Guests: Jack Ubinger
Jack Ubinger provided an update on the ALCOSAN Wet Weather Plan and other related efforts within ALCOSAN. Jack is a policy consultant to 3 Rivers Wet Weather and has been intimately involved in the Sewer Regionalization Implementation Committee and is managing the legal committee that is developing the principals around the potential transfer of the trunk sewers and the liability to ALCOSAN. Jack has a background in environmental law, and environmental regulation. He has been actively engaged with 3RWW since January 2013 but has been working with John since 2008.
The meeting’s focus was to have a conversation with Jack about the ALCOSAN consent decree and how it would effect municipalities in the near future. Jack began with a review of the consent decree which required ALCOSAN to provide a wet weather control plan to the EPA in 2013. ALCOSAN made a determination that if it were to devise a plan as close to the consent decree as possible it would cost around $3.6 billion. ALCOSAN made an alternative selective plan acknowledging it would not be in compliance with the consent decree but was more in line with the affordability index. After submitting the wet weather plan in 2013 to the EPA, ALCOSAN asked for an 18 month extension to look into green infrastructure, source reduction and to try and convince the EPA that full compliance by 2026 is unaffordable. The EPA agreed to the extension and further conversations. The EPA wants ALCOSAN to make more progress towards regionalization, source reduction and flow control in the modified plan.
The EPA is coming to Pittsburgh June 17th at 7:00 pm at the Green Tree Double Tree hotel. All municipalities will be receiving an invitation shortly.
There have been many committees to determine how to best approach the requirements of the consent decree and the obligations involved with the extension. In late 2011 ALCOSAN and the Allegheny Conference came together to determine alternatives for regionalization, and released recommendations known as the Cohen Commission. The consensus of that body was that we really do need a way to integrate the system. This does not mean taking over the entire system, only the multi municipal trunk lines.
There is currently a consultant working on a map to determine where these multi municipal trunk lines are and which ones are integral to integration. They are also working a defining what constitutes a multi municipal trunk line. The map being created will be the foundation for identifying which trunks should be transferred to ALCOSAN. The final recommendation will include accepting the proposed definition of a multi municipal trunk line and municipalities agreeing to give those trunk lines to ALCOSAN. All other sewer assets will remain with the municipalities. This will hopefully meet the EPA requirement for regionalization. Once the map is constructed it will be circulated to all the municipalities who have a piece of those trunk lines.
Another recommendation from the Cohen Commission was to change the governance structure of ALCOSAN. Two committees were formed. One was facilitated by the Institute of Politics, which Amanda sits on. They recently finished their report and provided recommendations to the County Executive and Mayor of Pittsburgh. The second committee, the Sewer Regional and Implementation Committee, has been looking at the asset transfer piece. The committee, facilitated by 3RWW and CONNECT, is to recommend how the multi municipal trunks are to be transferred to ALCOSAN.
Jack explained that there are three starting criteria that were used to define a multi municipal trunk line. 1. The path the line has to go through is more than one municipality and then connects to ALCOSAN. 2. The line has to be at least 10 inches in diameter. 3. The line has to effect the integrated operations of the system.
In addition, all municipal wet weather infrastructure will be part of the regionalization plan. An example of this is a storage tank holding water when there is heavy rain. This will ensure a wet weather plan for the region is handled solely by ALCOSAN.
The subcommittee that Jack sits on has constructed a short document to outline the transaction principles. He is going to be presenting the principles to the entire committee after the meeting this morning. If the committee ratifies the transaction principles it will be ready for distribution to the municipalities.
One principle that is being recommended is that ALCOSAN would take the sewer pipes as is. ALCOSAN would then become responsible for whatever feasibility study obligations are outstanding on those pipes. This also means that ALCOSAN will not be providing monetary consideration to the municipality in terms of purchase price, however they will assume monetary obligations of the trunk line.
Jack hopes to have the principles and other recommendations ready for distribution to the municipalities before the EPA meeting June 17th. The format and date of that information to be released has not yet been determined.