Ways to strengthen rural health care are expected to be discussed during the 2020 legislative session, which begins on Feb. 4.
— Read on www.waff.com/2020/01/08/rural-health-care-priority-ala-legislative-session/
Curtailed water use and conservation are common topics of conversation in areas with water supplies limitations. As drought conditions worsen, the need for action increases, so when creating a regulatory framework, or when trying to measure water use efficiency, water supply managers often look for easily applied metrics to determine where water use can be curtailed. Unfortunately, the one-size-fits-all mentality comes with a potential price of failing to fully grasp the consequences decision-making based on such metrics.
One of the issues that water supply regulator like to use is per capita water use. Per capital water use is often used to show where there is “wasted” water use, such as excessive irrigation. However such a metric may not be truly applicable depending on other economic factors, and may even penalize successful communities with diverse economic bases. A heavy industrial area or dense downtown commercial center may add to apparent per capita use, but is actually the result of vibrant economic activity. Large employment centers tend to have higher per capital use than their neighbors as a result of attracting employees to downtown, which are not included in the population.
In south Florida, a recent project I was involved with with one of my students showed that while there was significant variability among utilities, but the general trend of increased economic activity was related to increased per capita use. Among the significant actors were health care, retail trade, food service and scientific and technical services. It appears to be these sectors that drive water use upward. As a result when evaluating the efficiency of a utility, an analysis should be conducted on the economic sectors to insure that water regulations do not stifle economic growth and jobs in a community. And conversely if you do not have these sectors, you water use should be lower. Something to think about when projecting or regulating water use. Limited water use may in fact be limiting economic activity in the area. Of course if you are water limited, limited new withdrawals may be perfectly acceptable if you want to encourage other options, like direct or indirect potable reuse, irrigation, etc.
It would be interesting to expand this study across the country to see what the national trends look like and how different tourism oriented South Florida might actually be.
Speaking of water supply problems, welcome to Flint, Michigan. There have been a lot of coverage in the news about the troubles in Flint the last couple of months. However if you read between the lines you see two issues – first this is not new – it is several years old, going back to when the City’s water plant came back on line in May 2014. Second this was a political/financial issue not a public health issue. In fact, the political/financial goals appear to have been so overwhelming, that the public health aspects were scarcely considered. Let’s take a look at why.
Flint’s first water plant was constructed in 1917. The source was the Flint River. The second plant was constructed in 1952. Because of declining water quality in the Flint River, the city, in 1962, had plans to build a pipeline from Lake Huron to Flint, but a real estate scandal caused the city commission to abandon the pipeline project in 1964 and instead buy water from the City of Detroit (source: Lake Huron). Flint stopped treating its water in 1967, when a pipeline from Detroit was completed. The City was purchasing of almost 100 MGD. Detroit declared bankruptcy. The City of Flint was basically bankrupt. Both had appointed receivers. Both receivers were told to reduce costs (the finance/business decisions). The City of Flint has purchased water for years from Detroit as opposed to using their Flint River water plant constructed in 1952. The Flint WTP has been maintained as a backup to the DWSD system, operating approximately 20 days per year at 11 MGD.
The City of Flint joined the Karegnondi Water Authority (KWA) in 2010. The KWA consists of a group of local communities that decided to support and fund construction of a raw water pipeline to Lake Huron. The KWA was to provide the City of Flint Water Treatment Plant with source water from Lake Huron. An engineer’s report noted that a Genesee County Drain Commissioner stated that one of the main reasons for pursuing the KWA supply was the reliability of the Detroit supply given the 2003 power blackout that left Flint without water for several days. Another issue is that Flint no say in the rate increases issued to Flint by Detroit. Detroit’s bankruptcy may also have been a factor given the likelihood of increased prices. While discussion were ongoing for several years thereafter, the Detroit Free Press reported a 7-1 vote in favor of the KWA project by Flint’s elected officials in March, 2013. The actual agreement date was April 2013. The cost of the pipeline was estimated to be $272 million, with Flint’s portion estimated at $81 million.
