Indiana Sewer Construction Permits:

Since 1993, the Indiana Department of Environmental Management (IDEM) has issued more than 11,000 construction permits for wastewater treatment facilities in Indiana.  These facilities primarily consist of sewer lines that connect to existing treatment plants.  

Improving Kids' Environment and the Indiana Clean Water Coalition obtained a copy of IDEM's facility construction database in July 2002.  To evaluate the database, IKE had to make changes to the database.  These changes include:

• Modifying city, county and wastewater treatment plant names so they are in a consistent format.  For example, should it be Fort Wayne or Ft. Wayne. Without this consistency, IKE could not develop totals or facilitate searches.  One remnant of this effort is in capitalization.  IDEM used a mixture of styles.  
• Modifying names of engineering firms for its totals but not in the searchable database.  A single engineering firm could appear under 20 slightly different names depending on punctuation and abbreviation.  While IKE did not change the database, it did modify the names when it ran the tally for the Top Engineering firms.  Therefore, search on just the core name of the firm you are interested in.
• Corrected obvious errors.  For instance, some facilities were entered on the wrong county - a county more than 30 miles away.  
• Changed the sewer flows from text to number format so totals could be developed.

Please note that the sewer flow is the design average daily flow that is reported on the permit application.  It is the expected flow not the worst case or maximum flow.  Also note that some permits appear to be duplicated.  IKE did not delete the duplication because it was unsure which was the correct permit.   

Be careful when totaling the flow for a county, a facility or a municipality.  Some of the permits are never implemented or never reach their design flow.  Some of the flows are not new flows because the existing sewer is being reconstructed.  Also, IDEM does not track sewer disconnects or efforts to stop water infiltration or inflow.  In other words, it is only a part - but a critical part - of the picture.  

IKE is still able to draw two conclusions from its analysis.  

A.    IKE's evaluation makes it clear that IDEM does not track the overall impacts of their approval of sewer connections permits on the municipal wastewater treatment plant. The database was formatted in a manner that made it difficult to look at total approved flows to any treatment plant.  Spelling errors and inconsistent formatting made it impossible to analyze the database without significant modifications.  Therefore, IKE believes that IDEM does not evaluate the cumulative impact of the permits it issues.    

Instead of using its permitting database, IDEM appears to rely on its sewer connection ban and early warning notice system supplemented with periodic inspections to identify capacity problems. 

This system could be sufficient except that:

1. IKE demonstrated in its July 2002 reports that there does not appear to be any consistent reasoning behind IDEM's decision-making process in its sewer connection ban and early warning notice system.  Since November 1999, IKE has repeatedly called upon the agency to issue a non-rule policy document explaining its process.  Commissioner Kaplan promised that this document would be available in June 2000 but the agency delayed because it was too busy on other tasks.  All to no avail.

2. For some cities, permits are approved so frequently that the early warning notices will be too late to prevent serious problems.  Once a housing development is built and the sewers connected, it is too late to rethink the impacts of the development on the sewer system.

3. While many cities are careful when they give IDEM the go-ahead to issue the sewer connection permit, municipalities tend to take the lead set by IDEM.  If IDEM does not consider an issue significant, some municipalities will follow suit.  IDEM's reluctance to clearly define how it makes early warning notice and sewer connection ban decisions sets a poor example.

County totals:

1. Sorted by flow
2. Sorted by number

Municipality totals:

1. Sorted by flow for municipalities accepting more than 100,000 gallons per day of new sewage flow since 1993.
2. Sorted by number for municipalities accepting more than 10 sewer connection permits since 1993. 

To search the community database yourself by county, city, wastewater treatment plant.

B.  Despite the lack of a "big picture" evaluation of facility construction permits, IDEM appears to closely scrutinize the permit applications. IDEM sends a deficiency letter to the applicant for more than 60% of the applications it received. In other words, IDEM received more than 6641 incomplete applications. 

These rates were surprising.  IKE evaluated the data to determine if the engineering firms that submitted many applications were faring better than average.  The answer is that they performed slightly better than average.  The top 40 firms submitted more than 55 applications with 58% of the applications receiving a deficiency notice  One firm submitted many more than any other firm with more than 700 application.  56% of its applications were incomplete.

For a tally of those 40 firms, click here.  Please note that IKE had combined firms with similar names on IDEM's database.  So the number may not be perfect. 

To search the engineering database yourself by engineering firm.