Proposed Solution for Lower Mill Creek Submitted to Regulators
2. Why has the cost estimate for the tunnel changed from the original estimate?
At the direction of the USEPA, the default tunnel solution was conceptualized in the final Wet Weather Improvement Plan (WWIP) as a default planning level conceptual solution. All parties (the Regulators, Hamilton County, City of Cincinnati and MSD) knew the default tunnel solution cost was a conceptual planning estimate, and that it was developed without any field engineering or analysis undertaken to inform the conceptual cost. This approach is standard practice on capital improvement projects of this magnitude as it reduces the cost for ratepayers of an initial detailed analysis that may not be relevant as the project advances and the concepts are revised.
3. What if the original project cost exceeds community affordability?
Because of the concern about potential costs, the Regulators, City of Cincinnati and Hamilton County negotiated "triggers" within the Consent Decree that could provide more time or other modifications should the costs exceed the original estimate.
As part of the Lower Mill Creek study outlined in the final WWIP, the Consent Decree allows for an examination of alternatives to the default tunnel through a three-year study which include refinements to the planning level costs. As part of this study, an updated default "grey" solution was developed and designed to nearly 60% level of detail based on detailed field engineering that provided a more accurate assessment of the project realities. The design was developed to achieve a significant volume reduction of the combined sewer overflows (CSOs) within the Lower Mill Creek in order to achieve the goals of the final WWIP. All of these changes resulted in the updated cost estimate.
4. Will this project the Lower Mill Creek Partial Remedy meet the Consent Decree requirements?
Yes, any Lower Mill Creek Partial Remedy (LMCPR) will comply and meet requirements under the final WWIP and Consent Decree.
5. Will the proposed solutions for the project meet water quality standards?
Any LMCPR will comply and meet requirements under the final WWIP and Consent Decree to comply with the Clean Water Act. Under the Clean Water Act, water quality standards apply to streams, not projects. The statement referenced from the presentation to the City of Cincinnati, "Any approach the co-defendants pursue will NOT achieve the fecal coliform standard," refers to the fact that after a ¾-inch rainstorm, the Mill Creek as it enters Hamilton County does not meet the bacteria standard–regardless of any impact or improvement to the MSD combined system. The bottom line? Even if all the CSOs were removed, the Mill Creek would still not meet the bacteria (fecal coliform) standards because the standard is being exceeded at the county line, well upstream of the first overflow.
6. How does MSD determine where to invest resources?
MSD is committed to improving public health and the environment. With compliance with the Consent Decree and final WWIP, MSD is committed to finding the most cost-effective solutions for its ratepayers. MSD conducts detailed engineering and technical analysis, and considers USEPA’s integrated approach to work with partners to identify those cost-effective solutions.
7. How are project costs being covered–who is paying for this?
MSD is committed to ensuring that MSD ratepayers only pay for MSD responsibilities. MSD is collaborating with multiple governmental, nonprofit and other entities to find the best and lowest cost to achieve compliance. The complexity of "integrated" solutions requires continual engagement with multiple agencies across Hamilton County and the City of Cincinnati to ensure parks, roadways, community development, and other issues are integrated properly. MSD has worked diligently to track costs and account for them in good faith.
8. How is MSD addressing historical and cultural issues under the proposed Lick Run Alternative concept?
Historical and cultural issues have been an important area of focus in MSD's efforts to-date on developing the Lick Run Alternative concept. MSD has had discussions with its citizen advisory committee (the Communities of the Future Advisory Committee or CFAC), and federal agencies. Community members have also provided input, as historical and cultural issues were prominently featured in the three community design workshops where input was solicited from the South Fairmount community.
Given the current status of the proposed project, a federal lead agency has not been defined for compliance with Section 106; Section 106 is an obligation of a federal agency to perform. However MSD has taken actions to initiate a process consistent with Section 106 regulatory standards. This assessment of potential project affects on historic properties has been undertaken by MSD out of an abundance of due diligence and commitment to community input.
In light of the fact that this stage of the project will not involve federal agency compliance with Section 106, MSD has decided to take a Best Management Practice (BMP) approach to cultural resource management interests. This approach was developed to consider and address potential historical issues and move forward on decisions under an established BMP process so that a lead agency - should one be defined in the future–can review and understand project related decisions, including community input.
