|
| Author
|
Post |
 
|
|
untanglingwebs
El Supremo
|
Detroit:
Genesee's application fails to properly address the option of utilizing DWSD's existing water supply system, which it is required to do by Sec. 5.b of the Compact. GCDC fails to note that the DDWSD water supply system is fully capable of meeting all of its needs and that DWSD hs spent millions of dollars to address its request for a backup supply line. As such,the new withdrawal request is an unnecessary duplication of existing resources. Clearly,the proposed new withdrawal is inefficient with respect to the use of existing resources.
O'Brien:
To avoid requesting a withdrawal permit, Genesee requested purchase of untreated Lake Huron water from DWSD. DWSD said no. Now DWSD reiterates that our application is for an increased withdrawal. If DWSD believes that we have ownership of a portion of the withdrawal capacity on their system,we are willing to withdraw our application for a new withdrawal and willsubmitan application for a relocation of the withdrawal. You cannot work both sides of the issue. Our permit is a new withdrawal. |
|
|
Wed Apr 25, 2018 12:32 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
Section 2(xi) of the application states that DWSD's system is not acceptable, using the following language:
"The Lake Huron water supply currently in place does not meet the requirements for reliability to the region. In the event of a failure on a single water supply pipeline that is servicing the region, several hundred thousand customers will be without a potable water supply. Such an interruption of service has already happened and resulted in closing of businesses, cancellation of surgical procedures, compromise of home dialysis,and issuance of boil water notices."
This statement is remarkable for what it leaves out. In recent years, DWSD has held a number of meetings with GCDC and Flint officials in an effort to develop plan for providing additional reliability to them. The result of this effort has been DWSD's commitment to build a new water main from its Orion Pump Station in Oakland county to serve Flint and GCDC. DWSD does not understand why GCDC ailed to mention this in its application. |
|
|
|
Wed Apr 25, 2018 1:02 pm |
|
|
untanglingwebs
El Supremo
|
O'Brien:
Since the construction of the existing pipeline in 1965, the City of Flint, Genesee County, the then MDPH, and MDEQ have been requesting a second pipeline of redundant supply to this region. DWSD has planned and promised to construct this line over the last 30 years. Their most recent plan stated it would be built in the 2040 decade. Only when Genesee became serious about an alternate supply did DWSD move forward with design of the pipeline with construction to begin in September 200. Obviously they missed this date. As the State knows,a plan does not mitigate deficiencies. Genesee/Flint are tired of the promises and DWSD has not been willing to address the financial concerns of Genesee/Flint. |
|
|
|
Wed Apr 25, 2018 1:17 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
GCDC acknowledges, throughout its application, that the population its withdrawal would serve is already being served by DWSD. It argues, however, that an entirely new withdrawal system is the only way to address what Genesee characterizes as deficiencies in the DWSD system. This application fails, however, to provide statistical data regarding these alleged deficiencies. Obviously. this data should also include dates, time, impacts, and suspected causes. This data should also identify the role of Flint and or/ GCDC's distribution systems in either causing or contributing to any alleged deficiencies. The application also fails to acknowledge that DWSD has a plan to address those alleged deficiencies, that DWSD has already designed those improvements and outlined a proposal that would implement those improvements and provide a rate reduction to Flint and GCDC.
O'Brien:
Again, DWSD has been promising a redundant supply for 30 years. The State has deemed the County's water supply deficient because we do not have a reliable redundant supply. This water withdrawal and our subsequent system willadress our redundancy issue. |
|
|
|
Wed Apr 25, 2018 1:32 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
Under GCDC's proposed plan, each of the three communities, GCDC, Flint and GLCUA would be required to construct a new water treatment plant, duplicating the water treatment capacity that already exists in DWSD's system. GCDC"s application does not mention this very costly element of its plan for a new water system. Clearly, the proposed new withdrawal is inefficient with respect to the use of DWSD'd existing water system.
O'Brien:
The proposed plan and costs includes new treatment facilities and redundant distribution system for the region. Treatment of Lake Huron water is significantly less costly thn treatment of the Flint River water oreven Detroit River water, as DWSD well knows. The majority of the costs for the project are in the pipeline and intake pipe. The water treatment costs is less than 25% of the capital cost. |
|
|
|
Wed Apr 25, 2018 1:45 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
GCDC claims that it needs to build a new water system in order to supply redundancy that would provide water in an emergency. However, in order to have that redundancy, GCDC would have to maintain a connection to DWSD's water system and continue to purchase a significant amount of water from DWSD.
