October 23, 2015

To: Tina Quagliato, City of Springfield

From: Andrew Fisk, CRC

Re: Phase II HUD National Disaster Resiliency Competition

via electronic mail

Dear Tina,

Please accept the following comments on behalf of the Connecticut River Watershed Council.  CRC appreciates the opportunity to provide comments on the draft proposal and is very supportive of the City’s efforts to improve the climate resiliency, economic vitality, and quality of life in Springfield.  We are supportive of many of the ideas in the proposal and appreciate the significant amount of work that has gone into thinking through this proposal.

As we have noted previously however we continue to have concerns about the still apparent disconnect between this proposal and the current version of the Springfield Water & Sewer Commission’s (SWSC) long-term control plan for the abatement of combined sewer overflows.  In short, while the HUD NDRC proposal does not make specific reference to design storms, recurrence intervals, or precipitation data it appears from the narrative that the proposal is following the guidance and expertise of the Northeast Regional Climate Center to determine the hydrologic, hydraulic, and engineering specifications for the various projects to be funded by HUD.

This is not the case with the SSWC’s combined sewer overflow abatement plan. This plan is based on outdated precipitation data, has no anticipation of climate change over the 30-year life of the plan, uses a design storm that is smaller than typical, and an annual discharge frequency that is higher compared to other plans in the state and region.  This plan is wholly out of tune with climate adaptation and resiliency policies.

It appears that this deficiency is a pending issue with the Commonwealth of Massachusetts as well, given the wording of the Secretary’s Certificate when the Final CSO Long-term Control Plan/Environmental Impact Report went through the MEPA process in November, 2014.  An excerpt from the Certificate reads:

“The adaptive management framework provides an opportunity to continue updating and calibrating the model.  In addition, it provides an opportunity to consider long-term changes in precipitation frequency and severity that are associated with climate change.  The National Weather Service has published draft precipitation frequency updates for Massachusetts (Atlas 14 Volume 10), with an expected publication date of September 2015 that could be used in subsequent modeling and evaluation of alternatives.  The proposed projects will reduce CSO discharge and improve water quality; however, increases in the number and intensity of storms could erode the effectiveness of the LTCP. I note the concerns expressed by the CT River Watershed Council regarding the use of the typical design year (1976).  I expect that the MassDEP and the Commission will consider whether reliable new data sources can be incorporated into subsequent analysis associated with re-evaluation of the effectiveness of constructed and proposed projects.”

This data was in fact updated and is available on the National Weather Service’s Precipitation Data Frequency Server.  We have had no response to this issue from SWSC, EOEEA or the DEP at this point.

We are concerned that the efforts of the City to become climate resilient are being undermined by the outdated and insufficient standards in the SWSC’s combined sewer overflow abatement plan.  This HUD proposal is an opportunity for two distinct units of government to develop much stronger consistency in their planning and so realize much better and more robust resiliency targets.  And given that the various combined sewer overflow projects are being cited in the proposal as leveraging funds, it is important to ensure these projects are in fact designed to comparable resiliency standards as to what the City is proposing.

We would encourage HUD in its review of this proposal to ensure that the SWSC’s plans are revised to incorporate the best available precipitation and storm data in the refinement of its ongoing combined sewer overflow planning and implementation.  As well it would be useful for the HUD proposal to provide some specificity as to what data and design it will be using to design the various projects included in the proposal.  Including this in the HUD proposal is an important piece of information to gauge the outcomes of the various proposed projects.

In regard to the proposed storm water reduction projects, we think it would be beneficial to provide some specific projections on how the tree planting and tree box filters will affect the amount of directly connected impervious area within the City and the project areas.  We assume that 24 tree box filters will treat approximately 6 acres of impervious area, but that is not stated in the application.  The proposal notes the City overall has 34% directly connected impervious area.  How much is in the project areas and how much will be disconnected as a result of the storm water projects?  We assume that this work will become part of the implementation for the next MS4 permit that is expected to be issued in 2016 by the EPA.  We also encourage the City to contemplate a variety of effective low impact development (LID) projects to reduce storm water volumes, rather than only the tree box filters mentioned in the draft proposal.

The Phase II proposal frequently cites CSOs as an issue that is affecting health and quality of life in Springfield.  CRC agrees.  CRC staff see families with young children picnicking along the banks of the Connecticut River next to CSO outfall pipes.  Clearly, eliminating raw sewage discharges from these pipes would have a positive impact on the residents of Springfield, and also improve economic vitality in the urban area.  The Phase II proposal could be made perhaps stronger by citing current statistics about the volumes of CSO discharges that the city is facing.  For example, in 2013, Springfield’s 19 overflow pipes discharged a total of 434 times and the estimated volume of untreated CSO discharge was 423 million gallons for the year.  This far exceeds Holyoke’s discharge of 144 million gallons and Chicopee’s 157 gallons that year.

We highly recommend that Springfield consider adopting an increasing block rate structure for water billing that is recommended by the MA Conservation Standards which may help finance water infrastructure as well as create an incentive for water conservation.

Additional thoughts you may want to weave into your proposal:

  • Water conservation saves pumping and treatment costs and energy .  It also can help reduce the amount of water going to a treatment plant during a storm, thus reducing CSO overflow volumes.
  • Using storm water onsite for irrigation/lawn watering is highly cost effective for both the landowner and the community, and can also help recharge aquifers while avoiding the energy and other costs associated with providing potable water for irrigation purposes (or private onsite wells which also require energy for pumping)
  • Reducing infiltration and inflow (I/I) and CSOs reduces wastewater treatment costs and associated energy consumption
  • LID retrofits e.g. tree planting can also have significant energy savings for adjacent buildings in terms of shade and windbreaks, while also increasing property values and quality of life.

We appreciate that the Commission’s combined sewer overflow plan has a very significant price tag and this runs hard up against the many other projects that a City of Springfield (and its surrounding service center) must undertake.  However the better response is not to try to reduce costs by designing the project down in terms of standards (which is just going to push off the problem to more expensive future dollars), but to design to the best available information with reasonable climate, cost, and revenue projections over the life of the plan.  And go slower with the tradeoff of better results.

The roles and responsibilities of the storm water and CSO projects should be well laid out between the City of Springfield DPW and the SWSC; because the agencies are different entities, sometimes they don’t work in full coordination with one another.  This has become apparent to us on numerous occasions and we would hope that this application process would be an opportunity to more fully integrate the combined sewer overflow, treatment plant upgrades, and the municipal storm water program.

I have attached a copy of the EOEEA Secretary’s Certificate on the Final Environmental Impact Report which includes CRC’s comments as attachment.

I am happy to discuss any of this further if that is useful in the preparation of the final proposal.  Again, thanks for the opportunity to comment.  We appreciate the significant amount of work that this proposal has required and agree it is an important opportunity for the City and the region.

We look forward to your reply.


Andrew Fisk

Executive Director