Responsiveness summary

 

1. Comment:   Resident on Park Ave. indicated his concern about the impacts of the proposed new route for the conveyance that uses Park Ave. He noted the buildings along Park include a school, Sacred Heart Basilica and the Syracuse Polish Home along with many homes and businesses. Feels the new route impacts more people and businesses than the County's previously proposed route which impacted Eureka St. He suggested that the pipe should follow the route of the existing Harbor Brook along Sackett St., then across W. Genesee St. (Robert Synakowski, President of Syracuse Polish Home. Similar concerns also raised later in the hearing by David Pilat.)
 

Response:   Previously the Harbor Brook Interceptor Sewer (HBIS) followed the route of the Brook until it was re-routed during replacement in the 1980s. At that time, the new interceptor sewer was re-routed due to poor subsurface conditions west of W. Genesee Street. The original HBIS pipe had settled, and there was concern that placing the new HBIS in the same location might cause settlement to surrounding structures.
 
As a result of questions raised at the public hearing, the County committed to re-investigate the alternate route along the brook as suggested for the conveyance line. (See below.) An assessment will also be made to determine if heavy construction within this area could cause damage to the subsurface structure that encloses this section of Harbor Brook.
 
With regard to the Park Ave. route vs. the Eureka St. route, the County has calculated that there are about an equal number of residences that would experience short-term construction impacts along either the Park Ave. route or the Eureka St. route. In addition, use of the Park Ave. to State Fair Blvd. route would shorten overall construction time in the streets in this area of the city. Also the County's design engineers for the conveyance pipe have estimated that total construction costs of the Park Ave. route would be approximately $830,000 less than the Eureka St. route. The cost reduction is due primarily to a significantly shorter conveyance pipe and a reduced number of manhole structures at bends in the sewer.
 

2. Comment:   Area resident indicated his interest in the project because it provides an opportunity to improve the neighborhoods while also improving the sewer system. He gave four suggestions for neighborhood improvements that the County could pursue in conjunction with the Harbor Brook project (Suggestions have also been discussed at TNT meetings and previous meetings with the County):

• Install sidewalks along Grand Avenue where none currently exist.
• Repair the athletic field at Fowler High School.
• Remove three existing buildings at the corner of Grand Ave. & Delaware and create recreational space.
• Make improvements to the City's Frazer Pool so
it can be re-opened (Robert Oberst representing TNT and Neighborhood Watch).

 

Response:   The County has been and is open to mitigation and amenity suggestions from the public which relate to this construction project. The County is considering completing the sidewalks along Grand Ave. and creating the new recreational space at the corner of Delaware and Grand. With the proposed pipe routing traversing the Fowler Athletic Field and involving construction near the school, the County is also working with representatives of the City of Syracuse School District and Fowler High School to coordinate and accommodate future planned school district improvements to the Fowler building and the athletic fields. The County will restore all areas disturbed by construction including the Fowler athletic fields and will work with school officials to ensure the field restoration is acceptable and compatible with their schedule and plans.
 
The County does not know the details of the reasons the Frazer pool is closed; however, as far as the County making the improvements to the Frazer pool as part of this Harbor Brook project, it is not likely. Installation of the new conveyance pipes will not impact the pool; therefore, it would be difficult to justify incorporating Frazer pool as part of the Harbor Brook project.
 

3. Comment:   Why does the Facilities Plan list creation of additional sanitary sewer lines for the City to operate and maintain as a disadvantage to sewer separation? The City's existing sewer system has problems as demonstrated by the recent sewer collapse in the Midland/Colvin area. (Salendria Mabrey from the Partnership for Onondaga Creek)
 

Response:   In each area where we undertake sewer separation, it will result in the City having two systems to operate and maintain—instead of one. Sewer separation will not eliminate the existing aging combined sewer pipe, but in most cases, it will be converted to use as a stormwater sewer. The newly installed pipes will be sanitary sewers for wastewater only. The City would own and therefore operate and maintain both the stormwater sewers (created in the former combined sewers) and the newly installed sanitary sewers. Because this increases City responsibilities, it is cited as one of the disadvantages to sewer separation in the Facilities Plan.
 

4.   The following comments were made by Aggie Lane, from the Partnership for Onondaga Creek:
 

a.   Speaker indicated concern that the County is spending $55 million to capture an additional 7% of the flow.
 

