THE TRUTH
JUNE 15, 2011
We Present the Truth, But You Do Not Comprehend
By Dennis L. Pearson

(c) 2009 by Dennis  L. Pearson --- All Rights Reserved --- No part of this work may
be reproduced or transmitted in any form by any means, electronic or
mechanical, including photocopying and recording or by any information
storage or retrieval system, without permission from the author.


PART FOUR

PREFACE

The Municipal Wastewater Treatment Construction Grant Amendments Act of
1981 authorized the expenditure of as much as $2.6 billion a year in construction
grants to local government’s. The program’s intent from previous authorizations
had been changed to the satisfaction of President Reagan from that which
emphasized public programs for the sake of public works programs to that
which represented rededication to environmental goals. Of importance, one such
environmental goal was the targeting of areas with water quality problems. But
Congress, additionally concerned about the threat of runaway costs in the
sewage grant program, also mandated controls on spending effective the
beginning of the start of fiscal year 1985, or October 1, 1984. Under these
controls, the federal share of the cost of sewage treatment would drop from
seventy-five percent to fifty-five percent. Importantly, the new federal controls
stipulated that stricter engineering reviews or audits be required for large plants.

Then too, under new federal controls, the federal government would not pay for
spare treatment capacity for future population growth. In analysis, the change of
emphasis or intent was aimed to benefit states in the industrial Northeast as the
legislation eliminated anticipated population growth, a bargaining point on which
the Sun Belt has relied as a basis for grants to build sewage lines and waste
water treatment plants.

          ***                        ***                        ***

The United States Environmental Protection Agency (EPA), delegated by
Congress with the responsibility to administer the federal sewage treatment aid
program, informed Allentown public officials March 2, 1984 that it would
conditionally give the city 1 million dollars for planned odor control measures at
the city’s kline’s Island Wastewater Treatment Plant. The catch being that the city
had to obtain the approval of its final design and construction plans by both the
Pennsylvania Department of Environmental Resources (DER) and a technical
branch of the EPA prior to October 1, 1984 to guarantee the receipt of the entire
$1 million.

Of financial importance, if it would happen that DER and EPA approval of the
before mentioned City of Allentown final design and construction plans would be
delayed until after the October 1, 1984 deadline, a reduction in federal assistance
the city would actually be eligible to receive inorder to defray planning and
construction costs for the needed odor control project would be triggered by
law. This being the fixed reality of new federal controls on spending that
President Reagan signed into law December 29, 1981 as part of a $10.2 billion
package that continued federal sewage treatment aid to local governments
through fiscal year 1985 but at the same time marked a reduction in the federal
government’s role.

Prior to the announcement, Allentown officials were both worried and concerned
that the EPA would not honor the city’s latest request for funding. Historically, of
course, they should have been concerned. After all --- those who stand accused
in history of having a public record of misplanning, miscalculation and, are short-
sighted for political reasons habitually, should be brought into account for their
transgressions.

But importantly, the Municipal Treatment Construction Grant Amendments Act of
1981 also sought to encourage innovation in wastewater treatment design. This
policy demonstrated by the availability of federal grant awards for the
development of innovative technology.

Allentown, of course, wished to capitalize on this concept to receive funding they
otherwise might be ineligible to receive. The fixed reality was that the city
expended its own funds for the installation of odor control systems in 1982-1983.
Consequently, they allowed the Pennsylvania Department of Environmental
Resources to inspect the experimental odor control systems newly installed on
two of the wastewater treatment plant’s four existing Plastic Media Trickling
Filters. Following DER’s review, the City was advised that construction of similar
systems on the other two PMTF’s would be eligible for federal funding or cost
participation.

Just the same, after the EPA announcement, and the assurances by DER,
Allentown public officials still had cause to worry and express concern in regard
to their latest request for federal assistance. The truth being, much in-house
activity needed to be done inorder to complete work on final design and
construction plans before the October 1, 1984 deadline. Obviously, with the
projected cost of the city odor control initiative quoted as $1,333,320, the city
preferred to receive the highest possible federal assistance to defray costs.
Financially, the seventy-five percent federal share of fiscal 1984 or $1 million
dollars rounded off looked better then the fifty-five percent federal share of fiscal
1998 or $733,326.

          ***                        ***                        ***
Please note --- Daniel E. Koplish, Superintendent of Operations at the Kline’s
Island Wastewater Treatment Plant, in a report entitled “ Odor Control at Minimum
Cost Through Innovative Process for Plastic Media Trickling Filters “ and
presented October 2, 1984 to the 57th Annual WPCF Conference in New Orleans,
Louisiana suggested that prior to the 1978-79 City of Allentown Wastewater
Treatment Plant expansion project certain areas of the city received sewage
odors due to the following variables:

1.        The wastewater treatment plant’s urban location;
2.        The wastewater treatment plant’s overloaded facilities;
3.        A gravity collection system resulting in unusually long detention times of
incoming wastewater: (For example – travel time from certain major industrial
contributors being in excess of ten hours.)
4.        The local geography; and lastly
5.        Prevailing climatological conditions.


Statistically, the number of logged odor complaints from the neighborhoods
surrounding the plant in the years 1976, 1977, and 1978 was sixty-four, twenty-
four and seventeen respectively. In analysis, the apparent trend toward reduction
in citizen aesthetic complaints between the years 1976 and 1978 seems to be an
indication of one of two things. First --- the citizenry might have become tired of
making complaints that in their perception were not acted upon or corrected by
the city. And lastly --- the city might have been successful in minimizing or
controlling the instances of unpleasant off-site conditions.

Koplish claims in his report that in the years between 1976 and 1978 that the City
took the following stabilization actions to minimize and control the odor causing
variables:

1.        The city initiated rigorous in-plant housekeeping;
2.        The City initiated operational changes; and lastly;
3.        The City applied chemical oxidation at specific process locations. (For
example – hydrogen peroxide was applied at the inlet to the sludge thickening
tanks and liquid oxygen at the discharge of the main sewage pumps. And, Harry
Forker continuing his role as a good citizen wrote a stream of letters to chemical
companies and public officials inquiring as to the potential success of these
chemicals on these units and other units.)

But of great interest historically, the level of citizen complaints rose to one
hundred twenty one in 1979 and to one hundred eight five in 1980. This upward
trend in citizen aesthetic concern surely was an indication that there was a
serious problem associated with new facilities put in line in late 1978 at the Kline’
s Island Wastewater Treatment Plant.

Koplish in his 1984 presentation claims that the new facilities were providing
adequate treatment in regard to effluent discharges into the Lehigh River. But he
admits that apparent operational or design failures in certain newly constructed
facilities adversely affected the aesthetics of the surrounding areas to a greater
degree or range. For example, the range of affectation expanded from a radius of
approximately one-half mile, predominately in an eastern direction to an omni-
directional radius impact of approximately two miles.

          ***                        ***                        ***
In analysis, objectionable odors are not generated in properly designed and
operated plants with biological towers. Towers are simply biological reactors
with the bacteria supported on a fixed media or bed. Aerobic biological activity,
which is free of fungus, does not generate odors. The Plastic Media High-rate
Trickling Filters (PMTF’s) installed by Envirotech as part of the City of Allentown
1978-79 wastewater treatment plant expansion program would only operate
satisfactory if there was sufficient oxygen available for the biomass. The PMTF’s
were never designed to operate without problems in either anaerobic or septic
conditions. (Please note – the media comes in modules approximately one meter
long by one half a media high are stacked within towers in a building block
fashion.) But Allentown Mayor Joseph S. Daddona seemingly had ignored early
warnings of probable problems related with PMTF operation under certain
conditions when his administration gave Metcalf & Eddy the go ahead to seek
federal funding in 1976 for the 1978-79 construction project. Importantly, what
last minute (4/23/76) modifications the Daddona Administration made to the
original 1971 design upgrade did not help PMTP performance for these
modifications did not address the serious pre-treatment problems in Upper
Macungie.

Anaerobic conditions within a filter can develop if the wetting rate of the filter is
too low and some areas (media) are not getting sufficient moisture. Septic
conditions within a filter can develop when the influent sewage is not “fresh.”
That is, the influent sewage is without appreciable dissolved oxygen content.
This puts air thru the filter, which is beneficial in transferring oxygen to the
process; however, it also tends to strip the odors down from sewage thereby
causing odors in the surrounding communities.

In the case of Allentown’s regional system the influent that comes into the plant
primarily through a gravity flow system must travel a great distance (17 miles)
and contains high strength brewery and creamery wastes that enter the sewage
system many miles upstream from the treatment plant. (Please note --- taking well
over eight hours and sometimes as much as sixteen hours to reach the treatment
plant). If the waste arriving at the treatment plant is anaerobic or septic it has
insufficient dissolved oxygen to prevent anaerobic biological action. Then too,
the smell will be bad due to the possible presence of hydrogen sulfide,
mercaptions, aldyhydes and other gases and vapors. Possible odor control
activities might require prevention of odors in the sewer collection system. Then
too --- designs for odor control removal at the plant usually would incorporate
pre-aeration. Joseph G. Richard and Robert P. Kingsbury in a 1973 presentation
entitled “Design Considerations for Plastic Media Biological Towers” suggest
that on-site odor destruction may be easily accomplished by placing a cover
over a pre-aeration tank and purifying the tank’s exhaust units. Pre-chlorination
or similar chemical addition ahead of the tower according to Richard and
Kingsbury is totally unacceptable for odor control, since residuals may carry
over and kill the beneficial bacteria in the tower. Then too --- Richard and
Kingsbury urge caution that designers not use excessive detention time in
clarifiers at low inflows because septicity must be avoided. (Again note- this
being a case well documented in the experience of the Lehigh County Pre-
treatment Plant in Upper Macungie Township.) Consequently, within the plant,
the operator must take care to prevent septicity and odors in clarifiers by
continuous or frequent sludge withdrawal. Septic effluent from the primary
clarifier or recycled effluent from a post-tower clarifier can carry objectionable
odors that will be stripped to the atmosphere by the tower.

Importantly, it is the opinion of Richard and Kingsbury that objectionable odors
are not generated in a tower, which is properly designed and operated, provided
the waste, is properly conditioned for aerobic biological treatment. Therefore,
Richard and Kingsbury strongly object to tightly covering the towers either with
or without forced ventilation. Domes cause serious changes to the ventilation
patterns, particularly in large towers. Consequently, Richard and Kingsbury
firmly maintain:

“We know of no enclosed plastic media towers or rock ‘trickling filters’ where
ducting or baffling, even with forced ventilation, has been adequate to improve
performance over that of comparable tower with unrestricted neutral ventilation.”

The opinions of Richard and Kingsbury, indeed, had much influence on City of
Allentown decision-making in regard to providing or not providing “covers” for
the four PMTF’s.

          ***                        ***                        ***

For the historical record, the lowest cost design proposals put forth by Metcalf &
Eddy in 1971 did not make provision for immediate installation of “Covers.”

But Allentown City Councilman Benjamin F. Howells in a memo to Allentown City
Controller Louis J. Hershman, dated September 24, 1981, provides us with the
following insights in regard to City of Allentown decision-making concerning the
“Cover” issue and other wastewater treatment issues in general.

Howells writes:

“I wish Engineering were an exact Science; it is not!

The design proposals put forth in 1972, yielding a plant design accepted in 1975
made provision for retrofitting covers if the material the plant treated caused an
intolerable odor problem.

No one at the time would have been willing to stake their reputations on whether
a plant with known mechanical design would in an odor-free manner treat
influent of varying strength, temperature, loading, flow in an ambient with varying
humidity, temperature, wind velocity, and receiving olfactory senses of varying
efficiencies. There were just too many unknowns.

There were some design deficiencies that should have been anticipated and,
unfortunately, the design was approved with these built-in deficiencies.”

          ***                        ***                        ***

Please note --- the historic reality of Howells’ admission forcing us to ask the
following questions:

1.        Why did City officials fail to report the fixed reality of a built-in deficiency in
their wastewater treatment plant to the residents of the City of Allentown?
2.        How could Daddona tell the public in 1977 that once the new expansion to
the wastewater treatment plant was completed in 1978 that all odors could be
eliminated for good?

INSTALLMENT ONE

Indeed, all of us are aware this continuum of time is divided into three parts for us
mortal beings: the past, the present, and the future. We do not have control of the
past for we cannot change it unless by some miracle we become time travelers
and go back. However, we do have a measure of control over the present but just
for an instant for then it becomes the past and presents roadblocks for a
controllable future. From this we derive that the future is multi-directional and, it
is decisions in the momentary present state that decide the direction our future
course will go. This fact of life being the same for individuals as it is for
corporations and government bodies.

Historically, dare we point a finger at any one or two individuals for the persistent
problems related directly or indirectly to regional wastewater treatment
processing and regional economic development activities?

Yes, we can dare, and already we have pointed a ghostly finger when members
of the Lehigh Valley Council for Regional Livability, Inc. attempted to present a
sleeping bag to Allentown Mayor Joseph S. Daddona. Consequently, Daddona is
just one of many public officials scheduled to receive the visitation of the ghosts
of the time continuum --- that is, the ghosts of Kline’s Island past, the ghosts of
Kline’s Island present and the ghosts of the multi-directional Kline’s Island future.

Of course, already in this the ghosts of the time continuum have made their
presence known. Certainly we cannot relate that Joseph S. Daddona acted alone
in this drama of transformation. Then again, neither was he there at the
beginning. Yet interestingly, he emerged at a time the perceived regional desire
for economic development took a giant step toward the undefined future.

A future that George A. Stahl, one of the actors in our real-life drama, helped set
the stage but since has voiced reservations as evidenced by his bicentennial
inspired booklet Lehigh County --- Yesterday, Today and Tomorrow.

To sum it up, from 1968 to the mid 1990’s Joe Daddona had been the principal
political leader most involved in construction, design and funding of expansion
projects related to the Kline’s Island Wastewater Treatment Plant upgrading and
remedial work. Then too, we are certain that he did not disassociate himself from
past and more recent regional decision-making facilitating the needs of
Allentown’s suburban neighbors.

This point accidentally relearnt when this observer stumbled upon a breakfast
meeting in the now defunct Hamilton Plaza involving the Mayor, Community
Development Director Don Bernhard, City Financial Director Jim Flucke and
representatives of AT & T Communications.

          ***                        ***                        ***
Interestingly, Daddona in Allentown’s former Commission government sought
the Directorate of the Department of Streets and Public Improvements believing
that the department best matched his abilities and interest. Philosophically,
Daddona believed that his educational training as an electrical engineer and his
work background in design and planning aspects of engineering would aid him
in the broad understanding of all engineering fields. In other words, he could
relate to the specialized language of civil engineering or wastewater treatment as
well as he could relate to his own specialty --- electrical engineering.

Arriving when he did in government service, Daddona can be absolved of
decision-making relating related to basic design that influenced the final plans,
which upgraded the Kline’s Island Wastewater Treatment Plant from a 17 m.g.d to
a 28.5 m.g.d hydraulic rating.

Operationally, however, Daddona as Director of Streets and Public
Improvements was accorded the opportunity to implement policy that in the long-
run could have produced a more efficient operation of the Imhoff Tanks when
their status changed as a result of problems related to sludge build up on the
Imhoff Tanks. The incumbent City Engineer William A. Jacoby anticipated septic
problems related to sludge build up on the Imhoff Tanks. Consequently, as early
as January 24, 1968, Jacoby suggested to both Daddona and the Allentown
Authority that $85,000 be spent to remove the build up of sludge which had
occurred over a period of twenty years or more on the Imhoff Tanks. Jacoby
believed the expenditure would be of benefit for it would allow maintenance men
to keep a closer check on the tank. Allentown Authority Chairman, Clarence F.
Siegfried, apparently agreed for he suggested that sludge should be cleared
away from the tanks at regular intervals after each year or two of operation.

But the same absolution in regard to decision-making related to final design
cannot be said of Daddona’s involvement in the planning process toward
upgrading the plant to a paper 40 m.g.d. Hydraulic capacity.

          ***                        ***                        ***


In a move that signaled an irreversible commitment to urban development,
Daddona facilitated Arthur L. Wiesenberger’s client communities (that is --- the
Borough of Alburtis and Macungie and the Townships of Lower and Upper
Macungie) by reserving 4.5 m.g.d in the Allentown wastewater treatment plant.
Importantly, this promised allocation when combined with the demands of
existing users for additional capacity created the need to further expand the
Kline’s Island Plant.

(Please note – In 1969 it was anticipated that wastewater treatment capacity
would be expanded from the existing 28.5 m.g.d to that of 36.1 m.g.d.)

Thus, the design upgrade process for an expanded Kline’s Island facility began
as follows.

On December 16, 1969 the Allentown City Council gave the Allentown Authority
permission to employ Metcalf & Eddy, Boston as engineering consultant to
prepare a feasibility report, preliminary design and final design and all other
necessary engineering services pertinent to the expansion of the Allentown
Wastewater treatment plant and pertinent intercepting sewer lines for the
treatment of sewerage from the discharge area encompassed within December
22, 1969 agreement between the city of Allentown and the Lehigh County
Authority. Historically, Councilman Joseph S. Daddona, Ray Bracy, Sam
Fenstermacher and Bill Ritter voting to the affirmative and Councilman J.
Raymond Cramsey casting the sole negative vote.

It should be understood that Metcalf & Eddy, Allentown’s long standing
engineering consultant since the late nineteen twenties, had participated in the
Kline’s Island expansion project which raised its processing capacity from 17
million gallons a day to 28.5 m.g.d.

Interestingly, Cramsey’s negative vote represented a desire to replace Metcalf &
Eddy with a local engineering consultant, namely the engineering firm of Arthur
L. Wiesenberger Associates. This also is said to be the position of Councilman
Daddona in private and in committee. But politically, Daddona and other
councilmen heeded the advice of the Allentown Authority against presenting the
contract to Arthur L. Wiesenberger Associates due to the real potential of conflict
of interest resulting from the Allentown engineering firm’s status as engineer for
the Lehigh County Authority’s sewer program.

Whatismore, one of the Allentown Authority’s strongest arguments to keep the
same engineer was cost. The fact being that Metcalf & Eddy had already
performed the preliminary engineering and cost study for the new projects that
the City Council resolution encompassed. In fact, City Councilman and Director
of Streets and Public Improvements Joseph S. Daddona had already received
the “Feasibility Report to the City of Allentown, Pennsylvania on Additional
Waste Treatment Facilities at Kline’s Island” of December 8, 1969, which the
resolution approved after the fact. The Authority maintained that some of these
costs would be recoverable as part of Metcalf & Eddy’s full engineering bill. A
new engineer could have entered into duplicate work to some degree.

With the decision, Clifford “Chips” Bartholomew, the first mayor elected under
the new Allentown Strong Mayor Charter, was legally bound to honor this
commitment made by a lame duck government. One might say with a touch of
irony that Joe Daddona got his revenge upon his successful opponent for Joe
challenged Bartholomew in the mayoralty election of 1969. The was set for the
Bartholomew – Daddona contest when Joe Daddona bested incumbent Mayor
Ray Bracy in the spring Democratic primary of 1969.

          ***                        ***                        ***

Allentown’s new Strong Mayor Government established itself January 4, 1970.
With the new government, the Department of Streets and Public Improvements
was reorganized and renamed the Department of Operations. “Chips”
Bartholomew, a long-time Allentown High School Principal, as politically would
be expected, replaced Joe Daddona as Operations Department head in naming
George B. Kandra the first non-elected professional to head the department.
Importantly, the Bartholomew Administration had inherited from Daddona (or in
technicality the Bracy Administration) the task of planning for the expansion of
Kline’s Island Wastewater Treatment Facility to 36.1 million gallons a day.

In meeting its responsibility, the economic minded Bartholomew Administration
contacted in 1970 with Metcalf & Eddy to prepare a design report for a 7.6 m.g.d
expansion to the existing plant. The design report entitled “ Report to Allentown
Authority, Allentown, Pennsylvania On the Design for Increased Capacity and
Tertiary Treatment at the Allentown Wastewater Treatment Plant” was submitted
to the city November 15, 1971.

However, in March of 1972, George A. Kandra, in response to suburban requests
for additional capacity, set the size of expansion at 11.5 m.g.d instead of 7.6 m.g.
d, raising the total expected capacity to 40 m.g.d. Inevitably, this upgrade in
capacity forced modifications in plant design plans; consequently, historically,
Metcalf & Eddy, the project engineer, released its new plans entitled “1974
Addition and Alternatives to the Wastewater Treatment Plant,” February 24, 1973.
Four days later, February 27, 1973, the City of Allentown submitted to the
Commonwealth of Pennsylvania Department of Environmental Resources (DER)
a construction grant application for upgrading of Allentown’s wastewater
treatment facilities.

With this submittal, it would be left to the movement of the time continuum to
judge whether the Allentown project was a “fine example of keeping costs down
and using what you have” or “a penny pinching lemon.”

The plant upgrade (intended to serve a 1995 estimated population of 339,000)
called for an average daily dry weather flow of 40 m.g.d, and capable of treating a
peak flow as high as 72 m.g.d though not continuously for an extended period of
time.

          ***                        ***                        ***

Interestingly, the Bartholomew Administration was not able to commence
construction activities for an expanded wastewater treatment plant for two
reasons. First, state processing of Allentown’s construction grant application
was set back by the impoundment of federal wastewater treatment construction
grant expenditures by the Nixon Administration; and secondly, the outgoing
Bartholomew Administration turned over reigns of government to Democrat
Joseph S. Daddona in 1974. Daddona, as Mayor, subsequently appointed Harry
Bisco to succeed George A, Kandra as Director of Operations. As events panned
out, the Daddona Administration had to wait until December 3, 1974 before the
Pennsylvania Department of Environmental Affairs gave notice that federal grant
monies were again available. But as it played out, the Allentown project was not
funded in fiscal year 1975 due to a low state priority ranking.

          ***                        ***                        ***
We note – that in making its final decisions concerning plant upgrade, the
Daddona Administration was given three options from Metcalf & Eddy, Boston,
Consulting Engineers for the City of Allentown.

Option Number One, the selected alternative employing PMTF’s and the existing
rock media trickling filters was estimated to cost approximately $12 million
dollars.

Option Number Two, a similar alternative that utilized the existing rock media
trickling filter was estimated to cost approximately $17 million.

And finally, Option number Three, the alternative that eliminated the rock media
trickling filter and employed a two stage activated sludge process was estimated
to cost $28 million dollars,

In actuality, these were the very same options or concept models that the
Bartholomew Administration had at its disposal. And in fact, the Bartholomew
Administration selected the very same option as selected by the Daddona
Administration. But from our vantage point in the future we have every reason to
believe that the Daddona Administration erred when it ratified the Bartholomew
selection. The reason was at that early date the Bartholomew Administration had
no hard evidence that anaerobic conditions would occur in the system.
(However, the Bartholomew Administration could not discount completely that
anaerobic conditions would not have occurred in the system. This would be
especially true if preventive maintenance was not performed on the Imhoff
Tanks. The Imhoff tanks in 1970-1977 being referred to as the Primary Settling
Tank and thereafter as the Intermediate Settling Tanks with the completion of the
1978-1979 construction activities.) The probability becoming more certain when
the failure to resolve problems relating to odor emitting from the Wiesenberger
designed pre-treatment plant in Upper Macungie forced the abandonment of the
plant and caused direct injection of creamery and brewery waste into the
seventeen mile Lehigh County Authority-Allentown interceptor lines. Therefore,
with such waste coming down the line, the responsible officials should have
reviewed and updated final design plans according to the new conditions.

Ironically, if President Nixon hadn’t once “impounded” or refused to spend for
one year funds in the sewage treatment grant program, a move that many
members of Congress said was illegal, the Daddona Administration might have
never been in a position to formulate final plans for the expansion of the facilities
at Kline’s Island. Surely, the Bartholomew Administration would have been in a
position to formulate final plans and award construction contracts. However, as
events would play out, Daddona would still have some influence over a
Bartholomew government. Given his status as a hold over City Councilman from
the Old Commission government, Daddona was on board to preview and render
judgment upon all final plans and construction awards that required Council’s
approval. But in analysis, it is historically clear that once the Daddona
Administration assumed power in 1974, it failed to exercise a proper review of the
many evolving scenarios. Consequently, it should be held responsible for its
failures in decision-making in the momentary present state that affected the multi-
directional future.

A December 1981 James M. Montgomery Consulting Engineering Feasibility
Study of the Kline’s Island Treatment Facility conducted for Lehigh County
sheds some light concerning the failure of the city to answer the processing
needs of untreated brewery and creamery wastes. According to James M.
Montgomery, Metcalf & Eddy throughout each design stage of the Kline’s Island
Plant had assumed that a pre-treatment facility would be functional (that is –
would be on line) and thus, would be fulfilling the requirements of the December
22, 1969 Allentown-LCA Sewage Contract.

          ***                        ***                        ***

We note – a research paper by Margurite Beardsley entitled “Decision-Making in
an Environment of Conflict: The Case of Allentown, Pennsylvania” provides us
with interesting and important commentary in regard to Allentown’s reliance on
Metcalf & Eddy expertise during the initial design phase of Kline’s Island
proposed expansion. Ms. Beardsley’s research paper was part of a March 1978
report to the United States Environmental Protection Agency entitled “
Introducing New Technology to Municipal Wastewater Treatment: A Decision-
Making Study” and conducted by the Syracuse Research Corporation.

Ms. Beardsley writes:

“The two major technological alternatives considered for the Allentown project
were trickling filters modified through the use of plastic media, and an activated
sludge process which utilized high purity oxygenation. The consultants chose
modification of the trickling filters, but oxygenation was strongly advocated by a
local manufacturer.”

The local manufacturer, of course, was the Trexlertown based Air Products &
Chemicals, Inc., an international corporation specializing in the generation of
gases for industrial use. Air Products being the major competitor of Union
Carbide in the design and sale of wastewater treatment processes that utilize
oxygenation.

Ms. Beardsley continues:

“…Near the beginning of design phase (25% along) of the Allentown project, Air
Products approached Metcalf & Eddy with the proposal that oxygenation be
adopted for the design. The company contended that its process would require
less space, cost the same or less, meet effluent standards more effectively, and
control odor problems better than the trickling filter modifications favored by the
consultants.”

But Metcalf & Eddy did not concur with the Air Products analysis. Consequently,
Ms. Beardsley writes that Metcalf & Eddy based its choice on modification of the
existing trickling filters on the following conclusions:

1.        Efficient use of existing facilities was appropriate;
2.        Oxygenation was more expensive (A Metcalf & Eddy report concluded that
oxygenation would cost $3 million more then the anticipated $10 to $12 million
cost of trickling filter modification.)
3.        Proper operation of the trickling filter process would eliminate any odor
problem.

Additionally, Ms. Beardsley relates that John Najarian, Project Manager of Metcalf
& Eddy, criticized the Air Products design as not having had sufficient backup
capability. The Project Manager did not believe that the proposed Air Products
design would have met EPA standards for “Standby” capability. And more to the
financial point, Najarian believed that Air Products’ estimates of the cost of some
features of construction were unrealistically low.

Ms. Beardsley presents the following Air Products response to Metcalf & Eddy
criticisms:


“Ray Langslett, Air Products Sales Manager, suggests that Metcalf & Eddy may
have been psychologically unable to recommend another alternative to
modification of the trickling filters because the last expansion of the filers
designed by the firm had been so recently completed. Langslett believes that the
city should have realized that Air Products would have offered a very competitive
bid on the project to prevent competitors from getting a major contract in Air
Products” ‘backyard.’ In the view of Air Products representatives, Allentown
would have greatly benefited from the natural desire of Air Products to provide
an exemplary showcase of its oxygenation process in its hometown. Langslett
also contends that consulting firms in general are guilty of ‘over-designing’
systems based in part on EPA regulations and historically based operator
maintenance records; and that, Air Products design reflected a reduction of
engineering redundancy rather than an unrealistic assessment of costs.”

In the end, the Bartholomew Administration decided to accept the
recommendation of Metcalf and Eddy. In analysis, Beardsley writes:


“…Aside from the predisposition to follow the advice of consultants who have
been hired to provide advice, it was suggested that economic considerations
prevailed. There is little question that if an entirely new plant had been under
design, oxygenation would have been the preferred technological choice.
Metcalf & Eddy had expertise with designing pure oxygen activated sludge
plants for three other cities. However, under the circumstances of previous
investment in trickling filters and the suspicion that two separate types of
treatment processes in the same facility would prove difficult to manage, city
officials believed that trickling filter modification constituted the most rational
technological choice. Another important factor emphasized by respondents
concern that the operating costs of an oxygen activated sludge facility would be
substantially higher than those of a trickling filter process and that the operating
cost of oxygen activated sludge might be more susceptible to rapid and
unforeseen increases…”

          ***                        ***                        ***

There was indeed opportunity in 1974 for the new Daddona Administration to
have its consulting engineer Metcalf & Eddy reassess its proposed design plans
for the Kline’s Island expansion project. The regular meeting of a City Council
Operations Committee held February 27, 1974 to provide an update on
wastewater treatment design provided the first opportunity; and a
communication from the Pennsylvania Department of Environmental Resources
conceivably could have provided a convenient follow-up.

Clearly, there was concern on Council that the Metcalf & Eddy proposal should
be reassessed. Therefore, Air Products was requested by an unnamed city
official to intervene into the design and technology issue. At the before said
February 27, 1974 meeting, Air Products was in fact represented by two
engineers – John Petering and Roy Langslett.  Both men asked Metcalf & Eddy
why they did not recommend the oxygenation process in Allentown when they
were involved in the design of an oxygenation system in New Rochelle, New
York. In reply, representatives of Metcalf & Eddy said the question was
considered two years previously and the decision was made to have the filters.
John Najarian, Project Manager for Metcalf & Eddy, said the cost of the
expansion would be an additional $2 million for the “pure oxygen system’
without significantly increasing the quality of the treatment. And, added rather
bravely: “We don’t feel there will be an odor.”

We note- the plans submitted to the state called for an estimated cost of $17.6
million to expand the plant from its then existing capacity of 28.5 m.g.d to 40 m.g.
d. The expansion would incorporate the filters in the secondary stage of
treatment.

Council members who advocated oxygenation concentrated their arguments on
the benefits of the process in controlling odors. Councilman Dennis Cramsey
remarked: “It’s time we stop looking at pinching pennies if we are going to solve
the problem for years to come.”

But importantly, it was the monetary issue and time considerations that
ultimately prevailed. John Najarian testified before Council that it would take
about a year to redesign the system and plan for oxygenation. Then too, the
engineer added that the state had ordered the City to have the expanded plant in
operation by June 1976 and the timing had already been delayed six months
because federal funds had not been allocated to the project.

The above being a veiled reference to the nationwide impoundment of water and
sewer construction funds by the Nixon Administration, which prompted
Allentown Mayor Joseph S. Daddona to express a wish that the funds be
released so that Allentown would receive an expected $13.1 million to cover
seventy-five percent of the proposed Allentown project.

The Mayor maintained that it was too late to change the course of then current
planning that was still in design phase. Furthermore, he asserted: “The whole
thing was studied by the previous administration and council and that the
decision was to go ahead with the plans.” The Mayor explained that no one was
questioning that oxygenation was not a more advanced technology, but he
questioned whether the advanced technology made it worthwhile to scrap
previous planning and start over with the risk that expected federal funds would
be lost.

Of course, little did Daddona realize that with having made this decision,
historically the weight of the consequence of this shortsighted decision fell upon
Daddona? Daddona for just an instant, in the present, had the power to produce
a better future for Allentown, Lehigh County and the region. But in that instant, or
momentary present, it happened that Daddona blew his historical chance to be
considered a truly great leader in Allentown history. The resulting unfortunate
historical impact handed down to us was that the good people of Allentown, in
the mid-nineteen eighties and later, had to contend with the continuing economic
and environmental consequences of past Daddona decision-making.

But importantly in that momentary present, we must also grimly infer from Dennis
Cramsey’s above stated comments that Council as well should be considered
shortsighted in the long-range. After all, as it happened members of Council, in
the end disciplined themselves to the position of the Mayor and the City’s
consulting engineering firm, Metcalf & Eddy. Effectively, Council, as well, became
more concerned about someone else providing funding to the maximum extent
allowed by then existing law they were about the ultimate utility, effectiveness
and quality control og the before said project in question. Unfortunately, as it
would transpire, John Najarian explained to Allentown City Council members
February 27, 1974 that for the city to qualify for federal funds, the project had to
be the least costly to build and operate. Najarian assured Council that the
existing proposal would meet the “cost effective” analysis required by the U.S.
Environmental Protection Agency. And importantly, Council did not have the will
to allocate additional local monies to upgrade and supplement the project.

