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untanglingwebs
El Supremo
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Between 2009 and 2010 John F. O'Brien, P.E.,BCEE, Director of Genesee County Water and waste Services Division, wrote both the DEQ and the Detroit Water and Sewer Division to battle attempts by Detroit and the state to undermine the KWA Pipeline.
July 13, 2009
Mr Brant Fisher , Environmental Engineer Specialist, MDEQ (Water Bureau)
This letter addressed a letter from the Detroit letter of June 29, 2009, and their comments regarding the water withdrawal application of the Genesee County Frain Commissioner's office. |
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Wed Apr 25, 2018 7:59 am |
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untanglingwebs
El Supremo
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Comments of Detroit:
The City of Detroit and DWSD have a direct interest in MDEQ's decision on the permit application. We object to the issuance of this permit based on technical, financial,and public policy concerns as set forth below. FWSD currently supplies water to GCDC and the communities that it proposes to to serve with the water system it proposes to build. We strongly believe that GCDC's proposal fails to address the availability and efficient use of existing water supply systems and that GCDC's proposed water system is not cost efficient.
O'Brien's response.
The City of Detroit's interest in our permit application is purely a financial interest. As one of the outer most customers of their system, we are charged additional fees for distance and elevation. These charges result in some of the highest rates on their system. With the loss of us as customers, DWSD will have to choose to either reduce their operations, maintenance and debt service costs or increase charges to their municipal customers. |
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Wed Apr 25, 2018 8:15 am |
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untanglingwebs
El Supremo
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Detroit:
DWSD has contracts to supply water to Flint, and the Greater Lapeer County Utilities Authority (GLCUA). Both are expired and continuing on a year-to-year basis. Flint in turn sells water to GCDC, which in turn sells water to several communities in Genesee County;Davison Township, Burton, Swartz Creek, Genesee Township. Mt. Morris Township, Vienna Township, Montrose Township, Flushing, Clayton Township, Gaines Township, Mundy township, and Grand Blanc Township, GCDC proposes to continue selling water to these communities, as well as to Flint, GLCUA, and Sanilac County.
O'Brien:
The Genesee County Drain Commissioner's office does not intend to recreate the buyer seller arrangement. We have made application on behalf of the other communities and we will set-up an authority to supply raw water to each constituent community, who will in turn, provide treatment and distribution to the local residents. |
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Wed Apr 25, 2018 8:29 am |
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untanglingwebs
El Supremo
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Detroit:
GCDC, Flint and GLCUA are served by DWSD's Port Huron Water Treatment Plant, which has a treatment capacity of 400 MGD. DWSD's water system has a current permitted capacity of 1,600 MGD. The intake for the Port Huron Water Plant has a capacity of over one billion gallons per day, although the plant has not yet expanded to that level. DWSD;s water system has more than enough capacity to serve the current and future needs of GCDC, Flint, GLCUA, and all of Southeast Michigan.
O'Brien:
DWSD has always had intake capacity to serve our region but DWSD has neither the treatment nor distribution systems to meet either the the peak day demands or the redundancy needed to to ensure a safe and reliable water supply. DWSD states that we are served by the Port Huron facility, yet we are required to finance and support their other four plants and distribution systems. |
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Wed Apr 25, 2018 8:45 am |
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untanglingwebs
El Supremo
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Detroit:
The first negotiation session between DWSD, Flint,and GCDC occured on September 3, 2008 and was attended by Frain Commissioner, Jeff Wright, as well as members of his staff. Further meetings occurred on September 16, 2008 and march 10, 2009. Key attendees have included Commissioner Wright, Flint Utilities Director Lyle Hippensteel, and Flint Finance Director Suzanne kayser.
