects that provide greater environmental benefits.

What does affordability mean for the Commission?
The Commission is required to meet various laws and regulations promulgated by the state and federal governments. All of these laws and regulations have costs associated with compliance. Realistically looking at fiscal projections, there are many factors to consider when prioritizing the financial needs of an organization, including:

  • The costs of essential services and functions within the organization and the inflation related to those costs.
  • The capital replacement/improvement costs needed to provide sustainable infrastructure into the future.
  • The added costs of regulatory compliance.
  • The future needs to meet population changes or changes in demand.
  • The ability and willingness of the users to pay for the services.

Financial Reality for a Water and Sewer System
By 2010 the Commission will have borrowed $150 million in the previous decade: $70 million for much-needed water and sewer infrastructure repairs and $80 million for CSO work. There remains a looming amount of $180 million needed to complete the identified CSO projects in the Draft LTCP. Also on the radar screen is another $100 million for sewer repairs, based on a detailed assessment of the sewers in one section of the city. The 70-year-old flood control pumping stations require upgrades to the tune of an estimated $10-15 million.

On the drinking water side, major replacement of a 100-year-old water storage tank and repairs and replacement of miles of large transmission pipe are being evaluated. These water projects could easily reach $50 million over the next 10 years. And, the Commission is considering a new water treatment plant at Ludlow Reservoir to meet future water demands at a cost of $25 million.

The Commission's FY 2008 annual operating budget is approximately $50 million, of which about 9% is for debt service. In 2010 the annual budget is expected to increase to $57 million, with an estimated debt service rate equaling about 16% of the total. If the Commission proceeds down the road to borrow another $400 million over the next 10 years, the annual debt service would increase about $32 million with an additional debt service reserve of $72 million required to satisfy bond covenants. The debt service would account for approximately 50% of the operating budget. Such numbers would be staggering to the City and would cause financial and political chaos resulting in rigor mortis for the Commission.

Collapse of an 8-foot-diameter brick sewer, circa 1880, resulted in the reconstruction of the street, all underground utilities and the CSO regulating chambers at a cost of $8 million.

In the last four years, four unexpected projects have developed which cost over $12 million to repair. The largest project was an 8-foot-diameter brick sewer collapse (circa 1880) which resulted in an $8 million repair. While writing this article, another sinkhole problem developed around a major water transmission main gate chamber and the preliminary estimate is $4 million to repair. This major transmission main may need to be removed from service pending the repair. These types of unexpected emergency repairs will continue to plague the Commission considering the age of the system.

Springfield's case is not unusual. It represents a community that has an aging infrastructure, which has seen continual underinvestment in maintenance and upgrades to the water and sewer systems. The systems now require major capital repairs and improvements. When considering the rate impacts over the next 10 to 20 years, meeting the repair and replacement needs must be a top priority and the Commission must always have sufficient funds to repair the unforeseen.

Environmental Yield
Another significant issue that cannot be overlooked is Environmental Yield. The question that should be asked continuously by both the public works official and environmental regulator is, "If this project is developed and constructed, and the program is implemented, what will be the meaningful benefits to the environment?" If the question cannot be answered with a positive environmental result or the potential benefits are negligible, it is probably not a good investment of public dollars. Too many projects in the past have taken on lives of their own without defining the Environmental Yield.

The Commission recognized the importance and regional nature of Environmental Yield for the Connecticut River. In conjunction with the Cities of Holyoke, Chicopee, and the Pioneer Valley Planning Commission, a study was prepared to develop a regional water quality model of the Connecticut River. The model simulated approximately 50 CSOs, stormwater discharges and upstream river conditions from Holyoke to the Connecticut border. A brief synopsis of model results includes:

  • Fecal loading from the upstream non-point source runoff and stormwater significantly exceed those from CSOs.
  • After Phase I CSO controls are implemented, water quality swimming criteria exceedences during wet weather would reduce only by less than four hours following a three-month storm.
  • Reducing CSO loads would have relatively small effect on overall river quality.
  • If all CSOs were eliminated, water quality goals would not be achieved during the one-year storm event.