          ***                        ***                                ***

Historically, of course, we must question whether there existed February 27,
1974 a clear and present danger that Allentown would lose federal funding if its
design process was delayed as a result of re-evaluation of technology. The fact
is, following the enactment of P.L. 92-500 and the formation of the United States
Environmental Protection Agency (EPA), new regulations went into effect that
would impact the Allentown project. By such regulations, the EPA determined
that an environmental assessment of Allentown’s proposed project had to be
completed before any grant or stipend could be awarded.

We note – the fixed reality of an environmental assessment would effectively
cause delay in release of federal monies even if the before mentioned Nixon
Administration impoundment of water and sewer funds ended suddenly.
Therefore, Allentown, in fact, had the time to review its existent design for
wastewater treatment expansion after the February 27, 1974 meeting. Historically,
Marshall Cashman, Chief, Program Services Section, Bureau of Water Quality
Management, Pennsylvania Department of Environmental Resources in a letter
dated February 28, 1974 informed Clarence E. Siegfried, Chairman, Allentown
Authority that Allentown’s February 27, 1973 grant application would be deferred
pending receipt of data in accordance with then existing Environmental
Protection Agency rules and regulations. The requirements were published in
the FEDERAL REGISTER (40 CFR 35.927) on February 11, 1974.

Section 35.927 stipulated: “All applicants for grant assistance after July 1, 1973,
must demonstrate to the satisfaction of the Regional Administrator that each
sewer system discharging into the treatment works project for a which a grant
application is made is not or will not be subject to excessive infiltration inflow.”

Then too, Allentown had to provide the DER data pertaining to industrial Cost
Recovery requirements, which also had to be determined in accordance with,
then existing Environmental Protection Agency rules and regulations.

Setting a November 1, 1974 deadline, Allentown obtained the required data from
tributary municipalities and was able to complete its environmental assessment
to facilitate DER processing. As it played out, the processed application was
submitted to the EPA March 21, 1975.

Invariably the report became the basis for discussion during the course of an
Environmental Assessment meeting held in the Philadelphia offices of EPA
Region III, December 19, 1975. In attendance were Harry Bisco, members of his
staff, a representative of the Lehigh County Authority, the Pennsylvania
Department of Environmental Resources and the EPA. The outcome of the
meeting was a January 6, 1976 order from the EPA to the City of Allentown that it
cover two proposed 40-foot wide receptacles used to thicken the sludge in the
early stages of treatment by May 1, 1976 and also, the idea that the Upper
Macungie Pre-treatment plant be converted to a chemical feed station to control
brewery and waste odors with additional chemical feed stations being added
along the Little Lehigh Interceptor that links the Upper Macungie Plant to Kline’s
Island.

Indeed we think it probable that Metcalf & Eddy in the “Third Addendum to the
Agreement” dated April 23, 1976 made last minute modifications to the 1971/73
designs to satisfy the January 6, 1976 EPA order. This action taken after the EPA
February 27, 1976 agreed to fund seventy-five percent of total costs for the Kline’
s Island expansion project. But in this regard we are a bit puzzled for the EPA
order was not truly satisfied until an aluminum and plastic overlay was
constructed over the thickening tanks in the early 1980’s.

Please note – in the atmosphere of a thirty-minute exposure of hydrogen sulfide
gas at 0.1 concentrations by volume can prove fatal. In small concentrations it
can cause nausea. But be it noted that in very small concentration, offensive
odor from Hydrogen Sulfide presence can be detected. Therefore, the EPA order
was both an attempt to eliminate the offensive odor and a precaution to protect
the neighboring communities from the potential side effects of hydrogen sulfide
built-up. The covers over the thickening tanks theoretically prevented the escape
of hydrogen sulfide into the atmosphere. Of course, with the covers hydrogen
sulfide could still build-up within the covers to dangerous levels if no additional
action was taken. Consequently, there was also a need to protect employees
whom had occasion to enter the covered thickening tanks from the effects of
hydrogen sulfide. Thus, to prevent the build-up of hydrogen sulfide within the
covers it was necessary for the city to install exhaust fans and remove the odor
through charcoal filters.

Unfortunately, the final design plans for the 1978-79 construction project proved
inadequate to prevent the enhanced development of malodorous conditions in
and around the Kline’s Island Wastewater Treatment Plant. This could only mean
that the Daddona Administration failed to make adequate revisions in design
subsequent to the December 19, 1975 EPA re-assessment hearing; and also, it
failed to make changes that answered the processing needs of untreated
brewery and creamery wastes.

Simply put, the Daddona Administration chose the lowest cost alternative; and
also, the one option alternative that would least meet the needs of a regional
wastewater treatment plant conducted in the midst of a populated area. This is
another case of the axiom one gets what one pays for. If one wants a quality and
sufficient product, it can be had for a good price. But if one seeks a product with
not as much sufficiency then it can normally be had at a cheaper price. But since
this product may wear out quicker and not meet area growth needs, it might have
to be replaced at an additional cost. Therefore, that would make the quality and
sufficient product a better buy.

To summarize, design plans originally devised in 1971 recommended that a new
aerated grit chamber and four primary settling tanks be installed in the area
south of the then existing trickling filters. A major portion of the BOD would be
removed in the primary settling tanks and the first stage filters. With the
decreased BOD loading going to the then existing trickling filters, Nitrification
would take place within the second stage filter.




TABLE VI--- Basic Design Data Kline's Island Plant 1978-79 Expansion
______________________________________________________________

                  
                                          Initial                Design        
WASTEWATER PROCESSING
1.        Wastewater Characteristic
o        Sewered population                159,000                181,000
Design Year                                                  1995
o         Sewage Flow
Average, gcd                    170                    220
Average Daily, mgd             27.0                   40.0
Maximum hourly, mgd             52.0                     70.5
Return from sludge
Processing, Mgd              1.5               1.5
o        Sewage Characteristics
Influent
Settable Solids, ml/L             19.0                        7.4
Suspended Solids, mg/L            215.0                     230.0

                                          Initial                Design        
WASTEWATER PROCESSING
1.        Wastewater Characteristic
o        Sewage Characteristics
Influent
Suspended Solids
1b/capital day              0.29              0.42
Suspended Solids
1b/day                 46,800            76,500
BOD, mg/L                   269               210
BOD, 1b/capital/day           0.26              0.42
BOD, lb/day              41,800            70,000
Ammonia nitrogen, mg/L       30                30
Effluent
Settlement Solids, mg/L       0.3               0.1
Suspended solids, mg/L       30                30
BOD, mg/L                    20                20
Ammonia Nitrogen, mg/L      3/9*               3/9*
(* - Higher limit in effect November 1 through May 31)
2.        Pre-treatment Works
o        Mechanically-Cleaned Screens
Number                                          2
Clear bar spacing, in.                     3/4, 1-1/2
o        Sewage Pumps
Main Pumping Station
Pumps 1 & 4
Capacity, each, gpm          9,200             9,200
Pumps 2 & 3
Capacity, each, gpm    12,100            12,100
Auxiliary Pumping Station
Pumps 5 & 6
Capacity, each, gpm    16,600            16,600
o        Plant Flow Measurement
Venturi meter
Size, in.                                         34
Range of accuracy, mgd                                7.2 to 72
o        Aerated Grit Chambers
Number                                                                2
Length, ft                                                   52
Width, ft                                                       28
Depth, ft                                                        12
Detention time of
Peak flow, min                4                 3
Air supply, cfm/ft.                         1.5 to 4.5
Blowers
Number                                          2
Unit capacity range, cfm                       160 to 480
Method of grit removal                clamshell buckets
o        Comminutors
•        Number                                                        4
•        Type                                  full rotational
•        Capacity, each, mgd                            24
•        Screen opening, in.                                    3/8

  

                                          Initial                Design        
WASTEWATER PROCESSING
3.        Secondary Treatment
o        Primary Settling Tanks
o        Number                                                        4
o        Diameter, ft                                            120
o        Sidewater depth, ft                                     12
o        Total Volume, mil. Gal                                      4,06
o        Surface loading rate Gpd/sq. ft.
Average flow                    596                    884
Peak flow             1,150             1,558
•        Detention time, hrs.
Average flow              3.6               2.4
Peak flow                 1.9               1.4
o        Primary Effluent Pumps
(In intermediate Pump Station)
•        Pumps 7, 9, 11                                variable speed
Capacity, each, gpm                               15,000
•        Pumps 8, 10                         constant speed
Capacity, each, gpm                    10,000
o        Plastic Media Trickling Filters
o        Number                                                        4
o        Diameter, ft                                            100
o        Depth, ft                                                 32
o        Total Volume, Cu. Ft.                            1,000,000
o        Organic loading
Ave. Daily 1bs
BOD/1,000 Cu. Ft          28.8              48.3
o        Hydraulic Loading
Gpm/sq. ft                        
Minimum (Inc.
Recirculation                0.57                      0.57
Maximum flow              1.14              1.59
•        Recirculation              To minimum flow of 26 mgd
o        Plastic media effluent pumps
(In intermediate Pump Station)
•        Pumps 12, 14, 16                                variable speed
Capacity, each, gpm                               15,000
•        Pumps 13, 15                        constant speed
Capacity, each, gpm                    10,000     
o        Intermediate Settling Tanks
o        Number                                                        6
o        Length, ft                                                   71
o        Width, ft                                                       65
o        Depth, ft   (average)                                     26
o        Total Surface area, sq. ft                 27,000
o        Surface Overflow rate
Gal./sq. ft/day
At average flow        978              1,449
At peak flow         1,884                2,554



                                          Initial                Design        
WASTEWATER PROCESSING
3. Secondary Treatment
o        Intermediate Settling Tanks
o        Total Volume, Approx. Gal                    5,400,000
o        Detention time, hrs.
Average flow              4.8               3.2
Peak flow                 2.5               7.8
4.        Nitrification
o        Rock Media Trickling Filter
•        Number                                                        4
•        Total Acreage                                                5.32
•        Depth of Stone, ft                                     10
•        Total volume, acre-ft                                     53.2
•        Number of dosing siphons                                8
•        Loadings
1b/1000 cu.ft/day
               BOD5                                2.7               4.3
                   NH3-N                                2.9                         4.3
o        Final Settling Tank
•        Number                                                         8
•        Diameter, ft         
        Tanks 1 to 4                                        70
        Tanks 5 to 6                                     100
        Tanks 7 to 8                                     110
•        Sidewater depth, ft.
        Tanks 1 to 4                                         8.5
        Tanks 5 to 8                                         8.5
•        Total surface area, sq. ft.                      65,800
•        Surface Overflow rate,
Gpd/sq.ft
        Average flow         400                     600
        Peak flow            800               1,000
•        Total Volume, gal                        3,450,000
•        Total Volume, Approx. Gal                     5,400,000
•        Detention period, hrs
        Average flow           3.1                 2.1
        Peak flow              1.6                 1.2
5. Disinfection
o        Chlorine Contact Tank
•        Number                                                        1
•        Length, ft                                                  135
•        Width, ft                                                       82.5
•        Depth, ft                                               9.2
•        Total volume, cu. Ft.                            103,000
•        Detention at Peak flow
Minutes                            21                     15
o        Chlorination Equipment
•        Number of chlorinators                                        2
•        Number of Evaporators                                        2


                                          Initial                Design        
WASTEWATER PROCESSING
5. Disinfection
o        Chlorination Equipment
•        Total Chlorination,
1b/day                                                 10,000
(With one unit out of service)
        Average flow                22                     15
        Peak flow                        12                      8.5


SLUDGE PROCESSING
1.        Sludge Pumping/ Transfer
o        Primary Sludge Pumps
•        Number                                                        6
•        Type                                        Positive-displacement
•        Number of grinders                                        6
(One per pump)
•        Pump rating                                  150 gpm @ 100 psi
•        Speed                                          infinitely variable
•        Discharges to                              Digesters
o        Intermediate Sludge Transfer
•        Method                                   Riser Draw off
•        Number of Draw offs                                        12
(Two per tank)
•        Operation                                  Automatic timer
•        Capacity                                  As required
•        Discharges to                          Gravity Thickeners*

(* - Valving at valve box # 1 provides the capability of returning Intermediate and
Final Sludge to Plant Influent for capture in Primary Settling Tanks)

o        Final Sludge Pumping
•        Pump Station # 1 (Serving FST’s 1 through 4
        Number of Pumps                                        4
        Type                                        Vertical Nonclog
        Pump Rating                                100 gpm @ 18 ft.
        Operation                                Automatic Timer
        Discharges to                                Valve box # 1
    (And thence to gravity thickeners)
•        Pump Station # 2 (Serving FST’s 5 through 6)
        Number of Pumps                                        3
(One Standby)
        Type                                        Vertical Nonclog
        Pump Rating                                100 gpm @ 18 ft.
        Operation                                Automatic Timer
        Discharges to                                Valve box # 1
    (And thence to gravity thickeners)


                                          Initial                Design        
SLUDGE PROCESSING
1.        Sludge Pumping/ Transfer
o        Final Sludge Pumping
•        Pump Station # 3 (Serving FST’s 7 trough 8)
        Number of Pumps                                        3
(One Standby)
        Type                                        Vertical Nonclog
        Pump Rating                                100 gpm @ 18 ft.
        Operation                                Automatic Timer
        Discharges to                                Valve box # 1
    (And thence to gravity thickeners
2.        Sludge Thickening
o        Gravity Thickeners
•        Number of tanks                                                2
•        Feed Sludge
        Type                                Final and Intermediate
        Mature                                Humus
        Feed Concentration                                        1.0
        Thickened concentration, %                                5.5
•        Diameter                                                   40
•        Sidewater depth, ft                                     12
•        Total Area sq. ft.                                 2,500
•        Surface loading
Rate, gpd/sq. ft                380                            600        
•        Solids loading
Rate, 1b/sq. ft/day          4.7                                7.5
3.        Sludge Digestion
o        Primary Digester
•        Number                                                        2
•        Diameter, ft.                                             80
•        Sidewater depth, ft.                                     30
•        Mixing System                                Gas recirculation
•        Cover Type                                        Floating
•         Usable Volume, Cu. Ft.                                300,000
•        Digester loading, 1b day
        Average day           38,000                         56,400
        Max. Week           84,000                        124,000
        Max. Month           46,000                67,500
•        Feed concentration, %          5.8                                5.8
•        Digester loadings,
Cu. Ft./day
        Average day           10,500                         15,000
        Max. Week           23,200                         34,300
        Max. Month           12,700                         18,700
•        Detention, days
        Average Day                 28.6                             19.2
        Max. Month                 23.6                             16.0
•        Volatile %                         75.0                             75.0        
•        Volatile Solids
        Average                        0.095                        0.141
        Max. Month                  0.115                      0.169
Initial                Design        
SLUDGE PROCESSING
3. Sludge Digestion
o        Primary Digester
•        Volatile Solids
Destruction percent                    50                    50
•        Sludge disposition                Transfer to Secondary
Digester (Gravity
o        Secondary Digester
•        Number                                                         1
•        Diameter, ft.                                             80
•        Sidewater depth, ft.                                     27
•        Mixing System                                Gas recirculation
•        Cover Type                                        Gasholder
•        Usable Volume, Cu. Ft.                                136,000
•        Feed concentration %                                        5.0
•        Digester loading, 1b day
        Average                      23,800                         35,200
        Max. Month             28,800              42,200
•        Digester loadings,
Cu. Ft./day
        Average                       7,600                         11,300
        Max. Month              9,200                         13,500
•        Detention, days
        Average Day                   17.8                     12.0
        Max. Month                   14.8                     10.1
4.        Sludge Conditioning
o        Elutriation Tank
•        Number                                                         2
•        Diameter, ft.                                             40
•        Sidewater depth, ft.                                     12
•        Total Area, sq. ft.                                  2,500
•        Total Volume, gal                                        240,000
•        Available Washwater, gpm                            400
•        Washwater ratio                 10.1:1                  6.8:1
•        Surface loading,
1b/sq/ft/hr                          0.40                        0.59
•        Surface overflow rate
Gpd/sq/ft                        250                            265
(Including Washwater)
o        Lime
•        Type                                                         Bagged
•        Storage                                                Pallette
•        Preparation                                Bag-breaker in chute
•        With dust collector
•        Slurry Tanks                        2 – 800 gals. Each
•        Lime Slurry Pumps
        Number                                                        2
        Type                                        Simplex plunger
        Rating                                        On-Off and Speed
•        Control                                Control at filter panel

Initial                Design        
SLUDGE PROCESSING
4. Sludge Conditioning
o        Ferric Chloride
•        Storage tanks
        Number                                                        2
        Type                        Pressurized, air-padded
•        Capacity, each, gal.                                  2,600
•        Day Tanks
        Number                                                        2
        Capacity, each, gal                                    600
•        Ferric Chloride
Pumps
        Number                                                        2
        Type                                                Diaphragm
        Capacity                                                0 to 25 gpm
        Control                On-Off and speed control at filter
Panel.
5.        Sludge Dewatering
o        Vacuum Filters
•        Number                                                        2
•        Type Media                                                coil
•        Total Surface area
Sq. ft.                                                  1,000
•        Filtering rate
1b/sq/ft//hr                                                4.5
•        Sludge to filters
Dry lbs/week                192,000               283,000
•        Operating period
Hrs/week                             43.6                        62.9
•        Operating period
Hrs/day                              8.5                        12.6





Figure II – General Plan of Kline’s Island after 1978-79 Construction Activity

INSTALLMENT TWO

Construction contracts for the City of Allentown 1978-79 completed wastewater
treatment program was executed June 29, 1976. The historic reality being that the
following firms were awarded contracts to perform specialized craft functions as
the construction program progressed:

1.        General construction – Louis Picciano Sr. Corp., Endicott, New York -
$13,935,000;
2.        Plumbing – Funari & Bogna Co., Allentown, Penna. - $146,000;
3.        Heating and Ventilating – Corbit’s Inc., Reading Penna - $216,000;
4.        Electrical- Wertz Engineering Co., Reading Penna. - $939,000.

Please note – the total cost of the 1978-79 completed City of Allentown
wastewater treatment construction program was $15,235,900 with construction
commencing July 15, 1976.

But as it happened, the 1978-79 completed wastewater treatment construction
program commenced by the Daddona Administration was destined to fail. An
early warning of this came (February, 1978) from the Pennsylvania sector of the
EPA. (Note – Leo Fetzer, the Allentown Business Manager, temporarily assumed
the head of Allentown government when Frank Fischl, the newly elected Mayor,
was sidelined as a result of unexpected but necessary heart surgery in late
January, 1978. The health problem was discovered after Fischl had attended a
combined meeting of East Allentown neighborhood associations at Midway
Manor which I had arranged but could not attend because of a schedule change
at work.) The EPA had warned Acting Mayor Fetzer that the actual flow capacity
of the plant might be less then the 40 m.g.d. Planned because the actual loads,
which the plant received, probably would exceed the wastewater loads used to
design the plant modifications.

Unfortunately, this failure meant the continuation and expansion of odor
problems affecting city neighborhoods despite contrary predictions by public
officials in the 1977 municipal election.

Daddona in an East Allentown – Common Sense Herald election survey of
municipal candidates is quoted as saying: “Once the new expansion to the plant
is completed in 1978 all odors should be eliminated for good.” Allentown City
Councilman Benjamin Howells in the same issue claimed: “The new plant should
make those odors a bad memory,” Interestingly, Karl Kercher, 1977 City Council
President, was more cautious in his statement saying: “Upon completion of the
current sewer plant expansion (early 1979) the odor problem should be severely
reduced or eliminated.”

In retrospect, V.J. Ciccone & Associates, Inc., Woodbridge Virginia in its EPA
Office of Inspector General sanctioned “Technical Evaluation of Allentown
Wastewater Treatment Plant for Final Audit of Federal Grant – January 30, 1984”
made the following general conclusions in regard to plant design performance:

1.        The plant was constructed in accordance with approved plans and
specifications. However, the plant is not being operated in the manner reflected
in design plans.
2.        The lack of pre-treatment of the wastes from the Lehigh County Authority
greatly impacted upon the operation of the plant with the result that more than
anticipated quantities of humus sludge was being generated.

(Note – the slough from the rock media and plastic media biological growth is
called biological or “humus” sludge.)

3.        It can be seen that solids loading calculations for plant design, especially
grit removal and the contribution of B.O.D. Biomass conversion, could have been
more accurately accounted for in the mass balance calculations. The result is
that the sludge capacity of the plant is proportionately reduced.
4.        Currently, the plant is not operating to the intended design criteria.
Because of the recycle of rock media trickling effluents and increased amounts
of return flow, the plant operational mode varies from intended design. And,
5.        There was a noticeable increase in noxious odors coming from the plant as
the new unit processes and renovated units began operating in late 1978.

Incredible as it may seem, both the city’s project engineer, Metcalf & Eddy,
Boston, and its Operation’s Director, Harry Bisco, denied publicly the existence
of offensive odors contributed to plant operation for a number of months
following the end of construction work at Kline’s Island.

But the incidence and occurrence of public complaint indicated otherwise.
Interestingly, Bisco who as Director of Operations in the Daddona Administration
had assured the EPA that Allentown would not build a plant that in three years
would prove to be defective had in reality achieved such a feat. The tower that
Allentown expanded, indeed, was not up to “snuff” as far as the citizenry was
concerned for the off-site odors that the plant had generated was of greater
strength, duration and territory. In the end, once the Fischl Administration faced
up to the situation, it had no alternative but to study and make plans for the
development of an odor control system to alleviate or eliminate the problem.

Thus, as it would be, Allentown officials in March, 1980 would make request of
the Pennsylvania Department of Environmental Resources and the United States
Environmental Protection Agency to provide funds so that the City could
contract the service of an odor consultant to specifically identify the odor
constituents occurring off-sit and the specific process units from which these
odors originated.

          ***                        ***                        ***

Allentown was notified May 1980 that the regulatory agencies would give the City
$10,000 to defray in totality or part the services of an odor consultant. But
interestingly, it appears that two trained odor analysts from Arthur D. Little visited
the Kline’s Island Wastewater Treatment Plant during a three-day period –
Tuesday, April 29 to Thursday, May 1, 1989. These visits, of course, occurring
before the $10,000 study was announced.

Little summarized its findings with the following statements:

“ Based on our three-day site visit, fecal odors associated with ‘Humus’ sludge
storage, intermediate settling tanks and sludge thickeners were frequently
detected off-site (along Basin Street) at complaint level intensity levels. Of these
three sources, the major source appears to be the ‘humus’ sludge storage areas.
On occasion, a burnt tarry/hairy (odor relatable to petroleum) associated with
emissions from the sludge digesters was detected off-site.

The P.M.T.F at the time of our visit was not a significant contributor of complaint
level odors in the community. Our odor analysts could not detect its odor off-site.
Two samplings of odor emissions from the P.M.T.F (Tank 1) indicated that the
predicted ambient intensity from the source would be a maximum of barely
recognizable (0.2) odor or below. We recommend that continued surveillance be
made of the Kline’s Island plant by trained odor analysts particularly during the
summer months to determine if odor emissions from the P.M.T.F system under
differing operating conditions are a problem.”

As recommended by Little the city again contracted Little to make odor
observations Friday evening June 27, 1980 and Saturday morning, June 28,
1980. Again the observations were remarkable in the evidence presented. That is,
Little did not characterize the P.M.T.F’s as being the major contributor to the odor
problem.

Little writes:

“ The Plastic Media Trickling Filter (PMTF) had a similar odor quality and intensity
(winy sour) that occurred in our April visit. Winy sour odors at threshold or barely
recognizable intensity were observed off-site periodically during odor surveys 1
and 2. The PMTF is not a significant contributor of complaint-level odors in the
community.”

Little continues:


“…Fecal odors from the humus sludge storage area were of lower intensity, as
the bulk of the stored sludge had been removed. Fecal odors from the
Intermediate settling tank (particularly the two western inactive tanks) and the
sludge thickeners were also observed off-site. The canvas over the sludge
thickeners is in a bad state of repair. The thickener should be appropriately
covered (perhaps with a dome) and the collected emissions treated.”

Of extreme historical interest, the before mentioned Sludge Thickener Tanks
representing in fact the same Sludge Thickener Tanks that the EPA had ordered
the City to cover January 6, 1976. The important fact revealed at this late date that
this order had not been complied with by the City. One might ask why?

          ***                        ***                        ***

As it developed, the regulatory agencies commissioned Allentown in September
1980 to conduct an extensive study of the odor problem. The contract awarded
to Allentown’s long-standing consulting engineer, Metcalf & Eddy in December
1980. The $101,295 price tag for the study divided between the regulatory
agencies and the City. The City’s share would be $25,395 while the regulatory
agencies paid $75,900.

The Study report entitled “Report to the City of Allentown, Pennsylvania on Odor
Investigations at the Kline’s Island Wastewater Treatment Plant” received the
following critique by this observer in December 1981:

“ The Boston firm, Metcalf & Eddy, recently completed its $101,295 odor survey
of the operations of the Kline’s Island Wastewater Treatment Plant.

It was contracted by the City of Allentown to investigate potential or existing odor
sources at the Wastewater Treatment Plant. Three-fourths of the survey cost
borne by the federal Environmental Protection Agency (EPA).

Interestingly, the value of the Metcalf & Eddy Odor Surveys being a subject of
close scrutiny because the engineering company admitted in its report that the
odor surveys  ‘did not identify any single treatment unit as the major source of
the plant’s odor problems, as none of the surveys were conducted during a
period of frequent odor complaints.’ Moreover it being incredible that the
engineering company could not confirm the evidence of complaint-level odor
levels in East Allentown. The report saying: ‘It is noteworthy that no plant odors
were detected in the residential areas of East Allentown (from which
approximately half of the complaints normally originate) during the first four
periods of surveys.”  

The observer continued:

“However, the company did collect wind data from the National Weather Service
Office at the Allentown-Bethlehem-Easton Airport (now renamed the Lehigh
Valley International Airport) and reviewed it in an attempt to correlate wind
directions with the localities from which odor complaints were originating. Thus,
from this correlation it is evident that the prevailing winds in Allentown are
westerly; and that, winds rose approximately toward the area having the highest
concentrations of odor-level complaints. (That is, East Allentown and the Skyline
Terrace area.)”

In the end the observer concluded:


“ This observer can only conclude that the Metcalf & Eddy Company, Allentown’
s long-standing Wastewater Treatment Engineering Consultant, did not conduct
a comprehensive odor survey at off-site areas as it might have. The truth being,
the consultant does not answer the questions as to the basic cause of the
continuous odor problems at the plant. Consequently, the report ought to be
considered a series of experiment guesses as to what might be done but with no
assurance of success.”


          ***                        ***                        ***

In the end – a City of Allentown Odor Control System Invitation to bid information
packet released April 1982 pinpointed the existing P.M.T.F’s and Thickening
Tanks as the sources of malodorous substances indicated to be generally fecal,
rancid, sour and musty in nature and being generated as a result of biological
decomposition of solids and organic matter. Of course, the predominate odors
detected off-site and at various units during consult surveys being fecal and
partial oxidation products of sulfur-bearing and nitrogenous matters. In general,
the odor descriptions and probable chemicals responsible for the odors are
given below:

Odor characteristic        Probable Chemical

  Fecal        Mercaptions, sulfides,
          Disulfides, Phenyl acetic
          acid, fatty acids, indole,
          skatole, amines.
          Burnt Fecal        Partial oxidation, products
          Above
  Rancid        Unsaturated Fatty Acid
  Sour        Fatty Acid, Alcohols
  Musty        Polychloramisoles

INSTALLMENT THREE

Remarkably, in 1984 we again find Joseph S. Daddona very much involved in
wastewater treatment decision-making. This time we see the Mayor trekking to
Washington D.C., the nation’s capital, looking for federal money to subsidize
odor control work that would not be necessary had the proper decisions been
made in the first place. (The program had it basis in a report released by Metcalf
& Eddy - October 1981 ((a  Fiscal Administration Project)) entitled “Report to the
City of Allentown, Pennsylvania on Odor Investigations at the Kline’s Island
Wastewater Treatment Plant.”) We ask? Did the federal government have the
obligation to satisfy the mayor’s funding demands? Sincerely, we believe the
answer should have been no. This attitude to some may seem severe, but it is
our belief that federal agencies like the EPA, unless they are likewise at fault, are
under no obligation to pour new or additional monies into projects that remedial
action is required due to repetitive consultant or in-house design flaws in
engineering or because design specifications called for as a basis for grant
approval were not achieved in actual construction.

How ironic is it that one section of EPA would give the city yet another million for
odor control while another section initiated the following requited action:

1.        Formal audit of expenditures of ($16 million) funds received through 1978
Kline’s Island construction grant award.
2.        Technical evaluation of the design and construction of the Kline’s Island
Plant and its operations.

Of course, the focus of the technical evaluation has been design for renovations
to the plant, the construction of the renovations completed in 1978-79, the
persistence of odors at and from the plant, and the issuance of organic loadings
in the plant.

The EPA grant representing seventy-five percent of the expected cost of design
and installation in performing work under the Second year of a program
designed to control such off-site odors attributable to plant operations.

  ***        ****                        ***

We note – the City of Allentown undertaking of first year odor control renovations
carried out within federal assistance. But Daddona in trekking to Washington in
1984, in any case sought to convince EPA officials to no avail concerning the
wisdom of approving retroactive federal payment for the City of Allentown’s first
year odor control construction costs. Included in these costs being the
November 1982 completed installation of covers and scrubbers on two Sludge
Thickening Tanks.

In analysis, if we again report the story of Mr. Daddona going to Washington for
funds under the Municipal Treatment Construction Grant in a later year, things no
doubt will be that much tougher for Have Mayor Will Travel. The reason for this
analysis is that the federal government under Ronald Reagan has cast the signal
that the days of local dependence upon the federal government for quick money
for community projects has peaked if not over. The fixed reality was, the $2.6
billion a year program, down from $5 billion in annual spending in the late 70’s
was facing the possibility of being phased out by Congress.

          ***                        ***                        ***

In a departure from past practice, in-house staff and personnel performed design
work for Allentown’s odor reduction program. Bill Engle, the City’s Water
Resources Manager was empowered to oversee design work for the multi-year
program. As a result Metcalf & Eddy, Allentown’s long-standing engineering
consultant for wastewater treatment was not retained by the City to follow up
upon its preliminary odor reduction investigations and findings.

But most certainly, the ghost of Metcalf & Eddy continued to hover over the Kline’
s Island Wastewater Treatment Plant as the City’s remedial project progressed.
The fact is the City continued to draw upon Metcalf & Eddy’s former reports and
studies to make their current and future design specifications. In otherwords, the
body need not be present for the City to rely upon its former expertise as long as
it leaves a record of its thoughts; and indeed, Metcalf & Eddy has left a calling
card.


Before Allentown initiated its multi-year remedial program that included the
installation of covers on th P.M.T.F’s, Metcalf & Eddy suggested the probable
need of such installation in at least three known reports it made for the City of
Allentown. The first occasion was in the original study plans for the 1978-1979
construction project. However, for economic reasons, city officials in 1972
thought it prudent to forego the installation of covers if there was a good chance
that they would not be needed. Then too, Metcalf & Eddy in its “Report to the City
of Allentown on Request for Additional Funding to Eliminate Odors Emanating
From the Waste Water Treatment Plant – October 12, 1979” again recommended
the placement of covers on the P.M.T.F’s; and additionally, this recommendation
was further reinforced in its October 1981 study entitled “ Report to the City of
Allentown, Pennsylvania on Odor Investigations at the Kline’s Island Wastewater
Treatment Plant.”

Importantly, we believe that the October 1981 was the blueprint for odor
reduction activity in the Daddona Administration. The report identified the most
probable sources of complaint-levels odors at the plant as being the sludge
storage area, the plastic media high-rate trickling filters, the sludge thickening
tanks, and the intermediate settling tanks and recommended the following
actions to mitigate odors from the plant:

1.        Vigorous enforcement of City Sewer use ordinances.
2.        Provide covers and exhaust gas treatment for the P.M.T.F, Sludge
Thickeners and elutriation tanks.
3.        Conduct study to evaluate the impact of biological (humus0 sludge on the
anaerobic digestion process.
4.        Eliminate the storage of sludge at the plant.
Replace existing intermediate settling tanks with new tanks if periodic cleaning
of existing tanks doesn’t mitigate odors.

