HomeMy WebLinkAboutComments Miscellaneous 5/6/2004
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Home Builders
ASSOCIATION
of Lane County
. RECEIVED'
MAY 0 7 2004
.4:;6
BY: '~0VU-.1/ ~.
May 6, 2004
Springfield Planning Commission
225 5'h Street
Springfield, Oregon 97477
Eugene Planning Commission
99 West 10th Street
Eugene, Oregon 97401
Lane County Planning Commission
Public Service Building
125 East 8'h Street
Eugene, Oregon 97401
Re: Amendments to the Comprehensive Plan and the Public Facilities Plan
Oear Commissioners:
The Home Builders submit the following comments on the proposed Metro
Comprehensive Plan Amendments and amendments to the Eugene-Springfield Public
Facilities and Services Plan.
Before addressing the specific proposed amendments, we would like to explore the level
of discussion that is appropriate for the commissioners to hold. As you are aware, the
Eugene-Springfield Metropolitan Public Facility and Services Plan, A Refinement Plan
of the Eugene~Springfield Metropolitan General Plan (Public Facility Plan), was adopted
by the three jurisdictions in Oecember, 2001, as part of periodic review. The second
objective of the public facilities plan is:
Comply with the requirements of Statewide Planning Goal 11 and Goalll
administrative rules to adopt a public facilities plan for water, wastewater,
stormwater, and transportation facilities. This plan also includes information
about and maps for electrical facilities although not required by law.
Transportation system requirements are met through Transplan, incorporated into
this refinement plan by reference (page 2).
2053 Laura Street Springfield, OR 97477 (541) 484-5352
Date Received
MAY 06, o~
Planner: BJ
FAX: (541) 484-5386
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At the public hearing on April 20, I compared the level of detail that the planning
commissioners should require for the wastewater facility to that of Trans plan. That is
because Transplan was in fact done as a periodic review work task as part of the Public
Facility Plan as well as under Goal 12. It serves as an appropriate guide to the level of
public and planning commission scrutiny that is justified when considering the proposed
amendments before you.
The Metropolitan Wastewater Management Commission did participate.in the 2001
Public Facility and Service Plan update. Susan Smith, General Manager ofMWMC, and
Troy McAllister, Senior Civil Engineer for the City of Springfield, both served on the
Technical Advisory Committee. New text on the assessment of the MWMC facilities,
including the treatment facility, was included in the document. What was. not includ~d in
the document was description of projects that would be required by MWMC so shortly
after the document was adopted. The requirement to include wastewater treatment
facilities in the Public Facility Plan is specifically identified on page 3 of the document,
under the title Statewide Planning Public Facilities Plan Requirements. It is difficult to
conceive why it was assumed that the treatment facility would be required to be included
for some parts of the public facility plan and not others. But, in any case, the
reassessment of the facility and the examination of the projects proposed for the
wastewater treatment facility must go through the same level of examination now as they
would have been subject to during the original public review process.
With regard to the Metro Plan amendments, the Home Builders have not objections to I,
2, and 4. We have comments on the others.
3. Amends Policv #2 to include local caoital imorovement olans as a means to
imolement oolicv.
It is the position of the Home Builders that this amendment violates state law. In essence,
this would allow public facility projects to be adopted through the budget process rather
than the land use process, which clearly violates the state planning goals. Using the CIP
to implement wastewater policy is the process that MWMC has used improperly until
now, with some real land use consequences. An example is the poplar plantation.
About three years ago, MWMC spent several million dollars to purchase approximately
600 acres to plant a poplar plantation for distribution of wastewater effluents and dry tons
ofbiosolids. The project never came before the planning commissions as an amendment
to the Public Facility Plan as Goal 11 requires, but was simply. adopted as policy through
the MWMC budget process. Some of the acreage was outside the UGS and some was
inside the UGB. None ofthe poplar trees have yet been planted because the project has
run afoul ofIand use issues. The FaTIn Bureau is opposed to the planting of the poplar
trees on agricultural land outside the UGB because the trees are being planted to serve an
urban purpose (disposal of urban biosolidsand effluents) and the trees have virtually no
agricultural value, ergo a possible Goal 14 problem. There is also opposition to the trees
being planted on the acreage inside the UGB. That land,is zone industrial an~:ople are
questioning if a poplar plantation is the best use of scarce industrial land. In I!Yate Received
MAY 0610{"
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Planner: BJ
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meantime, the ratepayers have a considerable amount of their money tied upin
. unproductive land at a time when their rates are going to increase substantially over the
next few years to pay for additional projects.
The majority of the MWMC commissioners are volunteers who work on wastewater
issues. They are dedicated, hard-working people, but they do not deal with land use
issues. The state has assigned the review ofland use issues to the planning commissions.
If the poplar plantation (biofann) project title had been before the planning commission
as an amendment to the Public Facility Plan, members of the public on the planning
commiss{ons' interested party list, who are typically interestcd in land use issues, may
have raised the relevant land use problems. If not, the planning c01~missioners
themselves and the local planning staffs, given their land use expertise and the necessity
to review state goal implications, would probably have identified the possible land use
problems. Those kind ofland use issues simply can't be dealt with through the budget
process and it is extremely unlikely that they would even be raised.
Any single project that any of the public facilities plans has land us~ implications. For
example, many if not most of the MWMC projects have to do with odor control, thermal
regulations, or product outfall to the Willamette River. Those obviously have Goal 6
irilplications, because Goal 6 involves compliance with federal and state air and water
environmental quality statutes. One of the proposed MWMC projects in their facility
plan, for example, is an additional bankside outfall to the river. Springfield planning
commissioner William Carpenter raised the question of the mixing zone in the
Willamette River during the joint planning commission meeting on 'April 20 and also at
the MWMC hearing on the facilities plan the next morning. That is clearly Goal 6 land
use issue, as is just about anything relating to waste water treatment plants and sludge
disposal sites.
MWMC wants you to adopt an amendment that would authorize them to bypass you and
any land u,se review on all of these issues, and instead allow $144 million dollars of
wastewater projects to be handled exclusively by the MWMC commissioners, who would
seek approval from the elected officials through the budget process.