Response:   The Harbor Brook service area produces 564 MG of combined sanitary and stormwater volume on an average annual basis. The existing combined sewer system has capacity to convey 75% (425 MG) to Metro for treatment. The remaining 25% (139 MG) exceeds the capacity of the existing combined sewer system and is discharged to Harbor Brook from 18 combined sewer overflow points.
 
The County's proposed plan is designed to address the 139 MG of excess combined sewage volume that is discharged to Harbor Brook on an average annual basis. The County's plan provides capture of 138 MG within the two regional treatment facilities for either storage or treatment. The remaining 1 MG will be treated within the five floatable control facilities prior to discharge.
 
The County's plan provides for storage and/or treatment of 100% of the average annual combined sewage volume that is currently discharged without treatment to Harbor Brook.
 

b.   By putting both CSOs (078 & 018) that are in the retention basin through the proposed SUNY ESF wetlands treatment demonstration, there would only be less than 2 MG of remaining CSO volume to store at the Amy Street Site with underground storage.
 

Response:   The alternative of using a wetlands treatment system for CSOs 078 and 018 is addressed in section 3.2.2.5 of the draft Facilities Plan. Based on the volume of the CSOs, abatement of both of these CSOs through wetlands would require nearly all the available acreage within the existing retention basin (est. 35 acres). The primary function of the retention basin is to serve as stormwater retention and prevent downstream flooding. Construction of wetlands treatment requiring use of the entire basin could compromise its primary function.
 
Additionally, wetlands treatment alone would not adequately address floatables and bacteria. Some type of floatables removable before the wetlands treatment and some form of disinfection after treatment in the wetlands would still be needed to meet ACJ requirements.
 
The County has been working cooperatively with SUNY ESF on their proposed CSO wetland treatment demonstration project for a number of years (first meeting held 2001). Initially ESF had considered testing this technology in a small area along the brook near Grand Ave. and Wilbur. At the County's suggestion and with the willingness of SUNY ESF and ASLF, the project was relocated to the retention basin. Based on initial field work and sampling, ESF requested to use flow from CSO 018 rather than 078. There are no plans to have this demonstration project address the complete flow of both CSOs. The research scientists from SUNY ESF have informed us that sampling for further design work on the demonstration project on CSO 018 should be underway shortly.
 
The existing interceptor sewer between CSO 078 and CSO 009 is in need of replacement. Sections of the interceptor have undergone settlement resulting in reduced pipe capacity. Since the proposed pipe is a dual use (wet weather as well as dry weather) conveyance pipe, it will not be eliminated even if a portion or all of CSO 018 and 078 were put through wetlands treatment.
 

c.   Agree with the County plan to put in 4-5 floatables control in the middle basin, but suggest that CSO basins 005, 006, 006A and 007 should be separated at a cost of $9,000,000 instead of placing conveyance pipes connecting them to the Lower Basin RTF at a cost of $4,000,000. Then do underground storage for CSO 003 and 004 at the State Fair Blvd. site and put floatables control as planned on Emerson St. CSO 063.
 

Response:   Using figures contained in the draft facilities plan, the cost of sewer separation within the above mentioned basins and including CSO 008 (not mentioned above) would be $4.4 million. The cost of conveyance pipes along the Eureka route to the lower basin RTF would be $3.0 million. The revised route proposed for Park Ave. would reduce the conveyance costs by an estimated $830,000 resulting in a conveyance pipe cost of $2.2 million. Sewer separation would create more construction related disruption in this area and would introduce 100% of the polluted stormwater into Harbor Brook. The proposed RTF and conveyance system would capture over 80% of all stormwater as well as combined sewage. In fact, the existing combined sewer system is capturing 75% of the stormwater. We believe that this suggested approach would not only increase the project cost, but would cause greater disruption to the neighborhoods in these CSO basin areas and increase untreated stormwater discharges to Harbor Brook and Onondaga Lake.
 

d.   In the Facility Plan, the only underground storage option reviewed was at Metro with CSO being pumped there and brought in by conveyances.
 

Response:   This comment appears to reference Scenario 2 that looked at conveying all CSO flows to Metro, rehabilitating the existing tertiary tanks for storage and providing full treatment. The projected cost for this option is $125 million.
 