Concerning this in-house work, we could find no reason to quarrel with the
concept. After all, prior to the establishment of the Second Daddona
Administration we made the following comments both in the Lehigh
Valley/Allentown Common Sense Herald and in public speeches made in the
course of my unsuccessful 1981 City Council campaign:

“Why should the taxpayer engage the service of high-priced professional
engineers and then have to engage the services of consulting engineering firms
whose opinions have often been conflictual, redundant, or experimental. The
whole point of hiring consultants is to get the know-how and experience our own
people lack; and if we resort to the use of consultants they ought to work closely
with our people each step of the way, and give us the kind of specific advice and
technical support our situations calls for. The result is that at some point our
people should be able to take over themselves. The sooner this happens the
better for our region and incidentally the lower our consultant costs are likely to
be.”

Any concern we do have, however, is the belief that the Daddona Administration’
s decision to perform design work in-house was more related to making a
scapegoat out of Metcalf & Eddy in order to escape judgment itself then
acknowledgement of superior technical expertise in city professional engineers.

However, one should not underestimate the real potential for political
accountability in the in-house design policy. Why? The Daddona Administration
by dropping Metcalf & Eddy had removed the protective screen behind which the
Administration could previously hide. Now, with in-house design, the Daddona
Administration in the long-term lived or died by citizen opinion determined by the
persistence of malodorous inconvenience in the neighborhoods surrounding
the plant.

But that was just one problem for the increased production level of undigested
sludge by-product when water flow levels remained the same also presented
trouble for the Daddona Administration as far as storage and disposal.

          ***                        ***                        ***

Rules and regulations of the Pennsylvania Department of Environmental
Resources require a municipality or private hauling contractor to obtain a permit
to apply sludge on land in the Commonwealth. The applicant for a permit must
provide a laboratory report showing the chemical analysis of the sludge and a
site inspection report of the land on which it is applied. The farmer on whose
land the sludge is applied does not have to obtain a permit unless he qualifies as
a commercial hauler. In either case the land on which the sludge will be spread
must be inspected and the analysis of the sludge must be evaluated before the
permit is issued.

Sewage sludge clearly is a by-product of wastewater (sewage) treatment.
Experts claim, in general, that more than 99 percent of the raw sewage piped into
a wastewater treatment plant is discharged as sewage effluent. Consequently,
the less than one percent, we have not thus far accounted for, remains as
sewage sludge. Then too, what remains is largely a biological material consisting
of solids, which settle out during the treatment of sewage wastewater. We note –
these solids referred to as sludge also undergo additional treatment, most
commonly anaerobic or aerobic digestion. This treatment stabilizes the sludge
by reducing the quantities of easily decomposable organic materials, reducing
pathogenic (disease causing) organisms, and eliminating the undesirable odors
associated with raw sewage.

Sludge contains almost every conceivable element or compound found in
wastes from human, domestic, commercial and industrial sources. Importantly,
the Pennsylvania State University, Cooperative Extension Service has
suggested in a circular that sludge may contain substantial quantities of organic
matter, plant nutrients, trace elements, and some potentially hazardous
compounds. Then too, specific research at the Pennsylvania State University
has demonstrated that sludge from treatment plants throughout the
Commonwealth contain varying quantities of nitrogen, phosphorous, potassium,
calcium, magnesium, iron, manganese, boron, molybdenum, zinc, and copper.
Furthermore, Commonwealth sludge may also contain nonessential trace
elements and heavy metals such as chromium, lead, nickel, mercury, cadmium,
and several other compounds such as exotic organics, polychlorinated
biphenyls (PCB’s) and pesticides. Unfortunately, a number of these substances
can be toxic to plants at relatively low concentrations in the soil. Cadmium is
particularly toxic to animals and humans, and its uptake by plants may be
hazardous to the food chain. When sludge is spread on land, many heavy metals
such as zinc, copper, chromium, lead, nickel, and cadmium are chemically bond
by the soil indefinitely. Hence, the land application of sludge that contains
appreciable amounts of heavy metals may become a real concern to farmers and
landowners in the future.

Good judgment would suggest that farmers not accept or apply sludge on
cropland without taking a complete chemical analysis of thee sludge.
Importantly. Sewage sludge applied to cropland should be digested and
stabilized. Then too, cropland soils on which sludge is to be applied should be
tested and evaluated for soil fertility and productivity which due consideration for
crop to be grown. The pH of the soil on which sludge will be applied should be
adjusted and maintained between 6.5 to 7.0 to help lower the availability of heavy
metals to the plants; and importantly, soil samples from sludge treated fields
should be tested every three years to monitor the buildup of heavy metals and to
protect the farmer from future destruction of crops as proposed EPA regulations
would require should such materials be found in soil samples above certain
levels.

In analysis, one could not blame a farmer for being hesitant to accept free
fertilizer from a sewage plant under such regulations; and personally, having
traveled both the Upper and Lower Egypt (that is, the course of the Nile River
from the City of Aswan at the base of the New Aswan Dam that formed Lake
Nasser to the Mediterranean Sea resort of Alexandria in the Nile Delta) this world
traveler can testify to the dangers and inconveniencies inherent in eating certain
vegetables or food crops fertilized by potentially harmful waste residue that
included dung deposits. Therefore we can concur with the Pennsylvania State
University, Cooperative Extension Service that animals should not eat forage
and pasture crops while any residual sludge remains on the vegetation. Then
too, sewage sludge should not be applied on land that is used for the production
of vegetables or human food crops that are eaten raw.

          ***                        ***                        ***

The issue of actual plant capacity is important as it ties directly to future
wastewater treatment plant capacity requirements for the Allentown metropolitan
wastewater treatment service area. In early 1979, construction activity to upgrade
the wastewater treatment capacity of Allentown’s Kline’s Island Wastewater
Treatment Plant was completed. The result being, wastewater-processing
capacity was increased from a rating of 28.5 million gallons per day (m.g.d) to 40
m.g.d. Statistically, the addition of 11.5 m.g.d represented a twenty-nine percent
increase in capacity.

Please note – this rating is strictly hydraulic or it is based on flow. It does not
consider high strength organic loadings.

However, due to the failure of the Lehigh County Pre-treatment Plant at Upper
Macungie and the subsequent problem of conveying excessive strength waste
discharge from certain industries located in industrial park areas of Upper
Macungie Township, this combined and organic capacity has hindered the ability
of the Kline’s Island plant to process its full 40 m.g.d hydraulic rated capacity free
and clear of publicly offensive air emissions.

The Sewage Task Force Report (November 1980 of the Allentown-Lehigh County
Greater Community Council (GCC) implies that actual plant capacity can be
extended by correcting two malfunctioning processes at the Kline’s Island Plant.
Basic Oxygen Demand (BOD) is not being adequately treated because the Imhoff
Tanks (Intermediate Settling Tanks) have become septic; and Ammonia is not
being adequately treated because the rock filters are not “dosing.” That is,
allowing the flow to spray over the entire area of the rock filter.

The rock filters can be repaired by installing valves that permit dosing. But the
GCC claims that the Imhoff Tanks may be obsolete; and suggests, that they can
be replaced by an “activated sludge sedimentation process.”

The Plastic Media High-rate Trickling Filters are cited by the GCC as a potential
source of aid in BOD removal if they are capped (covered) and air activated. It
was certainly a wanted development that the capping of the PMTF’s would aid in
reducing noxious odors and would help reduce seasonal changes in plant
performance.

The GCC believed that once BOD could be treated before the wastewater
becomes septic, the Kline’s Island Wastewater Treatment Plant should have
sufficient excess capacity to meet the needs of the signatories of the Allentown
metropolitan wastewater treatment service area.

          ***                        ***                        ***

Of historic note – during the first year of the phased odor reduction program,
Quad Environmental Technologies of Illinois was awarded the construction
contract to install covers, plenums and odor control equipment on two of the
four Environtech constructed Plastic Media High-Rate Trickling Filters (PMTF’s)
at an appropriate cost of $890,000. In addition, a belt press was added at an
approximate cost of $457,000 to provide a more efficient sludge dewatering
system and to remove solids from the wastewater system.

The two remaining uncovered PMTF’s would be the focus of year two work at an
contract price of $824,623 let out to Johnson Construction Co., Dover, York
County, Pennsylvania.

The new belt press operation with a polymer added leaves a sludge by-product
that is relatively free of water content and bothersome odor. Thus, the long-term
benefit of the process would be the savings it would produce in sludge hauling
charges if prices of sludge hauling and disposal remain the same. That is- no
longer would the city be charges for sludge tonnage that would be saturated
with water. Instead this water would be withdrawn by the belt press operation
with the resultant downward movement in sludge weight and sludge hauling
charges.

Other projects to be undertaken in year two of the phased program include:

        The construction of a lime silo with pneumatic feeders to stabilize the
odorous sludge being processed at a contract cost of $334,000;
        The installation of hooded enclosures over the solids dewatering
processes (vacuum filters and conditioning tanks) to control ammonia in the
treatment plant at an estimated cost of $40,000;
        The installation of covers over the decant boxes on the digester overflow
boxes at an estimated cost of $6,000;
        Finally, the expenditure of another $125,000 to $250,000 for a septage
unloading facility to accommodate septage haulers.

Please note – Bill Engle in an effort to reduce costs but not reduce efficiency
planned to combine the construction of a new solids thickening tank (properly
covered and vented with oxidation scrubbers to control odors and eliminate the
recycling of septic solids) with the septage unloading facility.

Other planned or contemplated phased work included:

        The installation of covers, plenums and gas scrubbers on four primary
settling tanks;
        The installation of covers, plenums and gas scrubbers on two elutriation
tanks;
        The construction of an enclosure over the aerated grit chamber with
venting accomplished through the primary tank scrubbers;
        The conversion of the rock media to a mechanical forced ventilation plastic
module unit, based on current plant testing;
        The modification of existing Intermediate Settling Tanks to regulate flow,
remove solids and control odor emission to the airshed or replace units with new
units.


Note – decision-making in regard to Intermediate Settling Tanks was intended to
be based on test results of a pilot project started in the summer of 1983. That is, a
special hydra-hydraulic rake piping system used extensively in de-silting in coal
basins had been installed in one of the two sludge holding compartments of the
Intermediate Settling Tanks to permit a more rapid removal of sludge. If the pilot
project was successful, the Intermediate Tanks need not be replaced.

          ***                        ***                        ***

Concerning the Engle led in-house repair to a defective system – we couldn’t be
positive at the time in predicting the ultimate success of the multi-year project.
After all – what guarantees could be given that the remedial work would under
both operating and non-operating conditions be effective in limiting air leakage
to less than one percent? Therefore, we had to ask the responsible officials –
Were proper precautions been taken to assure the complete capture of odors
with the installation of new ventilation and odor processing systems? Then too –
Would there be any possible short-circuiting of air through the units or through
the covers or enclosures? Truly we hoped for the best, inevitably not wanting to
be confronted with news of the worst. Certainly, we shuddered at the prospect
concerning the living environment around the wastewater treatment plant that
there was no future, only the past happening over and over. Importantly, we had
to be concerned because the ghosts of Kline’s Island Past work to inform us that
except for a few modifications in design and scope of work the Engel led odor
control program implemented by the City in the early to mid 1980’s seemingly
paralleled the steps followed by the Lehigh County when the County attempted
to save its troublesome pre-treatment plant in Upper Macungie.

Historically, we know that the County efforts to save the Upper Macungie pre-
treatment plant failed. The remedial efforts implemented by the County never
were able to alleviate the malodorous conditions that so aggravated neighboring
residents in Upper Macungie and Trexlertown.

Just the same, City of Allentown Water Resources Manager Bill Engle expressed
confidence that Allentown’s planned odor control system would work. In fact
Engle as contract administrator of Allentown’s in-house odor contract sought to
make it clear to us the salient differences between the facilities and remedies
attempted at Upper Macungie and the facilities and remedities attempted or
pursued at Allentown. First, he cited an example that Kline’s Island can remove
large harmful particles (sometimes metal) from the wast stream prior to hitting the
system. Such capability according to Engle was said to be absent at Upper
Macungie and therefore, was a contributory factor towards harming the system.
Second, the fans installed by Quad Industries in conjunction with the covers are
capable of removing odors into an air scrubber by pull or push action from
above or below the PMTF’s with proper footer control use. In comparison, the
plant at Upper Macungie had fan action that could only force air from below into
the air scrubber; and third, Engle indicated that Allentown’s odor control project
would install an air collector to provide uniform distribution of air over the entire
cross-section of the Plastic Media Trickling Filter. A capability that was said to be
absent at Upper Macungie.

Harry Bisco, Allentown’s Director of Public Works had caused public confusion
concerning a claim he publicly proclaimed relative to PMTF cover effectiveness.
Bisco said that the Quad equipment had effectively reduced odor by ninety-
seven percent. Unfortunately, this assertion was hard to believe for the
occurrence and level of odors attributed to plant operation remained at high
levels during the summer of 1983 when work was said to be completed on the
installation of covers. The incidence of odor complaints in 1981, 1982 and 1983
being 189, 116 and 124 respectively. The important fact noted that eighteen odor
complaints were received after the odor control system was totally on line and
debugged as of September 10, 1983 with September totals prior to 9/10/83 being
seventeen for a total September total of thirty-one. Take note – the September
through December totals for odor complaints in 1981, 1982 and 1983 being forty-
four, forty-seven and thirty-five respectively.

Please Note – Bisco’s title changed from Director of Operations to Public Works
in the second coming of Joe Daddona’s run as mayor.

Incidentally, the fact that two PMTF’s remained uncovered during the period
could not be the causal factor for the persistence of odors because the two
PMTF’s were never in operation during the period and were still out of service in
early 1984. This being the normal operating mode of PMTF operation since
October 1979.

Bill Engle attempted to clear up whatever public confusion that had developed
from Bisco’s statement. Engle acknowledged that actual odors emitted from the
plant had not been reduced ninety-seven percent. But he accepted the ninety-
seven percent statement about odor reduction within the PMTF’s as valid. That
is, the system, in fact, removed ninety-seven percent of odors on a continuous
basis from the captured gas stream that entered the PMTF’s and the Thickening
Tanks.

Incidentally, year two of the odor control program would provide covers to units
that were not currently in operation. (Note – with the installation of covers all
PMTF units would be placed on line with the exception of periods of emergency
or required maintenance with reduced loadings in each. But at time the evidence
was obvious, unless work performed on the sludge digester and vacuum filter
produced better results in neutralizing the effects of odor causing changes in
chemical balance, we did not truly expect the nature of odors in 1984 and 1985 to
be diminished to acceptable intensities and durations.

INSTALLMENT FOUR

Calvin Coolidge, a former United States President has stated:

“Of course we look to the past for inspiration, but inspiration is not enough. We
must have action. Action can only come from ourselves; Society, government,
the state, call it what you will, cannot act. Our only strength, our only salvation,
lies in the individual. American institutions are built on that foundation. That is
the meaning of self-government, the worth and the responsibility of the
individual. In that America has put all her trust, if that fails, democracy fails,
freedom is a delusion and slavery must prevail.”

In analysis, of course we look to the past to seek clues to the genesis of our
perceived problems, but this search for the discovery of the genesis is not
enough. We must act upon our discoveries to be of any usefulness in alleviating
or otherwise resolving the gremlin=like social or physical legacies of the past.

          ***                        ***                        ***

On August 20, 1970, Metcalf & Eddy was legally engaged by the Allentown
Authority to render certain services (see Insert I) relative to the 1978-79
enlargement of the wastewater treatment plant at Kline’s Island, and pursuant to
an agreement entered into December 22, 1969 between the City of Allentown and
the Lehigh County Authority.

The Allentown Authority was requested to enter into the aforementioned
agreement by resolution No. 23222 adopted by City Council on December 16,
1969.

INSERT 1 – SERVICES OF METCALF & EDDY PURSUANT TO 8/20/70 CONTRACT


Feasibility Study
Make studies and submit a feasibility report including the following:
1.        Estimated of the capacities of various trunk and intercepting sewers in the
City and the effect the added flows will have on these sewers.
2.        Preliminary estimates of the cost of constructing the waste treatment plant
addition for alternative types of treatment.
3.        The estimated cost of operating the enlarged facility.
Sewer Service Agreements
1.        Consult with the City and Authority officials on the engineering and costs
aspects of sewer service agreements between the Allentown Authority, the City,
Lehigh County and other municipalities, which are expected to contribute flow to
the plant.
2.        Prepare such engineering data as may be required for these agreements.
Design Report
Upon submission of the feasibility report, and following agreement among all
signatories of the sewer service agreements as to additional reserved capacity
they will each require. Submit a report covering the following:
1.        The necessary degree of treatment and the method of sewage treatment.
2.        Revised estimates of the cost of constructing and operating the enlarged
plant.
3.        A detailed discussion and recommendation concerning the ultimate
method of disposal of the filter sludge cake.
4.        Preliminary design documents consisting of design criteria, drawings, and
outline specifications for the recommended addition to the sewage treatment
facilities.
5.        Location plans and specifications for subsurface exploration.
6.        Discussion of possible State and Federal Aid.
7.        A recommend a program of construction
During this phase, engineer will also:
8.        Furnish assistance in filling out the necessary application forms for State
and Federal Aid.
9.        Confer with appropriate State and Federal Officials to assure compliance
with their requirements and with City and County officials for their approval.
Final Contract Drawings and Specifications
The engineer will:
1.        Prepare contract drawings, specifications and other contract documents
for the construction contract or contracts for required treatment facilities.
2.        Prepare drawings in pencil on tracing cloth suitable for reproduction in
accordance with Engineer’s usual procedure.
3.        Confer and cooperate with the Authority and City officials in order that the
drawings and specifications will be in conformity with the needs of the Authority.
4.        Furnish to the Authority engineering data for and assist in the preparation
of the required documents so that the Authority may secure approval of such
governmental authorities as have jurisdiction over design criteria applicable to
the project.
5.        Furnish six sets of prints of the drawing and six sets of the specifications
and other contract documents without charge. Additional copies will be provided
at cost plus 50 percent to cover overhead and handling. Provide a revised cost
estimate for the project based on the completed drawings and specifications.
Services during Construction
After receipt of bids, the Engineer will:
1.        Assist the Authority in securing and evaluating bids and furnish
recommendations on the award of the construction contracts.
2.        Provide consultation and advice on construction matters including
periodic visits to the site to observe the progress and quality of the executed
work and to determine in general if work is proceeding in accordance with
contract documents.
3.        Review and either approve or reject shop drawings, diagrams, illustrations,
catalog data, samples and schedules, the result of tests and inspections and
other data which the contractor is required to submit for conformance with the
design concept of the Project and compliance with the requirement of the
contract documents.
4.        Assemble maintenance and operation instructions, and parts lists, which
the contractor submits in compliance with the contract documents.
5.        Review and if appropriate approve progress and final estimates for
payments to the contractors.
6.        Upon completion of construction, furnish to the City the original contract
drawing, which will be marked to show the works as, built.
7.        In connection with field and acceptance tests of equipment and
appurtenances, observe the tests of equipment and operating conditions, record
test data, submit reports relative to the tests, and make final inspection of the
work.
8.        Prepare an operation and maintenance manual describing the purpose,
functions, and controls for each process in the plant. The physical and
laboratory controls, maintenance functions and staffing requirements necessary
to operate the facility will be detailed. The manual is also to receive the approval
of the Federal Water Pollution Control Administration.
Resident Representation
Upon the request of the Authority, the Engineer will furnish a resident
representative and assistant as required who will:
1.        Coordinate the establishment of the necessary lines and grades, which are
to be furnished by the Authority to the construction contractor.
2.        Visually inspect and approve or reject materials, equipment, and supplies
delivered to the site of the work.
3.        Observe the contractor’s work with respect to quality, suitability and
conformance with the contract requirements.
4.        Keep records of construction and installation progress.
5.        Prepare a set of marked points for use in marking record drawing.
6.        Make measurements and computations for and prepare monthly and final
payment estimates for work done by contractor.
7.        Receive, process and handle shop drawings and the like, transmitting
certain ones to the Engineer’s home office for review in accordance with
services under construction, section three.
Services During First Year of Operation
During the first year after the addition is placed in operation, the Engineer will:
1.        Train and instruct plant personnel in plant operating procedures during
initial plant start-up period.
2.        Make periodic visits, correspond with, instruct and advise City personnel
relative to plant operation and maintenance.







***                        ***                        ***

Mother Theresa, the catholic nun who won the Nobel Prize for her thirty-five
years work on the behalf of the poor and homeless in India has stated:

“Yesterday is gone, tomorrow is not yet here. We can only think of what faces us
today.”

In 1979, it was difficult for Metcalf & Eddy to separate the present from the past.
After all, as the consulting engineer by the City of Allentown through its Authority
to oversee details relating to planning, design and construction for the
enlargement of wastewater capacity at Kline’s Island, city officials would
conveniently rise above public criticism by putting blame on Metcalf & Eddy
whether Metcalf & Eddy was responsible or not. Consequently, Metcalf & Eddy
found it necessary in its “Report to the City of Allentown On Request for
Additional Funding to Eliminate Odors Emanating from the Wastewater
Treatment Plant” of October 12, 1979 to explain the rationale behind decision-
making that led to the 1978-79 completed construction activities at Kline’s Island.

  ***                        ***                        ***

The following is a Metcalf & Eddy statement in regard to Kline’s Island
enlargement planning decisions as found in its “Report”:

“In 1971 during the planning stages of this project several alternative methods of
treatment were studied. Some employing trickling filters and others employing
the activated sludge process. In addition, Mr. Eugene N. Wetzel, of the
Pennsylvania Department of Environmental Resources requested that we study
the elimination of the existing rock media trickling filters and utilize a two stage
activated sludge process. This was also studied. In Chapter 8 of our existing
rock media trickling filters cost approximately $12 million dollars. A similar
alternative, which also utilized the existing rock media trickling filter, cost $17
million dollars. The alternative, which eliminated the rock media trickling filter and
employed a two-stage activated sludge process, was estimated to cost $28
million. It was decided, at the time, that the lowest cost alternative should be
selected. It was not the engineer’s decision alone to select the lowest cost
alternative. There were also other reasons to use a trickling filter over activated
sludge. One major reason was that it is much simpler to operate and did not
require a great degree of sophistication as far as operations is concerned. The
operators were used to operating a trickling filter and there would be extensive
training or new hiring required to operate additional trickling filters. In addition
the plant had been hit with a series of chemical dumps, which killed some of he
biomass on the rock media trickling filter. The trickling filter, however, because
only the outer layer sluffed off, was able to recover. In addition, the EPA has a
practice of only funding the least cost alternative. If a municipality wishes to go
with a higher cost alternative thy must pick up the entire cost between the least
costly alternative and the selected alternative. The city officials in Allentown, at
the time, (1972) did not want the city to fund the additional $5 million dollars all by
itself.”

          ***                        ***                        ***

Indeed, complaints from numerous individuals over an increasing territorial field
in regard to the existence of malodorous conditions caused public relations
problems for retired Air Force Colonel Frank Fischl shortly after he succeeded
Joseph S. Daddona as Mayor of Allentown, Fischl, of course, did not have to look
long to discover the genesis of the perceived problem. The fact is he inherited
from the Daddona Administration a wastewater treatment expansion project
whose design was not adequate to meet the impact of incremental BOD and
Suspended Solids loading.

As a candidate for Mayor, Fischl said:

“ The problems at the Sewage Plant are a reflection of bad management, all the
way from the Mayor to the Director of Operations to the Superintendent of Water
Resources to the Superintendent of Waste Water. Mismanagement, inadequate
supervision and lack of expertise in management rank the cause of the problem.”

As Mayor, Fischl brought in Bill Engle as Superintendent of Water Resources but
kept Harry Bisco as Director of Operations.

Interestingly, Daddona in defeat had escaped immediate political responsibility
for continuing problems at Kline’s Island. In fact, when he successfully ran for
Mayor in 1981 against Bob Smith, Daddona acted publicly as if he had nothing to
do with the Kline’s Island problem. But being a candidate for city council in the
1981 democratic primary, I know different. I remember being warned privately by
Daddona to drop the Kline’s Island issue because it made me appear to be
unneutral in the democratic primary. That is, my use of the issue made me appear
that I supported Daddona’s opponent Louis Hershman for Mayor.

The fixed reality being that Daddona feared that my pointed questioning of past
decision-making in regard to water and sewer issues would be detrimental to his
candidacy in the fall election; and also, that my position in the community would
grow to the point that I would become a serious future challenger within the
Democratic Party to his established political position in the community.
Consequently, my City Council campaign perceived in this manner, Daddona
and his political cohorts were determined to undermine any positive wide scale
reaction to my campaign. Quietly Daddona’s cohorts through their support to
Barbara Irvine and Frank Palenchar, the eventual winners in the 1981 Democratic
Party City Council Primary and successful candidates in the General Election of
the same year.

          ***                        ***                        ***

Despite the Daddona legacy the Fischl Administration could not afford to lay
back and do nothing in regard to citizen concern about the quality of Allentown
air. Accordingly, a meeting was held in Allentown, Pennsylvania on October 2,
1979 between the City of Allentown, representatives of EPA Region III,
representatives from the Pennsylvania Department of Environmental Resources,
and representatives of Metcalf & Eddy, a Delaware registered corporation with
main offices in Boston, Massachusetts. The purpose of the said meeting was to
discuss odor problems experience in the City of Allentown since the completion
of the Plastic Media High-Rate Trickling Filter (PMTF) construction in September,
1978, Another purpose was to determine whether federal or state funds would be
available to put covers on the PMTF’s and other sources of odors that may be
present.

The preliminary cost estimates to put covers on the four 100-foot diameter 32
foot high PMTF’s to pull off the nocuous air, and scrub it was 2.5 million dollars.
The annual operating cost was estimated to be $110,000.

Encouraged that state and federal funds would be available, Harry Bisco,
Allentown’s Director of Operations, submitted to George Parks, regional Sanitary
Engineer, Pennsylvania Department of Environmental Resources October 15,
1979 a formal request for additional finding for project number 420-831-01.

At the same time, Bisco asked permission from DER for the City to by-pass the
Plastic Media High-Rate Trickling Filters for the purpose of temporarily returning
to the use of the original rock media, and renewed compliance to the N.P.D.E.S
(National Pollution Discharge Elimination System) requirements for discharge
until such time permanent solutions to the odor problem with the PMTF’s could
be realized.

But before Allentown would become recipient of additional state and federal
dollars for project number 420-831-01, much data and information had to be
provided to EPA authorities.

Accordingly we see Daniel E. Koplish, Superintendent of Operations Kline’s
Island Wastewater Treatment Plant, October 19, 1979, responding in writing to
inquiries of Ms. R. Sarah Compton, Director, Enforcement Division, U.S
Environmental Protection Agency, Region III, Philadelphia, Pennsylvania.

Koplish conveyed to Compton:

1.        “The influent to Allentown’s Kline Island Plant POTW is septic. Laboratory
results on effluent samples from Lehigh County Authority have shown that this
material is septic in that it has no appreciable dissolved oxygen content and is
odorous.
2.        Laboratory personnel are in the process of determining other discharges
whose effluent is septic at the time of discharge. Information on discharges to
the Lehigh County sewerage system is limited since the operation and
maintenance of the County’s system belongs to the Authority not to the City of
Allentown.
3.        Influent sewage to the plant is normally septic. The duration extends over a
twenty-four (24) hour period, seven (7) days per week.
4.        The City has passed and is implementing an amendment to its Industrial
Waste Ordinance wherein dischargers of wastewater having concentration levels
in excess of 300mg/L BOD5 and 360 mg/l Suspended Solids are surcharged for
that material. The City is also in the process of reactivating its legal suit against
Lehigh County Authority with respect to the quality of effluent being discharged.
5.        Presently we are considering several measures, which can be initiated to
help eliminate septic conditions, but the plans have not been fully developed
since the individual interceptor studies need to be completed.
6.        As of this date, 99% of the construction has been completed. With the
exception of certain aesthetical items, the construction will be complete within a
month.
7.        The Kline’s Island plant is meeting final permit limitations.
8.        Enclosed is a copy of Ordinance 12003 with amendments 12145 and
12345.”

***                        ***                        ***

As would be expected, there was some citizen response to the Metcalf & Eddy
suggestion that the PMTF’s be covered. An example was correspondence from
David Cullen, Executive Director of the Allentown Community of Neighborhood
Organizations, Inc., to Allentown Mayor Frank Fischl dated March 12, 1980 in
which Cullen wrote:

“Indications are that the City is moving ahead to install these covers (on the
PMTF’s). The (CNO Environmental) Committee questions the wisdom of this and
very definitely feels that more public input must be gotten before any money is
expended. The Committee feels that there is strong evidence indicating that the
Plastic Media Trickling Filters are defective and that covers cannot correct this
problem.”

In reply, Frank Fischl expressed the following questions and comment in a letter
to Cullen dated March 17, 1980:

“Covers at Kline’s Island:
1.        What problems does the (CNO Environmental Issue) Committee have with
the installation of ‘covers’?
2.        Is the Committee aware that we are talking about a total ‘odor control’
system? We are not simply talking about putting lids or ‘covers’ on the plastic
media trickling filters.
3.        Is the Committee aware that the Pennsylvania Department of
Environmental Resources has approved the concept of the odor control system
and has agreed to provide the bulk of funds as a pass-through agency for the U.
S Environmental Protection Agency?
4.        Why – specifically – does the Committee feel that such an odor control
system will not work?
5.        Is the Committee saying that you would rather have odor problems in and
around the vicinity of the treatment plant as opposed to the installation of odor
control equipment?
6.        Is the Committee aware that we are talking about at this point is the
concept of the installation of odor control equipment? The specific design of the
equipment and the type of equipment will be left to the engineering phase of this
evaluation. Do you object to even entering into that kind of an evaluation?”

In any case, in December 1981, the Metcalf & Eddy odor relief recommendations
were seconded by the Consulting Engineering firm of James M. Montgomery,
Incorporated. JMM was hired by the County of Lehigh (August 1981) to conduct a
feasibility study related to the Kline’s Island Plant. Generally speaking, JMM
recommended that the towers be covered and the existing Intermediate Settling
Tanks (that is, the Imhoff Tanks) be replaced.

Of interest, JMM believed that many of the other related odor problems might
have been caused by the fact that the solids handling facilities appeared to be
overloaded. In regard to the PMTF’s, JMM said the original design loading was
48,300 1b. BOD/day. But baseline mass balance indicated that actual loading was
11.5% greater than design. Therefore, the originally projected BOD removal rate
of 80 percent through the intermediate process might not be achievable, due in
part, to increased loads. Additionally, the August 1981 Schaefer-Stroh loads
would be 71% greater than anticipated in the original Metcalf & Eddy design.
Then too, the PMTF’s are designed at 48.3 1bs. BOD/1,000cubic foot.
Consequently, using JMM’s mass balance and considering the fact that the City
in 1981 was operating only two PMTF’s for hydraulic loading reasons, the actual
tower load was 107.8 1bs. BOD/1,000 C.F (54 1bs. BOD/1000 C.F for four towers).
JMM also claims that the August 1981 projected Schaefer-Stroh’s loadings would
increase this amount to approximately 83 1bs. BOD/1,000 C.F for four towers or
165 1bs. BOD/1,000 C.F for two PMTF’s under then existing 1981 operation.

          ***                        ***                        ***

Importantly, for the historic record, we state that Allentown Mayor Joseph S.
Daddona was incorrect in his Christmas Eve 1984 message to the Allentown City
Council when he claimed credit for the initiation of planning activities for a multi-
year odor reduction program. We have demonstrated in this installment that the
process began prior to the second Daddona Administration. Hence, any attempt
to say otherwise by Daddona shows an extreme memory flaw or an attempt to
distort history. But then again, that is a malady that many politicians succumb to
when they want to perpetuate power.

INSTALLMENT FIVE

The major purpose of a regional comprehensive plan is to deal with issues and
problems that transcend municipal boundaries. Subjects as transportation,
planning, providing for sewer and water systems, dealing with complex
questions of growth policies, farm preservation, etc., are examples where a
regional perspective is needed in addition to a local perspective according to a
Joint Planning Commission, Lehigh-Northampton Counties Comprehensive Plan
for Lehigh-Northampton Counties adopted November 1977 but updated
November 1982.