It also means that EWEB and SUB could bypass the Goal II administrative rules for
water projects by running them through their own budget process. Eugeneand
Springfield staff could avoid land use review, of storm water projects by running them.
through the cities' budget process. In short, this amendment means,that all of the public
facilities could do an end run around you and the Gmil 11 process. Would they all do
that? Maybe not. However, we know that MWMC would, because they have used that
process exclusively in the past and are asking for an amendment to the Public Facility
Plan that would allow them to continue to do so in the future. State, law does not permit
you to delegate the responsibility to perform land use review of public facilities projects
to MWMC, other utlitities, or the budget processes.
, 5.
Prooosed Policv G.9 reads:
Date Received
MAY 0 6 I ()~
Planner: BJ
Wastewater conveyance and treatment shall be provided to lneet the needs of
projected growth inside the UGB that are capable of complying with regulatory
requirements governing beneficial reuse of effluent and beneficial reuse or
disposal of residuals.
I'm not sure exactly how to interpret that policy. Obviously, its applicability is limited to
just wastewater treatment. It sounds as ifMWMC does not have to provide sewage
conveyance and treatment for projected growth if, for some reason, MWMC is not
capable of complying with regulatory requirements governing beneficial reuse of effluent
and beneficial reuse or disposal of residuals. It sounds as if, under those conditions,
MWMC may impose a moratorium on new development. Conditions under which
moratoriums may impose on development for lack of public facilities are specifically
identified under state law. There doesn't appear to be a good reason for the Metro Plan to
specifically speak to moratoriums solely for the benefit of MWMC,especially because
the language may conflict with the state provisions on moratoriums.
6. Modifies definition 37. Wastewater: Public Facilities Proiects. rChaDter V
Glossarvl
The proposed definition'reads as follows:
b. Wastewater: Primarv Collection Svstem: Pump stations and wastewater lines
24 inches or larger.
Treatment Facilities Svstem: Water Pollution Control Facility
(WPCF) project, beneficial reuse project and residual project
necessary to meet wastewater treatment facilities system design
capacities for average flow, peak flow, biochemical oxygen
demand and total suspended solids so as to provide service
within the urban growth boundary (UGB) for a projected
population in 2025 consistent with the population assumed in
this plan, in compliance with MWMC's discharge permit.
MWMC's Capital Improvement Plan, as amended from time to
time, shall be used as the guide for detailed planning and
implementation of the WPCP project, the beneficial reuse
project and the residuals project
That is not a definition of wastewater. IfMWMC were to simply liinit the definition of
wastewater to the facility components, as is done with water and stormwater, we would
not have an issue with this: What MWMC is atternpting to do is incorporate its proposed
project titles, its proposed pianning period, and its proposal to use the budget process to
adopt projects and implement policy within the definition of wastewater. Including the
proposed amendments to the Metro Plan into the glossary is not appropriate and is not
consistent with type of definitions provided for the other' two types of public facilities -
water and stormwater - in the glossary. OAR 660-011-0060 contains a definition of
Date Received
MAY 9610Y
Planner: BJ
Sewer System. Using relevant parts of that definition may be appropriate for glossary
purposes.
The Home Builders have no objections to Amendment 2 of the Public Facility Plan. We
have comments on the other proposed amendments.
1. Modifies the text on oage 28. nreceding Table 3. and adds Tables 4a and 4b that
identifv MWMC Wastewater Treatment and Primarv Collection Svstem
jmorovements. resoectivelv.
The first part of this amendment is to strike the words "short and long-term" from the
text.
The contents of and amendments to the Public Facility Plan are governed by OAR 660-
o 11 ~OOO through 660-011-0065.
OAR 660-011 c0025 Timing of Required Public Facilities (I) says: The public facilities
shall include a general estimate of the timing for the planned public{acilities projects.
There is no specific requirement that the timing be specified in terms of short or long
tenn. Nevertheless, the administrative rule does require that the planned projects have a
general estimate of the timing of the projects. The only timing provided for the MWMC
projects is in proposed Table 16a and that seems inadequate. The largest identified
groups of projects, for example, WPCF Treahnent ProjeCt, with an estimated cost of$126
million, is estimated to be completed by 2025. All that says is that the project will be
finished before the end of the twenty-year planning period. It doesn't provide any
infonnation on the projected 'start dates or the estimated length of construction time. In
short, it really provides no information at all with respect to estimated timing of the
projects.
The second part of this amendment is the tables intended to identify the proposed
MWMC projects. As I discussed during my oral testimony, the proposed projects 300,
and 301, and 302 are not projects at all within the definitions of the administrative rules.
Instead they are baskets containing a number of different types of projects with different
timings and, and in the case ofthe MPCF Treatment Project, with different functions.
Most of the individual unnamed projects within the baskets could be and many will be
constructed completely independently of each other. It is these projects that are the
projects titles required under the administrative rules.
This really goes back to the issue of allowing theCIP and budget process to be used for
the adoption of actual projects and the implementation of policy, which removes any land
use review for the projects.
On April 13,2004, I received a response from Dave Jewett, MWMC's attorney to a
question I had posed to him about the relationship of the MWMC Facility Plan (the $160
million in projects which MWMC intcnds to take directly to the public officials without
having them reviewed by the planning commissions) and the comp plan amendBme Received
MAY 06/Cir[
5
Planner: BJ
Specifically, my question was: "What is the relationship, if any, between the facilities
plan that MWMC will consider on April 22nd and the amendment to the Comp Plan that
is also being proposed?"
Mr.Jewett's response was: '''MWMC's Facilities Plan update analyzes the status of the
regional wastewater system and identifies capital improvements needed to meet
operational standards necessary to comply with the Commission's policies (emphasis
added) and the requirements ofMWMC's NPOES permit through the year 2025. The
Eugene / Springfield PubliC Facilities Plan (PFSP) is an adopted functional plan of the
Eugene / Springfield Metropolitan Area General Plan (Metro Plan)."
That is exactly our concern. First, MWMC commissioners cannot make policy. Only
elected officials can do that and the majority of the MWMCcommissioners are
volunteers. Most importantly, assessing the status of the public facilities and making
recommendations to the elected officials about future public facility projects so thev can
make policy is precisely the role given to the planning commissions. by the state under
Goal II. MWMC can not usurp that role and the planning commissions may not abdicate
it.
OAR 660-011-00 I 0 The Public Facility Plan requires that the public facility plan
contain the following items:
(I) A list of the significant public facility projects which are to support the land uses
designated in the acknowledged comprehensive plan. Publicfacility project
descriptions or specifications of these projects as necessary (emphasis added). The
key here is the requirement that the list of projects contain descriptions or
specifications as necessary - for what? Presumably to allow the public to idcntify thc
type of project that is planned.
