RECENT COMMENTS
Combined sewer overflows and Gillies Creek
by Kristin
The City of Richmond is trying to argue that Gillies Creek is a lost cause when it comes to cleaning up fecal coliforms that spew into the river via multiple combined sewer overflows everytime it rains more than 0.2 inches. They are proposing to do a “use attainability analysis” to show that its not feasible to reduce bacteria to a level that is safe for human health. Essentially, the City would like to put cleaning up Gillies Creek on the back burner in perpetuity, essentially meaning that raw sewage would flow untreated into the James River for generations to come.
Much of Church Hill is in the Gillies Creek watershed. I guess that means we just shouldn’t poop when it rains?
I don’t know about you, but the thought of our collective raw sewage being dumped into Gillies Creek, and subsequently the James River, is disgusting and deserves some attention.
I understand that it may take a while to fix, but the City should at least come up with a plan, even if we can’t implement it right away.
Anyone who wants to comment on the idea of the City investigating whether Gillies Creek is worth cleaning up or not, should check out the public notice and send comments to the State Water Control Board:
Comments should be received by November 1, 2010 and submitted by mail to David Whitehurst, Department of Environmental Quality, P.O. 1105, Richmond, VA 23218, or 629 E. Main Street, Richmond, VA 23219, or via email to david.whitehurst@deq.virginia.gov. Phone number for questions is (804)698-4121.
Also, here is a link to the document the City submitted to the Department of Environmental Quality and the State Water Control Board justifying why Gillies Creek is at the bottom of their to do list:
http://www.deq.virginia.gov/wqs
It is also worth noting that at the State Water Control Board meeting on Sept. 28th, board members asked City officials pointedly if the public had access to Gillies Creek. Two board members made it very clear that children will find creeks and play in them, whether the water quality is healthy or not. City officials insisted that Gillies Creek flows through private and city lands, strongly implying that public access is not feasible. They failed to mention that Gillies Creek flows right through a public park. I belive there was a stream clean up held there just a few weeks ago. Shameless!
Guest written by Kristin. Have something that you’d like to see published?
Kristin, the link does not seem to take me to any study. Also, I don’t mean to defend the city, but technically the creek does not flow through the park, it flows on the north side of Soney Run Road, whereas the park is on the south side of the street.
I think this is an important topic as it is strongly related to issues of environmental justice but also fiscal prudence. We need to clean up the Bay, which means cleaning up the James. It won’t be cheap so where can we get the most bang for our buck?
Also, there is the whole issue of the City, and by extension City taxpayers and utility customers, bearing the full cost of all improvements to the CSO system. Many, many people downstream from Richmond will benefit from improved water quality that results from the City making improvements to its CSO system, yet we have to bear most of the cost. Seems like the state and perhaps feds should be chipping in a bit more.
Fred, while I agree with your presentation of economic and environmental tensions, I’m not following your downstream logic.
I think the larger issue has to do with civic stewardship. We made the mess and we need to wipe our own behinds. Not ask the down river folks to do it for us.
@MJI, it’s hard to make a complete argument in a comment, but here’s my point. Most of the problem is the result of infrastructure decisions made nearly a century ago. “We” as in the current city residents didn’t really make the mess, we inherited it. I would agree that generally when a polluter is creating a problem, the responsibility lies on them to clean it up, but things are rarely so simple in the real world.
Let’s just say it’ll cost $300 million to clean up Gillies Creek to a level that is safe for human contact. Now, some of benefits that derive from that clean up would certainly accrue to the City and in particular to adjacent land owners by virtue of a cleaner stream. But a decent chunk of the benefits would also accrue to downstream land owners (i.e. relatively wealth folks who can afford river front property on the James) and users as the James River would now be cleaner. Furthermore, there’s a whole class of folks downstream who benefit, such as fishers, crabbers and others.
Given that “we” (i.e. City residents and utility customers) did not create the original problem it stands to reason that all beneficiaries of the clean up ought to assist with the cost of the clean up. I’m not saying the City doesn’t have some financial responsibility in the matter. It just seems unfair that the City, saddled with old, inherited infrastructure, high rates of poverty and all manner of other problems is being asked to bear nearly all of the cost of these improvements when substantial benefits will accrue to others downstream. Therefore, it would be appropriate for more state and federal funding for CSO improvements rather than leaving the cost burden mostly on the City.
This goes both ways, though – the folks downstream have been paying the cost of our pollution already for years. Asking them to help pay for the clean-up now doesn’t exactly seem fair.
