chapter 11: 2020 facilities plan implementation

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2020 Facilities Plan Facilities Plan Report 11-1 Chapter 11: 2020 Facilities Plan Implementation 11.1 Introduction This chapter discusses the implementation of facilities, programs, operational improvements and policies (FPOPs) recommended in Chapter 10, Recommended 2020 Facilities Plan. Included within this chapter are the following: An initial implementation schedule for the recommended FPOPs A financial plan with funding recommendations including the estimated financial impact of the proposed improvements on system users A view to future implementation activities combining the 2020 Facilities Plan (2020 FP) recommendations, the Southeastern Wisconsin Regional Planning Commission (SEWRPC) Regional Water Quality Management Plan Update (RWQMPU) recommendations and a Milwaukee regional partnership (Section 11.14) A framework for development of the tracking mechanisms that will be required throughout the implementation process (Section 11.15) The discussion of combined implementation of the 2020 FP and the RWQMPU through a regional partnership in Section 11.14 is built upon the scientific data produced in the Water Quality Initiative (WQI) planning effort, including the water quality modeling evaluations of the screening and preliminary alternatives, which led to the key findings below. a These key water quality impact findings directed the development of the Recommended 2020 Facilities Plan: 1) The region’s surface waters generally are achieving water quality standards for most pollutants. 2) Nonpoint pollution (e.g., stormwater runoff) is the largest source of fecal coliform bacteria, which is the pollutant of primary concern. 3) Reducing (or even eliminating) sanitary sewer overflows (SSOs) will result in little or no water quality improvement on an annual basis. 4) The Milwaukee area can achieve significant improvements to water quality only through regional implementation of extensive measures to reduce pollution from nonpoint sources as recommended in the RWQMPU. b As discussed in Chapter 10, Recommended 2020 Facilities Plan, the following conclusions that were derived from the key water quality findings directed the development of the Recommended Plan: 1) The primary focus of the 2020 FP must be to develop a Recommended Plan that meets the regulatory requirements regarding Milwaukee Metropolitan Sewerage District’s (MMSD’s) point sources (e.g., SSOs, combined sewer overflows (CSOs), wastewater treatment plant effluent discharges). The Recommended Plan strives to meet all a See discussion in Section 10.1 of Chapter 10 of the Facilities Plan Report and the detailed water quality data presented in Facilities Plan Report Appendices 9B, 9C and 9E. b See SEWRPC Planning Report No. 50, A Regional Water Quality Management Plan Update for the Greater Milwaukee Watersheds, Chapter X for further discussion.

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11-1
11.1 Introduction This chapter discusses the implementation of facilities, programs, operational improvements and policies (FPOPs) recommended in Chapter 10, Recommended 2020 Facilities Plan. Included within this chapter are the following:
♦ An initial implementation schedule for the recommended FPOPs
♦ A financial plan with funding recommendations including the estimated financial impact of the proposed improvements on system users
♦ A view to future implementation activities combining the 2020 Facilities Plan (2020 FP) recommendations, the Southeastern Wisconsin Regional Planning Commission (SEWRPC) Regional Water Quality Management Plan Update (RWQMPU) recommendations and a Milwaukee regional partnership (Section 11.14)
♦ A framework for development of the tracking mechanisms that will be required throughout the implementation process (Section 11.15)
The discussion of combined implementation of the 2020 FP and the RWQMPU through a regional partnership in Section 11.14 is built upon the scientific data produced in the Water Quality Initiative (WQI) planning effort, including the water quality modeling evaluations of the screening and preliminary alternatives, which led to the key findings below.a These key water quality impact findings directed the development of the Recommended 2020 Facilities Plan:
1) The region’s surface waters generally are achieving water quality standards for most pollutants.
2) Nonpoint pollution (e.g., stormwater runoff) is the largest source of fecal coliform bacteria, which is the pollutant of primary concern.
3) Reducing (or even eliminating) sanitary sewer overflows (SSOs) will result in little or no water quality improvement on an annual basis.
4) The Milwaukee area can achieve significant improvements to water quality only through regional implementation of extensive measures to reduce pollution from nonpoint sources as recommended in the RWQMPU.b
As discussed in Chapter 10, Recommended 2020 Facilities Plan, the following conclusions that were derived from the key water quality findings directed the development of the Recommended Plan:
1) The primary focus of the 2020 FP must be to develop a Recommended Plan that meets the regulatory requirements regarding Milwaukee Metropolitan Sewerage District’s (MMSD’s) point sources (e.g., SSOs, combined sewer overflows (CSOs), wastewater treatment plant effluent discharges). The Recommended Plan strives to meet all
a See discussion in Section 10.1 of Chapter 10 of the Facilities Plan Report and the detailed water quality data presented in Facilities Plan Report Appendices 9B, 9C and 9E. b See SEWRPC Planning Report No. 50, A Regional Water Quality Management Plan Update for the Greater Milwaukee Watersheds, Chapter X for further discussion.
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regulatory requirements in the most cost effective manner, and achieve the resulting water quality improvement.
2) As the result of this planning process, a minimum 5-year level of protection (LOP) for SSO control under 2020 Baseline population and land use conditions is determined to be consistent with state and federal requirements. This minimum 5-year SSO LOP will be achieved for MMSD’s conveyance system; however, a 7-year SSO LOP is projected to be achieved for tunnel-related SSOs.
3) The satellite municipalities must continue efforts to maintain infiltration and inflow (I/I) at year 2000 levels (within existing development).c An I/I allowance, based upon the year 2000 I/I levels from newer sewersheds, is provided to accommodate future growth. The municipalities will also need to comply with MMSD I/I standards adopted under revisions to MMSD Rules and Regulations (Chapter 3 revisions), which will require poorly performing sewers to be improved.
4) Detailed recommendations for nonpoint control measures are presented by SEWRPC in its RWQMPU rather than in the 2020 FP because MMSD does not have the authority to direct the implementation of regional nonpoint control measures. The RWQMPU concurs with the recommendations of the 2020 FP and recommends the additional MMSD facilities needed to address SSOs, but also includes regional recommendations regarding the reduction of nonpoint stormwater pollution.
The coordinated implementation of the 2020 FP and the RWQMPU using the “watershed approach” is further discussed in Section 11.14. Implementation of the 2020 FP recommendations will cost effectively achieve the publicly-inspired goal of complying with regulatory requirements. Implementation of the RWQMPU recommendations will cost effectively achieve the greatest water quality improvement.
11.2 MMSD Capital Project Implementation Schedules Two alternate capital project implementation schedules are presented. Figure 11-1 illustrates the Adaptive Implementation Schedule (AIS), which recognizes that the population and land use growth may not occur as aggressively as projected in Chapter 5, Watershed Assessment - Future Condition. Figure 11-2 presents the Full Implementation Schedule (FIS), which assumes population and land use growth occur fully as projected. The costs for the AIS and FIS are also summarized in Table 11-1. The associated capital financing plans to finance the two implementation schedules from 2008 through 2020 are described in Section 11.13.
c Maintenance of I/I at current levels applies to existing development. There is an I/I allowance assumed in the 2020 FP for future development.
FIGURE 11-1
5/8/07 FP_11.0001.07.05.08.cdr
FIGURE 11-2
5/8/07 FP_11.0002.07.05.08.cdr
$25,000,000 25,000,000
J_WW_1 Inline Storage System Pump Station Capacity 5 Expansion 50,000,000 108,000,000
C_WW_1 Flow Monitoring and Rain Gauge System Improvements 6
31,000,000 37,400,000
300,000 300,000
1,500,000 1,500,000
0 97,000,000
Subtotal $122,800,000 $339,300,000
C_2020_1 Preliminary Engineering Study and Construction
of Additional South Shore Force Main 10 23,300,000 23,300,000
J_2020_2 JIWWTP Aeration System Evaluation and Construction 10
15,300,000 15,300,000
800,000 800,000
3,400,000 3,400,000
J_Bio_1 JIWWTP Dewatering and Drying Facility Upgrades 115,000,000 115,000,000
P_Bio_1 Interplant Sludge Pumping and Pipeline Improvements 3,000,000 3,000,000
S_Bio_3 New Gravity Belt Thickeners at SSWWTP
for Digested Sludge Thickening 2,225,000 2,225,000
S_Bio_1 New Gravity Belt Thickeners at SSWWTP
for Waste Activated Sludge Thickening 7,700,000 7,700,000
S_Bio_4 SSWWTP Plate & Frame Press Upgrade 5,000,000 5,000,000
J_Bio_2 JIWWTP New Biosolids/Energy System 20,000,000 20,000,000
S_Bio_2 SSWWTP Digester Rehabilitation & Expansion 0 117,000,000
Subtotal $153,225,000 $270,225,000
Total $318,825,000 $652,325,000
TABLE 11-1 SHEET 1 OF 2
SUMMARY OF COSTS FOR BOTH ADAPTIVE AND FULL IMPLEMENTATION SCHEDULES 2020 FACILITIES PLAN
FP_11.T001.07.05.08.cdr5/8/07
KK = Kinnickinnic
1) Assumed funding level based on Adaptive Implementation Schedule (AIS). In addition to the newly identified projects present in Table
10-1, of Facilities Plan Report Chapter 10, several additional existing projects have been incorporated into the implementation schedule
as noted in remaining footnotes.
2) Assumed funding level based on Full Implementation Schedule (FIS). In addition to the newly identified projects present in Table 10-1, of
Facilities Plan Report Chapter 10, several additional existing projects have been incorporated into the implementation schedule as noted
in remaining footnotes.