That supposition is supported by OAR 660-011-0020 Public Facility Inventory and
Determination of Future Facility Projects. The first thing to note is that this section
pertains to future projects as well as those within the current inventory. Subsection (2)
requIres:
The public facility plan shall identify significant public facility projects which are
to support the land uses designated in the acknmyledged comprehensive plan.
The public facility plan shall list the title of the project and describe each public
facility project in tenus of the type offacility, service area, and facility capacity.
It is clear that the intent of the administrative rule is to provide a sufficient identification
of the project, through title and description as well as cf\pacity, to give the reviewing
public and elected officials knowledge of what kind of project is actually going to be
constructed. Three mere words - WPCF Treatrnent Project, Residuals Treatment Project,
or Beneficial Reuse Project - do not provide enough information to the public or the
elected officials as to the nature of the actual projects. The titles of the actual projects are
Date Received
MAYQ610~
Planner: 8.1
required to permit a discussion about the necessity or desirability of the projects. No
capacity descriptions are provided at all, though the administrative rules require them.
One ofthe arguments thatMWMC has made against 'using the actual projects is that they
do not want to have to amend the Metro p,lan and the Public Facility Plan if they decide
to change the projects. However, that is what is required and for a reason. This morning,
for example, MWMC voted to recommend the $160 million (actually, it is now $144
million) twenty-year project list to the city council. One of the questions I had asked was
why we were not having the discussion that Eugene Planning Commissioner Rusch had
raised about the new innovative types of wastewater systems. The commissioners and
CH2MHill all agreed that if they wanted to completely change the type of system they
were building down the road that they were free to do so, so therefore there was not really
a reason why we had to have that discussion now. And that is exac!ly the point. With
both the Public Facility Plan and the MWMC Facility Plan, the type of wastewater
system, the capacity of the system, and the sophistication of the system, iiIOn2: with the
accomoanvin2: land use imolicatioris, are supposed to be subject to public review and
discussion. After all, these are public facilities.
The process envisioned by MWMC is one where the public and the public officials, by
way of the planning commissions, approve $140 million dollars of ~eneric project names
(i.e. MPCF Treatment Project for $126 million).' MWMC would then have the actual
projects approved through the budget process. That inherently eliminates the land use
discussion. That is simply not the way the state Goal II process is supposed to work.
3. Modifies the existin2: narrative on "Wastewater Svstem Con'dition Assessment" in
Chaoter IV (Pa2:e 82) .
The issue we have with this amendment is the second paragraph. The assessment is
supposed to be an assessment of the existing system. We do not have a problem with
identifying the deficiencies in the current facility. That is, after all, integral to the
assessment. The proposed paragraph says that CH2MHill has evaluated the system and
that $160 million worth of improvements (projects) need to be completed through the
year 2025 to accommodate growth and meet new regulatory requirements. It is those
projects and the way in which we define the need to accommodate future growth and
regulatory requirements that are really'the subject of this public review and the
recommendation by the planning commissions to the elected officials. We believe that a
proposed $160 million of projects requires a bit more detail in the assessment. What
specific deficiencies do we need to correct? What regulatory requirements are driving
these projects? How much capacity will we need to add to the existing system to
accommodate growth or new regulations over the next twenty years?
4. Modifies existin2: oara!!Taohs #1 and #2 under the discussion of "Wastewater" in
the subdivision entitled "Long-Term Service Availabilitv Within Urbanizable
Areas" in Chaoter IV. (Pa2:e 97).
Date Received
MAY 061 01
Planrier: BJ
We have very significant issues with the changes in the last of the two paragraphs. The
first thing to note is that the existing language that MWMC wishes to change was new
language in the current Public Facility Plan. This is not a part of the Public Facility Plan
that was overlooked two or three years ago.
The first proposed paragraph reads:
There are no areas of the metropolitan UGS that will be difficult to serve with
wastewater facilities over the long"term (six to 20 years) assuming that public
infrastructure specifications 'and reauirements of the developing area can be
addressed. Appropriate engineering design practices must be used during the
development and expansion into sensitive areas that are approved for
development (ex. - hillside construction. etc.). Expansion of the existing
collection system will be necessary to meet demands of growth over this time
period.
I am not sure what purpose the additional language serves. All infrastructure installation
has to meet specific engineering and design requirements of the local public works
departments as a condition of approval, or, in the case of MWMC projects, MWMC's
requirements. On the other hand, I can'\ really identify any harm iri it. It just seems
. redundant.
The second paragraph is really at the crux of our issue with the facility plan that was
before MWMC and the $140 million generic project names proposed in the Public
Facility Plan. .
The proposed language of the second paragraph reads as follows:
J3ased on 2003 analvsis. the Eugene-Springfield metropolitan area treatment
facilities svstem will reauire facilitv improvements to address both drv and wet
weather regulatorv reauirements relating to pollutant loads and wastewater flows.
Regional and local imorovements to the collection and treatment svstems are
nlanned for and will be imnlemented to allow for lrrowth within the UGS and for
regulatorv compliance.
The omitted language reads as follows:
The Eugene-Springfield metropolitan area Regional Wastew'ater Treatment Plant
has. sufficient design capacity to accommodate population increases and serve all
new development at buildout. However, peak wet weather conditions limit the
treatment of the plant from achieving its design capacity. Wet, weather-related
improvements are needed at the plant and within the regional collection system to
extend the plant's wet weather capacity beyond the year 2007.
Allow me to repeat myself. The language that MWMC proposes to ,strike from the Public
Facility Plan is text that they either proposed or approved just a short time aif)m~t~eceived
MAY 06, (Jl(
8
Planner: BJ
current Public Facility Plan was written. That abundance of capacity, excepting wet
weather peak flow because of infiltration and inflow (1/1), has been relied upon in other
planning documents. For example, the 2050 Plan on which LCOG and the local
jurisdictions are currently working has this to say about the MWMC capacity:
The Metropolitan Wastewater Management Commission is responsible for
providing wastewater treatment to expanded areas of the ur~an growth boundary
for Eugene and Springfield. The dry-weather design capacity of the existing
regional wastewater treatment facility is 49 million gallons per day, which is
expected to serve a population of about 290,000... (Yesterday, Today, and
Tomorrow Scenarios, April 3, 2002, page 12).
