Wednesday, October 26, 2011

The other viewpoint, with footnotes and references added

The Newsletter below was send out to all households in Santaquin (or at least the ones that contain registered voters)  Below, for your reading pleasure, we have inserted the actual facts of the matter in Red.  Although it's a bit more lengthy than a typical blog post, it is also much more important.  

Another view of the Proposed MBR and the 9.9 Million Dollar Bond

In 1991, the City of Santaquin decided to create a sewer treatment facility for its citizens.  After extensive consideration, the City determined to construct a treatment lagoon system at the west side of town.  The treatment facility consisted of three aerated treatment ponds, one winter storage pond, and processing and pumping facilities for irrigation.  The City expanded this system in 2002 to its current size and capacity.  Through this expansion, the system has kept pace with Santaquin’s population growth.  Similar expansion could see to future needs.

Yet now the City has made the determination to build a new, $18 million, self-contained “Membrane Bio-Reactor” (MBR) mechanical sewer plant at a new location.  The new MBR plant would require an additional $9.9 million in bonded debt, to be incurred by the city of Santaquin and its citizens – $1,155 for every man, woman and child in the city of Santaquin (based on 2009 census figures).  The debt would be paid back over the next forty years, a legacy to Santaquin’s youngest citizens who cannot yet vote or read.  In addition, the MBR mechanical sewer plant would require acceptance of a $6.35 million federal grant; an additional $2 million balance that has been drawn from city funds.

 The initial cost of the MBR mechanical sewer plant would only be the beginning!  In contrast to the relatively simple, low-cost operation of the existing system, an MBR plant would entail significant increase in operation and maintenance costs, none of which have been budgeted or even estimated by city planners.[1]

[1] Operation and Maintenance costs have been considered.  Funding partners on the project required O&M estimates with applications for their funds.  The funding partners required Santaquin to charge a sufficient user fee to cover O&M costs.  The rate increase of $20 last year was determined by the funding partners to be sufficient to cover O&M costs as well as the debt service on all sewer system debt.


For reasons that have never been explained, the City’s plan for the $18 million MBR plant, and for $9.9 million in new public debt, completely disregarded (1) the viability of a partnering agreement with Payson City[2], which maintains an existing mechanical treatment plant less than five miles to the north of Santaquin City over virtually level grade; (2) plans for a regional facility on the shores of Utah Lake, to be constructed within the next 25-30 years[3]; and (3) at least two low-cost alternatives for extending the life of Santaquin’s existing treatment[4] facility.  When a group of citizens challenged the City’s actions in this regard, and petitioned for placement of the bond issue on the November ballot, Santaquin City Administration flatly refused.  It took a petition to the Utah Supreme Court to persuade Santaquin’s Administration to give its citizens a voice in the process. All of these actions by the Administration were carried out without City Council knowledge or approval.[5]

[2] The City Council requested that consideration be given to the Payson connection in each Capital Facilities plan prepared for the City.  The City Council asked City staff to meet with Payson to discuss this option.  The most recent meeting to discuss costs and options took place on September 28, 2011 with Payson’s City Manager and City Engineer.

[3] This option was considered in the City capital facility plan, adopted by the City Council on May 6, 2009, and the additional preliminary engineering report. Due to the timing of this facility, the extraordinary cost to Santaquin City to participate, and the urgency of addressing the City’s wastewater needs, this option was not considered the best option at this time.

[4] These were likewise considered in the City’s plans. The City Council determined that although they required the least amount of initial capital cost, the long term costs exceeded the short term benefits.

[5] The City Council minutes of April 6, 2011 reflect that the City Council did know of the potential Supreme Court actions and discussed sending the petition back to the Supreme Court for their action and decision during this meeting.  The “administration” did not act independently of the City Council in this regard.


 Now, Santaquin’s voters have the opportunity to vote on City Hall’s plan to build a costly MBR mechanical sewer treatment plant, and burden its citizens with a $9.9 million debt. In the days leading up to the November 8 elections, most voters in Santaquin have received calls or letters from City Hall trying to justify its decision.  We believe that it is time to set the record straight, and give Santaquin’s voters the other side of the story.  In particular, we need to debunk ten myths which have circulated concerning the proposed initiatives, and the City’s plans for providing waste water treatment services to its citizens.