In regard to regional trends, major sewer system extensions during the late 1960’
s and 1970’s were carried out to service new development, as well as existing
development in boroughs, villages and older subdivisions, which were suffering
from problems malfunctioning on-lot sewage. Naturally, increased wastewater
flows from these new interceptor systems, as well a from new commercial and
industrial development produced pressures for the expansion of major
wastewater treatment facilities located in the tri-cities of Allentown, Bethlehem
and Easton, the major cities located in the metropolitan Lehigh Valley area.

The JPC Comprehensive Plan claims that early sewer systems were completed
in Palmer and Forks Township areas, around Easton and in the western Lehigh
County area. More recent sewer systems were in Bethlehem Township,
Walnutport and the village of New Tripoli in Lynn Township/ One major proposal,
however, the Bushkill/Lower Lehigh Sewer Project experienced delays for
several years over questions about the need for the project, the cost and the
potential growth impact of long sewer extensions through relatively
undeveloped areas.


In regard to residential land use trends, the JPC Comprehensive plan
summarizes:

“Between 1964 and 1972, a large amount of new development occurred in the
region. Little change took place in the boroughs and cities. However, residential
acreage in the suburban townships increased by one-third, or about 6,000 acres.
Residential land in rural townships increased 4,700 acres between 1964 and 1972.

The dispersion of residential development accelerated between 1972 and 1980.
During the eight year period, residential acreage increased by 11,486 acres.
About 7,100 acres or 61% of this increase took place in the rural townships.
Another 3,820 acres, one-third of the total residential acreage increase, occurred
in the suburban townships and the remaining 6% was in the cities and
boroughs. Nearly all of the new residential acreage in the rural townships and
most of the acreage in the suburban townships was for single family detached
housing.”

Indeed- this trend harbored important implications for the JPC and others since
so much of this new residential development has occurred in areas that did not
have centralized water and sewerage, good roads and other support facilities
that are often demanded by urban populations.

Since 1964, the JPC has observed a steady increase in commercial development.
Most of this has occurred in the townships surrounding the three cities
(Allentown-Bethlehem-and Easton). Between 1964 and 1980, the area of land
devoted to commercial uses increased 1,491 acres or 40%. Most of the new
commercial development was in the form of shopping centers and discount
stores and strip development along major arteries such as MacArthur Road
(Whitehall), Stefko Boulevard (Bethlehem) and Lehigh Street (Salisbury –
Allentown).

Then too, the region has not escaped the impact of industrial development
activities. Industrial acreage expanded rapidly between 1964 and 1972 but had
leveled off by 1980. Most of the industrial expansion located in the industrial
parks and suburban townships. But, in the early 1980’s after years of intermittent
economic recession, there has been renewed concern for industrial growth in
the region based on the location of high technology – silicon valley type industry
in place of traditional smokestack industry beleaguered by the need for
modernization, foreign competition and reduction for demand for products.

Examples of regional industrial park activity include:
1.        The Forks/Easton Industrial Park located north of Easton.
2.        The Lehigh Valley Industrial Park – Section I, II, III and IV located north of
Bethlehem in Hanover Township – Lehigh and Northampton Counties.
3.        The Queen City Airport and Thruway Park located off Lehigh Street in
southwest Allentown.
4.        The Iron Run Industrial Park at Fogelsville.

TABLE VII
REGIONAL LAND TRENDS

LAND USE CATAGORY        1964
ACRES        
%        1972
ACRES        
%        1980
ACRES        
%        2000
ACRES        
%
RESIDENTIAL         57,830         12.4         69,617                14.9         81,103         
17.4        109,800          23.5
COMMERCIAL          3,731          0.8          4,482          1.0          5,222          1.1          
7,600          1.6
Industrial, Wholesale & WAREHOUSING          11,191          2.4         14,029          
3.0         14,784          3.2         16,600          3.6
TRANSPORTATION, COMMUNICATIONS & UTILITIES          32,179          6.9         
34,031          7.3         34,325          7.4         35,050          7.5
PUBLIC & QUASI-PUBLIC          6,996          1.5          7,032          1.5          7,136          
1.5          7,400          1.6
PARKS & RECREATIONAL         11,659          2.5         17,829          3.8         
18,748          4.0         21,030          4.5
AGRICULTURAL & VACANT        342,783         73.5        319,351         68.5        
305,053         65.4        268,831         57.7
TOTAL ACREAGE        466,371        100.0        466,371        100.0        466,371        
100.0        466,371        100.0


Please note – TABLE VII breaks down all available land in Northampton and
Lehigh Counties into seven land use categories. The land use categories being
the following: Residential – Commercial - Industrial, Wholesale and Warehousing
– Transportation, Communications & Utilities – Public & Quasi-Public – Parks &
Recreational – Agricultural and vacant. The purpose of TABLE VII being to detail
the regional land use trends for each land use category from 1964 to projected
figures for 2000.

There is some suggestion in JPC reports that the rate of conversion of
agricultural & vacant lands into other uses has slowed, but where development
still occurs it is mostly in rural townships. Hence the JPC suggests that we are
still living with the implications of these trends toward access and travel,
provision of public services, and the changing character of the region.

What then will the region be like in the year 2000? The JPC seems to think that if
the trends of the 60’s and the early 70’s were to continue, new development
would be distributed widely, although the concentration of development around
existing urban areas would remain. As expected, the greatest amount of new
development would be in the suburban and rural areas. The Comprehensive
Plan indicates that if the trends of the 1972 and 1980 period continue over 28,000
additional acres will be developed just for residential purposes between 1980
and 2000. Agricultural and Vacant land would decrease by 36,200 acres and
would represent 57.7% of the region compared to 65.4% in 1980.

To make this study complete, we must revisit this topic in a future
INSTALLMENT. It would be interesting to see how Lehigh County and
Northampton County land preservation efforts would impact on the JPC
prediction for the year 2000. It would be interesting to see whether Agricultural &
Vacant land would constitute more or less then the predicted 57.7% estimate.

INSTALLMENT SIX

R.J. Schaefer, III, the President of the F. & M. Schaefer Brewing Company wrote
in 1969 in regard to the significance of his company’s decision to relocate its
Brooklyn Plant in the Lehigh Valley:

“We have little doubt that construction of this project will open the entire western
Lehigh County area to major tax-paying industrial users…”

Indeed, the F. & M Schaefer project provided the base from which other projects
would spring. As a result, the farmlands and open space of western Lehigh
County were opened to a different economic usage. Up till that time, let us note F.
& M. Schaefer could not locate in the valley without certain public and quasi-
public utility services and facilities in-place or under construction.

This privately-owned or quasi-public infrastructure includes: railroad and
trucking services, gas and electric power, and the required facilities to service
the same. Essential as well, is the infrastructure provided by municipal
government. This infrastructure includes: public highway access, storm
drainage facilities, water supply and a sanitary sewage and industrial waste
treatment system.

          ***                        ***                        ***

Significantly, the end point of Allentown’s Little Lehigh Creek Collector Sewer,
which was also known as the Emmaus Interceptor, provided a convenient
conduit through which industrial wastes from F & M Schaefer and other
industries in western Lehigh County could flow for processing at the regional
wastewater treatment plant in Allentown. We hazard a guess that if the terminus
of the Little Lehigh Creek Collector Sewer was not built or chosen as the site
where the Emmaus and Allentown systems would meet, the economic activities
we have seen in the farmlands and open spaces of western Lehigh County since
1969 would not have occurred.

          ***                        ***                        ***

At Keck’s Bridge the 24 inch-sewer serving Emmaus and Salisbury Township
and the 36 inch-Lehigh County Authority (LCA) interceptor both connect to the
24-inch terminus of the Allentown system. The LCA interceptor transports
wastewater from seven municipalities in western Lehigh County: Lower
Macungie, Upper Macungie, Upper Milford, and Weisenberg Townships and the
boroughs of Alburtis, Emmaus and Macungie. With the exception of Upper
Milford, where LCA provides direct service, the collection systems are owned
and operated by the individual municipalities. In the case of Emmaus, the LCA
interceptor transports approximately 60 percent of its wastewater to Keck’s
Bridge. In addition, portions of the Allentown and Salisbury sewer systems are
tributary to the Allentown interceptor, both at and below Keck’s Bridge.

The City of Allentown granted to the Lehigh County Authority the perpetual right
to convey sewage and wastes in an amount not to exceed 10 cubic feet per
second (c.f.s) through the Little Lehigh Creek Collector which runs from a point
at Keck’s Bridge to appoint at Shrieber’s Bridge in an agreement made
December 22, 1969.This grant or privilege was extended in consideration of
payment to the city of the charge of $0.02 per 1,000 gallons of sewage and
wastes discharged by the County Authority into the Little Lehigh Creek Collector
Sewer until an aggregate of $420,000 is paid to the city. However, this discharge
was subject to the condition that the 10 c.f.s limit might be exceeded by 20
percent for a period of two hours per day for no more than one day per work. The
city also agreed that in the event the Little Lehigh Creek Collector Sewer required
relief as a result of the above grant and privilege to the County Authority.
However, should the limits in regard to agreed upon waste loads be exceeded,
the County will either (1) make plans to reduce the maximum flow or (2) relieve
such sections of the Little Lehigh Creek Collector Sewer as shall be necessary.

It was also agreed that once a service connection had been made that resulted in
sewage wastes being delivered by the LCA interceptor to the Allentown
treatment plant for final disposition such sewage and wastes should not
thereafter be diverted until the LCA and the city agree to such diversion.
However, the County Authority reserved the right to establish such other
treatment plants as would be necessary for the efficient and economical
treatment of sewage and other wastes emanating from any of the municipalities
which by good engineering practice could not be delivered to the treatment plant
on a practical and economical basis and/or to handle the treatment and
disposition of sewage and other wastes which would result in the County
Authority exceeding its reserved capacity in the treatment plant.

Then too – the County Authority in order to comply with sewage and waste
discharge limitations as defined in the December 22, 1969 agreement (these
being the same limitations or restrictions detailed in Part Three, Installment Six)
was obligated to construct and operate or cause to be constructed and operated
all necessary pre-treatment facilities.

INSTALLMENT SEVEN

The composition of wastewaters depends on the origins and volume of water in
which the wastes are carried. Those waste streams coming entirely from
residential communities consist solely of human wastes, bathing and washing
water, and wastes from kitchens. Also, each additional connection to a public
sewer system adds to the volume the system must process. Consequently,
sizable communities must continuously deal with wastewater in astonishing
amounts. For example – a city of million inhabitants can expect about
100,000,000 gallons of wastewater a day, just from domestic sources. This
translates to more than 400,000 tons. Then too, wastewater volume from
commerce and industry may be added to the residential volume providing
variations in concentration and composition of the waste stream. And, of course,
storm water run-off can add to these volumes at brief but crucial intervals.

Certainly, these varied waste streams affect the efficiency of wastewater
treatment operations. It is logical that plants designed primarily for residential
waste streams would experience operational difficulties upon acceptance of
commercial and industrial waste streams. Therefore, former Allentown City
Engineer Earle W. Meckley was correct in his analysis that steps would have to
be taken to neutralize and equalize the commercial and industrial waste streams
that state decision-making and regional politics forced upon his administration of
wastewater treatment operations.

          ***                        ***                        ***

The Comprehensive Plan of the JPC, Lehigh-Northampton Counties indicated
that the percentage of new residential development served by public sewers
systems increased from the mid 1960’s until 1973 during the time when many of
the major suburban sewer systems were being built. Since 1973, however, the
percentage of new residential development served by public sewers has
decreased irregularly and then leveled off. In part, this decrease was attributed
by the JPC to the fact that the three major treatment plants in the region were
operating at or above capacity in the mid 1970’s.

Certainly, protracted negotiations in the Allentown area over sewage allocations
effectively limited the availability of sewage capacity somewhat, as did the delay
in the start-up of the Bushkill/Lower Lehigh sewer system. However, the
availability of new capacity in the late 1970’s at all three Lehigh Valley regional
plants was not sufficient to reverse the trend.

Obviously, other factors operate to contribute to the decline in the percentage of
new residential units using public sewers. What then are these factors? The JPC
offers the following examples in explanation of the decline in the percentage of
residential hook-ups:

1.The trend in the late 1970’s to construct large-scale, large lot developments
using on-lot sewage systems and individual wells or private water companies;
and

2.High interest rates have made it difficult for developers to finance major
developments requiring large up-front costs for sewers, waters and roads.

Concerning point one – the state by legislation (Act 537 – The State Sewage
Facilities Act which took effect October 5, 1973) encouraged the development of
on-lot sewage systems and individual wells or private water companies in the
case of large-scale large lot rural developments. Act 537 eased State Department
of Environmental Resources (DER) regulations requiring disposal permits for
rural residential lots of 10 acres or more, which were intended for use by no more
than two families. However, these developments would still be subject to more
stringent regulations imposed by individual municipalities to supercede the
relaxation of state controls.

Clearly, a primary advantage of on-lot disposal systems is their lower cost
compared to conventional collection, treatment and discharge alternatives.
Therefore, properly designed, installed, and maintained on-lot disposal systems
have shown to have a life expectancy of 20-30 years which is comparable to the
life expectancy expected of municipal sewage treatment plants. Nevertheless it
should be stressed that on-lot disposal systems require the continued attention
of the homeowners and, if not maintained or if abused, the properly designed
and installed system new system in good soil can fail, resulting in ground or
surface water pollution.

Concerning these on-lot systems and the JPC concern that the percentage of
residential waste streams using public sewers would increase back to the level
of the early 1973’s, we suspect that only in cases of the availability of public
service, township and borough regulations, or problems with malfunctioning on-
lot systems would homeowners with these on-lot systems elect to make hook-
ups to the regional system.

Concerning point two – the JPC itself is uncertain whether lower interest rates
would provide the incentive to increase the residential percentage to the early
1970 levels.

          ***                        ***                        ***

The impetus for the December 22, 1969 Sewage Agreement between Allentown,
Lehigh County, Lehigh County Authority and other signatories was the creation
in 1968 of an industrial park in western Lehigh County. With Kraftco Corporation
and Schaefer Brewing Company being the two major industries in this park.

Food processing and brewing of beer require large amounts of water, and the
effluent from these industries is high in suspended solids and BOD. Note-
suspended solids are added to wastewaters at an average rate of 0.2 pounds per
person per day in the United States. These are a burden on the receiving
waterways because of the BOD that the organic particles exert, the turbidity they
impart, and the sludge deposits that can build up in the stream.

Suspended solids are classified as either fixed or volatile. The fixed are
essentially inert; the volatiles make up the organic portion suitable for biological
degradation or incineration. Suspended solids are also classified as settable or
nonsettable, with the former readily removed by a period of quiescence in a
sedimentation tank (primary treatment), and the latter requiring removal by other
means (secondary treatment).

BOD is the oxygen required for the biochemical breakdown of organic matter in
wastewater, and is determined by measuring the amount of oxygen used by
decay microorganisms in a sample of the wastewater over a specific period of
time (usually 5 days) at a specific temperature (usually 68o). The BOD indicates
the impact that the wastewater can be expected to have on the oxygen content of
the waterway receiving the waste. Too much BOD means not enough oxygen for
fish and other marine life to sustain life.

Not mentioned above, but the evaluation of wastewater quality also includes
tests for acidity or alkalinity, and the type and quantity of microorganisms found
in it.

Acidity and alkalinity can be toxic to microorganisms that are used in wastewater
treatment. Generally, domestic wastewaters are neutral (neither acid or alkaline),
but industrial wastes can tip the balance one way or the other. When this occurs,
the wastewater must undergo special pre-treatment to render it neutral again.

The 1969 Sewage Agreement obligated the County Authority to construct and
operate or cause to be constructed and operated all necessary pre-treatment
facilities.

          ***                        ***                        ***

Allentown’s Kline’s Island Wastewater Treatment Plant is one entity in the
Allentown Metropolitan Wastewater District responsible for the processing of all
incoming categories of wastes streams (that is-residential, commercial or
industrial). It is also the one entity responsible for complying with the Federal
Water Pollution Control Act provisions including meeting quality limitations set
under the National Pollutant Elimination System (NPDES) permit. It is responsible
to the Pennsylvania Department of Environmental Resources (DER) for
compliance under the Pennsylvania Clean Streams Act. Also, it must receive
permission from the Delaware River Basin Commission (DRBC) to increase the
flow of effluent from the plant into the Lehigh River, a tributary of the Delaware
River.

The 1969 Sewage Agreement committed the city to increase the processing
capacity of its existing wastewater facility from a rated hydraulic capacity of 28.5
mgd under normal operations to that of 40.0 mgd under similar conditions. The
project was expected to cost $17.6 million. Interestingly, DER in 1974 without any
expansion of plant capacity rated the Kline’s Island Plant at 31.0 mgd.

In regard to proposed treatment plant enlargement, Metcalf & Eddy, Allentown’s
Engineering Consultant, believed that the upgrading of hydraulic capacity to 40.0
mgd would not alter dramatically the basic sewage effluent characteristics as
exhibited in the existing plant. Under normal operating conditions, Metcalf &
Eddy believed the treatment plant would continue to produce an effluent monthly
average quality of 30 mg/L Suspended Solids, 20 mg/ BOD and 3 mg/L Ammonia
Nitrogen during the summer (June 1 to October 31). During the winter (November
1 to May 31) the Ammonia Nitrogen levels would be 9 mg/L.

Of course, with increased input or processing capacity, the output or effluent
would increase as well. Consequently, Allentown was obligated to present the
case for increased outflow into the Lehigh River before the DRBC even if effluent
sewage characteristics remained the same.

Interestingly, printed data before the DRBC indicated that the project would alter
the ration of industrial to residential capacity. In 1973, the plant was rated for 8.1
mgd of industrial sewage to 20.4 of residential waste. With expansion the
industrial capacity rating would be increased to 18.6 mgd while the residential
allocation would be increased only slightly, to 21.4 mgd.

          ***                        ***                        ***

In analysis, we conclude by these figures that Allentown officials believed that
most of the economic development activities in western Lehigh County would be
industrial in nature rather then residential. Allentown officials believed that
workers in these new industries in western Lehigh County would choose to
reside in the city instead of locating in the suburbs and rural areas.
Consequently, Allentown officials thought that the city would benefit by
economic or industrial activity in western Lehigh County through a gain in taxes
collected from wages of those Allentown residents working in western Lehigh
County but living in Allentown.

But from our advantage point in the future we can only conclude that Allentown
officials did not envision the impact that large lot, rural on-lot development might
have on residential living patterns; and surely, neither did they comprehend or
understand the desire of many Americans to live in open uncrowded conditions.
A fact of life or dream made possible or inevitable by he availability of motor
vehicle transportation.

Importantly, it can be debated whether the development of utility infrastructure
such as water and sewer systems serves as a catalyst to attract homes and
businesses or whether such systems are developed in response to the
development of homes and businesses.

Interestingly, public officials for the Lehigh County have repeatedly stated that
their agency does not promote growth but only responds to it. The claim
repeated March 18, 1986 by Aurel Ardnt, General Manager of the LCA, at a forum
on Authorities sponsored by the Allentown Area League of Women’s Voters. But
just the same, at a September 12, 1979 meeting of the Lehigh County
Commissioners, Harry Forker characterized the LCA as “public enemy number
1.”

Please note – at the same meeting, Bethlehem Steel Engineer Bruce Mordaunt of
Breinigsville, PA called for the end to Lehigh County subsidization of sewer and
water systems in the farms and fields of western Lehigh County. Mordaunt
feared that such subsidization provided the economic incentive for developers
to slice up the before said open space and greenery.

Mordaunt, of course, wished to channel the economic energies of these
developers in different directions. The fact was, Mordaunt believed that the
economic energies of these developers ought to be city-oriented; and that,
economic disincentives should be developed to restrict economic growth
activities in the farmlands of western Lehigh County.

In other words, Mordaunt believed that the price tag for sewer and water
development and extension should be purposely made costly as to restrict
widespread development in the County. Mordaunt maintained that such utilities
should be paid homeowners and developers directly as an economic
discouragement to the slicing up of valuable open space resources.

We note – Forker and Mordaunt argued unsuccessfully September 12, 1989
against the Lehigh County Board of County Commissioners approving a new
line of credit for the Lehigh County Authority totaling about $4.4 million to
refinance “old debt” and permit some expansion of the LCA system in western
Lehigh County.

          ***                        ***                        ***
For the historic record, the DRBC approved Allentown’s application October 31,
1973 without verbal testimony from George A. Kandra, Allentown’s Director of
Operations, who was present for the hearing. Kandra on October 17, 1973
announced his intention to leave the post effective December 1, 1973 unable to
procure public statements for retention from both candidates in the 1973 race for
Mayor. After Kandra’s announcement, LeRoy S, Bogert, the Republican
candidate, commented: “ I think I would have retained Kandra. I think he did a
tremendous job.” Joseph S Daddona, the Democrat candidate, praises Kandra’s
performance as operations director. Although he was noncommittal as far as his
response to a question whether he would have kept Kandra on the job.

Allentown, of course, could not commence construction activities concerning
the planned expansion until state and federal approval was granted.

Then again, the Nixon administration’s impoundment of $9 billion in appropriated
federal funds of which Pennsylvania’s share was $500 million and changes in
federal regulations based on a new ranking system delayed consideration of the
Allentown sewer project to fiscal 1975 and beyond. Dr. Maurice K. Goddard,
Secretary of Pennsylvania’s Department of Environmental Resources, in
addressing the opening sessions of the 38th annual Pennsylvania Local
Government Conference in Hershey, revealed in March 1974 what he said was
the first public announcement of DER’s revised priority list for Pennsylvania
sewer projects. Out of 198 state projects, Allentown’s Kline’s Island Wastewater
Treatment Plant expansion project ranked 35th on the priority list. Unfortunately
for Allentown’s expansion plans, funding was available only for the first 32
projects. Consequently, state consideration of Allentown’s sewer project was put
on the back burner awaiting future federal appropriations.

          ****                        ***                        ***

In regard to evaluation of the type and quality of microorganisms found in
wastewater, a variety of viruses and other microorganisms, especially the enteric
organisms that inhabit the intestines of man and other warm-blooded animals,
are found in large numbers in wastewaters, A small amount of these are
pathogenic, associated with such diseases as cholera, typhoid, and dysentery,
and their identification is difficult. So, for routine purposes, the presence of
certain enteric indicator organisms, including the coliform group, provides
evidence that pathogens may be present. Human wastes discharged each day
about 1,000,000 coliform organisms per person. All residential or domestic
wastewaters, for that reason are heavily loaded with coliforms, and a measure of
their numbers indicates the overall degree of water contamination.

Drinking water standards set forth by the U.S. Public Health Service require that
an average of no more than one coliform organization be present in a 100-
milliliter sample of water. Such low coliform concentration suggests that
pathogenic organisms probably are not present.

With hundreds of thousands of coliform organisms per milliliter usually present
in ordinary wastewater, and conventional wastewater treatment able to remove
only 99 to 99.9 percent of them, chemical Disinfection is necessary if the water is
to be reused.

Where water requires Disinfection, chlorine demand becomes important;
chlorine is the most widely used disinfectant. Generally, the higher the degree of
wastewater treatment performed, the lower the chlorine demand of the treated
effluent is likely to be.

Significant concentrations of nutrients especially nitrogen and phosphorous
compounds, are found in residential wastewaters. Together with fertilizers used
on cultivated fields, these promote the growth of large populations of algae and
other organisms (eutrophication) in receiving waterways and may interfere with
normal ecological balance there.

Heavy metals and synthetic compounds in wastewaters cause special problems,
as high concentrations tend to interfere with the treatment processes. The heavy
metals, mercury and lead, are toxic to animal life including humans. What's more,
some of the synthetic organic compounds, including insecticides such as DDT
can be toxic and can be dangerous if they enter the water supply or food chain.

          ***                        ***                        ***

Related to the possible long-term or short-term introduction of potentially
harmful microorganisms and toxic material into the Allentown drinking water,
John P. Durr, Regional Sanitary Engineer, Pennsylvania Department of
Environmental Resources, in a letter to George A. Kandra, Director of operations,
City of Allentown dated February 20, 1973 cited the city for illegal surcharges
(overflows) from the Emmaus Interceptor and, ordered the city to take immediate
corrective steps. In all probability, City of Allentown lack of compliance with the
DER citation might have proved detrimental to continue growth activities in
western Lehigh County. A situation that would not be favorable to certain
interests whether these interests are economic, social or political. The reason –
Durr threatened to disapprove any city, township or borough request for the
extension of any jurisdictional trunk line until the overloading at the wastewater
treatment plant and the trunk line paralleling the Little Lehigh Creek was relieved.
In response, Kandra, obediently, informed Durr in a letter dated March 20, 1973
that he would notify the Lehigh County Authority, Salisbury Township and South
Whitehall by April 1, 1973 that the City required for its own use the existing
design capacity of the trunk line that prompted Durr’s citation and concern. (A
1.2-mile trunk line along the Little Lehigh Creek, running from Shrieber’s Bridge
to Fountain Park.) And additionally, that by April 1, 1974 a relief interceptor had to
be constructed by said governmental or quasi-governmental units for their own
use. Historically, we have evidence that Kandra, in fact, made contact with the
western Lehigh County signatories of both the 1965 and 1969 sewage
agreements for the Kandra mandate to the said signatories was publicly
announced in the media October 25, 1973.

According to Metcalf & Eddy, Allentown’s Engineering Consultant, the cost of the
parallel line would cost $300,000 and design engineering, including
topographical studies would add another $20,000 to $25,000. It was anticipated
that the Allentown Authority, the official owner of the city system, would act as
the financing agent for the 1.2-mile sewer line to be used by suburban
municipalities, But in actuality the entire cost of the line ordered by the state was
projected to be borne by the suburban municipalities that would use it through
reimbursements to the city authority.

Interestingly, the April 1, 1974 deadline passed due to the failure of the city and
the three signatories to draft contract agreements regarding construction,
ownership, maintenance, financing, administration and other matters. The
agreement had to be finalized before money could be borrowed for construction
and construction undertaken.

George A. Kandra, of course, left the post of Allentown Director of Operations
December 1, 1973 to assume an assignment with A.L.
Wiesenberger Associates. Kandra’s successor Harry Bisco did not begin his
assignment until April 15, 1974 more than three and a half months into the new
Daddona Administration. Prior to his appointment as Allentown Director of
Operations, Bisco had served the previous thirteen months as public works
director for Middletown, New Jersey. Prior to that, Bisco served the previous year
as project director for Kammerer, Symes & Associates, Inc., Cherry Hill
engineering consultants. Before that, Bisco was Public Works Director for
Cherry Hill Township Pollution Control and other areas of public works. Bisco’s
department had a $5-million capital budget and an annual general budget of $3.5-
million.

Joseph S. Daddona said upon Bisco’s appointment March 23, 1974 that he was
confident that he had picked the most available man capable to assume the
responsibilities of Allentown Director of Operations. Intriguingly, the selection
process to choose a new Allentown Director of Operations left the city’s
ultimatum to its western Lehigh County sewer customers in limbo. Kandra’s April
1, 1974 deadline passes before Bisco took over the helm of the Allentown
Department of Operations.

As it happened, the parallel line so ordered by the state turned out to be the
temporary “Green Monster” constructed in the Lehigh Parkway during the Frank
Fischl Administration. In 1984 the so-called “green Monster” was removed after
the Lehigh County Authority released its plans to build a permanent “piggy-
back” relief line parallel to the present line in the parkway to alleviate overflow
problems at Keck’s Bridge and other locations.

INSTALLMENT EIGHT

In June and July of 1969, the County of Lehigh signed separate agreements with
the F. & M. Brewing Company and Kraftco Inc. to provide permanent water and
sewer service in exchange for the industries locating new facilities on route 100
near the Trexlertown/Fogelsville Interchange on Route 22 in Upper Macungie
Township. Lehigh County. Both industries produce high strength wastewaters
that required pre-treatment to avoid the potential of harmful impact on host
municipal sewer systems designed primarily for residential treatment purposes.
The reason being, municipal sewer systems are highly susceptible to
interference and upsets from a variety of sources and pollutants. The County as
part of the agreement voluntarily assumed all costs for pre-treatment, and also,
subsidized treatment bills.

On the other hand, an intergovernmental sewage agreement with the City of
Allentown in which the County of Lehigh was party to required that pre-treatment
facilities be constructed to service the waste loads of the anticipated western
Lehigh County industries. The County by contractual agreement was
responsible to the City to comply with sewage and waste discharge limits
(examples being suspended solids, BOD, pH, copper, zinc, etc.) as defined in the
December 22, 1969 agreement and was obligated to construct or operate or
cause to be constructed and operated all necessary pre-treatment facilities. Of
course, the County by prior agreement with its industries had chosen to
construct and operate the required pre-treatment facilities by itself and through
an Authority it in fact created to service growth activities in western Lehigh
County.

As it was agreed, the townships of Upper and Lower Macungie and the
Boroughs of Macungie and Alburtis are served by the Lehigh County Authority
(LCA) which was authorized by the County of Lehigh to acquire and construct a
County interceptor system for the transportation of wastes to the Allentown
Sewer System. The inceptor system is leased to the Lehigh County, with LCA
serving as an agent for operation and maintenance.

A.L. Wiesenberger Associates designed the Little Lehigh Watershed Sewer
Complex project, as it was then known. Arthur L. Wiesenberger had sought the
support of then Allentown City Councilman and Director of Streets and Public
Improvements, Joseph S. Daddona, to facilitate the design and construction of
his project. Daddona’s aid was needed to guarantee that the Lehigh County
Authority would be granted the privilege to have its sewage and wastes
conveyed to the city’s treatment plane for treatment and disposal.

Waste from the County Interceptor enters the Allentown system at Keck’s Bridge,
approximately ten miles downstream from the site of the County pre-treatment
plant in Upper Macungie Township, a facility that A.L. Wiesenberger Associates
had also designed and constructed. Treatment is provided at the City’s Kline’s
Island Treatment Plant, about six miles downstream from Keck’s Bridge.

          ***                        ***                        ***

A letter jointly signed June 30, 1969 by the Lehigh County Commissioners
(Donald B. Hoffman, Harley S. Steward, Sr., and George A. Stahl), a
representative of the Lehigh County Authority (Chester T. Dutton) and
representatives of Upper Macungie (Harry K. Johnson and Kermit C. Haas) and
addressed to Mr. R.J. Schaeffer II, President of the F. & M. Schaefer Brewing
Company underscores these important points in regard to the providing of water
and sewer service to the F. & M. Schaefer Brewing Company by the County or its
agent, the Lehigh County Authority.

1.        Sewer and water figures are presented on the basis of 250 operating days
and 859,000 gallons per day average discharge for sewer during Phase I and
1,700,000 gallons per day sewer discharge in Phase II; 1,1 million gallons per day
average usage of water during Phase I and 2.2 miller gallons average use of
water during Phase II.
2.        Rates as follows:

  Phase I                        Phase II
Maximum        Per Year        Minimum                Per Year
Water        $150,000                $77,000                $154,000
Sewer        $150,000                $75,000                $150,000
                          
Total        $300,000                $152,000                $304,000

•        The minimum sewer figure during Phase I is on the basis of Kraft coming on
target at the same time as Schaefer.
•        The maximum is on the basis of nobody else of significance coming on
target.
•        The $.35 sewer figure is on the basis of a usage of 1,700.000 gallons per day.
•        The maximum sewer figure is on the basis of only the Schaefer 850,000 per
da, or approximately $.61.
•        The Phase II sewer figure was computed on the basis of 1,700,000 gallons
daily and 250 days, or 425 million gallons per year times $.35.
•        The $.28 water figure is on the basis of 2,2 million gallons per day usage

        Please note – The County anticipated erroneously that there would be
further reductions of water rates upon the completion of the Trexler Dam. The
fact is, citizen opposition led to the cancellation of the Trexler Dam project.
Consequently, no anticipated reduction in water rates due to the availability of
Trexler Dam could ever materialize. In spite of this, the above outlined figures
should not be construed as precluding the availability to Schaefer of any lower
rates that may be available to volume users. What is more, there would be foot
assessments for both sewer and water on the same basis as all other users –
domestic, industrial or otherwise. But most captivatingly, there would be no
special charges or assessments to Schaefer by virtue of diatomaceous earth
discharge, BOD content or otherwise and whether in the nature of surcharge, pre-
treatment charge or penalty.

3.        The industrial wastes would have the following Maximum strengths:
a.        BOD: 1,100 mg/L
b.        Suspended solids: 300 mg/L
c.        Acidity or Alkalinity (pH): 7.0 Ave, pH ranges: 5.0 to 9,0
But a benefit for Schaefer would be this. Schaefer would also have the right to
discharge diatomaceous earth directly into the sewer systems without pre-
treatment, leaching, or surcharge over twenty-four hours of time.
4.        The County expected that its sewer and water systems servicing the
brewery would be operational on or before August 1, 1971.

