PA DEP

PWSA Fields Questions on Stormwater Project Delays

Posted on November 12, 2021 by Special Reports 0

On Oct. 19, the Pittsburgh Water and Sewer Authority (PWSA) held a meeting via Zoom to update the public on its Four Mile Run Stormwater Project. The project, announced in 2017 as a way to address severe flooding in the Four Mile Run neighborhood (The Run), has come under fire from skeptics who say it is designed around the controversial Mon-Oakland Connector (MOC) plan. The MOC, announced in 2015, calls for building a road for university shuttles on the same land as the stormwater project. During the Q&A period after their presentation, PWSA officials made several false statements related to the MOC.

Shuttle road more integral to design than previously shared

Asked if PWSA is providing space in its stormwater plan for the MOC, Mallory Griffin of construction firm JMT (which is involved in the PWSA project) answered no. Yet PWSA senior group manager Tony Igwe asserted that removing the MOC from the watershed plan would require PWSA to start over, which would cause significant delay and cost millions of dollars in changes.

“PWSA has always said the stormwater project will still move forward whether the trail is there or not,” Mr. Igwe explained. “But what we never said was how much additional cost and time would be required if the trail isn’t there… To suddenly shut down one piece of that project, take it off the table, and then ask us to do a project, the first thing that’s going to happen is now we have to redesign the project to take that Mon-Oakland [Connector] out of the equation.”

The public has been told repeatedly at public meetings that the watershed plan and MOC are “two separate projects.” PWSA’s own notes from its Sept. 2020 public meeting on the stormwater project state:

“We are going to do the stormwater project no matter what. If the roadway stopped being planned, we would have to amend our permit, which would result in a paperwork review for [the Pennsylvania Department of Environmental Protection (PA DEP)] and some timing changes, but we would still do our project. For the stormwater project, the money is committed, the PWSA board has approved it, the design is essentially complete, and we are moving forward with it.”

In several earlier public meetings, former stormwater project manager and current PWSA Board Chair Alex Sciulli had assured residents that the stormwater project takes precedence and that removing the MOC would not cause a significant delay because they are two separate projects.

New mayor, MOC opposition portrayed as obstacles

Ms. Griffin said that the PWSA hopes to have the permit approved by this winter, but warned of consequences if the MOC is removed as residents have been requesting for years. Slide 21 of PWSA’s presentation reads, in part: “If the new City Administration changes or removes the Mon-Oakland trail design, permitting will need to start over causing significant delay.”

Outgoing mayor Bill Peduto introduced the MOC plan to advance university and foundation goals. Mayor Peduto became Pittsburgh’s first incumbent mayor to be unseated since 1933. Mayor-elect Ed Gainey, by contrast, has clearly stated that he opposes the MOC. According to his campaign website, “Ed will stop the buildout of Mon-Oakland connector and prevent the construction of other privatized or quasi-privatized mass transit systems designed to support luxury development at the expense of existing residential communities.”

Community members at the meeting reminded PWSA of this, but Mr. Igwe said, “Up until that is done officially, all we’re really dealing with is people giving us their ideas and opinions on where they stand, and until someone puts something in writing formally that says it’s from the office of the people who can make the decision, that’s where we have to assume the project is going until it’s absolutely clear that it will not.”

Run residents have suffered a total of 10 major 25- to 75-year flood events in the last 15 years. They say a 10-year flood event plan (per PWSA’s current design parameters) is dangerously inadequate and that addressing floods must be prioritized. Every flood in The Run is an illegal combined sewer overflow that contains raw sewage—not merely stormwater runoff—which independent stormwater management consultants have labeled a public health and safety crisis.

Budget numbers continue to fluctuate

PWSA will spend $42.65 million on the stormwater project, according to their latest presentation. In a June 2020 meeting, another public presentation revealed that only about $14 million is going directly to flood relief in The Run. Asked why, PWSA acting senior manager of public affairs Rebecca Zito responded in an email on Aug. 24, 2020, “The remaining funding can go towards future projects in the upper portions of the watershed, provide opportunities to collaborate with the universities and other community organizations on future stormwater projects, or revisit some of the original green infrastructure projects planned for Panther Hollow Stream and Phipps Run.” (emphasis added)

Excerpt from Nov. 10 PWSA letter in response to resident statement at Oct. 22 PWSA board meeting

Subsequent presentations between then and now have added items that were not previously considered part of the “core” project in the Junction Hollow section of Schenley Park. It is unclear whether the money set aside for opportunities to collaborate with the universities has been diverted to these new items, including “Construction Management / Inspection” (which presumably was always needed to complete the project).

