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To: NYS Department of Environmental
Conservation, Avon, NY
From: Hugh Mitchell, Conservation Chairperson,
Atlantic Chapter, Sierra Club
RE: Comments on DEC Permit application #:
8-2699-00097-00002
Monroe County Water Authority
application for East Side Water Supply Project
In community documents and in the application
for a new East Side Water Supply project the Monroe County Water Authority (MCWA)
gives the following reasons they feel a new water treatment plant is needed:
1) Homeland security issues/reduced
vulnerability for the entire region.
2) Improved reliability for production and
transmission systems
3) Improved energy efficiency and
associated operational costs.
4) Meets long-term water supply capacity
needs of the region.
5) Provides for the ability to meet future
water quality challenges.
6) Provides cost-effective solutions for
addressing aging infrastructure replacement needs.
The Atlantic (NY) Chapter of
Sierra Club questions most of these arguments because the MCWA presumes they are
the only water provider who can address the region’s water needs AND they
presume there is a need. Neither of these presumptions are true.
We summarize our major points spelled out below
as follows:
1) Better security and safety of the water
supply is gained by having multiple regional water providers rather than one
very large system. By adding only this new MCWA water supply from Lake
Ontario the system becomes more vulnerable and less secure if the MCWA
system fails. Multiple smaller systems are more secure and less vulnerable.
MCWA has argued that pipes crossing the
Genesee River canyon are vulnerable to terrorists. This is an absurd
argument designed merely to appeal to public fears stemming from the 9/11
attacks.
2) Improved reliability and transmission is
gained by improved connections to regional water suppliers in the high
southern upland, gravity fed, areas like the Conesus system or the Batavia
City system. The key to improved water reliability and transmission is
better maintenance and infrastructure management. The MCWA should use their
profits to help the City of Rochester improve their water infrastructure.
3) Improved energy efficiency. The MCWA now
spends in excess of $4 million dollars on pumping water up from Lake
Ontario, the lowest water source. Improved energy efficiency and the lowest
operational costs can come best by developing multiple upland water sources
which can transport water by gravity, as is done by the City of Rochester,
rather than by pumping over a large higher water use area.
4) Water Capacity needs. The MCWA is
exaggerating the water capacity needs of an area which is losing population.
Currently the MCWA system can produce a total of 171.3 million gallons per
day (mgd), while the City system (which is connected to MCWA) is licensed to
produce 48mdg, giving the immediate area nearly 220mdg. The MCWA average use
is 62mgd while the city averages less than 28mgd. Thus the immediate region
has an excess water supply of 130 million gallons per day which is more than
double the need. When coupled with shrinking population and stagnant
economic growth there is no need for a new 50mgd water treatment plant.
5) Water quality. MCWA claims a new plant
will meet water quality challenges, but all water quality must be certified
to meet Federal water quality standards. A new supply from Lake Ontario is
of questionable and unproven long term quality, whereas the water supply
from the Hemlock/Canadice system has proven quality for over 100 years.
6) Aging infrastructure. The problems of
aging infrastructure are related to the City system. MCWA is planning to
construct the East Side plant to replace the city system. What is needed is
County help to repair and modernize the city system rather than forcing the
city to sell its system to the MCWA by the threat of building a new East
Side plant.
The Atlantic Chapter of Sierra Club recommends
that the DEC reject the permit applications of the Monroe County Water Authority
for a new East Side Water Supply.
The Atlantic Chapter of Sierra Club has
reviewed the above application of the Monroe County Water Authority (MCWA) to
NYS Department of Environmental Conservation (DEC) seeking approval to construct
a new water treatment facility in Webster, N.Y. It is our position that this
facility is unneeded and unnecessary at this time. An East Side plant was
initially designed in the 1980’s when Monroe County was growing rapidly and
conceived even earlier in the 1960’s. The current application reflects old
statistics and old plans. It is badly out of touch with current times in which
Monroe County has been losing population and reducing the need for potable
water. Please see below some of our points related to why the license
application should be denied.
1) Monroe County currently has a more than
adequate supply of water and will continue to have more than needed into the
near future.
a. According to statistics in the
application the MCWA can now produce 171.3 million gallons of water a day.
Left out of the application are the additional millions of gallons a day (mgd)
available for purchase by MCWA from the City of Rochester who are licensed
to produce 48mgd and who use approximately 20mgd. Since the MCWA uses and
average of only 62mgd their system alone has an excess capacity of over
100mgd which is more than twice as much water as currently needed. When
combined with water available for purchase from the City the MCWA system has
an excess capacity of approximately 120mgd.
b. MCWA admits in their lectures that water
demand is down at least 15% because of the loss of manufacturing and because
of modern water saving pluming.
c. MCWA argues that a new plant in Webster
is needed to “balance Eastside water needs with Westside needs”. In fact
this presumption was based on the 1958 Metcalf and Eady Report on future
water needs for Monroe County. The fact is MCWA has announced in their 1999
Annual Report that it was their “manifest destiny” to aggressively expand
their “assets”. What followed, under the leadership of John Stanwix, was one
of the most aggressive expansion programs in New York State which included
taking over all piping in Genesee County and expanding into parts of four
other adjacent counties. MCWA now wants the water from the proposed Eastside
plant to further the expansion of water services into adjacent counties.
