Draft, February 2007
Why is Chester’s wastewater issue so important to our future?
Anyone attending a Water Pollution Control Agency meeting at the Chester Meeting House over the past year would have to have no soul not to be struck by the human and political drama of the debate, both real and suppressed. The electricity of real human passion, the dance of facts and ideology, all the frustration and idealism of the search for truth, and in all of its glory in the peaceful little village near the forests of Cockaponsett. After lengthy debate, controversy and frustration, only the barest of facts regarding Chester’s wastewater issue are clear to the citizens and others who will be affected by the decisions now being made about Chester’s future development. Why is this matter so difficult to understand?
A choice can only be made freely and rationally if you know what your choices are, and what foreseeable consequences they can be expected to bring with them. Otherwise, what appears to be freely chosen is a blind gamble, or a naïve submission to uninformed opinion. When choices have to do with the future, not of an individual, but of a community of people, a landscape with a history, and a larger world of countless beings living in delicate and robust interdependency, the stakes are much higher. Often the facts are more difficult to discern in such cases because there are more ramifications, more interests involved, more costs to consider, and especially, more important opportunities not to overlook. Here as elsewhere, the bigger the problem, the bigger the opportunities for innovation.
As a crucial basic infrastructure of our rural-suburban environment in Chester, wastewater treatment issues are a decisive component of our decisions regarding land use; as such, wastewater issues need to be informed by the best science, by all of our values, and by the values of everyone affected by these momentous choices. Life in Chester, as in every other small affluent town in North America, is heavily water-intensive. A single flush by a standard American toilet uses more water than millions of families elsewhere in the world use in an entire day. Life here is also chemical-intensive, meaning that our wastewater is likely to contain thousands of chemical agents of unknown toxicity. Combine high consumption with a steadily increasing population and you find yourself at the inextricable crossroads that Chester is currently facing. How we decide on this key issue will likely have large ramifications for the way our town develops in the future; ramifications which could help or hinder the resilience and vitality of our local economy and the health of our community.
What is our current situation?
Chester is presently facing a 15 year old consent order issued by the Connecticut Department of Environmental Protection (DEP) for “polluting the waters of the state.” More specifically, the consent order concerns the failure of a municipal septic system, technically, a ‘sub surface disposal system (SSDS)’ located under the Maple Street parking lot, to meet the discharge standards required of its permit.
The legal impetus to respond to our wastewater issue in town is a good thing. Before the passing of the Clean Water Act in 1972, otherwise well-intentioned individuals, municipalities and corporations used the Connecticut River as a dump, causing vast damage to one of the most spectacular, internationally-renown river ecosystems in the world. Now with salmon and shad returning along with the vitality of the river’s many human waterfront communities, many citizens are alert to the value of clean water and the value of regulatory bodies like the DEP. However water is not the only natural resource at stake in this issue.
The consent order does not specify how the town should resolve its wastewater problem. Instead, that decision rests in the hands of Chester’s local Water Pollution Control Agency (WPCA), which was legally empowered by the state for precisely this purpose. With its mission to protect “the long term health, safety and cleanliness of the groundwater of Chester,” the WPCA alone is authorized to construct and operate a sewerage system. As such it has the power to legally force a resident not otherwise inclined to connect to the system and can require the town government to levy a tax to pay for the construction. As such, WPCA has a unique power to determine town development, and therefore a unique responsibility to be richly receptive to both fact and public opinion.
Now according to Chester’s WPCA board, the facts surrounding Chester’s wastewater issues in the center, while confusing, are now well understood. While a possible option to build an additional SSDS site near the Chester Fair Grounds is still under consideration, currently the most likely scenario is to construct a sewer connection to the water pretreatment plant in Deep River. As they put it in a recently released statement, the plan calls for
"…expansion of the current sewer system to include homes and businesses in the immediate area with failing or inadequate systems, and properties where septic repair or installation would likely not comply with the current Public Health Code. This expanded Sewer Service Area would then be connected to Deep River’s system for treatment in Deep River’s Sewerage Treatment Plant."
