Dear Concerned Parties:
The following set of Questions and Answers has been prepared by the Plum Creek Municipal Authority (PCMA) and/or on behalf of the PCMA relative to the Act 537 Plan Updates for South Manheim Township and Wayne Township. Please note that this list is not entirely inclusive and that other responses are expected to follow.
(1) The Health and Safety of the Lake Wynonah community is dependent on a reasonable and cost effective sewage management plan (SMP)
The $50 annual Sewage Management Program Administrative Fee is the only charge for administering the Sewage Management Program (SMP). This fee covers the administration of the new SMP by an outside consultant, who is also a Sewage Enforcement Officer (SEO). When the PCMA closes the WWTP, it will have no income pertaining to sewage management other than the Administrative Fee. The Fee covers the inspection of each Septic Tank (every 3 years) and each Holding Tank (annually) during pumping events, as required by the PA DEP. It also covers the following:
· The initial program set-up, including the preparation of a Sewage Management District Map to facilitate ongoing administration and inspection for pumpers and the SEO;
· Preparation of a comprehensive database to generate notices, track pumping and inspection, etc.;
· The tracking of all pump-outs and management of administrative items such as pumping and hauling records, inspection records, malfunctioning system records, etc.; and
· All clerical and administrative fees.
(2) The proposed plan calls for private haulers from a list developed by PCMA that residents would then call for pumping That is a dramatic drop in our current “one-call” PCMA service guarantee. That is expected to dramatically increase septage hauling rates to homeowners with no assurance of the “one call” service our residents have utilized for 50 years. Sewage is not like trash hauling. PCMA should continue to manage sewage hauling and inspections. At a minimum, PCMA could negotiate and manage a contract with a single, licensed and certified professional waste transportation company hauler who will guarantee service to all Lake Wynonah residents and properties.
The Approved Haulers List is the new Single Point of Contact for the sewage pumping and hauling, and the revised Sewage Management Program (SMP) will be monitored by an SMP Administrator.
The following are requirements that must be met in order to be placed on the “Approved Outside Haulers List”:
1. Haulers must be licensed and insured for pumping and hauling of waste materials.
2. Haulers must be members of the PA Septage Management Association (PSMA).
3. Haulers will be required to perform and coordinate inspections of the tanks during cleaning events.
4. Haulers must guarantee a response time of three (3) days maximum for responding to pumping requests.
5. Haulers must empty the Septic and Dosing Tanks.
6. Haulers must complete all necessary pumping and hauling manifests and paperwork associated with each pumping event for use in record keeping.
The PCMA does not set the pumping rates/costs. Therefore, competition will drive the marketplace.
(3) Tank Inspection services should be performed by independent PCMA managed inspectors. Not private haulers. Conflict of interests regarding hauling and inspection by the same personnel is not healthy for our community.
The Administrative Fee includes inspection of the Septic Tanks and Holding Tanks, which will be conducted by an SMP Administrator, who is qualified to perform these tank inspections.
(4) I oppose any new “administrative” fees without clear justification. The proposed $50 annual administrative fee is not justified with recent increases in hauling fees and no reduction proposed for water rates.
See No. 1 above. The water fees are entirely separate from the sewer fees.
(5) The proposed $50 annual administrative fee should NOT be enacted by reason of unfairness.
See No. 1 above. The $50 fee is quite reasonable.
(6) Pumping of holding tanks and cleaning septic systems by ONE HAULER as has always been done, is best for residents’ health and safety.
This is why there will be an Approved Hauler’s List maintained by the PCMA and the SMP Administrator, with the criteria listed under No. 2 (above).
(7) Do NOT allow outside haulers jeopardize our health and well-being. Uniformity is key; and allowing haulers without knowledge of terrain, and our community in general should NOT BE DONE.
See No. 2 above. There will be a transition period to allow Outside Hauler’s to become accustomed to the local conditions and terrain.
(8) The PCMA should continue to handle pumping services and inspections to ensure service and consistency to all Lake Wynonah residents. Our expectations are that our lakes (and our community) will be protected by one entity handling this important aspect of waste management. This can be accomplished by PCMA negotiating a contract with a single, licensed and certified waste management company. This will guarantee consistent pumping and inspection services to all lake residents and property owners and therefore protect our bodies of water, a very valuable asset.