If the Commission were to spend $800 million to eliminate all CSOs, the river would still not meet water quality standards because of other point and non-point source contributions and upstream pollutant loadings. Common sense indicates the need to reduce and eventually eliminate sewage from entering the river. However, it is important to balance the level of spending as it relates to the environmental benefit that will be achieved. Projects with little or no Environmental Yield cannot be undertaken at the expense of all other necessary sewer, wastewater and water infrastructure improvements. A community cannot continue to spend money beyond the point of diminishing returns, simply to meet absolute regulatory compliance. There should be a viable, continuous reevaluation of where to best spend the limited resources to realize the best environmental benefit for our citizens. By continuously asking the Environmental Yield question, the prudent investment of public funds and improvements to environmental protection will be optimized and the benefits tremendous.

An example would be whether to invest in the replacement or repair of a critical pump station or force main or to control a CSO. If the pump station or force main failed, raw sewage would flow into the river 24 hours per day for months on end. If the CSO was not controlled, discharges of diluted sewage would come and go in wet weather. It is clear that failure of the critical infrastructure would have greater environmental consequences and a higher Environmental Yield. Environmental regulators must recognize this point as they work to advance CSO controls.

Conclusions
To quote Winston Churchill, "If you have an important point to make, don't try to be subtle or clever. Use a pile driver. Hit the point once. Then come back and hit it again. Then hit it a third time—a tremendous whack." The point to be driven home is simple—utilities cannot possibly comply with all the existing regulations together with those being promulgated and maintain existing water and sewer infrastructure. Some of the rules require substantial sums of money to enact and in the end, provide marginal benefit. In addition, utilities are spending money to comply with rules that are in conflict with other rules. In some cases, one regulator may be applying pressure for compliance, which is in conflict with another regulator's requirements.

The best solutions for local environmental problems are site-specific. Several lessons learned during Springfield's CSO abatement program include:

  • Conceptual information collected as part of the development of a LTCP is limited and cannot be used directly for design and implementation of specific projects.
  • The best solutions to environmental problems require significant research, detailed evaluations, modeling and in-depth investigation prior to implementation.
  • Regulatory compliance and ACOs should allow for flexibility in implementation. After the research, evaluations and modeling are conducted, the engineering solutions inevitably change for the better.
  • The quality of the river will not significantly improve if all CSOs are eliminated. Environmental Yield should be the focus. There is a limited pool of funds available for competing needs and water and wastewater services must be maintained through the regulatory implementation process.
  • Infrastructure repairs and improvements must be implemented regardless of the process of meeting or implementing new regulations.

In the future, to implement the lessons learned, utilities must conduct intelligent, ongoing discussions with regulators to define where limited resources can best be used for the public benefit. Projects and programs should follow a prioritization process that includes a cost/benefit analysis and takes into account the overall needs of the Commission. Public funds must be used for meaningful purposes and have measurable public benefits consistent with the amount of funds expended.

The Commission cannot continue to borrow money for capital projects to meet regulatory requirements and ignore the needed repairs to the infrastructure. That is a formula for system-wide failure and is irresponsible to our ratepayers. Infrastructure system failures result in significant negative impacts to the community and individuals. The existing infrastructure system needs to be maintained in balance with meeting regulations.

Both public works officials and environmental regulators have a tremendous stake in improving the environment and water quality for the next generation. The challenge is to meet these goals because there is competition with other state and national programs for the same dollars. One way to meet the challenge and reach the goal is working together. Just think of a coalition of public works officials and environmental regulators jointly addressing Congress in support of new funding mechanisms and regulations that make sense while protecting the environment. If this sounds far-fetched, think it through. The foundation of the public works profession is to build infrastructure that protects the public and the environment. The foundation of an environmental regulator is to ensure that laws and regulations adopted by elected officials are carried out to protect the environment. There is not a conflict between these two agendas. A new paradigm is required by both parties to realize that working together as a team provides a foundation for water quality improvements across the nation that noticeably progresses in the coming decades.

Joseph Superneau is the Chair of APWA's Water Resources Management Committee; he can be reached at (413) 787-6256 x-152 or joe.superneau@waterandsewer.org; Robert Stoops can be reached at (413) 787-6256 x-188 or bob.stoops@waterandsewer.org; and Joshua Schimmel can be reached at (413) 787-6256 x-139 or josh.schimmel@waterandsewer.org.