Update: Franklin aldermen voted unanimously to fund the expanded drinking water plant even after voicing concerns that new financial information was provided only a day earlier and outside experts already had found many of the same problems as prior analysis (see below). (press story).
October 11: Press examines City of Franklin legal tactics Against HRWA-- free speech legal expert, Paul Levy, an attorney at Public Citizen, in Washington, DC, interviewed by Tennessean says "What they want to do is beat the (watershed association) into the ground.... I would say it is a form of bullying." Tennessean story.
Send the petition to Franklin NOW and share it! If you want to personalize your message, use the links in blue below.
Attend Franklin meeting 5pm! 109 Third Ave South, Franklin, TN. City Hall on the Square downtown. Your presence is VITAL to show support for safe drinking water, rational decision-making, and the Harpeth.
See below for summary, details, and documents on the many key aspects of this issue!
Franklin's reliable source of drinking water is provided by a utility on the Cumberland River with a drinking water plant over 20 times the size of Franklin's tiny plant on the Harpeth. Current information on costs and effects on the Harpeth are either incomplete, incorrect, outdated, or confusing.
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Several times over the past decade with four different engineering firms, City Staff have pursued an expansion of the City's drinking water plant. After multiple attempts over the years, City officials have yet to approve the construction of a new plant either at the same size or expanded. The City’s service district serves just over 17,000 customers, purchases the majority of its water from a large utility on the Cumberland, and could not provide 100% of its own annual customer demand regardless of the size of any expanded plant [see City Service District Map]. Also, of those 17,000 customers, many are in Grassland and not city voters, so they do not have a say in their drinking water rate increases.
On June 9, the city staff update as they prepare construction plans is that a new plant is now another $2.7 million more! The expanded plant is now at least $14 million, plus the $1.5 million in engineering costs and $3 million that went into the repair of the reservoir that is integral to the system. This is over $18 million. Yet, the city staff and consultants indicated no intention of providing an updated unit cost, such as dollars to make 1000 gallons, to compare to their purchase price from their major supplier. Without this "apples to apples" cost comparison there is no way for the citizens or elected officials to make an informed decision.
Given the importance of this issue to the future of Franklin, City Leadership and Franklin citizens and ratepayers must ensure that the decision to expand the drinking water plant is the best choice available to City residents, ratepayers, and the Harpeth River. Ensuring the best decision means being well informed.
In order to make the best decision for the City, HRWA strongly encourages Franklin citizens and City leadership to have a well informed, honest and public discussion about the future of the river and the drinking water plant. Your involvement is critical.
To HRWA, the most important issue is to establish water withdrawal limits from the Harpeth River that avoid causing harm to the river's aquatic life during the high stress, low flow summer season. HRWA does not oppose the city's use of the Harpeth as a minor source of drinking water as long as the withdrawals are scientifically demonstrated to not cause further impairment to the Harpeth. The water quality of the Harpeth is impaired through Franklin according to state assessments. The state has determined that the city's current water withdrawals cause degradation. As a result, the Tennessee Department of Environment and Conservation (“TDEC”) issued a state permit to the City in 2007 that for the first time set conditions on withdrawals from the Harpeth. The permit prohibits the city from withdrawing more than 20% of the river's flow and from withdrawing when the river is below the cutoff of 10 cubic feet per second ("cfs"). Recently, TDEC stated that the minimum cutoff limit in the permit needs to be analyzed to determine if is is sufficient to prevent the withdrawal from causing harm to the river. As a result, TDEC has committed to form a statewide policy group and fund work to develop scientifically defensible withdrawal restrictions, including on the Harpeth. In addition, a version of the new permit that is to be issued shortly includes a limit to stop withdrawals when the river is below certain water quality standards.
Given the potential for withdrawal restrictions to change in the future, the City should be hesitant to invest tens of millions in an expanded plant, especially given the already questionable economic wisdom of expansion. Furthermore, if the City wishes to be a “good steward” of the Harpeth, construction should be postponed until a scientifically defensible withdrawal regime is established that guarantees no harm to the Harpeth.
For more information on the state water withdrawal permit and latest findings on the ecological effects of the Franklin's withdrawals, go to the drinking water section.