Thanks for posting this! The whole culvert cost THE CITY what like $250 million to build and now it’s going to cost how much to fix? Didn’t they demolish Fulton to build this mess? Do it right the first time and there won’t be a problem. The city should definitely fix it. It’s our sewage and hence our problem. It’s an embarrassment to our community. Demolish some of the high density and high crime areas in the watershed (you know who I’m talking about 31st st. and alphabet city) if you don’t want to clean up the mess to decrease the amount of sewage flowing downhill.
@john_m and Mars: I think we also need to consider the overall impacts of the costs associated with this cleanup, if we keep the costs entirely on the City and its residents. It will substantially raise utility rates and perhaps cause an increase in property tax rates. Now you’ve just discouraged people from living in the City and encouraged people to move to the suburbs (at least those with the means to afford to live in the suburbs), thus encouraging greater suburban sprawl, and diminishing the James River watershed further.
Mars, demolishing the high density development is actually the worst solution as all those people need to live somewhere. If they’re forced to live in lower density development the overall impact to the watershed will actually be worse.
John, I agree that the damage the substandard CSO system has been a burden to many people, but it’s been that way for over 100 years now, so the cost is effectively incorporated into everyone’s expectations of the value of property in the lower James watershed. If we pay the full cost to clean it up we’re effectively subsidizing their property value increases.
Lastly, I think the critical issues here are temporal and fiscal. The infrastructure in question was put down a century ago, blaming anyone today for it is absurd. Fiscally speaking, it seem patently unfair that one of the poorest jurisdictions in the state should have to bear the full cost of improving infrastructure when that improvement will accrue substantial benefits to many others outside that jurisdiction. BTW, the same logic applies to the CSO problems in Lynchburg. All of us in the greater Richmond area would benefit from cleaner water if they improved their CSO system, so we all ought to be contributing to its improvement.
Nice way to put that, thanks for the thoughtful response.
Thanks John. FWIW, I’m not saying the Gillies Creek shouldn’t be cleaned up. I’m just trying to point out the unfairness of the State forcing the City to do it and pay for it, when a lot of benefits will accrue to others. I’d love to see all the City’s waterways properly restored, but again, that’s expensive and the benefits will be widespread, beyond just the city.
How is it legal for raw untreated sewage to drain into a river, even with a small amount of rain as the cause? Someone call the EPA. They need to spend more time helping serious environmental issues, instead of just lobbying against certain industries.
This was not the reason they demolished Fulton Bottom.
@James, the EPA (by way of the state DEQ) has been very involved in getting the City to clean up the CSO system since the 1970s. While it’s sad that untreated sewage can still flow into the James River during certain rain storms, the incidence of untreated releases is much lower today than it was a decade ago. See the City’s timeline for CSO improvements here:
http://www.ci.richmond.va.us/PublicUtilities/projectCombinedSewerOverflowTimeline.aspx
I dispute the City’s claim that cleaning up Gillie’s Creek will cost $300 million. Yes in the long run, we need to fix all of our CSO’s so that raw sewage doesn’t pour untreated into our surface waters, but in the meantime, innovative approaches like regenerative stormwater conveyance systems, which could be designed in the existing concrete channel, could be used (see: http://cedb.asce.org/cgi/WWWdisplay.cgi?264716). This type of approach would significantly reduce bacteria concentrations in the stream channel, as well as in the discharge to the James.
And there are ample funding sources from state and federal governments to help pay for these types of projects.
I’m not arguing that we shouldn’t consider the expense of a project and prioritize appropriately, I’m arguing that we need to come up with a plan to fix the problem even if that plan will take decades to implement.
We are responsible for our sewage. Period. Regardless of the infrastructure we inherited.
Kristen, your ASCE link takes me to a blank page. I would be interested to find out more about these innovative solutions. Also the link to DEQ in the original article still doesn’t take you anywhere.
I would also point out that “ample” is a relative term. Yes, there are federal and state grant programs available for cities to upgrade their CSO systems, but the overall grant funding pales in comparison to the costs of the needed upgrades to all the CSO systems across the country. Just look at DC. Their sewer authority will need over $2 billion alone to implement their LTCP. And that will still leave them with a system that discharges raw sewage under certain circumstances. EPA and others aren’t handing out $2 billion grants left and right for these LTCP improvement. The vast majority of the funding ends up coming from the local utility rate payers or the local taxpayers.