See No. 1, 2, and 3 above. There will be an SMP Administrator, who will manage the new SMP. PCMA will not set rates for pumping and hauling, but it will maintain an Approved Haulers List per the requirements specified in No. 2.
(9) The Funding analysis, Section O.2. on page 16 of 127 (pdf page) indicates a “Service Fee.” Page 53 section 17.0 of Financial Responsibilities indicates there will be a $50 annual administrative fee per household for every household with an existing sewage facility, which is a “User Fee”. Will there be both a “Service Fee” and a “User Fee” If so, how much and for what services?
The only Fee that is part of the new SMP is the SMP Administration Fee of $50 per year. See No. 1 above. The only other costs to residents will be the individual costs for pumping and hauling the waste from their tanks, once every three (3) years for Septic Tanks, and at least once per year for Holding Tanks.
(10) PCMA currently administers the current SMP. These costs were embedded in “sewage costs” in the SSM Alternative analysis, which claims savings of several hundred thousand dollars/year to exit the sewage business. If closing the plant will result in such significant savings, why is a new fee of $50 per household per year needed?
See No. 1 above. The fee covers the SMP administration.
(11) Section 8. Administration Methodology and Record Keeping, Letters K say Property owners will be responsible for contacting the services of a registered Pumper or Hauler. Letter L says that PCMA will maintain a list of registered Haulers and Pumper, but it is not an “approved” list. We do not think this is acceptable.
The PCMA and the SMP Administrator will maintain an “Approved Haulers List.” See No. 2 above.
(12) We believe PCMA should continue to manage the hauling. Ideally, the property owner would contact PCMA when ready for pumping service. PCMA should then contact the qualified hauler(s), sequentially dividing the work among the qualified hauler(s). This will avoid any conflict of interest as previously discussed by the SEOs at several Township meetings. It will also serve to balance the load among the qualified haulers.
The SMP Administrator will now manage the system, but it is up to the property owner to schedule a pumping event when needed.
(13) Holding tanks are of particular concern and there still remain about 125 holding tanks. Currently “holding Tanks” pay about $190/pump. The “SSM Alternative Analysis” indicated that these fees could increase to the $500-$600 range. We believe PCMA, as the Municipal Authority, should do everything possible to prevent this, as fees increasing this fast will place an undue financial burden on the property owners and could encourage “cheating” which could be devastating for a lake community.
The PCMA has always had a “soft spot” for Holding Tank customers and has always kept their pricing low, at $190.00 per pumping event. When the PCMA closes the WWTP, the Holding Tank customers will be faced with real prices in the open marketplace, with a range of approximately $400.00 – 600.00 per pumping event. To blame the PCMA for the previous financial benefits is unfair. Holding Tank owners have been, and continue to be, asked to convert their systems, wherever possible, to Septic systems. This will allow the Holding Tank owners to save maintenance costs down the line.
(14) To date, we do not believe PCMA has demonstrated the economic advantage of using outside haulers vs continuing the use of PCMA trucks. We think a cost analysis of this should be required before any final decision is made to outsource hauling.
The PCMA has selected this option as the best choice long-term for the Community. The WWTP and hauling equipment are no longer cost-effective to maintain, and repairs to the WWTP could be $750,000 or more, which will include increased costs to the Lake Wynonah Community, not to mention the increasing maintenance costs and costs to Operate the WWTP.
(15) Don’t add an unfair $50 per year “administrative fee” per household when service is being reduced, water rates are not going down and the “administrative fee” could escalate over the years. . The one call system currently in use by PCMA for pumping tanks and hauling of sewage by PCMA continues to be a critical health and safety issue for Lake Wynonah. PCMA should continue to be the primary provider of pumping and hauling sewage. Multiple private sewage haulers is not a healthy or safe plan for Lake Wynonah.
See No. 1 and No. 2 above.
(16) Can we have a clear justification for the proposed $50 administration fee? And guarantee of no increase or contract stating when costs can be increased? PCMA should continue to manage inspections or an independent hauler hired by PCMA Sewage haulers should be limited to list of 1 or 2.