However, this is not the only storage option that was investigated. Scenario 9 contains a lower basin regional storage option for CSOs 003 and 004, Scenario 8 includes offline upstream storage with a vortex (as currently under construction at Midland) and Scenario 3 looks at storage at Metro for the lower and part of the middle basin CSOs. All of these scenarios have higher estimated costs than the County's recommended plan.
 

5. Comment:   Suggests that the County may want to provide some form of compensation to property owners and businesses for the inconvenience that construction will cause if the pipe does go down Park Avenue and State Fair Boulevard? (David Pilat, area resident)
 

Response:   Under NYS General Municipal Law, the County cannot provide direct financial compensation to property owners for inconvenience due to construction. However, the County can and will ensure that mitigation measures are implemented to reduce impacts during construction. These mitigation measures can include: requiring the contractors to utilize dust control systems, making sure that construction vehicles have proper muffler systems, maintaining access for local traffic, requiring that all excavated areas be covered to allow entry into driveways by the end of each work day and restoring and improving areas following construction. In addition as in other County projects within the City, the County will work with the Syracuse City School District concerning bus routes and pick ups and contact appropriate emergency service agencies if street detours are needed.
 
Residents will also be notified when construction will take place on their street and contact names and numbers will be supplied so that should issues arise, residents can bring any concerns to the County's immediate attention while construction is taking place.
 

Comment:   On behalf of fellow County Legislator Althea Chaplin, the speaker indicated that mitigation measures like those being discussed and looked into for the Harbor Brook project should also be remembered for the Midland project. She doesn't want Midland to be left out. The speaker asked for a listing of what mitigation measures people had suggested in the Harbor Brook project area. He indicated that he knew there had been a number of meetings where people from the west side had expressed their opinions on possible remediations and enhancements. (County Legislator Edward Ryan)
 

Response:   Commissioner Elander listed the following suggestions as received from meeting participants: sidewalks on Genesee Street in areas not receiving sidewalks under the "Automobile Row" improvements down to the underpass and down State Fair Boulevard. Sidewalks on Grand Ave. and Velasko Road where they do not currently exist. Funding assistance for necessary repairs to enable Frazer Pool to be re-opened. Acquisition of the property on the west corner of Grand Ave. and Delaware Street where there are currently two multi-family houses and a former bar to convert to use as a park, playfield, playground or similar recreational kind of area. Additionally, he pointed out the athletic practice fields already constructed by the County in the retention basin. The Commissioner noted that the county intends to do as much as we practically can within the monies made available through the County Legislature.
 

7. Question:   The County has said that with underground storage there would be times when capacity was exceeded and it would lead to untreated discharges. Is the County saying that with the vortex technology built for a one year design storm, there will be no untreated discharges? (Bruce Block)
 

Response:   There will not be any untreated discharges from the RTF. (Elander) For further clarification, as with any such storage and/or treatment facility to avoid flooding of the facility in catastrophic wet weather situations, there will be a diversion structure upstream of the treatment units of the RTF that will allow overflows in emergency situations only.

 

Concern:   Reconsider the use of Park Ave. for the installation of the conveyance line particularly near the Sacred Heart Basilica. Consider alternate routes. (Young & Kinane, Schimel, POC)
 
The Park Ave. to State Fair route is estimated to decrease the cost of the project by over $800,000, affects about the same number of residences as the Eureka St. route, reduces overall construction time in that area by reducing pipe length, reduces traffic impacts associated with constructing 200´ of piping in the east bound lane of W. Genesee Street and would eliminate the need to close Eureka Street during construction. Because Park Ave. is a wider street, it would not be necessary to close Park Ave. during construction on that street. These impacts were considered when the revised route was evaluated. Therefore for the reasons stated above, it was concluded that the proposed routing changes using Park Ave. result in fewer short-term construction impacts to residents than the Eureka route.
 
The County has further investigated two other alternate routes suggested at the hearing and in written comments including following the brook, and crossing W. Genesee St. before the intersection with State Fair Boulevard. Soil conditions along the brook discourage use of this alternative. Also because of soil conditions in this area, this alternative presents potential risks during construction associated with its nearness to Alan Beyer Auto Sales Showroom and the covered section of the brook.
 