City Staff have repeatedly stated in letters to the state government and in op-eds that the proposed work on the drinking water plant is not an expansion even though that has been the proposal presented since 2003 in numerous city documents [see Mayor Moore & City Administrator Stuckey op-eds]. Use of two definitions of capacity – “Firm” and “Production” capacities – has created confusion over the size of the proposed new plant. The City's existing plant has a full capacity of 2.1 MGD. The City maintains that while the full production capacity of the new plant is 4.0 MGD, one entire unit will remain out of service as an emergency backup. According to Water Department head Mark Hilty, this means the City "will operate the plant at 2.6 MGD unless there is critical necessity."
However, the City’s own Preliminary Engineering Report contradicts these statements. That design document says that the plant will produce 1035 million gallons per year – or 2.84 MGD [see 2014 engineering report Operation Costs, see highlight on table in same report]. This is more than the 2.6 MGD figure the City uses. The City’s planning documents clearly presume that the upgraded plant will be producing 4.0 MGD whenever possible. The Preliminary Engineering Report's only assessment of the proposed plant's annual production is tied to operation costs, which are themselves tied to production at 4.0 MGD in appendix charts to the Preliminary Engineering Report [see Appendix Operation Costs]. If the City does intend to only operate the plant at 2.6 MGD, then its analysis of economic return should assess this level of production. If the City intends to operate the plant at 4.0 MGD, it should tell Franklin's citizens and ratepayers.
Above: The annual production figures of the proposed plant are nearly twice that of the current drinking water plant.
To Clear the Smoke, here is an analogy:
The City staff want to build a 4000 square foot house, but are saying they will only use 2600 square feet of it much of the time. So they want to call the house only a 2600 square foot house, even though they will be building a 4000 square foot house. Then they want to use the entire house whenever they can, which is likely only about half the year. Whether they use the entire house or only part of it, the full size of the house is what is being build so it is a 4000 square foot house.
The reason the City can not use the entire design/full capacity of the proposed 4.0 MGD plant is that the Harpeth is too small! Even with the City's existing plant that is only 2.1 MGD (half the size of the proposed plant), summer low flows in the Harpeth prevent the City from producing at its 2.1 MGD capacity throughout the year [see 2008-2013 City Annual Water Production Charts]. Typically, the City has to run the plant at half capacity to avoid pulling the reservoir water out faster than it can be filled from the river.
summer low flows in the Harpeth prevent the city from producing at its 2.1 MGD capacity throughout the year see 2008-2013 City Annual Water Production Charts. Typically the City has to run the current plant at half capacity to avoid pulling the reservoir water out faster than it can be filled from the river.
In order to help TDEC assess the City’s application for a renewed withdrawal permit, HRWA commissioned an economic analysis by Dr. William Wade, an expert in water resources economics. Dr. Wade found multiple errors in the City’s assessment on the return it will get by expanding the plant. Surprisingly, the recent work by the city did NOT provide a unit cost of production (for example, in dollars/1000 gallons). This is essential information needed to compare the cost of producing water with the cost of purchasing drinking water, which is (and, even with expansion, will remain) the city's main source of drinking water. Dr. Wade employed the appropriate economic analytical approach using only Franklin data and their consultants' work.
City currently spends more to make own water than to purchase it:
Based on the City's most recent audited rate and financial reports from 2010-2013, Dr. Wade found that the average cost for the city to produce water was $2.80/1000 gallons compared to $2.04 to purchase from HVUD. Dr. Wade's economic analysis shows that the city has lost over $1.6 million from producing its own water versus purchasing all of it. Projecting to 2019 after the proposed 4 MGD plant is in place, the city would lose between $2 and $2.6 million, depending on whether the Harpeth Watershed has a dry or wet summer.
The city administrator has said in public several times that the Franklin produces water at $1.55/1000 gallons [recent press]. Recent review of documents the city provided to support this claim has shown that it is incorrect. The city forgot to include the capital costs to its operating costs. On top of this obvious error, the city was comparing an average between the years 2010-2012 to HVUD's price in 2013-- cherry picking the data. The correct costs are below. It is 33% more for the city to produce it's own drinking water, not 40% less as Eric Stuckey has repeatedly claimed.
