Open Letter to the City Coucil - By Butch Neylon

July 3, 2006

Dear Councilors:

With over forty years experience in the construction industry much of it in the Water and Wastewater areas, I have been involved in all aspects of the design, construction, commissioning, operation and maintenance of Sewage Collection and Treatment Facilities. I have been involved in the planning and budgeting process relating specifically to improving many wastewater collection and treatment facilities.

Some of my more recent projects include major upgrades to the collection system and treatment plant for the city of Lowell, Massachusetts, a 120-MGD facility, substantial upgrades to the wastewater treatment facility for the town of Adams, Massachusetts, a 10-MGD facility, substantial improvements to the pumping stations and treatment plants in the communities of Mystic, Stonington, and Pawacutuck, Connecticut consisting of multiple pump stations and three treatment plants along the Connecticut shoreline that handle a combined total of 7-MGD, upgrades to multiple pumping stations and a complete overhaul of the 180-MGD Bondi Island WWTP for Springfield, Massachusetts, and the addition of several pumping stations, improvements to existing pumping stations, and installation of new instrumentation and control systems at the 10-MGD wastewater treatment plant for the town of Enfield, Connecticut.

These are a few recent projects in which I have been involved, and I respectfully submit that my background and experience in this area qualifies me to speak to the issues confronting Marco Island with regard to the STRP. Every statement that follows is supportable and verifiable; I will be only too pleased to provide data and backup documentation for all assertions contained herein.

Improving Marco’s wastewater treatment plant and failing infrastructure is necessary regardless of whether the collection system is extended. Although there is some disagreement over this, plant capacity must also be increased to provide for undevloped lots already served by the sewer system, as well as for future development to build-out.

The initial cost analysis to rebuild the treatment plant exceeded $50 million, and ultimately grew to $68 million as the Utility opted for the more expensive MBR technology. Recovering this via the rate structure was not thought to be feasible because sewer rates would have more than doubled and existing users would have rebelled. Other sources of funds had to be found. At that time, it was assumed that septic systems were a health hazard and were polluting our waterways, and the STRP was born of these two parents; the need for additional funds to upgrade our WWTP and the presumption of pollution and health hazards caused by onsite treatment. In fact, the capacity charge portion of the special assessments was designed specifically to fill in the funding shortfall while providing some rationale for rebuilding the plant at the expense of new users. The STRP met with serious opposition, even more so now that the health and pollution claims have been disproved.

It is time to take a new look at funding the needed improvements for the WWTP based upon what we know today, and in light of the recent passage and signing into law of HB-149 it is doubtful that the STRP will remain intact for the entire 7-years as proposed. Therefore, funding for the WWTP must be crafted in a way that does not rely upon the STRP to raise money. Fortunately, this can be done! There is another – and far more equitable – way to rebuild the WWTP without perpetuating the STRP and the stiff opposition accompanying it.

This is a simple plan, one that has already been initiated and needs only to be formalized to stop the contention and put an end to lawsuits once and for all. The plan involves reducing the expenditure to rebuild the treatment plant by doing only what is necessary to correct the problem. In short, it calls for the Marco Island Utility to live within its means.

When the first phase of the Wastewater Treatment Plant construction – the so-called “substantial improvement” phase – is complete this fall, the plant will consist of one new 3.0-MGD MBR train and two existing 1.25-MGD conventional trains for a total plant capacity of 5.5-MGD. Projected cost is less than $30 million, of which $7 million is available from covenants of the 2003 bond issue, and applying grants and impact fees will reduce the amount by up to $8 million more.

There are two ways to pay for these improvements: sell a new revenue bond to fund the improvement and add the bond cost to the rate, or levy a one time assessment to existing users to pay for the new system. The first option will add between $6.00 and $8.00/per month to the sewer rate depending on the application of existing funds, grants and impact fees. The second option would require a one time fee between $1,000 and $1,500 per existing user and although there are significant interest savings to be realized by this method, it may be politically less palatable.

There are other advantages to stopping construction after the initial phase is complete. MBR is more expensive to operate and maintain than conventional treatment. It requires highly skilled and trained operators, and it is technically more difficult to maintain a balance of treatment capacity and low odor emission. In short, MBR is much less forgiving than conventional treatment. Taking this into account a hybrid plant consisting of, (3.0 MGD MBR and 2.5 MGD Conventional), has environmental, safety, and operational advantages over a 100% MBR plant. This hybrid plant will also have significantly lower operating costs which will ultimately be reflected in lower rate increases as energy costs rise. During times when the island is less populated and flows are lower, it may be possible to take the MBR train off line for maintenance and run the conventional trains, thereby producing a substantial savings in operating costs.

Furthermore if the 5.5-MGD capacity is reserved for the areas where it is needed, (the high density area of Collier Boulevard and other commercial areas presently served by the existing sewage collection system), then there will be enough capacity for these users through build out, and well into the foreseeable future. There is no need to sewer the neighborhoods, as the existing septic systems are not posing a public health hazard, causing any pollution of our waterways, and the expansion of the user base is no longer necessary to fund the plant improvements.

We can put an end to the lawsuits, stop digging up our neighborhoods, put Marco Island Utilities on an even keel with renewed infrastructure and a plant that will not be a burden on all of us for between $6.00 and $8.00/month added to the sewer rate. If the existing plan is carried out sewer rates will rise at least twice that amount and the island will experience 7 to 10 years of ongoing construction. As new information becomes available it is prudent to revisit recent decisions in light of that new knowledge, and, if appropriate, make whatever modifications are deemed necessary to improve the overall result of the original decision. As our elected officials you can do no less.

Respectfully,
Butch Neylon