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CONSTITUTION HALL • 525 WEST ALLEGAN STREET • P.O. BOX 30473 • LANSING, MICHIGAN 48909-7973
Michigan.gov/EGLE • 800-662-9278
STATE OF MICHIGAN
DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY
LANSING
June 8, 2021 TO: All Interested Citizens, Organizations, and Government Agencies SUBJECT: DRINKING WATER STATE REVOLVING FUND (DWSRF) CATEGORICAL EXCLUSION Project Owner: City of St. Joseph Project Name: Water Main and Lead Service Line Replacements DWSRF Project Numbers: 7487-01 and 7488-01 The purpose of this notice is to advise interested parties of a proposed decision by the Michigan Department of Environment, Great Lakes, and Energy (EGLE) that the criteria for qualifying for a Categorical Exclusion are met and these projects will not have a significant adverse impact on the environment or public health, and thus, qualify for a Categorical Exclusion under Section 5408 of 1994 PA 451. Consequently, an Environmental Assessment or an Environmental Impact Statement is not required to implement the water supply project discussed in the attached document. CRITERIA USED IN MAKING THE DETERMINATION Part 54 of the Safe Drinking Water Assistance Act specifies six exclusionary criteria that must be met before EGLE can conclude that a proposed project qualifies for a Categorical Exclusion. The criteria are as follows:
(1) The project must not result in an increase in residuals and sludge generated by drinking water processes which would negatively impact the performance of the waterworks system or the disposal methods or would threaten an aquifer recharge zone. (2) The proposed facilities must not be designed to provide service to a population greater than 30 percent of the existing population, unless population projections required in section 5405(3)(e) support projected needs. (3) The proposed public water supply project must not be expected to directly or indirectly affect cultural areas, fauna or flora habitats, endangered or threatened species, or environmentally important natural resource areas. (4) The proposed public water supply project must not directly or indirectly involve the extension of transmission systems to new service areas. (5) The proposed public water supply project has been shown to be the cost-effective alternative. (6) The proposed public water supply project will not cause significant public controversy.
PROJECT DETAIL An attachment describing the proposed project is provided. This information is also available on our website at Michigan.gov/DWSRF under “Related Links.” It presents information related to the proposed project, including the alternative selected, rationale for our decision to grant a Categorical Exclusion, and other pertinent information.
GRETCHEN WHITMER GOVERNOR
LIESL EICHLER CLARK DIRECTOR
Categorical Exclusion Page 2 June 8, 2021 The attachment provides information and allows appropriate federal cross-cutter agencies and state agencies an opportunity to submit information that may impact EGLE’s decision prior to its effective date. Significant issues raised by these agencies could result in EGLE staff preparing a full Environmental Assessment. WHERE DO I SUBMIT COMMENTS? Any comments regarding this decision should be submitted to:
Mr. David J. Worthington, Senior Project Manager Water Infrastructure Financing Section
Financing Division Michigan Department of Environment, Great Lakes, and Energy
P.O. Box 30457 Lansing, Michigan 48909-7957
EFFECTIVE DATE OF THE EGLE DECISION ON THE CATEGORICAL EXCLUSION Absent comments that introduce significant information contrary to EGLE’s final determination, the Categorical Exclusion will become effective upon conclusion of the 30-day comment period. Questions regarding this project can be directed to Mr. David J. Worthington, senior project manager, Water Infrastructure Financing Section, Finance Division, by phone at 517-554-1835, or by mail at EGLE, P.O. Box 30457, Lansing, Michigan, 48909-7957; or you may contact me at the aforementioned address. Your interest in this process is greatly appreciated. Sincerely, Kelly Green, Administrator Water Infrastructure Financing Section Financing Division 517-284-5433 Attachment
DEPARTMENT OF ENVIRONMENT, GREAT LAKES AND ENERGY DRINKING WATER STATE REVOLVING FUND
CATEGORICAL EXCLUSION WATER MAIN AND LEAD SERVICE LINE REPLACEMENTS FISCAL YEARS 2022-2023
June 2021
PROJECT HIGHLIGHTS
Applicant: City of St. Joseph
Address: 700 Broad Street St. Joseph, Michigan 49085
Authorized Representative: Mr. Tim Zebell, City Engineer
Project Numbers: 7487-01 (FY 2022) and 7488-01 (FY 2023)
Project Locations: Streets in the City of St. Joseph
Pre-Bid DWSRF Loan Estimates: 7487-01 $2,500,000 (Willa-Lester & LSLRs) 7488-01 $2,200,000 (Botham-Donna & LSLRs)
Construction Period 7487-01: April 2022 – November 2022 (advance LSLR work July 2021 – March 2022)
Construction Period 7488-01: April 2023 – November 2023 (advance work begins 2021-2022)
OVERVIEW.