The second suggested alternative investigated was routing the pipe down Park Ave and then crossing W. Genesee Street before State Fair Blvd. This alternative would result in use of another adjacent street—Dewey. Like Eureka Street, Dewey is narrow and construction on the street would necessitate full closure of that street during construction. Park Ave. and State Fair Boulevard are wider streets and would allow vehicular through traffic to continue during construction.
 
Following the above conclusions of further investigation, it was confirmed that the County's proposed revised alternate conveyance route using Park Ave to State Fair Blvd. would result in the greatest cost savings related to reductions in pipe length and the number of manhole structures needed at bends in the sewer, would provide the best access for future maintenance, would present the least disruption to the neighborhood and offers the best soil conditions thereby reducing risks to adjacent structures. For these reasons, the County reaffirms that the Park Ave. to State Fair Blvd. route for the conveyances is the recommended and preferred route.
 

Concern:   Concern about noise during construction. Requests construction not take place before 8 am. (Young & Kinane)
 
The County's contractor must adhere to permitted noise levels during construction and the construction sites will be monitored to document that levels are within required local noise restrictions. The timing of construction will be specified as part of the County's contract with the general contractor. Generally, construction is usually allowed during daylight hours to give the greatest amount of time for work per day and allow work to be completed as quickly as possible and areas disrupted for the fewest number of days. Area residents will be given names and numbers to call if there are concerns at the time of construction.
 

Concern:   Why wasn't the original plan of the Harbor Brook In-Water System implemented? (Schimel)
 
The proposed Harbor Brook In-Water System was fully evaluated during the Facilities Planning process. See Section 2 of the Facilities Plan. Section 2.2 describes the impediments to implementation of the in-water system and why it was ruled out as the CSO abatement plan for Harbor Brook.
 

Statement:   The County plan calls for 7 above ground sewage treatment plants (5 FCFs and 2 RTFs) within a mile of Metro. (Schimel)
 
All 5 of the floatable control facilities (FCFs) proposed would be below ground and not above ground. None of the facilities are full time sewage treatment facilities like the Metropolitan Treatment Plant which operates 24-7 and treats sewage in wet weather and dry weather conditions. The RTFs and the FCFs would only operate in wet weather conditions when combined sewers become full and discharge—this would be an estimated 50-60 times per year. The facilities plan does explore an option using Metro for storage and treatment of some of the combined sewer flow—but this was not found to be cost-effective.
 

Concern:   Disagreement with Recommended Plan as described in the Facilities Plan and suggest an alternate combination of technologies. (Schimel, POC and Heath)
 
The County's Recommended Plan includes: 2 RTFs and 5 FCFs. A total of 10 alternative scenarios were investigated by the County during the Facilities Planning process. These alternatives include combinations of 7 types of abatement technologies. All of the technologies evaluated within Sections 6 and 7 of the Facilities Plan meet the CSO control and upgrade program goals within the Amended Consent Judgment (ACJ). The County is recommending the most cost-effective alternative that meets all requirements of the ACJ and will meet State and Federal Clean Water regulations. The recommended plan would allow for the implementation of the SUNY ESF sponsored pilot project to establish sub-surface wetlands in the retention basin to evaluate wetlands treatment of combined sewer overflows. The project would require State DEC approval. To date, the design of the pilot project has not been completed. The Erie Boulevard Storage System has no additional capacity to take any of the Harbor Brook CSO flow as suggested by some commentors. Storage is not "relatively cheap to construct" (Schimel). Storage is second only to sewer separation in total construction costs. In response to concerns that sufficient nutrient removal will not take place under the County's plan, it is important to point out that the plan will meet the ACJ requirements for nutrient removal. . . . 
 

Concerns:   Indicated concerns about the human impacts of the County's proposed recommended plan: (Schimel, POC, Heath)
 
The FCFs proposed for the Harbor Brook area will not be net bag systems—the recommendation would be for mechanically cleaned screening systems. This type of FCF was previously installed to handle a CSO near Teall Ave. and Grant Blvd. on the City's north side and has proven to be an effective reliable system with no resultant complaints from neighborhood residents.
 
Hydrogen sulfide odors currently result from existing overflows that discharge untreated into Harbor Brook. By capturing the overflows and transporting the flow to the storage and treatment facilities planned for the upper and lower basins, these odors will be eliminated as the discharges are eliminated and the new storage and treatment facilities will be fully enclosed and will have state-of-the-art odor control systems using activated carbon filters.
 
