I delivered the letter below to Shepherdstown this afternoon. The Shepherdstown
Council meets in Town Hall 7:30pm tomorrow, Tuesday 12/9. The agenda includes
reviewing and scheduling hearings on a Sewer Plan, and some annexations.

Doubling Shepherdstown's sewer plant would allow 2,000 customers plus expansion
of Shepherd College. (The plant has 687 customers now and is not quite full.
Doubling the plant allows non-Shepherd customers to triple). The 2,000 customers
are assumed to have the same mix of business and homes as now. For example
today's 3 major hotels would become 9 major hotels.

The Sewer Plan proposes to double the plant, except they would quadruple parts
of it now and all of it in 10 years. Quadrupling the plant would allow 5,000
customers plus Shepherd expansion.

Paul Burke
------------------------------------------------
December 8, 2003

Dear Mayor and Council of Shepherdstown:

It is premature to ask for public comment on Chester Engineering's sewer
plan. I ask the Council to send it back for more information and for
better growth estimates. I mentioned my concerns to Board member Harvey
Heyser, and he asked me to put them in a letter.

As Chester says on p. 22, the size of a sewer plant is based on its peak
hourly flows, not daily flows. Plants also have limits on the pounds of
solids, biochemical oxygen demand, and Nitrogen they can handle. Only
daily flows are shown, and these are not the limiting factor. It should
not be hard to add a page of information on recent trends in peak hourly
flows and in the chemicals mentioned. These would show how close the
plant is to its limits, and they would allow projections to see when the
plant has to double, or reach some other size.

The Plan projects growth far above what has been proposed, or historical
experience. If the goal is for growth to pay for existing needs, many
towns have tried that and failed. The state does not let new customers
pay their own full costs, let alone existing needs. Buying too much
equipment too soon costs everyone money.

1. MONTHLY COST IS MISSING. The public needs to know the monthly cost,
before they can comment intelligently on the proposal. My estimate is
that the sewer plant proposed would initially increase home sewer bills
about $15 per month (half percent interest over 20 years, and 190 gallons
per day, GPD).

2. TECHNOLOGY THAT WILL BE OBSOLETE. Chester proposes to build parts of
the plant for quadruple its current capacity. Building quadruple capacity
is more expensive than building double capacity. For example replacing
the head work to handle twice the current flow can be done for $372,000
(alternative 1), but Chester recommends $527,310 (alt 3) to save money
in case the plant is eventually quadrupled. Technology moves fast, so it
is implausible that a design now will be the best way to expand in 10 or
more years. For example the plant's old design is not considered the best
way to expand now. Historically incomes have risen, so poor people now
should not pay extra to help out a richer generation in the future,
especially since quadrupling may be far in the future.

3. CUSTOMER PROJECTIONS. Chester assumes there is immediate growth at 11%
per year, declining to 4% per year in 20 years (p. 22). This is
impossible. Housing in the whole county grew only 1.7% per year in the
1990s and created an uproar which is slowly changing the way growth is
managed.

Chester's estimate is excessively high, because they assume (a) service
to existing subdivisions (discussed below under Existing Subdivisions),
(b) infill in town, though the town has been losing population, not
growing, (c) approval of 102 apartments, where the county thought that
was too dense, (d) over 700 more homes at unspecified locations, and (e)
unspecified businesses (other than Shepherd) providing 36% of the growth.


If growth continues at historical rates, or even lower, but the plant is
sized for a building boom, the costs will be an albatross on the town. If
growth continues at 1.7% per year, average flows when Shepherd is in
session will reach 400,000 in 2017.

2017 is far away, and I do understand that the real limits are the limits
on peak flows and chemicals, discussed below under Urgency. Chester
provides no information to say when the town and Shepherd will reach
those limits. Thus there is no information for the Board, Council, or
public to decide about need, how much capacity to build, and when.

Shepherd is estimated to average 110,000 GPD now, the equivalent of 445
other customers. Chester projects Shepherd will grow 140% to 264,000 GPD
(equivalent of 445 + 600 + 22 other customers). This may be too low,
correct, or too high, since the plan includes no document, schedule, or
breakdown from Shepherd. It is also surprising to use an estimate rather
than hard data for Shepherd's current flow.

Shepherd is estimated at a third of the peak flow now (320,000 GPD), but
does not pay a third of the cost, because it pays little during the
summer, while other customers continue to pay summer and winter to keep
that capacity ready for Shepherd. As Shepherd grows, the cost of
maintaining peak capacity for them will grow. An alternative of a
separate plant for Shepherd seasonal flows needs to be evaluated. Without
Shepherd and with historic growth trends, the current size of the plant
will serve the town indefinitely, though equipment will need gradual
replacing, as discussed below under Urgency.

