Special Board of Aldermen 10-14-2021 Page 16
permit. It’s the capacity management operation and maintenance section. So we are required to determine specific
achievable goals for the management of the collection system. For example, how many linear feet we intend to video of
the sewers. What is our standard operating procedure for cleaning the sewer and a potential replacement schedule?
We write this so we can tailor it to what we believe to be economically feasible. However, EPA and DES have the final
approvals on whether or not they believe it to be enough.
Long term control plan/integrated plan. This is, again, the CMOM portion of the NPDES Permit as well as the MS4
Permit. So this looks ahead - what are we looking to do moving forward for long term control of the CSOs as well as
storm water management. The consent decree is through the NPDS Permit but it's separate. It's a legal document
issued by the EPA, specifically requiring us to take additional steps towards long term CSO control. Our last consent
decree was from 2003 and was the specific driver for projects like the screening and disinfection facility, the wet weather
flow treatment facility, and Harbor Ave. sewer separation, as well as many others and we expect to see another following
the completion of this one.
The post construction monitoring plan is one of the final stages of the existing consent decree. It was written by Nashua
as a way to measure the effectiveness of the projects completed for CSO long term control. We've been waiting to kick
that off on the completion of several citywide projects. Storm water Management Plan is a requirement of the MS4
Permit and is a plan for the mitigation of storm water pollution. It looks forward at different projects - cleaning schedules
on catch basins and other structures, green infrastructure and more.
Illicit Discharge Determination and Elimination Program. This is another MS4 requirement. It provides a plan for looking
for illegal connections of storm water to our system and removing them. NOI is the Notice of Intent. It's a document
used to declare Nashua under specific general permits such as the MS4 and MSGP. The SWPPP is the Stormwater
Pollution Prevention Plan. This is under the MSGP and is written for the wastewater facility site. It includes inspection
requirements, testing, education, and training requirements. The SPCC is the Spill Prevention Control and
Countermeasure Plan and this is under the AST and UST certification as well as EPA requirements and its necessary of
any facility that has the capability of leaking large quantities of oil or fuel to the stormwater system and eventually to the
river. Because of the quantities of fuel on site for the emergency generators, we follow into this category and, again, has
inspections, reports, tests, and maintenance requirements. So we're going to turn it over to Frank Ayotte of Hazen and
Sawyer.
Frank Ayotte, Hazen and Sawyer
Yes, thank you. I'm one of the city's wastewater infrastructure consultants. Before we get into the slides, just to
comment on wastewater infrastructure. Always water infrastructure whether it's be treatment, collection, pumping is
designed to protect public health. As you can see in the slide, the city has over $85 million dollars and upcoming capital
investments to protect public health. There is a number of bulleted items there, which highlights some of the projects.
There are over 40 of them in the Capital Improvement Plan and these expenditures are required to replace the aging
equipment and infrastructure that keep the city in compliance with all the permits and guidelines Noelle mentioned as
issued by the USEPA to avoid costly fines and violations as a result of failed infrastructure.
Let's look how Nashua’s residential rates compare with selected regional rates. As you can see, these numbers have
been updated for 2021. Nashua is still lower than many of its peer communities. Of importance to note, the average
quarterly bill for the cities above not including Nashua is $156.43 as compared to Nashua this time for $94.97 and is still
well below the State average of $191.25.
So looking at the residential sewer rates from 21 to 23, we just had a residential increase in 2021 of 20% to bring us to
9497. In 2022, a 15% increase is projected and in 2023, a 0% increase is projected. As | mentioned before, this is still
well below the comparison cities averages and the New Hampshire State average. Of importance to note on that last
slide Dan, is prior to 2020 over a 16 year period, there was only an average increase of about 2% in the rate. So it was
very stagnant over that time.
So what is the City doing to control some of its costs besides taking advantage of State revolving loan fund, low interest
rates, and grants? The city has developed an integrated planning framework and has developed a dynamic sewer rate
model to comply with its consent decree from the USEPA. What is an integrated planning framework? It is an EPA
accepted planning framework that allows the city to prioritize its capital projects that best address the most pressing
system needs as determined by Nashua’s criteria. So all those capital projects are then linked into a dynamic sewer rate
model, which was developed by Hazen and Sawyer and allows us to defer capital projects that have determined to have
fewer benefits and some of your more pressing needs. What this allows us to do, it allows us to smooth the cost curve
by shifting projects further out into the future that may not have the most immediate benefit.