Which residents are directly affected by this plan? The initial consent order pertains only to the current users of the Maple Street SSDS. But when the DEP discussed the matter with the WPCA during an April 2006 meeting, the WPCA board agreed to expand the green zone to include an additional 143 properties with questionable discharge levels. To date, no properties have been voted off of the green zone. While the WPCA has not voted, and has explicitly stated that it does not intend to vote, to expand the sewer to any specific area beyond the proposed village solution, they have certified that the properties of the expanded green zone are noncompliant, therefore giving the DEP the power to mandate abatement of pollution.
Prices and costs
The price for connecting up the original properties utilizing the Maple Street SSDS to the Deep River facility is projected at between $2.1 million and $2.5 million. A system which was expanded to include the additional 143 properties would be more costly. The WPCA is currently working through a variety of scenarios to allocate the cost, and more definite numbers are expected to become available in the early part of 2007. But there’s no question: sewers are expensive infrastructure to build, operate and maintain. The WPCA believes that it is a price worth paying, and they are backed up to an extent by conventional opinion about how best to deal with the wastewater issues that inevitably accompany economic development. For one, while expensive, they offer centralized oversight for controlling ground water quality, rather than leaving individuals and town responsible for monitoring their waste composition and discharge rates. Secondly, as a capital-, energy-, and labor-intensive project, sewer construction and operation generates economic activity, creating work for contractors and new users for treatment plants. Thirdly, as a relatively large-scale operation, the price of sewerage is competitive only given its larger economy of scale. Sewerage entails expanding treatment capacity beyond the immediate needs of a municipality, thus creating room for future growth. Indeed, wastewater discharge limits effectively set limits on how quickly, and in what ways, a town will develop and the construction of a centralized sewage system inevitably serves as a spur to future economic development.
However, money spent is not the same as value received. Large-scale infrastructure investments do not always come without negative unintended consequences. If we can expect to pay $2 million just to build the initial physical system, what other costs might we foresee down the road? Moreover, are there external costs we need to consider? Are there things about our natural and social environment here in Chester whose value could be inadvertently diminished by not being factored into our accounting?
These are difficult questions to raise, but they are essential to address if we are going to make the most informed decision possible. In a 2004 special report prepared for the US Environmental Protection Agency (EPA), the Rocky
Mountain Institute (RMI) made such thinking one of its premises:
"The premise of this report is that communities need whole-system, lifecycle analysis of their wastewater system choices to make the right decisions. This means that all costs and benefits of each option must be taken into account, inside and outside the conventional bounds of infrastructure systems, and from initial capital investments through operation and maintenance to eventual rehabilitation or replacement of an aged system."
An accounting of such external costs might begin with the cost of pretreatment at the Deep River Sewage Treatment Plant, an energy-intensive process requiring a monthly fee. Deep River is only the first step, where the effluents are compressed and given a preliminary treatment before being hauled daily to the Mattabessett District Sewage Treatment Plant in Cromwell. There, waste from Deep River is mixed with toxic industrial effluents from elsewhere in the state, and then chemically treated, compressed and dried into a solid material known as sewage sludge.
Sludge is a very serious problem and there is currently no good solution to deal with it. This issue is obscured when we focus on water quality and forget about where the poisons removed from the water end up. To understand how serious a problem it is, think for a moment about what happens when you mix hazardous wastes from all over the state into one noxious brew. As Abby Rockefeller of the ReSource Institute for Low Entropy Systems (RILES) puts it, the more successful the treatment is, the more destructive the end product is going to be.
"It is in the nature of sewering and sewage treatment to compound environmental problems in the process of moving sewage and in attempting to remove from sewage the pollutants it carries… Sludge is the residue created in the attempt to retrieve clean water from sewage. The water is to be made clean by extracting from it the vast array of pollutants which it is the very purpose of sewers, hence sewage, to receive. The more thoroughgoing the attempt to clean the sewage, the more thoroughly noxious the residue— the sludge—will be. It is the very purpose of sewage treatment to make it so. And in this purpose, sewage treatment succeeds: it creates a mix so dense with the noxious as to be a very hazardous material."