3) The FIS includes all projects that are identified as new costs from the 2020 FP (as presented in Table 10-1 of Facilities Plan Report Chapter 10) and some “existing facility” upgrades (as presented in Table 10-2 of Facilities Plan Report Chapter 10). Therefore, a direct
correlation between Table 10-1 (and Table ES-1) and the FIS cannot be made.
4) Cost estimate from Table 10-2 of Facilities Plan Report Chapter 10. This is an “existing facility” upgrade cost estimate; not a new cost
from the 2020 FP recommendations.
5) Cost estimate for FIS taken from Table 10-1 of Facilities Plan Report Chapter 10. Cost estimate for AIS assumes approximately 50%
spent on facilities prior to 2020 and the remainder after 2020.
6) Cost estimate for the AIS taken from approximate midpoint of range ($25-37 million) given in Table 10-1 of Facilities Plan Report Chapter
10. Assume this also includes the $0.4 million for Preliminary Engineering. Cost estimate for the FIS taken from the high range of Table
10-1 of Facilities Plan Report Chapter 10 plus $0.4 million for Preliminary Engineering ($37 +$ 0.4 =$37.4).
7) Cost estimate from Table 10-1 of Facilities Plan Report Chapter 10.
8) Cost estimate for FIS taken from low end of range ($97-152 million) in Table 10-1 of Facilities Plan Report Chapter 10. Cost estimate for
AIS assumes no facilities built prior to 2020 because they are not required due to slower growth.
9) One of the 2020 FP recommendations is to complete a project specific facilities plan to evaluate service to the southwestern part of
Franklin and portions of Muskego and New Berlin as an alternative to conveyance project number 13 (see corresponding footnote on
Table 11-2). The financing plans include a preliminary cost estimate of MMSD’s share of this potential project if it is shown to be
necessary prior to 2020. Cost estimate for FIS taken from Table 10-1 of Facilities Plan Report Chapter 10, which assumes all MIS
projects are built except $15 million was included for the Ryan Road Creek Interceptor (C02006) instead of the $4.7 million for the
Franklin/Muskego MIS ($59.8-$4.7 +$15= $70.1). If the Ryan Road Creek Interceptor is constructed, the Franklin/Muskego MIS will not
be required. See also Table 11-2 of this chapter. Cost estimate for AIS assumes approximately $15 million for the Ryan Creek
Interceptor.
10) Cost estimate from Table 10-1 of Facilities Plan Report Chapter 10, and include a $0.3 million for Preliminary Engineering.
11) Cost estimate from Table 10-7 of Facilities Plan Report Chapter 10.
12) Cost estimate from Table 10-6 of Facilities Plan Report Chapter 10. FIS assumes all costs to be spent by 2020. AIS assumes there will
be no expansion of the SSWWTP digesters.
TABLE 11-1 SHEET 2 OF 2
SUMMARY OF COSTS FOR BOTH ADAPTIVE AND FULL IMPLEMENTATION SCHEDULES 2020 FACILITIES PLAN
FP_11.T001.07.05.08.cdr5/8/07
11-7
It is important to note that the implementation schedules (AIS and FIS) include all the newly recommended capital projects presented in Table 10-1 of Chapter 10, Recommended 2020 Facilities Plan and some selected existing capital projects from Table 10-2 of Chapter 10. However, they do not include all the 2020 recommended FPOPs presented in Chapter 10.d Recommended FPOPs that consist of entirely operation and maintenance (O&M) costs are not included in the AIS and FIS.e The capital financing plan discussed in Section 11.13, however, essentially incorporates all the capital 2020 recommended FPOPs.f
As described in Chapter 10, Recommended 2020 Facilities Plan, the total projected capital cost to implement the 2020 FP recommendations for capital improvements necessary if the 2020 Baseline population and land use occurs, is estimated to range from $481 to $646 million (2007 dollars at a projected Engineering News Record (ENR) Construction Cost Index (CSI) of 10,000). This cost estimate is based upon the projected 2020 population and land use conditions as discussed in Chapter 5, Watershed Assessment - Future Condition.
The biosolids cost, which is based on an interim plan, will be revised once a final biosolids plan is completed. The approximate $60 million related to the conveyance system assumes population and land use under the 2020 Baseline assumptions. The approximate $205 to $260 million for treatment systems assumes 2020 conditions under the Revised 2020 Baseline assumptions. It is recognized that the 2020 Baseline conditions, which include a 17% increase in MMSD sewer service area population by 2020 is optimistic, and may occur in some municipalities that the MMSD serves, but will not occur in all service areas. Many of the capital needs identified in Chapter 10, Recommended 2020 Facilities Plan, are based upon the population growth assumptions in the 2020 Baseline as discussed in Chapter 5, Watershed Assessment – Future Condition. These population and growth assumptions were used for conveyance analysis in the Conveyance Report. Thus, the conveyance system planning took this overall increase into account, while the storage and treatment systems assumed a more modest population growth of about 4%.
Because of these considerations, this recommended Implementation Plan for the 2020 FP is based upon a more realistic adaptive approach that assumes that the large population increase of 17% in the 2020 Baseline assumption does not fully occur within the planning period. As a result, some of the projects noted in Chapter 10, Recommended 2020 Facilities Plan, are not required to be constructed by 2020. Therefore, the AIS presented in Figure 11-1 includes expenditures during the planning period of approximately $319 million of the $481 to $646 million estimated in the recommended 2020 FP.
It is likely that the MMSD 2020 FP will be amended over time as new information is developed and the implementation of a watershed based approach matures. The AIS is meant to be monitored and revised periodically as water quality, population growth and land use changes occur. The MMSD will monitor population growth, land use changes, regulations, facilities conditions, wet weather peak flows and other drivers to assess the need for recommended projects (and the associated expenditures) necessitated by growth. When determining which d Table 10-1 Summary of 2020 FP Recommendations-New FPOPs Identified by 2020 FP; Table 10-2- Summary of Existing FPOPs Recommended by 2020 FP To Be Continued e For example: labor costs to initiate the Wet Weather Peak Flow Management Plan f The Full Implementation Financing Plan (FIF Plan) incorporates all FPOPs. The Adaptive Implementation Financing Plan (AIF Plan) essentially incorporates all FPOPs, but some are financed at a lower financing rate to the year 2020.
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projects will be selected for implementation and the schedule for their implementation, MMSD will prioritize the projects based on need while balancing expenditures within the cash flow objectives of MMSD’s financial plan.g
A significant milestone in this adaptive process will be review of the 2010 U.S. Census. This census data will be one of the initial indications of whether or not the growth projected for 2020 is actually occurring. The 2010 census data, which will be available in 2011, will coincide with the completion of many MMSD preliminary engineering analyses. The combination of the information from the preliminary engineering analyses and the new population data will allow MMSD to assess the AIS in 2011 and make changes to the remaining years as a part of the MMSD’s annual financial planning in 2011. While the implementation activities for the period of 2008 through 2011 will likely take place according to the schedule presented, activities after 2011 should be viewed as subject to change and refinement. This adaptive schedule will be monitored closely each year and revised as necessary, but most significant revisions are not expected to occur until 2011 or later, which would result in changes to the adaptive schedule in 2012 and beyond.
Figure 11-1 shows the adaptive implementation of the Recommended Plan, considering the factors noted above. The costs that have been considered in the AIS are based upon the facilities plan level estimates, which have a range of accuracy from +50% to –30%. All identified project costs will be refined over time as preliminary engineering analysis is completed. Thus, the final total projected cost could vary significantly from the estimates in the summary schedule.
The AIS presents the implementation of essential 2020 FP recommendations by 2020. Other recommendations that are dependent upon population growth or additional analysis are planned for implementation in the time frame of 2013 to 2020 or delayed past 2020 based upon the assumption that the projected large population growth for 2020 does not occur. This adaptive implementation approach allows for the use of a financial plan that is essentially in line with current MMSD financial objectives as discussed in Section 11.13.
The AIS will need to be revised if the full projected growth occurs or if regulatory requirements are not met. The schedule and resulting financial plans may be revised each year during the period 2008 to 2020 as MMSD evaluates the schedule of implementation of the 2020 FP each year as more precise project data and population and land use data become available to determine MMSD needs and schedule.
Population growth and the ongoing flow monitoring from the satellite municipalities will drive the need for further metropolitan interceptor sewer (MIS) relief sewers. This flow monitoring will serve as a continual check on the status of the need for the MIS relief sewers. This is discussed in more detail in Section 11.3.1.
Because of inflation, actual costs over the period 2008 to 2020 will be higher than shown in the schedule. The financing plans developed by MMSD for implementation takes into account the impact of inflation. Details of estimated future costs and impact on property taxes and user charges are discussed in Section 11.13.
This facilities plan includes recommendations on implementation of the FPOPs as discussed above. Thus, the financial impact of the Recommended Plan is not only in the implementation of capital improvements, but also in the implementation of new programs, operational g In general a project need will be necessitated by actual population and/or land use growth.
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improvements and policies. Most of the new programs, operational improvements and policies are revamped existing activities and therefore do not present significant cost impacts.
