On Friday, the Pennsylvania Environmental Council submitted formal comments to the Allegheny County Sanitary Authority raising fundamental questions about its plan to reduce combined sewer overflows in the Pittsburgh Region and the federal consent decree it is based on.

While commending ALCOSAN for its “thorough response” to the specific requirements of the federal consent decree, PEC said, “this plan is constrained by the parameters of the federal consent decree, the sequencing of the municipal consent orders and required feasibility studies, the composition of local governments in this region and the pending regionalization evaluation.”

PEC highlighted what it called structural deficiencies with the consent decree and the plan developed by ALCOSAN--

-- The gray infrastructure solution proposed by ALCOSAN does nothing to address the root cause of the CSO/stormwater problem in the region;

-- The process imposed by the federal consent decree is inconsistent with the process driving the municipal feasibility studies reducing the potential of green infrastructure and other source reduction measures to reduce excess flows;

-- The fee for service model used by ALCOSAN charges customers for the amount of water they use not the amount of water they put into the system for treatment doing nothing to incentivize source reduction; and

-- Green infrastructure and other source reduction measures are not address at all in the ALCOSAN plan.

A copy of PEC’s comments are available online.

            NewsClip: ALCOSAN Asked To Adopt Green Plan To Cut Sewage Spills

10/22/2012