In a letter responding to a resident’s statement at PWSA’s Oct. 22 board meeting, Mr. Igwe included the information from the budget slide and said the budget “does not contain $26 million ‘being held back for future projects.’”

Good news break: Sidewalks restored

The Oct. 19 presentation included photos of sidewalks in The Run that were dug up in the process of moving gas lines in advance of the stormwater project. One community member commented that the strip of rocks filling the trench down the middle of the sidewalk looked like “a tripping hazard.” A Run resident said they had been told the sidewalks would not be replaced until after the stormwater project is completed.

Ms. Griffin said the sidewalks were “100% in Peoples’ scope to replace” and pledged to “follow up with them tomorrow first thing to see what their schedule is for replacing the sidewalks.”

About two weeks after the meeting, construction crews returned to The Run. As of Nov. 12, they were putting finishing touches on the new sidewalks.

PA DEP concerns downplayed

PWSA received a technical deficiency letter from PA DEP dated May 27, 2021, in response to their permit application filed for the project in August 2020. Ms. Griffin and Mr. Igwe both mischaracterized this letter during the Q&A session, stating that the deficiencies identified were unrelated to the MOC. Ms. Griffin said that in a subsequent PA DEP letter “they had no questions on the trail’s impact to the flooding.” This point is debatable, but PA DEP’s concerns in the May 27 letter regarding the MOC are not incidental. Of 35 items listed in the 8-page letter, 13 specifically mention the MOC. For example, environmental comment 26 refers to additional permit requirements associated with the MOC:

“Since PWSA is the applicant, will PWSA be responsible for the operation and maintenance of this section of DOMI’s project? Alternately, please consult with DEP, regarding additional permit requirements, if PWSA will not own or have primary responsibility for this section of DOMI’s Mon-Oakland Mobility Project.”

On Oct. 29, PA DEP sent PWSA a second technical deficiency letter. They identified remaining “significant technical deficiencies” and requested a meeting with PWSA to discuss and explain them. Comment 17 in this second letter asks PWSA to “confirm that the Mon-Oakland Mobility Project is the same as the DOMI trail” and clarify that the full scope of the project is shown in a drawing called the “Boundary Street Concept North of Junction Hollow.”

“If there are additional components and/or sections of the overall DOMI Trail/Mon-Oakland Mobility Project,” the comment continued, “please note that a Comprehensive Environmental Assessment may be requested.”

After the Oct. 19 meeting and before receiving word of the second letter, residents asked the PA DEP to delay their decision to approve or reject the dual permit until at least February 2022.

PWSA Pushes Ahead on Four Mile Run Stormwater Project Without Permit

Posted on July 17, 2021 by Special Reports 0

Despite receiving a Technical Deficiency Letter from the Pennsylvania Department of Environmental Protection (PA DEP) in response to their dual permit application for the problematic Mon-Oakland Connector (MOC) shuttle road and Four Mile Run Stormwater Project, PWSA shows no sign of reconsidering its plans. The current stormwater project is inadequate to address the flooding issues, in part because it was designed around the MOC. On top of that, existing flood protection benchmarks do not account for worsening conditions caused by overdevelopment and climate change.

May 27: The PA DEP sent the Technical Deficiency Letter. Its engineering and environmental comments contained numerous references to the MOC and requests for clarification on its impacts. Here is a small sampling of problems from the 8-page letter.

Engineering comment 5d: Was the area as a result of the Department of Mobility and Infrastructure proposed trail and road incorporated into the flood analysis inundation limits study for proposed conditions. Provide evidence that the impervious area will not contribute additional flow increasing water surface elevations detailed in Figure 01 & Figure 02 of Project 2018-GI-102-0.

Environmental comment 25: Per Module S1, in the EA, “The purpose of the Project is to manageand/or remove direct stream inflow to the existing CSS within the Junction Hollow valley of Schenley Park and to improve the CSS system from Junction Hollow to the Monongahela River, by repair, replacement, and/or separation of the CSS and stormwater lines. The goals and benefits of the Project are to reduce CSOs; reduce flood risks and basement backups; reduce sediment transport; and leverage resources for regional benefit, including align with the Parks Master Plan.” Describe the relationship between PWSA’s project and the City of Pittsburgh’s project, in terms of the project purpose.

Environmental comment 26: The Pittsburgh Water and Sewer Authority (PWSA) is identified as the applicant, on the application form; however, the Project Description identifies the Mon-Oakland Mobility Project as a City of Pittsburgh project, led by the City’s Dept. of Mobility and Infrastructure (DOMI). Since PWSA is the applicant, will PWSA be responsible for the operation and maintenance of this section of DOMI’s project? Alternately, please consult with DEP, regarding additional permit requirements, if PWSA will not own or have primary responsibility for this section of DOMI’s Mon-Oakland Mobility Project.