The city of St. Joseph (St. Joseph) is applying for below-market-rate loans from the DWSRF program in Fiscal Years (FY) 2022 and 2023 to finance the planning, design, and replacement of approximately 3,700 linear feet or approximately 0.7 mile of water main along Willa Drive, Lester Avenue, Botham Avenue, and Donna Drive (Figures 1-4), including a total of approximately 70 lead service lines replacements (LSLR) along these streets, and another 180 LSLRs at priority sites in the city. These priority sites for 2022-2023 comprise a subset of the citywide LSLR overview map shown in Figure 5. Non-DWSRF funding will finance improvements to sanitary sewers and storm sewers in the street segments, plus full-width roadway reconstruction.
Water main replacement construction will resolve reliability issues due to structural and pressure deficiencies in antiquated, undersized pipes. When completed, the project will improve protection of public health by helping ensure reliable flows and a safe drinking water supply to all customers.
The expected annual debt repayment for up to six projects (two loans) combined will be approximately $206,300 for the water distribution system improvements.
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The interest rate for the FY23 loan is not known at this time. When the water system debt service is distributed across 3,931 city user accounts, it yields roughly $4.37 per month per account.
BACKGROUND
The municipal water system for the city of St. Joseph is described in the DWSRF Project Plan dated April 27, 2017, the DWSRF Project Plan Update submitted to EGLE on June 29, 2020, and prior environmental review documents prepared by EGLE in March 2018, October 2019, and July 2020. The 2020 planning update added annual future replacements of LSLRs as mandated under Michigan’s lead and copper rule (LCR). Descriptions of the city-owned municipal water treatment system, regional authority, and regional distribution system are available in these prior documents.
NEED FOR IMPROVEMENTS AND ALTERNATIVES ANALYSIS
As described in the 2017 DWSRF Project Plan, proposed improvements in the distribution system were developed as part of the city’s latest reliability study, strategic capital improvement plan, and integrated asset management plan for city utilities. The need for water main replacements remains unchanged from these prior planning documents: namely, excessive age, frequent breaks, and the buildup of mineral deposits and metal oxides on interior pipe surfaces that reduces the pipe’s hydraulic capacity and efficiency, increases pumping costs, and reduces pressure in the distribution system. Additional details about the need for improvements were presented in the 2017 DWSRF Project Plan and prior EGLE documents, as well as comparative analyses of potential alternatives for addressing the water distribution system needs.
In order to remain in compliance with the Michigan Safe Drinking Water Act, the city plans to replace 150 lead service lines per year for the next 20 years. The water services to be replaced have been evaluated and categorized by priority based on the following criteria: · Priority 1: LSLR’s as part of upcoming road reconstruction projects. · Priority 2: Water services that leak or need to be replaced as part of water main breaks. · Priority 3: Lead services that test high for lead. · Priority 4: Future projects listed in the Asset Management Plan slated for reconstruction. · Priority 5: Galvanized steel services previously connected to lead. Some Priority 1 projects are either already completed or already underway (most recently Langley Avenue). Beginning in 2021, priority services will be replaced on near-term Capital Improvement Plan (CIP) projects on Willa Drive, Lester Avenue, Botham Avenue, and Donna Drive, followed in future years by other CIP projects as appropriate. Since 2018, the city has been replacing lead service lines discovered during water main breaks, service leaks, and unrelated underground work that disturbs them. The city plans to continue these reactive replacements using local funds (on a pay-as-you-go basis) at an approximate rate of 25 per year. In 2020, the city let a project to replace water services that tested high for lead (a Priority 3 project). The 2020 project was a locally funded project; however, the city desires to finance future high-test service replacements using DWSRF funding at rate of 25 to 30 services per year. The city intends to bid and award a Priority 4 LSLR project that includes Broad Street, Donna Drive and Botham Avenue in 2021, using FY22 DWSRF funding. Beginning in 2023 services that are part of future CIP reconstruction projects will be replaced in locations to be
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determined, as Priority 4. Finally, galvanized water services that were previously connected to lead will be selected as Priority 5 projects, likely beginning with replacements on Botham Avenue between Niles Avenue and Morton Avenue in 2022. This is not the same project as the Botham Avenue water main replacement work between South State Street and Main Street. For LSLRs described in the 2020 planning update, the No-Action alternative was not considered a feasible option because it would not address the public health risk posed by water service lines made of lead or galvanized steel or meet the requirements of the Michigan Lead and Copper Rule. Partial replacements of LSLs (only up to the private property boundary) are not feasible because partial replacement is prohibited under the rule. Regionalization is not applicable, because the St. Joseph water system already serves customers in multiple communities, and the lead services in question are located entirely within the city. The only feasible alternative is full replacement of LSLs from the public water main to the customer's water meter.