The City of Detroit objected due to loss of revenues at a time when a receiver was trying to stabilize the city’s finances (in conjunction with the State Treasurer). In February 2013, the engineering consulting firm of Tucker, Young, Jackson, Tull, Inc. (TYJT), at the request of the State Treasurer, performed an analysis of the water supply options being considered by the City of Flint. The preliminary investigation evaluated the cost associated with the required improvements to the plant, plus the costs for annual operation and maintenance including labor, utilities, chemicals and residual management. They indicated that the pipeline cost was likely low and Flint’s obligation could be $25 million higher and that there was less redundancy in the KWA pipeline than in Detroit’s system. In 2013, the City of Detroit made a final offer to convince Flint to stay on Detroit water with certain concessions. Flint declined the final Detroit offer. Immediately after Flint declined the offer, Detroit gave Flint notice that their long-standing water agreement would terminate in twelve months, meaning that Flint’s water agreement with Detroit would end in April 2014 but construction of KWA was not expected to be completed until the end of 2016.
It should be noted that between 2011 and 2015, Flint’s finances were controlled by a series of receivers/emergency managers appointed by the Governor. Cutting costs was a major issue and clearly their directive from the Governor. Cost are the major issue addressed in the online reports about the issue. Public health was not.
An engineering firm was hired as the old Flint River plan underwent $7 million in renovations in 2014 to the filters to treat volumes of freshwater for the citizens. The project was designed to take water from the Flint River for a period of time until a Lake Huron water pipeline was completed. The City of Flint began using the Flint River as a water source in May of 2014 knowing that treatment would need to be closely watched since the Michigan Department of Environmental Quality in partnership with the U.S. Geological Survey, and the City of Flint Utilities Department conducted a source water assessment and determined the susceptibility of potential contamination as having a very high susceptibility to potential contaminant sources (take a look at this photo and see what you think).
Flows were designed for 16 MGD. Lime softening, sand filters and disinfection were in place. Everything sounded great. But it was not. Immediately, in May and August of 2014, TTHM samples violated the drinking water standards. This means two things – total organic carbon (TOC) in the water and additional chlorine being added to disinfect and probably reduce color caused by the TOC. Softening does not remove TOC. Filtration is not very effective either. High concentration usually needs granular activated carbon, ion exchange or membranes. The flint plant had none of these, so the carbon staying in the water. To address the TTHM issue, chlorine appears to have been reduced as the TTHM issue was in compliance by the next sampling event in Nov 2014. However, in the interim new violations included a total coliform and E. coli in August and September of 2014, and indication of inadequate disinfection. That means boil your water and lots of public outcry. The pH, salinity (salt) and other parameters were reported to be quite different than the Detroit water as well. A variable river system with upstream agriculture, industry and a high potential for contamination, is not nearly as easy to treat as cold lake water. These waters are very different as they City was to find. What this appears to indicate is that the chemistry profile and sampling prior to conversion and startup does not appear to have been fully performed to identify the potential for this to occur or this would have been discovered. This is now being suggested in the press.
The change in water quality and treatment created other water quality challenges that have resulted in water quality violations. Like most older northern cities, the water distribution system in almost 100 years old. As with many other municipalities at the time, all of the service lines from the cast iron water mains (with lead joints) to end users homes were constructed with lead goosenecks and copper lines. Utilities have addressed this with additive to prevent corrosion. In the early 1990s water systems were required to comply with the federal lead and copper rule. The concept was that on the first draw of water in the morning, the lead concentration should not exceed 0.015 mg/L and copper should not exceed 1.3 mg/L. Depending on the size of the utility, sampling was to be undertaken twice and a random set of hoses, with the number of samples dependent on the size of the system. The sampling was required to be performed twice, six months apart (note routine sampling has occurred since then to insure compliance). Residents were instructed on how to take the samples, and results submitted to regulatory agencies. If the system came up “hot” for either compound, the utility was required to make adjustments to the treatment process. Ideally water leaving the plant would have a slightly negative Langlier saturation index (LSI) and would tend to slightly deposit on pipes. Coupon tests could be conducted to demonstrate this actually occurred. As they age, the pipes develop a scale that helps prevent leaching. Most utilities tested various products. Detroit clearly did this and there were no problems. Flint did not.