The proposed regional storage and treatment facilities would use liquid chlorine for disinfection of the treated effluent during those 16—20 times a year when each of the facilities would receive enough flow to necessitate a treated discharge. The chlorine used (sodium hypochlorite) is similar to the chlorine bleach used in homes, businesses and medical facilities for cleaning and disinfection. Chlorine is used throughout the country at wastewater and drinking water facilities to kill harmful bacteria. Chlorine is used to kill bacteria in swimming pools in backyards, municipal parks and in schools such as Fowler High School.
 
Use of chlorine is an accepted disinfection method for combined sewer overflows by the State Department of Environmental Conservation, the Department of Health and the Federal Environmental Protection Agency. The chlorine residuals from the proposed RTF will be lower than the other public uses cited above due to the addition of a dechlorination step prior to discharge.
 
The County has eliminated its use of chlorine treatment and replaced it with ultraviolet disinfection at Metropolitan Treatment Plant on a 24-7 basis for 100% of the dry weather flow and a portion of the wet weather flow. An average of 70 million gallons a day of municipal wastewater is now treated by the County at Metro through ultraviolet lamps. The County researched the possibilities of use of ultraviolet disinfection for CSO facilities and found it is not effective in the treatment of combined sewer overflows due to the levels of suspended solids and it is not cost-effective due to the infrequent intermittent use with CSOs. However, disinfection through use of chlorine is safe and effective on CSOs and these facilities will only use the chlorine for disinfection about 16—20 times per year.
 
The elimination of untreated combined sewer overflows into a brook located within a block of Delaware Academy and thereby mitigating odors and health concerns in this uncovered area of the brook is a beneficial change. There will be no negative impacts to Delaware School or its students.
 

Concern:   Encourage use of wetlands treatment for CSO in retention basin and thereby reduce size and need for RTF at Amy Street. (Schimel, POC, J. Heath)
 
The County has been communicating with SUNY ESF and ASLF since 2001 about the proposed wetland treatment pilot project to test the effectiveness of wetlands treatment on combined sewer overflows. The County suggested the County-owned retention basin for implementation of the demonstration project and has supported the allocation of federal and state funding for the project. In addition, the County's Department of Water Environment Protection laboratory is running the analysis on the initial field samples collected by SUNY ESF staff for the design of the project. The wetlands project was not seen as a replacement to the Facilities Plan, but has been left as one possible augmentation to the Plan. Due to the deteriorated condition of the existing Harbor Brook Interceptor sewer line in the retention basin area, the pipeline would need to be replaced from Velasko Road to Fowler High School to handle dry weather flow alone. . . . 
 

Concern:   Appropriate archeological investigations need to be done on the revised pipe routes and a representative of the Onondaga Nation should be present. (J. Heath)
 

Response:   All archeological field work carried out by the consultant—Hartgen Archeological Associates, Inc. for the County on this project has been done with the presence and participation of Mr. Tony Gonyea of the Onondaga Nation as per the County's directive and paid for through County funds. Should additional archeological work for the revised routes be necessary as determined by our archeological subconsultants, Mr. Gonyea will be contacted for his continued participation.
 

Concern:   SPDES permit for Metro must reflect this project. (J. Heath)
 

Response:   The State Department of Environmental Conservation is responsible for administration of the SPDES program and is fully involved and aware of the ACJ program projects including Harbor Brook. All questions about the SPDES permit and modifications to such should be addressed to the NYSDEC.
 

Concern:   Believes a full EIS is required for this project due to issues he raises. (J. Heath)
 

Response:   The draft EID concludes that no detrimental impacts that cannot be mitigated have been identified as a result of the proposed project. Other than short-term impacts related to construction, no significant adverse environmental impacts have been identified during the facilities planning and environmental review process. In addition, the County did not receive substantive comments during the 30 day comment periods following the public meetings and the public hearing that identify potentially significant adverse environmental impacts that were not previously identified and assessed or were inadequately assessed or show a substantial deficiency in the proposed mitigation measures. Nor specifically do any of the following issues raised by Mr. Heath constitute any such unaddressed issues or impacts:

• Environmental impacts of the proposed piping relocation were not assessed . . .  In the Lower basin, the County did assess the impacts of the revised route and found impacts to be less than the previous Eureka St. route. See page 6.
   
