Lake Ontario St. Lawrence River Plan 2014

Drinking Water and Sanitation

Comment Received

IJC Response

The IJC’s analysis did not take impacts on infrastructure into account, particularly impacts on sewers and septic systems.

The IJC’s analysis did gather data and use performance indicators to capture the impacts to infrastructure. This included potential flooding of drinking water and wastewater treatment facilities, impacts to shore protection structures associated with infrastructure, impacts on water intakes and outfalls, and additional costs to treat taste and odor problems at low water levels. Impacts to sewage conveyance and septic systems were also considered. Systems that are vulnerable to flooding and erosion under Plan 2014 were found to be vulnerable to such impacts under the current regulation plan 1958DD and others that were considered.

Why does the IJC’s economic analysis show no net impact in municipal and industrial category?

The $0 impact from Plan 2014 in the municipal and industrial water category signifies the plan will produce no measurable change in the impacts to municipal and industrial operations compared to impacts under the current regulation plan. In all cases where concerns were raised about water supply and wastewater operations, the Study Board found that these facilities will experience the same problems under the existing regulation plan. For example, while drinking water treatment plants on the St. Lawrence River will incur additional treatment costs during prolonged droughts, these costs were the same under Plan 2014 and Plan 58DD. Any estimated flooding and storm impacts to buildings or shore protection used in water or wastewater were reported in the coastal damage categories.

When water levels are at 247-feet (75.29 m) and above, sewer systems from the Niagara River to Greece, through Sodus Point and up to Watertown will be flooded and cease functioning, causing major health and environmental problems.

Lake Ontario levels at elevation 247-feet (75.29 m) and above occur under the current regulation plan (Plan 1958DD) on a regular basis (the chance that the peak annual Lake Ontario stillwater level will be above 247-feet is 12.8 percent, and, the stillwater lake level is above 247 feet 2 percent of the time overall). While the IJC heard no evidence during the public hearings that major health and environmental problems have occurring in the past, systems that are prone to failure at elevation 247-feet (75.29 m) are, over time, almost certain to cause problems no matter how the lake is regulated. Communities cannot rely on the regulation plan to prevent such problems.

Plan 2014 would cause flooding and destruction of the Monroe County Water Authority potable water supply treatment plant.

Plant operators have written that the plant has been sandbagged under the existing operating rules. Given the design of the existing facilities, such procedures will be needed under any regulation plan, though sandbagging will be expected to occur somewhat more often under Plan 2014.

Higher water levels under Plan 2014 will likely increase Monroe County’s costs to stabilize the Irondequoit Lakeshore 36-inch wastewater interceptor, the foundations of which have been threatened by severe erosion.

The revetments installed in 1999 to protect the foundation of the wastewater interceptor from further shoreline erosion will require maintenance under any regulation plan. These costs will not likely increase under Plan 2014 if the revetments are designed to withstand conditions that occur under the current regulation plan.

Higher water levels under Plan 2014 will increase the risk of damage to the main sewer lift station in the Village of Sodus Point, which is at an elevation of 248 feet (75.59 m).

Lake Ontario has risen above this elevation in the 1970s and 1990s under the current regulation plan, and will almost certainly exceed this elevation in the future under any regulation plan. The IJC acknowledges that the odds that Lake Ontario will exceed 248 feet (75.59 m) are slightly greater under Plan 2014 (The stillwater lake level is expected to be above 248 feet 0.4 percent of the time with Plan 2014 compared to 0.2 percent with Plan 1958DD.), but believes that efforts are needed to reduce the risk of damage that will exist under any regulation plan.

The water intakes at the Montreal drinking water treatment plant will be vulnerable under climate change scenarios.

The potential for this impact was documented during the Lake Ontario-St. Lawrence River Study. Study findings on Montreal’s water system were discussed with the mayors of the region and they agreed to address the vulnerability of that system to very rare low levels. The risk to Montreal’s drinking water supply will not be increased by Plan 2014.