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Friday, January 7, 2011

Make a Public Comment on the NEORSD Sewer Rate Increase


The next step for the imposing of the proposed sewer rate increase in 63 communities in Cuyahoga and parts of Summit, Lorain & Lake County is the filing or formalizing of the proposed Consent Decree recently approved by the Northeast Ohio Regional Sewer District

The proposed Consent Decree between the Northeast Ohio Regional Sewer District (NEORSD) and the EPA has been filed in the United States District Court for the Northern District of OH.  This Consent Decree is for the $3 billion in upgrades to reduce Combined Sewer Overflow's (CSO's) as mandated by the EPA under the Project Clean Lake initiative and the Clean Water Act.  (United States and the State of Ohio v. Northeast Ohio Regional Sewer District, Civil Action No. 10-cv-02895).

The Notice of Lodging of a Consent Decree Under the Clean Water Act can be read by clicking here.
With the filing of this Consent Decree the Justice Dept has a 30 day period for public comment on the the proposed rate increases and mandated repairs.  Please take the time to make a public comment by email, U.S. Mail, fax and phone. 

Comments should be addressed to;

Assistant Attorney General  (Please note below RE: on envelope if mailing)
Environment and Natural Resources Division
P.O. Box 7611
U.S. Department of Justice
Washington, DC 20044-7611

Fax: (202)514-0097 


Tonia Fleetwood / Legal Information Specialist
PH: (202)514-1547
FX: (202)514-0097

PLEASE NOTE: For all correspondence & comments to be considered you must reference; 
United States v. Northeast Ohio Regional Sewer District, D.J. Ref. 90-5-1-1-08177/1

You can also approach the elected officials in your community and request that they pass a resolution against these arbitrary increases mandated by the EPA on an already economically distressed area.  Ask your elected official to forward the Resolution to the above contact information.

The Consent Decree and the $3 Billion EPA mandate to reduce CSO"s are the only sewer/infrastructure addressed in this proposed agreement. The combined sewer overflow is not the same and is seperate from a Sanitary Sewer Overflow (SSO) and storm water management.  In the near future we can expect the EPA will also mandate upgrades for SSO's due to the failing sanitary infrastructure throught this region/watershed.

What is a CSO? (Click here for map)
What is a SSO?

All three of the above fall under the Clean Water Act and are regulated by the EPA. To sum this up, the sewer rate increase for the $3 billion in repairs will only address the issues with CSO's and NOT SSO's or Storm Water Management issues. That means -- after the rate increase for the CSO' problem, they will soon be asking for MORE of your money to make EPA mandated upgrades on the SSO's and Storm Water issues.

Previous Sewer Rate Increase Posts;

1 comment:

  1. Assistant Attorney General
    Environment and Natural Resources Division
    P.O. Box 7611
    U.S. Department of Justice
    Washington, DC 20044-7611

    January 18, 2011

    Subject: Public Comment on United States v. Northeast Ohio Regional Sewer District, D.J. Ref. 90-5-1-1-08177/1

    To Whom it May Concern:

    The synopsis of this compliance plan is to spend $3bil on repairs to the CSO, leaving the SSO and storm water management non-compliance issues for a later time. I find this plan backwards and a waste of public funds and certainly requires additional significant funds for complete compliance.

    The storm water issues should be addressed first. It is the introduction of storm water that not only increases treatment cost (more volume at treatment sites) but it is the storm water that triggers CSO non compliance. I am not saying that handining all the storm water issues will totally eliminate CSO episodes from triggering, but in theory it should. The CSO fixes would be greatly reduced in cost and such things adding dams & resevoirs to contain CSO storm event (to be slowly released later for treatment as storm volumes diminish) would be totally eliminated.

    Also, by 'fixing' the CSO problems, you are gauranteeing that the public will be paying for all the storm water to be treated as sanitary effluent. The public not only has to pay for these $3bil in repairs but now has to pay for a significant more amount of water treatment driving costs up even further. The icing on the cake is that even after all this we are still no in compliance!

    Please revise this consent order and require that the storm water issues be addressed first. This will actually reduce the amount of treatment required and some of the costs of infrastructure can be offset with treatment savings. After the storm water issues are fixed the episodes of CSO release should be greatly dimished and monitoring duiring this period will show which site have more (or more serious) events and they can get priority for the final CSO fixing. Hopfully some CSO will only require capping the outlet to the public waterway and save the public much of this projected $3bil expenditure. I know some lines need replacing, but with reduced projected flows (no stormwater) the size of the system might be reduced and certainly resevoirs for storm surges are totally eliminated.

    If you see fault in my logic please point it out. I can not see adding expansions to a CSO system that will almost immediately be 'never used again' once the storm water issue compliance program is in place. Wasting parts of this $3bil (which could have helped expedite the storm water fixes) PLUS the increase in fees for treatment of all the additional storm water sent to the treatment facility puts the public in a lose - lose situation. Fixing the stormwater issue first, reducing the amount of effluent going to the treatment facility, creating a significant savings in the proposed CSO work, and theoretically stopping CSO events without doing any CSO modifications seems like a total win - win - win - win all around. I would imagine storm water fixes would be prioritized by current CSO history of severity so those types of events could be diminished ASAP and reduce the loads of effluent going into Lake Erie. This should satisfy the EPA, save the public money, minimize the repair costs, have the public enjoy the saving of not treating storm water much earlier, and not require CSO infrastructure be built that will quickly be obsolete.

    Again, please do not proceed with th e current plan of compliance. The best path for complaince, and the wisest expenditure of the public's money for the cost of compliance, would be to address the storm water issues first and the CSO issues last.

    Thank you for you time and attention to this matter,


    cc: Tonia Fleetwood / Legal Information Specialist


Thanks For Commenting