Myth No. 1:  Santaquin’s current wastewater treatment system is beyond capacity.

Santaquin’s current sewage treatment system has been[6] qualified and certified as a compliant “publicly-owned treatment works” facility under Utah Admin. Code R317-8-1.5(41).  The existing sewer lagoon facility currently processes just over 500,000 gallons of waste water per day[7].  Simple, low-cost modifications of the system, described below, could nearly double that capacity to over one million gallons per day.

[6] This is true so far as it complies with all regulations for waste water treatment found in the Utah Administrative Code.  These regulations include standards for treated water quality and disposal.  The quality of treated water has not passed total suspended solids standards since July 2009.  The BOD levels in the samples have continued to climb with two months in the last year failing quality standards.  The City Public Works Director, Wade Eva, and Water Master, Denny Barnes, have indicated that this problem must be addressed within 18 months.  The City’s disposal process of treated water is to irrigate an alfalfa crop.  According to state reuse standards, the City is over-applying 1.6 times the amount of water allowed on that crop, because it does not have enough land (see note 7).  The low cost modifications would address the treatment but not the disposal component of the system.

[7] The current treatment system is receiving on average over 510,000 gallons per day according to City public works records.  Its current treatment limit was only designed to handle 493,000 gallons per day. 


Myth No. 2:  Santaquin does not have enough land to dispose of treated waste water.
Santaquin’s current system produces treated irrigation water which may – and must – be used for irrigation purposes.  Currently, the city claims[8] to have only 48.5 acres of irrigable ground on which to sprinkle treated water from the existing plant. This results in over-application of treated waste water.

[8] Based on land application regulations and agreements with property owners adjacent to the application sight the City owns and utilizes 32.5 acres of ground for water disposal.  One adjacent farmer has agreed to accept some treated water for use on 16 adjacent acres.  Water used on the application site is metered.  Meter records indicate the City used 103 Million gallons between May 15 of this year and October 1 on the available lands.  This results in 316 acre feet of water being applied on the 48.5 acres.  The State has authorized the City to apply up to 4.15 acre feet of water per available acre, which results in a maximum of 200.86 acre feet on the available ground.  The City is currently over-applying water on the available ground by 1.6 times the state authorized amount.  Additionally, it is estimated that over 40 Million gallons of treated water is seeping directly into the ground through the lagoons.



In fact, the city has (or will shortly have) options to irrigate more than 230 additional acres with treated waste water from its existing plant.[9]  By its own figures, the city needs only 62.5 of these acres to bring its existing plant into full compliance with state requirements.

[9] Neither the City administration nor City Council has been presented with a proposal to utilize 230 acres of someone’s property.  One farmer has indicated the City could possibly use 80 acres of his ground, but he would need to gain permission from other interested family members.  The City has received multiple letters from property owners in the lagoon area against land application expansion.  Several of those opposed to expansion have threatened legal recourse if the City pursues this option further.  


Myth No. 3:  The $18 million MBR plant is the only viable alternative.

The City has claimed that its $18 million MBR plant is the only possible solution for Santaquin’s future waste water treatment and water needs.  This is simply not the case.  There are three workable, and less costly, alternatives[10].

[10] The City recognizes there are multiple solutions to address the sewer needs.  The MBR system is the BEST possible solution and will cost the least amount over the next 20 years.  This is illustrated in the City’s Wastewater Treatment and Collection Capital Facilities Plan adopted May 6, 2009.
 

A.                Increased aeration and irrigation acreage for the existing facility.

The simplest, and least expensive, alternative to an MBR plant is the addition of three additional aerators to the existing treatment ponds.[11]  The additional aerators would fit into the facility without the need of any expansion or additional acreage[12].  As mentioned above, this system alone could expand the treatment facility’s capacity to over one million gallons per day; the additional irrigation acreage would permit proper (and profitable) disposition of treated water for years to come.  This retooling of the existing facility would incur costs of no more than $3,000,000,[13] and could be maintained with existing operating personnel and procedures at minimal cost to Santaquin’s rate payers.

