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Evaluating LTCPs for Three Key Cities
Three cities have made significant progress developing their Combined Sewer Overflow (CSO) Long-Term Control Plan (LTCP). These cities are farther along than most cities. Only Mishawaka has submitted their plan to the State for approval. IKE has reviewed each of the documents and has the following observations:
Fort Wayne: Fort Wayne has almost one billion gallons of overflows a year and is under a EPA-imposed Agreed Order to develop a LTCP. In July, the Fort Wayne City Council adopted the lowest cost alternative of three alternatives presented which ranged $170 to $235 million. All options fall far short of achieving Indiana’s water quality standards. When implemented, the council’s choice will result in about 12 overflows of raw sewage a year. The city offered significant opportunities for public comment on the draft plan before the council decision.
IKE’s Comment: While the plan is not final, the components of plan that have been published did not follow several EPA requirements especially in the selected approach and range of alternatives — alternatives that should have included less than one overflow per year. The document focuses on the engineering aspects of the improvements and the overall function of the city’s sewer system. It did not adequately explain the improvements in water quality and the public health benefits that would result probably explaining why the city-council chose the lowest cost option. IKE met with the city about its concerns in late June and sent a follow-up letter outlining concerns. The city has not responded.
Indianapolis: With about eight billion gallons of overflows a year, Indianapolis has the worst CSO system in Indiana. In July, the city published a report that is likely to be the core of its LTCP. Costs range from $838 million to $1.3 billion, with the high end resulting in about four overflows a year. With the report as a basis, the city is conducting extensive public forums where citizens can influence the LTCP before a draft is published.
IKE’s Comment: In July, the city released a report that lays a foundation for the plan. This approach provides the city with more flexibility to respond to public input. The public participation effort is excellent. The report closely connects the alternatives to improvements in water quality. However, the public has not been provided with a full range of alternatives to consider as required by EPA. After meeting to discuss the issue with the city, IKE is hopeful that the full range of options available to the community will be presented.
Mishawaka: In May, Mishawaka finalized its LTCP and requested about $15 million in state revolving loan funds to implement it. The central feature of the plan is a 10’ diameter tunnel 40’ below grade that would extend 820’ along a redevelopment area. The changes will reduce the number of days where Mishawaka’s CSOs contribute to an E.Coli.. violation from about 50 to 3.3 days a year. One public hearing was held to discuss the LTCP.
IKE’s Comment: The plan follows the structure dictated by EPA guidance and considers a full range of alternatives. However, it does not acknowledge or address the extensive fishing and recreation that occurs on the St. Joseph River, especially the kayaking course in South Bend. In addition, there are questions about the rejection of satellite storage facilities and the sizing of the tunnel that need to be addressed. IKE will be meeting with the city to discuss these concerns in September.
See IKE's broader effort on combined sewer overflows for more details.