The recommended FPOPs are grouped into the following categories just as was presented in Chapter 10, Recommended 2020 Facilities Plan:
♦ Section 11.3 - Wet Weather Control Plan Implementation – includes implementation elements that are the responsibility of MMSD’s satellite municipalities
♦ Section 11.4 - Plan for Potential Improvements to Existing MMSD Facilities
♦ Section 11.5 – Interim Biosolids Plan
♦ Section 11.6 - Watercourse Plan
♦ Section 11.8 - New MMSD Programs and Policies to be Implemented
♦ Section 11.9 - Existing MMSD Programs and Policies to be Maintained
♦ Section 11.10 - Existing MMSD Operations to be Continued
♦ Section 11.11 – MMSD Committed Projects
This chapter also presents the following additional implementation information:
♦ Section 11.12 – Impact of the Recommended Plan on MMSD Staffing Requirements
♦ Section 11.13 – The MMSD Financial Plan for Implementation of the 2020 Facilities Plan
♦ Section 11.14 – Implementation of the Combined Recommendations of MMSD 2020 FP and the RWQMPU as a Watershed Approach
♦ Section 11.15 – Tracking and Evaluating Implementation Efforts
♦ Section 11.16 – Summary
11.3 Wet Weather Control Plan Implementation The 2020 FP includes a Wet Weather Control Plan (WWCP) to identify the FPOPs that are required by state and federal regulations under the current discharge permit for the anticipated 2020 population and land use. The components of the WWCP are dependent on future population growth, associated land use, and operation of the existing system. The MMSD WWCP consists of FPOPs that focus on maximizing capture of sewage during wet weather events. The implementation of the proposed FPOPs that are a part of the WWCP is summarized in the next two sections.
11.3.1 Wet Weather Control Plan Recommended Facilities
The following facilities improvements are recommended for construction or implementation by MMSD in order to maximize capture and treatment of sewage during wet weather.
Increase Inline Storage System Pump Station Capacity to Jones Island Wastewater Treatment Plant Through the evaluation of the screening and preliminary alternatives, the 2020 FP determined the need for additional pumping capacity from the inline storage system (ISS) to Jones Island
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Wastewater Treatment Plant (JIWWTP) in order to control SSOs to a 5-year LOP (as discussed in Section 9.6 of Facilities Plan Report Chapter 9, Alternatives Development, projected SSO LOP for the system is 7 years based upon tunnel related SSO). The modeling for the Recommended Plan determined that the pumping capacity from the ISS to JIWWTP must be increased to a firm capacity of 180 million gallons per day (MGD) in order to assist in meeting the 5-year LOP.
The MMSD has already acted on this recommendation by initiating a conceptual design project in November 2006 that addresses the evaluation of the ISS Pump Station. This conceptual design project will be completed in 2007 and will form the basis for the implementation of the rehabilitation and expansion of the ISS Pump Station. The AIS (Figure 11-1) will be revised for this recommended facility upgrade and expansion once the conceptual design project is complete. The AIS shows the rehabilitation occurring from 2008 through 2014 and the construction of some of the facilities in the period from 2015 to 2020, with the remainder assumed to be after 2020. Costs included in the adaptive financing plan before 2020 to increase the capacity of the pump station are assumed to be $50 million.
The FIS (Figure 11-2) shows the rehabilitation occurring from 2008 through 2014 and the construction of all the facilities in the period from 2012 to 2020. The FIS assumes completion of both the upgrade and the capacity expansion by 2020 (total cost of $133 million).
Implement Facilities Improvements to Flow Monitoring Program and Rain Gauge System As a part of the Wet Weather Peak Flow Management Program (WWPFMP), MMSD has already begun to make improvements to its flow monitoring system to assist in I/I management. This ongoing project includes investments for flow monitoring equipment and structures, where necessary, at the sewershed level, at connections to satellite municipalities, or at connections to the MIS system. In addition, the evaluation and implementation of any identified improvements to the existing rain gauge system are recommended.
The MMSD is in the process of purchasing and installing additional flow meters and developing a process for developing peak flow performance standards through collaboration with the Technical Advisory Team (TAT).
This project is anticipated to continue from 2008 through 2013 as shown on the both the AIS (Figure 11-1) and the FIS (Figure 11-2). However, MMSD may need to continuously update and modify this system. Costs are estimated at $31 million for under the AIS and $37.4 million under the FIS.h
h This is the midpoint of the range ($25-37 million) presented in Chapter 10 of the Facilities Plan Report. The cost for the preliminary engineering analysis ($0.4 million) is assumed to be included in the $31 million cost. The FIS cost assumes the upper range ($37 million) plus $0.4 million for the preliminary engineering.
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Hydraulic Analysis of Jones Island Wastewater Treatment Plant A hydraulic capacity analysis of JIWWTP has been identified as a need in the Treatment Report.i Two ongoing MMSD projects included in the 2007 Annual Budget (J01006, Preliminary Treatment Upgrade and J01008, Upgrade Primary Clarifier Mechanisms) address upgrading the preliminary treatment system and the primary clarifiers. The 2020 FP recommends that a hydraulic analysis of the JIWWTP be conducted after these projects are completed in 2010. This determination of hydraulic capacity may identify issues that would have to be addressed in order to assure the full capacity of JIWWTP as 300 MGD maximum day and 330 MGD maximum hour. The costs for this analysis are assumed to be included in the plant rehabilitation allowance.
Perform Capacity Analysis of South Shore Wastewater Treatment Report The 2020 FP identified the need to increase the treatment capacity of SSWWTP to achieve a 5- year LOP for SSOs. The current maximum day design capacity of SSWWTP is 250 MGD. However, based on actual historical flow data, 300 MGD was used in all 2020 FP analyses as the maximum daily capacity. It is possible that the actual maximum capacity may be even greater than 300 MGD. A detailed capacity analysis is recommended for SSWWTP in order to update the design capacity.
If the capacity of SSWWTP is actually greater than 300 MGD, the need for additional capacity may be reduced, which will reduce the costs for the proposed new additional secondary treatment (physical-chemical treatment). Therefore, it is recommended that the capacity analysis of SSWWTP begin as soon as possible. As shown in both the AIS and the FIS, this project would be completed in 2008 at an estimated cost of $300,000. This project may have a material impact on the potential need for SSWWTP expansion as noted in the following project description, and is not affected by the implementation assumptions.
Increase South Shore Wastewater Treatment Plant Capacity Through the evaluation of the screening and preliminary alternatives, the 2020 FP determined that additional treatment capacity at SSWWTP is needed in order to control SSOs to an appropriate LOP if full growth occurs. The modeling for the Recommended Plan determined that the treatment capacity of SSWWTP must be increased from the existing capacity of 300 MGD to 450 MGD in order to assist in meeting the 5-year LOP under full growth (Revised 2020 Baseline) conditions.
The analysis completed in the State of the Art Report (SOAR) revealed that the most cost effective and acceptable method to increase secondary treatment capacity at SSWWTP is to add physical-chemical secondary treatment with ultra-violet (UV) disinfection for the physical- chemical secondary treatment effluent. A long term (2-3 year) demonstration project is recommended at SSWWTP in order to prove the treatment concept, verify sizing assumptions, adequately address long term operational issues, determine disinfection effectiveness and address community concerns.
Under the AIS, the initiation of this demonstration project is planned for 2013 through 2016 at an estimated cost of $1.5 million. The initiation of the actual construction to increase SSWWTP capacity is assumed to occur after 2020, unless population growth or other circumstances require
i See Chapters 4, 5 and 8 of the Treatment Report.
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a change to this schedule. The need for capacity expansion is dependent upon many factors, including the following:
♦ MMSD operational measures to control SSOs (including volume reserved for separate sewer inflow (VRSSI) management)
♦ The results of the SSWWTP capacity study
♦ The results of the physical-chemical demonstration project
♦ The recommended evaluation of blending at SSWWTP
♦ The timing and amount of population growth in the MMSD sewer service area
♦ The potential success of MMSD and its satellite municipalities in reducing year 2000 I/I levels through the implementation of the Capacity, Management, Operations, and Maintenance (CMOM) program, the progress of the WWPFMP, and the enactment of the proposed revisions to Chapter 3 of the MMSD Rules and Regulations
Under the FIS, the demonstration project is planned from 2008 through 2011 and the design and construction of the expansion facilities would begin in 2011 and proceed to 2019.
In addition to the demonstration project, an evaluation is necessary to determine if increasing the MIS flow rate to SSWWTP will require control system refinements and structural modifications at the South 6th Street and West Oklahoma Avenue diversion chamber to the ISS. This evaluation should be initiated at the same time as the physical-chemical design is initiated because they are interdependent (i.e. an increase in flow to SSWWTP may necessitate modifications to the diversion chamber).
If the SSWWTP capacity improvements are not implemented within the planning period, the need for relief of the Ryan Road MIS for the 5-year LOP should be re-evaluated. Under the 5- year LOP Recommended Plan, relief of the Ryan Road MIS is not needed because the SSWWTP capacity improvements will result in a lowering of the hydraulic grade line (HGL) in this segment of the MIS such that critical elevations are not exceeded. However, if the SSWWTP improvements are not implemented, the HGL in the Ryan Road MIS will be higher. An evaluation would need to be performed to assess whether the higher HGL would exceed any critical elevations. If critical elevations are exceeded, relief of the Ryan Road MIS may be necessary for the 5-year LOP condition, in the absence of SSWTP capacity improvements.
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Add Metropolitan Interceptor Sewer Capacity as Necessary Table 11-2 summarizes potential projects needed to increase MIS capacity to prevent SSOs and provide free outlet conditionsj for local sewers for the 5-year SSO full growth condition. These improvements are needed to address either current capacity restrictions, based on available flow data, or restrictions that may occur as a result of increased flow due to anticipated future growth in population and/or land use changes. Additional flow monitoring to verify current flows and to assess future growth of flows will be necessary to verify whether MIS capacity enhancements are actually needed at these locations. To verify current flows, flow monitoring should be conducted for a representative period of time in order to assess performance of the MIS during a variety of rainfall events as well as during dry weather. Longer-term flow monitoring over several years in conjunction with monitoring of population growth and development is needed to assess whether growth projected during the facilities planning process does actually occur, thereby generating a need for MIS capacity enhancements. If flow monitoring confirms that an increase in MIS capacity is needed, preliminary engineering should be performed to identify the most appropriate conveyance system enhancement.