See No. 1 and No. 2 above.
(17) What does the $50 annual “service fee” cover? How was this number determined and what prevents it from being raised annually?
See No. 1 above. The PCMA and the SMP Administrator will do everything possible to keep this cost as low as possible.
(18) Fees to pump holding tanks will greatly increase. This will make properties with holding tanks significantly less valuable. What is a person with a property that will not perk and thus cannot convert to a septic system supposed to do?
Property owners with Holding Tanks have been asked to convert to Septic tanks wherever possible. However, the PCMA has determined that this is the most cost-effective long term solution for the Lake Wynonah Community. The 95% of the Community with Septic Tanks should not be asked to pay the increased costs of pumping out the 5% of the owners with Holding Tanks.
(19) How will owners know how to contact when a pumping is required and what prevents a single pumper from raising rates if there is no competition?
See No. 2 above. There will be an Approved Hauler’s List, and competition will drive the marketplace.
(20) Who will be responsible to ensure that property owners complete the 3 year inspection/pumping?
See No. 1 above. The SMP Administrator will track pumping and inspection schedules and maintain hauling manifests for the Community.
(21) Don’t add an unfair $50 per year “administrative fee” per household when service is being reduced, water rates are not going down and the “administrative fee” could escalate over the years. The one call system currently in use by PCMA for pumping tanks and hauling of sewage by PCMA continues to be a critical health and safety issue for Lake Wynonah.
See No. 1 and No. 14 above. The Administrative Fee is actually quite reasonable, and the PCMA will do its best to limit this fee in future years.
(22) Consider that the one-call system currently in use by PCMA for pumping tanks and hauling of sewage by PCMA continues to be a critical health and safety issue for Lake
Wynonah. Insist that PCMA should continue to be the primary provider of pumping and hauling sewage for this Community. Multiple private sewage haulers is not a good health & safety plan for Lake Wynonah. There would be a lack of checks and balances for pumping and septic inspections.
See No. 1 and No. 2 above relative to the SMP Administration Fee, the responsibilities of the SMP Administrator, and the fact that PCMA will retain a list of Approved Haulers. See No. 7 above regarding the transition period for Haulers to become accustomed to the conditions and terrain of the Community.
(23) We believe strongly that a single waste disposal company should be chosen via competitive bidding and that PCMA should retain oversight responsibility to ensure septic
system pumping as currently scheduled and related services for efficient waste disposal.
The PCMA will not set rates or require owners to use only one or two specific haulers for liability reasons. Competition will drive the marketplace, and the SMP.
(24) Environmental Impacts: Has there been an independent environmental review of the proposed plan, including the potential negative impact on lake and ground water
quality and property values? For example, what happens if an inexperienced ‘outside’ pump truck driver, unfamiliar with the hilly roads and driveways in the community, has an accident that results in massive sewage discharge into one of the lakes (small lake feeds into the big lake)? What happens to the quality of the well water if property owners ‘cheat’ and discharge untreated wastes, or if the inspection regimen is not strictly adhered to and fails to identify problem systems?
The SMP will be managed by an SMP Administrator, who will ensure that the inspection regimen is strictly adhered to and all problems are identified. The Administrator will also track pumping events and manage hauling schedules. There will be a transition period for outside haulers to become familiar with the local conditions and the terrain within the Community. These haulers are experienced and will be selected according to the criteria listed in No. 2.
(25) The DEP should ensure that the SMP makes the PCMA, or its qualified designee, responsible for taking calls from LW property owners for pumps; for contracting with pumper/haulers if PCMA does not pump/haul; for handling emergency calls; for scheduling, managing, and oversight of regularly scheduled septic and holding tank inspections; for customer billing and payments to pumper/haulers; for reading water meters at properties with holding tanks to ensure compliance; for negotiating septage discharge rates with SCMA (or others); for ensuring the proper decommissioning and environmental remediation of the PCMA plant; and for enforcing the SMP for LW.
See No. 1 for the duties of the qualified, SMP Administrator, who is responsible for administering the SMP on behalf of the PCMA.
