US Army Corps of Engineers

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

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

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