@Fred – try to copy and paste this address for the VA Town Hall regulatory notice:
http://www.townhall.state.va.us/L/ViewNotice.cfm?gnid=304
I’m not sure why the link to the ASCE site isn’t working – try copying and pasting maybe? http://cedb.asce.org/cgi/WWWdisplay.cgi?264716
Also, if you Google “regenerative stormwater conveyance systems” it’s the 4th link shown.
I think the thing to keep in mind is that a plan can be implemented over a long period of time, with the most critical components yielding the biggest “bang for the buck” done first. While we don’t see $2 billion grants for CSO repair all at once, we do see millions at a time – we just need to start taking the steps necessary to get there.
But our new storm-water tax….Oops, I mean “fee” is supposed to take care of this, correct?
We could start another initiative with all the non-migratory Canadian geese that pollute the James River. Have you seen how much these birds stain the rocks white with their own poop?
The reason why its a fee is to make sure entities like VCU and churches chip in.
It may not be completely corrected in my lifetime but I am glad to see a start.
My generation, Gen X, has a lot to fix.
The City has spent the better part of the last 25 years and upwards of 500,000,000 dollars “cleaning up” the CSO issues; that project is roughly two-thirds complete. Those fixes are one of the reasons our wastewater rates are as high as they are. Cleaning up Gillie’s Creek, a concreted structure with a 10 foot fence around it, and a depth of 2 inches, does not seem to me to be a place where we want to spend hundreds of millions more dollars to make the creek usable for recreational purposes. I would rather the money be spent on other fixes that give residents a bigger bang for the buck. Prioritizing where and how much money is spent is something that needs to be done. There is not enough money in the pipeline to fix all the infrastructure problems out there. we have to make hard choices. this is one of those choices.
I finally got a chance to read the whole “Reasonable Grounds” document and I generally have to agree with rivergirl here. The design of the existing channel and the typical flow rates mean the creek is not really a recreational resource. Furthermore, the draft planned Phase III CSO improvements will reduce CSO outfalls to Gillies Creek, it just won’t be enough to reach the water quality standards for recreational use. Considering the cost of the previously implemented CSO improvements has been $270 Million and the planned Phase III will cost $500 Million, plus the additional costs the City notes for other improvements DEQ will require, I can understand their hesitance to spending an additional $300 Million on further improving a waterway that is highly unlikely to be used for recreation.
I also looked at the “regenerative stormwater conveyance systems” and I don’t think they could be applied to Gillies Creek. When CSO outfalls occur, the creek is carrying diluted, untreated sewage. Creating ponds and other systems that hold this mixture of storm water and raw sewage would be more problematic as you would now have open ponds with diluted sewage near residences. This would be more dangerous as now you have a situation where children could actually submerge themselves in tainted waters. As someone who lived near Battery Park during its extended flooding, I can attest to the putrid smell that occurs when you have extended ponding of such mixtures.
While it is certainly not ideal to retain a system that allows the release of untreated sewage into local streams, we have to balance the cost and the benefits and in this instance it appears the benefits do not outweigh the costs at this time.
….and it’s not like the City is asking to completely write off the creek in terms of meeting recreational bacteria standards….the creek would still have to meet secondary contact bacteria criteria as opposed to primary contact criteria.
oh…and for you folks that can’t seem to find the Reasonable Grounds document try looking here –> http://www.deq.virginia.gov/wqs/designated.html
The secondary standard is 600 cfu/100ml – the primary contact stnd is 126 – you’re right, it would be more difficult to blow the secondary standard as its 4 times higher. I think the most the City could hope for is suspension of the primary contact use during 0.2″> events.
Anyone ever heard of Rocketts or Ancarrow’s Landing? Everybody lives downstrem folks.
If you think the state and feds should chip in more – a large amount of the money the city brags about having spent on CSO and capitol improvements WERE state and federal funds. DEQ was forced to cut its entire fish program and lost $500K in funding to the air program – just narrowly escaped layoffs due to the recession.
A UAA is just a study only it is followed by a decision which may result in the alteration of a designated use. The City has the right to ask to do one. Citizens should make it their own responsibility to pay attention to what’s going on in the waterways by voicing their concerns one way or the other during the comment period. The state needs input – get involved – no input means that decisions are made by default. If you have time to post a comment on this blog you have time to comment on the UAA study…that might actually get us somewhere.
Remeber – the Board meeting is public meeting too – everybody gets 3 minutes.