The Metropolitan Sewer District (MSD) and Hamilton County are proposing a risky venture instead of a sound Phase 2B plan to comply with the sewer Consent Decree.
Rather than utilizing proven, cost-effective methods to stop sewer overflows, address climate change storms, make rates and costs fair and affordable, and make our waterways safe, MSD and Hamilton County propose spending $1.8 billion to reduce a mere 1.456 billion gallons of sewage overflows. This is a sharp contrast to Phase 1 which cost $1.62 billion and reduced overflows by 7.8 billion gallons. In other words, Phase 1 cost an average of 23 cents per gallon, and the proposed Phase 2B costs five times more per gallon!
Phase 2B is a 10-year plan (like Phase 1) and includes a $418 million project (expanding components of the Mill Creek Treatment Plant) that does not accomplish any overflow reduction because it will require another expensive project (construction of a High Rate Treatment Facility at the Mill Creek Treatment Plant) before it delivers any benefit. It also includes a project that costs more than $100 million that MSD has claimed the Ohio Department of Transportation will pay for as part of the Brent Spence Bridge project, But there is, in fact, has no agreement with ODOT and the whole cost will be placed on rate payers.
MSD includes work which is primarily asset management (basic maintenance and replacement projects) that does nothing to reduce overflows – the whole point of the Consent Decree. MSD’s proposal is to build expensive High Rate Treatment (HRT) plants and hopes that the sewer system will, at some future time, be able to convey more sewage to those plants. That aspect of the plan is undefined, won’t happen for at least 10 years, and doesn’t differentiate the fact that stormwater has different treatment requirements than sewage.
Phase 2B ignores the things that have worked best for MSD in Phase 1. It includes minimal green infrastructure, few if any stormwater separation projects, and no expansions to their best-in-the-nation smart sewer control program.
Sierra Club urges US EPA and the Court to reject this Phase 2B plan and require MSD to implement a fair and affordable rate structure and proven, cost-effective projects to reduce overflows and basement backups. Green infrastructure, smart sewer improvements, infiltration wells, sewer separation and incentives for property owners to keep their stormwater on-site will provide lasting reductions in stormwater entering the sewer system and lessen the impacts of increases in stormwater that are resulting from climate change.
Since 1972, sanitary sewer overflows have been illegal. By 1985, rivers were supposed to be fishable and swimmable. Plans for reducing combined sewer overflows were required in 1994. The City and County are far behind in reaching compliance and, in fact, still do not have a complete plan for how they will achieve compliance.
The Phase 2 Consent Decree work was supposed to begin in 2018, and after six years of delay and negotiations, this Phase 2b plan puts off meaningful improvements for at least 10 years. To make it worse, MSD is proposing “openers” in Phase 2B to allow them to delay beyond the ten years and proposes more Phases to follow Phase 2B. The lack of hard deadlines and performance standards is allowing a never-ending boondoggle.
CSOs are combined sewer overflows, NEOs are new unnumbered overflows, PSOs are Pump Station Overflows and SSO are sanitary sewer overflows. The size of the circles indicates the volumes of the overflows from 1/1/2024 to 9/3/2024. More information on MSD’s overflows can be found at https://msdgc.org/programs/wet-weather-program-consent-decree/progress/. Scroll down the page to find the dashboards.
