The members of the Hamilton County Water & Wastewater Treatment Authority (WWTA) Board of Commissioners submit this letter to clarify the function, legal obligations and responsibilities of the WWTA. We are writing to inform our ratepayers and other interested parties about who the WWTA is, how we operate and how we are working hard to consistently provide the best service possible that our customers deserve while staying in compliances with all required rules and regulations.
WWTA was formed by the Hamilton County Commission in 1993, as authorized by Tennessee law to provide sewer collection and treatment services for communities surrounding the city of Chattanooga. We are responsible for the operation of the public sewer systems of the unincorporated areas of Hamilton County, Tennessee and the surrounding municipalities of East Ridge, Lakesite, Lookout Mountain, Red Bank, Ridgeside, Signal Mountain, and Soddy Daisy. (The WWTA is not responsible for sewers in the city of Collegedale, the town of Walden or the city of Chattanooga.) The system WWTA operates serves more than 30,000 customers, operates more than 60 pump stations, 500 miles of sewer pipe, grinder systems, a septic tank effluent pump (STEP) system, a wastewater treatment plant, two decentralized wastewater drip irrigation systems and other infrastructure.
We are the governing Board of Commissioners, which is composed of five county appointees: an engineer, an attorney, an accountant, a developer/homebuilder, a property manager, and one appointee from each town or city that is a member of the WWTA. The Board is responsible for the maintenance and operation of the sewer, standards and specifications for the construction of sanitary sewers, establishes sewer use rules and regulations, rates, fees, and billing policies, and the WWTA budget. The county appointees on the WWTA Board receive no compensation for their service on the Board.
The WWTA does not receive any local tax dollars. We are funded entirely by rates and fees from our customers. These rates and fees are used to perform the challenging task of safely transporting millions of gallons of sewage for treatment. Until recently, Tennessee American Water (TAW) collected sanitary sewer fees from WWTA rate payers in conjunction with fees collected for water service. TAW recently stopped performing this service and turned this function over to WWTA. With little time to prepare, WWTA was required to transition into providing sewer billing service for customers served formerly by TAW. This transition caused some confusion for WWTA and its customers, but WWTA has worked hard to resolve the issues caused by the transition.
The process of transporting sewage through miles of WWTA collection system must be done in a manner as protective as possible of human health and in compliance with the requirements of the U.S. Environmental Protection Agency (the EPA) and the Tennessee Department of Environment and Conservation (TDEC). The primary requirement imposed by these environmental agencies is that WWTA convey the wastewater without allowing it to overflow. For a sewer system, the number and volume of overflows is the measure used by regulators to determine compliance with laws that exist to protect human health and the environment.
Each community sewer system the WWTA has acquired and is now responsible for is unique. Some of the systems are relatively new and require less maintenance. Others are old and provide many maintenance challenges and headaches. Likewise, some of the systems have sufficient capacity to carry waste, while others cannot carry additional wastewater without overflowing. The condition and capacity of the sewer infrastructure WWTA operates is in large part a function of the condition it was in when it was turned over to WWTA.
A number of factors affect the ability of a sewer system to function properly. Older systems leak and allow precipitation and ground water to enter the pipes, which can overwhelm the ability of the sewer pipes to convey wastewater and cause overflows. For many older systems, heavy rains and other precipitation routinely cause overflows. This is caused by precipitation flowing into older, leaky pipes in large volumes, which can overwhelm the capacity of the pipes and overflow from nearby manholes and breaks in the pipe. The water that leaks into pipes like this is called inflow and infiltration, “I & I.”
I & I comes from many sources, but one of the largest is believed to be from leaking pipes from residences and other buildings. Because they are on private property, these “private sewer laterals” are difficult for WWTA to fix. As a solution to this problem, WWTA implemented the Private Sewer Lateral Program (PSLP). Although there are monthly upfront costs to ratepayers, the overall reduction in I & I generated by the program has reduced the demand on the WWTA system and is saving money for the ratepayers.
In addition to overflows caused by I & I, blockages of the sewer pipes caused by the disposal of illicit substances – such as rags, diapers, and other materials that do not break down in wastewater – also cause overflows. The largest cause of clogged pipes is grease that is disposed of into the sewer system which clogs the pipes and must be removed by WWTA staff or contractors. To help minimize problems caused by grease, WWTA requires restaurants −− the greatest generators of grease −− to install grease interceptors to remove the grease from their wastewater. Grease interceptor requirements for restaurants help prevent all of our ratepayers from paying for problems caused by the relatively few major grease producers.
The WWTA operates the sewer system under a wastewater State Operating Permit (SOP) issued by TDEC. Violations of the permit can result in costly penalties and other enforcement consequences by TDEC and by EPA. To help prevent permit violations, the permit prohibits the addition of new sources of wastewater upstream of any point in the collection system that experiences more than five overflow events per year or that would otherwise overload any portion of the sewer system. Thus, in areas where overflow conditions exist, moratoriums that prohibit additional connections must be imposed to comply with the permit. Moratoriums are currently in place in East Ridge, Red Bank, Lookout Mountain and Signal Mountain. Until the moratoriums are lifted, development in these areas will continue to be restricted.
WWTA understands the hardships created by moratoriums and other impediments to the use of the sewer system and has undertaken several projects designed to alleviate capacity issues caused by old infrastructure and capacity restraints. In addition to long term initiatives like the Private Service Lateral Program, WWTA is also performing hydraulic assessments in East Ridge, Red Bank, Lookout Mountain, Signal Mountain, the rapidly growing area in Ooltewah, and throughout all of our collection system. The resulting data from the assessments will be used to establish priorities for rehabilitation projects to fix deficient sewer infrastructure, to increase capacity in the existing pipes by reducing I & I, and the future capacity needed in these areas.
The goal of our Board, overtime, is that these projects and future work will address current issues with overflows and capacity. The WWTA Board hopes the rate payers of WWTA know that the members of this board take their responsibility of compliance to protect human health and the environment sincerely, and we are aware that many times our decision will not be popular. In the meantime, the WWTA Board, staff, and management welcome the input of the rate payers the agency was created to serve.