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Whether it’s on-lot systems or a cluster, the challenge is management.
By Penelope B. Grenoble
In case you missed it, onsite systems are here to stay. With development continuing nationwide and federal funds to subsidize centralized treatment all but dried up, what was once seen as a temporary solution is now being trumpeted as a permanent approach to wastewater management.
But what will this emerging brave new world look like? How far can we go with decentralized wastewater treatment? Are we looking down the barrel of watershed-wide management? Is reuse of onsite effluent in our future?
To get a handle on where we might be headed, Onsite Water Treatment spoke to advocates nationwide and turned up some good and not-so-good news. Future challenges include funding, public apprehension about alternative technology, and real and projected political hurdles. In the plus column we discovered lower costs for onsite wastewater treatment versus conventional sewer, innovative funding opportunities, and the potential for public-private partnerships.
Although the Onsite Water Treatment survey was random, everyone we spoke with considered the trend toward onsite systems a plus, which appears to be a good thing, considering the EPA estimates that onsite wastewater management currently serves 25% of the US population and 40% of new development. Across the country, visions varied from plugging onsite management into existing public utility structures to entrepreneurial partnerships. Despite the fact that the US Census concludes that at least 10% of existing systems have ceased to function and failure rates may be as high as 70%, management continues to be spotty. Some states, such as Maryland, have seen the future and it is now. Others, such as Alabama, have taken some cautionary first steps. One common denominator is a kind of missionary zeal among advocates and early adopters who are convinced of the value of onsite systems, particularly as part of a comprehensive wastewater policy.
At Aquapoint Inc. in New Bedford, MA, Chief Executive Officer Craig Lindell has made it his business to investigate where things might be headed. For Lindell, the future is one of integrated water resource management, although he admits we are a long way from arriving at this preferred destination. “The onsite world is largely administered under the health codes. But the health codes have no provision for management. They are basically codes that are meant to assess, advise, and assure.” What Lindell would like to see is more crossover between public health and water quality in a paradigm that would consider onsite and centralized wastewater management as components of an overall management “architecture.”
Here to Stay, but How to Manage?
Utility or management entity, public or private, we’re a long way from getting a handle on managing onsite systems.
In light of the decline of state revolving funds and acknowledging limitations on its initial intent to “sewer the world,” as one industry player puts it, the EPA reported to Congress in 1997 (Response to Congress on Use of Decentralized Wastewater Treatment Systems) that decentralized wastewater treatment was here to stay and should be taken seriously. In this newly anointed onsite world, the response veered toward alternative approaches that extend existing soil-based systems, eventually leading to the National Sanitation Foundation system certification program.
Seven years after its conclusion that onsite was the wave of the future, the EPA issued voluntary guidelines to help state and local jurisdictions with management (EPA Guidelines for Management of Onsite/Decentralized Wastewater Systems). The guidelines contain five management models, each level specifying progressively increasing controls as a function of accelerated environmental sensitivity and treatment system complexity. In addition, the document provided guidance for a management concept the agency dubbed “responsible management entities.”
Each of the EPA’s five models contains 13 critical elements the agency has identified for effective management programs including performance requirements, site evaluation, design and construction, operation and maintenance, residuals management, corrective action (to ensure systems function properly once installed), public education, planning (to coordinate zoning and wastewater management), training and certification for systems operators, compliance inspections, financial assistance and funding, and record-keeping and inventory. Although states have voluntarily adopted the guidelines, sticking to the EPA’s 13 requirements can be a tricky business.
According to onsite guru Kevin White at the University of South Alabama, the underling problem facing the onsite world is that without management, the performance life of systems currently being required to meet public health codes and environmental protection standards can be minimal. White originally envisioned the future as one in which the EPA’s management entities ruled and homeowners paid a monthly fee similar to centralized sewer services. His vision, however, has expanded.
“We need,” says White, “to be thinking about all of wastewater management on a continuum that ranges from septic tanks to decentralized clusters to big centralized sewer systems and megatreatment plants—and all under the realm of a wastewater management entity.”
Public Versus Private
But for state and local regulators, the EPA’s management entities may be the future’s double-edged sword. Alabama, for example, has created an accredited list of private entities, which are subject to a level of scrutiny the state’s municipal managers are exempt from. In Pennsylvania, Ed Corriveau, chief planning and finance manager in the south central regional office of the Pennsylvania Department of Environmental Protection, suggests caution if the entity is a public utility. “Large utilities tend to lose perspective,” says Corriveau, who nonetheless admits his state is “inching toward” some kind of centralized management of on-lot systems. “We know we need more operations and maintenance, particularly in the area of new technology.