SELECTED ALTERNATIVE
The selected alternative allows the option of either the removal or in-place abandonment of the existing water main. New water main will be constructed within the street right-of-way and connected to the existing system. Work will include hydrant replacements and other appurtenances necessary for the water main installation. The water main projects will be completed in conjunction with roadway, sanitary sewer, and storm sewer improvements.
The 2020 DWSRF Project Plan Update describes the construction method for LSLR in St. Joseph. To enable coordination among multiple labor sources and contracts, multiple funding sources, and/or right-of-entry requirements, some advance work may be necessary at some locations. This advance work will involve pushing copper pipe using trenchless methods from the tree lawn to inside the home for later connection during the road reconstruction project. Non-lead services on private properties will not need to be replaced.
COST AND FUNDING SOURCES
Funding for the water main projects is anticipated from a combination of DWSRF for the water main and LSL replacements, the city’s water and sewer funds, and the city’s local street fund.
Table 1 shows the estimated costs including planning, engineering, construction, and legal, financial, and bonding services. Eligible water main construction costs include restoration of the sections of roadway and sidewalk that must be removed to enable the water main work, but not the additional road-related improvements. The portions of construction and engineering eligible for DWSRF funding may be calculated using a standard method known as an Alternative Justifiable Expenditure, or by another method depending on contract details.
IMPACTS AND MITIGATION
All construction activity for water main replacement will occur within the street rights-of-way shown in Figures 1-5. Construction will directly impact residential properties plus a few public or commercial properties. Traffic will be restricted when construction crews are working in and along the street. Local access will be maintained to the maximum extent possible.
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Table 1. Pre-Design Cost Estimate for City of St. Joseph Water Main and LSLR Projects Fiscal Years 2022 and 2023 (rounded to nearest $5,000)
DWSRF Non-DWSRF Total 7487-01 FY 22 Willa Drive and Lester Avenue (no advance work 2021-2022) plus high priority LCR-LSLR
$2,500,000* $1,500,000 $4,000,000
7488-01 FY 23 Botham Avenue and Donna Drive (advance work 2021-2022) plus high priority LCR-LSLR
$2,200,000** $1,000,000 $3,200,000
*Includes approximately $1.2 million in construction for LSLR associated and not associated with water main project.
**Includes approximately $1.2 million in construction for LSLR associated and not associated with water main project.
Lead service line work will occur at priority sites visible on the city website in the interactive map link provided below:
https://www.sjcity.com/images/DSMI_Map_8.5x11.pdf
No known historical or archaeological resources will be impacted by the water main or lead service line work, as confirmed by the EGLE-WIFS staff review in cooperation with the State Historic Preservation Office. The Tribal Historic Preservation Officers were contacted, and none expressed specific concerns.
The projects are in the street corridors of developed urban areas and are unlikely to jeopardize or adversely affect the continued existence of the eight state-listed threatened or endangered species in Berrien County. Tree removals will be conducted between October 1 and March 31 to minimize impacts to the federally endangered Indiana bat and Northern long-eared bat. Although tree removals will be minimized, unavoidable loss of trees will occur and will be mitigated in coordination with the city’s tree planting program. No construction work is anticipated in, on, or near rivers, streams, wetlands, Lake Michigan, beaches, dunes, or other sensitive environmental areas, natural plant communities, or special natural features. Although the water pipe will be located below grade, no major dewatering is anticipated to be necessary for the purpose of maintaining groundwater levels below excavations during construction. The construction contract and permits for water main construction and the non-DWSRF sanitary sewer work will require common measures to control soil erosion and sedimentation, dust, and noise. If contaminated soils, materials, or groundwater are encountered, these will be properly handled according to state regulations and construction contract specifications. No site-specific concerns are anticipated that will require special mitigation measures.