[11] This is the simplest and least expensive option for initial capital outlay to address the aeration issue at the lagoons.  However, this does not address water disposal or collection system deficiencies (See footnote 8) nor address the long term costs associated with additional land needs (see footnote 12). 

[12] It is true that no additional acreage would be needed for the treatment part of the system, but with increased treatment capacity, additional acreage/right-of-way must be acquired or “secured”, according to State standards for water disposal.  Santaquin’s growth is projected to be around 1% for the next 3-4 years and then resume a 3% average growth for the next 15 years.  Additional land must be acquired for land application as well as winter storage to keep up with this growth. Just adding aeration will not address the issue of currently excessive water application and future needs (see footnote 7).

[13] From what is this number derived?  No professionally prepared proposals or bids have been presented to the City for consideration. 

B.                 Installation of Bio-Domes.

An alternative technology to increase the capacity of the existing treatment facility entails the installation of “bio-domes” into the existing lagoons – a system which has already been presented to and rejected by City Administration[14].  Bio-domes could be purchased and installed incrementally, to keep pace with increased need over time.  An initial installation would cost the city less than a $1 million; incremental increases could be put in place as required at a cost of $3,000 each.  Again, the bio-dome system could expand the existing facility’s capacity to over one million gallons per day, at a fraction of the cost of the city’s proposed MBR plant.

[14] A presentation about bio-domes was made to the City Council.  During the presentation, the makers of the Bio-dome technology (Wastewater Compliance Systems) provided a quote to the City Council of $2.0 Million to increase the lagoon capacity by 50%.  An additional $1.1 Million would be necessary to increase treatment capacity to 1 million gallons per day (Mgd) (Total cost of $3.1 Million for a 1 Mgd facility).  Engineering estimates to do the simplest and least expensive alternative of adding aerators is $2.2 Million for a system capacity of 1.5 million gallons per day. There has been no formal rejection of the bio-dome system by anyone in the City.  However, as indicated in paragraph A the least costly option of expanding the lagoons is to increase the number of aerators with the current system.


C.                 Partnering with Payson.

As communities throughout the State of Utah have done in recent years, Santaquin has the opportunity to partner with another municipality which already owns, operates and maintains a mechanical treatment facility.  The Payson City treatment facility, just over four miles away, currently operates at approximately 40%[15] capacity.  The piping of sewer effluent from Santaquin to the Payson plant would entail 7,000 feet of 30-inch pipe, and 22,000 feet of 24-inch pipe[16], and a lift of not more than 40 vertical feet.  Payson has already expressed willingness to partner with Santaquin City, and make such a connection a reality – but our Santaquin City’s Administration refuses to talk about it.[17]

[15] Payson City’s plant is a 3 Mgd facility.  Payson City records indicate the plant is at approximately 50% capacity.

[16] Where did this quantity come from?  The City’s capital facilities plan indicates the following items are needed to connect to Payson: 7,000’ of 30” pipe, 5,000’ of 18” parallel pipe in Payson, a lift station, and several Santaquin collection system modifications at a price tag of nearly $8 Million.  This conceptual estimate of costs and elements was based on multiple conversations held with the Payson City Engineer about their system and means of connecting to it if that option was pursued.  There would also be additional cost to buy-in to the Payson facility, as noted below.

[17] See footnote 2.


Myth No. 4:  Nothing but an MBR plant can produce Type 1 treated water.[18]

Part of the City’s plan is to construct a waste water treatment facility which will produce “Type 1” treated water.  In fact, sand filtration systems (again, costing a fraction of the proposed MBR treatment plant) are available which would produce Type 1 treated water from the existing sewer lagoons.

[18] The City has never asserted only MBR technology can produce Type I water.  It is recognized that additional filtering and chemical processes can produce water able to meet Type I water standards established by the State.

Myth No. 5:  Any partnership with Payson City would “sell Santaquin’s future”.

