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$3 Billion for Sewer Infrastructure Repairs:
Are We Misallocating Resources?
By
Bradley S. Tupi, Esq.
The Southwestern Pennsylvania Water and Sewer Infrastructure Project
Steering Committee has published an April 2002 report, "Investing in
Clean Water." It is available on the Internet at
www.campaignforcleanwater.com. Many are citing the Committee Report
as influential in shaping our region’s response to EPA’s demand for
sewer infrastructure improvements.
In reviewing the Committee’s description of the sewer overflow
problem, several points stand out.
First, over eight years (1994-2001) there were 96 Summer Season CSO
river advisories in Allegheny County, an average of 12 per year. These
river advisories are issued when our rivers are thought to be unhealthy
for recreational contact because of bacterial contamination. An advisory
may last a day or more. The striking fact is that EPA is asking our
region to spend billions of dollars to address about 12 incidents per
year.
Second, according to the Committee Report, the health effects
attributable to these contamination incidents are very few. The three
diseases associated with exposure to water contaminated by sewage are
giardiasis, cryptosporidiosis, and E. Coli-related illness. In 2001,
there were 161 reported cases of giardiasis, 23 cases of
cryptosporidiosis and 29 cases of E. Coli-related illness, or a total of
212 cases of disease in 2001. These are transient, not fatal, illnesses.
If our region were to spend $3 billion on sewer infrastructure in order
to deal with 212 cases of illness, we would be spending over $14 million
per case. Assuming the expenditure occurs over a 10-year period, we
would be spending about $1.4 million for each of the cases that would
occur over a decade. Surely it is debatable whether this is a wise
allocation of resources.
The Committee Report does not state the origin of these 212 cases of
disease. It may be that some or all of them arose from contaminated
drinking water wells, not from exposure to sewer overflows. Perhaps the
regulators should find out before demanding that our region spend $3
billion.
EPA’s focus on CSOs and SSOs implies that these are the cause of
water quality problems and waterborne disease in Allegheny County.
However, the Committee Report states that "The risk of illness is more
acute for users of groundwater than for users of treated surface water."
In other words, the people who are getting sick are those using
groundwater wells as their source of drinking water. Indeed, between
1989 and 1998, "every outbreak of waterborne illness attributed to
bacterial contamination in drinking water in the U.S. was traced to
groundwater problems, according to Centers for Disease Control." But in
Allegheny County, 83% of the population is served by public water
systems that draw (and treat) their water from surface sources (rivers
and reservoirs). Only 2% of Allegheny County’s population is served by
private wells or springs, so it would seem that only 2% of Allegheny
County’s population is at high risk for waterborne illness. If we are
going to spend $3 billion to address an alleged "health crisis," it
would seem to make sense to focus the effort upon those at highest risk,
in other words, those 2% of Allegheny County residents who get their
drinking water from private wells and springs. Of course, the consent
orders proposed by DEEP and ACHED do nothing of the sort. So the $3
billion expenditure may have no appreciable impact on the health effects
we are supposedly concerned about.
The Committee Report identifies three principal sources of fecal
bacteria in surface water and groundwater: (1) sewer overflows; (2)
malfunctioning on-lot septic systems; and (3) animal waste in
agricultural and storm water runoff. Other reports identify a fourth
important source, (4) wildcat sewers, that is, unpermitted sewers that
dump untreated sanitary sewage directly into ditches, streams and
rivers. The Committee Report notes that "it is difficult or impossible
to pinpoint the exact source of a given sample of fecal bacteria." The
Report does not present any data from which one could determine where
the majority of fecal bacteria originates. EPA has estimated of the
quantity of water that overflows from sewers, but the Committee Report
presents no comparison that would enable one to conclude that sewer
overflows contribute more fecal bacteria than other sources. As a
result, the expenditure of $3 billion on sewer infrastructure in the
ALCOSAN service territory may, in fact, do nothing to alleviate the
principal sources of fecal bacteria in the Three Rivers.
It would seem to make better sense to develop the scientific data
necessary to quantify the relative contributions of various pollution
sources before determining a remedy. Surely we should focus our spending
on the most important pollution sources. But the regulators are
operating from the presumption that reducing sewer overflows will
improve water quality and reduce disease. We may end up spending $3
billion to rebut a false presumption, $3 billion that could have been
better spent on identifying and fixing the most important sources of
bacterial contamination. From the regulators’ point of view, it may seem
too difficult to identify the contributions being made by individual
septic systems and farms. It is much easier, of course, to pursue a
large municipal treatment facility (ALCOSAN) and municipalities, many of
which are undoubtedly contributing to sewer overflows. However, because
this $3 billion effort begins without adequate water quality baseline
data, our expenditures may yield little or no benefit in terms of
improving water quality or reducing the risk of waterborne disease.
Nevertheless, it seems as though the "critical mass" has already
formed in support of the regulators’ presumptive approach. A May 28,
2002 editorial in the Pittsburgh Post Gazette cited the "Investing In
Clean Water" Report as describing a "crisis" and an "intractable health
threat." Muted are the voices who would ask whether our region is
embarking on a wasteful, ill-conceived program.
Perhaps in responding to the DEP and ACHD draft consent orders,
municipalities should demand a provision calling for water quality
monitoring designed to establish baseline fecal bacteria data and
identify whether sewer overflows are indeed an important contributor to
water contamination and waterborne disease.
For more information on the subject of this newsletter, please
contact Brad Tupi at 412/594-5545 or via e-mail at
btupi@tuckerlaw.com.
Brad Tupi is an
environmental lawyer and a former township commissioner. He has served
as Vice Chair of the Southern Communities Basin Group and as a member of
the Three Rivers Wet Weather Demonstration Project Stakeholders Group.
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