O'Brien:
Again, DWSD refused to consider an interconnect with their system. Our propose plan and cost includes a redundant system. |
|
|
|
Wed Apr 25, 2018 1:52 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
GCDC cannot simply close the connection to DWSD's system at the county line and open it in an emergency. In order to maintain water quality in the line, GCDC and Flint would have to continue to take water to maintain the connection. At the March 10, 2009 meeting, GCDC advised DWSD that it would have to continue to purchase a substantial amount of water from DWSD in order to achieve the level of redundancy it needs. If GCDC and Flint would have to continue to take a significant amount of water from a system that can provide all of its redundancy needs, building a new water system is not an efficient use of existing water supplies. That would be a violation of Sec. 4.11 of the Compact, which requires rejection of the application. Furthermore the GCDC application does not offer any detail on how much water it would continue to purchase from DWSD in order to maintain redundancy after it completes its new system. This is a significant deficiency that should be addressed before MDEQ makes a decision on the application.
O'Brien:
Once again, DWSD refused to consider an interconnect. We again on March 10, 2009, asked if this was possible because it would reduce our construction cost. DWSD would nor consider this option. An interconnection is not contemplated in our region's water supply system. |
|
|
|
Wed Apr 25, 2018 2:48 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
GCDC's application fails to mention the efforts DWSD has made to address its concerns, fails to disclose the need to build expensive new water plants;fails to fully disclose the cost and impact of its plans, and fails to disclose its own role in planning the Flint Loop Project. It also fails to fully address the fact that after it builds its new system, it will still have to purchase a substantial amount of water from DWSD to maintain redundancy. This is disturbing. to put it mildly. GCDC is giving MDEQ a less than complete picture of the situation. Its failure to adequately address these issues violates the mandatory decision-making standards quoted above.
O'Brien:
DWSD allowed Genesee to participate in the route of the water line but not in the sizing or operational layout of the system. The purpose as to obtain construction and right-of-way permits not negotiations. Again, our plan does not include an interconnect with DWSD. |
|
|
|
Wed Apr 25, 2018 3:26 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
Flint is DWSD's largest customer. According to DWSD estimates, if Flint, GLCUA and FCDC were to leave DWSD's system, it would create an immediate 6% rate increase for all the rest of DWSD's 85 wholesale customers, as well as the residents of the City of Detroit. That is because the fixed costs of DWSD's water supply system would have to be distributed to a smaller customer base. The cost increase would occur at a time when the entire region is experiencing a widespread,significant economic downturn due to the loss of manufacturing jobs and reductions in automotive productions. The cumulative effect of the loss of customer base on top of the already severe financial situation is a significant concern to DWSD and its customers.
O'Brien:
This statement by DWSD identifies the failure of their rate model. If it were a true cost of service model, each community would be paying their cost of service. Loss of a customer should not impact another community's rate. Second,this is adecision by DWSD instead of reducing costs for reduced services, they would just pass the lost cost on to the remaining customers. |
|
|
|
Wed Apr 25, 2018 3:44 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
GCDC's application also fails to describe the economic burden that the construction of a new water intake, transmission pipeline and three new water treatment plants will place upon the residents of Flint, Genesee County, and Lapeer County. GCDC has stated that the estimated cost of GCDC's project is $600 million. That is the estimated cost for the intake, the pipe, three new water plants, pump station and a reservoir. That figure does not, to our knowledge, include the cost of maintaining a connection to DWSD's system, which will be necessary if GCDC is to have the redundancy it needs. GCDC's failure to include and discuss the total cost of its project in its application is a significant deficiency that should be addressed before a decision is made on the application.
O'Brien:
DWSD says it will build the pipeline. Genesee/Flint says it will build a pipeline. There will be an economic burden placed on the region regardless of who builds the pipeline. The point is moot. Again, DWSD has refused to consider an interconnect, which would reduce our overall construction costs. |
|
|
|
Wed Apr 25, 2018 4:04 pm |
|
|
untanglingwebs
El Supremo
|
Detroit:
Based on studies conducted by other DWSD customers that have considered constructing separate water supply systems, DWSD believes that the construction and operation of an entirely new, duplicative system would result in significant rate increases for the customers that GCDC proposes to serve. During the construction period, GCDC's customers will be paying for DWSD water in addition to paying the construction costs of the new system. That means a significant rate increase for the customers of GCDC, Flint and GLCUA. After the GCDC system becomes operational, it will continue to pay part of the cost of the DWSD system in order to maintain the redundancy it needs. We believe this will result in residents of Flint, Genesee County and Lapeer County paying higher water rates than they currently pay.