“Right now, Pennsylvania is tying approvals back to management that is established by individual municipalities, but we haven’t yet reached a conclusion about the actual amount of bare-bones management we need. My suggestion would be to have a complete municipal oversight and management program. Whether it’s staff or contracted, I see people who are doing everything from taking care of operations to inspections and repairs.”
Bob Pickney didn’t waste any time 15 years ago in establishing the Tennessee-based Adenus Group, a private management entity, which now includes clients in Alabama, Tennessee, Mississippi, and Georgia. Pickney says that anyone thinking of entering the field should know that after 15 years, the company is just now breaking even.
“In some most states, we’re classified as a public utility company. We’re no different from the telephone company or natural gas provider, which provides service to the public in a regulated manner. Except for Alabama, every state we operate in has a public service commission or a public utilities commission that handles the financial regulations, plus agencies that handle the environmental compliance. So there’s a nice box for us to fit into.”
Managing the Manager
Approximately 25% to 30% of Alabama is currently on onsite systems: Focus on new construction and the state matches the EPA’s assessment of 50%. In an attempt to get a handle on how these systems are managed, Alabama passed legislation two years ago that requires all private onsite management entities operating two or more systems to be certified and undergo financial scrutiny every two years. A primary goal, says Jimmy Coles, director of community environmental protection in the Alabama Department of Public Health, is to keep onsite systems from being turned over to homeowner associations that are not equipped to manage them.
As Coles describes it, developers building subdivisions outside city limits have the choice of putting houses on individual systems or building clustered systems and turning them over to a municipality or a private management entity. Cole’s Department of Public Health sets the fees for clustered service in conjunction with the state’s Public Service Commission. In legalese this means management entities must have a certificate of financial viability from the health department, but it’s the Public Service Commission that makes the judgment about the financial strength of the entity. If the entity is judged sound, the commission will recommend a rate to be charged to system users. The Department of Health, on the other hand, has the authority to set the actual tariff.
Coles admits this involvement of the Public Service Commission is unique, but it also fills in a gap in the health department’s expertise. So far, fees have been established at $40 to $50 a month. However, only one or two of the management entities have been through a two-year turnover, and on the first round their costs were estimated.
Coles sees lack of scrutiny of collection systems as a major weakness in Alabama’s management of onsite treatment. “Most of the treatment is essentially black box. An engineer designs the flow coming into it, and the effluent is disposed of in disposal fields. We’ve found that the big management entities like the Pickneys build a good system because they know if they don’t, they’re going to have problems. But we’ve already had a couple of cases where a system has been installed that was less than perfect and we had to go back and get it fixed. So we’re trying to get more uniform collection systems going in.”
Pickney thinks Alabama’s attempt to manage the management entities is inadequate because the Department of Public Health lacks funds and a staff. “They approved the program, but they didn’t approve the money or the mechanism to make it work. Given all the systems that have to be inspected and looked after, one person can’t be in charge of managing all these management entities.” Coles agrees. “My guys go out in the field looking at people’s backyard septic tanks. They’re not experts in 2 miles of gravity-sewer and pump stations.”
The solution? Minimum specifications, says Coles, that require certification by a qualified engineer, or perhaps the state. “That’s the best we can do right now. The next step would be to have public health inspectors.”
The situation differs in Alabama’s public sector where White has convinced three public utilities in Mobile County, including the Mobile Area Water & Sewer System and the rural Central Alabama Electric Cooperative, to utilize treatment clusters. With White as consultant and cheerleader, the utilities have in turn convinced developers to pay some of the capital costs of system installation and have picked up a payback in the form of the monthly service fees.
“I’ve advocated that the utility control absolutely everything,” says White, “meaning they own and operate every component of the systems. We’re using effluent sewer here so each home has a septic tank and pump, sometimes a STEP system. The utility owns them, which means it has access to come onto property and open the tank and clean it when necessary—at no charge to the customer. If the pump goes out, the utility replaces it, again at no charge to the homeowner. The sewer line is put in to spec by the developer and then turned over to the utility for ownership and operation. The treatment plant is owned and operated by the utility, just like a central sewer system.”
And the challenges of taking on management at this level? Number one, says White, is lack of knowledge within the engineering community that advises public wastewater utilities, which he thinks is just not up to speed on decentralized onsite systems. “Technologically it’s simple, but it’s the concept the engineers have a problem with. The other major problem is the utilities themselves, which are used to operating large sewage treatment plants. But if you think about how a septic tanks works, it’s the same process that’s used in a large treatment plant. It’s just a different format.”