Now suddenly, however, according to CH2MHill, MWMC's engineering consultant,
and MWMC staft~ virtually all the capacity in every part of the facility is gone. The
question, of course,. is why?
Some general background infonnation. The MWMC treatment facility was designed in
1977 and became operational twenty years ago in 1984. It was designed to serve a
population of277,100 persons and it was estimated in 1977 that number of persons
served by the facility would be reached in 2005. The current number of persons served
by MWMC in 2004 is 217,690 persons, so the initial 1977 population projection that the
facility would reach its service capacity next year was substantially in err. Based solely
on population to be served, the facility would currently be using 72.5% of its capacity.
Oesign of the original WPCF (Water Pollution Control Facility) was based on
demographic and population data established in the mid-1970's. The facility was
designed to provide adequate sewerage capacity through the' year 2005 for a
projected population of277,100. This projection was made for the sewer service
area that existed in the 1970s. However, the growth rate during the 1980s was
significantly less than projected. This trend in the growth rate was common
throughout much of Oregon because of depressed economic :conditions during the
mid-1980s (April, 2004 Oraft MWMC Facilities Plan, page 1-6).
In addition, LCOG population projections for the 1990s were higher than the actual
numbers provided by the 2000 US Census.
Another factor significantly affected the projected use of the facility,'s capacity- water
conservation efforts. A substantial part of our wastewater, both dry weather flows and
wet weather flows, is just what the name suggests - water. I am not referring now to
inflow and infiltration (1/1), but rather the composition of the wastewater that is released
from homes, businesses, and industrial plants. Whether the wastewater originates from
the shower we take in the morning, the dishwashers at a restaurant, or a car wash, the
greatest percentage of our wastewater is simply water. The amount of wastewater sent
from homes and businesses to the sanitary sewer pipes correlates so,closely to our actual
water usage that our winter water consumption is the basis upon which our MWMC
sewer bill is calculated: Every year since the mid or late 80s, because of water Date Received
MAY 0 6 I N
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Planner: BJ
conservation efforts, our per capita consumption of water has declined. We flush our
toilets with less water and use more efficient shower heads. Because of past drought
years, we turn off the water while brushing our teeth rather than leaying the tap running
as was customary in the 70s.
The Register Guard recently ran an article reporting that while the state population had
grown by 17% (I believe since 1990), water consumption had increased by only 2% in
the same period. Some of the water conservation results in water savings that do not
impact our wastewater flows - more efficient ways to water our lawns, for example.
However, much of the conservation has occurred inside homes and businesses. The
result is that the MWMC facility can actually serve a larger population than the 277,100
persons originally projected in the mid-70s. As previously noted, LCOG has estimated in
the 2050 Plan that the facility can now serve a population of 290,000 persons, which is
almost exactly to the end of MWMC's 2025 planning period. '
There are four sources that we can use to determine how much facility capacity still
exists: (I) The 1997 MWMC Master Plan prepared by CH2MHill; (2) the 2004 Oraft
MWMC Facilities Plan prepared by CH2MHill; (3) the 2002 Fact Sheet and NPOES
Wastewater Oischarge Permit Evaluation prepared by the Oepartm~nt of Environmental
Quality (OEQ), (4) and the Technical Background Report: Existing Conditions and
Alternatives, Eugene-Springfield Metropolitan Area Public Facilities and Services Plan
(1999). The latter is the separate technical document that supports the Public Facility Plan
that MWMC proposes to amend. The wastewater facility has many components but
reference is frequently made to four moregeneral categories of capacity: (I) Liquid
effluent dry weather flow, (2) liquid effluent wet weather flow, (3) BOO and TSS dry
weather capacity, and (4) biosolids processing. It is important to look at each of the
larger category's capacity individually.
Liauid Effluent Orv Weather Capacitv:
OEQ defines the dry season as May I through October 31, although the 2002 permit
appears to extend the. emergency overflow criteria for a storm event greater than the one-
in-five-year, 24-hour duration storm through May 21 rather than M~y I, and allows that
same criteria to extend to June 1 if there is no increase in risk to beneficial uses. The
facility has two important effluent dry weather design capacities. T)1e average monthly
dry weather flow capacity is 49 million gallons per day (mgds). The average monthly
capacity most closely reflects the base flow from residences, businesses, and industrial
plants. It contains some III, but the amount is minimal. The other important design
capacity is that of dry weather maximum month, which, according to the 1977 Master
Plan, is 66 mgds. Some of the months classified as "dry" by OEQ, 'especially May, can
in fact be very wet and contain substantial amounts of 1/1. Therefor,e, the design capacity
for the dry season maximum month flow is higher than that of average monthly flows to
reflect the presence of the 1/1. The difference between the specific design capacity and
the actual corresponding flows represents the capacity available to meet future needs.
Date Received
MAY 0 6, O~
P!anrlE!3r: BJ
The 1997 MWMC Master Plan examined the amount of dry season average monthly
flows as well as the dry season maximum monthly flows to detennine the amount of
capacity that was being used by current users. It also projected.the available years of
capacity remaining in that part of the facility.
It identified the dry weather'average month capacity as 49 mgds and the actual average
monthly flow as 26 mgds (Table 3-3, page 455). It also identified the dry weather
maximum month design capacity as 66 mgds (page 456).
It reported that "average dry weather flows were 53 percent of plant design capacity
(p'age 440). It estimated that there were 30 years remaining dry weather monthly average
capacity and 27 remaining years of dry weather maximum month capacity - taking us to
the years 2027 and 2024 respectively (Table 3-5 Remaining Life ofE/SWPCF, page
457). It concluded the dry weather capacity analysis as follows: "Ample dry weather
capacity remains well beyond the current LCOG planning horizon (page 456)" ,
,
The Technical Background Report to the Public Facilities Plan has a more detailed
assessment of the MWMC facilities than the Public Facility Plan itself. It provides the
following evaluation of the treatment facility: .
The treatment plant has a dry weather design capacity of 49 'mgd. Current actual
dry weather flows range from 45 percent to 57 percent of the design capacity.
Sufficient treatment capacity exists to meet projected growth throughout the PFSP
planning horizon. However, peak wet weather flow, not influent wastewater
characteristics, currently constrains the life span of the planes design
capacity.. . (page 19).
The 2004 Oraft MWMC Facilities Plan, prepared by CH2MHill, also identifies the dry
weather average month design capacity as 49 mgds. However, the amount of monthly
flow, either average month or maximum month is dependent upon population estimates.