The preliminary engineering effort should include an assessment of whether the provision of free outlet conditions for local sewers is needed in each of these project areas. In some cases, the local connections are very deep; limited surcharging of these connections can most likely be tolerated without posing a risk of basement backups. If it is verified that limited surcharging of connections can be tolerated, some of the projects in Table 11-2 may be reduced in scope or eliminated.
The Franklin-Muskego MIS (with the option of the Ryan Creek Interceptor/Force Main Project) as proposed (an additional force main) is dependent upon planned growth in the tributary area. The option of construction of a different force main in Ryan Road in Franklin to serve some of this need is also dependent upon planned growth; however, construction of this option may also accommodate additional growth in currently undeveloped areas. More details regarding increasing MIS capacities are presented in Chapter 9, Alternatives Development of the Conveyance Report. If the Ryan Creek Interceptor is constructed, the Franklin/Muskego MIS will not be necessary (as discussed in footnote in Table 11-2).
j The free outlet condition could not practically be achieved for the Mill Road/Green Bay Avenue Relief Project (5- year LOP), so the project is configured so that the HGL is below basement elevations as explained in the Conveyance Report, Chapter 9.
Project Project Name 5-Year Recommendations
Sized for 2020 Baseline and
Ultimate Buildout Conditions Capital
Sewer and Pump Station 5.9
2 Milwaukee River MIS Sewer Replacement 18.1
3 Range Line Road MIS Sewer Replacement 1.1
4 River Hills MIS Sewer Replacement 0.5
5 Green Bay Avenue/Mill Road MIS Green Tree Pump Station Modification
and New Force Main 16.0
7 Menomonee River MIS Sewer Replacement 1.3
9 South 81st Street MIS Sewer Replacement 3.5
10 South Howell Ave MIS Relief Sewer 8.3
13 Franklin-Muskego MIS 1
Parallel Force Main 4.7
Strategy Improvements 0.4
Notes:
All costs are escalated using the Engineering News Record Construction Cost Index (ENR-CCI), which was projected to be 10,000 in 2007.
Capital cost includes construction cost plus 25% for engineering and 35% for technical services and administration.
These costs do not include O&M and salvage values.
Projects 6, 8, 11, and 12, as shown in the Conveyance Report Chapter 9, Section 9.2 and Table 9-4, are not required for a 5-year level of
protection, and therefore are not listed in this table.
1) Project 13 is subject to refinement or change based on a project-specific advanced facilities plan to evaluate options for the Ryan Creek
Interceptor and the upgrade to the existing Franklin-Muskego MIS. $15 million for the Ryan Creek Interceptor has been included for this
project in both the AIS and FIS. If the Ryan Creek Interceptor is constructed, the Franklin/Muskego MIS will not be needed.
2) This $59.8 million was rounded to $60 million in the Facilities Plan Report and Conveyance Report
TABLE 11-2
POTENTIAL METROPOLITAN INTERCEPTOR SEWER CONVEYANCE RECOMMENDATIONS FOR A 5-YEAR LEVEL OF PROTECTION UNDER FULL GROWTH AND ULTIMATE BUILDOUT CONDITIONS 2020 FACILITIES PLAN
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In considering implementation, the recommendations for potential MIS projects were reevaluated using ultimate population and land use conditions, based upon maximum buildout conditions. The recommended projects have the capacity to convey both the year 2020 full growth and buildout condition flows. The cost of implementation for the 10 potential conveyance system recommendations is estimated to be $59.8 million. Under the FIS, if the Ryan Creek Interceptor is constructed, the total capital cost is $70.1 million. The FIS assumes all MIS projects are constructed from 2010 through 2020. The AIS assumes only the Ryan Creek Interceptor is constructed and it would occur from 2017 through 2020. Table 11-2 summarizes the cost for the conveyance recommendations.
Priority should be given to implementing those projects that are not driven by future growth, (i.e., driven by current capacity restrictions as verified by additional flow monitoring) provided that near-term flow monitoring verifies the need for these projects. This includes Projects 2, 3, 4, 5, 7, 9, and 10.
Some strategies for sequencing and coordinating the construction of the potential recommended projects have been identified. Project 2, the Milwaukee River MIS and Project 4, the River Hills MIS are hydraulically and physically connected. The River Hills MIS connects into the Milwaukee River MIS at the intersection of West Greenwood Road and North Pierron Avenue on the west side of the Milwaukee River. In order to minimize the disturbance of the area and interruption of traffic due to the construction effort, the two projects should be combined into one project and constructed at the same time, when the need for these projects is confirmed.
The Green Tree Pump Station may be upgraded for Project 5, the Green Bay Avenue/Mill Road MIS. However, because flow to the Green Tree Pump Station is from the Milwaukee River MIS, the pumping capacity of the Green Tree Pump Station should be rated for flow from the Milwaukee River MIS. Additionally, the pump station should provide the peak capacity at a head that will not surcharge the Milwaukee River MIS above the crown of the pipe. This will provide a free outlet condition along the Milwaukee River MIS when the pumps are at full capacity. Finally, any planned modifications to the Green Tree Pump Station need to be coordinated with MMSD’s current pump station upgrade project, which is addressing general facility upgrade needs.
Because of the interrelationships between the recommended facilities for Projects 2, 4, and 5, a single preliminary engineering evaluation should be performed to address all of these projects. The final projects to be implemented need to function as an integrated system.
The recommended changes to the real time control (RTC) operations of the DC0103 ISS gates (Project 14) are needed to use the full capacity of the recommended treatment upgrade at SSWWTP. Structural improvements at DC103 may be required in conjunction with the RTC operation changes. Therefore, both the structural improvements and the RTC changes need to be coordinated with implementation of the increased SSWWTP capacity.
The actual schedule for initiation of these projects depends on the following:
♦ The extent of population growth in the MMSD system.
♦ Increase in SSWWTP capacity.
♦ Verification of current hydraulic restrictions as verified by additional flow monitoring.
♦ Verification of peak flows in areas tributary to the project locations.
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♦ The success of MMSD and its satellite municipalities in maintaining year 2000 I/I levels through the implementation of the CMOM program, the completion of the WWPFMP, and the enactment of the proposed revisions to Chapter 3 of MMSD’s Rules and Regulations. However, this success should not be expected to significantly decrease I/I levels because the goal is to hold year 2000 I/I levels, not to decrease them to any substantial degree.
♦ In the case of the service area(s) for Franklin and Muskego, the implementation of the Franklin-Muskego MIS (or another version of this project) will dependent upon growth needs in this part of the MMSD service area.
To prepare for the eventuality that the service needs for Franklin and Muskego may require MIS expansion, and to allow for other potential needs, $15 million has been identified in the adaptive implementation plan in the years 2017 to 2020.
11.3.2 Wet Weather Control Plan Recommended Programs, Operational Improvements and Policies Implementation
MMSD Elements As presented in Section 10.2.2 of Chapter 10, Recommended 2020 Facilities Plan, a series of programs, operational improvements, and policies are recommended for implementation in order to maximize capture and treatment of sewage during wet weather.
The 2020 technical team estimated that the annual operating and maintenance cost to implement the WWPFMP to control I/I growth is approximately $600,000. The MMSD will have to determine whether these estimated costs are new, additional costs, or a reallocation of existing efforts. The costs for the remaining programs, operational improvements, and policies will be included in the ongoing annual operating budget.
A recommended schedule for implementation of these programs, operational improvements, and policies is presented in Table 11-3. More details can be found in Chapter 10, Recommended 2020 Facilities Plan. It is important to note that some of these programs, operational improvements and policies are already underway. The recommended initiation date in the table represents the date the program or policy should be (or was) initiated). It may take up to several years following the initiation date to begin implementing each program or policy.
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TABLE 11-3 WET WEATHER CONTROL PLAN RECOMMENDED MILWAUKEE METROPOLITAN SEWERAGE
DISTRICT PROGRAMS, OPERATIONAL IMPROVEMENTS, AND POLICIES - RECOMMENDED IMPLEMENTATION
Item to be Implemented Primary Reason for Implementation Recommended Initiation
Date
1. Policy: Implement MMSD’s WWPFMP to Control I/I Growth
Establish peak wet weather flow standards, outline provisions for deteriorated sewersheds and incorporate other actions to keep I/I from growing beyond current levels.
Underway since 2004
2. Program: Implement MMSD’s CMOM Program
Requirement of Stipulation. Will serve to control degradation of sewersheds and curtail I/I.
Underway since 2002
3. Program: Implement CMOM for Municipalities and Milwaukee County
Requirement of Stipulation. Will serve to control degradation of sewersheds and curtail I/I in municipal sewers.
Underway since 2002
4. Program: Implement MMSD’s SECAP
Requirement of Stipulation to ensure adequate capacity and mitigate SSOs. This requirement has been met by completion of the 2020 FP.
Complete in 2007
5. Program: Implement SECAP for Municipalities
Will serve to ensure adequate capacity and mitigate SSOs in municipal sewers.
MMSD limited SECAPs for each municipality completed in 2006
6. Program: Implement Flow Monitoring for High Priority Areas
Flow monitoring to identify and monitor high priority areas where high levels of I/I are expected.