Franklin water rates higher than other utilities serving Williamson county and Nashville.
See chart that compares customer bills for residential and commercial for a typical 7000 gallons/month. Franklin NON-residential customers pays the MOST at over 43% more than city residents! The utility operates as a business wholely separate from city taxes, so why are customers that are getting the same service charged differently as resident and non-residents? Franklin rates need to be compared to similar urban utilities not rural ones with less than 32 customers/mile (HB &TS for example).
Also, Franklin public statements say that their drinking water rates have increased mostly due to increases from HVUD. This is not the case. The attached chart shows the breakdown of the city's rate increases over the last 6 years. The city's own costs to operating the drinking water system added 2 to 3 times the value of HVUD's portion of the rate increase during this time.
Projections of future costs with a new, doubled in size drinking water plant: Need "apples to apples" cost comparisons.
The City’s consultant did not incorporate large annual labor costs, missed some annual operating costs, excluded their engineering costs ($1.5 million), and the City’s debt service to pay back already sunk costs, such as the $3 million for the reservoir repair. Also, Dr. Wade's work is based on the appropriate probability analysis of the high variability in the water in the Harpeth. The City also presumed large annual rate increases from the City's primary water source, Harpeth Valley Utilities District (HVUD). Had the City asked HVUD for a rate forecast, as HRWA did and has since been provided to the City, they would have found much more conservative rate growth, including no rate increases in 2015 [see HVUD rate forecast]. Dr. Wade’s analysis shows that neither the City’s current plant nor its proposed expansion can produce water at lower cost than HVUD can sell water to the City [see City vs. HVUD Cost Comparison]. Dr. Wade's analysis found that over the 20 year life of the new plant, the city can not recover all its costs for the new plant. The loss is projected to be about $7 million to $11 million depending on the natural variability of wet, normal and dry years in the Harpeth [see Dr. Wade's full report on Franklin's Water Treatment Plant Financial Analysis].
References by the Mayor, staff and consultants that HVUD's rates increases of the past several years of 7% would be similar in the future have been found to be misleading. The new HVUD 10 year rate forecast of 1.45% annually is not included in the City's consultant's cost analysis, but is used by Dr. Wade. Interestingly, HVUD informed all its customers that it would increase rates for 3 years ending in 2015 to cover a 12 Million gallon a day expansion to reach 60 MGD in 2015 based on the five year growth projections of their customers, including Franklin. HVUD did no rate increase in 2015.
Dr. Wade has repeatedly brought his concerns to the attention of City leadership. The City has stated publicly that it does not agree with Dr. Wade’s analysis; however, the City has not provided any substantive review or refuted his analysis in any way. Instead, the City has offered figures and conclusions with little to no documentation or analysis in support. The documents that do exist have errors or do not support the City's contentions. Given the stakes, the City needs to commission an independent economic analysis of the investment.
Recently another review of the city's documents and new information provided by the city have confirmed Dr. Wade's work but taking painstaking time to pour through to understand how the city's analysis was done. Contact us for documents that may not already be on this web site.
The City of Franklin's economic growth has been tied to its connection to the Harpeth Valley Utilities District to supply the bulk of the city's system with drinking water in the 1980s. HVUD has a recently expanded 60 MGD drinking water plant on the Cumberland River. The Harpeth is too small to be a reliable source of drinking water because of its natural low summer flows [see Cumberland versus Harpeth monthly river flow chart].
Because of the Harpeth's highly variable river flows, the city uses a reservoir where it pumps river water for storage. This arrangement is common when the source water is variable. The drinking water plant makes water from the reservoir, which is filled by withdrawing water from the river. The reservoir leaked so heavily in the past several years that it dramatically affected the city's ability to produce water in the summer. The city spent $4 million on repairs a few years ago ($1 million was a federal grant). The new reservoir is NOT big enough to enable the current 2.1 MGD plant to operate at capacity year-round. Based on the new size and assumptions used by the city's consultants, the reservoir's operating capacity would need to be TWO times bigger and almost over 5.7 times bigger for the proposed expanded 4 MGD drinking water plant [see Water Withdrawal Report by AquAeTer that is part of Dr. Wade's report].