Distributed Management
In Loudoun, VA, the Loudoun County Sanitation Authority (LCSA) provides wastewater services to unincorporated parts of the county and took on onsite systems management in a fluke. “Starting in the ’70s,” says the LCSA’s Todd Danielson, who sits on the Water Environment Federation’s Small Communities Committee, “we took over a couple of community-scale package plants, then a couple of lagoon systems. Since then, the county Board of Supervisors has signaled that it’s interested in maintaining the county’s rural and historic nature and passed an ordinance that would cluster new development. They also made the decision that these new communities would not be served by centralized sewer. Developers would have the choice of building individual on-lot systems or clusters, and LCSA would own or operate any community systems that were built.
“Essentially LCSA has established a policy that we don’t want to concern ourselves with operating on-lot systems because it would be cost prohibitive and would distract us from serving the larger public. So right now, we don’t serve any systems of less than 15 connections. The county allows private operation of systems of no more than two connections, so there’s a gray area between three and 14 connections.
“At LCSA we haven’t completely closed our minds to the idea of at some point managing onsite systems, especially if they’re above groundwater sources that we use to provide drinking water. It’s just that historically, utilities have not considered it, and private entities don’t always have the sustainability component of public utilities.” Having said that, Danielson thinks the future may look something like what Lindell refers to as “distributed management,” where one entity manages systems whether they’re individual onsites, clusters, or a mix. Danielson agrees this approach could provide a “much better managed scenario and may be much more economically appropriate.”
Above all, Danielson recommends a full-cost accounting of what it takes to install an onsite system, what he calls the triple bottom line concept. “You’re not only looking at the economics but also the environment—that is, putting a dollar value on environmental protection, and on the social aspects. With long sewer pipelines, there’s a huge risk potential for raw sewage entering the groundwater, and of lowering groundwater tables with the French drains in collection systems.
“A community-based perspective could be beneficial to the environment and more sustainable. We’ve got cluster systems discharging back to groundwater we’re using for drinking supplies. Hands down this is a more sustainable approach than someone with a water facility discharging their effluent downstream several miles where they can’t use that water again. This kind of thinking leads you to start considering the real role of utilities and the services they provide.”
A Question of Funding
In Pennsylvania, Corriveau thinks management of on-lot systems boils down to management control of state-certified sewage enforcement officers. “There’s enough systems out there to keep everyone busy,” says Corriveau, “but part of the problem with individual on-lot systems is determining what you charge. And then how do you get owners of existing systems to pay for something they haven’t paid for the last 10 to 20 years?
“I don’t think you can do that on the private side. You have to have a private-public partnership. The public has to want to protect its water, and the politicians have to be committed. Massachusetts gives a tax break for nitrate systems. Maryland has a flush tax. That’s one of the milestones—that states at some point make the statement that everyone’s got to be responsible for water.” According to Corriveau, Pennsylvania is seeing 25,000 to 35,000 new on-lot systems a year added to the million-plus already in place. “Everybody was in denial that these were just temporary systems. But onsite is a long-term solution and we have to respect it as such.”
Down in Maryland, John Boris, project manager for the Maryland Department of the Environment’s Bay Restoration Fund, says “flush tax” is a misnomer. The Bay Restoration Fund is actually a $30 fee paid by every property owner in the state. “We call it a fund because it’s a dedicated source of funds directed toward a dedicated purpose. If you’re on a public utility, the $30 goes toward upgrading sewage treatment plants. Sixty percent of the money, $7.5 million, goes to help offset the cost of upgrading septic systems to denitrification units. The other 40% goes to cover crop programs.”
Through the fund the state is covering the first five years of operations and maintenance in the cost of installing the onsite units. “We’re doing this,” says Boris, “because we realize that without management, these systems don’t work.” In some cases, the per-system cost turns out to be less than a comparable utility bill.
By way of getting a handle on what’s actually happening in the field, the state is also requiring manufacturers to provide training to contractors who service the new units. “The service entity would be anybody who’s trained by the manufacturer of the unit, private contractors basically. We feel this is the best way to go about the individual on-lot systems. This also means that in effect we’re looking to privatize management, but anytime you can privatize a system, you’re creating industry at the same time you avoid expanding government.”
