PLEASE ATTEND A PUBLIC HEARING
HOSTED BY THE EPA ON THEIR
DENIAL OF A WAIVER FOR A SECONDARY TREATMENT FACILITY
THURSDAY, MARCH 24TH AT 6:30 PM
KYROUZ AUDITORIUM, GLOUCESTER CITY HALL
Denial of the 301(h) Waiver Would Crush Already Over-Burdened Citizens
Ø Construction of a secondary treatment plant will cost at least $60 million and result in additional annual operational costs of at least $1 million.
Ø The full cost of the new facility would fall on the ratepayers of Gloucester, which would double their rates.
Ø There are currently no federal grants available for secondary treatment plant construction, as there were for all of the secondary plants built between 1972 and 1990.
Ø As a result of EPA’s decision, the annual charges for the average household would increase from $1,251 per year to $2,570. By way of comparison, the average rate per household in Massachusetts is $584 per year, and the current highest rate in Massachusetts is $1,632. This annual charge would be about 5.4% of the Median Household Income in the City, almost three times the percentage that EPA considers a “very high” burden on residential customers in its guidance on affordability of sewer infrastructure improvements.
Ø In any economic climate, the prospect of dramatically increased costs of water and wastewater services, especially with no measurable environmental improvement, would have serious and immediate repercussions in the business and real estate sectors of the City.
The recent decision by EPA to deny the 301(h) permit renewal, and therefore force the city to build a $60 million secondary treatment plant, is not only cost prohibitive at this time, but also provides no appreciable environmental benefit.
The City is committed to preserving and protecting the ocean resources that have played a major role in our history, which is a vital part of Gloucester’s identity. However, the City cannot look at wastewater issues in isolation, but more of a component to the overall infrastructure challenges. The City is committed to implement an infrastructure master plan that will reflect a reasonable balance between cost, demand and environmental benefit.
The following points touch upon the background of Section 301(h), the EPA’s change in position and the financial impact mandating the City to build a $60 million secondary treatment plant:
Background of Section 301(h) and the Gloucester Treatment Plant
Based on Congress’ determination that secondary treatment provides little environmental benefit for discharges to deep ocean waters, Section 301(h) of the federal Clean Water Act allows publicly owned treatment works with ocean discharges to receive a variance from the Act’s secondary treatment requirements as long as statutory criteria are met.
In 1985 and again in 2001, EPA determined that statutory criteria were met and granted a waiver for Gloucester’s treatment plant. If anything, the quality of Gloucester’s discharge has improved since 2001.
EPA’s Change of Position on the 301(h) Waiver
Despite that there has been no adverse impact on the marine environment in the vicinity of the outfall (One mile off-shore at a depth of 90’) and the fact that the City has recently invested $35 million in an EPA-mandated CSO project and $20 million on upgrades to the Wastewater Treatment Plant, EPA issued a draft denial of the 301(h) waiver for the Gloucester treatment plant in November 2010. EPA’s application of the statutory criteria to the treatment plant in 2010 is strikingly inconsistent with its earlier positive decisions in 1985 and 2001.
The City has invested $3 million over 20 years monitoring conditions in the waters and sediments around the outfall. This extensive EPA-approved program has shown no evidence of any change in the marine communities or of accumulations of organics or pollutants in the sediments. There has been zero change in the abundance, diversity or composition of the marine communities.
An expensive secondary treatment plant will not necessarily address the issues EPA raised.
The City recently switched contract operators of the waste water system and have stabilized and made dramatic improvements at the plant.
Gloucester submitted detailed technical and legal comments to EPA demonstrating that the discharge satisfies all of the 301(h) statutory criteria. More importantly, there will be absolutely no water quality benefit in forcing the City to spend more than $60 million to upgrade to secondary treatment.
The total sewer enterprise debt of the City would more than double, thus doubling the rates and have a major impact on the City’s bond rating.
The City of Gloucester will continue to challenge the EPA denial by putting forth the most compelling legal, technical, scientific and
financial arguments. For the complete testimony, please see www.gloucester-ma.gov.
LET YOUR VOICE BE HEARD. COME TO THE HEARING AND SHOW YOUR CONCERN. (YOU DON’T HAVE TO TESTIFY.)
Bob Hastings Executive Director, Cape Ann Chamber of Commerce