Location: CT River and Tributaries in Central CT; Hartford, CT | Status: Active
Summary:
Combined sewer systems collect rainwater runoff, sewage, and industrial wastewater into one pipe. During wet weather conditions, this combined flow might exceed the capacity of the system. When it does, it is intentionally discharged into a water body without any treatment. Raw sewage and other pollutants are, therefore, discharged directly into water, harming public health and the environment. Combined sewer systems are a remnant of historical design and can be found in older municipalities like the Greater Hartford area, where millions of gallons of combined sewage and stormwater pour into area waterbodies each year. The EPA requires these municipalities to develop and implement a Long Term Control Plan to eliminate the combined sewer overflows by either expanding the capacity of the system to treat all of the combined flow or separating stormwater from sewage and industrial wastewater, so that the latter are properly treated.
The Metropolitan District (MDC), which serves the Greater Hartford area, has been subject to a consent order with DEEP since 2006, requiring compliance with a Long Term Control Plan. In 2006, it was estimated that MDC discharged 974 million gallons of combined raw sewage and stormwater each year. The initial completion date for projects that would eliminate combined sewer overflows, per the consent order, was 2029. By 2022, MDC had achieved annual CSO reductions of 488 million gallons per year, yet there was significant work yet to be done, with hundreds of millions of gallons of combined raw sewage and stormwater still discharged from the remaining combined sewer outfalls during storm events each year. In 2018, MDC requested an extension of nearly 30 years, to 2058, for completion of the remainder of the CSO abatement projects, citing financial concerns. Save the Sound and its environmental partners worked hard to ensure that progress towards eliminating these CSOs remained steady and that no further delays were approved without sound reasoning. Save the Sound also submitted comments to DEEP requesting that equitable rate structures be fully evaluated by MDC, and other quasi-public entities and municipalities, in Financial Capability Assessments prior to the approval of extensions based primarily on ratepayer ability to pay.
In lieu of granting this extension, DEEP approved a short-term project list, and issued a new consent order in September 2022 that rendered this short-term project list enforceable. These projects are expected to further achieve a reduction of 97 million gallons of CSOs per year by 2029. DEEP and MDC will negotiate the next phase of projects beginning in 2027. However, the end date of the LTCP and the remaining CSO projects therein remain unknown, leaving concerns as to the indefinite nature of compliance. At the conclusion of the 2022 consent order, it is estimated that there will still be annual CSO discharges of 393 million gallons. Save the Sound is fighting to ensure prompt compliance with the LTCP in order to eliminate this threat of CSOs to the environment and public health.
Latest steps:
- DEEP approved the short-term project list, spanning until 2029, and issued a consent order in September 2022 incorporating this schedule.
- MDC’s first CSO project deadline under that CO is December 31, 2022 for: completion of Park River and South Meadows Area sewer rehabilitation; completion of Bloomfield and North Branch Park River sewer rehabilitation; and completion of Gully Brook Area sewer rehabilitation.
- Save the Sound and partners submitted comments to DEEP requesting that equitable rate structures be fully evaluated by MDC, and other quasi-public entities and municipalities, in Financial Capability Assessments prior to the approval of extensions based primarily on ratepayer ability to pay.
- EPA released its proposed 2022 Financial Capability Assessment Guidance for public comment. This guidance document influences the factors that may be considered when granting such schedule extensions. Save the Sound submitted comments on the proposed 2022 EPA FCA Guidance.
Next steps:
- Save the Sound will closely monitor compliance with the 2022 consent order.
- MDC will host a public meeting in 2023 to update the public on progress and forthcoming projects.
- Save the Sound, with partners, will continue to submit feedback to DEEP and will request measures to ensure transparency and accountability.
Further reading:
Action opportunities:
Page Last Updated: November 17, 2022