O'Brien:
Separate studies of different systems have no bearing on our application for new withdrawal. Genesee/Flint are looking for a long-term solution to our water reliability. Yes during the construction period , the region would have to purchase water from DWSD ut over the 25 year year study period, the region would be saving substantial sums of money versus a new contract with DWSD. The rates used in our study for DWSD were confirmed by DWSD. |
|
|
|
Thu Apr 26, 2018 8:22 am |
|
|
untanglingwebs
El Supremo
|
Detroit:
Subsection 5.3 of the compact establishes criteria relating to "the probable degree and duration of any adverse impacts caused or expected to be caused by the proposed Withdrawal and use under foreseeable conditions, to other lawful consumptive or non-consumptive uses of water..." The permit application filed by GCDC addresses this criteria from the standpoint of impacts. As noted above, residents of Detroit, DWSD's other customers, plus Flint, GLCUA and GCDC's customers would be adversely impacted y the proposed withdrawal, in the form of higher water rates. Clearly, GCDC's permit application is deficient with respect to this factor, as it does not provide a rate forecast based on expected service costs.
O'Brien:
This is a bold statement. DWSD remaining customers will have a negative impact solely by the decisions made by the City of Detroit. Our region will see a positive impact in reduced costs and a reliable water system. |
|
|
|
Thu Apr 26, 2018 8:38 am |
|
|
untanglingwebs
El Supremo
|
Detroit:
Beyond the criteria cited above from the Great Lakes Decision Making Standard, there are other compelling issues. As indicated above, significant questions as to whether the proposed new intake, treatment plants and distribution system would be cost effective way to serve the area. DWSD's cost estimates indicate that its existing water distribution can furnish water to the area at much lower expense. Cost effectiveness will be an important factor in the state's decision whether to provide low interest loan assistance from the DWRF program. We would note that MDEQ has already rejected loan applications in similar situations where the proposed project would have withdrawn customers from an existing service area where the infrastructure was built and paid for with tax dollars. Specifically, MDEQ refused to finance a proposal from the City of Mt. Clemens to expand its wastewater treatment plant so that existing DWSD customers could withdraw from Detroit's system.
O'Brien:
The County has applied for a withdrawal permit. We have not applied for a loan from the DWRF program. This has nothing to do with our request. |
|
|
|
Thu Apr 26, 2018 8:57 am |
|
|
untanglingwebs
El Supremo
|
Detroit:
In addition, Genesee County fails to demonstrate its financial capacity to undertake such a costly project. In the 2008 Comprehensive Financial Audit Report of the GCDC, the audit firm Plante Moran, identified significant deficiencies in Genesee's management of Bond Premiums and Discounts, as well as Bond covenants. Plante Moran implies that Genesee has not been levying rates required to prevent violation of its bond covenants. DWSD questions whether the appropriate risk analysis has been done regarding GCDC's financial strength and its ability to carry out its plans.
O'Brien:
The County does admit to deficiencies in our 2007 CFAR. This issue was resolved within two weeks of the problem being identified. Our auditors interpreted an old bond covenant to apply to all outstanding bonds. Our bond attorney clarified the matter and we have submitted our 2008 CFAR without that deficiency. This again, has nothing to do with our request for withdrawal. |
|
|
|
Thu Apr 26, 2018 9:16 am |
|
|
untanglingwebs
El Supremo
|
Detroit:
Lastly, from a public policy perspective, we note that infrastructure investments need to be carefully considered given the limited capital resources available to finance new facilities. We believe that Michigan cannot afford to undertake construction of unneeded redundant water supply facilities at a time when other infrastructure needs are going unmet. In our judgement, it is inappropriate to approve GCDC's water withdrawal application in this context.
O'Brien:
DWSD does not believe Michigan can build a pipeline. In fact, DWSD does not believe we should build the pipeline but we should sign a 30 year contract and let them build a pipeline. The fact is anew redundant pipeline will be built! By us or DWSD. DWSD would like the State of Michigan to force Genesee/Flint to remain a customer of DWSD.
Under State Law, the State cannot force a community to purchase water from another community MCL 325.1004. Section 4(b)
(b) The department includes in the approval conditions related to depth, pumping capacity, rate of flow,and ultimate use that ensure that the environmental impact of the withdrawal related to public health , safety, and welfare. This subdivision does not confer upon the department any authority to require a person to connect or to remain connected to an existing drinking water supply owned by a political subdivison |
|
|
|
Thu Apr 26, 2018 9:40 am |
|
|
|
Forum Rules:
You cannot post new topics in this forum
You cannot reply to topics in this forum
You cannot edit your posts in this forum
You cannot delete your posts in this forum
You cannot vote in polls in this forum
|
|
|
|
|
FAQ
Search
Memberlist
Register
Profile
FlintTalk.com Forum Index
> Political Talk