Underway since 2004
7. Operational Improvement: Continue Operation of Real Time Control (RTC)
Use current algorithm and continue development with more data to optimize MMSD’s systems during wet weather events.
Underway since 2004
8. Operational Improvement: Evaluate Need for Control System Refinements at 6th & Oklahoma Diversion Structure
Necessary to determine if increasing the MIS flow rate to the SSWWTP will require system refinements at the 6th & Oklahoma diversion chamber to the ISS.
2008
Implement Milwaukee Metropolitan Sewerage District’s Wet Weather Peak Flow Management Plan to Control Infiltration and Inflow Growth
In 2006, the MMSD Commission adopted a policy to draft a WWPFMP in cooperation with the TAT and coordinated with MMSD’s CMOM program. The MMSD has drafted a WWPFMP Strategic Plan that contains the following main elements:
♦ The objectives and priority for wet weather peak flow management
♦ The program objective for the management and control of wet weather peak flows
♦ Guiding principles for a Wet Weather Peak Flow Management Program
♦ Implementation of the Wet Weather Peak Flow Management Program
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♦ Determination of acceptable wet weather peak flow
♦ Customer and community collaboration and education
♦ Existing policies and procedures from the MMSD rules
♦ Other agencies’ wet weather peak flow management programs
♦ Funding and staffing considerations
The 2020 FP acknowledges and reinforces MMSD’s plans to fully implement a WWPFMP to assist in controlling I/I growth. The WWPFMP will develop a comprehensive and sustainable plan with the goals of:
1) Reducing I/I from separated sewerage systems
2) Managing peak wet weather flows in the combined sewerage system
3) Incorporating wet weather peak flow source control measures
The WWPFMP will establish peak wet weather flow standards that address poorly performing sewersheds to ensure that I/I does not grow beyond year 2000 levels.
The 2002 Wisconsin Department of Natural Resources (WDNR) Stipulation requires revisions to Chapter 3, Infiltration and Inflow, of the MMSD Rules; these revisions have been initiated and are expected to be approved by the MMSD Commission by June 30, 2007.
As an input to the “Determination of acceptable wet weather peak flow” element noted above, the 2020 FP also recommends that the WWPFMP develop a standard for peak I/I in sewersheds that is consistent with reasonable design peak flows and consideration of when a sewershed is “broken” or performing poorly. It is recommended that a peak flow performance standard be based upon the same type of analysis presented in Appendix 9A of the Conveyance Report. The recommendation is based upon the same methodology used in the 2020 FP modeling analysis of I/I in the sewersheds.k The proposed methodology is illustrated in Chapter 10, Recommended 2020 Facilities Plan, Figure 10-1. It involves setting a variable standard based upon a differential from the mean sewershed I/I peak flows (in terms of gallons per acre per day – peak flow), which is further adjusted for the area of the sewershed. This recommended standard has been incorporated into the revisions to Chapter 3 of the MMSD Rules and is found in Section 3.201.
Implement Milwaukee Metropolitan Sewerage District’s Capacity, Management, Operations and Maintenance Program
The CMOM program is a regulatory program initiated by the U.S. Environmental Protection Agency (USEPA) that promotes a flexible, dynamic framework for municipalities to identify and incorporate widely accepted wastewater industry practices in order to accomplish the following:
♦ Better manage, operate, and maintain collection systems
♦ Investigate capacity constrained areas in the collection system
♦ Respond to SSO events
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As required by the WDNR in the 2002 WDNR Stipulation, MMSD is currently in the process of developing and implementing a CMOM program to assist MMSD and the 28 satellite municipalities it serves to provide better sewer service and maintenance by controlling the degradation of the sewer systems and curtailing I/I. The MMSD has completed its CMOM Strategic Plan and is now in the process of implementing the program. The MMSD’s CMOM program includes the following elements:
♦ Management Plan
♦ Compliance Communication Plan and Program Audit
Cost estimates for the MMSD CMOM program for 2007 are presented in MMSD’s 2007 Annual Budget. Additional MMSD CMOM program details are presented in Chapter 8, Common Conveyance Facilities, Programs, Operational Improvements, and Policies for the Recommended Plan of the Conveyance Report.
Implement Milwaukee Metropolitan Sewerage District’s System Evaluation and Capacity Assurance Plan
The SECAP, which was a requirement of the 2002 WDNR Stipulation, identifies additional necessary capital improvements to ensure adequate capacity and to mitigate SSOs. The SECAP is a key component of MMSD’s CMOM program. Completing the 2020 FP meets the requirements of the SECAP because the 2020 FP evaluated the conveyance system to identify potential hydraulic restrictions.
Implement Flow Monitoring for High Priority Areas
The MMSD has already begun implementation of enhancing flow monitoring for high priority areas or areas where high levels of I/I are expected. The MMSD began monitoring high priority sewersheds in 2004. Most recently, 25 new portable area/velocity flow meters were purchased and 30 meters were installed in October 2006 to monitor flows from 53 sewersheds that were identified by the 2020 technical team as having excessive I/I during wet weather conditions. These meters were installed in an effort to ascertain the accuracy of the modeled flow assignments in these areas. The 2020 FP recommends that flow monitoring be continued to verify modeled data to assist in controlling I/I.
Continue Operation of Real-Time Control
The MMSD uses a complex network of monitors, sensors and computerized weather reporting systems to monitor and control its sewer system. This network is called the RTC system. The 2020 FP recommends that the operation of the RTC system be continued and enhanced in order to use all wet weather event data and further improve the prediction algorithm. The prediction algorithm is used to optimize the operation of MMSD’s systems (e.g., storage and wastewater treatment plants’ capacity) during wet weather events. Additional work is recommended to continue to analyze the operating data and further refine the algorithm. More details regarding the RTC system and proposed improvements are discussed in Chapter 10, Recommended Plan of the Conveyance Report.
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Municipal and Milwaukee County Capacity, Management, Operations and Maintenance Implementation
As required by the WDNR in the 2002 WDNR Stipulation, MMSD must pass new rules that require all MMSD satellite municipalities to implement CMOM programs to control the degradation of the sewer systems and curtail I/I. These requirements are incorporated into the revisions to Chapter 3 of the MMSD Rules discussed above. The MMSD will lead and support the implementation of CMOM programs for Milwaukee County and MMSD’s 28 satellite municipalities. The MMSD has already begun to work with the satellite municipalities to develop plans similar to MMSD’s CMOM program. Cost estimates for MMSD’s CMOM program for 2007 are presented in MMSD’s 2007 Annual Budget. Additional CMOM program details are presented in Chapter 8, Common Conveyance Facilities, Programs, Operational Improvements, and Policies for the Recommended Plan of the Conveyance Report. Implementation of these programs needs to begin by 2009.
Implementation of System Evaluation and Capacity Assurance Plan for Municipalities
The MMSD will lead and support the implementation of SECAPs for the 28 satellite municipalities it serves as a part of its comprehensive CMOM program. If a municipality needs a SECAP to be prepared, MMSD can require the municipality to complete the SECAP. Cost estimates for the MMSD portion of the program for 2007 are presented in the MMSD’s 2007 Annual Budget as a part of the CMOM program. Additional CMOM program details are presented in Chapter 8, Common Conveyance Facilities, Programs, Operational Improvements, and Policies for the Recommended Plan of the Conveyance Report.
11.4 Implementation Plan for Potential Improvements to Existing MMSD Facilities The following facilities improvements are recommended for construction or implementation by MMSD for the reasons stated in each section below:
Rehabilitate the Inline Storage System Pump Station The MMSD initiated a project in November 2006 to develop a conceptual design for rehabilitation and upgrading the ISS Pump Station as well as expanding it in conformance with the Recommended Plan outlined in Chapter 10, Recommended 2020 Facilities Plan. This was discussed in Section 11.3.1.
The original purpose of the project was to rehabilitate existing system components that are at the end of their useful service life and to upgrade other systems in order to resolve existing operational issues. The 2020 facilities planning process identified the need to increase the ISS Pump Station capacity in order to meet the needs of a 5-year LOP with Revised 2020 Baseline population and land use. As a result of this recommendation, the project will now evaluate both the rehabilitation upgrades and capacity expansion to ensure that the ISS pump station will meet the capacity requirements of the 2020 FP as discussed in Section 10.2 of Chapter 10, Recommended 2020 Facilities Plan. The cost estimate to rehabilitate the pump station is $25 million with the proposed work occurring from 2008 through 2014 under both the AIS and FIS.
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Complete Preliminary Engineering Analysis for Additional Force Main A preliminary engineering (PE) analysis is recommended to determine the utility and system benefits of adding a 48-inch force main from the ISS Pump Station to the diversion chamber (DC0103) at South 6th Street and West Oklahoma Avenue. This analysis evaluates the feasibility of taking JIWWTP out of service on a short term basis for maintenance. The PE analysis should include an evaluation of the benefits of adding the force main.l
Under both the AIS and FIS the PE analysis for this project is planned to occur from 2011 through 2012 (at an estimated cost of $300,000). If recommended after completion of the PE, the construction of this system is assumed to begin in 2016 and continue to 2020 (with an estimated capital cost of $23 million).
Complete Evaluation of Jones Island Wastewater Treatment Plant Aeration System An analysis of the aeration system and associated power needs and costs is recommended to be completed at JIWWTP. The loss of wet industries over the past 10 to 20 years, and especially the recent loss of LeSaffre Yeast, has greatly reduced the biochemical oxygen demand load at JIWWTP. An evaluation should be performed to determine if the size of the aeration system could be reduced, which may in turn reduce long term energy costs. It may be possible to install smaller blowers and new diffusers in the aeration basins, which may reduce electrical demand.m
Under both the AIS and FIS the PE analysis for this project is planned to occur in 2008 at an estimated cost of $300,000. Under the AIS, the actual construction of this system is assumed to begin in 2018 with an estimated capital cost of $15 million. Under the FIS, the construction is planned to occur from 2012 through 2016.