O'Brien:
The first negotiations began over 5 years ago in 2004 with the previous administration of DWSD. The current group has been involved for less than one year and is not aware of all of the discussions. |
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Wed Apr 25, 2018 8:53 am |
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untanglingwebs
El Supremo
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Detroit:
DWSD has addressed those concerns. In September 2007,based on requests from GCDC, Flint and many other customers to expedite the provisions of redundant supply to Flint/Genesee and to improve water pressure in other parts of its service area, DWSD announced its intention to construct the Flint Loop and the Northern Oakland Loop. These two water transmission main projects will extend a second water line from DWSD's system in Oakland County into Genesee County and Flint, where it will connect with the existing pipe,completing a loop into the system. The project has been designed to supply GCDC with its average day demand.should an emergency curtail service on the line from Port Huron. This should be sufficient to address GCDC's concerns about the redundancy and emergency supply.
O'Brien:
DWSD contradicts itself. The pipeline design contract were awarded in the early spring of 2008. City/Council even questions the projects moving forward without a
long-term contract with Flint/Genesee, then Director, Victor Mercado, said these lines are required regardless of Flint/Genesee. DWSD identified the true purpose of the two waterlines to serve their customers in Oakland and Macomb Counties. |
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Wed Apr 25, 2018 9:13 am |
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untanglingwebs
El Supremo
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Detroit:
These two projects would also improve water pressure in Macomb and Oakland Counties and allow the Lake Huron Water to supply the entire DWSD system in case of an emergency that shuts down DWSD's four other water plants. This would be a substantial benefit to the entire region of Southeast Michigan.
O'Brien:
The DWSD pipeline is designed to flow south out of Genesee to Oakland and Macomb. In an emergency situation, they can reverse the flow and provide us with only ADF. To provide us a true redundant supply, they must also construct the Eastern Macomb loop from the Port Huron plant. DWSD has not commented upon the probable cost of these other major improvements and the rate implications these improvements will have on all DWSD customers. |
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Wed Apr 25, 2018 9:24 am |
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untanglingwebs
El Supremo
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Detroit:
DWSD has completed the design of both projects, with considerable input and interface from GCDC. The total cost of the design has been $28.6 million. The plans and specifications are complete and can be put out for bids as soon as Flint and GCDC sign a new contract with DWSD.
O'Brien:
The projects were designed and authorized by the Detroit City Council prior to the current DWSD administration taking office. At the time of the approval, then DWSD administration stated these pipelines needed to be constructed with or without Genesee/Flint. |
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Wed Apr 25, 2018 9:34 am |
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untanglingwebs
El Supremo
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Detroit:
On September 16, 2008, DWSD"s Assistant Director of Engineering and its Project Manager presented the design, in detail, to Mr. David Jansen of GCDC. At the conclusion of the meeting, he indicated his belief that the loops would provide GCDC with adequate service in case of an emergency situation. The comments below are taken verbatim from meeting minutes that were not refuted or objected to by Mr. Jansen.
"All participants agreed that their meeting had been valuable, and Mr. jansen said that DWSD had answered his technical questions about redundancy. He indicated that based on the information provided (given a more detailed design would provide more comfort) gave him assurance that Genesee/Flint would receive adequate water supply in an emergency.With that in mind, there was a comfort level in the group (DWSD/Genesee) to continue the contract negotiations process."
O'Brien:
The staff of DWSD did answer Mr. Jansen's questions and informed him that until the the Macomb loop is constructed, we will not have a full redundant system. This was a technical meeting and did not answer any of the contractual concerns over the Master Agreement or the financial issues. |
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Wed Apr 25, 2018 9:52 am |
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untanglingwebs
El Supremo
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Detroit:
Using the completed DWSD design, GCDC constructs the northerly portion of the Flint Loop.
O'Brien:
DWSD omitted that the reduction of 40% rates will require the Flint/Genesee group to expend $268 million and be responsible for long-term operation and maintenance costs of the proposed pump station, which is to be located in Grand Blanc Township. |
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Wed Apr 25, 2018 10:00 am |
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untanglingwebs
El Supremo
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Detroit:
Although DWSD has continued to provide GCDC with information in response to questions about this offer, DWSD has received no response from GCDC.It should also be noted that GCDC filed an application for a withdrawal permit in February 2009, a factit fifnotcommunicateto DWSD at the March 10,2009 meeting.