***                        ***                        ***



A letter dated July 10, 1969 from the Kraftco Corporation Vice President of the
Kraft Foods Division to the Township of Macungie, the Lehigh County Authority
and the County of Lehigh underscores these salient points in regard to the
purchase of real estate and the development of necessary public roads, storm
sewers, sanitary sewers and water service to facilitate operations at the
proposed food, edible oil and fats processing plant in Upper Macungie Township.

1.        Win the assistance of the Lehigh Economic Advancement Project (LEAP),
enough real estate was procured in Upper Macungie Township to facilitate plant
construction and future growth needs. LEAP would hold title to the parcel where
the plant would be constructed until construction activities at the site were
completed.
2.        Upper Macungie Township, without cost or expense to Kraftco, agreed to
construct and install or cause to be constructed and installed a public road from
Schantz’s Spring Road southerly across the Kraftco Corporation real estate on
and along a 100-foot right=of-way and extending southerly or southwesterly over
an additional 100-foot right-of-way to Route 100. To facilitate the project Kraftco
loaned Upper Macungie Township a sum not to exceed $100,000, interest-free,
repayable over a period of five(5) years.
3.        Upper Macungie agreed to construct and install or cause to be constructed
and installed a public storm drainage system adequate to provide storm drainage
for the Kraftco Corporation food, edible oil and fats processing and packaging
plant in Upper Macungie Township. Storm drainage capacity included the ability
to carry away and dispose of unpolluted water used for cooling purposes.
4.        The Lehigh County Authority and the County of Lehigh, in conjunction
with Upper Macungie Township agreed to construct and install or cause to be
constructed and installed a public water supply system, including source of
supply and distribution system, to service the planned Kraftco Corporation food,
edible oil and fats processing and packaging plant in Upper Macungie Township.
Providing said plant with water of sufficient pressure, quantity and quality to
meet operation needs. ( Note – the physical and chemical properties of water
supplied should conform to Public Health Service drinking standards for all
elements.)
5.        The same parties agreed to construct and install or cause to be
constructed a public sewerage system, including sewers and sewage treatment
facilities adequate to collect, treat and dispose of the sanitary sewage and
industrial waste deprived from Kraftco Corporation food, edible oil and fats and
packaging plant in Upper Macungie Township

Note – the County agreement with Kraftco specified the following wastewater
characteristics Kraftco would be responsible for meeting: 0.60 MGD, 2500 mg/L
BOD, and 400 mg/L suspended solids.

6.        All involved governmental units and authorities agreed that the public
water supply system and the public sewerage system would be financed and
constructed by the Lehigh County Authority and operated by the County of
Lehigh.

SUMMATION

The Upper Macungie Pre-treatment Plant (also referred to as the Trexlertown Pre-
treatment Plant) first received sewage for shakedown in April of 1972, with
continuous operation begun in August of the same year.

As party to the December 22nd Sewage Agreement of 1969, the Lehigh County
Authority (LCA) promised “to use all reasonable methods and due diligence to
prevent the discharge into the Kline’s Island Wastewater Treatment Plant of any
waste, industrial or likewise, which is dangerous to public health and safety or in
violation “of any of the required effluent characteristics as defined in the 1969
agreement.

Unfortunately, the Upper Macungie Pre-treatment plant did not perform as was
expected. Operational difficulties were experienced throughout the operation of
the plant, and to such extent that discharge requirements were not being met.

On one occasion, the city sought evidence that LCA was violating the terms of its
1969 contract. In July, 1973 the Kline’s Island Wastewater Treatment Plant was
rendered inoperable by a “slug” of unidentified material, which passed through
the plant. The bacteria necessary for the treatment of the wastewater in the
Trickling Filters were killed. Consequently from July 18 to July 28, 1973, Metcalf &
Eddy, Allentown’s Engineering Consultant, conducted a study of the effluent
coming from the Upper Macungie Pre-treatment Plant. The study showed
excesses of
suspended solids, BOD, and pH above the limits set in the 1969 agreement. In
addition, violations of the 1973 City Ordinance in regard to levels of heavy metals
such as copper and zinc were found.

Then too, periodic severe odor problems resulted in numerous community
complaints. The County and Wiesenberger Associates, its design consultant,
made various efforts to improve plant performance. Actions included the hiring
of a second design consultant, Malcolm Pirnie of White Plains, New York, in 1973.
But all these efforts had no marked success. Consequently, in the spring of 1975
the LCA Pre-Treatment Plant was taken off line,

As it developed, the County of Lehigh paid all costs associated with the pre-
treatment plant in Upper Macungie Township, the initial and subsequent re-
engineering costs, only to have the facility fail to operate properly. The failure of
the pre-treatment plant, also meant additional costs for the County, for the
County was forced to absorb all costs associated with the LCA chemical feed
stations in the attempt to reduce or alleviate odor and corrosion in the LCA
interceptors resultant from the existence of high strength waste streams in the
line.

Consequently, Allentown Mayor Joseph S. Daddona who as City Councilman
and Director of Streets and Public Improvements in 1968-69 had facilitates Arthur
L. Wiesenberger’s Little Lehigh Sewer Complex and pre-treatment projects by
promoting the 1969 Sewage Agreement now was forced to accept the untreated
high strength waste from the industries in western Lehigh County for processing
in a plant that was itself experiencing capacity difficulties. In addition, this high
strength waste had to travel many miles through an interceptor that was judged
to be overloaded by the State and which during wet weather overflowed into the
Little Lehigh Creek, one of Allentown’s prime water sources. Problems, which in
1984, all the king’s horses and all the kings’ men still endeavored to solve.

          ***                        ***                        ***

In 1969 the City had agreed that the permanent daily wastewater allocation
reserved for the LCA as of January 1,1976 for treatment and disposal in an
improved and expanded Kline’s Island Wastewater Treatment Plant would be 4.5
mgd with 4.) allowable in the interim between signing of the sewage agreement
and the date that LCA’s permanent wastewater allocation would take effect.

Then too, by agreement, once a service connection had been made that resulted
in wastewater being delivered to the treatment plant for final disposition, such
wastes should not from that date be diverted elsewhere unless mutually agreed
by the County Authority and the City. However, the County Authority reserved
the right to construct such other treatment plants as may be necessary to serve
its client municipalities in western Lehigh County. Such treatment facilities being
needed when the County Authority exceeded its reserved capacity in the
Allentown plant.

Interestingly, in October 1973 when Allentown sought the Delaware River Basin
Commission approval to expand its plant from a hydraulic capacity of 28.5 mgd
to that of 40.0 mgd, the Lehigh County Commissioners were mulling a separate
system to service western Lehigh County. The Commissioners believed that the
metropolitan system, even expanded to a capacity of 40.0 mgd would not be
large enough to handle the growth anticipated for suburban Lehigh County.

Indeed, the Commissioners, under orders from the City of Allentown to provide
relief to an overloaded interceptor susceptible to overflow in wt weather and
entangled with problems with their own pre-treatment plant in western Lehigh
County, were concerned about meeting the needs of the industries in western
Lehigh County.

          ***                        ***                        ***

In January 1973 the Allentown Authority held title to a sewage collection system
(including interceptor sewers, trunk sewers, branch sewers, outfall lines and
service lines) and a sewage treatment plant located on Kline’s Island along the
Lehigh River near the place where the Little Lehigh Creek flows into the Lehigh
River. The Allentown Authority whom owned the Allentown Sewer System leased
the System to the City for use and operation under an Agreement of Lease dated
May 1, 1960.

In sum, these two entities through their delegated function are responsible for
the Allentown Sewer System operation, maintenance and debt service for the
plant and sewage collection system. Also, when environmental problems arise, it
is these two entities that had to deal with public pressure from near citizens and
correct these problems under the Pennsylvania Department of Environmental
Resources persistence. Surely, it would be expected that the legal
representatives for these two entities would write into legal agreements that
extended the facilities of the Allentown Sewer System to other municipal users
certain provisions protecting the system from harmful properties attributable to
the actions of the users.

In analyzing the 1969 agreement, this appearance of protection is suggested by
the following provision:

“ Section 11- Subject to the provisions of Section 4, County Authority further
agrees that it will cause to have enacted and enforced ordinances, resolutions,
rules and regulations governing sewer connections and the admission of
sewage into the sewers, which ordinances, resolutions, rules and regulations
shall conform with existing ordinances, rules and regulations of the City and
further agrees to cause to be enacted and enforced additional ordinances,
resolutions, rules and regulations to conform with future ordinances, rules and
regulations adopted by the City to govern the admission of sewage into the
Allentown Collection System or the Treatment Plant.”

But incredibly, the City in January 1973 still did not have a comprehensive
sewage ordinance. And also, the right of the County Authority to construct at any
time such treatment plants to service the sewage requirements of western
Lehigh County when combined with the stipulations found in Section 2D risked
the possible ruination of the City watershed and its superb parkway system.

By design or accident Section 2D of the 1969 agreement stipulated:

“ Whenever the City does not require or desire to share in the use of such
sewers, County Authority, singly, or in conjunction with other parties, may
provide for the construction and financing thereof. In order to facilitate
installation of required facilities as contemplated in this paragraph, City shall
grant required rights of way, easements, licenses and privileges in, over and
under City streets. Lanes, highways, roads and other City-owned properties for
the purpose of construction, maintenance and replacement of such facilities
without consideration or charge and shall otherwise cooperate in such required
construction and acquisition of property or interests in property subject to
approval of City Engineer as to location. The aforesaid grant shall be subject to
all City ordinances and regulations relating to the manner of opening the surface
and the repair of streets, lanes , alleys, highways and roads.

Note – we have underlined a certain part of Section 2D to underscore the
omission of other city properties in the provision subject to City ordinance.
Whatismore the passage of a comprehensive city ordinance April 18, 1973 did
not correct that omission.

PART FIVE

PREFACE

Historically, backwater has been known to discharge from the rain submerged
and overloaded Jordan Creek, Trout Creek and Little Lehigh - Section One Trunk
Sewers (Constituting the lower portion of the Allentown Wastewater Interceptor
System) and flood private property immediately adjacent to such trunk sewers,
the cause diagnosed as too high level of sewage entering the wet wall of a
pumping station associated with operations at the Kline’s Island Wastewater
Treatment Plant. Consequently, it would be advantageous for Allentown in light
of its December 22, 1969 agreement with the Lehigh County Authority (LCA) to
resolve the before stated problem. After all, as the LCA system expanded toward
full development and its sewage flows approached design values, the before
mentioned homegrown backwater effect would become more pronounced and
extensive if nothing else was done to otherwise resolve the problems. (See
FIGURES THREE AND FOUR)

          ***                        ***                        ***        

It is recognized and certain amount of infiltration of groundwater and inflow of
surface drainage (I/I) enters nearly every sanitary sewer system. And, of course,
such extraneous flows increase significantly during and after maximum storms.
The content of these flows consisted of raw sewage according to Pennsylvania
Department of Environmental Resources estimates.

Unfortunately, for those promoting growth in western Lehigh County, this fixed
reality constitutes a barrier to continued commercial and residential growth
upstream. That is, every gallon of I/I gained means a gallon of genuine sewage
capacity not available for legitimate use.

          ***                        ***                        ***

Most assuredly, the twin occurrences of I/I and upstream interceptor line
bottlenecks or restrictions has served to guarantee that a Lehigh County
Authority- City of Allentown public highway froe sewage would at times become
surcharged (that is, becomes overloaded) and would discharge its contents on
land and in stream immediately adjacent to its gravity flow course.

Understandably, the LCA-Allentown public highway through Allentown’s Lehigh
Parkway for incoming sewage and wastewater derived from and for the benefit of
Sewered developments in western Lehigh County has been a source of
longstanding complaint.

Indeed, sewage overflows have occurred in the Little Lehigh Creek (a major
source of Allentown’s drinking water) in the vicinity of Schrieber’s Bridge – that
is, the junction of the 36-inch Emmaus Interceptor and the 27-inch Little Lehigh
Trunk Sewer. Then too, such overflows have also occurred at Keck’s Bridge
where the LCA’s 36-inch sewer line for Western Lehigh County connects into the
City’s 24-inch Emmaus Interceptor from Emmaus and Salisbury Township. The
problem occurring at two manholes, which are located on the north bank of the
Little Lehigh Creek. One manhole located approximately 160 yards upstream
from Keck’s Bridge, the other 230 yards upstream.

We note – this public highway can handle all sewage flows during normal
periods of use. However, during peak flow periods (mainly wet weather
conditions), the incoming flow historically has exceeded the carrying capacity of
the Allentown Interceptor. The consequences being – the interceptor becomes
surcharged and discharges raw sewage into the Little Lehigh Creek (a
“Conservation Stream.)

Indeed, the problem was and may still be inevitable because the existing
interceptor was built in bottlenecks. That is, places where larger, newer lines
send sewage into smaller lines thereby causing predictable back-ups.

What-is-more, increased flows increase the hydraulic pressure within the line
thereby requiring relief at some point when restrictions occur. Naturally, this
relief ultimately would occur at the weakest point or points in the system; and of
course, it is inevitable that step-by-step symptomatic treatment of a serious
problem might not render adequate resolution to the whole problem.

In other words, the systematic sealing of manhole castings including the
replacement of bolts in covers of watertight castings in certain manholes along
the interceptor might work to transfer the problem elsewhere rather then promote
permanent relief; and more importantly, such remedial activity might be counter-
productive toward continued Sewered development upstream.



INSTALLMENT ONE

Harrison E. Forker, a colleague of mine in the Lehigh Valley Council for Regional
Livability, Inc. has made comment in notes dated, December 5,1983 in regard to a
Scott Bieber by-lined article appearing in a local Allentown newspaper.

Forker inferred that the infiltration/inflow (I/I) problems as described by Bieber for
the Keck’s Bridge Area was not just isolated to the Keck’s Bridge location but
also existed at other points in the inter-connecting Lehigh County Authority
(LCA) – City of Allentown wastewater collection system. Consequently, the
problem was not just one that concerned solely the LCA, but also an Allentown
concern as well.

Indeed, Forker was right!

After all, the operators of Allentown’s wastewater treatment plant needed to
determine the characteristics of the incoming flows in order to process it
properly.

***                        ***                        ***

What Forker did not reveal December 5, 1983 was Allentown’s past concern in
regard to the infiltration of groundwater into its system prior to the LCA hook-up
and prior to the Daddona era in Allentown’s history.

***                        ***                        ***

Metcalf & Eddy’s  “Report to Allentown Authority, Allentown, Pennsylvania, On
Enlargement of Sewage Treatment Plant” --- September 1964 noted that pumping
records at the Kline’s Island Wastewater Treatment Plant showed an almost
immediate increase in flows during times of rainfalls with intensities greater than
0.1 inch an hour. Consequently, the Allentown City Council in 1965 felt the need
to check the possibility of excessive groundwater infiltration into the interceptor
and collector system.

Accordingly, Metcalf & Eddy was authorized by resolution No. 20487, dated
January 5, 1965 to perform the following service:

“Make measurements of sewage flow in sewers at 14 stations during wet
weather, then repeat the measurement again at the same hour and place on a dry-
weather day one week later. A third series of measurements were to be obtained
on a dry-weather day during the peak period of the day. These measurements
were to consist of depth of sewage flow in sewers and velocity measurements at
each of the 14 stations.”

Unfortunately, rainfall conditions during the gauging period were not conducive
to producing maximum wet-weather sewage flows. Gaugings were made in the
midst of a “most unusual and long-sustained drought.” Not only had there been
a marked deficiency in rainfall in the months proceeding the gauging study, but
also during the months of July 1965 through April 1966, when the gauging was
made. The total rainfall deficiency was 11.56 inches. During this period, stream
flows and groundwater levels were unusually low. As a result, eventhough
substantial amounts of rain fell on some of the gauging days, flow conditions in
the sewers could not be assumed to represent the conditions that would occur
during long-sustained periods of heavy rainfall and high groundwater levels.

In any case, Metcalf & Eddy’s “Report to City of Allentown, Pennsylvania on 1965-
66 Trunk Sewer Gauging” was released to the Allentown Council July 2, 1969.

***                        ***                        ***

(Please note – Joseph S. Daddona having succeeded Lloyd E. Grammes as
Allentown City Councilman And Allentown Director of Streets and Public
Improvements in 1968 was the man vested with the responsibility of accepting
and reviewing the report in 1969.)

***                        ***                        ***

On the positive side, Metcalf & Eddy concluded the observed flows from storm
water were not caused by excessive infiltration as formally believed, but were
due primarily to roof drain connections and needed repairs on some trunks.

But negatively, Metcalf & Eddy noted that discharges from sewers in low areas of
Allentown had been caused by water backing up from the wet wall at the Sewage
Treatment Plant. A study of the sewerage system showed that such flooding was
believed to be caused by allowing the sewage level in the wet well to reach a too
high an elevation. For example, if the wet well was allowed to fill to Elevation 7.5
or higher the backwater would flood out the trunk sewers for some distance.

Under such circumstances, Metcalf & Eddy expected the Jordan Creek Trunk
Sewer to be submerged for about one mile from the sewage treatment plant.
Similarly, the flooding in the Trout Creek Trunk Sewer would extend about one-
quarter mile from its mouth, and the Little Lehigh Trunk Sewer would be affected
up to the 24-inch river crossing at the upper end of Section One.

Then too, Metcalf & Eddy admitted the flooding of these trunks would cause
sewage to back-up in the lateral sewers and, in some cases, be forced back into
private property. This worst-case scenario, of course, would encourage the
formation of deposits in the laterals, as well in the trunks, and thus, increase
cleaning costs.

For that reason, Metcalf & Eddy recommended it would be advantageous for the
city to maintain sufficiently low sewerage levels in the wet well as to avoid
significant backwater effects. Why? As the Lehigh County Authority tributary
area approached full development and the sewage flows approached design
value, the problem would become more pronounced and expensive.

***                        ***                        ***

In regard to the LCA – Allentown public highway for sewage through Allentown’s
Lehigh Parkway, Metcalf & Eddy predicted that Sections 1 & 2 of the Little Lehigh
Creek Trunk Sewer would need relief at full development. This was especially
true of Section 2, as the expected flows in 1990 would exceed the 1969 capacity
by more then 50 percent. Peak flows beyond 1969 capacity would require a 30-
inch relief line running from the junction of the Little Lehigh Creek Collection
Sewer (also known as the Emmaus Interceptor) and the Little Lehigh Creek
Trunk Sewer, Section 2, to the twin 24-inch pipe river crossing at the upper end
of the Little Lehigh Trunk Sewer, Section 1, a distance of some 5,350 feet.

But from the standpoint of long-range city livability and common sense
environmental preservation, we must assert that the December 22, 1969 Sewage
Agreement between Allentown and the LCA at the beginning of the Daddona era
should not have given the LCA the free license to deteriorate Allentown’s
Parkway/ watershed environment in order to provide relief to the LCA –
Allentown public highway infrastructure.

INSTALLMENT TWO

Former United States President Richard M. Nixon in a message to Congress,
August 1970 said:

“We have treated our land as if it were a limitless resource. Traditionally,
Americans have felt what they do with their own land is their own business.
Today we are coming to realize that our land is finite. The uses to which our
generation puts land can either expand or severely limit the choices our children
will have. The time has come when we must accept the idea that none of us has a
right to abuse the land, and that on the contrary society as a whole has a
legitimate interest in proper land use.”

In analysis, these remarks represent an activist position for regional or local land
use planning from a President who was thought of as being moderate or slightly
conservative in policies. Importantly, this presidential initiative would serve to
heighten or spark land use debates (that is, agricultural versus residential,
agricultural versus commercial or industrial, etc.) in perceived “metropolitan
areas” where economic transformation or community metamorphosis activities
had been planned or were in the stage of being implemented.

In the Lehigh Valley, the post Korean War push for economic transformation and
community metamorphosis had its economic justification in arguments
advanced January 8, 1973 by the Lehigh County Commissioners in the midst of
public debate over their advocation of a proposed Trexler Dam and reservoir on
the Jordan Creek. (A project that in 1964 Allentown’s water consultant Morris &
Knowles, Inc., Pittsburgh, had considered a feasible future source of raw water
for the City of Allentown second only to the volume that could be obtained from
the Lehigh River.) The Commissioner’s offering the contention that the Lehigh
County might have to sacrifice its traditional agricultural ties in order to compete
successfully with Philadelphia for economic development.

However we note – the Commissioners apparently did not share the same
opinions about the propriety or the benefits derived from the inducement or
unwarranted growth.

County Commissioner Donald B. Hoffman, in fact, was somewhat rhapsodic
about the future tax benefits derived from potential building development in the
County.  His line of argument being that “tax dollars from a home was far
superior to tax dollars derived from open land.” In other words, to Hoffman
money issues rather than livability issues were far more important.

On the other hand, George A. Stahl, then Chairman of the County
Commissioners, was genuinely apologetic about the inducement of growth
activities in the County. Stahl offering the following political defense:

“ We don’t have a choice. These people keep coming in and building homes. We
can’t stop the. It’s the position we’re in between Philadelphia and New York and
Pittsburgh and Washington.”

A message reminiscent of what Dr. James Cope said October 7, 1957. That is:

“We can not stop the metropolitan age, we can only channel it. The Lehigh Valley
must decide. What you have? What do you want? How do you get it?

To this question Allentown Councilman Benjamin F. Howells expressed the
following sentiments March 31, 1981 at a public forum sponsored by the
Allentown-Lehigh County Greater Community Council:

“Our first point involves the general question of growth in our region. The report
(of the Greater Community Council) proceeds under a very large assumption that
economic growth and development are in the best interest of Allentown and the
Lehigh County. Growth may well be critical to the economic well being of this
region, but that growth must meet certain criteria. It, first of all, must be
reasonably controlled by entities interested in maintaining the quality of life in
our region and dedicated to preserving our critical natural resources. The growth
cannot be fueled by unreasoning municipal competition for the location of new
housing, new factories, and new commercial centers.”

Nevertheless, in spite of everything Ben Howells may publicly profess, given the
tradition in the Lehigh Valley of fiercely independent local governments (three
cities and numerous suburban and rural municipalities) growth in the Lehigh
Valley, indeed, might be fueled by unreasoning municipal competition for the
location of new housing, new factories, and new commercial centers.
Consequently, the dream of uniting the distinct communities as one region to
foster controlled growth activities has been resisted for years and may be
resisted for many years to come.

***                        ***                        ***

George A. Stahl further defined his above position in his booklet Lehigh County
--- Yesterday, Today and Tomorrow.  He wrote:

“The treat to our fertile farmland is real, for though Pennsylvania’s soil is among
the richest in the Country, this irreplaceable resource is being covered by heavy
developments or shopping centers. Shopping centers that are too often
unneeded, serving mainly to steal business away from already developed
downtown areas.”
Some of these heavy developments included the location of new industries (that
is, Kraftco Corporation and F. & M. Schaefer Brewing Company) in Upper
Macungie Township. The effect of such new land use caused an eight-fold
increase in land assessments on at least 43 tracts (comprising 802.9 acres) being
active farmland and private residential units with modest to large front, side and
back yards.

The 802.9 acres carried an assessed valuation of $68,580 in 1972. But based
upon industrial use evaluation, the assessed valuation in 1973 was $552,320. The
upshot being, even if township and school tax rates remained the same, there
would be a jump in real estate taxes from $3,024.62 in 1972 to $24,357.23 in 1973.

Individually, Mabel Adams and Homer Zimmerman may have been hit the hardest.
For example, Mabel Adam’s assessment on 213.2 acres went up from $16,260 in
1972 to $266,550 in 1973 resulting in a 1973 real estate tax bill of $11,754.85 as
compared to $717,06 in 1972. Likewise, Homer Zimmerman’s assessment on
150.5 acres went up from $12,750 in 1972 to $87,490 in 1973 resulting in a 1973
real estate tax bill of $3,858.37 as compared to $562.28 in 1972.

Of course, for all property owners affected, this eight-fold increase in property
assessment was an unwelcome consequence of the new fixed reality in their
lives. But we observe, for Homer Zimmerman and his wife Mary, this new fixed
reality was served in double portions. That is, they were impacted negatively by
the decision of the Lehigh County Authority and Upper Macungie Township
planners to condemn for easement purposes a portion of their farm property to
facilitate wastewater disposal needs of the newly constructed Kraftco
Corporation creamery plant, in addition to the rise in their real estate tax
assessment. The fact being, the new fixed reality immediately raised the question
of fairness --- that is ---was it fair or moral for the County to assess F. & M.
Schaefer and Kraftco undeveloped industrial use land at a lower amount per acre
then smaller (industrial use?) tracts held by homeowners in the adjacent area?

No wonder J. Bruce Mordaunt, a member of the Northwestern Lehigh Citizens
Coalition and a future member of the Joint Planning Commission, Lehigh –
Northampton Counties, in addressing the Trexler Dam Water Project issue
January 31, 1973 stated that the County’s policy of “inducing growth and
subsidizing it should be terminated.”

Indeed, our interest is aroused. Whether such spot reassessment was pre-
planned or incidental, Lehigh County could not have found a better way to clear
out the area immediately adjacent to the new industry for further industrial
growth. Truly, the County (and the Township that rezoned the tract from
agricultural to industrial) severely limited the land use choices that the current
owner of those properties or their heirs or successors had in the economic
usage of land (which has either been incorporated or adjacent to land once
controlled and owned by the late General Harry C. Trexler); and, what-is-more, in
many cases the new assessment priced the land right out of the economical use
for farming and forced the land’s sale for other economic usages.

Statewide there was concern over the loss of farmland. For example – in 1974 the
Pennsylvania Farmland and Forest Land Assessment Act of 1974 (Act 319-
December 19, 1974) was written to provide relief to farmers potentially affected
negatively by industrial use spot assessments. The aim was to have agricultural
land assessed for taxation purposes on the basis of the use rate then its
potential industrial, commercial or residential development. However, for some,
the relief provided by the enactment of such legislation was too late.
Furthermore, land speculators took advantage of the provisions of an earlier
farm abatement act (Act 515) to acquire long-term investments. That is – they
took advantage of agricultural and forest land real estate tax abatements until
such point they were prepared to take windfall profits by resale of such lands for
economic usages other then agriculture.

By any standard such shortsighted behavior might be judged to be business
wise. Yet it can be considered to be morally compromising. After all, the real
public intent of farm tax abatement legislation was and should still be the
preservation of farmland, certainly not the legislation of another investment tax
shelter.

***                        ***                        ***

Farmland Protection Tools and Techniques
State and local governments have taken the lead in protecting farmland for more
than 40 years. All states provide property tax relief for owners of agricultural land
and protection from nuisance lawsuits for farmers. Many states have additional
programs that are designed to prevent farmland conversion and improve the
economic viability of farms. Twenty-one states have authorized purchase of
agricultural conservation easement (PACE) programs that offer farmers
compensation for giving up the right to develop their land. Sixteen states allow
farmers to form special agricultural districts where commercial agriculture is
encouraged and protected.
Local communities can use comprehensive land use planning and farm-friendly
zoning ordinances to control growth in agricultural areas. Some counties and
towns also have PACE and other programs to protect farmland, as do the federal
government.
Some farmland protection tools rely on regulations. The advantage of regulatory
strategies is that they can be put in place relatively quickly, and do not require
governments to spend a lot of money. But new land use regulations are often
controversial, and laws can always be changed--they don't guarantee that
farmland will be protected in the long term.
Other programs give farmers economic incentives to keep their land in
agriculture. These programs are voluntary, and they are usually more popular
than regulations. But they may also be more expensive, and they may not be able
to protect large blocks of land.
Purchase of agricultural conservation easement programs compensates
property owners for restricting the future use of their land. PACE is known as
Purchase of Development Rights (PDR) in many locations.
PACE programs are based on the concept that property owners have a bundle of
different rights, including the right to use land, lease, sell and bequeath it, borrow
money using it as security, construct buildings on it and mine it, or protect it from
development, subject to reasonable local land use regulations. Some or all of
these rights can be transferred or sold to another person. When a landowner
sells property, generally all the rights are transferred to the buyer. PACE
programs enable landowners to separate and sell their right to develop land from
their other property rights. The buyer, however, does not acquire the right to
build anything on the land, but only the right and responsibility to prevent
development. After selling an easement, the landowner retains all other rights of
ownership, including the right to farm the land, prevent trespass, sell, bequeath
or otherwise transfer the land.
Landowners voluntarily sell agricultural conservation easements to a
government agency or private conservation organization. The agency or
organization usually pays them the difference between the value of the land as
restricted and the value of the land for its “highest and best use,” which is
generally residential or commercial development. The easement price is
established by appraisals or a local easement valuation point system. Typically,
PACE programs consider soil quality, threat of development and future
agricultural viability when selecting farms for protection.
Easements give qualified public agencies and private organizations the right to
prohibit land uses and activities that could interfere with present or future
agricultural use.
Terms may permit the construction of new farm buildings and housing for farm
employees and family members. Easements “run with the land,” binding all
future owners unless the document establishing the easement provides that the
covenant may be terminated for cause or at the end of a specified period of time.
HISTORY
Suffolk County, N.Y., created the nation’s first PACE program in the mid-1970s.
Following Suffolk County’s lead, Maryland and Massachusetts authorized PACE
programs in 1977, Connecticut in 1978 and New Hampshire in 1979. Concern
about regional food security and the loss of open space were motivating forces
behind these early PACE programs.
***                        ***                ***
In Lehigh County, George A. Stahl, like Bruce Mordaunt, has voiced concern in
regard to the loss of precious farmland and open space in the County. Stahl
served as County Commissioner from January 1964 to January 5, 1976 in the
County’s three-commissioner old form of government.
As County Commissioner at the onset of the proposed Trexler Dam Water
Project controversy, Stahl acknowledged that the “Ecology of the region can be
destroyed when land is paved and built upon. But ironically, he concluded that
the dam would preserve the very thing the public wanted. That is, in the midst of
heavy development the recreational lands surrounding Trexler Dam would
provide a large permanent oasis of open space.
Upon leaving office, Stahl wrote Lehigh County – Yesterday, Today and
Tomorrow.  Of interest, the work was released for public sale one month after the
Joint Planning Commission, Lehigh-Northampton Counties (JPC) released its
Comprehensive Plan for Lehigh-Northampton Counties.
In this 1977 booklet, George A. Stahl suggested the following solutions to state
and regional growth problems:
“But as the population mounts, voices will be raised to take cropland out of use.
To prevent this, some way must be found to distribute population more evenly
while reserving the best land for agriculture. To work toward this end, we must
first realize that our local zoning boards and Joint Planning Commission are too
limited in scope and authority to adopt a comprehensive plan. A better approach
would be for Pennsylvania to enact a Land use act similar to that of Hawaii; a
State Board could review and coordinate the counties’ concept of land use and
would define what areas can be used for agriculture, industry, residences, parks,
and open spaces. Without such careful planning, the Northeast will cease to be
at all self-reliant in supplying its own food – a great liability should our society
revert to small-scale, regional agriculture as some futurists predict.”
In this piece we see some evidence that Stahl did not give enthusiastic
endorsement to the Comprehensive Plan of the JPC, which we shall soon
discuss. That Stahl preferred the land use law as it was applied in Hawaii. And
lastly, there is no evidence Whether or not Stahl was familiar with the PACE
program as was first initiated in Suffolk County, New York in 1974. But there is
some evidence that Stahl might be in favor of the program given his fear that the
Northeast would cease to be self-reliant in supplying its own food.
***                        ***                        ***
To Review PACE once again but more thoroughly:
As it occurred, the nation’s first purchase of development rights (PDR) to
preserve farmland was initiated in 1974. The Suffolk County Farmland program
(New York) has seen 7,000 acres come into the program to date. Land stays in
private ownership and the County acquires non-agricultural development rights.
These rights are valued as the difference between the full market value of
property for its "highest and best use" (full value) minus the value of the
agricultural rights (residual value). The owner files property covenants similar to
a conservation easement limiting the use of the property to agricultural
production
FUNCTIONS & PURPOSES
PACE compensates landowners for permanently limiting non-agricultural land
uses. Selling an easement allows farmers to cash in a percentage of the equity in
their land, thus creating a financially competitive alternative to development.
Permanent easements prevent development that would effectively foreclose the
possibility of farming. Because non-agricultural development on one farm can
cause problems for neighboring agricultural operations, PACE may help protect
their economic viability as well.
Removing the development potential from farmland generally reduces its future
market value. This may help facilitate farm transfer to the children of farmers and
make the land more affordable to beginning farmers and others who want to buy
it for agricultural purposes. The reduction in market value may also reduce
property taxes and help prevent them from rising.
PACE provides landowners with liquid capital that can enhance the economic
viability of individual farming operations and help perpetuate family tenure on the
land. For example, the proceeds from selling agricultural conservation
easements may be used to reduce debt, expand or modernize farm operations,
invest for retirement or settle estates. The reinvestment of PACE funds in
equipment, livestock and other farm inputs may also stimulate local agricultural
economies.
Finally, PACE gives communities a way to share the costs of protecting farmland
with landowners. Non-farmers have a stake in the future of agriculture for a
variety of reasons, including keeping locally grown food available and
maintaining scenic and historic landscapes, open space, watersheds and wildlife
habitat. PACE allows them to “buy into” the protection of farming and be assured
that they are receiving something of lasting value.
ISSUES TO ADDRESS

The effectiveness of PACE programs depends on how jurisdictions address
several core issues.
These issues include:
•        What kind of farmland to protect, which areas to target and how to set
priorities?
•        What restrictions to put on the use of the land?
•        How much to pay for easements?
•        How to raise purchase funds?
•        How to distribute state funds among local jurisdictions?
•        How to administer PACE programs?
•        How to monitor and enforce easements?
BENEFITS
•        PACE protects farmland permanently, while keeping it in private ownership.
•        Participation in PACE programs is voluntary.
•        PACE can be implemented by state or local governments, or by private
organizations
•        PACE provides farmers with a financially competitive alternative to
development, giving them cash to help address the economic challenges of
farming in urban-influenced areas.
•        PACE programs can protect ecological as well as agricultural resources.
•        PACE limits the value of agricultural land, which helps to keep it affordable
to farmers.
•        PACE programs involve the non-farming public in farmland protection
DRAWBACKS
•        PACE is expensive.
•        PACE can rarely protect enough land to eliminate development pressure on
unrestricted farms.
•        PACE programs are generally unable to keep up with farmer demand to sell
easements. This results in long waiting lists and missed opportunities to protect
land.
•        Purchasing easements is time-consuming.
•        The voluntary nature of PACE programs means that some important
agricultural lands are not protected.
•        Monitoring and enforcing easements requires an ongoing investment of
time and resources.
Source: American Farmland Trust, Saving American Farmland: What Works
(Northampton, Mass., 1997).
***                        ***                        ***
.
SUFFOLK COUNTY AGRICULTURAL PROTECTION PLAN as re-stated June 1996

Suffolk County continues to see a rapid decline in farmland acreage despite its
longstanding conservation efforts. From 123,000 acres in 1950, the number of
farm acres is now reduced to approximately 31,000, only 7,000 of which is
protected by easement. At the current rate of conversion and the current rate of
development rights acquisition, only 10,000 acres of farms will remain in 2012. To
achieve the goal of 20,000 acres of protected farmland, preservation efforts must
be accelerated.