The utility I was at was a perfect 100% non-detects the first time were tested. We had a few detections of lead and copper in samples the second time which really bothered me since the system was newer and we had limited lead in the lines. I investigated this and found that the polyphosphate had been changed because the County purchasing department found a cheaper product. I forced them to buy the old stuff, re-ran the tests and was again perfect. We instructed our purchasing department that saving a few bucks did not protect the public health, but the polyphosphate product did. Business and cost savings does not trump public health! Different waters are different, so you have to test and then stay with what works.
Now fast forward to Flint. They did not do this testing. The Flint River water was different that Detroit’s. Salinity, TOC, pH and overall quality differed. Accommodations were not made to address the problem and the state found no polyphosphates were added to protect the coatings. Veolia reported that the operations needed changes and operators needed training. Facilities were needed to address quality concerns (including granular activated carbon filter media). As a result the City appears to have sent corrosive water into the piping system, which dissolved the scale that had developed over the years, exposing raw metal, and created the leaching issue. Volunteer teams led by Virginia Tech researchers reported found that at least a quarter of Flint households have levels of lead above the federal level of 15 ppb, and as high as 13,200 ppb. Aging cast-iron pipe compounded the situation, leading to aesthetic issues including taste, odor and discoloration that result from aggressive water (brown water). Once the City started receiving violations, public interest and scrutiny of the drinking water system intensified.
The City Commission reportedly asked the receiver to switch back to Detroit water, but that request was initially rebuffed and the damage to pipes continued. Finally in October 2015, the water supply was switched back to Detroit and the City started adding additional zinc orthophosphate in December 2015 to facilitate the buildup of the phosphate scale eroded from the pipes by the Flint River water. But that means the pipes were stable, then destabilized, now destabilized again by the switch back. It will now take some time for the scale to rebuild and to lower lead levels, leaving the residents of Flint at risk because of a business/finance/political decision that had not consideration of public health impacts. And what is the ultimate fate of the KWA pipeline?
Just when things were starting to look up (?), in January 2016, a hospital in Flint reported that low levels of Legionnaires’ disease bacteria were discovered in the water system and that 10 people have died and another 77 to 85 affected. From the water system? A disinfection problem? Still TOC in the water? The lawsuits have begun but where does the problem lie? Let’s look at Walkerton Ontario for guidance in the aftermath of their 2000 incident.
First it is clear that public health was not the primary driver for the decisions. Treating water is not as simple as cost managers think. You need to understand what water quality, piping quality and stabilization you have and address the potential issues with new water sources. Membrane systems are very familiar with these challenges. Cost cannot be the driver. The Safe Drinking Water Act does not say cost is a consideration you use to make decisions. Public health is. So the initial decision-making appears to have been flawed. Cost was a Walkerton issue – cost cannot be the limiting factor when public health is at risk.
The guidance from consultants or other water managers is unclear. If the due diligence of engineers as to water quality impacts of the change in waters was not undertaken, the engineering appears to have been flawed. If the engineer recommended, and has lots of documentation saying testing should be done, but also a file full of accompanying denials from the receivers, another flawed business decision that fails the public health test. If not, I see a lawsuit coming against the consultants who failed in their duty to protect the public health, safety and welfare.
The politics is a problem. A poor community must still get water and sewer service. Consultants that can deal with rate and fee issues should be engaged to address fairness and pricing burdens. Was this done? Or was cutting costs the only goal? Unclear. The politics was a Walkerton issue.