As a hazardous waste, sewage sludge cannot be monitored, regulated or remediated. Containing upwards of 80,000 known chemical agents, unknown numbers of biological organisms, virulent and resistant strains of disease organisms as well as synthetic pharmaceutical drugs of every kind, sludge has a chemical make up which is constantly changing, too complex to monitor and too toxic to simply regulate. Since dumping sludge into the ocean is no longer permitted, the Mattabessett plant incinerates the sludge, and then buries the toxic ash in underground tanks in Berlin where it must be permanently monitored to avoid leakage. Incineration, however, dramatically affects air quality, and in ways which are disproportionately paid by people living in the low-income neighborhoods where incinerators are invariably located.
This is not speculation but a concrete pressing issue. After dangerous levels of mercury were found at the Mattabessett site, State representative James O’Rourke of Cromwell introduced a bill calling on the DEP to study alternatives to sewage sludge incineration. In fact, it was only after being sued by the state Attorney General and the DEP that the Mattabessett Plant admitted in 2002 that it had released an estimated 60 pounds of mercury into the Cromwell environs and agreed to pay fines and submit to more rigorous pollution control standards. Mercury is a danger to pregnant animals of many different species, including humans. It is the reason why pregnant women should not eat fish caught in the Connecticut River and why various species of birds, for example, ducks which feed on mercury-laced barnacle larvae, are on the endangered species list.
Independently of the very serious questions about sludge disposal, the long-term financial sustainability of centralized sewage treatment plants in Connecticut is unclear. Electricity rate hikes, increasing maintenance costs, and declining funding for critical plant improvements will force treatment facilities to pass these costs onto customers. Federal money that had been available in the past to help offset the maintenance burdens is slated to disappear entirely by 2010. Such pressures will also naturally create incentives to find new users to connect to the system in order to shift cost burdens. The extent to which the DEP is looking to Chester to help bailout ailing sewer-plant infrastructure beyond Deep River is a natural question. The state DEP is surely aware of the long-term unsustainability of this system. In their State of Connecticut Solid Waste Management Plan amended in December 2006, they call for a new approach to waste management. As they put in the introduction to the plan,
"We need to shift away from a "throwaway society," toward a system that promotes a reduction in the generation and toxicity of the trash we produce and dispose through increased source reduction, reuse, and recycling. We must further ensure that what waste remains, will be disposed in an efficient, equitable, and environmentally protective manner."
This would suggest that the problem is not primarily with sludge disposal but rather with a system that necessarily produces sludge. Not only do central sewer systems compound the toxicity of effluents, making whatever recyclable resources they may contain unusable, they encourage people to be mindless about what they are putting down their drains. As Rockefeller puts it,
"It is the reality that as long as there are sewers and waterborne carriage of wastes, and as long as the disposers and the destination can be anonymous, “getting rid of” whatever can be put down toilets and drains will be gotten rid of in that way."
Is there a sustainable alternative to sewerage?
In a policy recommendation that supports the stated aims of the DEP, the ReSource Institute suggests, as an alternative to sewer construction, the use of “biologically-based on-site pollution prevention and resource recycling technologies.” The reasoning follows from a whole-systems perspective on wastewater treatment. Natural systems run on daily sunlight, not expensive and dirty fossil fuel-based electricity, require no expensive built infrastructure and are intrinsically environmentally-friendly because they recycle everything. Moreover, while centralized systems disincentivize user responsibility, onsite systems motivate users to be aware of what they putting into the ground, and facilitate the monitoring and regulation of effluents by distributing pollution control oversight. There are other benefits to keeping water treatment local. Again the ReSource Institute:
"Pollution problems can first be dealt with locally, at their source, where it is possible to focus on the worst polluters and actual failures. Real capital and maintenance costs are always much less for on-site systems than for central sewering and treatment. And with on-site treatment, development of communities is not bound to the rigid grid of sewer lines. And most importantly, the problem of water pollution becomes solvable instead of merely movable."
