Waltham I&I Overview

I/I OverviewInflow and infiltration (I/I) occurs when groundwater and storm water seep into sewer pipes.  This is problematic because the increased volume flowing through the sewer pipes causes an unnecessary strain on sewer treatment systems, and causes sewer system overflows that pollute public waters and pose a serious public health and safety concern. In fact, between 2008 and 2010, there were 13 reported sewer overflows in Waltham resulting in the discharge pollutants into the public water supply. I/I is traditionally a result of antiquated infrastructure and typically peaks after heavy rain events, snowmelt or when the groundwater table is at its highest. The two primary ways to mitigate I/I is to repair or replace infrastructure (such as sewer pipes, storm drains, etc.), or to limit the flow of sewer through the system.
The I/I problem in Waltham was so severe that the Massachusetts Department of Environmental Protection (DEP) required the city to enter into an Administrative Consent Order (ACO) to remedy the problem.  This ACO has been in place for a number of years, but was reissued in 2010 with the following requirements:The City of Waltham may add one gallon of flow to the system for every 4 gallons of I/I that are removed from the system;Additionally, 1200 gallons of flow may be added to the sewer bank every time a sump pump is diverted from the system;The allowable new flow shall be calculated as part of a “sewer bank” which shall serve as the tally of available flow available to new users system wide.
As part of the ACO, the city is required to submit semi-annual reports to DEP in January and July of each calendar year. These reports summarize the status of the city’s I/I mitigation efforts. 
Why are businesses complaining?DEP has given the city a lot of latitude to implement the requirements of the ACO and DEP does not dictate how the city implements the I/I removal requirements, despite what many have been lead to believe. For instance, DEP has not mandated that the city implement the 12-month vacant policy. Under this policy, the city requires 4 to 1 I/I removal for existing office buildings if the space has been vacant for 12 months or more. This has created an enormous burden for property owners attempted to attract new tenants to vacant space.
Another common concern among businesses is the lack of direction from the city on I/I mitigation projects. When applicants come before the city for permits, some simply looking to put new users in empty space, the city tells them to “find an I/I removal project” that meets the 4 to 1 removal requirement. The burden is on the business to identify the appropriate public works project to meet their flow requirements, and then to undertake construction on public infrastructure.  There have been incidents whereby the city has directed businesses to undertake construction on private property, as well. This process creates an enormous amount of uncertainty, cost and additional risk to businesses. 
Further, there has been an historic lack of communication from the city on I/I removal and the plan for a long term remedy.  Businesses have been asking “When will the problem be solved?” and there has been little to no response from city hall. In August 2014, the city is required to submit a 5-year report to DEP detailing the progress made to date and the continued mitigation plans for the coming 5 years.  These reports are public information, yet they are not available on the city’s website.  Further, the mayor’s office has not sought input from the business community on how the last five years of the ACO have impacted them, or solicited business input for ways in which to do this better over the coming five years.  Businesses feel as though these plans and policies are being developed in a city hall vacuum, with no regard for communication with the people who are paying for most of them: businesses.
The lack of predictability and uncertainty on this issue is creating a negative brand for economic development in Waltham, and causing companies, small and large, to seek a home in other communities or withhold further investment until the local market becomes more certain. 
Why Host a Citizens Input Hearing?The City Council’s Economic Development Committee is seeking ways to maximize economic opportunity in Waltham and remove obstacles that are preventing further investment in our city. Because this concern has been voiced by so many businesses in Waltham, the Economic Development Committee is hosting a Citizens Input Hearing to give businesses an opportunity to share their concerns, experiences and possibly, ideas for improvement. The Economic Development Committee is giving businesses a voice.