Environmental comment 29: Since this application only includes a section of DOMI’s Mon-Oakland Mobility Project, identify and describe, to the extent possible, any and all potential impacts to aquatic resources, including watercourses, floodways, floodplains and bodies of water, from the overall Mon-Oakland Mobility Project. Please note that based on your response to this item, that a Comprehensive Environmental Assessment may be requested.

The letter stated that PWSA had 60 days to respond to these comments, or the application would be considered withdrawn. The deadline was July 27.

May 28: At the monthly PWSA board meeting Ziggy Edwards of The Run urged the PWSA to create a model for the stormwater project that does not include the MOC. She also asked for a report PWSA commissioned from ms Consultants that provides great detail on the Four Mile Run watershed and was funded with ratepayer dollars.

June 3: PWSA chief of project management Alex Sciulli denied Ms. Edwards’ request for the report. Regarding the dual permit application, Mr. Sciulli said he “asked staff to prepare a response to the PA DEP letter and to provide additional clarification regarding the stormwater impact of the proposed MOC, including the specifics of the ms Consultants report and previous modeling.” He added, “At the appropriate time, we will be happy to share and discuss our response to your inquiries.”

Mr. Sciulli did not clarify how PWSA would be able to address in two months the fundamental shortcomings identified by PA DEP.

June 13: Intense storms caused flash flooding in The Run that totaled several cars, damaged a garage, and caused sewage backups in basements.

June 25: At the monthly PWSA board meeting, several Run residents spoke and/or submitted statements regarding the June 13 flood. Ms. Edwards again implored the PWSA to come up with a plan to address flooding that is not designed around and hindered by the MOC.

“We need answers on how much better PWSA could address the combined sewer overflows without [the road]. These answers have life-or-death importance to The Run,” she said.

Ray Gerard of lower Greenfield recounted the flood’s aftermath in his statement. “The City again neglected to show up and remove inches of leftover fecal matter on the streets, sidewalks and limited community green space. The neighborhood literally smelled like [$#!*] for days. It’s understood that there are other areas of the city that suffered damage and flooding, but that was runoff storm-water, not raw sewage… Residents and their children are forced to breathe this toxic air in for days. Our local officials continue to ignore, at great risk, the lives and health of Run residents.”

July 9: PWSA senior group manager Tony Igwe sent a letter to Run residents informing them that although “the plans for the stormwater project are being reviewed by the [PA DEP] and we cannot move forward with construction [on the stormwater project] until a permit is issued … People’s Natural Gas (PNG) will begin construction to replace existing gas lines along Saline Street, Alexis Street, Four Mile Run Road, and Boundary Street.” The letter included a tiny image of a map with illegible text (see image above).

Stay tuned for updates on PWSA’s response to the Technical Deficiency Letter and whether PNG’s planned construction lacks necessary permits.

8 Urgent Questions for PWSA Board of Directors Re. Stormwater Project

Posted on February 27, 2021 by Special Reports 0

On February 26, 2021, Ziggy Edwards of The Run addressed PWSA’s board of directors at their monthly meeting. She brought concerns from her neighborhood that the design and implementation of PWSA’s Four Mile Run (4MR) Stormwater Project suffers from skewed priorities. The project, which will include major construction on the only road into The Run, focuses on accommodating the Mon-Oakland Connector (MOC) rather than fixing severe flooding.

The following questions, which PWSA also received via email, are based on information in the Right-to-Know (RTK) request documents we have received so far and independent expert analysis of the plan submitted with the permit application to the PA Department of Environmental Protection and the US Army Corps of Engineers.

1. Why did the Heinz Endowments pay Howard Neukrug (past Philadelphia Water Commissioner) to review the PWSA stormwater project? (source: PWSA/CEC 4MR Weekly Meeting Minutes, April 16, 2019)

2. How much of the $40 million for the PWSA stormwater project did not come from the Heinz Endowments and/or other foundations that own the Hazelwood Green development?

3. How can the three new PWSA board members, who all have ties to entities with vested interests in the Hazelwood Green (HG) development, oversee the stormwater project in a fair and impartial manner that doesn’t benefit HG at the expense of Schenley Park and residents in The Run? For that matter, how can the other board members be fair and impartial in this project when they were all directly nominated by Mayor Peduto (a longtime proponent of the MOC)?