Temporary water service interruptions are anticipated as pipes are being replaced. Residents will be notified prior to replacement work. As with any city construction project, customers will be given the name and phone number of a contact person for construction-related concerns.
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PUBLIC INVOLVEMENT
Throughout recent years involving drinking water grant implementation and the development of asset management plans and the water reliability study, the community has been invited to review the findings, recommendations, and impacts of proposed plans, including discussion at city commission meetings. Public notices and public hearings occurred in Spring 2017 and Spring 2020 for the DWSRF Project Plan and its recent update. The most recent public hearing was held virtually on June 8, 2020. Questions and comments were addressed at the public hearing. After the close of the public hearing, the City Council passed a resolution approving the project plan and agreeing to implement the selected alternative. Various city outreach efforts since 2017 have included website announcements and updates for various water main and road construction projects.
RATIONALE FOR CATEGORICAL EXCLUSION
In accordance with Part 54, Safe Drinking Water Assistance, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, Section 5408(5) specifies criteria that must be met to grant a Categorical Exclusion from further environmental review activity to a proposed DWSRF-assisted project. The water main and LSLR projects will have no significant adverse direct, indirect, or cumulative effects on socioeconomic, cultural, or environmental features. Minor construction impacts will be localized to the construction zones and will be temporary. These impacts can be mitigated with sound construction practices and adherence to permit requirements.
Questions regarding this Environmental Assessment should be directed to:
Mr. David Worthington, Project Manager Water Infrastructure Financing Section
Finance Division Michigan Department of Environment, Great Lakes, and Energy
P.O. Box 30457 Lansing, Michigan 48909-4957
Telephone: 517-554-1835 E-Mail: [email protected]
City of St. JosephEngineering Department700 Broad StreetSt. Joseph, MI 49085
Telephone: 269-983-5541Email: [email protected] [email protected]
Figure 1 - Fiscal Year 2022Water Main Replacements on Willa Drive & Lester Avenue
DRAWN BY: AKADATE: 5/3/2021
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ST. JOSEPH DRIVEADDITIVE ALTERNATE
LSLR Priority 1
City of St. JosephEngineering Department700 Broad StreetSt. Joseph, MI 49085
Telephone: 269-983-5541Email: [email protected] [email protected]
Figure 2 - Fiscal Year 2023Water Main Replacements on Donna Drive
DRAWN BY: AKADATE: 5/3/2021
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LSLR Priority 4
City of St. JosephEngineering Department700 Broad StreetSt. Joseph, MI 49085
Telephone: 269-983-5541Email: [email protected] [email protected]
Figure 3 - Fiscal Year 2023Water Main Replacement on Botham Avenue
DRAWN BY: AKADATE: 5/3/2021
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City of St. JosephEngineering Department700 Broad StreetSt. Joseph, MI 49085
Telephone: 269-983-5541Email: [email protected] [email protected]
Figure 4 - Fiscal Year 2022Lead Service Line Replacements on Broad Street
DRAWN BY: AKADATE: 5/3/2021
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LSLR Priority 4 & 5
DSMI CatagoryAny Portion Contians Lead (96)
Contains Galvanized Previously Connected to Lead (35)
Contains Neither Lead, Nor Galvanized Previously Connected to Lead (578)
Unknown - Likely Contains Lead (2,365)
Unknown - Likely Does Not Contain Lead (26)
Unknown - Material(s) Unknown (853)
City of St. JosephEngineering Department700 Broad StreetSt. Joseph, MI 49085
Telephone: 269-983-5541Email: [email protected] [email protected]
Figure 5City Wide High Priority Lead Service Line Replacement Limits
Drawn By: AKA5/3/2021
Scale: 1" = 2,000'
Also Published as 5/3/2021 Water Distribution System Material Inventory
LSLR Priority 3