Boris says the objective is that property owners will pick up the maintenance contract after the five years of grace the state provides. Given current views of the “flush tax,” this assumption may nor may not be well founded. “Nobody else has tried generating the money to encourage the use of these denitrification systems,” say Boris. “And in Maryland, it’s very controversial. Some people view it as a tax, and some people view it as a necessary evil to restore Chesapeake Bay. You would think $30 a year wouldn’t be a big deal, but it’s very controversial politically. The estimate is that bay-wide, only 4% of onsite systems are contributing to the nitrogen problem, but we have very specific sub-watersheds where the number is as high as 50%. It would be great if growth were always going to occur in what we call our priority funding areas, which are served by public treatment systems. But the reality is this is not going to happen. So the cost-effective solution is to start building more cluster systems. Right now, we’re writing discharge permits of 8 milligrams per liter for nitrogen. This is pretty low for onsite systems.”
As Boris suggests, public acceptance can be a sticky wicket in the brave new world of onsite management. In many cases good intentions get bogged down in questions of funding, and as White has suggested, in the old predilection to sewer. Austin-based consultant David Venhuizen has run into both situations. The small town of Bluff, UT, which was leaning toward combining individual on-lot systems with small cluster systems, appears to be backpedaling because of cost. “The community evaluated on-lot plus some small clusters as the most favorable among alternatives that included a centralized system,” says Venhuizen. “But projections about losing population related to declining flows in the San Juan River has sparked concerns about taking on long-term debt. The thinking now is more toward on-lots and minimizing the clusters.”
Similarly, Venhuizen says, a New Mexico community faced with the opportunity of a sewer trunk line appears to be edging away from less-familiar onsite technology. And across the country in Orange County, NY, in an emerging second-home community an hour above New York City, old and malfunctioning onsite systems have sparked a watershed-wide evaluation of wastewater alternatives to control phosphorus in receiving waters. Whether the community will buy into expanded onsite management and where it will get the funds to replace the old systems with new onsite technology is a big question for consultant Simon Gruber, who’s pinning his hopes on a new, environmentally sensitive mayor.
And, Danielson points out, such concerns are real. “There’s the issue of how much you want to rely on a treatment system versus the soil. We’re engineers, not soil scientists, and we’re not used to relying on the natural environment to provide a level of treatment. How much risk are you willing to take with respect to that? You would seem to be reducing your risk potential by having multiple point sources. But how much risk is the health department willing to take or the department of environment quality?
“At LCSA we established certain baseline standards that in retrospect were more stringent than they probably needed to be. So now in terms of sustainability, we’ve got some very expensive systems to operate out there. We’re starting to back off a little bit and rely on the natural environment to treat some of this wastewater so we’re not charging what could be considered inordinate amounts to our customers.”
The Road Ahead
Venhuizen and Danielson seem fundamentally in synch with Lindell’s vision for the future, which boils down to a watershed-wide approach whereby comprehensive wastewater management is integrated into a watershed-sized agenda. Wastewater, which we all see as a community resource, should be treated as close to where it’s generated as practical and maximum use made of the reclaimed effluent.
“Remember,” says Lindell, “wastewater is a relatively new utility. The presumption is that wastewater is an expense that can’t be born unless the public sector does it. So what you really have to do is market the sociology.
“What I’m suggesting is that communities would create water resource management districts in which the goal would be practicing sustainable hydrology along with community preservation and smart growth. One way to do that would be with private- public partnerships so you can take advantage of depreciation and market incentives. The idea is not to think in terms of comprehensive management plans as much as a continuous, constantly evolving planning process. With their monitoring and assuring function, health departments have exactly what they need to support this kind of watershed agenda, but we need to move the management into a professional model, and that’s the Department of Public Works.
“Currently individual communities typically have a conservation commission, a building code, some sort of zoning commission or planning group, plus a health department. The problem is that the local government has no way to correlate activities across this spectrum. They have the responsibility, but not the ultimate authority. But what if you had them all linked to a water resource management district? There are precedents for private-public partnerships in public services such as water, transportation, and energy, but that hasn’t happened in wastewater because everybody assumes it’s an expense.”
And as Boris points out, before we arrive at Lindell’s brave new world, we have to contend with more than a few ruts in the road. “In Maryland it’s documented that we could possibly reduce our nitrogen load quite drastically just with cover crops and treatment plants. But in the end we’re going to find that we’ve done all this work and the numbers have flip-flopped. We’re going to find the majority of our pollution coming from our urban stormwater runoff and our septic systems. Now comes the question of how we’re going to fund the upgrades to solve this problem. Because once you’ve picked the low-hanging fruit, it’s gone. Now you’ve got to get a taller ladder. And the taller ladder usually means doing things that we don’t want to do, which is usually to raise taxes or try to find new revenue sources. So the big question to me comes down to just ‘where do we get the money from?’”
Journalist Penelope Grenoble is a frequent contributor to environmental publications.
OW - July/August 2007 |