4. As you may know, the proposed MOC adds at least 0.80 acres (34,850 square feet) of paving to Junction Hollow. With the types of storms Pittsburgh has had in the past 10 years, a year with 50 inches of rain would generate an additional 1 million+ gallons of runoff to The Run. Why does the plan in the permit application propose to pollute this stormwater runoff by directing it from the MOC to the existing combined sewer system and not to the new stormwater network that flows directly to the river?

5. Did any consultant not funded by HG owners evaluate the impact of this stormwater project design on The Run? What did the consultants say about the absence of stormwater inlets of pipes along the proposed MOC road? What did they say about the absence of stormwater runoff from the road to the daylighted stream?

6. Is it true that the PWSA stormwater project’s construction plan calls for 4MR Field across Alexis Street from Big Jim’s to be used as a staging area for construction equipment and materials?

7. Because the “Parkway side” of the 4MR watershed is excluded from PWSA’s stormwater project, residents of The Run are still likely to see stormwater arrive in our neighborhood from that side of 4MR—even after this highly disruptive project is completed. Any flood water that enters the combined sewer network above The Run will still be in the combined sewer pipes running under the neighborhood. Therefore, if the volume of stormwater entering the combined sewer pipes above The Run is greater than those combined sewer pipes can handle, we are still likely to see raw sewage come to the surface from the remaining combined sewer inlets and/or manholes. Why is none of the $41 million earmarked for this project, which was billed as a solution to flooding in The Run, being spent on remediating the “Parkway side” of 4MR?

8. Is the PWSA board of directors aware that PWSA was ordered by the Office of Open Records to complete a review and provide the rest of its documents responsive to our RTK request? The deadline was yesterday [February 25, 2021]. At 8:52 p.m. we received a link to a zip file with a password that doesn’t work. Will the board encourage PWSA Attorney Samuel Hornak to resolve this issue as quickly as possible, since PWSA effectively missed the deadline?

Letter to PA Dept. of Environmental Protection and U.S. Army Corps of Engineers

Posted on December 31, 2020 by open letters 0
image from permit application

Pennsylvania State DEP
Dana Drake, P.E.
dadrake@pa.gov
Phone: 412-442-4149 l Fax: 412-442-4242

U.S. Army Corps of Engineers
Mike Engelhardt
Michael.D.Engelhardt@usace.army.mil
Phone: 412-395-7141

Dear Ms. Drake and Mr. Engelhardt,

This open letter concerns the Pittsburgh Water and Sewer Authority (PWSA) permit application for the Four Mile Run Stormwater Project:

Pennsylvania State DEP ID: E0205220-031
U.S. Army Corps of Engineers Permit ID: CELRP-RG LRP-2018-774

As you know, Pittsburgh’s Department of Mobility and Infrastructure (DOMI) is attempting to get their developer-driven Mon-Oakland Mobility Project (also known as the Mon-Oakland Connector, or MOC) approved by the Pennsylvania Department of Environmental Protection (DEP) and the U.S. Army Corps of Engineers (USACE) by attaching it to the PWSA stormwater project.

These two projects do not belong together.

Junction Coalition joins numerous individuals, community organizations, and public representatives in calling for the PA DEP and USACE to send this permit application back to PWSA with direction to remove the DOMI project from the application before the permit is approved.

The PWSA stormwater project enjoys nearly universal public support because it was sold as a solution to The Run’s chronic flooding problem. Run residents have been asking for help to fix the flooding for more than a decade. They were told the city lacked funds as the problem worsened from combined effects of climate change and unregulated overdevelopment of surrounding higher-elevation areas.

A 2009 flood, which PWSA labels a 75-year event, caused catastrophic damage: Cars floated down the streets in 6+ feet of water and sewage, while residents watched 70+ inches of the mix breach the first floor of their homes. 

A 25-year flood event in 2016 gained citywide attention when dramatic footage showed firefighters rescuing a resident and his son from the roof of their car. Later that year, Mayor Bill Peduto tasked PWSA with finding funds and developing a plan to fix the flooding.

A city-mandated 2017 survey of Run residents recorded unanimous demand for flood relief and a large majority of residents adamantly opposing the MOC.

The MOC is a road through a public park that debuted to Run residents in a 2015 Pittsburgh Post-Gazette article reporting the project as a done deal. It is a huge investment of taxpayer dollars in a private development plan that studies show does not meet Pittsburgh’s stated goals. Even DOMI director Karina Ricks admits that the MOC is not a transportation solution.