On December 20, 2012 – after nearly three years of technical evaluation and stakeholder involvement to develop an integrated watershed-based solution to wastewater, combined sewer overflow (CSO) and stormwater issues – MSD submitted its Lower Mill Creek Partial Remedy (LMCPR) Study Report to the USEPA and other Regulators1 governing MSD's Consent Decree. USEPA is holding a public comment period on the LMCPR in January 2013.
Lower Mill Creek Partial Remedy (LMCPR) Study Report – December 2012 (4 MB)
Excerpts from LMCPR Study Report on Community Engagement
LMCPR Community Engagement Outreach Summary (compilation of actual materials) (123 MB file size - may take 10 minutes or longer to display file, thank you for your patience.)
MSD's study proposes a "Revised Original Lower Mill Creek Partial Remedy (LMCPR)" for eliminating 1.78 billion gallons of CSOs annually into the Mill Creek by 2018 (during Phase 1 of MSD's Consent Decree) and improving water quality. Additional solutions will be proposed for Phase 2 (after 2018).
The proposed Revised Original LMCPR uses sustainable infrastructure, recommended by MSD in September 2012 to Hamilton County and City of Cincinnati. The sustainable approach seeks to reduce CSOs by primarily focusing on reducing the amount of stormwater entering combined sewers during heavy rains; it integrates green infrastructure with gray to provide a lower cost and more favorable outcome that also provides community, economic and environmental benefits.
With the submission of the Lower Mill Creek study, the Regulators are formally requested to approve the Revised Original LMCPR. The Revised Original LMCPR includes many of the projects referred to in MSD Town Hall meetings and Hamilton County public hearings as the "sustainable alternative" and is a substitute and replacement for the deep tunnel solution (referred to as the Original LMCPR in the Consent Decree).
The Revised Original LMCPR or the sustainable solution includes a suite of projects that were identified and refined using an integrated watershed planning approach in the following sub-watersheds within the Lower Mill Creek watershed:
- Lick Run
- Kings Run
- West Fork
- Bloody Run
The projects – which range from new stormwater sewers and stormwater detention basins to the restoration of streams – will eliminate the CSOs at a cost of $244 million (in 2006 dollars). The solution was refined to achieve a 1.78 billion gallon reduction of CSOs (which is equivalent to the original 2 billion gallon reduction based on the updated baseline model). With the Revised Original LMCPR, MSD's proposal is more than $200 million less expensive for ratepayers than the Original LMCPR, making the mandated fix more affordable for MSD’s ratepayers.
The Lick Run project reduces overflows into the Mill Creek from the largest CSO in MSD's system by an estimated 624 million gallons annually. This project keeps stormwater out of the combined sewer system through the installation of new stormwater sewers, stormwater detention basins and the creation of an urban water/valley conveyance system interconnected with various best management practices to improve water quality prior to flow entering the Mill Creek. The project will also help reduce localized flooding and improve community conditions.
The West Fork project reduces CSO volume into the West Fork Channel, a tributary of the Mill Creek, by an estimated 173 million gallons. It addresses the largest overflow in the West Fork Watershed and removes a significant volume of natural drainage from Mt. Airy Forest, the largest park in the City.
The Kings Run project reduces CSO volume into Mill Creek and the Kings Run tributary by an estimated 156 million gallons . This project includes stormwater detention basins to reduce peak flow into the combined sewer system, new stormwater sewers, repurposing of existing infrastructure that is better sized for stormwater and construction of a new sanitary sewer.
The Bloody Run project reduces CSO volume by an estimated 93 million gallons into the Mill Creek. This project includes the installation of real time controls inside the interceptor sewer. Real-time controls include gates, pumps and inflatable dams, etc. that are constructed inside sewer lines to divert excess flows to a different part of the sewer system to prevent overflows.
The sustainable solution was developed through a sustainable watershed evaluation planning process known as SWEPP. This process allows MSD to identify current conditions in a watershed and the most cost-effective, sustainable and beneficial combination of infrastructure types to address those conditions.
The sustainable solution will benefit the environment by keeping stormwater out of our combined sewer system and returning it directly to the Mill Creek and its tributaries with the use of best management practices to improve its quality. This will improve the health of our rivers and streams.
The Regulators are anticipated to make a decision on the proposed solution in early 2013.
For more information, please contact MSD Engineering Customer Service at (513) 557-3594 or MSD.Communications@cincinnati-oh.gov.
1The Regulators include the U.S. EPA, Ohio EPA and the Ohio River Valley Water Sanitation Commission (ORSANCO).
How does the "Revised Original LMCPR" differ from the September 26, 2012 MSD Recommendation?