There is a discrepancy in the population estimates that CH2MHill provided on March 26,
2004, for the Oraft System Oevelopment Charge Methodology, in which CH2MHill
estimated the current population serVed in 2002 as 217,690, and the estimated 2005
population estimate of229,145 found in the draft faCilities plan. Based on the latter 2005
population, CH2MHill estimates actual dry season average flows of29.6 mgds and dry
season maximum monthly flows of 46 mgds (page 4-13). That means we would be using
60.4% of our dry season average monthly capacity and 69.7% of our dry season
maximum monthly capacity, using the design capacities of 49 mgds and 66 mgds
respectively.
CH2MHill identifies the projected 2025 dry season average flow at:38.4 mgds, still
substantially below the 49 mgd average flow design capacity, and the 2025 dry weather
maximum month flow at 59.3, also below the design capacity of 66'mgds. .
OEQ also provided an evaluation of the MWMC treatment facility in 2002 in conjunction
with the renewal of our NPOES wastewater discharge permit. It noted:
Date Received
MAY06/0t{
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Planner: BJ
The design Average Ory Weather Flow (A OW F) for the facility is 49 million
gallons per day (MGO). The AOWF is the estimated maximum flow during May
1 to October 31 (expressed as average daily flow), at which the design engineer
expects the treatment facility can still meet all effluent limits. The dry weather
flows do not contain the high levels of infiltration and inflow that are associated
with the winter in Oregon. Therefore, the design dry weather flows are used
mostly to estimate how much treatment capacity there is for, organic loads. The
,current actual dry weather flow for May I to October 31, for the past two years, is
28.6 MGO, On the basis of the current tlows, this facility is at approximately
60% of organic treatment capacity. Based on the current lo~ flows compared to
the design flows, and the lack of effluent violations, no expansion of the facility is
needed at this time (page 2).
To summarize the availability of dry weather effluent capacity, seven years ago the
MWMC Master Plan estimated that we were using 53% of our dry weather capacity.
Five years later, in 2002, OEQ dismissed the importance of discussing the liquid eftluent
dry weather capacity and noted that the real issue was the amount of capacity for
treatment of organic loads (such as BOO and TSS) and estimated th'e used capacity at
approximately 60%. Two years later, using the numbers provided by CH2MHill in the
draft facilities plan, the estimated the dry weather average month capacity would be just
over 60% and the dry season maximum month at just under 70%. However, CH2MHill
is also estimating that 1/1 will be reduced by approximately 17% during the planning
period, which would make more dry season maximum capacity available (Oraft System
Oevelopment Charge Methodology (page C-2). .
All three ofthe sources indicate that we have substantial dry weather capacity remaining
in the facility, which is what we would expect, given the reduced population projections
and the effect of water conservation efforts on plant flows.
However, CH2MHill does contend in the proposed System Oevelopment Charge
Methodology that the available dry weather"capacity is substantially less than that
providcd by the other sources. In that document, CH2MHill e1aims'that we are currently
using 89% of our liquid eftluent dry weather capacity. CH2MHill arrives at that
conclusion by calculating the available capacity differently than they did in the Master
Plan or than OEQ does in its evaluation of the plant capacity. In the Master Plan
CH2MHill arrived at the dry weather capacity by comparing the dD' season maximum
month design capacity of66 mgds with the dry season maximum month flows (apples to
apples). OEQ compared the dry season average month design capacity of 49 mgds with
the dry season average flows (again, apples to apples, albeit different apples). In the
system development charge methodology, CH2MHill compares the dry season average
flow design (49 mgds) with the dry season maximum monthly flow (apples to oranges).
. The design capacity used does not inelude any significant 1/[, but the maximum monthly
flow does. Needless to say, the available capacity evaporates immediately, and we go
from having 40% of the dry season capacity available to meet future needs to having only
II % of the dry season capacity available. That is an incredible difference. While Date Received
"
MAY 0 6{ otf
12
Planner: BJ
'.,
haven't seen any place in the facility plan where current dry season.capacity is identified,
CH2MHill suggests that the same comparison would be used.
The existing average dry weather design flow for the WPCf,as stated in the
current NPOES permit is 49 mgd. This is defined as the average day flow
calculated from May.1 through October 31. Although stated as an average dry
weather capacity, the facility must meet the effluent requirements on a 30-day
average flow (monthly basis). Because any 30-day period, including the
maximum 30-day flow period (or maximum month flow) during the dry season,
must meet the NPOES effluent flow and load requirements stipulated for the
average dry season flow, it is prudent to compare the actual dry season maximum
month flow (OSMM) to the average dry weather design flow in order to assess
treatment capacity. This method was reviewed by OEQ staff and verified as the
appropriate method.'
When I had talked with Mark Hamlin at OEQ on previous. occasions, I was assured that
OEQ only looks at output and results and that OEQ does not tell junsdictions how to
calculate capacity. I called Mark Hamlin last Thursday after reading in the draft facilities
plan that OEQ staff had said the apples to oranges comparison was the appropriate
method to calculate the dry weather capacity. Mark then told me tHat he had evaluated
the MWMC dry weather capacity at 60% in'the Fact Sheet and NPOES Wastewater
Oischarge Pennit Evaluation. Furthennore,.it is clear in thatevalu1\tion that OEQ did not
use the method being proposed by CH2MHill. Instead, OEQ compared the average flow
capacity of 49 mgds with the average flows of28.6 mgds. IfOEQ preferred the method
being proposed by CH2MHill, why wouldn't they use it themselves? And why would we
voluntarily dismiss 29% of our current capacity as unavailable for future needs when
OEQ estimates our remaining dry weather capacity at 40%, and says that "Based on the
current low flows compared to the design flows, and the lack of effluent violations, no
expansion of the facility is needed at this time?
Liauid Effluent Wet Weather Canacitv;
Wet weather capacity applies to the facility's capacity from November I to April 30. Just
as dry weather capacity comes in two design capacities, so does wet weather capacity.
One is the average monthly wet weather capacity and the second, and probably the more
important one, is peak flow capacity.
