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CCR2007097. . . 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. . . . 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). . . . 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.