(26) DEP should review and clarify the historical record, PCMA’s financial condition, and the physical condition of the plant to enable stakeholders to determine if the Alternatives Analysis was performed properly and the condition of the plant warrants its closure. However, the continuing operation of the plant is not the main issue—the continuation of a Single Point of Contact for sewage pumping and hauling is the main issue.
The Approved Haulers List is the new Single Point of Contact for the sewage pumping and hauling, and the revised Sewage Management Program (SMP) will be monitored by an SMP Administrator.
(27) What is the timeline for the proposed shutdown of the plant, the transition to outside haulers, the deactivation/environmental remediation and removal of the old plant and appurtenances? What is the schedule for completing the modification of Schuylkill County Municipal Authority Deer Lake treatment plant to accept trucked-in septage? DEP should ensure that DEP’s review and approval of the planned modifications to the SCMA Deer Lake plant (to receive trucked in septage) is conducted expeditiously, and that the modifications to the Deer Lake Plant are complete before the PCMA plant is shut down. DEP should also review the PCMA Act 537 process to ensure that the outcome of the Alternative Analysis was not predetermined and that PCMS’s choice of Option B is the optimum solution. We believe it is not.
The PCMA wishes to shut down and decommission its wastewater treatment plant (WWTP) as soon as possible. There are significant repairs needed to the WWTP, totaling over $750,000. The PCMA does not wish to pass on that expense to the Community in order to repair a 50-year old WWTP. Proper removal and environmental remediation will shortly follow the shutdown of the WWTP. The PCMA WWTP shutdown/decommissioning is not linked to, nor dependent on, the opening of the Schuylkill County Municipal Authority’s (the SCMA’s) Deer Lake WWTP septage receiving station, although that would be a positive, alternative, disposal location.
(28) Cost – What is the short and long-term cost to LW property owners, and to the LWPOA? What are the costs/benefits to property owners (cost to transition from Holding Tanks to septic systems) and the costs for future pumping, hauling, treatment, inspection, and management of the SMP? What is the cost/benefit for the LW POA to ‘open the gates’ to outside haulers? Are the costs used in the Alternative Analysis legitimate.
The following summarizes the cost to the Lake Wynonah Property Owners:
|
Customer Type |
PCMA Current Fee |
Anticipated Outside Hauler Fee |
|
Septic Tank Customer |
$280 per Hauling Event |
$200 to $400 per Hauling Event |
|
Holding Tank Customer |
$190 per Hauling Event |
$400 to $600 per Hauling Event |
|
Cost to Lake Wynonah Property Owner’s Association (LWPOA) |
||
|
|
$0 |
$0 |
|
Long Term Savings to Lake Wynonah Property Owners – $750,000+ in WWTP Upgrades and Debt Service |
||
(29) Environmental Impacts: Has there been an independent environmental review of the proposed plan, including the potential negative impact on lake and ground water quality and property values? For example, what happens if an inexperienced ‘outside’ pump truck driver, unfamiliar with the hilly roads and driveways in the community, has an accident that results in massive sewage discharge into one of the lakes (small lake feeds into the big lake)? What happens to the quality of the well water if property owners ‘cheat’ and discharge untreated wastes, or if the inspection regimen is not strictly adhered to and fails to identify problem systems?
The change in Environmental Impact is minimal in that the same number of pumping events is expected to occur. Actually, there will be fewer pumping events, as more property owners transition from Holding Tanks to Septic Tanks. See No. 1 above for the duties of the SMP Administrator. See No. 7 above regarding the transition period for Haulers to become accustomed to the conditions and terrain of the Community.
(30) DEP should inspect the plant, review the list of necessary repairs, and confirm the condition/projected remaining life of the sewage facilities. DEP should take note of the July 10, 2019 Resolution by the LW Board of Directors opposing Option C, and supporting Option B, which was passed via a unanimous vote of all 9 Directors. The DEP should ensure that the SMP makes the PCMA, or its qualified designee, responsible for taking calls from LW property owners for pumps; for contracting with pumper/haulers if PCMA does not pump/haul; for handling emergency calls; for scheduling, managing, and oversight of regularly scheduled septic and holding tank inspections; for customer billing and payments to pumper/haulers; for reading water meters at properties with holding tanks to ensure compliance; for negotiating septage discharge rates with SCMA (or others); for ensuring the proper decommissioning and environmental remediation of the PCMA plant; and for enforcing the SMP for LW.