The wet weather average monthly flow is similar to dry season aveiage monthly flow. It
contains a significant amount ofI/1 just because it is measured in the wet months, but the
plant has sufficient capacity to handle the flow. The Master Plan identifies the average
wet weather design capacity at 70 mgds and the average wet weather flow at 41.8 mgds
(Table 3-3, page 455). OEQ, in its evaluation in 2002, said the average wet weather flow
design is 75 mgds and the current average wet weather flows were 56.4 mgds. The draft
facilities plan notes the average wet weather flow to be 52.5 mgds (page 4-13) and the
design capacity to be 75 mgds (footnote to Table 5.1.1-1, page 5-3). The draft facilities
plan projects that the average wet weather flows in 2025 will be 68'.11 mgds - bt}afe Received
MAY 06 f D4
13
Planner: BJ
75 mgd design capacity. The Master Plan projected that we had 18 years of remaining
average wet weather flow capacity, or capacity until the year 2015.' If the design capacity
of 75 mgds had been used rather than the 70 mgds, the remaining years of capacity would
be further extended. .
The critical capacity issue involves peak wet weather flows. Like many municipal
wastewater systems, we have a serious III problem. In January, 2001, CH2MHill and
MWMC staff released the Wet Weather Flow Management Plan, which described the
problem:
The treatment plant was designed in the 1970s to provide adequate capacity
through 2005. From a base flow and loading standpoint, the treatment plant
performs well within its capacity (49 million gallons per day [mgd]) in dry-
weather months. However, winter rainfall creates flows to the treatment plant that
exceed the plant's peak capacity (175 mgd) on average several times 'per year and
exceed full (secondary) treatment capacity (104 mgd) more frequently...
Peak flow estimates for conditions associated with the 5-year storm event are used
to size and plan future system improvements at the treatmen! plant and in the
collection system. Through system modeling, the 5-year peak was estimated at
264 mgd. Peak flows are attributed to high infiltration and inflow (III) rates in
many areas of the collection system. 1/1 occurs from extraneous water getting into
the system from illegal roof drain connections, sewer pipe cracks, and other
sources. 1/1 is often associated with older pipes in the system which have
deteriorated. Sanitary pipes in older areas are also more likely to be subject to
improper storm drainage (inflow) connections when construction inspection
practices were more lenient and / or such connections were allowed, creating a
combined flow system. Newer pipe systems reflect improvements in construction
techniques, materials, and inspection and typically exhibit far less I/I. In Eugene,
II percent of the pipes are at least 50 years old. In Springfield, the percentage of
pipes at least 50 years old is i5 percent... Because the primary sources ofI/1 are
in the existing system and limited III is anticipated from system expansion,
growth in the system does not contribute significantly to projected system
deficiencies. The 5-year peak is estimated at 298 mfd. Of this peak, only 4
percent or 12 mgd, is estimated to be the result o(J/I from future pipes.
Estimates made at the time of design of the treatment plant, relative to the amount
of rainfall-derived infiltration and inflow (ROIl) that could be cost-effectively
removed, were overly optimistic. This has resulted in insufficient capacity to
manage peak flows at the treatment plant and has increased the risk of sanitary
sewer overflows (SSOs) at a number oflocations in the collection system.
Example problems include basement and street flooding and,discharges to
stonnwater facilities and receiving waters. Although the magnitude of wet
weather flows differs greatly, they are significantly diluted because the source of
the majority ofthe flow is rainwater, not sanitary sewage. Ti-eatment plant flow ,
data indicates that wet weather flow is diluted such that the concentratDate Received
MAY 06, 04
lPlan\1er: BJ
typical pollutants in wet weather flow is 50 percent to 60 percent of that in dry
weather flow (Executive Summary, page 1465). '
The Master Plan also talks of the lack of peak flow capacity.
Peak flows have approached or exceeded the hydraulic design capacity of the plan
in seven instances, but no NPOES pennit violations have occurred - mass limits
have been suspended in those instances. Flows greater thanthe peak design
capacity have been pumped by relying on redundant, spare pumps. The frequency
of peak flow exceedances will increase as the base, average wastewater flow
increases. This could potentially lead to NPOES permit violations caused by
sanitary sewer overflows or exceedance of effluent quality permit limits.
All of the documents agree that the peak flow design capacity is 175 mgd. Everyone also
agrees that under our permit we are required to have enough capacity during the wet
weather months to treat the wastewater flow that would occur during a storm event
described as "the one-in-five-year, 24-hour duration storm" and that we do not have
sufficient capacity to do so.'
The 2001 Wet Weather Study prepared by CH2MHill proposed three alternatives to deal
with the lack of peak weather flow. The MWMC commissioners voted to approve the
second option. It had a cost of$33.1 million. The draft facilities plan proposes a parallel
system to deal with peak flow excesses which would about $11 million.
Effluent Biosolid Loads:
BOO (now often seen as CBOO) and TSS can be measured in either lbs/day or dry tons.
In the reports, you would see both used. Sometimes you may wish to compare data from
different reports that are expressed in different measurements (lbs/day or tons/year). To
convert Ibs / day to dry tons / year, multiply the lbs / day by 0.1825. To convert dry tons
per year to lbs / day, multiply by 5.4795.
Under our permit, we are required to remove at least 85% of the mcinthlyaverage for
BOO and TSS. The existing capacity for BOO is 66,000 lbs per day and for TSS is
71,600 lbs per day (Master Plan, page 455 and System Oevelopmel}t Charge
Methodology, page C-I). The Master Plan identifies the average dry weather BOO load
as 28,682 lbs/day and that ofTSS as 31,056 lbs/day (Tlible 3-3, page 455). It estimates
that there is a remaining life BOO average month capacity in the facility of 40 years and
maximum month remaining capacity of33 years. TSS has a remaining average month
capacity of35 years and a maximum month capacity of29 years (Table 3-5, page 457).
The Master Plan concludes: "For BOO, the E/SWPCF has substantial remaining capacity
to about 2030 as a result of lower than design per capita loadings arid historical growth
rates (page 462). It also speaks to TSS. "The results of remaining capacity, as measured
by TSS, are also substantial, to about 2026 (page 462).
Date Received
MAY 06, <et
15
Planner: BJ
OEQ, in its 2002 Fact Sheet and evaluation discusses the different s~mmer (dry season)
and winter (wet season) 8.00 and TSS pennit requirements. It con9ludes:
"A review of recent monitoring data indicates thepennittees should generally be
able to comply with thepennit limits. No changes from the previous pennit are
proposed... An 85 percent removal efficiency limit is included in the proposed
permit to comply with federal requirements. An examination of the OMR data
indicates the pennittee will be able to meet the limit with the current facilities
(page 10).
