Lehigh County Authority Chief Executive Officer Liesel Gross gave a presentation on the LCA’s Kline’s Island Sewer System Act 537 plan at the April 10 Lowhill Township Board of Supervisors meeting.

“I want to be very clear this presentation is for a very small portion of Lowhill Township,” she stated.

“The Kline’s Island Sewer System is a large regional sewer system that was built for the most part in the 1920s through the 1980s, so it is an old sewer system,” Gross explained. “The plan I’ll be presenting to you really is to focus on replacing aging infrastructure and making sure that the next 100 years we have a well-functioning sewer system for our region.”

She said there are 15 municipalities that are connected to this system including Lowhill Township maybe a decade or so ago Lowhill transferred the sewer system over to LCA so we operate the system in Lowhill Township but the other 14 systems are either run by the townships themselves or by LCA so it’s a combination of things.

“It is a large system we’re providing service to about 270,000 people and we treat 32,000,000 gallons of wastewater every single day and the system is comprised of almost 1,000 miles of sewer lines that are buried underground,” Gross said.

She said LCA serves a small portion of the system in Lowhill Township, which consists of 43 homes in the West Point phase A, and C.

“The purpose of the plan again is to address aging infrastructure and I’ll get into some of the challenges that we’re trying to solve,” Gross stated. “It is not including any expansion of the system in Lowhill Township. Therefore, there are some areas of the system that are still growing but for Lowhill Township it is really just a plan to make sure that these 43 homes continue to receive the level of service that they deserve. If there’s other Township planning needs that are required for the rest of the Township that is a separate issue that the Township would need to address in a separate plan.

“For the communities that are growing we’ll need to expand the system and for communities that aren’t growing we’re still concerned about the age of the system and making sure leakage from rain and other sources does not enter the system, so when a sewer system leaks it’s actually rainwater getting into the pipe and chewing up capacity for the rest of the system.

Gross stated that LCA also does have some problems with overflows at various locations.

She said back in 2018 and 2019 when there was a lot of rain for an extended period of time the wet weather in the system and the leakage getting into the pipe caused a series of administrative orders and other regulatory actions by the Environmental Protection Agency and more recently by Department of Environmental Protection.

“The reason that we’re doing this 537 now is because that 2018-2019 period caused us to be in a violation of what’s called Chapter 94,” Gross explained. “So our sewage flows for the whole system exceeded the permanent capacity of the system and so we’re in a violation now. The remedy the DEP has dictated to us is that we shall develop a regional Act 537 plan to address the problem and that plan is due in 2025 so we’ve been working on it for several years and we’re just about ready to submit that to the public for review and approval.”

She said the first five years of the plan which is what they are submitting to the DEP is very heavily focused on removing leakage, doing sewer system rehab, and then some upgrades at the treatment plant to handle the peak flows during storm events.

“The 10-year plan is really what we’re looking at long term of all the projects that we plan to do including the sewer rehab work roughly $100 million worth of sewer rehab work, upgrades at the treatment plants, the relief intercept, we call it the KISS Relief Interceptor, that’s more in the city of Allentown and then the Western Lehigh Interceptor, that’s the future project,” she stated. “We probably won’t get started on that project until beyond 2030 so we’re several years out. We put it together as a 10-year plan originally because we wanted to understand all of the projects that are coming at us down the pike but DEP is really asking for a five-year plan and so a lot of these big projects are not going to happen in the next 5 years. So the plan that we’re submitting to DEP is a smaller scale plan based on just those five-year projects or the projects in the next five years focused on the municipal sewer rehab program and some upgrades at the treatment plant.”

Chairman Curtis Dietrich asked Gross about the cost and how she anticipates generating the money and if it would be up to the township to change the rates or how that would work.

Gross responds.

“Well a couple of different ways. First of all I have to be clear that the municipal sewer rehab programs primarily are going to be planned and paid for by each municipality that owns the system that’s leaking,” she stated. “Lehigh County Authority owns and operates your system so we will set rates based on the need of the system. We actually own and operate Lowhill, Weisenberg and Upper Milford township’s system, so we sort of combine those three systems, all three of them are small and don’t require a lot of work, but we combine the system so that we get some economies on the rates and we set the rates every year.

“We haven’t done a rate increase in about 13 years so it’s been quite a while as some of these projects start to fold in especially the treatment projects. We should expect to see some increases but we don’t have a rate projection for you today.”

Gross said more than anything, the most important thing for LCA with this plan is that all 15 municipalities are involved and that they are bought into and understand the impacts of this plan.

“Right now we are in the approval process that we are going to be kicking off probably next week and we really need all 15 municipalities to not only understand but officially approved the plan,” she stated.

Gross said they need to submit the plan by the end of this year.

“We’re expecting to deliver the plan the final draft plan to the planning commissions including the Township Planning Commission next week and that starts the clock on the approval process, so there’s a 60-day window for the planning commissions to review or provide any written comments,” she stated. “There will be a public advertisement and a public review process time of 30-days for the public to review and provide comments and then once we have all the comments we will compile them and write responses to them and include them in the plan and then give them to the municipalities, the entire plan with the comments for approval, so we don’t expect the township to get the plan for approval until maybe August or so. What we’re really looking for the planning commissions to do is to provide a letter saying you either have no comment or these are the comments of the Planning Commission.”

LCA really needs to have DEP approve the plan that is kind of the very first step, Gross stated.

“Once we have DEP involved and we hopefully get their approval and we say OK great now we have a plan let’s negotiate this agreement and kind of follow through on all those things.

“So, what we’re going to be asking later this year from the township is for the resolution to be adopted or to pass the plan,” Gross said.