Ongoing Treatment and Conveyance Upgrades It is recommended that MMSD continue to fund routine ongoing treatment and conveyance upgrades that are necessary to provide adequate sewage conveyance and treatment. The costs are based on historical experience.n These costs are reflected in the MMSD financing plans discussed in Section 11.13.
Geotechnical/Structural Analysis of Wastewater Treatment Plants The 2020 FP recommends that a full geotechnical and structural analysis be performed on both wastewater treatment plants. Parts of JIWWTP will be nearly 100 years old by 2020 and a full analysis of the condition of the facilities has not been completed in over 20 years. Such an analysis will identify areas that may need repair or replacement in order to prevent any unanticipated expenditure due to structural/geotechnical failures.
The analysis for this project is planned to occur from 2011 through 2014 under the AIS and from 2012 through 2015 under the FIS. The estimated cost is $800,000 for the analysis. Any recommended construction projects resulting from this analysis are not known at this time and thus are not possible to estimate. The ongoing costs included in the MMSD financing plan for treatment system upgrades would be assumed to be the source of any project funds for the results of this analysis, unless future financial plans provide otherwise.
l Further details are discussed in Chapter 8 of the Conveyance Report. m Further details are discussed in Chapter 10 of the Treatment Report. n Further details are presented in Chapter 8 of this report.
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Recommended Treatment and Conveyance Projects - Included in the MMSD 2007 Annual Budget The 2020 FP recommends that a number of previously identified treatment and conveyance projects proceed into construction. These projects are included in the MMSD 2007 Annual Budget but were not yet “committed” within the meaning of this plan because they are not part of the 2002 WDNR Stipulation or construction has not been initiated. A detailed list of these projects is presented in Chapter 8, Common Facilities, Programs, Operational Improvements and Polices for the Recommended Plan, Table 8-4. These projects are included in MMSD’s financing plans (discussed in Section 11.13) but are not included in the implementation schedules. The MMSD financing plans (both AIS and FIS) have allowed for an estimated $89 million for ongoing treatment projects (anticipated to be spent from 2010 to 2020) and an estimated $162 million for ongoing conveyance projects (anticipated to be spent from 2013 to 2020).
11.5 Interim Biosolids Plan The MMSD currently recycles the biosolids that are a normal byproduct of the wastewater treatment process. At JIWWTP, most of the biosolids are converted to and sold as Milorganite®, a popular natural organic fertilizer. The remaining sludge is processed at SSWWTP into Agri-Life®, a natural organic biosolids product that is applied to the soil at area farms to provide nutrients for crops. Any remaining biosolids not used for the production of Milorganite® or Agri-Life® are made into filter cake, which is usually land applied. Milorganite® production, and corresponding sales and revenue, are expected to decrease in the coming years due to the decrease in flows from wet industries with high organic loads. Therefore, it was necessary to analyze the long-term trends in Milorganite® production and prepare a future plan for biosolids. The need to repair or replace much of the equipment used for sludge processing and the relatively high cost of biosolids processing compared to other wastewater treatment plant processes also provided impetus for the analysis of the future biosolids production.
As discussed in Chapter 9, Alternative Analysis of the Treatment Report and Chapter 10, Recommended 2020 Facilities Plan of this report, a comprehensive biosolids handling evaluation (including energy needs) was performed as a part of the 2020 facilities planning effort. The analysis showed that based on the present value cost estimates for each alternative there was no strong financial basis for making a 2020 recommendation to change the current MMSD biosolids management method. The 2020 FP recommends that MMSD continue with existing operations for an interim period in order to continue to evaluate all alternative biosolids options and to fully understand the impacts of the loss of wet industries (primarily LeSaffre Yeast). The interim recommendations consist of the following:
♦ Conduct Milorganite® marketing analysis (assuming 5% or less nitrogen content)
♦ Evaluate Milorganite® nitrogen balance
♦ Create Assessment Report on energy management and power supply/power generation
♦ Develop final Biosolids Recommended Plan
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These analyses will be conducted in 2008 (extending to 2009 under the FIS). The Milorganite® marketing analysis is already planned to be completed in 2007. The nitrogen balance evaluation will be ongoing and can be completed at minimal additional cost to MMSD under existing operating budgets. The schedule and budget for completing the assessment report on energy management and power supply/power generation is shown in Figures 11-1 and 11-2. These analyses will form the basis for a final Biosolids Recommended Plan.
Interim facilities improvements are recommended as follows:
♦ Rehabilitation of JIWWTP Dewatering and Drying facilities
♦ Interplant sludge pumping and pipeline improvements
♦ New gravity belt thickeners for SSWWTP digested sludge thickening
♦ New gravity belt thickeners for SSWWTP waste activated sludge thickening
♦ Upgrade SSWWTP plate and frame presses
♦ JIWWTP new biosolids/energy system (the details of this are to be determined after the final Biosolids Recommended Plan is developed)
The proposed schedules for the implementation of these projects under the AIS and FIS are shown in Figures 11-1 and 11-2, respectively; however, the initiation of construction will be dependent on the recommendations in the final Biosolids Recommended Plan. For example, a preliminary engineering analysis is recommended to confirm the requirements for rehabilitating various components of the dewatering and drying systems at JIWWTP. While there are three dewatering and drying rehabilitation projects (J04013, J04014, and J04015 - see Chapter 8, Common Facilities, Programs, Operational Improvements, and Policies for the Recommended Plan, Table 8-4) already included in MMSD’s 2007 Annual Budget, the 2020 technical team identified the possible need for other dewatering and drying rehabilitation projects depending upon the recommendations that come from the long term biosolids handling evaluation.o This final work is dependent upon the completion of the final Recommended Biosolids Plan, but at this time approximately $115 million for rehabilitation is included in the AIS to be spent from 2015 to 2020 and from 2012 through 2020 under the FIS.
Thus, the recommendations for facility improvements and the corresponding schedule must be revisited once the final Biosolids Recommended Plan is completed.
o Further details on the rehabilitation of drying and dewatering systems as they relate to the recommendations for biosolids handling can be found in the Treatment Report, Chapter 9.
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11.6 Watercourse Plan The following four elements are recommended as a part of the 2020 FP in order to improve water quality, reduce municipal I/I, and enhance flood mitigation. More details are presented in Chapter 10, Recommended 2020 Facilities Plan.
Watercourse Flood Management Plan A watercourse flood mitigation plan is needed not only to manage flooding but to also control municipal I/I thus assisting in the control of SSOs.
The following projects are in various stages of implementation by MMSD:
♦ Milwaukee River Flood Managementp
♦ Indian Creek Flood Management
♦ Milwaukee County Grounds Detention Basins
♦ Western Milwaukee
The schedules for these projects are not impacted by the 2020 AIS or FIS and are as shown in the 2007 MMSD Six-Year Financing Plan and incorporated into the MMSD financing plans (discussed in Section 11.13).
Concrete Channel Renovation and Rehabilitation Approximately 26 miles of concrete channelized waterways under MMSD jurisdiction are in need of repair or replacement; they were channelized by MMSD from the 1960s through the 1980s (as discussed in Chapter 10, Recommended 2020 Facilities Plan). These channels were lined with concrete to improve conveyance so as to avoid flood conditions. In many areas, the channel liners are failing, particularly near storm sewer outfalls and bridge crossings.
The MMSD has approached the United States Army Corps of Engineers (USACE) Detroit District for funding on several projects. The USACE is in various stages of project planning or design for up to six projects and has also discussed with MMSD the funding of projects through the Water Resources and Development Act.
The two highest priority projects (Underwood Creek Reach 1-W21005) and Menomonee River Reach 1 –W20021) are included in both the Full Implementation Financing (FIF) Plan and the Adaptive Implementation Financing (AIF) Plan (discussed in Section 11.13). Two other projects (KK River Reaches 1 & 2 – W40002) and Wilson Park Creek – W54001) are only included in the FIF Plan and are not included in the AIF Plan for implementation in the time frame of 2008 through 2020.q
p Milwaukee River Flood Management is included in the Full Implementation Financing Plan but not the Adaptive Implementation Financing Plan. See Section 11.13 for a description of the financing plans. q These projects are listed in Table 8-5, Concrete Lined Channel Projects, Chapter 8 of this report as “Priority 1” projects. Not all lower priority projects on this table were intended to be completed by 2020.
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Renovation of Kinnickinnic River Flushing Station The Kinnickinnic (KK) River flushing system was constructed in the early 1900s to improve water quality in the lower reach of the Kinnickinnic River. The system pumps water from Lake Michigan into the KK.
In 2002, a preliminary engineering study reviewed options for renovating the intake and the outlet structures of the KK flushing system.(1) The intake structure was noted as being severely deteriorated and a public safety hazard. The outlet structure was filled with silt and debris that could not be easily removed because of access issues. The buildup of silt and debris were thought to be significantly reducing the capacity of the pump station and the ability of the system to improve the downstream water quality of the KK. Work associated with the tunnel and the pump station was not a part of the project. The cost estimates to renovate the intake and outlet structures of the flushing station are based on the 2002 preliminary engineering analysis.r
Prior to the intake and outlet structure work, the 2020 FP recommends an engineering study on the physical and operational condition of the pump station and the tunnel. In addition, a more detailed study should be conducted on the impacts the tunnel operation has on water quality downstream of Chase Avenue and whether the sediment downstream of the tunnel outfall should be dredged. The KK flushing station rehabilitation is planned to occur from 2012 through 2014 under both the AIS and FIS.