The Oraft Facilities Plan indicates that our permit.has a Maximum Week TSS permit
limit / removal requirement~ of28,000 lbs / day and that CBOOhas a Maxill1Um Week
requirement of 24,000 lbs/day. Actually, the permit.does not refer to Maximum Week
requirements. The permit chart refers to Monthly Average lbs/day, Weekly Average
lbs/day, and Oaily Maximum pounds. CH2MHill chose to convert the requirement into
Maximum week terms rather than use the measurements provided by OEQ in the permit.
The answer would appear to be the same as why we lost all of our dry weather capacity
under"the System Oevelopment Charge Methodology. Rather than using the'Monthly
Average measurement provided in the permit to compare to the Monthly Average
capacity of 49 mgds (apples to apples), the decision was made to convert the data to
Maximum Week lb/day and compare that number to the average flow design capacity of
49 mgd (apples,to oranges).
Ory season mass limitations for both C800 and TSS outlined in the NPOES
pennit are based on the current dry season flow of 49 mgd. The mass limit
requirements must be met for the highest 30-day flow period in the dry season
(maximum month basis). Even if the constant concentration limits for CBOO and
TSS are met, the mass limits imply a lower concentration requirement if the
wastewater flows exceed the current dry weather design capacity or if the future
dry weather design capacity of the facility is increased. Concentration limits was
well as percent removal requirements are also specified in the NPOES pennit...
Permit removal limits apply; however, they are not a factor during the dry season
because the mass and concentration limits are 'significantly lllOre stringent (page
5-4).
The question arises again. Why measure things differently than OEQ does? OEQ, in the
permit, provides three different means to measure the,CBOO and TSS in both the dry
season and the wet weather seasons. Why convert to a fourth measurement that is not
provided by OEQ? Since OEQ refers to the average monthly dry weather design capacity
of the facility of 49 mgds and provides a limit for monthly average flow, why not use
monthly average flow to arrive at your capacity (apples to apples)? By converting to
Maximum Week, III is again included in the flow but not in the design capacity, which is
automatically going to skewer the measurement and result in a significant loss of facility
capacity.
Date Received
MAY 06 IOL(
Planner: BJ
As a result, CH2MHill determined in the System Oevelopment Charge Methodology that
the facility is now operating at 83% of our BOO capacity and at 90.4% of our TSS
capacity. Seven years ago, when CH2MHill prepared the Master Plan, they concluded
that we had a great deal of effluent BOO and TSS capacity. "The remaining treatment
capacity of the E/SWPCF is substantial for average dry and wet weather flow conditions
and convcntional pollutants (BOO and TSS) (page 450). '
OEQ, as you will recall, placed the capacity used for et11uent organic loads at 60%. It
also said: "The current permit contains CBOO and TSS removal efficiency limits of 85
percent. The facility has been able to comply with the pennit limits and has not had any
violations even during the extremely wet months (page 4 of the Fact Sheet and
evaluation)." As you recall, OEQ also concluded that our current facilities would allow
us to continue to remain in compliance with our permit.
A second decision made by CH2MHill and MWMC staff also affected the amount of
BOO and TSS capacity reportedly available. When calCulating BOO capacity, for
example, CH2MHill used the following formula for the System Development Charge
Methodology:
Current BOO = (0.19 x 217,690 x 1.3) + 2,402 = 54,800 lbs/day where
0.19 is the selected pounds per capita per day based on dry season values from
1990 to 2002
217,690 is the population served in 2002
1.3 is the selected peaking to convert average dry season load to OSMM (dry
season maximum month) load (based on 1990 to 2002 data)
The key piece is the selected pounds per capita per day. Per capita loads, according to
the Master Plan, have been lower than the design capacity and the Master Plan identified
the per capita load for BOO as 0.17. On two different occasions (the last time at the
second public forum), Matt Noeson from CH2MHill assured me that thc change in the
per capita pounds per day from the 0.17 they had used in the Master Plan to the 0.19
being used now was not based upon any new data or any change in how the capacity
should be calculated. The change in per capita load was done solely for the purpose of
further reducing our chances of having a permit violation during a wet May. However,
the effect on the amount of BOO capacity is significant. The used capacity drops to
50,500 lbs per day. Changing the per capita load results in an additional 8.5% loss of
BOO capacity.
If we substitute the population figures that are used in the Oraft facility plan for those
used above, we have the following formula:
(0.19 x 229,145 x 1.3) + 2,402 = 59,000 lbs per day that we are using of our 69ate Received
lbs/day capacity, we are now using 89.5% of our BOO capacity. : "
MAY 0610cf
Planner: BJ
This is the.dilemma that we face. According the Master Plan prepared by CH2Ml;Iill
seven'years ago, we were using about 46% of our BOO capacity. According to OEQ,
five years later, we are using ~pproximately 60% of our capacity and our current facility
would allow us to comply with our new pennit requirements. However, according to
CH2MHill and MWMC staff in the Oraft Facility Plan, the sky is falling.
. The same argument applies to TSS capacity. According the Master'rlan, we were using
46% of our TSS capacity seven years ago. According to OEQ in 2002, we were using
approximately 60% of our capacity. Using the population numbers in the facility plan
and the fonnulaprovided by CH2MHill in the System Oevelopment Charge
Methodology, we are generating the following amount ofTSS:
(0.21 x 229,145 x 1.4) + 2,224 = 69,593 lbs/day ofTSS. Our capacity is 71,600, so
according CH2MHill and MWMC staff, we are currently using 97% of our TSS capacity.
As in the BOO calculation, we are now using a different per capita load of .21 rather than
the .19 used in the Master Plan.
j
Why such a large difference? 1 believe it is the combination in the draft facility plan of
comparing dry weather average flow design capacity with maximum rather than average
flows and the change in the peaking factor (for calculation of dry weather flow, which I
did not discuss) and per capita loads for calculating thc capacity of BOO and TSS. I
don't know what peaking factors and pounds per capita that OEQ used. I do know that
they did not compare maximum flows with average flow design capacity to calculate
capacity. OEQ seems to have taken the most moderate approach compared to either the
Master Plan or the Oraft Facilities Plan and for that reason would appear to be more
reliable in their capacity evaluations.
(As an interesting side note. In February of this year, CH2MHill and MWMC staff were
actually using larger per capita loads for BOO and TSS - .20 and .22 respectively. If we
were to use the February 0.22 pounds per capita and plug it into theTSS foimula using
the population estimates in the draft facility plan, we would be generating 72,800 lbs per
day ofTSS, which would actually exceed the design capacity of 71 ,600. The following
month, the pounds per capita for both BOO and TSS were reduced by .01.)