Was the water being treated properly? Water quality testing would help identify this. Clearly there were issues with operations. Telling the state phosphates were used when they were not, appears to be an operations error. Walkerton also had operations issues as well. A major concern when public health is at risk. Veolia came to a similar conclusion.
The state has received its share of blame in the press, but do they deserve it? The question I have is what does the regulatory staff look like? Has it been reduced as the state trims its budget? Are there sufficient resources to insure oversight of water quality? The lack of provincial resources to monitor water quality was an issue in Walkerton – lack of oversight compounded local issues. That would then involve the Governor and Legislature. Politics at work. Likewise was there pressure applied to make certain decisions? If so, politics before public heath – a deadly combination.
So many confounding problems, but what is clear is that Flint is an example of why public utilities should be operated with public health at the forefront, not cost or politics. Neither cost of politics protect the public health. While we all need finances to pay for our needs, in a utility, money supports the operations, not controls it. We seems to have that backward. Private entities look sat controlling costs. Public agencies should look at public service first; cost is down the list. We need the operations folks to get the funds needed to protect the public health. And then we need to get the politicians to work with the staff to achieve their needs, not limit resources to cut costs for political gain. Ask the people in Flint.
So is Flint the next Walkerton? Will there be a similar investigation by outside unconnected people? Will the blame be parsed out? Is there a reasonable plan for the future? The answers to these questions would provide utilities with a lot of lessons learned and guidance going forward and maybe reset the way we operate our utilities. Happy to be a part of it if so!
In my last blog I introduced our ethics project we hope to make progress on. But here is one of the interesting questions, especially in Florida. I could not find any actual laws or rules issues here, but it is increasingly common for big engineering contracts to have lawyers, lobbyists, etc. get involved in what is intended to be a qualifications based selection process? There is an interesting issue raised in 287.055 FS (CCNA) where the legal intent is that governmental agencies “shall negotiate a contract with the most qualified firm for professional services at compensation which the agency determines is fair, competitive, and reasonable.” Most states use credentials and qualifications for selection as opposed to cost, because the lowest cost may not get you the best job. You want people doing engineering that have experience with the type of project you are doing. This has come up to me with storage tanks, membrane plans, deep wells, etc. You want someone that has done it before, not someone who is cheaper but hasn’t. There is too much at risk.
In addition the statute is fairly specific about contingent fees (as are most states):
Ch 287.055 (6) PROHIBITION AGAINST CONTINGENT FEES.—
(a) Each contract entered into by the agency for professional services must contain a prohibition against contingent fees as follows: “The architect (or registered surveyor and mapper or professional engineer, as applicable) warrants that he or she has not employed or retained any company or person, other than a bona fide employee working solely for the architect (or registered surveyor and mapper, or professional engineer, as applicable) to solicit or secure this agreement and that he or she has not paid or agreed to pay any person, company, corporation, individual, or firm, other than a bona fide employee working solely for the architect (or registered surveyor and mapper or professional engineer, as applicable) any fee, commission, percentage, gift, or other consideration contingent upon or resulting from the award or making of this agreement.” For the breach or violation of this provision, the agency shall have the right to terminate the agreement without liability and, at its discretion, to deduct from the contract price, or otherwise recover, the full amount of such fee, commission, percentage, gift, or consideration.
So here is the question: As the public becomes more aware of these types of political lobbying activities, does it move the perception of engineers away from a profession and more towards profession toward developers, lawyers and others who are often seen as less ethical than perhaps engineer, doctors, educators, and scientists? And if so, is this good for either the engineering profession or the local governments (and their utilities) involved in the selection process? The comment that “that’s how business get done” is not an acceptable argument when the priority purpose of engineers, and utility operators is the protection of the HEALTH, SAFETY AND WELFARE OF THE PUBLIC. Somehow I think the politicizing of engineering contracts does not help our profession. Looking forward to your thoughts.