The goals of the plan are as follows:
•        Preserve agriculture as an important Suffolk County industry.
•        Ensure public policy of protecting, promoting and sustaining agriculture.
•        Preserve farmland as an important natural resource.
•        Preserve the cultural continuity of farms and farm families.
•        Preserve 20,000 acres of productive farmland through the purchase of
development rights.
Suffolk County still leads New York State in market value of crops, two-thirds of
which is in nursery and greenhouse products. Because Suffolk County has one-
third of all the irrigated farmland in New York State, the farming industry is able to
sustain itself in droughts, such as the 1995 growing season. Economically, the
farm industry generates 8,000 jobs and contributes a quarter of a billion dollars
to the local economy.

Upzoning to larger lot sizes over the years has actually been damaging to farm
preservation because it is based on a suburban sprawl model of single family
detached homes and requires more land, more roads, more uniform
development. It has also promoted sterile, cookie-cutter development and
discouraged rural, farm-based commercial and industrial development as
alternatives to single-family homes. Development pressure on farms has
increased, and conflicts between farming practices and rural residential lifestyle
has grown with each new residential incursion into farmland blocks.

The municipal finance effects of farm conversion are apparent and negative. For
every dollar an acre farmland pays in property tax, it uses $0.30 in services. For
every dollar an acre a homesite pays, it uses $1.23 in services. Loss of farms,
farm jobs, economic activity and favorable property tax ratios to more homes,
more traffic and less open space, puts a drain on municipal services and
accelerates a decline in the quality of life.

Agricultural districts (which allow 8 year property tax reductions) and better
mapping of parcels, soils and parcel characteristics are helping decision-makers
in the preservation of large blocks of farmland. Future programs for installment
purchases, increases in public funding, both locally and on the state and
national level for the purchase of development rights and other techniques hold
great promise that the goal of preserving 20,000 acres can be met.

Improvements in agriculture practices, marketing of produce, community
involvement, estate planning, government and institutional support are all
helping to support and sustain farming and raise the level of interest in
agriculture as an important element in the overall economy of Suffolk County.

***                        ***                        ***

In reality the Joint Planning Commission, Lehigh-Northampton Counties (JPC)
privately agreed with George A. Stahl’s views in regard to the long-range
success of  its COMPRREHENSIVE PLAN for it publicly acknowledged that  the
organization’s powers were too limited in scope and authority to force the
compliance of regional governmental units or authorities with a comprehensive
regional plan. In the midst of the Trexler Dam Water Project debate (1973), Gary E.
Scout, Assistant Director of the JPC appealed to environmental groups to
cooperate instead of viewing the JPC as an antagonist.

He said: “If you all are looking for a government entity that can control growth in
the region, you will find exactly none.”

In analysis, Stout was relating that regional governmental units such as the
boards of the County Commissioners and the JPC had no authority over critical
growth policies such as land-use controls and water and sewerage plans. The
reason for this is that all public policies that could be brought to bear on growth
rates are vested in the profusion or glut of local governments throughout the
Lehigh Valley,

Because of this fact, the JPC November 1977 COMPRREHENSIVE PLAN, which
was essentially an attempt to encourage the cooperation of regional
governmental units in seeking solution to established and potential regional
problems, was largely ignored by all governmental units including the County
Board of Commissioners.

Interestingly, an updated version of the original 1977 COMPRREHENSIVE PLAN
in 1982 has been similarly ignored as policy by almost every regional unit
through the fall of 1984. The lone exception to the general rule was Lehigh
County. The Board of Commissioners adopted the JPC land use plan as policy in
the fall of 1984.

Of course, this policy action of the Board of County Commissioners has given
much needed encouragement to the JPC staff and regional planning advocates.
JPC officials presently express a hope or a desire that other governmental units
in the bi-county planning area would follow the lead or precedent as established
by the Board of County Commissioners.

***                        ***                        ***

Of historical importance, the JPC’s goal has gained the open support of a group
known as the Lehigh Valley Partnership  (LVP). Organized in 1985, the Lehigh
Valley Partnership is a consortium of regional business owners and executives
with county and municipal government leaders as ex officio members. The main
purpose or interest of the Lehigh Valley Partnership being to instill a regional
concern in broadening economic development and to attack problems whose
solutions could create ripples of benefits throughout the area.

According to Lehigh Valley Partnership spokesman Robert K, Campbell, then
President and Chief Executive Officer of the Pennsylvania Power & Light
Company, speaking at the fourth annual Two Rivers Area Chamber of Commerce
business-industry dinner at the Country Club of Northampton County (October 7,
1986) the then stated objectives of the Partnership being:

1.        The completion of an extension to Route 33 that would connect Route 33
and Interstate 78.
2.        Bring to reality plans for a regional incinerator to handle the bulk of Lehigh
Valley’s solid waste disposal.
3.        Promote the building of major water and sewer projects.

Campbell’s remarks having been made on the twenty-ninth anniversary of
Genevieve Blatt’s historic October 7, 1957 visit to the Lehigh Valley in which
another P.P. & L Executive Officer, Ralph C. Swartz, played such an important
role.  Genevieve Blatt was the former Pennsylvania Secretary of Internal Affairs in
the Administration of former Pennsylvania Governor George Leader.

Thus in 1986 the vested interest of the P.P. & L continued to be the promotion of
enhanced urban growth. And if one made a prediction about what vested interest
the P.P. & L would have when the 21st century begins on January 1, 2001 one
would again conclude that the P.P & L would continue to be an agent of Lehigh
County transformation from its historic agricultural roots to that of enhanced
urban sprawl.

Above and beyond its promotion of its 1986 stated objectives, the Lehigh Valley
Partnership did not go away. The fact is, in 1995 the Lehigh Valley Partnership
under the leadership of P.P. & L President and C.E.O William Hecht would involve
itself in the initiative of creating a private, non-profit corporation known as the
Lehigh Valley Economic Development Corporation (LVEDC). The aim of the LVP
was to overcome the then prevalent balkanization of regional economic
development marketing efforts with the creation of a single regional economic
development unit. LVEDC, as a single regional economic development marketing
organization, would represent the Lehigh Valley as a whole. Through
regionalized marketing and communication initiatives for business retention and
attraction, LVEDC would offer businesses and industries one unified source for
information about the Lehigh Valley.

Then in 1996 the Lehigh Valley Partnership identified and promoted the need for
a strategic plan for development of the Lehigh Valley. It formed approximately 17
committees to look at many different quality of life issues in the Valley. While
exploring the need to revitalize the region's cities, the LVP concluded that
redevelopment of numerous old and abandoned industrial sites was essential.
To focus on this issue, the Partnership formed a subcommittee that came to be
known as the Brownfields Strategy Task Force ("Task Force").
The first task of the Task Force was to determine the number of brownfields sites
in the Lehigh Valley that had the attributes necessary for successful
redevelopment. The Task Force identified 72 "Potential Redevelopment Sites" in
25 municipalities.
Following many months of work by the Task Force on a number of substantive
issues, the Task Force concluded that realizing these opportunities would
require an office dedicated to the redevelopment of brownfields. To achieve this
end the Task Force created the Lehigh Valley Land Recycling Initiative ("LVLRI"),
which began its operations on January 4, 1999.
***                        ***                ***
George A. Stahl, not having the advantage of a Lehigh Valley pro-active group in
his era such as the Lehigh Valley Partnership, was quick to recognize that
regional or even for that fact, state-wide cooperation in the establishment of a
comprehensive land use plan would be wanting. For that reason, he presented in
his 1977 booklet a case study of Ramapoo, New York.  Stahl desperately wanting
to present an example for regional government officials and planners of what an
industrial municipality might do to control the rate of growth within its
boundaries in absence of regional or state-wide controls.
Stahl wrote:
“If the state does not act, Lehigh County Communities might combat the influx of
too many people too quickly much as Ramapo, New York did just thirty minutes
from Manhattan, this town more than doubled in population from 1960 to 1968.
To meet the threat of over development, Ramapo adopted a strict zoning
approach that has been upheld by the courts. Land developers who want to
build in Ramapo must obtain a special permit from the Town Board before they
can get a building permit. The special permit is not granted unless sewers,
drainage, schools, etc. already in the area can accommodate the growth. These
public facilities are provided under an 18-year capital budget program. They may
also, however, be provided by a builder at his own cost, but a few have gone this
route. By upholding quality of life in this way, Ramapoo has brought rampant
population growth under firm control. The annual number of new residential
units built there has gone from 943 (in 1965) to 200 to 250 for the last four years.”

INSTALLMENT THREE

Bill 1 – 1973 to prohibit local industries from discharging sudden, massive
“slugs” of chemical wastes into the Allentown wastewater treatment system was
introduced to the Allentown City Council January 17, 1973 and with amendments
passed in final form April 18, 1973.

Bill 1 – 1973 having become Ordinance 12003, was the first comprehensive
sewerage influent ordinance in the City’s history, superceded and improved
upon ten existing laws effecting access to the Allentown wastewater disposal
system by city users whether they be residential or industrial. Doubly, its
provisions applied to surrounding boroughs and townships and townships and
their authorities, which joined the Allentown metropolitan wastewater treatment
system by virtue of various agreements made since 1959.
The proposed ordinance expediently made available to area industry for
comment and review six months prior to its submittal to Council by the
Bartholomew Administration.
The ordinance developed by the City Operations Department headed by
Operations Director George A. Kandra in accordance with state directives based
on the Clean Streams Act that required permits and fees for certain discharges,
mandated sampling and inspections of flow, and set up controls to handle the
disposal of hazardous chemicals and metals.
The basis or prime motivation for such legislation being the announced reality
that chemicals and metals, particularly those believed to be discharged by textile
industries, had been upsetting digesting operations at the Kline’s Island
Wastewater Treatment Plant, and accordingly, hampering the performance of the
plant and leading to the pollution of the Lehigh River. Naturally, this fixed reality
led to conflict between the City and State environmental agencies. As it turned
out, the State bore down on the City due to the problem, leaving the City no
alternative but to adopt more stringent controls.
Copper and chromium, were in fact, the two worst metals the Kline’s Island Plant
received. The treatment plant was able to handle the metals when their
discharges were spread out, but not in bulk disposal.
Accordingly, one of the provisions of the ordinance would be to limit the
discharge of chemicals and metals by controlling harmful concentrations.
Industries would be required to supply the City with reports of the analysis of
their influent and the City, in turn, would provide them with safe disposal
allocations. Additionally, the ordinance provided for the monitoring of wastes
through laboratory tests by a full-time inspector to tell exactly what the plant was
getting, and to pinpoint the industry or industries dumping the waste, In the
event any industry couldn’t meet the stipulated requirements, it would be
requested to install pretreatment facilities at its own expense, to maintain certain
standards.

***                        ***                        ***

In PART THREE – INSTALLMENT SIX was listed such limitations on the use of
the Allentown Sanitary Sewer System and the admission of industrial waste as
found in the inter-municipal sewage agreement of 1965. At the same time we
compared such limitations with limitations found in the 1959 agreement with
Emmaus. But no such comparison was made thus far between the limitations
found in the 1965 agreement and those limitations found in the inter-municipal
sewerage agreement of 1969. The explanation being, there can be no
comparisons made for the limitations agreed to in 1965 were not changed or
modified in the 1969 agreement.

Clearly, such limitations imposed on the use of the Allentown Sanitary Sewer
System and the admission of industrial waste as found in Ordinance 12003 –
1973 were more specific and comprehensive then provisions found in all
previous inter-municipal sewerage agreements made since 1959.

***                        ***                        ***


Simply stated, Ordinance 12003 – 1973 provided that industrial waste of the
following strength or character should not be discharged from any improved
property into the Allentown Sanitary Sewer System:

1.        Industrial waste having a B.O.D. greater then three hundred mg/l;
2.        Industrial waste having a content of suspended solids greater then three
hundred sixty mg/l;
3.        Industrial waste slugs having an average daily flow greater than five
percent of the daily sewage flow at the sewage treatment plant of the sewerage
system.

Additionally, industrial or domestic wastes having the characteristics described
below:

1.        Having a Temperature higher than 150OF or less than 320.
2.        Containing more than 100 milligrams per liter (mg/l) of fat, oil, or grease
3.        . Containing any gasoline, benzene, napltha, fuel oil, paint products, acid or
other inflammable or explosive liquids, solids or gases.
4.         Containing unground garbage, or afflux from mechanical garbage
grinders, which does not meet all requirements of the Plumbing Code.
5.         Containing but not limited to any ashes, cinders, sand, mud, straw
shavings, metal, glass, rags, feathers, tar, plastics, wood, whole blood,  paunch,
manure, bentonite. Lye, building materials, rubber, hair bones, leather, porcelain,
china, ceramic wastes, or solid or viscous substance capable of causing
obstruction or other inference with the proper operation of the sewerage system.
6.        Having a "pH", stabilized, lower than 6.0 or higher than 9.0 or having any
other corrosive or scale-forming property capable of causing damage or hazard
to structures, equipment, bacterial action or personnel operating the sewerage
facility.
7.        Containing a toxic or poisonous substance in sufficient quantity to injure
or interfere with any sewage treatment process, to constitute a hazard to humans
or animals, or create any hazard in the receiving waters of the sewage treatment
Plant.
8.        Containing total solids greater than 2,000-PPM or such character and
quantity that unusual attention or expense is required to handle such materials in
the sewage facility.
9.        Containing noxious or malodorous gas or substance, which creates a
public nuisance.
10.        Containing dye from any source that will not have an effluent the
equivalent of that produced by alum coagulation and chlorination to remove
suspended or colloidal matter and leach the dissolved dyes.
11.        Containing radioactive substances and/or isotopes of such half-life or
concentration as may exceed limits in compliance with applicable State or
Federal regulations.
12.         Having a chlorine demand in excess of 12 mg/l.
13.        Prohibited by any permit issued by the Commonwealth of Pennsylvania.
14.        Containing wastes , which are not amenable to biological treatment or
reduction in existing treatment facilities, specifically non-biodegradable carbon
compounds.
15.        Containing concentrations of anions, cations, and other various
objectionable substances that would make the City responsible for discharging
such substances in excess of that amount permitted in the allocated portion of
the critical flow of the receiving stream. The maximum allowable concentrations
permitted to be discharged from the waste water treatment plant shall be as
follows:

Substance                                Maximum Concentrate (Mg/l)
          Arsenic                                0.01
          Barium                                1.0
          Beryllium (as Be)                        1.0
          Cadmium (as Cd)                        0.01
Substance                                Maximum Concentrate (Mg/l)
Chromium (trivalent)                        0.5
Chromium (hexavalent)                        0.30
Color ( Platinum Cobalt Standard)                  100.0
Copper (as Cu)                                0.1
Cyanides                                none
Fluorides                                2.0
Iron                                        4.0
Lead                                        0.05
Mercury                                        none
Nickel (as Ni)                                2.5
Phenol                                        0.005
Phosphorous                                     10.00
Selenium                                0.01
Silver                                        0.05
Tin                                        1.0
Zinc (as Zn)                                0.3

***                        ***                        ***

In analysis – the monitoring provisions of Ordinance 12003 would become even
more important as design and operational difficulties in the LCA pre-treatment
plant located in Upper Macungie, from its service date, prevented efficient pre-
treatment of brewery and creamery high strength waste. Thus, it became very
possible that industrial waste discharges coming down the 17 mile LCA-
Allentown public highway for sewage and wastewater would display
characteristics of improper pre-treatment thereby becoming a causal factor that
would contribute to possible performance difficulties at Allentown’s Kline’s
Island Plant.

Of course, with Ordinance 12003-1973, Allentown at least had at its disposal
certain legal mechanisms to seek customer compliance with sewage influent
regulations. These mechanisms include:

•        The ability to reject the waste;
•        The ability to require pre-treatment to an acceptable condition to the public
sewers;
•        The ability to require control over quantities and rates of discharge; and
lastly,
•        The ability to require immediate discontinuance of the waste discharge until
such time as it satisfactory meets the required standards as established by said
ordinance.

Recognizing that certain domestic or suburban users of the Allentown Sanitary
Sewer System may respond slowly to comply with the provisions and intent of
Ordinance 12003 – 1973, Allentown officials should have understood that the key
to compliance rested upon the threat to enforce the Ordinance’s provisions; and
of course, enforcement was conditioned upon commitment of those who held
the responsibility for upholding Allentown’s inter-governmental wastewater
treatment agreements and ordinances.

***                        ***                        ***

Historically, the LCA operated pre-treatment plant (built in 1971 at a cost of
$803,901) closed forever January 27, 1976 after experiencing unsolvable
operational difficulties.

Seemingly, the closure action by the Authority violated the 1969 Prime Sewage
Agreement, which obligated the County to construct and operate or cause to be
constructed and operated all necessary pre-treatment facilities, and additionally
violated equally binding provisions of Allentown’s Comprehensive Sewage
Ordinance of 1973 – Ordinance 12003.

But fascinatingly, Joseph S. Daddona, Harry Bisco, Karl Kercher, Watson
Skinner , Sam Costa and Benjamin Howells were involved in City of Allentown
decision-making that removes the following language from Section 4 (E) of
Ordinance 12003, Section 941.04 (e) of the Codified Ordinances of the City:
“Nothing contained in this section shall be construed as prohibiting any special
Agreement or arrangement between the City and any person whereby industrial
waste of unusual strength or character may be admitted into the sewerage
system by the City subject to proper continuous pre-treatment prior to discharge
into the sewerage system…”

The purpose of such removal was to facilitate the decision-making to convert the
Lehigh County Authority Pre-treatment Plant to a Chemical Feed Station and to
allow for the addition of other Chemical Feed Stations along the Little Lehigh
Interceptor in the hope that the sewage would cause no problems in
transmission and at the Kline’s Island Plant. Accordingly, Ordinance 12145 (
passed October 15, 1975) produced the following changes in language to
Section 941.04 (e) of the Codified Ordinances of the City:

“Nothing contained in this section shall be construed as prohibiting any special
Agreement or arrangement between the City and any person whereby industrial
waste of unusual strength or character may be admitted into the sewerage
system by the City subject to payment of a surcharge therefor by such person or
by proper and continuous pre-treatment prior to discharge into the sewerage
system. The surcharge shall be revised annually, and shall be initially determined
by the following formula:

Quarterly Surcharge: 0.00834 Q<(BOD –300) $21.39 + (SS –360) $22.23>

Where: o.oo834 is a constant to convert waste strength expressed in mg/l of
BOD and/or SS to thousands of pounds of BOD and/or SS per million gallons of
industrial waste.

Q is the quarterly industrial waste from an improved property expressed in
million of gallons.

BOD is the biochemical oxygen demand of industrial waste in mg/l.

SS is the suspended solids of industrial waste in mg/l.

300 and 360 are the allowable waste strengths in mg/l prescribed in this section
for biochemical oxygen demand and suspended solids.

In order to ascertain the strength of every industrial waste requiring a surcharge,
the City shall cause appropriate sampling and analysis to be made four (4) times
each year. Said appropriate sampling shall consist of seven (7) twenty-four (24)
hour composite samples taken every day for seven (7) consecutive days.  
Results of each analysis shall be used to establish the surcharge for the
particular quarter during which the particular samples is taken and quarterly
billing shall be made by the City.”


INSTALLMENT FOUR

Historically, the Lehigh County Authority operated pre-treatment plant closed
forever January 27, 1976 after experiencing unsolvable operational difficulties.

The plant’s closure facilitated by provisions in City of Allentown Ordinance 12145
(passed October 15, 1975) that permitted Lehigh County Authority installation
and operation of temporary chemical feed stations at he inoperative wastewater
pre-treatment plant in Upper Macungie Township, at Keck’s Bridge in Salisbury
Township, and at Shrieber’s Bridge in Allentown’s Lehigh Parkway.

***                        ***                        ***

It being the fixed circumstance of history that decision-making in regard to City
of Allentown Ordinance 12145 essentially being the cause of City of Allentown
subsidation of industrial waste processing costs for certain industrial clients of
the Lehigh County Authority in Western Lehigh County. In addition, it resulted in
the largest number of complaints from the public in regard to the presence of
malodorous sewage gases in Allentown that until the summer of 1976 had ever
been recorded by either the City of Allentown or Environmental Agencies.

The epicenter of the recorded 64 citizen complaints apparently located in and
around the Lehigh Parkway area.  Hence, enactment of purpose, no matter from
what reference point its creators impulse of conscience be derived, unfortunately
worked to heighten the continuing misery of an already bad situation.

***                        ***                        ***

Public records indicate that Allentown Mayor Joseph S. Daddona informed the
Lehigh County Authority October 13, 1976 (almost a year to the date of the
passage of City of Allentown Ordinance 12145) of City of Allentown intent to
increase by new ordinance the surcharge it made to the Lehigh County Authority
for the processing of untreated industrial waste.  The mayor asserting that such
action was necessary because the revenue it received from LCA towards the
treatment of industrial waste from western Lehigh County was insufficient to
offset actual costs.

For political reasons, the mayor wanting assurances from the Authority that it
would pass the additional surcharges on to those Authority customers most
responsible for the large amounts of untreated industrial wastes – Schaefer
Brewery and Kraft Creamery.

Please note – it also being the fixed circumstance of history, that the two before
stated industries had been identified by city officials as being in violation of both
effluent quality and quantity limits as established by inter-governmental legal
agreements and the City of Allentown Comprehensive Sewage Ordinance 12003
– 1973.

***                        ***                        ***

But of significance, City of Allentown subsidation of the foreign waste stream
that emanated from western Lehigh County continued for the duration of the first
Daddona Administration.

The fixed reality being that no serious move was formally made to amend the
surcharge provisions of Article 941 of the Codified Ordinances of the City of
Allentown until January 3, 1979. That being the date that Councilmen Benjamin F.
Howells Jr and Guy Kratzer introduced Administration sponsored Bill 1 –1979 for
first reading to the Allentown City Council as a courtesy to Daddona’s successor
--- Frank Fischl.

***                        ***                        ***

Frank Fischl, a retired Colonel in the United States Air Force, was elected Mayor
of Allentown in November 1977 by a very close vote, and formally assumed office
January 4, 1978. The January 4, 1978 date also marked the formal end of the first
Daddona Administration; and for the first time since January 1966, Joseph S.
Daddona had no official status in City Hall. To this day Daddona attributes his
loss to his failure to energize his voting base in the 1977 election. Daddona
claims that too many loyal democrats elected to sit out the election with the
undesirable result for Daddona that the Republican minority was able to win the
election.

Yet in analysis – the soul and body of the first Daddona Administration wreaked
havoc on the Fischl mayoralty. That is, while the soul created the conditions that
controlled the agenda of the Fischl Administration, the body worked cunningly to
plot the end of the Fischl mayoralty, thus enabling the establishment of Daddona’
s second administration in 1982.

***                        ***                        ***

As it happened Bill 1- 1979 was enacted into law by the Allentown City Council
March 21, 1979 becoming Ordinance 12345. The bill on the surface seemingly
being the pending legislation that Daddona October 13, 1976 advised the LCA
would be brought to City Council for its review and approval. Yet utilization of
common sense suggests otherwise.

The probable historical explanation for the failure of the mayor to carry out intent
or purpose being the following:

•        The mayor was unable to find adequate support on Council to enact such
legislation during his incumbency.

(Hard to believe in light of the fact that Daddona had a reliable democratic
Council in his first term.)

•        The mayor preparing for an upcoming re-election campaign, simply was
making a “symbolic” public relations gesture knowing full-well that the pending
Councilmatic legislation had nothing to do with increased surcharge fees.

(Bill 42 – 1976, a.k.a. Ordinance 12250 established a program for senior citizen
water and sewer rebates keyed to household income.)

•        The mayor on the advice of technical experts and legal council elected to
pursue other means to force the willingness of LCA to accept additional
surcharges and its cooperation fully in abating odors.

(On October 13, 1976 Daddona suggested the possibility that the Schaefer and
Kraft plants be closed. But at the same time assigned the task to Lehigh County
rather then the City. Then too, of more interest, Jack Peek, Allentown Director of
Community Development stated that the Pennsylvania Department of
Environment Resources had indicated that it could either help close down the
two companies or prevent the allocation of any additional sewage treatment
capacity to the Lehigh County Authority until such time corrective action was
taken or do both.)

***                        ***                ***

But whatever the reason for the mayor’s appeared inaction, it can not be denied
that industrialization in western Lehigh County, particularly Upper Macungie
Township served as a great catalysis to induce City of Allentown air pollution
problems and the subsidation dilemma.

Allentown City Councilman Benjamin F. Howells Jr. commenting October 13,
1976: “I cannot believe that reasonable men signed such a sweetheart contract
and gave everything in this County away.”

The above concern making reference to the deal that Lehigh County
Commissioners George Stahl, Donald Hoffman and Harley Steward Sr, had made
in mid-1969 with F. & M. Schaefer Brewing Company and Kraftco.

Then too – a veiled reference in Howells comments that evening being the belief
that someone then in power ought to have been charged for misfeasance in
office.

In reply, Raymond Snyder, General Manager of the Lehigh County Authority,
asserting: “ The City should have been more involved with that (contract) in
1969.”

In analysis – Snyder’s comments leading us to inquire as to whom held prime
responsibility for pressing regional wastewater treatment issues confronting the
City of Allentown in 1969.

Who let the Dawgs out? The answer must be Joseph S. Daddona. This belief
based on a letter dated September 2, 1968 from Arthur L. Wiesenberger of A.L.
Wiesenberger Associates to Joseph S. Daddona then serving as a full-time
Allentown City Councilman and Director of the City’s Department of Streets and
Public Improvements under Allentown’s former Commission government.
Daddona, of course, in 1969 had been preoccupied with his campaigns to
become Allentown’s first Mayor under the Strong Mayor form of government.
First his successful campaign against incumbent mayor Ray Bracy in the spring
democratic primary; and lastly, his unsuccessful campaign against former Allen
High School Principal Clifford “Chips” Bartholomew in the November General
election.

***                        ***                        ***

Returning our attention to City of Allentown Ordinance 12345, City of Allentown
Ordinance 12345 basically changing the Quarterly Surcharge formula from:

0.00834 Q<(BOD –300) $21.39 + (SS –360) $22.23>

Where: 0.00834 is a constant to convert waste strength expressed in mg/l of BOD
and/or SS to thousands of pounds of BOD and/or SS per million gallons of
industrial waste. Q is the quarterly industrial waste from an improved property
expressed in million of gallons. BOD is the biochemical oxygen demand of
industrial waste in mg/l. SS is the suspended solids of industrial waste in mg/l.
300 and 360 are the allowable waste strengths in mg/l prescribed in this section
for biochemical oxygen demand and suspended solids.

To:

(Ordinance 12345 adding a prohibition against the introduction of Kjeldahl
Nitrogen ((a.k.a. Ammonia in nitrogen)) greater than 85 mg/l unless permitted by a
surcharge agreement.)

8.34 Q<(BOD –300) $0,085 + (SS –360) $0.076 + (TKN – 85) $0.184 > … Where: 8.34
is a constant to convert waste strength expressed in mg/l of BOD and/or SS
and/or TKN into pounds of BOD and/or SS and/or TKN per million gallons of
industrial waste. Q is the quarterly industrial waste from an improved property
expressed in million of gallons. BOD is the biochemical oxygen demand of
industrial waste in mg/l. SS is the suspended solids of industrial waste in mg/l.
TKN is the total Kjeldahl nitrogen of the industrial waste in mg/l.  300 and 360 and
85 are the allowable waste strengths in mg/l prescribed in this section for
biochemical oxygen demand and suspended solids and total Kjeeldahl nitrogen.

But interestingly, the major incentive for the enactment of Ordinance 12345 was
the imposition of user charges as required by Federal legislation controlling the
1978-79 expansion of the Kline’s Island Wastewater Treatment Plant:

Section four of 12345 providing:

“Discharges of any and all wastewater flows to the City Sanitary Sewage System
is absolutely contingent on the payment of user charges based on a user charge
system in accordance with Title 40 of the Code of Federal Regulations, Section
35.913-13, and Appendix B to Part 35. This requirement is intended as a minimum
and does not prohibit the imposition of sewer service charges in excess of
federal requirements. The purpose of this limitation on the admission of sewage
into the City system is to fulfill Federal requirements and grant conditions
associated with the Federal finding of wastewater system improvements.”


INSTALLMENT FIVE

As the holder of a regional permit to discharge wastewater effluent into the
Lehigh River, Allentown had to abide by certain guidelines or risk state or federal
environmental agency displeasure.
But no such permit was held by Allentown or any Lehigh County community to
directly discharge wastewater whether it be treated or untreated into the Little
Lehigh Creek. Therefore, Allentown risked state citation whenever its interceptor
system surcharged and discharged its contents into the “Conservation Waters”
of the Little Lehigh.

Allentown might have done well to heed the indirect warning that John D. Durr,
Regional Sanitary Engineer, Pennsylvania Sanitary Engineer, Pennsylvania
Department of Environmental Resources gave the city when he spoke in West
Reading January 28, 1973 to representatives of the Bethlehem based Ecological
Protection Society, Trout Unlimited, and the Monocacy and Bushkill Area
Watershed Associations.

The conservationists were told that in the future developers no longer would be
given permits to dump wastes into “Conservation Streams.” Hence permits
would require very strict guidelines that 1973 state of art sewage treatment could
not meet. This meant that “Conservation Streams” such as the Bushkill,
Monocacy and the Little Lehigh would in principle if not practice remain
protected until technology developed better waste treatment methods.