Here, City Hall pulls out its scare tactics and half truths:  By partnering with Payson City, City Hall maintains Santaquin’s residents would surrender control over their sewer rates to Payson City[19].  This simply is not true!  Once initial costs of connecting to Payson City’s existing plant (addressed below) are covered, the remaining terms of service are negotiated in advance between the two cities.  How the two partnering cities will divide up costs, set rates, etc. is determined by agreement, and not dictated by Payson City.  The problem is that Santaquin has refused to even sit down at the table with Payson to discuss possible terms of service[20].

[19] The Payson City Manager has asked Santaquin to consider a contract similar to what Mapleton has with Spanish Fork City for shared sewer facilities. In the referenced agreement Spanish Fork sets the budget for the treatment facility each year and Mapleton must pay their proportionate amount of whatever budget Spanish Fork sets.  Using this template Payson would establish how much money Santaquin must pay every year.  The contract would also require Santaquin to negotiate for service anytime a new commercial user wanted to connect in Santaquin. 

[20] See footnote 2.


Myth No. 6:  The Payson City connection would be prohibitively expensive.

City representatives have suggested various astronomical connection and operational costs associated with any joint operation with Payson City.  Nowhere, however, has the city explained where its numbers come from[21].

In fact, an initial one-time buy-in cost of $2.5 million would be assessed by Payson City for connection.  Costs for the connection line and pumping equipment have been estimated at $5,600,000.[22]  Thereafter, the estimated operational cost would be only $1 per thousand gallons treated.  All remaining costs and terms (as indicated above) would be subject to negotiation and agreement between the two cities.  Finally, federal grant money[23] would likely be available to defray costs associated with a Payson City connection.
Contrast all the foregoing to the City’s proposed $18 million duplicate, free-standing facility, and the economic waste entailed in the City’s proposal becomes obvious.

[21] All information is available to the public on the City’s website and at sewer.santaquin.org.  The City capital facilities plan adopted in March 2009 by the City Council has continually been referenced and is the basis for additional reports such as the preliminary engineering report prepared in conjunction with applications for project funding.

[22] Where is the reference for this information?  Engineering estimates based on discussions with the Payson City Engineer and market analysis indicate the cost of pumping equipment and the connection lines at over $8 million.  This information is available in the City’s adopted capital facilities plans (see footnote 21).

[23] The only federal grant money currently approved and available to Santaquin is $4.9 Million from USDA and $1.0 Million from CUP, which is attached to the referendum bonds. Any request for grant money must go through an application process.  The grant money through USDA Rural Development is available because the Santaquin population was less than 10,000 people when we applied for it over three years ago.  The City population in the 2010 census was 9,128.  It has been two years since that census with 84 more homes issued building permits.  Not counting natural increase this equates to 348 more people in the City based on Census household estimates.   There is no certainty that other grant funds are available or will be available with application delays and the Federal budget climate today.


Myth No. 7:  The Payson connection would sacrifice valuable water rights.
            Water rights will be retained by Santaquin City and can be used at a later date.[24]

[24] Where is this information from?  There are  no agreements in place and currently no additional funding available for water to be provided back to Santaquin after it reaches Payson.  The State Engineer’s office has recognized Santaquin’s claim on 5,300 acre feet of water for reuse out of our treatment facility.  That claim is valid because none of the treated water has gone “downstream.”  Once that water hits another jurisdiction, they can utilize it and claim rights it.   There has not yet been a proposal to compensate Santaquin for loss of those rights or how Santaquin retain them for use “at a later date.” Any means of getting water back up the hill will have additional expense.  The only sure way for Santaquin to retain its water rights and have the actual water for its citizens to use is to not let the water go downstream.
 

Myth No. 8:  The proposed MBR plant bonding represents a “bargain.”

Citing low interest rates and available federal funding, the City attempts to characterize its proposed bonding plan as a “bargain” for its residents.

Debt, though, is debt.  And the City wants its residents to assume nearly $10 million in debt for the next 40 years. This would duplicate operations[25] of an existing wastewater treatment facility that has yet to be paid for. The City’s plan represents no “bargain” at all.

[25] The proposed facility will not duplicate the existing treatment process. Treated water will not be retreated between the lagoons and the proposed MBR.  In fact, the new facility will triple the amount of water able to be treated and assure a long term solution to the City’s current sewer situation.  Yes, the debt will exist for a long time.  The City Council did the same thing in 1993 when it approved a 40 year loan on the current system, with expectations it would only handle 20 years of growth in the community. 