While septic systems utilizing aeration technologies still have to be pumped periodically, and therefore contribute to the sludge problem, a surprising amount, over 95%, of the organic material is broken down into nutrients which are composted naturally back into the soil in the leech field. Hence the volume of ‘wasted’ waste ending up at a centralized sewage treatment plant like Mattabessett is a small fraction of the waste ending up there under a centralized sewer connection.
Is such an option available to Chester? According to Chester’s WPCA board, the answer is unfortunately no. Anyone following this contentious issue in town will be aware of the SoilAir technology that the town installed in September 2004 at the Maple Street SSDS site. SoilAir is a biologically-based onsite wastewater technology developed by a progressive engineering think tank Geomatrix to offer a low-cost, environmentally-friendly solution to improving the performance of failing septic systems. The technology works to increase the hydraulic load and filtration processes of septic leach fields by aeration. Mimicking nature’s own ways of filtering water and maintaining hydraulic flow, SoilAir injects oxygen into the soil, increasing the activity and populations of microorganisms in the soil that break down the organic matter, including harmful pathogens contained in the effluent, thus unclogging the flow of wastewater through the leech field. Involving only a high-pressure blower, some pipes and a microprocessor, the technology is very cheap. In comparison to the $2+ million figure for a sewer connection to Deep River, an April 2006 proposal by Geomatrix to install and run the SoilAir system for 18 months would cost the town approximately $87,000.
In an April 2006 report signed by the First Selectman as well as the WPCA, the town engineering firm, Jacobson and Associates, suggested that SoilAir could solve the problem, given the demonstrated ways the system had substantially reduced the hydraulic load and concentrations of contaminants (specifically, nitrogen) in the discharged water. According to David Potts, the environmental scientist who developed the technology, the system was running so productively between September 2004 to 2005 that eight of the twelve leeching galleries were shut down and allowed to go dry, allowing the system to function well with considerable 2/3 excess hydraulic capacity. However, in a recent statement explaining why the SoilAir technology is not a “long-term solution,” the WPCA argues that the onsite technology does not meet the DEP’s parameters for acceptable discharge rates and nutrient levels. While the current system has documented flows of over 20,000 gallons per day (GPD), and the Soil Air proposed limit is 15,000 GPD, the DEP is stipulating an average flow level per day of 6,700 GPD and a maximum allowable flow of 10,000 GPD. Moreover, while nitrogen levels at a key monitoring well dropped 40% while SoilAir was in operation, the WPCA argues that the total nitrogen concentration at the point of environmental concern - an unnamed tributary to Chester Creek - has never been within the 10 mg/l required by the DEP. Hence, their conclusion: “There is no $85,000 solution to this 16 year old problem that will ensure the safety and cleanliness of the groundwater in the village. We wish it were that easy.” Case closed?
While we need to protect the quality of our ground water in Chester, we also need to look at the whole equation so that in attempting to improve one part of our environment we do not end up producing even greater harm to another part somewhere else at a later time. Given the severe environmental costs and financial uncertainties involved with the sewer option, we need to be reasonably certain that meeting these rigid DEP requirements is so absolutely essential to our local well-being that the larger costs of sewering are justified. Are there any reasons for doubting this? In fact there are. Discharge rates for municipal septic systems, for example, are not set in stone but flexible, based on an overall assessment of the hydraulic circumstances surrounding the systems. We know there are other sites in the state that process more gallons per day than Chester on the same or slightly smaller footprint. (For example, the Saybrook Point Marina in Old Saybrook which uses a DEP-approved SoilAir system to process 22,000 GPD. See http://www.chesterct.com/Ct_locations_using_Soil_Air_DEP_letter.pdf) The DEP routinely increases discharge permits at the request of a town, provided there is good engineering data to back up the request. When questioned on this issue by concerned citizens at a September 2005 meeting, DEP Deputy commissioner Betsey Wingfield implied that the DEP would permit what the town’s WPCA was willing to advocate for and was open to a wide range of possibilities. This makes sense, given that the DEP is surely aware of the unsustainability of status quo waste management practices in Connecticut. Of course we do not want to pollute our own waters in Chester, but it’s not clear that the data do suggest we are in fact polluting the waters. As noted above, the April 2006 engineering report by Jacobson and Associates recommended SoilAir, noting that the system had managed to alleviate the hydraulic load on the Maple Street SSDS with 2/3 spare capacity. While failing to meet the stipulated 10 mg/l level for nitrogen concentrations, the SoilAir did reduce concentrations to 10.1 mg/l: within a hair-splitting .1 mg/l of the DEP standard. (NOTE: It is worth noting that this well is approximately 80 feet from the true point of concern, which is the property line as it intercepts the ‘no name’ stream at the edge of the Maple Street parking lot property with the adjacent property. The actual measurements for the total nitrogen at the true point of concern have not exceeded 10 MG/L in the past five years per the Jacobson reports. For unknown reasons, the DEP has shifted the point of concern from the downstream monitoring point to monitoring well no. 102.) Might these parameters be revised in light of the large environmental and financial benefits to be gained by staying with a biologically-based onsite technology like SoilAir?