Can you even see the Harpeth river flows during the summer?
Franklin's drinking water plant is a very small facility because the Harpeth does not have enough flow to even support this small one to run at capacity year round. Also Franklin's system only serves 1/3 of the city's entire population. Other utilties serve these areas and all get their drinking water from purchases from HVUD. Since franklin only provides 25% on an annual average in it's own system, when looking at the entire city popluation as a whole, Franklin only produces 8% of the drinking water demand.
Water Losses are a part of drinking water systems. Throughout the US there has been a push to reduce these losses of precious drinking water. Losses of 25% are considered high by the EPA, with many states now having set standards for losses to be down around 10%-15%. The southeastern US has been slow to focus on water losses.
HRWA reviewed the drinking water utilities that serve the Harpeth River Watershed. In 2013 the state required all to report using a standard form designed by AWWA to be able to compare across systems. Franklin and many of the utilities in the area have losses around 25%,. HVUD's losses were only 14% in 2014 and Mallory Valley Utility, that serves the Cool Springs commercial area is only 7%!
Franklin's losses in 2014 were reported at half a billion gallons (500 million gallons)! It's own drinking water plant produced less than that (436 million gallons). Having a new drinking water plant does NOT fix water losses.
Demand for drinking water in the Franklin serve area is DOWN! Estimates of size and growth rate are incorrect in city analyses.
Franklin' current system demand has dropped nearly 14% in the past 8 years (see chart from recent city water operating budget below). Instead the city's analysis for the new drinking water plant are based on increases that start at amounts far above the current system demand of 5.6 mgd. And that 5.6 mgd current demand number includes 1.6 million gallons a day of leaked, lost, and "non-revenue" water. The various scenarios have the demand starting anywhere from 39% to 67% higher than current demand with one scenario of a drought year with demand starting at 14% above.
Franklin spent $2 million to develop a long range sewer and drinking water plan for the next 20 years. This plan is a TOILET TO TAP arrangement with a proposed second sewer plant just UPSTREAM of the drinking water plant. The plan is based on the second sewer plant discharging 4 million gallons a day of treated effluent into the river to "make the Harpeth bigger" so the proposed larger drinking water plant would be able to make a bit more drinking water in the summer when the river is low.
see chart for city powerpoint showing proposal to "increase" drinking water plant production by adding treated sewer effluent flow.
The city's proposal would mean the river flow could be 25%-50% effluent that the drinking water plant would withdrawal to treat during the summer low flow season. There are a huge range of issues with treating sewer effluent to drinking water from incredible cost that is in not incorporated into the city's current work, emerging contaminants of concern, and the absolutely lack of need to do this from a water supply standpoint.
See this link on the issues with emerging contaminants of concern and future details. There is more press on utilities in California treated sewage effluent to drinking water standards, but almost all are putting this back into groundwater and larger bodies of water to enable further treatment and dilution. This is NOT the city's proposal.
The aldermen balked at this concept in 2012 when the overall plan was discussed and the first components adopted. At that time the approval on the drinking water plant was to start analysis to just REPLACE the 2.1 MGD plant and only do "preliminary design" to expand to 4 MGD. Aldermen Burger summed up some of the concerns by stating the Harpeth isn't getting any bigger so where is water going to come from for a bigger drinking water plant.
In June 2014, the preliminary engineering report on the costs for the drinking water plant did NOT provide a comparison between replacing the plant a current capacity and doubling it (2.1 mgd versus 4 mgd). These have been the sizes comparisons in debate since 2003. The report gave the aldermen a comparision of 4 MGD and 6 MGD! (see number 3 above) with a change in terminology to make it look like the smaller plant sizes. it is clear from the review of all the city documents that the analysis focused on the plant producing 4 mgd when possible.
The city staff effort to rename and confuse the sizes of the plant is very likely driven by the nature of the alderman approval in 2012. The aldermen approved the work to compare 2.1 MGD and 4 MGD and they do NOT have that. there is no work to show the cost for a replacement.
it appears to be a shell game or one of bait and switch with the contorted effort to avoid consistently referring to these options all in the same way-- what their full capacity is. Serious public decision-making should not be this confusing.
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