CCR2007097.
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CITY OF MUSKEGO - COMMON COUNCIL
RESOLUTION #097-2007
RESOLUTION OUTLINING CITY OF MUSKEGO'S POSITION
REGARDING THE PROPOSED 2020 MMSD FACILITY PLAN
WHEREAS the Milwaukee Metropolitan Sewerage District (MMSD) has prepared a 2020
Facilities Plan for the MMSD planning area; and
WHEREAS the City has not had an adequate opportunity to conduct a proper technical review of
the plan because of the timing of its availability. Important information included in the plan,
such as the fiscal impact on our businesses and homeowners, was still not available as of
April 20, 2007; and
WHEREAS the plan will have a significant financial impact on the City, and will not produce
any measurable water quality improvements; and
WHEREAS this planning effort has developed a scientific understanding of how the pollution
sources degrade the water quality of the region; and
WHEREAS the communities served by MMSD have already expended in excess of $4 billion
dollars on the reduction of combined sewer overflows (CSO's) and separated sewer overflows
(SSO's) and the planning data clearly show that any further efforts to eliminate SSO's will
produce no measurable water quality improvements in the region; and
WHEREAS this 2020 Plan assumes that the MMSD's current discharge permits and DNR
regulations (regulatory approach) would need to be followed while at the same time providing
sufficient data to qualify the region to consider a water quality, watershed based approach to
water quality management; and
WHEREAS the 2020 Plan recommends that the regulatory approach be followed which will
require the expenditure of $481 to $646 million dollars to further reduce SSO's which constitute
1.6% of the water quality problems, and further recommends spending nothing to reduce CSO's
which constitute 6.6% ofthe water quality problems; and
WHEREAS it is recognized that the MMSD system is unique in Wisconsin in that the system is
fully integrated and accommodates both combined and separated wastewater with the same
facilities, which make the regulation of MMSD using two sets of different regulations (one for
SSO's and one for CSO's) overly complex and totally at odds with a focus on overall water
quality; and
NOW THEREFORE BE IT RESOLVED that the Mayor hereby submits to the MMSD the
following comments and concerns relating to the Draft 2020 MMSD Facilities Plan:
1. Because the planning process fell behind schedule, which did not allow for all of the
documentation of the findings and recommendations to be properly reviewed and discussed
with the community's technical staffs, any submittal of the plan to the DNR should indicate
that additional review and analysis by the MMSD and the communities may require
amendments to the recommended plan.
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Reso. #097-2007 Page 2
2. The assumption that the plan needed to meet the current DNR regulatory requirements
precluded analysis of how the region's tax dollars could be better spent to achieve improved
water quality conditions. The scientific data developed as part of the planning process
clearly indicate that a water quality approach based upon water-quality objectives and
standards together with a water-quality management process is far superior to the regulatory
approach being taken. Additional efforts on the MMSD's part are needed to work with the
DNR to obtain a water quality based permitting system for the watersheds concerned so that
excessive capital expenditures with no attendant improvements in water quality can be
avoided. Our community would support an effort to work with the DNR to achieve a more
rational approach to achieving the desired water quality objectives.
3. With the draft plan being committed to the regulatory approach, various options, which
would increase the hydraulic capacity of the system and reduce overflows were either
overlooked or discounted. For example, the Jones Island wastewater treatment facility,
which currently is allowed to utilize blending for up to 60 MGD, could be allowed to blend
up to its full hydraulic capacity for blending of 100 MGD. This would involve virtually no
extra costs and would eliminate an additional 40 MGD of untreated overflows.
4. The South Shore wastewater treatment facility, which treats both combined sewage and
separated sewage, should be allowed to utilize blending up to the existing hydraulic capacity
available. This would be the least expensive way to reduce system overflows and increase
the hydraulic capacity of the system. Any amount of blending would be preferred over
overflows of combined or separated sewage.
5. Our community supports the provision of additional pumping capacity from the inline
storage facilities to the Jones Island wastewater treatment facility as this would increase the
hydraulic capacity of the system. In addition, the proposed re-rating of the Jones Island
facility, along with increased blending, should be evaluated before any decisions to provide
additional capacity are made.
6. Our community agrees with the use of the revised 2020 baseline population and land use
forecasts for determining the needed future capacities of the Jones Island and South Shore
wastewater treatment facilities and of the storage tunnels. The population of Milwaukee
County is, however, declining and wet industries continue to leave the area. Given the
attendant uncertainty of the forecast growth and the future success of the wet weather peak
flow management program, our community could not support proceeding with any additional
capacity improvements, over and above those already mentioned, until actual growth and
attendant flows become more predictable.
7. It is recommended that MMSD and its customer communities work with the DNR and
USEP A to attain formal regulatory recognition of the integrated nature of the MMSD system,
eliminating the present artificial distinction between inline storage system-related SSO's and
CSO's. This would entail achieving a watershed based water quality approach to permitting.
The permitting process should include variable wet weather discharge limits, authorization
for blending when the use of the existing facilities are maximized, and would allow for the
cost effective trade-off between alternative water quality control measures. This objective
could be accomplished through the existing DNR permitting process supported and
monitored through the existing area wide water quality management agency (SEWRPC).
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Reso. #097-2007 Page 3
BE IT FURTHER RESOLVED that the City of Muskego Common Council while supporting the
overall goals of a water quality based permit and plan, expresses its disappointment in the
timeliness of plan documents for review and the lack of Chapter 11, the cost and implementation
chapter. Further, the Common Council is disappointed with the timeliness of public comments
and debate, originally due in the next week, especially considering the additional 526 million
dollars worth of expenditures proposed under the 2020 Plan, which is in addition to the already
committed 2.5 billion dollars of MMSD projects and financing and the estimated 1.5 billion
dollars of local expenditures.
DATED THIS 24TH DAY OF APRIL, 2007.
SPONSORED BY:
FINANCE COMMITTEE
Ald. Bob Melcher
Ald. Neil Borgman
Ald. Keith Werner
~~o~ City of Muskego
This is to certify that this is a true and accurate copy of Resolution #097-2007 which was
adopted by the Common Council of the City of Muskego.