The PCMA has chosen Option C as the best alternative for the whole Lake Wynonah Community. The SMP Administrator will be responsible for administering the SMP. Much study and thought went into making that serious decision. The Lake Wynonah Board of Directors has consistently chosen to favor the few residents that have Holding Tanks in its decision-making process.
(31) It should be noted that an argument in support of the Plan states that only holding tank owners will be adversely affected by the plant closure, and that 95% of property owners subsidize the 5% of permanent residences with holding tanks. Of the approximately 1250 systems in the community, about 150 are holding tanks, of which about 75 are permanent residences. Although holding tank owners will face the largest increases, septic tank owners will also see increased costs as 3rd party pumpers will likely charge more than PCMA currently does. It now appears that all property owners (or just property owners with a sewage system?) will be charged $50 per year for the Sewage Management Plan Administration by PCMA. How does the new fee benefit property owners? LW is a private community and contractors must be licensed and insured to enter, and possibly meet other requirements that might be imposed by the LW BOD. It is likely that some haulers will choose not to service the community. It is not likely that they will be as responsive and prompt as the PCMA (current response time for Holding Tank pump is 2 business days). As a whole, the community should present an attractive book of business for haulers, and there should be at least 2 or 3 under contract to PCMA. DEP should require PCMA to develop more recent and accurate cost estimates for the plan, and, if approved, require the PCMA to negotiate pumping, hauling and treatment fees before the plan is implemented. The price uncertainty and wide range of estimates contained in the Alternative Analysis is not sufficient information on which to approve the plan.
Approximately 95% of property owners will likely see some changes in their septic tank pumping fee, once every three (3) years during cleaning and inspection. Only about 5% of property owners will definitely see significant change in their Holding Tank cleaning fee. However, 100% of the property owners will be spared additional fees associated with the $750,000 estimated fees to repair the WWTP, in addition to the costs required to maintain the aging, pumper truck equipment and ongoing monthly operational fees for the WWTP, which also continue to increase.
See No. 1 relative to the SMP Administrative fee. This is the only charge for administering the new SMP. The charges for water by PCMA for residents is totally separate from the sewage charges. Additionally, the PCMA does not establish pricing for outside haulers. The haulers are private haulers and will charge their own fees. Competition will drive the marketplace. See No. 2 above relative to the requirements for being placed on the “Approved Outside Haulers List.
(32) Any plan that does not call for a single entity, like PCMA, to be fully responsible for the SMP should be rejected. This apparently was the position of the DEP in the past and should be now and in the future. The DEP was concerned that the sewage on-lot and holding tank systems could be polluting the drinking water, ground water, and the lakes. The thing that concerned the DEP the most was the density of the systems. The SMP program was adopted by both Townships’ Act 537 Plans, making the program “the law of the land”. “As long as the authority can prove through its records that the Sewage Management Program requirements are met, and as long as a program of extensive water testing is adhered to, Lake Wynonah will not have to implement central sewage.” One very important point that the DEP wanted included in the program was that the authority would be the only entity responsible for pumping and inspection of the systems because of the absolute necessity of single-party record keeping and accountability. The DEP should, when reviewing the plan, take into account the 1250 existing lots with septic, the small lot size (1/3 -1/2 acre on average), the private roads, the use of ground water as drinking water, the proximity of the lakes, soil types and slopes, and other unique features of LW.
The PCMA retains full responsibility for the SMP in Lake Wynonah, but the SMP will be administered by a qualified, SMP Administrator. With the shutdown and decommissioning of the WWTP, changes will have to be made with pumping and hauling to another treatment facility. The PCMA feels that utilizing several, approved, outside haulers is the best solution for the whole Community. See No. 1 and No. 2 above.
Thank you all for your time and consideration in this matter! Take Care!
Sincerely,
Jamie D. Lorah, P.E.
Manager, Process Engineering
Spotts, Stevens and McCoy
1047 N. Park Road
Reading, PA 19610
P: 610-621-2000 | D: 610-898-3044