Greenseams Program The MMSD’s Greenseams program includes purchasing natural wetlands to retain stormwater for the purpose of reducing the risk of flooding, providing natural attenuation for polluted stormwater, protecting riverfront land from development, and providing increased public access to the waterways. The MMSD has acquired funding from state and federal grants to offset some of the costs of the land purchases. The implementation of this program is ongoing and the costs are included in the 2007 MMSD Annual Budget and the MMSD financing plans discussed in Section 11.13. The Greenseams program will continue in concert with the recommendations from the RWQMPU.s
11.7 Best Management Practices
It is recommended that the MMSD continue to fund the development and implementation of best management practices (BMP) projects that demonstrate the benefits of BMPs on managing the volume, rate, and quality of stormwater runoff.
A specific BMP demonstration project for nonpoint stormwater bacteria reduction is included as a part of the Recommended Plan. The BMP technologies selected for the demonstration project(s) should be studied for effectiveness and feasibility to implement on a watershed-wide basis. The status for the BMP Plan is summarized in Chapter 10, Recommended 2020 Facilities Plan, Table 10-8. The costs for the demonstration projects are expected to be minimal and therefore can be included in the annual operating budget.
r Further details are presented in Chapters 8 and 9 of this report. s Further details are presented in Chapters 8 and 9 of this report.
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11.8 New Milwaukee Metropolitan Sewerage District Programs and Policies to be Implemented As presented in Section 10.7, of Chapter 10, Recommended 2020 Facilities Plan, new programs and policies are recommended for implementation as a part of the 2020 FP in order to support the other elements of the Recommended Plan that are not specific to the Wet Weather Control Plan (WWCP). The costs to implement these programs and policies have not been determined but can be incorporated into the annual operating budget. A recommended schedule for implementation of these programs and policies is presented in Table 11-4. More details regarding these programs and policies can be found in Chapter 10, Recommended 2020 Facilities Plan. The recommended initiation date in the table represents the date the program or policy should be initiated or formulated for subsequent implementation.
TABLE 11-4 NEW MILWAUKEE METROPOLITAN SEWERAGE DISTRICT PROGRAMS AND POLICIES -
RECOMMENDED IMPLEMENTATION
Recommended Completion Date
2007 2012
2. Policies to Support RWQMPU 2007 2008 3. MMSD Chapter 13 Revisions 2007 2008 4. Opportunistic Sewer Separation
Consideration 2008 Ongoing
5. Educational Outreach Program 2008 2020 6. Geographic Information Technology (GIT)
Vision Ongoing since 2004 2010
7. Implement Recommendations from Information Management Report
2008 2010
11.9 Existing Milwaukee Metropolitan Sewerage District Programs and Policies to be Maintained
As presented in Section 10.8 of Chapter 10, Recommended 2020 Facilities Plan, a set of existing MMSD programs and policies are recommended for continuation as a part of the 2020 FP. The costs to implement these programs and policies have not been determined, but because they are ongoing programs, the costs are assumed to be absorbed into the annual operating budget. Table 11-5 summarizes these programs and the recommended enhancements to these existing policies and programs. These are all existing programs and policies and therefore implementation is currently underway in 2007 and should continue.
Program or Policy Recommended Enhancement/ Reason for Implementation
1. Monitor USEPA
Blending Policies
Continue to monitor USEPA blending policies to determine if any changes in policies will
impact MMSD facilities or operations.
2. Long Term Control
Plan (LTCP) Complete LTCP as required by permit. All aspects of the final LTCP will be implemented.
3. Water Quality Sampling
Consider additional monitoring parameters including biological indicators and other pathogen
indicators that will support identifying the most cost effective stormwater best management
practices (BMPs) and track performance of 2020 FP/ RWQPMU recommendations.
4. Bacteria Research
and Pathogen Source
Further enhance bacterial, algae, and pathogen studies to improve beaches, quantify risks,
and protect public health.
Program Support
Expand studies of illicit sanitary/storm sewer connections in order to identify high priority
areas and make recommendations to address the problems.
6. Water Conservation Continue to support water conservation through “Every Drop Counts” program.
7. Bacteria Measurement
Continue to participate in national efforts to assess different bacteria measurements and the
potential impacts on JIWWTP and SSWWTP disinfection.
8. Stormwater BMP
Implementation
Continue to support research and implementation of stormwater BMP techniques and
programs.
Stations
Support adding flow monitoring gauges at Honey Creek, Little Menomonee River, and Root
River (at Grange Avenue) as part of USGS Phase II of Corridor Study.
10. Maintain 2020
Modeling Tools
Maintain modeling tools developed during the 2020 FP so that they can be used for
preliminary engineering studies, other future planning tasks, and the evaluation of wet
weather events.
Rulemaking
Continue to monitor and participate in development of SSO rulemaking in order to anticipate
possible impacts of rule changes on MMSD’s facilities and operations.
12. Monitor Air Emission
Regulations
Continue to monitor the development of air emission regulations in order to anticipate the
impacts of rule changes on MMSD’s facilities and operations.
13. Monitor Research
Products
Continue to monitor ongoing national research on emerging contaminants, but also continue
to support collection of pharmaceuticals as part of MMSD’s educational programming and
Household Hazardous Waste Collection Program in order to reduce pharmaceuticals from
entering the local waterways.
14. Maintain All Other
Continue existing Household Hazardous Waste Collection Program, Stormwater Reduction
Program, Stormwater Disconnection Program, and Industrial Waste Pretreatment Program to
support water quality improvements. Also continue with Pollution Prevention (P 2 ) Initiative to
encourage reduction of pollution at the source.
15. Watercourse Policy Continue the policy that supports the watercourse projects.
USEPA = United States Environmental Protection Agency
USGS = United States Geological Survey
TABLE 11-5
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11.10 Existing Milwaukee Metropolitan Sewerage District Operations to be Continued As presented in detail Section 10.9 of Chapter 10, Recommended 2020 Facilities Plan, the 2020 FP recommends the following existing MMSD operations continue to be funded due to their importance in maintaining the watercourses. The specific costs to implement these existing operations have not been determined but because they are ongoing they are assumed to be incorporated into the annual operating budget.
♦ Jones Island Wastewater Treatment Plant Wet Weather Blending (in accordance with permit)
♦ Skimmer Boat Operation
• Debris Removal from Natural or Concrete Channels on Milwaukee Metropolitan Sewerage District Property
• Vegetative Maintenance on Milwaukee Metropolitan Sewerage District Property
• Structural Controls Repairs
• Mechanical/Electrical Controls Repairs
• Concrete and Natural Channel Repairs
11.11 Milwaukee Metropolitan Sewerage District Committed Projects The Recommended Plan includes all the MMSD committed projects that were either identified in the 2002 WDNR Stipulation (but were not yet complete as of the end of 2006) or that were already in construction and therefore considered committed. The list of these projects is presented in Tables 8-1 and 8-2 of Chapter 8, Common Facilities, Programs, Operational Improvements and Policies for the Recommended Plan. The total cost for the committed conveyance and treatment projects is approximately $528 million ($81.8 for treatment projects and $446.2 for conveyance projects) and the cost for the committed watercourse projects is approximately $161 million. These dollar figures represent the total original project costs. As these projects are completed, the remaining costs generally will decrease until the project is finalized. All these projects are committed by MMSD to be completed.
11.12 Impact of Recommended Plan on Staffing Requirements The implementation of the recommendations of the 2020 FP may require the addition of a small number of MMSD staff. Three to five additional staff positions may be needed to analyze the data that is being collected as a part of the WWPFMP.
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11.13 Financing Plans
11.13.1 Introduction By statute, MMSD is responsible “to project, plan, design, construct, maintain and operate a sewerage system for the collection, transmission and disposal of all sewage and drainage of the sewerage service area…” Wis. Stat. sec. 200.31(1). The MMSD has authority to raise funds for both its capital improvements program and O&M responsibilities. Capital financing decisions made by MMSD, including the adoption of the capital budget, changes to that budget, and decisions to borrow against taxes, require a two-thirds approval vote from all MMSD Commissioners (Wis. Stat. sec. 200.27(2)). The 28 satellite municipalities in MMSD’s planning area own, operate, and maintain their own local sewer collection systems. They each have the authority to raise funds for capital improvements and O&M needs for their own respective collection systems.
The MMSD developed two financing plans to reflect the two different (AIS and FIS) implementation schedules. The capital expenditures to implement the AIS and the FIS will be funded as capital improvements through MMSD’s ad valorem property tax system. With regard to the individual projects recommended in this 2020 FP, the financing plans include the estimated costs and estimated schedules for both the AIS and the FIS. Each project will be reviewed for potential use of state and federal, grant and loan programs. A summary of these programs is discussed in the next two sections.
11.13.2 State of Wisconsin Clean Water Fund Program The planning, design, and construction work needed for wastewater infrastructure is generally eligible for a low-interest, 20-year loan from the Clean Water Fund program. The current interest rate for projects necessary to maintain permit compliance is 2.475%. The interest rate is adjusted with each state bond issuance for the Clean Water Fund Program. Based on the proposed state biennial budget, sufficient funds are available to help fund projects scheduled to begin construction during the next two years.
The Wisconsin Departments of Administration and Natural Resources jointly administer the loan program, which has previously provided financial assistance to the Milwaukee Water Pollution Abatement Program (MWPAP).