  In addition, in response to questions and suggestions from the public, following the hearing, the County looked into two other possible alternative routes both of which had more potential impacts than the Park Ave.- State Fair Blvd.route.
   
  In the Upper Basin, the re-routing of the pipe moves the pipe only one block over and reduces the length of pipe to be installed; thereby resulting in a shorter construction period in this area, reduced costs and most importantly, reduces the number of residences impacted during construction.
• EID does not evaluate environmental effects of disinfection by-products Disinfection of wastewater by use of chlorine followed by dechlorination through the use of sodium bisulfate is an approved method of disinfection and dechlorination under both state and federal water quality regulations. One purpose of the dechlorination process is to reduce the production of chlorine by-products. The residual level of chlorine by-products in the effluent discharged from the regional storage and treatment facilities will be well within safe levels. The discharge will go into the receiving stream via a discharge pipe.
• Environmental justice Response: Following completion of the draft EID, the County has determined that this project will result in no significant adverse environmental impacts. Any potential impacts will be temporary and short-term related to construction. These construction impacts will be mitigated as much as practicable and in accordance with applicable local and state ordinances for noise, dust, street closures, etc. These temporary impacts will be offset not only by the County's mitigation measures but in addition, by the overall environmental benefits brought about by this project in the closure of 6 CSOs and mitigation of 12 CSOs that currently discharge into Harbor Brook as it runs through residential areas on the City's west side. This project will reduce odors and health concerns to the area caused by these overflows particularly in the stretches of the brook that are uncovered in both the upper and lower basin areas.
   
  In addition, Section 3.1.5 of the draft Environmental Information Document shows that the demographics and economics of the Harbor Brook area are comparable to the demographics and economics of the City of Syracuse as a whole. As such, there is no racial, ethnic or socioeconomic group that would bear a disproportionate share of the project impacts.
   
  Through public participation activities undertaken by the County since 2000, the County has sought input from the area residents on possible mitigation measures and community enhancements that could be carried out by the County to benefit the community. These include installation of sidewalks where none currently exist thereby improving the safety of the area. See list of other possible related improvements above.

 

Concern:   The ACJ does not preclude redesign of this project. It is critical that Onondaga County carefully assess its actions to ensure that the ACJ's goal can be achieved. (J. Heath)
 

Response:   The County has planned, developed and constructed all of its ACJ projects to ensure they meet the ACJ goals. Carrying an estimated total cost at this time (1/06) of over $458 million, all work that the County is required to perform under the ACJ is subject to the review and approval of the State DEC prior to initiation of such work. (See ACJ page 19—Transmission, Review and Approval of submittals). The State DEC is equally concerned that all ACJ goals are met as a result of the implementation of the ACJ as are the other parties to the ACJ including the Atlantic States Legal Foundation, and the State Attorney General's office. In addition, although not signatory to the ACJ, the US Environmental Protection Agency continues to be actively informed and involved in implementation of the ACJ from a regulatory and funding perspective.
 

Correction/clarification:   A correction to pg. 6 of Mr. Heath's letter, where he states that "already significant changes have occurred since the ACJ was adopted . . . remediation of associated subsites is proceeding apace, including IRMs for CSOs underlying I-690." These discharges are non-municipal storm sewers conveying drainage from an industrial site and are totally unrelated to the County's sewer system.
 

Concern/Suggestion:   Proposed alternative to the County's recommended Facilities Plan that includes the following components—a subsurface wetlands treatment system for CSOs 078 and 018; a regional underground storage tank located at Amy Street for CSOs 017, 016, 015 and 014; 4 floatables control facilities in the middle basin; 3 sewer separation areas, underground storage for CSOs 004 and 003 at the State Fair Boulevard site, an FCF for CSO 063 and upgrading of a portion of the interceptor sewer. Total projected cost of $44.62 million. (Aggie Lane for POC)
 

Response:   We appreciate the interest and time given by POC to propose this alternate plan; however we have a number of issues with the plan and the estimated costs attached to that plan.