Instead of responding to residents’ legitimate concerns about the MOC, public employees twisted those concerns to seem like a baseless fear of progress. They tried to pit neighboring communities against each other. They filed fraudulent grant applications and applied for new grants without telling the public. They used public meetings for time-share marketing tactics rather than honest discussion, pretending to consider alternative routes for the shuttles before again settling on Schenley Park. They responded to Right-to-Know requests with claims of attorney-client privilege and a 7,185-page unsearchable PDF. They obscured and constantly changed details such as the route. And recently, several Run residents who live near one of the rejected alternative routes received letters from DOMI implying they may lose their homes and businesses through eminent domain.

These are not the actions of people with good intentions. If the MOC benefited those who live in the communities it affects, Mayor Peduto’s administration would not need to resort to duplicity and steamrolling. Furthermore, if Hazelwood Green’s powerful owners had no desire to annex Schenley Park and adjoining neighborhoods, they would drop their single-minded focus on getting shovels in the ground as soon as possible and instead support alternative plans such as Our Money, Our Solutions that offer more effective transportation for more people without causing the harms of MOC. 

Evidence shows that PWSA’s stormwater plan fails to prioritize the severe flooding issue and was designed to accommodate the MOC project. In their current 10-year flood event design, PWSA is following behind-closed-doors directions from Mayor Bill Peduto’s office. From their budget of $40 million, PWSA listed their flood mitigation efforts at $14 million. Asked where the remaining $26 million would be spent, PWSA responded via email, “The remaining funding can go towards future projects in the upper portions of the watershed” and “provide opportunities to collaborate with the universities.” All PWSA Board members are nominated by Mayor Peduto, a longtime MOC proponent. PWSA’s plan includes several wish-list items of the Pittsburgh Parks Conservancy, a private entity on whose Board of Directors Mayor Peduto sits.

Expert consultants who have analyzed the current PWSA stormwater plan tell residents:

  • The proposed Mon-Oakland Connector project would most likely harm flood control—with an approximately 1/2-mile long (39,600 sq ft) impervious surface that eliminates 7 acres of old-growth tree canopy from Schenley Park. That amount of paving would generate about 295,000 gallons of runoff. Every acre of impervious surface generates 27,000 gallons of runoff for each inch of rain and Pittsburgh has seen a range from around 36-60 inches of rain over the last 10 years. PWSA has not proven that including the MOC will not harm flood control and has refused repeated requests for all engineering plans/documents of the PWSA stormwater project for independent analysis.
  • PWSA concentrates the stormwater work in the Schenley Park/Oakland end of the watershed, which would address only 1/3 of flooding in The Run. The rest comes from the opposite end of the watershed—the Squirrel Hill/Greenfield/376 Parkway end. Although it only accounts for 1/3 of the cause of flooding, the water/sewage mix from 5,200 structures above Panther Hollow Lake in Schenley Park feed into a 50-inch pipe that completely bypasses the Panther Hollow/Junction Hollow area of the watershed and feeds directly into The Run. PWSA’s plan does not address this specific connection and its effects on the neighborhood. 
  • PWSA’s plan would level approximately 7 acres of tree canopy to make room for the MOC project (beginning with 900 trees in the northern end), which will never be replaced in the space the roadway would commandeer. Furthermore, replacement saplings will not equal the water absorption of 7 acres of mature trees.
  • PWSA’s 10-year event plan “makes no sense”—unless it involves changing the floodplain and eliminating properties. RTK-obtained notes from a Mayor’s office meeting show PWSA Chief of Program Management Alex Sciulli stating, “More cost-effective options may be to change the floodplain and purchase the affected properties.” The “cost-effective” plan makes sense only within a larger plan to raze the neighborhood, forcing out residents and demolishing structures instead of the promised flood mitigation.

Flooding in The Run is a serious health and safety issue that cannot be ignored to serve developers’ financial interests. Therefore:

  • The dual permit application from PWSA and DOMI to the PA DEP and USACE must be denied, and PWSA must be directed to fully separate the two projects. 
  • The PWSA plan must prioritize the flooding issue instead of merely providing cover for an unwanted, unnecessary road that will permanently degrade Schenley Park and eventually erase two historic Pittsburgh neighborhoods.
  • PWSA must present a plan acceptable to residents whose lives and properties are at risk. Such a plan would include:
    • Documentation of studies done to assess the impact of MOC on the PWSA stormwater plan.
    • An Environmental Impact Study on the overall stormwater plan.
    • A Community Benefits Agreement guaranteeing compensation to residents who suffer damage from future flooding, as many residents currently cannot acquire flood insurance.

We are disappointed in your timing of the public comment period on this joint permit application to coincide with the holiday season. We hope you will give this important matter the time and impartial consideration it deserves.

Sincerely,  

 Junction Coalition

Categories

Most Shared Posts