11.13.3 Direct Federal Line-Item Grant The U.S. Congress has provided federal, site-specific, line-item grants for wastewater projects for each of the last seven years. The grants come from the State and Tribal Assistance Grant portion of the USEPA budget. The Wisconsin Clean Water Fund Program also receives its USEPA capitalization grant from this same budget. Through 2006, MMSD has received $11.8 million in USEPA grant assistance for its Harbor Siphons Project. The long-range financing plan for the 2020 FP assumes the continuation of direct federal line-item grants for MMSD construction projects. This funding source has yielded more than $3 billion in direct wastewater- related grants to agencies and cities in 25 states since 1992.
11.13.4 Financing Plans and Impact to Users The MMSD has for a number of years prepared a six-year capital improvement program and long-range financing plan as part of its annual capital budgeting process. As part of the 2020
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planning effort, MMSD has developed two different long-range capital financing plans for the period 2008 through 2020. The AIF Plan reflects the implementation of the AIS and the FIF Plan reflects the implementation of the FIS. These plans allow MMSD to create a picture of its long-term financing and resource needs. The purpose of the AIF and FIF Plans is to help understand, in a general sense, the level of financing necessary to support a given capital improvement program. As mentioned previously, the financing plans include not only the capital projects presented in the AIS and FIS but also the other recommended FPOPs presented in Chapter 10, Recommended 2020 Facilities Plan.t The financing plans developed by MMSD for implementation takes into account the impact of inflation.
The cash flows that reflect MMSD’s financial plans for both the Full and Adaptive Implementation Schedules are shown in Appendix 11A. The AIF Plan reflects a deferred principal payment structure on the upcoming refunding of MMSD’s Series 1997A Bonds. The deferred principal payment structure on the refunding enables MMSD to begin $30 million of work between 2008 and 2012 on the ISS Rehabilitation Project and Jones Island Biosolids Project, for which sufficient funding would not be available under a level payment structure refunding.
A summary of the estimated costs is presented in the tables below. The AIS represents estimated costs through 2020 based upon slower growth in population and land use than assumed in the 2020 FP. This adaptive plan is reasonable because it proceeds slowly on costly new expenditures to prevent building facilities that may not be needed before 2020. The need for many of the recommended facilities in the 2020 FP is dependent upon regulatory issues, gathering of additional data, preliminary engineering work, and population growth. All of these factors will influence the AIS, which will be changed as needed.
The FIS represents estimated costs assuming all growth occurs by 2020 as assumed in the 2020 FP revised baseline population estimates.
The impacts of the costs shown in Tables 11-6 and 11-7 on the average household in the MMSD service area can be summarized as follows:
♦ The AIF Plan will result in property tax rates that are unchanged from the rates projected by the MMSD for the 2007 to 2012 Capital Financing Plan presented and approved by the MMSD Commission in October 2006 as part of the 2007 Capital Budget (4.7% increase annually). The AIF Plan accomplishes this by delaying some projects that were in the 2007 to 2012 Financing Plan and by refunding and restructuring a portion of outstanding MMSD debt.
♦ The FIF Plan will result in property tax rates that are approximately 20% higher than those rates projected by the MMSD for the 2007 to 2012 Financing Plan (8% increase annually to 2018). These increases are not expected to begin until 2009. The FIF Plan includes all 2020 Facilities and does not delay any projects which were in the 2007 to 2012 Financing Plan. The FIF Plan also refunds a portion of outstanding MMSD debt.
♦ The incremental user charge (operation and maintenance) cost impact on the average household is about $2.00 per year (starting in 2014) for the AIF Plan and about $5.00 per year (with $2.00 in 2014 and the remaining $3.00 in 2020) for the FIF Plan.
t These additional FPOPs may be funded at different levels in two different financing plans (AIF vs. FIF Plans).
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CAPITAL COSTS, $ MILLIONS1,2 FOR 2020 FACILITIES PLAN ELEMENTS ONLY
Component Adaptive Implementation
Plan3 Full Implementation Plan4 Wet Weather Control Plan $123 $339 Interim Biosolids Plan 153 270 Other Recommendations 43 43
Totals $319 $652
1) These costs are MMSD only and do not include costs for communities to control I/I. 2) These costs are estimated in 2007 $ and are +50/-30% estimates. 3) As presented to MMSD Commission on 4/16/07, and modified slightly to reflect subsequent refinements. 4) As presented in the Facilities Plan Report Chapter 10 – Table 10-1 and in the Executive Summary – Table ES-1. Note that those
tables also include a separate category for Preliminary Engineering at a total cost of $2.8 million. In Table 11-6, all of the Preliminary Engineering is included in the three categories presented.
TABLE 11-7 ESTIMATED YEARLY FINANCIAL IMPACT ON TYPICAL CUSTOMER1
FOR ALL MMSD SPENDING 2008 THROUGH THE YEAR 2020
Adaptive Implementation Plan Full Implementation Plan Property Tax3 Property Tax4
Assumption1 2008 Annual
User Charges5
$150,000 Value Home2 $201 4.7% $349 $85 $201 8% $435 $88 $300,000 Value Home2 $402 4.7% $698 $85 $402 8% $870 $88
1) The charges estimated above apply to a home in a member community. 2) Home value assumed to increase at the rate of 4.8% each year. 3) District equalized value growth rate assumed to be 4.8% per year in the adaptive implementation plan. Seventeen percent of
these costs (as shown in Table 11-6 for $319 million) are for the 2020 Facilities Plan. Other costs are for ongoing capital needs. 4) District equalized value growth rate assumed to be 5.67% per year in the full implementation plan. Twenty-eight percent of these
costs (as shown in Table 11-6 for $652 million) are for the 2020 Facilities Plan. Other costs are for ongoing capital needs. 5) User charges for recovery of O&M costs averages about $83 per household in 2007; thus the increase expected for the Adaptive
Implementation Plan is about $2 per year and for the Full Implementation Plan is about $5 per year. The estimated cost increases for user charges do not include the expected increases due to the expiration of the existing operating contract in 2008.
11.14 Implementation of Combined MMSD 2020 FP and SEWRPC RWQMPU – Implementation of a Watershed Approach
11.14.1 Introduction As discussed in Chapter 10, Recommended 2020 Facilities Plan, MMSD and SEWRPC formed the WQI partnership in 2002 through the execution of the Memorandum of Understanding (MOU), which included the WDNR. The WQI partnership used the USEPA endorsed
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“watershed approach” to assess the greater Milwaukee watersheds (GMW) on a holistic basis. The watershed approach was followed in the preparation of two integrated documents:
♦ The SEWRPC RWQMPU, or Section 208 Plan, for the GMW
♦ The MMSD 2020 FP, or Section 201 Plan
As provided in federal and state regulations,u a Section 201 Plan, such as the 2020 FP, must conform to the approved RQWMPU.v Similarly, the applicable recommendations of an approved facilities plan are required to be used whenever possible in a Section 208 Plan to determine an urban area’s wastewater treatment needs.w The watershed approach, as manifested in the MOU between SEWRPC and MMSD, provides the necessary coordination and integration between the 2020 FP and the RWQMPU during the planning effort. The two plans were prepared using the same data and analytical models, joint public involvement, and a shared technical team.
The shared purpose of the MMSD and SEWRPC plans is to identify water resource impairments and their causes, and to recommend cost effective actions to manage, mitigate, or eliminate existing and potential impairments. Because the SEWRPC effort encompasses entire watersheds, it necessarily extends well beyond the MMSD planning area. Given their reliance on one set of scientific findings, the plans are closely integrated and are intended to provide a sound framework for the improvement of water quality.
Both plans clearly show that significant improvements to water quality can only be achieved through regional implementation of extensive measures to reduce pollution from nonpoint sources.x The WQI invested significant time and effort into gathering and evaluating water quality data for the GMW; as a result, MMSD and SEWRPC concur that the most effective way to manage the next phase of improving water quality in the GMW is through continued implementation of the watershed approach. Implementation necessarily involves translating science into action, with measurable, positive results.
The need to address overall integrated water resources in a holistic fashion has gained increased recognition in the greater Milwaukee area. This need has been discussed in a recent report sponsored by the Milwaukee Public Policy Forum.(2) This report discusses various ways to translate a holistic integrated water resources approach into actions and results. This study and others have pointed to the need to develop methods to promote:
♦ Preservation and improvement of water quality
♦ Preservation and improvement of water related environmental corridors and habitat
♦ Continued acquisition and analysis of data to track progress and chart future pathways and actions
A watershed management value added analysis workshop held by MMSD from March 7-9, 2007 provided input on watershed management from national watershed management experts, USEPA
u Clean Water Act and the Wis. Admin Code NR 121.05(1) (g). v In accordance with NR 110.08(4). w In accordance with NR 121.05(1) (g). x See SEWRPC Planning Report No. 50, A Regional Water Quality Management Plan Update for the Greater Milwaukee Watersheds, Chapter X for further discussion.
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and the WDNR.y Based on input obtained during this workshop and through other communications, the WQI concluded that efforts leading to a watershed-based permit could provide an effective framework to achieve long-term, cost-effective water quality improvements for the GMW and ultimately for Lake Michigan.
Developing watershed-based permits (in lieu of traditional individual source permits) is a relatively new concept initiated by USEPA that rethinks traditional National Pollutant Discharge Elimination System (NPDES) permitting in an attempt to attain better results in water quality improvements. In traditional permitting, individual sources are regulated without regard to the other sources of pollution within a watershed. In the watershed-based permitting approach, an NPDES permit (or its state equiv