Another indication of the difference in how CH2MHill and MWMC staff are calculating
current biosolid loadings is in the tons currently being generated by the facility. In Table
C,3 of the Oraft System Oevelopment Charge Methodology (page C~6), MWMC stafl
and CH2MHill ipdicate that we have a current loading of 5,927 tons per year. OEQ, in
its 2002 evaluation of the facility, indicated that "The MWMC wastewater treatment
facility generated 4,240 dry metric tons during the reporting period January I, 2000 to
Oecember 31,20.00 (page 3)." The 5,927 tons ofbiosolids reported by CH2MHill is not
in metric tons; but if you convert the OEQ number from metric tons'to tons, the numbers
still are not close. The mere passage of three years can not explain a 21 % difference
between OEQ's and MWMC's numbers.
Date Received
MAYiJ6,6L{-
PlanI8n'':i'r'' PL1
, "~fE~..::: r~-x-~'.;'""
Biosolid Processing:
In 1997, the MWMC Master Plan spoke to the deficiency of the biosolid capacity. "The
biosolids management facility has insufficient capacity to process solids currently
produced by the E/SWPCF. The facultative sludge lagoons will be .full in -3 to 5 years
(page 450)."
The Technical Report to the Public Facility Plan identified the remedy: "MWMC is
currently completing designs/engineering, and will construct a mechanical dewatering
facility in 1999/2000 that will eliminate the biosolids processing capacity constraint
(page 20)." That facility was finished about three years ago. How much capacity do we
have remaining according to the SOC methodology prepared by CH2MHill? Zero. Zip.
Zilch. Nada. None. I realize that eliminating the capacity constraihts won't last forever,
but somehow I would expect it to last more than two or three years.
So where did all of the capacity go? The same place that all the rest of it went. It
disappeared because we changed the way we calculated the capacity - in this case by
changing the pounds per capita in the formula. .
I raised these issues before MWMC in the hearing on the facility plan. The consultant
from CH2MHill claims that OEQ changed the way that effluent capacity must be
calculated in 1991 and it went into effect in 1996. He then said that the way CH2MHill
calculated capacity in the 1997 Master Plan was in error. He said that the way that Mark
Hamlin from OEQ calculated MWMC's capacity in 2002 was in error. He didn't
mention the Wet Weather Study that CH2MHill did in 2001, but since it also identifies an
abundance of dry weather influent and solids capacity, presumably, it was also in error.
They are now saying the Public Facility and Service Plan, which MWMC approved three
years ago, is in error and, although they have not spoken to the Technical Report, that
must also be in error. The presumptions in the 2050 Plan would be in error.
That isa lot of planning history to throw out the window because of an assertion now by
CH2MHill that OEQ required a change in how capacity should be calculated 13 years
. ago; a change that has enormous implications for future projects needs, and a change that
no one, including CH2MHill and OEQ, have recognized to have existed over the last 13
years.
In short, the proposed text aniendments need additional justification before they should
be made.
5. Adds new Table 16a (following Table 16) entitled "MWMC Wastewater
Treatment and Collection Svstem Imorovements. Rough Cost Estimate. and
Timing Estimate." Page 101),
See discussions under Public Facility and Service Plan Amendments 1,3, and 4.
Date Received
Adds new Chaoter VI regarding amendments to the PFSP.
6,
MAY 06, bt
Planner: B~j
.
This first part of the proposed amendment, the test under Flexibilityiof the Plan, is a poor
idea. The process for amending the Public Facility and Service Plan is prescribed by
OAR 660-011-0045. This is not subject to local control and, in fact; the .text in this
section is taken almost verbatim from the administrative rules. There are two problems
with this approach. First, they are not word-for-word the same, which always has
potential difficulties. Second, if OLCO changes the amendment process in the
administrative rules, we have to amend the Facilities Plan to reflect those changes,
because our amendment process can not be at variance with the state requirements.
Copying the administrative rules into our Public Facility Plan does not add anything of
value and it always has the potential of forcing us to go through the amendment process
in the future because of state changes. It may also mislead .people. It may actually be
inaccurate if the state has made changes that are not reflected in our, local version of the
amendment process.
We don't have an issue with the intent of the text under Process for Making Changes.
The only concern we have is what happens if there is a disagreement on whether a project
serves only one jurisdiction, or whether it serves two, or even all three of the
jurisdictions. Oetennining in which jurisdiction a project is located.is easy. Oetennining
which jurisdiction or jurisdictions are served by a project may, in some cases, be cause
for serious debate (transportation projects would be an example). Because this is by
definition a land use process, the only place to reach final resolution on those
disagreements may be LUBA. But, perhaps that is perfectly all right.
There are other issues - inconsistencies with the Metro Plan in population projections and
the planning period, for example. However the principal issue is one of process.
MWMC, through the City of Springfield is proposing key amendments in order to avoid
the state land use process. The Home Builders Association urges you to reject the
amendments in whole and require that MWMC submit Metro Plan and Public Facility
and Service Plan amendments that respect and comply with the land use process.
Thank you for your attention-to our comments.
Sincerel y,
I~Y(A' c::-----u(~-
Roxie Cuellar
Oirector of Government Affairs
Accompanying Oocuments:
I.
2.
3.
1997 Master Plan prepared by CH2MHill ( Cover page and pages 450, 455-457)
2001 Wet Weather Flow Management Plan (Cover page and:pages l465~.&itl.. Rece'lved
Average Monthly Residential Sewer Usage (2 pages) UC:t t1 . . .
MAY 06{ O~
Piannefr<:~ .;t~, ~
~ll . c';:" :,:+,:
.
. 4. 1999 Technical Background Report: E~isting Conditions and Altematives,
Eugene-Springfield Metropolitan Area Public Facilities and Services Plan (Cover
Page and pages 1186-1187)
5. Fact Sheet and NPOES Wastewater Oischarge Pennit Evaluation prepared in
2002 by Oepartment of Environmental Quality (pages 1-16)1,'
6. Oregon's Statewide Planning Goals and Guidelines. Goal 6:' Air, Water and Land
Resources Quality from OLCO's web site (pages 1-2)
r
Date Received
MAY 0 6 ,Ot{
Plafilner: BJ