Myth No. 9:  If we build the plant, your sewer rates will never go up.

The City has claimed that, if we just borrow the $9.9 million and accept the federal funds, Santaquin residents will never see another rate increase beyond cost of living adjustments.  Simply put, the city administration is in no position to make such a promise[26].

[26] It is true that the City administration does not set the fees for the City.  City fees are approved and set by the City Council.  In relation to the current sewer fees, however; in order to obtain the proposed funding package Santaquin was required by the State of Utah Department of Water Quality (DWQ) to to set a maximum range for the proposed average sewer fees and hold a public hearing on that range.  That hearing took place on December 16, 2009 with the proposed average range of total sewer fees being between $35 and $45.  The average sewer fee was later set by the City Council on August 18, 2011 at $42.00 with an annual increase based on consumer price index (CPI) changes.  The DWQ board approved Santaquin’s funding based on this City rate and the maximum affordable rate for household median incomes in Santaquin. 


While the city engineer has estimated the initial construction costs of the proposed MBR plant, no one has projected – or even estimated – increased operation and maintenance costs[27] associated with the system.  Neither has the city projected the cost of its proposed plan to deliver the Type 1 waste water produced by the plant to Santaquin’s [28]homes, fields or commercial properties – a process that would require special hose bibs, and special limited use instructions – costs which would inevitably have to be recovered either through increased rates and/or fees.

[27] See comment #1.

[28] The funding package includes funds necessary for the pumping and piping of the Type I water into the irrigation system.  It also includes funds required to retrofit all the hose bibs in the City to accept the water.  No additional fees are needed to pay for these items.


In short, the proposed MBR plant will cost Santaquin residents a great deal more than $18 million in the long term.  Funds to satisfy additional (and presently unknown) costs will have to come from somewhere.[29]

[29] The City has already spent $1.9 Million toward fixing the sewer problem.  There is no additional City sewer money to solicit other funding sources if the proposed bonds do not pass.  Additional monies needed to secure other funding opportunities, at presently unknown costs, will have to come from somewhere. 


Myth No. 10:  We can borrow the money now, and decide what to do with it later.

Mounting opposition to City Hall’s proposed bonding initiatives in recent weeks has produced a remarkable shift in the City’s position[30].  Rather than simply dictating the construction of the plant as previously stated, City representatives are now saying that the bonding should be put in place, and the obligation incurred; and then we can revisit the question of what to do with the money.

With respect, this is the height of fiscal irresponsibility.  Obligating the citizens of Santaquin to repay nearly $10 million, over the course of 40 years, without first finalizing a firm plan for disposition of revenues, simply makes no financial sense at all.  Without a plan in place, nothing establishes whether the bond amounts are excessive, inadequate, necessary or unnecessary.  Public indebtedness is a serious concern under any circumstance. Public indebtedness without purpose is simply foolhardy.

*  *  *  *  *
Santaquin’s future wastewater treatment needs will clearly change as the population grows.  The proper response, though, is a carefully-considered, staged and proportional expansion of existing facilities, or partnering in existing mechanical facilities – not a rush to multi-million-dollar municipal bonding for the construction of a duplicative mechanical facility which Santaquin does not need, and cannot afford[31].

[30] The City has known since the bond discussions in January 2011 and had it reiterated in July 2011 by USDA that the funding package could be utilized for any option previously considered in engineering reports.  All funding partners have said that the money could only be used for options previously considered, which do have estimated costs associated with them.  The City Council has continually asked staff to consider in more detail the options other than the MBR in case the funding package does not pass.  Although these options have cost estimates there has been no design completed for them.  The State Department of Water Quality has stated that if the City chooses a non-MBR option it will need to amend its planning documents and complete additional environmental review processes and construction drawings before the money could be used. All other options will cost the City additional monies.

[31] Both the USDA and the State of Utah have determined that Santaquin can afford the proposed funding package even if no additional growth occurs.  This is partially based on the $1.9 Million dollars the City had available to invest in a sewer project.  If the bonds are not approved, then the City stands to lose over $1.5 Million of the funds


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