NEO Sewer District calls
for Innerbelt stormwater plan

On February 9, 2004, The Northeast Ohio Regional Sewer District's executive director, Erwin Odeal, wrote a letter to Ohio Department of Transportation District 12 director, David Coyle calling for the Innerbelt project to address stormwater runoff. The Sewer District has been helpful in connecting land-use and transit issues to watershed maintenance. Following is the text of the letter.

February 9, 2004

Mr. David Coyle
District Deputy Director
Ohio Department of Transportation, District 12
5500 Transportation Boulevard
Cleveland, Ohio 44125

Dear Mr. Coyle:

A strong and varied transportation infrastructure has long been recognized as one of the strongest assets of the Greater Cleveland Area. We are excited to work with the Ohio Department of Transportation and area stakeholders to further improve the transportation system via improvements to the Cleveland Innerbelt and connecting projects.

We note that our water resources, particularly Cleveland's lakefront, are also increasingly being recognized as dominant assets of the region. Accordingly, large investments of public dollars are being made to protect and restore the area's water resources. For instance, NEORSD anticipates spending between $1.3 billion to $1.5 billion to control Combined Sewer Overflows (CSOs) in its service area. Additionally, the City of Cleveland is doing extensive renewal planning to capitalize on a cleaned-up waterfront. But CSOs are not the only problem.

Stormwater runoff, including highway runoff, is one of the significant lakefront pollution sources. If all major sources of pollution, including highway runoff, are not addressed in a comprehensive and coordinated fashion, large public investments for pollution control will not achieve the optimum result of a cleaner, more usable lakefront.

The Innerbelt project planning process represents a critical point in time for community representatives and public officials to affirm that projects involving public investments must address both existing and new sources of project-related pollution that affect Cleveland's lakefront and other valued regional water resources.

For the Innerbelt project, this would likely include addressing the problem of runoff from current pavement area and controlling stormwater pollution from the new elements of the Innerbelt project. As the Innerbelt project is in the early planning phases, we are aware that studies have not been conducted to determine the impacts of runoff from either the current or proposed highway infrastructure. As well, the cost of treating these sources of stormwater is not yet known. We understand that much of the work to balance cost and benefits of pollution control will be done in the forthcoming project phases of preliminary engineering and environmental assessment.

Given the potentially significant costs of pollution abatement we suggest that it is beneficial to discuss funding sources at the earliest possible juncture. Fortunately, the Transportation Equity Act for the 21st Century (TEA-21) provides for federal participation in the cost of environmental restoration and pollution abatement projects using Surface Transportation Funds (STP). The Federal Highway Administration's fact sheet on TEA-21 STP funds identifies that eligible activities specifically include "environmental restoration and pollution abatement projects, including retrofit or construction of stormwater treatment facilities (limited to 20% of the total cost of 3R-type transportation projects)."

As you are aware, because comprehensive stormwater management is a new and developing discipline in Ohio, regulatory requirements and programs are not fully developed. The result is a significant project management challenge for such a large project as reconstruction of the Cleveland Innerbelt. Further, regulatory requirements are not the only measure of prudent cost-effective decision-making for stormwater management, pollution abatement, and environmental restoration work. As a result, we feel there will be a continuing need to consult and dialogue with the community with respect to decisions regarding the appropriate level of environmental controls.

In an effort to build consensus around the issues of comprehensive stormwater management and pollution abatement, we suggest the following steps:

1) Assure that abatement of existing stormwater sources of pollution is well documented as an objective of the Innerbelt project. Include this objective in the project's official Purpose and Need Statement to the extent that doing so will help to maximize the eligibility of abatement and environmental restoration activities for cost sharing using STP funds or other state or federal funds and communicate this important need to stakeholders.

2) Assure that the environmental assessment phase of the project development is adequately scoped and funded to provide a database from which to make sound decisions regarding pollution abatement, to identify environmental restoration opportunities, and to provide for comprehensive management of stormwater runoff.

3) Collaborate with stakeholders to develop and evaluate a range of options for stormwater management and potential environmental restoration activities. Include options to control project related pollutants (from both existing and new sources) to levels which support identified or anticipated community uses of the lakefront, recognizing that these levels may not currently be defined as regulatory requirements.

4) Take reasonable steps to advocate and secure the eligibility of pollution abatement and environmental restoration activities to use STP funds and other potential state or federal funding opportunities. Communicate to the stakeholders roles they can play to support this process.

5) Identify opportunities for pollution abatement and environmental restoration activities that could be effectively coordinated with the Innerbelt project but which might not be eligible for state and federal funding support.

In crafting our suggestion we have tried to draw on the principles of strong public involvement, regional collaboration, and community consensus building. On this note, it is appropriate to recognize the outstanding efforts by your office throughout the Cleveland Innerbelt Study in the aforementioned areas. Your commitment to an inclusive process gives us assurance that you will continue to work with the community to address the issues that we have raised and to forge consensus as the project moves forward.

Additionally, as a partner in maintenance and enhancement of the region's infrastructure we are happy to meet with you to share our data on stormwater and to coordinate our pollution abatement projects with your plans for Innerbelt transportation improvements. We believe that close collaboration can be important in our joint efforts to help build a vibrant and attractive community.

Sincerely,

Erwin J. Odeal
Executive Director
Northeast Ohio Regional Sewer District

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