***                        ***                        ***

Allentown Mayor Clifford Bartholomew and members of City Council indeed were
notified in correspondence from Durr dated February 20, 1973 for discharges of
raw sewage into the Little Lehigh Creek from its Emmaus Interceptor. The
discharges generally occurred during and following runoff periods due to the
limited capacity of the 30-inch receiving sewer paralleling Lawrence Street, which
is now named Martin Luther King Boulevard. Pennsylvania Department of
Environmental Resources records indicate a possible maximum flow of
approximately 20 million gallons a day from the total of the intercepting sewers
along Cedar Creek and Little Lehigh west of Allentown. The existing capacity of
Lawrence Street portion of the Little Lehigh Interceptor was less than 8 million
gallons per day.

These illegal discharges of raw sewage into the Little Lehigh Creek (observed by
the Reading PA-DER office February 2, 1973), of course, constituted a violated of
the Clean Streams Law of Pennsylvania. However, Durr inferred the issue of
greater importance was the concern that the Allentown water works intake was
located immediately downstream from the discharges. And, he added that the
same discharges constituted a violation of a permit dated May 4, 1960 and
bearing number 9606, with special condition “A” stated:

“When the area tributary to the Emmaus Interceptor has developed to the point
that the flow from this existing interceptor renders imminent the overloading of
the existing 30” City of Allentown Little Lehigh Interceptor, a relief line must be
constructed. The plans for the relief sewer must be submitted to the Sanitary
Water Board for approval before construction.”

Consequently, Durr issued an order that required the City to stop the illegal
overflows of raw sewage from the Little Lehigh Interceptor. In this order he
maintained that the sewer under consideration seemed to reflect two conditions,
namely: 1) excessive infiltration along its entire length of ground water and/or the
presence of surface water inlets since the condition occurred during an
following precipitation runoff and, 2) the near total use of sewers capacity during
the non-precipitation period because of the rapid occurrence of sewer overflow
at times of precipitation. And importantly, this order directed the City to submit
within thirty days of receipt of the Durr communication a report of the steps that
would be taken to investigate the causes of the problems together with the dates
these studies were to be started and completed.

Allentown Director of Operations George A. Kandra, the responsible city official
to implement the Durr directive, did not deny the state official’s concerns
although the correspondence included an order for Allentown to take immediate
action to stop the overflows. In a letter dated March 20, 1973 to Durr, Kandra
wrote: “We concur that the periodic overflow you refer to exists. It was
recognized in 1970 that deficiencies were apparent in this area.” Nevertheless,
Kandra also wanted to inform Durr of Allentown’s efforts to resolve the problem
prior to the issuance of the February 20, 1973 citation.

We note – in decision-making Kandra could avail himself of two Metcalf & Eddy
reports releases in 1969.

Metcalf & Eddy in its “Report to the City of Allentown, Pennsylvania on 1965-66
Trunk Sewer Gaging --- July 2, 1969 “had indicated that Section 1 and 2 of the
Little Lehigh Trunk Sewer (also known as the Little Lehigh Interceptor) would
need relief at full development. This was especially true of Section 2, as the
expected peak flows in 1990 would exceed 1969 capacity by more then 50
percent. Of course, the peak flows beyond 1969 capacity would require a 30-inch
relief line running from the junction of the Little Lehigh Creek Collection Sewer
(also known as the Emmaus Interceptor) and the Little Lehigh Creek Trunk
Sewer, Section 2, to the twin 24-inch pipe river crossing at the upper end of the
Little Lehigh Trunk Sewer, Section 1, a distance of some 5,350 feet. But Metcalf &
Eddy considered it premature to recommend (at that time) relief activity for the
lower portion of the Little Lehigh Creek Trunk Sewer, Section 1.

Then too – Metcalf & Eddy in its “Feasibility Report to the City of Allentown,
Pennsylvania on Additional Waste Treatment Facilities at Kline’s Island –
December 8, 1969 “ did not overlook the possible problems connected with the
discharge of wastewater from the Lehigh County Authority. It reasoned:

“ Allentown’s principal interceptors would have had sufficient capacity to handle
wastewater from the city and the presently connected townships and boroughs
for the design period, However, with the proposed discharge of wastewater from
the Lehigh County Authority, relief interceptors may be required for certain
reaches of the Emmaus and Little Lehigh Interceptors in the future.”

The question we derive from the above passage is that at what point would
Allentown decision-makers determine that relief interceptors would be required
for certain reaches of the Emmaus and Little Lehigh Interceptors?

We note – Metcalf & Eddy did address the issue in its 1966 released reports. But
at the same time, we find cross-reference or comparison of these reports made
difficult by use of different titles or identification for interceptions. For example,
the Metcalf & Eddy reference to Lower-1 Little Lehigh Interceptor in the
December 1969 study corresponds with reference to the Little Lehigh Trunk
Sewer, Section 2 in the July, 1969 study and of course, Little Lehigh Trunk
Sewer, Section 1 in July, 1969 study is referred to as Little Lehigh Interceptor
Lower-2 in the December 1969 study. (See FIGURE FOUR)





Fundamentally the key to determining when an interceptor needs to be relieved
is having knowledge of the absolute size and capacity of that line. And also,
having knowledge as to the Volume (measured in cubic feet per second) of peak
flows that enter such lines. Therefore, in its December, 1969 report Metcalf &
Eddy recommended to the city that gauging on the Lower-1 section of the Little
Lehigh Interceptor should be started on a periodic basis in 1970 so that
information would be available in the future to judge when this sewer would have
to be relieved. And additionally, it advised that the peak flows in the 24-inch
section of the Emmaus Interceptor (that is, the Keck’s Bridge area) and the
Lower-2 Section of the Little Lehigh Interceptor should be closely observed and
gauged periodically to determine when these sections would require relief.

Metcalf & Eddy (December, 1969) figures indicate that capacity flow in the Lower-
1 Section of the Little Lehigh Interceptor as being 15.4 c.f.s and respectively,
capacity flows in the 24-inch section of the Emmaus Interceptor and the Lower-2
Section of the Little Lehigh Interceptor as being 12.2 and 26.45 c.f.s. In regard to
the 24-inch Emmaus Interceptor we further note an additional limitation in
capacity by virtue of the December 22, 1969 Allentown-Lehigh County Authority
Sewage Agreement. That is, the City of Allentown granted to the Lehigh County
Authority the perpetual right to convey sewage and wastes into the Allentown
system in an amount not to exceed 10 cubic feet per second (an equivalent of 6.5
million gallons per day.) The exception being that the 10 c.f.s could be exceeded
by 20 percent for a period of two hours per day no more than one day per week.
(A situation when combined with inflow/infiltration would virtually assure line
surcharge.)

Then too, it was Metcalf & Eddy’s recommendation that plans and specifications
be prepared for the Lower 1 Section of the Little Lehigh Interceptor relief Sewer
as soon as annual gauging indicated that the sewer was going to be surcharged.
In this way construction of this relief sewer could proceed as soon as the
capacity of the existing interceptor was exceeded. The design and construction
of the relief sewers for the 24-inch Emmaus Interceptor and the Lower 2 Section
of the Little Lehigh Interceptor according to Metcalf & Eddy should be delayed
until it had been determined when or even if the expected peaks would occur.
In analysis, these Metcalf & Eddy advanced warnings of the future necessity for
the City to provide relief to its Little Lehigh Trunk Sewer from the Shrieber’s
Bridge to Fountain Park (as well as other locations) as legitimate upstream peak
sewage flows increased was taken in account by responsible officials of the
newly established Bartholomew Administration. Kandra reported in a March 20,
1973 letter to Durr that it was determined that by 1975 the before said relief sewer
would have to be installed predicated on evidence of 1970 current conditions
and projected flows for the following six years. Consequently, the project
(estimated cost being $292,000) was listed in the city’s six year capital
improvements program with work scheduled to begin in 1975.

Of course, from our vantage point in the future we note that no such relief line
was constructed on a permanent basis from the junction of the Emmaus and
Little Lehigh Interceptors (a location more commonly known as Shrieber’s
Bridge area) to the twin 44-inch pipe river crossing located in Fountain Park
within visual view of the vintage spare parts and manufacturing facilities of Mack
Trucks Inc.

The fact is short-range solutions were applied to buy more time and delay the
moment of truth.

***                        ***                        ***

Of particular interest in regard to inflow/infiltration, Metcalf & Eddy’s 1965-66
gauging study indicated that infiltration was not a serious problem. We quote
from the 1965-66 “Gaging” report:

“The observed heavy flows from the storm water are not caused by excessive
infiltration, as formerly believed, but are due primarily to roof drain connections
and needed repairs on some trunks,”

In regard to anticipated extensions of the existing sewerage system, Metcalf &
Eddy believed that such extensions should be constructed of concrete and
vitrified clay pipe having rubber-gasket joints. They reason that rubber gasket
joints are more easily made tight, and thus admit less groundwater than the
poured or mortar joints used in most of the then existing system. Therefore,
Metcalf & Eddy concluded that carefully constructed extensions to the system
could not increase infiltration appreciably. Consequently, lower allowance for
such infiltration on a per capita basis would be justified in the design of future
extensions.

We ask – Did theory as presented by Metcalf & Eddy in its 1965-66 “Gaging
Study” translate into fact.

Clearly, if theory became fact, why then was it necessary for John P. Durr to
issue a citation to Allentown February 20, 1973 for illegal overflows into the Little
Lehigh Creek?

We note – Kandra revealed in his March 20, 1973 correspondence to Durr that a
1971-72 Gaging Study by Metcalf & Eddy determined that average maximum
flows within the LCA-Allentown public highway for sewerage increased by
approximately 100%, and average minimum flows increased 50% over the 1965-
66 readings. Kandra could not contribute this total increase solely to new
customers. Therefore, speaking for the administration, he admitted that storm
water was a major fact in interceptor surcharging.

For the record, Metcalf & Eddy was authorized to study and submit a feasibility
report that would indicate an estimate of the capabilities of the various trunk and
interceptor sewers in the city as one facet of a more comprehensive service
agreement signed August 20, 1970 between the Allentown Authority and the
Boston firm. The Allentown was requested to enter into the before stated service
agreement with Metcalf & Eddy by City Council Resolution No. 23222 adopted
December 16, 1969.

Interestingly – Joseph S. Daddona was both City Councilman and lame-duck
Director of the city Department of Streets and Public Improvements at the time of
the city council vote. George Kandra with the establishment of the new form of
government was appointed by “Chips” Bartholomew to take over Daddona’s
administrative duties.

Then too (in regard to LCA’s interceptor construction program) Daddona,
perhaps, had too much faith in the ability of LCA to install connecting
interceptors that would be watertight enough to reduce the percent of infiltration
of storm water and groundwater in the lines. Therefore, he was party to a
decision that did not allow much allowance for said infiltration during peak
periods of peak flows. The result being, where bottlenecks existed in the
Allentown system, with any amount of heavy or extended rainfall the lines
became surcharged. And historically, as the LCA system developed toward full
potential this surcharge condition became visible for longer durations.

***                        ***                        ***
Faced with a major storm water infiltration problem, Kandra had to determine
whether the problem was domestic (that is- confined to causes within the city) or
foreign (that is- confined to causes outside the city). The Metcalf & Eddy 1971-72
gauging study did not change plans for the installation of a relief line, but
showed the necessity for the city to initiate a program for the elimination of storm
water as well. Kandra in correspondence with Durr revealed that city council
budgeted a sum of $180,000 as “seed money” to make a start on the elimination
of storm water into the sanitary sewer systems.

Then too, bids were received January 15, 1973 for the purchase of a TV seal unit
for this purpose. The unit was delivered the latter part of February 1973. Four
additional people were hired and after one week of schooling, men and
equipment started a planned sequence of work.

But the problem was more pervasive and was impacted by external influences.
As evidenced by a full flowing pipe (29”) during peak periods (and with a state
citation in hand) Kandra decided it was time for the city to begin work on the
construction of a relief line before 1975. However, the Operations Director
realizing that with a pipe flowing one half full during morning hours, and
surcharging during rainy spells there was evidence of substantial storm water
infiltration. Thus, Kandra felt the need to address both problems. To accomplish
this end, Kandra had no alternative but to inform John Durr March 20, 1973 that
he intended to pursue the following course of action:

•        First –he would notify the Lehigh County Authority, Salisbury and South
Whitehall Townships by April 1, 1973 that the City required for its own use a
portion of the Little Lehigh Interceptor {a 1.2-mile line along the Little Lehigh
Creek, from Shrieber’s Bridge to Fountain Park}. And then, he put the same
entities on notice that they must construct a relief line running from Shrieber’s
Bridge to Fountain Park for their own use by April 1, 1974. {Authorization for
such action being found in Section 2D of both the 1965 and 1969 Sewage
Agreement}.
•        Second – approximately forty-two miles of city interceptor lines would be
inspected and sealed.
•        Third – he would formally notify Emmaus, Salisbury, South Whitehall and
the Lehigh County by April 1, 1973 of their obligations to eliminate storm water
infiltration within their respective sewer systems. And would demand that a
timetable of action must be submitted to the city within ninety days,
{Authorization for such action found not only in the 1965 and 1969 sewerage
agreements but also in the 1959 agreement as well.}

Interestingly, Kandra’s April 1, 1974 deadline passed with divergent views as to
whether infiltration into the Cit of Allentown sanitary sewer system attributable to
sources west of Allentown had been corrected sufficiently to warrant the lifting of
what in effect had been a ban or moratorium on sanitary sewer hook-ups to the
city’s trunk lines.

John P. Durr, Regional Sanitary Engineer, Pennsylvania Department of
Environmental Resources, in a March 25, 1974 response to a progress report
written by outgoing City of Allentown Operations Director George A, Kandra
commented:

“After several meetings and exchanges of correspondence, you have advised by
your letter of March 22, 1974, of significant accomplishments in the reduction of
inflow/infiltration and the plans for additional reductions by early summer of
1974, with the exception of that associated with the City’s extensive sewer
system. It would appear now that the surcharging condition has been brought
under control.”

On the one hand, this was not the opinion of Allentown City Councilman
Benjamin F. Howells Jr. or Allentown Mayor Joseph S. Daddona. Both
maintained April 17,1974 that the manhole cover on the interceptor in the Little
Lehigh Creek near Cedar Creek had overflowed during “recent rainstorms,”
indicating that the water infiltration problems were not yet solved. Daddona, in
fact, wrote to Durr that it would be a “grave mistake” to release the moratorium
on the sewer connections until the infiltration of water was substantially reduced
or until the city’s proposed Lawrence Street relief line was completed.

But John Durr did not believe that a “grave mistake” had been made when he
commented in the same March 25, 1974 letter that:

“By practicing diligence in sewer construction, continuing to eliminate
inflow/infiltration and care in issuing building permits, it is believe the existing
facilities can function within the several Department permits until the relief
intercepting sewer is constructed as well as the proposed additions to the City’s
sewage treatment plant.”

Kandra in his March 22. 1974 letter to Durr had indicated that based on survey
findings and actual repair work completed, the interceptor line in the vicinity of
Shrieber’s Bridge had been relieved. He maintained that approximately 500,000
gallons per day of clear water had been eliminated from the system in question
and, that a proposed new interceptor relief line approximately 6,000 feet in length
had been designed by the Lehigh County Authority and submitted to DER on
February 28, 1974. The submission had been made along with an application for
Federal grant funding under PL 92-500.

But the fixed reality would occur that the proposed line would not receive federal
funding. The fixed reality being the case with or without a program of
construction that would produce a completed interceptor in time for resumption
of building construction during the summer of 1974 and in advance of the federal
grant award. Interestingly, Raymond H. Snyder, General Manager for water and
wastewater of the Lehigh County Authority in a January 31, 1974 letter to
representatives of municipalities tributary to the Little Lehigh Inceptor sewer said:

“A schedule which would produce a completed interceptor in time for
resumption of building construction during the summer of 1974 would require
contract letting prior to the processing by Department of Environmental
Resources of a fund grant request. To do so would presumably make the project
ineligible for financial assistance.”

Clearly we can derive the following assumption from the before said Snyder
statement. Indeed this is hard evidence that the LCA would not let contracts for
any required relief line construction until sought after federal funding was
received; then too, the communities impacted by Kandra’s April 1, 1973 order
took a pragmatic view (that is, they demonstrated a lack of willingness to expend
local user fees or local tax resources on the project) and this approach
guaranteed that the then current environmental problem would in actuality
remain unsolved.

The consequence being that a problem was extended which had continued to
remain an active concern of citizen groups and state regulatory agencies as the
mid-1980’s arrived.

In analysis, with the Kline’s Island Wastewater Treatment Plant re-rated by DER
from a hydraulic capacity of 28.5 mgd to a hydraulic capacity of about 31 or 32.5
mgd based upon new design data gathered by the City and its sewerage
consultant Metcalf & Eddy, and the related problem at Shrieber’s Bridge
suddenly determined by DER to be relieved to its satisfaction on paper,
homebuilders and industrial development people awaited the expected lifting of
an implied but never officially mandated moratorium on new construction in
western Lehigh County. Surely, the communities west of Allentown by this turn
of events no longer had the incentive to act immediately. Rather, the incentive
was provided for these same communities to await the next crisis in order to take
action.

More specifically, prior to the expansion of the Allentown Wastewater Treatment
Plant to 40.0 mgd hydraulic capacity as called for by a 1969 agreement and after
the DER re-rating of Allentown Wastewater Treatment Plant hydraulic capacity,
the flow limits of the communities tributary to the Kline’s Island Plant stood as
follows:

        City of Allentown                23.6 mgd
        Lehigh County Authority                  4.0 mgd
        South Whitehall                          2.5 mgd
        Coplay-Whitehall                          2.3 mgd
        Salisbury                          1.2 mgd
        Borough of Emmaus                  1.4 mgd
      Total                        31.0 mgd

***                        ***                        ***

The before mentioned controversy just one of many political and environmental
problems or confrontations that has occurred between the City and those
suburban communities that tied their futures to Allentown’s city owned-and
operated sewer lines and wastewater treatment plant since 1959.

Remarkably, the unresolved nature of these controversies have given
unexpected aid and comfort to those who oppose the complete transformation
of the Lehigh County landscape from its historic base of being largely rural and
agricultural to that which is widely urban in characteristic. Why? The unresolved
nature of the continuing city-suburban controversies has unwittingly slowed the
growth of sewer related residential and industrial development in suburban
areas.

INSTALLMENT SIX

As shown in FIGURE FIVE, the upper reaches of the Lehigh County Authority
wastewater collection system extend into the Upper and Lower Macungie
Townships. Beginning in this area, the interceptor systems conveys wastewater
toward Meter Station Number 5 located near Keck’s Bridge in Salisbury
Township. Immediately following Meter Station No. 5 the Authority’s interceptor
system connects to the Emmaus Interceptor, which extends from this area to its
downstream confluence with the Cedar Creek Interceptor (more commonly
known as the Little Lehigh Trunk Sewer – Upper or the Little Lehigh Trunk Sewer
– Section 3). The Little Lehigh Trunk Sewer – Section Two (also known as the
Little Lehigh Trunk Sewer – Lower 1) begins at this confluence point and serves
as the final conveyance step in the transport of wastewater to the City of
Allentown Wastewater Treatment Plant at Kline’s Island.

***                        ***                        ***

In previous INSTALLMENTS we have already alluded to the difficulties in
reaching political settlements to the issue. But from an engineering standpoint
the problem with the interceptor, which runs parallel to the Little Lehigh Creek, is
at least understandable. The 36-inch Emmaus Interceptor and the 27-inch Cedar
Creek Interceptor discharge their combined waste loads into the 30-inch Little
Lehigh Interceptor. The result producing a pressure induced restriction and the
increased probability of the discharge of raw sewage into the Little Lehigh Creek
– a cold water stream and an important raw water source for Allentown.

But we note – engineering problems related to interlocking systems cannot be
unraveled unless regional politicians reach a mutually beneficial agreement. And,
of course, that fixed reality ought to be considered a great achievement
considering the many varied interests, and considering the fact, that in our times
men (or for that fact women) tend to love nothing but money and self.

John Durr, Regional Sanitary Engineer, Pennsylvania Department of
Environmental Resources in a letter dated May 2, 1973 to George A. Kandra,
Allentown Director of Operations commented:

“The meeting held in the City building on April 16, 1973, with representatives of
the surrounding municipalities appears to have raised more questions than
problems solved. I have requested to male all types of explanations for bans on
sewer connections by builders and residents in the suburban municipalities.

At the meeting on April 16, 1973, someone whom I cannot now identify made
reference to several dates, which would be applicable to a connection ban. I had
not addressed myself to a ban in any previous communication; however, if these
municipalities were willing to impose a ban, I was agreeable because it improves
very definitely the chance of reducing surcharging conditions. The dates that
were mentioned, I presumed, might have been in correspondence not originated
by me.”

But in subsequent discussions with many persons pertaining to the so-called
ban, Durr indicated that each municipality had an obligation to control infiltration;
and these obligations were clearly stated in the Standard Conditions that were
issued with each sewerage permit.

The following Standard Conditions were included on all sewage permits issued
prior to September 1972:

1.        No storm water from pavements, areaways, roofs, or other sources shall be
admitted to the sanitary waters herein approved, which shall be used exclusively
as carriers of domestic sewage and suitable industrial wastes. Storm water shall
be admitted only to such sewers as are specifically approved for use as
combined sewers. (Conditions Six)

(Note – the City of Easton was the only municipality in the Allentown-Bethlehem-
Easton Standard Metropolitan Statistical Area that had in part a combined sewer
system. It comprising less then 10% of the city and was located in the old
downtown section where a large amount of urban renewal projects had been
undertaken. As a part of this renewal program, when the combined sewers had
to be relocated, they would be eliminated with the construction of separate
sanitary and storm sewers.)

2.        If at any time the sewerage system of the permittee or any part thereof, or
the discharge of sewage therefrom shall have created a public nuisance, or such
discharge is or may become inimical and injurious to the public health or to
animal or aquatic life or to the use of receiving water or domestic or industrial
consumption, or for recreation, the permittee shall forthwith adopt such remedial
measures as the Sanitary Water Board may advise or approve. (Condition
Fourteen)

The following Standard Conditions included on all sewerage permits issued after
September 1972:

1.        No storm water from pavements, areaways, roofs, and foundation drains or
other sources shall be admitted to the sanitary sewers herein approved.
(Condition Five)
2.        If at any time the sewerage facilities of the permittee, or any part thereof, or
the discharge of the effluent therefrom, shall have created a public nuisance, or
such discharge is causing or contributing to pollution of the waters of the
Commonwealth, the permittee shall forthwith adopt such remedial measures as
are acceptable to the Department. (Condition Twelve)

In further comment to Kandra, Durr inferred that his office initiated no ban on
house connections. Whatismore, the sanitary engineer did not anticipate that a
house connection ban would be initiated so long as surcharging conditions
were brought under control. However, he warned that if such movement toward
achieving control had not been accomplished within the intent of item 3 of
Kandra’s letter dated March 20, 1973, then a ban would be initiated. A total ban, of
course, would require a total cessation of all new connections in the affected
area.

***                        ***                        ***

Durr had hoped that after the April 16, 1973 meeting the entities impacted by
Kandra’s April 1, 1973 pronouncement would attack the problem in a spirit of
cooperation and good will. But alas, the April 1, 1974 deadline for providing relief
to the often time surcharged Little Lehigh Interceptor passed with a muddled
situation toward ultimately resolving the issue. The fact being that prior to the
deadline there were voices that questioned whether the deadline could be met.
One such voice rose being that of William G. Malkames who opinioned that the
April 1, 1974 target date for completion of relief work was no longer realistic in
light of the fact that as of December 13, 1973 the County had not yet let a contract
for necessary engineering studies.

Being as George A. Kandra had left the post of Allentown Director of Operations
with the appointment of Harry Bisco, it was left to Harry Bisco (whose tenure in
Allentown began April 15, 1974 near the beginning of the first Daddona
Administration) to grapple with the unresolved issue of eliminating the discharge
of raw sewage into the Little Lehigh Creek by action of providing relief to the LCA-
Allentown public highway for sewage in Allentown’s Lehigh Parkway.

The task proved to be difficult and complex for the Lehigh County Authority
simply ignored the problem and devoted all their tine and attention to justifying
their inaction as being the consequence of the lack of the availability of federal
dollars to pay for the required relief interceptor. The above actually was the
position of Allentown Mayor Frank Fischl and City Council President Benjamin F.
Howells Jr. in a public statement issued September 25, 1979.

Historically there is validity in the Fischl and Howells comments of September 25,
1979.

During the course of an October 24, 1973 meeting attended by legal, engineering,
and other representatives from Allentown, Lehigh County Authority, Salisbury
and South Whitehall Townships and their authorities, it was generally agreed that
the Allentown Authority would act as financing agent for the 1.2 mile long sewer
line within Allentown’s Lehigh Parkway to be used by the before mentioned
suburban entities for the transmission of raw sewage to Allentown’s Kline’s
Island Wastewater Treatment Plant. Metcalf & Eddy, Allentown’s consulting
engineer, had determined that the cost of providing relief to the Little Lehigh
Interceptor would be $300,000 with design engineering fees, including
topographical studies adding another $20,000 to $25,000 to the project. But the
Allentown Authority by resolution dated November 14, 1973 declined to
undertake the design and construction of the before said 1.2 mile long
interceptor. Interestingly, the Allentown Authority recommended that the Lehigh
County Authority, Salisbury and South Whitehall Townships employ Metcalf &
Eddy to design the before mentioned interceptor,

The before said suggestion of the Allentown Authority receiving the approval of
the Salisbury Township Board of Commissioners late in 1973 as evidenced by a
communication dated December 28, 1973 from James G. Kellar, Salisbury
Township Solicitor to Chester S. Dutton, Chairman of the Lehigh County
Authority. But in his communication, Kellar offered a new element to the design
issue. He offered:

“Choice of a design engineer, of course, is only one small part of the over-all
situation. It would seem to me that no intelligent decisions can be made until we
have in hand the report of Malcolm Pirnie, Inc. Our respective engineers will need
to study this report so that we can intelligently come to some decisions. Until
these decisions are made, it will not be known what the design engineers are to
design. And, of course, various other decisions must be made in order to permit
preparation of the necessary agreements between the parties.”

Nevertheless, late in 1973 the Lehigh County Authority directed its engineer, A.L.
Wiesenberger Associates to proceed “immediately” with preparation of
specifications for the project. We note – by February 7, 1974 the estimated cost of
a parallel sanitary sewer line along the Little Lehigh Creek from Shrieber’s Bridge
to Fountain Park had risen $150,000 to a total cost of $500,000. And of
importance, by February 28, 1974, engineering design, in form suitable for review
by the Pennsylvania Department of Environmental Resources, was submitted to
that agency, in time to meet the March 1, 1974 Federal application for funding
under PL 92-500.

Thereafter, A.L. Wiesenberger Associates proceeded to finalize design details, in
order to get plans in condition for presentation to the interested municipalities for
review and comment. At that point the Lehigh County Authority would expect to
meet with representatives of each affected municipality in order to reconcile any
problem involving design and achieve agreement in regard to a cost-sharing
plan.

According to Raymond H. Snyder, General Manage of the Lehigh County
Authority, in an April 30, 1974 communication to municipalities tributary to the
Shrieber’s Bridge intercepting sewer, it did not seem appropriate to ask the
parties to convene until the LCA had the final design and estimated project costs
that could then be translated into cost sharing figures.

Then too, Snyder observed in the same April 30, 1974 letter:

“As we have told officials of both Allentown and Department of Environmental
Resources, of course, a considerable amount of infiltration/inflow work was
under contract or otherwise committed, but not yet physically accomplished, as
our 19 March letter to those officials. It is essential that this work move along on
schedule. Otherwise we may expect Allentown officials to take action to protect
their water quality.”

Unfortunately, difficulties related to obtaining federal assistance forced serious
delays in the resolution of the problem for the Lehigh county Authority and the
suburban municipalities to Allentown’s frustration demonstrated a lack of
willingness to expend local user or tax resources for the project. And
additionally, the situation became more complex when Malcolm Pirnie, Inc, of
White Plains, New York, retained by the Lehigh County Authority to perform a
variety of services related to the development of a countywide sewerage system,
released a report that included comment in regard to the before said mentioned
parallel interceptor.

***                        ***                        ***

Also, It is our continuing concern that resolution of the problem would be
predicated upon the suburban municipalities determining their place in the
undefined future. Indeed they did not want their growth activities limited or
thwarted by the fixed reality of the ultimate capacity of the City of Allentown
wastewater treatment systems and by political cunning sanctioned by Ordinance
and contract agreements. After all, they reasoned, economic activity in the
suburban areas would keep the Lehigh Valley a growth area throughout the rest
of the twentieth century and beyond – at least that was their hope

In 1973 – the Lehigh County Authority retained the services of Malcolm Pirnie,
Inc., Consulting Environmental Engineers to develop a comprehensive
wastewater management plan for Lehigh County for purposes of maintaining
acceptable water quality in local streams that will be or have been impacted to
future year detriment by past, present and future growth activities. This would be
accomplished by the eventual construction of appropriate water pollution control
facilities.

Among the immediate concerns that confronted Malcolm Pirnie in 1973 were:

•        The need to improve the processing of high strength industrial waste at the
LCA’s pre-treatment plant located in Upper Macungie;
•        The need to reduce or eliminate groundwater and storm water infiltration
into the LCA Interceptors; and
•        The need to provide relief to prevent periodic overflow conditions of the City
of Allentown’s Little Lehigh Interceptor.
And of course, Malcolm Pirnie’s expertise in regard to these was reflected in its
“Summary Report to Lehigh County Authority, Lehigh County on Water Pollution
Control Facilities – September 1974.”

In regard to existing wastewater treatment facilities, Malcolm Pirnie maintained
the following in its report:

“The existing wastewater treatment collection and treatment facilities within the
County include a system of regional interceptors and trunk sewers terminating at
the existing Allentown Wastewater Treatment Plant on Kline (sic) Island and two
smaller wastewater collection and treatment systems on the Lehigh River at
Catasauqua and Slatington. The capacity of the Allentown plant will be 40 mgd
upon completion of a current expansion program. Hydraulic studies by Metcalf &
Eddy, Inc., Consulting Engineers for Allentown, have indicated that process-
piping sizes limit any further expansion of the existing Allentown plant.
Therefore, a separate new facility will be required.”

The Catasauqua and Slatington plants can be modified to meet stream standards
and expanded to provide the 2.5 mgd and 0.8 mgd flow capacities, respectively,
which are estimated for those services areas in 1995. Like the Kline (sic) Island
site at Allentown, the Catasauqua plant could become a regional wastewater
treatment site by the addition of a new plant. The Slatington site, however, is too
remote from central Lehigh County to be used as a regional site.”

The separate new regional facility for wastewater processing in addition to
Catasauqua alluded to above by Malcolm Pirnie would be located in the
Riverside Industrial Park Tract in Salisbury Township. Malcolm Pirnie determined
that the tract of land met all of the environmental and physical criteria established
for new treatment plant sites in Lehigh County.

That is:

        Size and shape of site;
        Topography of site;
        Proximity to development;
        Potential for flooding;
        Accessibility for construction and operation of maintenance functions;
        Foundation conditions;
        Environmental conditions; and
        Receiving stream discharge criteria.

Whatismore – Malcolm Pirnie maintained that the Riverside tract was the only
tract of sufficient size to support the additional advanced wastewater treatment
facilities that would ultimately be needed in the future in Central Lehigh County.

TABLE VIII defines the recommended service areas plant locations, and
treatment capacities of the “required” wastewater treatment facilities for Central
Lehigh County.



TABLE VIII
RECOMMENDED TREATMENT FACILITIES AND SERVICE AREAS

LOCATION                        TREATMENT FACILITY        SERVICE AREA
Catasauqua                        2.5 mgd sub-regional plant                Catasauqua, North
Catasauqua
                                                   And Hanover
Allentown                        40 mgd regional plant                Allentown, Salisbury
Township,
                                                   Emmaus and portions of the
                                                   Cedar Creek drainage basins
Salisbury (Riverside)                15 mgd regional plant                Western Lehigh
County and
                                                   Portions of northern central
                                                   Lehigh County where flows
                                                   Exceed the capacity of the
                                                   Allentown plant

Malcolm Pirnie in its 1974 report addressed the issue of adequate capacity of
existing regional interceptors and force mains. It related:

“A system of regional interceptors currently exists in Lehigh County. Some of
these facilities, however, are now being used to capacity and, in some cases, in
excess of capacity resulting in periodic overflows to adjacent streams.”