Chester says they project 20% business growth, not 36%. However they
project 247 GPD per house. Since houses use only about 170-190 GPD, the
other 23-31% is business use. Chester adds another 20% for even more
business, with no idea what kinds of business or where. For 30 years
business has grown less than housing in the county, not more.

4. SEWER PIPES. State rules require sewer plans to evaluate the cost of
laying pipes and methods of sludge disposal (47 CSR 31 Appendix A-IV).
The Plan does not cover these. The county's Cattail Run study estimates
pipes at about three times the cost of the plant. That ratio would mean
sewer bill increases up to $60 per month, rather than $15. Just as in
Shepherdstown, the Cattail ratio excludes pipes inside subdivisions,
which developers would pay for. Cattail uses long pipes, but it also
divides the cost over a large customer base. Shepherdstown's costs could
include expanding pipe sizes in the existing area and could be very
different from the Cattail ratio. Board, Council and public cannot
evaluate a proposal when a big cost is unknown.

The Plan also lacks required information on environmental impacts and
infiltration (47 CSR 31 Appendix A-II.C and VI). An infiltration study
required by permit section B.1 was due 10/31/03.

5. EXISTING SUBDIVISIONS. The customer counts assume that Mechlenburg
Heights, Chapline's Choice, Heatherfield, and Leland Meadows will
participate. This is not feasible, since (a) there is no source of money
for pipes in these subdivisions, or for their share of plant and general
pipe expansion, and (b) they have cheaper alternatives. Cheaper
alternatives include requiring biennial pumpouts, home aeration for the
few systems that fail, and/or collecting just the clarified liquid (in
much smaller pipes, probably for local treatment) after partial treatment
in existing septic tanks. Chester's draft plan depends on forcing
existing homeowners to pay thousands of dollars to hook up, close septic
systems and pay high monthly sewer bills, when only a few have failing
septic systems. The customer counts also assume that Cress Creek will
participate, again without study of alternatives.

Documentation of need, including septic tank failure rates and health
reports must be included in a sewer plan (47 CSR 31 Appendix A-II.G).

6. ARBITRARY PRICE ESTIMATES. For all alternatives, even if the town buys
most of the system as a package installed by the manufacturer, Chester
Engineering includes flat markups of: 15% general overhead, 15%
contractor markup, 25% contingency, and 20% engineering (20% of markups
as well as the base). Thus engineering is 17% of total cost, regardless
of how much work they do. Furthermore, WV allows only 10% contingency,
not 25% (47 CSR 31 Appendix A-VIII.A.1), and other costs must be related
to the work done.

7. URGENCY. The need for expansion or modernization may be urgent, but
the study does not show it. The study says the average flows when
Shepherd is in session are 320,000 GPD, in a plant designed for averages
of 400,000 GPD, and able to handle hourly peak rates of 1,000,000 GPD (a
factor of 2.5, p. 22).

A recent letter (12/3/03) from DEP and the Bureau for Public Health to
Chester said the Charles Town plant's limiting factors are the daily
weight of solids, biochemical oxygen demand, and Nitrogen that it can
process, rather than daily flows. These would be limits in all sewer
plants. The Shepherdstown study has no information on the trends of these
items in Shepherdstown, and how soon they will reach their limits.

The study needs to show how close the plant comes to its limits on
chemicals and hourly peak flows, and what the trend has been in those
peaks. The study reports a peak daily flow of 753,500 gallons in 1998,
but has no data on peak hourly flows or peak chemicals, although
overloads are caused by hourly flows, not daily flows. Daily peaks for
recent months are shown in the graph.

There is also a possibility that the equipment is too old to continue
using. This would justify replacing parts of it as needed. The study
needs to show which parts of the plant are cheaper to replace than
maintain. Those are needed costs, but are not shown. Excess expansion and
debt will make rates more expensive, not cheaper.

8. CONCLUSION. The size of any replacement equipment should be based on
past trends in peak hourly flows (unknown so far), trends in the
chemicals mentioned by DEP and BPH (unknown so far), and add historic
growth trends with or without Shepherd, to see what will be needed in
5-10 years. Then a realistic price is needed for that capacity, and the
resulting monthly cost. Required state information (47 CSR 31) should
also be included.

Sincerely,
Paul Burke