The attached letter and addendum was sent to the city and county and MSD (sewer district) on July 11, 2019. USEPA is requiring the city, county, and MSD (Defendants) to implement the plan. The Defendents did not submit a joint plan that they both agreed, including any changes they wanted in the original list of next projects. Here is the letter Hamilton Cty Cincinnati ltr 7-11-19 and the plan Regulators’ Phase 2A Schedule of Work enclosed with 7-11 letter
The following quote is from the USEPA letter.
“Based on Defendants’ own estimates, the measures set forth in the Regulators’ Phase 2A Schedule are estimated to cost a total of approximately $938 million in 2006 dollars. (To maintain consistency with the consent decrees and the WWIP, except where noted otherwise, all dollar figures in this letter are 2006 dollars.) If, as Defendants have assumed in their RI calculations included as part of their different proposed Phase 2A schedules, the RI analysis assumes that Defendants also spend $50 million per year (in 2006 dollars) on asset management, the RI associated with the Regulators’ Phase 2A Schedule for the service area is 1.45% of MHI. The FCI score for the service area is 2.5 (placing Defendants’ service area FCI score on the border between Mid-Range and Strong). Consequently, the cost associated with the measures set forth in the Regulators’ Phase 2A Schedule places Defendants squarely in the “Medium Burden” category, which means that, under the Financial Capability Guidance, the Regulators’ Phase 2A Schedule length of 10 years is appropriate and financially practicable.
The Regulators recognize that Defendants will still be required to implement approximately $700 million (in 2006 dollars) worth of remaining WWIP measures after the Regulators’ Phase 2A Schedule has been implemented. However, it is appropriate to focus on Defendants’ financial capability to implement as much as Defendants can implement during the next phase of work, and to evaluate Defendants’ financial capability anew when developing a schedule in the future for constructing the remaining WWIP measures.”
The city and county can still modified the plan and jointly submit it to the USEPA. The city and county can do more to address sewage backups into basements, their lack of capacity to handle sewage at the plant and in the pipes, implement green infrastructure to keep stormwater out of the sewer pipes. The city and county can implement a rate structure that allows low income residents to pay what they can afford, lower the minimum charge on properties with small meter sizes (single family homes and small apartment units and businesses), eliminate discounts for large volume water users like multinational corporations, implement pervious surface fees, especially on those who have paid nothing for the treatment of stormwater for decades (which shifted the burden to single family homes and small apartments).
The years of delay harm our communities with the backups of sewage and sewer overflows. The fight between the city and county harms the MSD rate payers.