Public Support Boosts Inflow and Infiltration Ordinance

Minnesota regional sanitary district provides actionable intel to engage customers and gain support.

Public Support Boosts Inflow and Infiltration Ordinance

Enacting a sweeping inflow and infiltration ordinance across 17 member communities presents plenty of challenges. Getting all those communities to buy in, along with the general public, has been the path to success for the Western Lake Superior Sanitary District.

Achieving public engagement in any project can be daunting, but in the case of I&I, the best way is simply making sure customers understand the issue at hand.

“People want to do what they can do to help,” says Karen Anderson, director of community relations for the Western Lake Superior Sanitary District.

The district encompasses 17 communities in a 530-square-mile region around Duluth, Minnesota. Like many, they experienced severe I&I issues through the 1990s and 2000s, kicking off a series of Environmental Protection Agency lawsuits, penalties and new permit requirements.

Those problems culminated in a consent degree, signed in 2009 and completed in 2015. Through that time, public education was paramount.

“Along with the requirements of our consent decree, we were required to pass an I&I ordinance, which puts responsibilities on each of those 17 communities,” Anderson says. “They may not have chronic overflows, but they have to start eliminating that I&I from the system.”

Each community in the Western Lake Superior Sanitary District creates and submits its own annual plan for I&I mitigation efforts and community outreach. The district provides resources and materials for education, as well.

Simple terms

In the water and wastewater industries, there can be a lot of trade-specific language. Anderson encourages utilities to keep that in mind when crafting outreach messages.

“In this industry, we don’t use a whole lot of plain language, and we just have to remember we’re working with people who don’t know what a foundation drain is,” Anderson says. “We had to try to think about the words that people don’t know.

“I remember being in college here in town — they were talking about I&I — and thinking, ‘I wonder what that means?’ Because I&I was a big deal, and I lived here, but I didn’t have any idea what they were talking about,” she says.

As important as the quality of the content is the quantity. Consistent and ongoing outreach is important to keep the public’s attention and increase awareness.

When the Western Lake Superior Sanitary District was sued by the EPA, their efforts were handicapped by a lack of awareness — even among community leaders of its member cities and townships.

A popular mayor in Duluth, who eventually helped the district push its I&I ordinance, was completely unaware of the problems they were having, despite being on City Council prior to his election as mayor.

Getting that mayor on board was a huge steppingstone for the district.

“We were very fortunate that the mayor of our largest customer community was making it a priority and talking about it himself, too,” Anderson says. “That’s how we ended up with success: He had a lot of support.

“The message that the city of Duluth used is that we have a responsibility here, to the lake,” she says. “We talk about clean water being important to our quality of life, recreation, health and commerce. We each have a responsibility to do these things to preserve that.”

Down the drain

Another important facet of the district’s outreach strategy is encouraging individuals to contribute to the cure. I&I and other city or regional issues can seem abstract to the average citizen — too big for them to do anything about.

But in the case of I&I, there are steps private homeowners can take to help.

“You need to have public support, and you need to give them that compelling reason as to why it’s important to do these things. But additionally, people want to do what they can do, and really that’s where a lot of contribution comes from,” Anderson says. “People think that sewers are the public responsibility, and they don’t think about each one’s contribution. Part of that is telling people what they can do.”

In addition to giving the public an understanding of I&I, the district also distributes materials showing the effects of roof drains and foundation drains on I&I. When homeowners make the connection between something they’ve seen in their house, but didn’t really understand, and a citywide issue, they are much more likely to do something about it.

“On the residential side, we did have a pretty robust education campaign around that. It was called ‘Money Down the Drain,’ talking about not just the cost of having to treat clearwater, but also showing the impact of just one roof in a typical rainfall and how much that would contribute,” Anderson says.

“We’ve tried to teach people what their individual contribution is because the problem seems really big and a sewer system seems to be a government’s responsibility,” she says. “People need to understand that we have a separated sewer system — clearwater belongs in the storm sewer, not in the sanitary sewer, and you can help. You have a contribution.”

Clear consequences

In the end, customers need motivation to put effort into a program like this — they need to know what they are working for and the consequences of failure.

The last element of any public education is giving people hope that there will be a positive effect if they participate.

“Part of the imagery that we’ve used is really showing the results of clean water. Showing people using clean water in all aspects of their lives,” Anderson says. “Reminding people how important clean water is to their everyday activities and those things that are important to them — that they can contribute to making sure we continue to have clean water.”


Moving forward

Despite completing the consent decree and satisfying demands stemming from the Clean Water Act, the inflow and infiltration ordinance is still in place and the Western Lake Superior Sanitary District isn’t slowing down.

“We just don’t want to go back where we used to live, and I remember it well: We were reactive to wet weather and trying to chase things down after they happened,” Ezell says. “Now, we think we’re on a good path, where we can predict where problems will occur.”

The district works with its cities and townships to create annual plans, including everything from large-scale public projects to customer education and private-side programs like foundation drain disconnections.

The ordinance itself provides guidance on mitigation tactics and programs — in addition to outlining penalties for failure to complete goals. Fines are one penalty, but the ordinance includes more drastic options.

“One of the consequences is we stop approving sewer extensions for new developments. And that does get attention,” Ezell says. “Fortunately that’s been minimal, and I think the last couple years we haven’t had anybody penalized.”

Getting the buy-in from multiple parties is a challenge all municipalities face. Formatting guidelines and requiring compliance has been the No. 1 method to achieve broad peak flow mitigation for the district.

“We’ve seen great progress and great investment by our member communities over the past several years,” Ezell says. “As a result, we’re seeing exceedances drop substantially for wet-weather events.”


Ordinance drives changes

When it came time to enact its inflow and infiltration ordinance, the Western Lake Superior Sanitary District had 17 separate member communities to bring into compliance.

As part of the ordinance, municipalities have to submit annual plans for I&I mitigation efforts and community outreach programs — and risk significant penalties if they fail to meet those goals.

“It’s been a dynamic process, to keep an ordinance,” says Jack Ezell, manager of planning and technical services for the Western Lake Superior Sanitary District. “It has evolved over time, things we’ve learned working with the member communities, and we think we have an ordinance right now that really does work. I’ve seen the results in terms of wet-weather flow reductions and number of exceedances.” 

Ezell has been with the district for 44 years and has visibly witnessed the progress over that time.

“I remember sewage overflows when it seemed like we had a sprinkle, and we just don’t see those anymore,” he says. “We’ve virtually eliminated sewage overflows caused by wet weather in the district. Which is a huge achievement.”

Between 2008 and 2017, the district eliminated an estimated 27 mgd. That steady I&I mitigation, in addition to the construction of storage basins and infrastructure upgrades, resulted in completion of the consent decree by 2015.

“Our board of directors and the city councils throughout the district have followed suit,” Ezell says. “It’s been a long but successful process. All these communities have really made substantial progress in reducing wet-weather flow, and they’ve made substantial investments to get there.”



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