Sierra Club has charged (in our 2000 study) that “Sprawl Follows the Pipes”.
d. Expanding the water supply by building
the Eastside plant will result in environmentally harmful sprawl development
done at an economic cost to both existing suburbs and the city.
The permits should be denied on the basis
that more water is not needed.
2) The Webster plant was planned at a time
Monroe County population was growing where as now the population is shrinking.
The Webster plant was originally conceived
as a cooperative project with Xerox to combine cooling the Xerox facilities
and provide potable water for Eastern Monroe County. Eventually Xerox backed
out of the project and downsized. This part of the history is not mentioned
in the application but should be considered as relevant information.
Currently the Monroe County population
between 2000 and 2004 has dropped from the peak by 27,000. There is no need
to expand water services when the population has dropped. Further, future
demographic studies do not support the kind of growth in Monroe County which
the MCWA projected to justify the plant back in the initial planning in the
1980’s.
3) MCWA proposes to discharge effluents and one
million gallons of backwater per day from the treatment process into Lake
Ontario. Although this matter is discussed in the SPDES permit there should be
no discharge into the Lake at the point of pure water in-take.
The Monroe County Water Authority
application calls for a new combined sewer overflow of effluents and
backwater from the residue of the treatment process back into Lake Ontario
of approximately one million gallons per day. This matter been inadequately
addressed in the application. It does not seem wise to pollute Lake Ontario
water near where the drinking water intake will be located.
Construction spoils: There is inadequate
identification of where the construction spoils will be stored and how they
will be kept out of the Lake from any storm caused washout.
4) No mention of storage of treated water.
a. The application is inadequate in that it
does not address where and how MCWA will handle the excess of treated water.
Will they build a new reservoir on their Webster property or some where else
in Monroe County? There is currently national pressure to cover all
reservoirs. Will MCWA build a new, covered reservoir to handle the 150mdg of
excess water? There has been no public discussion at all about a new
reservoir. This should be referenced and discussed in the application.
5) Planning for the plant dismisses the
Waterfront Revitalization and Coastal Resources Act.
a. This matter needs to be more thoroughly
researched and addressed. It is insufficient to simply say that the
“…project is not subject to Policy 29”. Further, the future of the Lake
Ontario and particularly the near shore areas are under intense study by the
Lake Ontario Coastal Initiative Federal grant. The effects of taking coastal
wetlands and the effects of the backwater need to be discussed more
thoroughly in relation to multiple Lake Ontario studies such as the
Rochester Embayment and International Joint Commission work.
6) Plant costs
The actual costs of the East Side plant
have not been publicly disclosed. Publicly the MCWA is reporting the plant
will cost $128 million, where as the NYS Revolving Loan applications from
MCWA for Monroe County 2006/07 there are loan requests totaling $133 million
for the Eastside Supply project. When construction over ride costs and
inflation are taken into account the project is likely to cost even more. We
question whether an investment of this amount is necessary and wise for the
economic health of the area. It is certain that the MCWA will have to raise
water rates to pay the costs of the plant.
7) Questions on MCWA Oversight & Responsibility
Recently the NYS Controller found a lack of
Board oversight over the Executive Director and the Office has further
studies underway on possible MCWA contract irregularities. The fact is the
Board is largely made up of persons associated with the real estate, finance
and construction interests. Because three members of the Board that failed
their oversight duties are still on the Board the permits should be denied
until public trust is reestablished in MCWA operations.
Conclusions
It is the opinion of Atlantic Chapter of
Sierra Club that the MCWA permit applications for a new Eastside Water
Treatment plant be denied.
For further comment and clarification
contact:
Hugh Mitchell, Conservation Chairperson,
Atlantic Chapter, Sierra Club
(585) 244-2625
goshawk@frontiernet.net
Support documents were submitted under separate
cover on 7/13/06 to John Cole, DEC staff.
“Watering Sprawl: Is a new water treatment
plant in Webster needed or will it just be the engine of unsmart growth?”,
Rochester Regional Group of Sierra Club, 2005.
“Sprawl Follows the Pipes: An inquiry into
the relationship between water distribuioin and development in the Rochester
Region of New York”, Rochester Regional Group of Sierra Club, 2001.
  
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