O'Brien:
Again, this administration is under the impression that negotiations began with them. The county has been working with the DWSD over the last 5 years as we developed Phase l and ll of our report. THis administration became involved during Phase lll. The County has always been open with DWSD and they knew we were going to compare our alternative against their best offer. To that end,the County decided that a withdrawal permit needed to be obtained prior to the establishment of the Karegnondi Water Authority.
And as DWSD states, these are negotiations and in negotiations,you need to keep both alternatives moving forward. |
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Wed Apr 25, 2018 10:14 am |
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untanglingwebs
El Supremo
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Detroit:
DWSD"s 2003 comprehensive Water Master Plan addresses providing redundancy in the water supply for Flint, GCDC and Glcua. DWSD has completed the design work and is ready to start construction. The proposed new withdrawal is not, therefore,necessary to address the redundancy concern. Indeed, DWSD's system is the only system capable of ensuring a redundant system. Even if GCDC constructs its new system, it would still need to purchase water from DWSD's system in order to maintain the second source of water it needs for redundancy.
O'Brien:
Genesee/Flint requested DWSD to consider providing the new pipeline with redundancy off the existing pipeline. Both the past and current administration said they would not support our separation from the system. Therefore, the Phase lll plan includes full redundant systems without reliance on the DWSD system. We have estimated a $120 million dollar reduction in cost if we could reach a mutual aid agreement with DWSD, but it is their position not to consider an interconnection. |
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Wed Apr 25, 2018 11:06 am |
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untanglingwebs
El Supremo
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Detroit:
Section 2(xi) of the Genesee supplemental data elaborates on the contention that the DWSD system is deficient by stating that an interruption of service has already had dramatic consequences. That section fails to point out that the interruption of service was associated with the massive power failure that occurred throughout the northeastern part of the UNited States in August 2003, which is not attributable to DWSD's system.
O'Brien:
The buyer communities funded generators and secondary power sources for the system. These were not available or not working during the blackout. This statement only reinforces our contention that that the DWSD water system does not provide adequate redundancy. Redundancy ust include all critical aspects of a water supply. Power is a critical aspect. |
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Wed Apr 25, 2018 11:21 am |
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untanglingwebs
El Supremo
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Detroit:
Section 2 (viii) of GCDC's permit application estimates that the proposed service area will experience an approximate 34% growth in water demand over 25 year planning period (2014-2039). DWSD's Comprehensive Water Master Plan projected only an approximately 13% increase in population in the combined Genesee and Lapeer Counties during the period 2010 -20140. Based on the significant population declines in Michigan since the Comprehensive Water Master Plan was finalized, which have been well documented, and the anticipated impact of the recent economic downturn, Genesee's forecast of growth in demand appears to be unrealistic. Even if Genesee's projections are accurate, DWSD would have all the capacity necessary to meet that demand.
O'Brien:
DWSD is correct, their Master Plan (CS-1278) only predicts a 13% increase in their service area. But their own report predicts a 53% growth for the service area covered by the Flint system. We have reduced thisans increased our service area. |
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Wed Apr 25, 2018 11:40 am |
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untanglingwebs
El Supremo
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Detroit:
4 b. If the Proposal is for an increase Withdrawal or consumptive use,whether efficient use is made of existing water supplies;
O'Brien:
DWSD implies that we are seeking an increased withdrawal permit. The county is seeking a new withdrawal,therefore Section 4.b does not apply.Furthermore,as stated in our application, the atr loss from the proposed system at most will be only 25% of the water loss experienced by the current DWSD system. |
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Wed Apr 25, 2018 11:50 am |
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