• As addressed above, the County has been supportive of the planning and implementation of a pilot demonstration project to test the effectiveness of a sub-surface wetland treatment system on CSO 018 in the retention basin along Grand Ave. However, this is a small-scale pilot project only. It is estimated that a wetlands treatment system designed to handle flows from CSOs 078 and 018 would require 34 acres. The retention basin itself is 35 acres and its primary function is stormwater retention to prevent downstream flooding. This primary function could be compromised by use as a CSO treatment system. In addition, to meet ACJ requirements, the wetlands treatment would need to be augmented by floatables removal and disinfection.
• One of the benefits of using subsurface wetlands to treat CSOs 078 and 018 cited in the POC proposal is elimination of the construction to install conveyance pipelines in the upper basin area. Installation of this pipeline would still need to take place. As cited in the Facility Plan, the Harbor Brook Interceptor sewer is deteriorated and needs to be replaced. This replacement is planned for the length of the interceptor from Velasko Road along the brook to the Amy Street facility and past the facility to Fayette Street. In addition, CSO 014-017 would need to be brought by conveyances to the interceptor even if the Amy Street facility was only to be used for storage for those CSOs as proposed by POC.
• POC agrees with the County Plan to construct Five Floatables Control Facilities for CSOs 013, 011, 010, 009 and 063. However, proposes to sewer-separate CSO areas 007, 006A and 005 instead of bringing them into the lower basin regional treatment and storage facility as proposed by the County. Additionally, POC proposes to eliminate CSO 006 and 008 through the Pump station upgrade described in four of the scenarios reviewed under the County plan. Thereby, reducing conveyances and the need for a regional treatment and storage facility as called for in the County's plan. The County, in analyzing the 10 scenarios/ combination of alternative technologies in the Facility Plan, determined that the most cost-effective and environmentally sound plan that will meet the ACJ requirements is the recommended Scenario 5a. This plan does not include sewer separation that is costly and would be much more disruptive during construction in the residential and business areas of the Lower Basin including areas along Park Ave., Eureka, Richmond, Sackett, Geddes and West Genesee Streets. This sewer separation would disrupt considerably more residences and businesses than the conveyance line proposed by the County.
• There is no data to support the POC's statement that their proposal would be "cheaper to maintain" than the County's proposal. The major difference is the use of regional storage in lieu of RTFs. Storage would still require pumps to move the stored CSO to Metro as would the RTFs. Storage tanks will also require cleaning, odor control and other maintenance as the RTFs. The sewer separation in POC's plan would require maintenance of the new sewer lines just as maintenance would be required for the new conveyance line in the County's plan.

The following is a listing of disagreements with POC's cost estimates:

• The county estimate for a storage tank for CSOs 003 and 004 in the lower basin of Harbor Brook is included in Scenario 9 and is listed at an estimated cost of $26.3 million including a 25% contingency and 25% engineering, legal and administrative factors. Using this cost would increase the POC's proposed plan by $6.4 million.
• POC's estimate for conveyances for CSO 003 and 004 is $1 million. The County's estimate for the same conveyances is $3.45 million including the 25% contingency and 25% engineering, legal and administrative costs (ELA).
• By adding the 25% contingency and 25% ELA, the estimated cost of POC's subsurface wetlands treatment increases to $2.34 million.
• Conveyances would still be needed for the Upper Basin RTF and the Harbor Brook Interceptor sewer line would still need replacement as called for in both the POC and County plan. However, the POC plan estimated that cost at $2.34 million whereas the cost of the entire length of interceptor replaced would be $2.34 plus $8.9 m ($5.7m including 25% contingency and 25% ELA) that would bring the estimated cost to $11.24 million.

In summary, the POC proposal would cost $63.2 million as compared to the County's proposal for $55.2 million.
 
The POC proposal would:

• Be more disruptive of the neighborhoods where
sewer separation is proposed vs. the County's planned installation of a conveyance line
• Would cost substantially more
• Would increase overall construction time
• Would be predicated on the successful operation
of a technology (subsurface wetlands treatment) that would not be implementable on the site proposed, has yet to be implemented on a pilot-scale at the site and as yet, is not an established proven method for CSO treatment.

The County's recommended plan will enhance the neighborhoods around Harbor Brook by eliminating the impacts of the 18 CSOs along Harbor Brook through sound accepted approvable technologies that will meet the ACJ requirements and goals. The County is committed to continuing to work with area residents to ensure areas are restored to better condition than before the County project and mitigation measures are adopted and amenities are constructed as discussed.