Unfortunately, WPCA board has either not looked into these large costs of sewerage, or have not shared their analyses completely with the public. To be fair, the WPCA is on the side of conventional wisdom in opting for the sewer system option. Such thinking focuses on protecting local groundwater quality above all else, sees the larger (state-wide) economic benefits of a capital- and energy- intensive engineering project, and is wary of giving too much responsibility to municipalities to look after their own waste issues. Moreover, constructing a sewer connection in town opens up much larger room for economic development in Chester Center. In contrast, the SoilAir system allows for a moderate level of growth, approximately 50% to 100% in the village before additional wastewater capacity would need to be contemplated.
This raises a very key question: do we want our desired rate and style of development in town to be determined by our choice of wastewater system, or vice versa? According to the RMI report cited earlier, this is one of the gravest pitfalls to avoid on the question of municipal wastewater management policy.
"It is essential that community planning occurs, not just wastewater planning. And community planning ideally should precede wastewater planning. Too often community “process” has been conducted solely to get buy-in to a technology. That is a recipe for disaster, as many case studies show."
For instance, not only does a sewer connection build in over-scaled treatment capacity, it is capacity with no natural limit, just continuous flow. This facilitates growth in ways which have no direct relationship, hence no direct responsiveness, to the local natural and social environment. That is to say, sewer connections quite naturally incentivize styles of development that are not as receptive to the social and natural health and well-being of a community as they ideally could be. In an extraordinary town that now finds itself located in the richest county (yes, Middlesex is now no. 1) in one of the richest states in the country, it would be naïve to dismiss the possibility that commercial interests might well take advantage of the subsidized growth potential offered by sewerage to develop the town according to their own ideas of value.
This brings us to the question we started with: the importance of the wastewater issue for the town’s future. Some citizens of Chester would like to see more conventional economic development in town, others less or none at all. A small but growing group of folks in town have a vision of Chester as a sustainable local economy: a fusion of the old self-sufficient factory town and gardening community with the new creative energies of the town’s artists, craftspeople, professionals and nature-lovers. Ideally, a consensus could be reached about what the level and kind of growth ought to be, based on a truly shared vision of how we want the town to mature in the future. Thus it is imperative not to make decisions about infrastructure that will lock us into a form and rate of development not informed by our best shared dreams. While large-scale wastewater solutions like central sewerage have the benefits noted above, they also tend to stimulate growth, if only to pay for their cost, and in ways which easily overwhelm the best intentions of town planners. This is undoubtedly why the town’s current Plan of Development from 1995 lists sewer avoidance as one of its main public health goals. (“Continue to pursue an active sewer avoidance program, including public education, on-site inspections, a systematic maintenance and pumping program for on-site sewage disposal systems and economic disposal of septage sludge.”) Small, appropriately-scaled, low-cost technologies are oftentimes beautiful, as our First Selectmen Tom Marsh demonstrated admirably with his support for a small scale solution to the Wig Hill bridge problem, going so far as to turn down federal grant money to build a larger bridge: "It was an issue of government waste, a big bridge going over a little creek." While the hard work of Chester’s WPCA board needs to be acknowledged, they also need to be held accountable for making decisions affecting something that they have no mandate and no special knowledge to decide: the future of Chester.
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