Malcolm Pirnie then recommended that the following measures be taken to
alleviate the problem:

“The first phase construction program will provide an express pipeline from
western Lehigh County to the vicinity of Kline (sic) Island to relieve the already
overloaded Little Lehigh Creek Interceptor through Allentown. It also will provide
a pumping station and force main from the area adjacent to Kline (sic) Island to
the Riverside plant site. A connection with the Allentown plant will provide added
reliability to the system because each plant will be able to act as standby for the
other in case of temporary plant upset.

Later phases of construction will reinforce existing facilities to the north and est
of the Little Lehigh Creek pipeline.”

***                        ***                        ***

Of course, what Malcolm Pirnie proposed would have an economic cost. And the
fatal flaw in the proposal would be that the Lehigh County Authority would not
finance the cost unless it was able to receive a sufficient level of federal and state
funding.

The estimated construction costs for the recommended project, which included
pipelines, pumping facilities, and wastewater treatment facilities, were based on
preliminary design data for the wastewater treatment facilities. The United States
Engineering News Record (USENR) Construction Cost Index was used for
developing construction costs trends.
The total and net local project costs for the facilities included in the first phase of
the recommended plan are shown in TABLE IX. Malcolm Pirnie estimates
included allowances for technical services, legal and financial costs, and for
construction contingencies. Also, it reflected an anticipated 75 percent federal
grant for eligible construction costs.


TABLE IX
ESTIMATED CONSTRUCTION AND PROJECTS COST
FIRST PHASE OF LEHIGH COUNTY AUTHORITY CONSTRUCTION PROGRAM
USENR = 2800 FOR TREATMENT PLANT USE
USENR = 2600 FOR ALL OTHER FACILITIES

Description of Facilities                        Area Served                        Estimated Cost
Little Lehigh Creek Interceptor                Portions of Upper and
Keck’s Bridge to Lehigh River,                Lower Macungie, Alburtis,
48”, 6.3 miles                                Macungie, and Upper Milford        $ 5,000,000

Lehigh River Pumping Station                All of above and North
                           Central Lehigh County                $ 3,500,000

Lehigh River Force Main 30”                All of the above and North
Sewer, 2.3 miles                                central Lehigh County                $ 1,200.000

   Subtotal – Construction costs of pipelines and
               Pumping Station                                $ 9,700,000

Riverside Treatment Plant                        Western and North Central
15 mgd capacity                                Lehigh County                               $24,800.00

   Total - Construction Costs                                        $34,500,000

Contingency and Technical Services                                        $ 6,900,000

   Subtotal – Eligible Construction Costs                        $41,400,000

Federal Aid at 75% of Eligible Construction Costs                                $31,100,000

   Subtotal ---- Local Project Cost                                $10,300,000

Estimated land, Rights of way, legal costs and conversion of
Pretreatment Plant to Chemical Feed Station                                        $ 1,500,000

Financing Costs

Interest during Construction                                        $ 1,000,000
Bonding Costs Including Reserve Funds                                $ 1,800,000

Net local Project Costs                                                $14,600,000


Figure Six













***                        ***                        ***

In final analysis, comprehensive examination of the 1974 Malcolm Pirnie
document offers us a key to understand the fixed reality of ongoing political and
environmental battles that have occurred during the past decade.

Of interest, the Malcolm Pirnie document plain and simple is a blue print for
continued economic development – that is, a blue print for continued growth
activities in western Lehigh County. The document also was a plan that would
promote or foster an enhanced degree of urbanization in Lehigh County.

Malcolm Pirnie presented its own analysis of the merits of its own recommended
plan in the following statement:

“The recommended plan combines economy of scale for treatment works with
an integrated system for utilization of existing interceptor capacity and an
environmentally sound plan for future wastewater management in the Study
Area. It is, first of all, cost effective relative to any other alternatives that may be
considered. Second, staffing of a single new treatment plant will likely present
fewer problems than for two or more new plants. Third, the selection of the
Riverside site over the Kline (sic) Island site provide flexibility for future process
changes or additions at Kline (sic) Island, better utilization of the assimilative
capacity of the Lehigh River, and generally lower treatment requirements. Finally,
the new facilities at the Riverside site will be designed to accommodate the
special BOD5 and suspended solids wastewater characteristics and loadings
produced by the existing industry in the western part of the County. Therefore,
the existing pretreatment plant in Trexlertown will be converted to a chemical
feeding station for the purpose of providing for chemical addition to the County
wastewater en route to the new facilities.”

Allentown officials, quite certainly, were not philosophically opposed to the
concept of enhanced urbanization of Lehigh County. Just the same, Allentown
officials, seeking to protect their long-standing financial investment in the Kline’s
Island Wastewater Treatment Plant and administration position in regard to the
network of sewers and treatment facilities within Lehigh County, sought from its
engineering consultant, Metcalf & Eddy, viable alternatives to counter the
program advanced by the County.

Metcalf & Eddy’s response being found in Report to Allentown Authority,
Allentown, Pennsylvania on Additional Wastewater Treatment Facilities on Kline’
s Island --- November 18, 1977. The Report suggesting the following alternatives
in the administration of sewer and wastewater treatment facilities within Lehigh
County:

“There are two prime alternatives in the administration of the sewer and
treatment facilities within Lehigh County. First, total administrative capabilities
can be assumed by one management organization. Second, facility
administration can be split between two or more organizations, with a division of
operational and billing responsibilities. The visibility of each mode of
administration will also be affected by whether or not each administration utilizes
agreements as a definitive tool to divide responsibilities among the signatories,
and whether or not communities serviced by these facilities will be split between
to treatment plant sites. An assessment of the existing agreements should first
be made, with subsequent analysis of the advantages and disadvantages of
facility administration by one or tow administrative organizations.”

Importantly, this subsequent analysis of the disadvantages and disadvantages
of facility administration by one or two administrative organizations can be
extracted from the Executive Summary of Conclusions and Recommendations
contained within the same report.

Please note – One Metcalf & Eddy conclusion being the following:

“… A comparison was made of the costs associated with construction, operation
and maintenance of plant expansion at Kline’s Island with the costs developed in
the September 1974 Malcolm Pirnie report for plant expansion at the Riverside
Industrial Park site and adjusted to current dollars. Construction costs should be
about equal. Operation and Maintenance costs, on the other hand, should be
considerably lower for the Kline’s Island site.”

The above conclusion resulting in the following recommendation:

“… Since the Kline’s Island land site will be most cost-effective for location of
additional treatment capacity, there appears to be no inherent advantages to
removing or replacing the Allentown Authority as the managing organization
responsible for operating and financing wastewater treatment facilities for
Lehigh County communities tributary to Kline’s Island.”

Having made its professional opinion very clear, Metcalf & Eddy in its 1977
Report proceeded to detail a project program that contemplated the additional
expansion of the Allentown Wastewater Treatment Plant from its anticipated 40
mgd hydraulic rating after the present expansion to 70 mgd hydraulic rating
sometime around the year 2016. This proposed expansion to be accomplished in
increments of three 10 mgd expansion phases.

But interestingly, the Allentown Authority’s position as the managing
organization responsible for operating and financing wastewater treatment
facilities for and Lehigh County communities tributary to Kline’s Island did
change. This change seemingly indicated in a letter dated November 18, 1977 to
then Mayor Joseph S. Daddona from Charles Y. Hitchcock, Jr., Senior Vice
President for Metcalf & Eddy, Inc. that accompanied the engineering firms report.

The historical record was that the City of Allentown for whatever motive and long-
range purpose had reassumed financial liability for sewer and wastewater
treatment debts March 15, 1977. The City of Allentown having sold ownership
rights to the wastewater treatment plant and accessory carriers and interceptor
systems by formal agreement with the Allentown Authority dated May 1, 1960.
But by leaseback it retained rights to function as operator and manager of the
wastewater treatment plant and its accessory carriers and interceptor systems.

As stated by City Councilman Watson Skinner Jr, March 2, 1977, this formal
reversal in city policy was based on economics. Skinner claiming that the twin
impact of reduced interest rates on the refinanced bond issue and the elimination
of the requirement to set aside twenty per cent of annual debt payments would
save $918,000 over the next twenty-nine years. In analysis of Skinner’s
statement, longtime City Controller Louis Hershman informs us that under then
existing state and federal laws and regulations that the Authority operated, it had
to maintain a twenty per cent escrow account above and beyond its contracted
debts or liabilities. This escrow account according to Hershman was not
required of the City under then applicable state and federal laws and regulations.

On the surface, at least, one can reasonably conclude that the prime motivation
for the Administration’s sponsored initiative to regain for the City of Allentown
ownership of the Kline’s Island Wastewater Treatment Plant and accessory
carriers and interceptor systems as being economic. But in the long-range
additional motivation can be postulated considering the new directions of
regional economics and political adventurism. The point is Skinner also implied
March 2, 1977 that the City’s Administrative Department would have
recommended this transfer even if no dollar savings were involved. That the
Administrative Department actually wanted an immediacy in decision-making for
Mayor Daddona and Leo Fetzer, the Business Manager of the City of Allentown,
in attacking the difficult sewage issue. Of material import, in 1977 Daddona faced
a tough re-election challenge.

(Please note – the Joint Planning Commission of Lehigh-Northampton Counties,
interestingly, revealed March 2, 1977 a plan to set aside 3.7 million gallons of
future sewage capacity at Allentown’s Kline’s Island Wastewater Treatment Plant
for industrial and commercial growth. The plan proposes “pooling” that amount,
rather than allocating it to the individual municipalities linked to the Kline’s Island
Plant. The plan being developed in wake of an Allentown proposed tax-base
sharing system, whereby all signatories would gain a part of the new tax
generated by industrial and commercial growth.

The advantages of a tax-base sharing system being the following:

•        It is said to reduce competition among jurisdictions for commercial and
industrial development. That is, each member community within a region shares
in the benefits of commercial-industrial growth.
•        There is said to be a reduction for the need to make land decisions purely
on economic grounds. That is, other considerations, such as environmental
impact, could be given increased weight in the decision-making process.
Then too, the disadvantages of a tax-base sharing system being the following:

•        It would appear that under Pennsylvania law a strict application of the
formula is impossible. That is, industrial-commercial property cannot be taxed at
two different rates by a municipality.
•        There appears to be no legislative mandate to compel local governments to
cooperate in a tax-base sharing plan.

Indeed we ask – Was Allentown, whose public position has always been stated
that the City of Allentown should remain the managing organization for operating
and financing wastewater treatment facilities for Lehigh County communities
tributary to Kline’s Island, prepared to bargain for the sell out of its system and its
responsibility to either private industry, the Lehigh County Authority or a new
created county wide regional authority? Then too, we ask – Did Joe Daddona,
Sam Costa, Dennis Cramsey, Watson Skinner, Alton Frey Jr., Benjamin F.
Howells Jr., Bob Lang, Karl Kercher, Leon Hontz and Thelma Barnes serve as
facilitators to advance this long-range objective?

Importantly, in the short-range, the elimination of the Allentown Authority’s
mandate in regard to wastewater treatment matters streamlined the cast of
characters responsible to state Allentown’s position during negotiations for a
long-term sewerage solution with Allentown’s sewer district signatories. The
implication being, the approval of the Allentown Authority was no longer required
for ratification of any long-term sewerage pact with Allentown’s Sewer district
signatories. The net effect being that the City Administration would have a freer
hand to deal directly with difficult regional issues.

Important too, if Allentown Mayor, if Allentown Mayor Joseph S. Daddona had
any long-range plan for settlement of regional economic and developmental
issues, this plan was either taken over, reshaped, put on hold or derailed with his
defeat in the 1977 Mayoral election by Republican Frank Fischl.

As it occurred in March, 1979, it would be the responsibility of Frank Fischl not
Joseph S. Daddona to deal with Lehigh County Executive David K. Bausch in
order to prepare the groundwork to settle outstanding economic and fiscal
problems between the County, City and outlaying municipalities. This initiative
would lead to the formation of the Allentown-Lehigh County Greater Community
Council. The Council’s prime purpose was “to develop a constructive, realistic
and implementable solution” to several regional issues.

Please note – the most complex and perplexing was the regional sewage
problem. A problem related to signatory disputes over sewage treatment
capacity and the future provision of treatment facilities when needed.

It being the stated intent of the Allentown --- Lehigh County Greater Community
Council ( Co-chaired by Dexter F. Baker, President, Air Products & Chemicals,
Inc. and Robert K. Campbell, President, Pennsylvania Power & Light Company)
that it create an analytical database that officials from the City of Allentown,
County of Lehigh and Allentown Sewer District Signatories could refer to during
negotiation stage of regional sewage problem resolution. This analytical
database can be found in its report entitled Sewage Task Force Report ---
Analysis of the Issues and Recommendations --- November 1980.

The Council report made the following recommendations of regional historical
importance:
1.        A regional authority should be created through the “buyout” of the
Allentown Sewage Treatment Plant and all intercepting sewers then owned by
Allentown and suburban municipalities. Collection systems should remain the
responsibility of local municipalities.
2.        Acquisition of above systems would be accomplished through a “wash”
arrangement. The regional authority would then assume all outstanding debt and
pay back through an current value credit all equity which each municipality then
held in the system.
3.        A regional economic development policy based on the Joint Planning
Commission’s 1977 Comprehensive Plan would then be implemented to match
industrial and commercial growth to available sewerage capacity.
4.        A portion of the available capacity at the Allentown Sewage Treatment
Plant would then be allocated to an industrial and commercial pool to facilitate
the attraction of new industries.
5.        Capital projects should be undertaken to increase the capacity of the
Allentown Sewage Treatment Plant to treat biochemical oxygen demand (BOD)
and suspended solids (S/S), and to reduce the inflow/infiltration in sewage
system.

Historically, the City of Allentown, County of Lehigh, the Coplay-Whitehall Sewer
Authority, the Lehigh County Authority, the Township of Salisbury and the
Township of South Whitehall reached accommodation in regard to sewage
treatment capacity and other outstanding issues in December 1981 near the end
of the Fischl Administration.

As stated in the agreement’s preamble “the City is, and at all times, was the legal
titleholder and operator of a sewage and wastewater treatment plant.”  Thus the
debate over sew plant equity ended with a regional agreement that formally
characterized the County of Lehigh and the other signatories as customers of
the City,” who purchase and will purchase a service, which is the transmission of
their wastewater discharge from the City limits to the City treatment plant” for
purposes of treatment of this wastewater.

Prior to the regional agreement, treatment capacity in the Allentown Treatment
Plant was subject to one limitation, namely Hydraulic Flow. After the regional
agreement, treatment capacity in the Allentown Treatment Plant became subject
to two limitations, namely Hydraulic Flow and Allowable Loadings.

By agreement, no party to the agreement would be able to exceed its Hydraulic
Flow limit or it Allowable Loadings limit. The term “Hydraulic Flow” refers to the
volume or amount of wastewater discharged by a signatory for treatment at the
Treatment Plant.

More specifically, prior to the December 1981 regional agreement Hydraulic Flow
limits of the signatories were as follows:

City of Allentown                        28.2 mgd *
Lehigh County Authority                                4.5 mgd
South Whitehall                                  2.0 mgd
Coplay-Whitehall                                  2.3 mgd
Salisbury                                        1.6 mgd
Borough of Emmaus                          1.4 mgd
                                   _______
                   Total                 40.0 mgd

•        Allentown figures includes 0.5 mgd of allocation committed to South
Whitehall.

After the         December 1981 regional agreement Hydraulic Flow limits of the
signatories stand as follows:

City of Allentown                        23.05 mgd *
Lehigh County Authority                                6.15 mgd
South Whitehall                                  2.00 mgd
Coplay-Whitehall                                  3.42 mgd
Salisbury                                        1.98 mgd
Borough of Emmaus                          1.40 mgd
                                   _______
                   Total                 40.0 mgd

•        Allentown figures includes 0.5 mgd of allocation committed to South
Whitehall.
•        Environmental Reserve includes 0.25 of Allentown allocation committed to
South Whitehall.

Importantly, within the context of the 1981 agreement, the signatories of the
regional agreement, acknowledged publicly that the operation of the Treatment
Plant and the City’s Interceptor Sewers have created environmental problems in
the form of odors, excessive stockpiling of sludge, organic overloading and
overflows from the Interceptor sewers. Consequently, the pact mandates that the
signatories agree to the following conditions:

1.        That the signatories use their best efforts to work cooperatively in solving
said problems;
2.        That the suburban municipalities agree to assist the City in obtaining sites
to dispose of sludge with the cost thereof shared as set forth in the pact:
3.        That the suburban municipalities neither initiate nor support efforts to
prevent disposal of sludge on any site approved by the Pennsylvania
Department of Environmental Resources;
4.        That when said environmental problems are solved to the satisfaction of
the Mayor of Allentown “in accordance with reasonable objective standards,” an
additional 2.0 mgd treatment capacity held in Environmental Reserve for Future
Allocation would be distributed and allocated as follows:

City of Allentown                1.35 mgd *
Lehigh County Authority                0.34 mgd
Coplay-Whitehall                        0.20 mgd
Salisbury                        0.11 mgd

•        Please note --- 0.25 of Allentown’s reserve allocation actually belongs to
South Whitehall Township “ when and at such time “ the Township
demonstrates “ a desire or need for additional Hydraulic Flow capacity.

The term “Allowable Loadings” refers to the characteristics of wastewater
discharged by any signatory with respect to three specific characteristics,
namely, 5-day Biochemical Oxygen Demand (BOD), Suspended Solids (“S/S”)
and Total Kjeldahl Nitrogen (“TKN”).

More specifically, the design capacity of Allentown’s Kline’s Island Wastewater
Treatment Plant with respect of said three items is:

BOD                         210 mg/l
S/S                        230 mg/l
TKN                          40 mg/l

Which means based upon the Hydraulic Flow allocations of each of the
signatories and the stated design capacities of the Kline’s Island Plant, the
Allowable Loadings of each of the signatories is stipulated as follows:

ALLOWABLE LOADINGS PRIOR TO DISTRIBUTION OF 2.0 ENVIRONMENTAL
RESERVES

Hydraulic Flow                Allowable loadings (lbs per day)                
Party                                Allocation MGD                BOD                S/S                TKN        
City of Allentown*                23.05                        40,370                44,215                7,690
Lehigh County Authority                  6.15                        10,771                11,797                
2,051
South Whitehall                          2.0                          3,503                  3,836                   667
Coplay-Whitehall                          3.12                          5,465                  5,985                
1,041
Coplay-Whitehall (LV Dairy)**          0.30                             525                     
575                   100
Salisbury                         1.98                          3,468                  3,798                   661
Emmaus                                 1.4                          2,452                  2,685                   467
Environmental Reserves                 2.0                          3,503                  3,836                   
667
   Total                      40.0                        70,057                76,727                    13,344

* Includes loadings attributable to 0.5 mgd committed to South Whitehall.
** The Lehigh Dairy, formerly a customer of the City, exceeded these loading
limits in 1981. Any loadings above these limits were deemed to be loadings of the
City.

ALLOWABLE LOADINGS AFTER DISTRIBUTION OF 2.0 ENVIRONMENTAL
RESERVES

Hydraulic Flow                Allowable loadings (lbs per day)                
Party                                Allocation MGD                BOD                S/S                TKN        
City of Allentown*                24.40                        42,734                46,804                8,140
Lehigh County Authority                  6.49                        11,364                12,405                
2,165
South Whitehall                          2.0                          3,503                  3,836                   667
Coplay-Whitehall                          3.32                          5,815                  6,365                
1,108
Coplay-Whitehall (LV Dairy)**          0.30                             525                     
575                   100
Salisbury                         2.09                          3,661                  4,009                   697
Emmaus                                 1.4                          2,452                  2,685                   467
   Total                      40.0                        70,057                76,727                    13,344

* Includes loadings attributable to 0.75mgd committed to South Whitehall.
** The Lehigh Dairy, formerly a customer of the City, exceeded these loading
limits in 1981. Any loadings above these limits were deemed to be loadings of the
City.

And finally, the 1981 agreement recognized that the loading in the wastewater
then being discharged by the Lehigh County Authority exceed the County
Authority’s stated allowable loadings because of the absence of pretreatment of
certain industrial wastes, namely creamery and brewery wastes. Therefore,
Lehigh County agreed that within five years from the date of the agreement” it
will provide, or cause to be provided, such pretreatment as to bring the County
Authority within the limits of its Allowable Loadings, or cause to be provided, an
alternate solution to said overloading problem which is acceptable to the City
and which does not reduce or infringe upon the rights of the other parties with
respect to Hydraulic Flow allocation and/or Allowable Loadings under the
agreement.”

Of interest, during the stated five-year period, the Lehigh County Authority (LCA)
did have the right to continue to exceed its allowable Loadings upon payment of
the proper charges for treatment of the over-strength wastewater so discharged.
But it did not have the right during the same period to allow any new or
additional discharges of wastewater in aggregate exceeding 2,890 pounds per
day of BOD, 3,165 pounds per day of S/S, or 550 pounds per day TKN.

As it happened, the County’s new pretreatment plant was not in line by
December 1986 as stipulated in the agreement.

Hence it was up to Joseph S. Daddona who succeeded Frank Fischl in 1982 as
Allentown Mayor to deal with County delays in meeting its contractual
commitments and also to determine when the before stated environmental
problems were resolved “in accordance with reasonable, objective standards” to
allow the release of the promised additional allocation to the signatories.

Then too, there remained for Daddona’s attention issues, differences or disputes
that remained unsettled between the City and the other parties to the 1981
agreement, namely:

1.        The establishment of a regional sewer agency of some type to possibly
own and operate the Treatment Plant, to plan and build any future treatment
plants as they may be needed, to own and operate major interceptors and to own
and operate all of the collection systems themselves;
2.        The amount of any additional future capacity which may be required by the
various parties to the 1981 agreement;
3.        Storm water run-off controls and programs to minimize and prevent
downstream flooding problems; and
4.        The regional benefits of tax base sharing and transfer of financial
responsibility for City services and facilities to the County for purpose of cost
effectiveness and equity.

(P.S. --- Concerning Point One, when all this was happening we worried that the
Lehigh County Authority which started out as a water authority and which built
the disasterous Wiesenberger Pre-treatment plant would be given the
responsibility of serving as a regional sewer agency in any future agreement.)


INSTALLMENT SEVEN

We note – the proposed Riverside Plant did not become fact in the last seventies;
and, it has not become fact as we enter the twenty-first century. Yet the concept
was not completely forgotten in the 80’s and 90’s by those who had a vested
interest in promoting the creation of a new metropolis west of Allentown.
In fact, at a meeting not open to the public held February 1, 1985, James M.
Montgomery, Inc. Engineering Consultant for Lehigh County, briefed Terry
Schutten, Lehigh County Administrator, Rob Fulton, Lehigh County Director of
Human Services, Jim Creedon, Lehigh County Director of Planning and
Development and Lehigh County Commissioners John Brosious and John
Yurconic in regard to various options for Lehigh County’s proposed
construction of a new sewage plant.

Simply put, the following main proposals with variations or refinements were
presented to the participants attending the secret sessions:

1.        A large-scale full treatment plant near Fogelsville for industrial and
domestic users;
2.        A pre-treatment plant which could be converted to a full treatment plant;
3.        A facility which could be strictly pre-treatment to satisfy the County’s
obligations to Stroh brewery; and
4.        A full treatment plant for all users at the Riverside Industrial Park in
Salisbury Township.

Of interest is Point Four, for here we see the rebirth or reactivation of the
Riverside Industrial Park Sewage Treatment Plant idea. We emphasize that the
infrastructure to be created will not exactly be duplicate of what Malcolm Pirnie
suggested in its 1974 blueprint for action but it would be similar, In otherwords
the directors have tinkered with the general plot as outlined by the author but
overall the plot will be generally the same. This Phoenix-like reappearance of the
concept of Riverside or new boldness to promote growth activities becomes
even more obvious with knowledge that the Lehigh County Authority November,
1984 has updated Malcolm Pirnie’s July, 1974 plans to provide “relief “ to the
Allentown/Emmaus Interceptor from Keck’s Bridge to the Jefferson Street Lehigh
County Authority Park Pumping Station with the installation of a large 42”/48”
diameter Gravity Flow interceptor. Coincidentally, the 1974 Malcolm Pirnie Report
proposed a 48” diameter line leading from Keck’s Bridge to the vicinity of Basin
Street which would be connected with a 30 mgd Pumping Station and 30”
diameter force main leading to the Riverside Industrial Park Sewage Treatment
Plant. A 42” diameter line leading from the Lehigh County Authority Service Area
would connect to the Keck Bridge 48” diameter line. But interestingly, LCA’s
existing infrastructure within Allentown’s municipal boundaries completed
December 1983 (that is, a 16 mgd capacity LCA Park Pumping Station with
accompanying 24”, 30” and 36” diameter Force Mains leading from the Jefferson
Street area to the Little Lehigh Interceptor at the confluence of the Little Lehigh
and Trout Creek) was never suggested in the original Malcolm Pirnie proposal.

We ask – Why then were the LCA Park Pumping Station and the accompanying
Jefferson Street Force Mains built? We respond – It was the expedient end result
of events that started with Pennsylvania Department of Environmental
Resources Regional Sanitary Engineer John P. Durr’s message to Allentown
Director of Operations George A. Kandra February 20, 1973. The term expedient
being the correct term to use because industrial development loan agencies,
developers, and township planners did not want their activities in western
Lehigh County handicapped by temporary or permanent bans on sewage
connections to the Allentown wastewater treatment plant.

Then too- it was for the purpose of obtaining continued access to contract
allocated reserve capacity in the Allentown plant that developers agreed to fund
construction costs for the temporary LCA above ground relief line running from
Shrieber’s Bridge to the vicinity of Fountain Park that visitors to Allentown’s
Lehigh Parkway have termed in a non affectionate way the “Green Monster.” But
in analysis, the design and environmental conditions that necessitated the relief
of the Little Lehigh Interceptor at Shrieber’s Bridge were not solved by the
construction of the “Green Monster” or by its successor the LCA Park Pumping
Station – Jefferson Street Force Main Water Control Construction Project. Why?
These projects did nothing to resolve the inflow/infiltration problems of the LCA
infrastructure outside the boundaries of Allentown; and more important, the peak
flow surcharge condition as evident at Shrieber’s Bridge was only transferred
upstream to the Keck’s Bridge area.

***                        ***                        ***

But professional we realize our research would be devalued and incomplete if
we ignored or overlooked the following historical summarization as provided by
George L. Parks, Regional Water Quality Manager, Pennsylvania Department of
Environmental Resources in relationship to restrictions placed on western
Lehigh County sewer extensions into the Allentown wastewater treatment
system resultant from problems associated with the Little Lehigh Interceptor.
This historical summarization found in a communication written February 12,
1982 by George L. Parks and delivered by certified mail to the Presidents of the
Lower Macungie Township Sewage Authority and the Salisbury Township Board
of Commissioners. Thus, from his perspective, Mr. Parks writes:

“ On Ma 29, 1979, I wrote to the parties and municipalities shown on the attached
sheet briefly explaining the problems and proposed solutions to the Little Lehigh
Interceptor which is tributary to the Allentown Sewage Treatment Plant. In my
letter, I expressed concern with allowing uncontrolled sewer extensions being
connected to the Little Lehigh Interceptor. I stated that we would allow
connections to be made and that they totaled approximately nine hundred (900)
equivalent dwelling units, we would reassess the capacity of the existing lines
and make determination whether or not to allow continued connections to be
made to the Little Lehigh Interceptor.

Please note – historically a reassessment of Little Lehigh Interceptor Capacity
having been made September 30, 1981 and November 11, 1981. Consequently
Parks relying on this data presents the following observation in his February 12,
1982 communications:

“On September 30, 1981, and November 11, 1981, with the assistance of the City
of Allentown, we conducted surveys of the Little Lehigh Interceptor to determine
whether or not to allow additional sewer connections to be made to this line. The
temporary relief line appears to be successful; the permanent relief line is
currently under construction and should be in service in approximately one and
one-half years, and there visibly appears to be a modicum of capacity left in the
Little Lehigh Interceptor.”

The implication of this observation was that the Department of Environmental
Resources would lift all environmental restrictions to western Lehigh County
sewer restrictions. Leaving in place only those restrictions based on contractual
obligations and responsibilities. Thus, Parks concludes his February 12, 1981
communication with the following emphasis:

“ The above reasons coupled with no problems being reported during the nearly
three-year period has caused us now to allow additional connections to be made
to the Little Lehigh Interceptor and its tributary lines. These connections shall not
exceed the remaining capacity of the interceptor and shall be monitored jointly
by the Lehigh County Authority and the City of Allentown. If problems do occur
with the Little Lehigh Interceptor, the Lehigh County Authority and the City of
Allentown shall cause immediate corrective action to be taken.”

SUMMATION

Looking back into history, it is amazing that in 1974 Malcolm Pirnie estimated the
total cost of constructing a completely new sewage treatment network
complementing the Allentown system would be $41.4 million. Of course, as
evidenced by the Lehigh County Board of Commissioners December 1984
approval of a $48 million bond issue in preparation for decision-making in regard
to various options involving full or partial treatment of wastes in the LCA service
area, the cost would be much larger. It becoming public knowledge that Lehigh
County prior to making its final decision never had serious intent of providing a
full-scale wastewater treatment plant in Upper Macungie. That, a pre-treatment
plant, with additional design capacity would be built to serve planned Stroh
Brewery production increases and existing operations at Kraft Foods. Lehigh
County having become by a 1981 agreement with Allentown to replace its
defunct pre-treatment facility in Upper Macungie with some type of pre-treatment
capacity. The option still left the door for the future construction of the Riverside
Industrial Park Wastewater Treatment Plant in Salisbury Township. Allowing
justification for speculation that in the interim the public would be prepared for
such eventuality by the manipulation of events and the continuation and
transference of existing environmental problems.

Importantly, Malcolm Pirnie was contracted by LCA to update existing flow
estimates for and estimate hydraulic capacity of the Allentown/Emmaus
Interceptor, review the magnitude and frequency of overflows which had been
occurring in the Keck’s Bridge area, and estimate maximum infiltration and inflow
rates. In July 198, Malcolm Pirnie completed its study and presented its finding
entitle Report on Allentown/Emmaus Interceptor to the Lehigh County Authority.
The report examined several methods, which would increase the capacity of the
Allentown/Emmaus Interceptor, effectively eliminating the sewage overflows into
the Little Lehigh Creek and allow for the future expansion anticipated in the
western portion of the county. A preferred alternative was presented and after
review by the LCA and the Pennsylvania Department of Environmental
Resources, the decision was made to proceed with design bases upon the
preferred alternative, consisting of a 36-inch diameter dual decked gravity/force
main utilizing the original sewer trench.

The managers of LCA received the necessary approval of the Allentown City
Council August 15, 1984 for their preferred alternative and withstood a
September 5, 1984 effort to rescind the said approval.

But the results of a soil test pit program (conducted to determine the type of soil
to be excavated, the depth of ground water and most importantly, the condition
and prevalence of rock along the proposed course of the new interceptor)
created the possibility of additional alternatives that would be more cost effective
than the preferred alternative identified in the July 1984 report. Thus, Malcolm
Pirnie released its Updated Report on the Allentown/Emmaus Interceptor
November 1984. And, of course, we find it extremely fascinating that the new
preferred alternative called for the step-by-step upgrading of capacity of the LCA
Park Pumping Station to 40mgd. Then too, this alternative would require that
approximately 2,000 feet of 30” diameter force main be constructed from the Park
Pumping Station to the upstream end of the existing 36” diameter section of the
Little Lehigh Relief Force Main.

In analysis – we viewed the new proposed alternative as a means to bring the
existing LCA infrastructure within Allentown in line as much as possible with the
original 1974 Malcolm Pirnie blueprint to service Riverside. And also, we did not
suspect that discharge conditions within the Little Lehigh Interceptor would
disappear as the result of the construction of the new relief line. Why? We didn’t
believe that the inflow and infiltration problems would be answered upstream
from LCA’s Number Five Metering Station. Also, the Little Lehigh, Jordan Creek,
Trout Creek, Front Street – Union Street Interceptors would converge to cause
overflow problems in the Basin Street area. And, of course, recognizing that the
worst case scenario and with study of the 1974 Malcolm Pirnie document we
concluded as early as August 198 that public events could be manipulate to
foster the need to construct a new interceptor to the Riverside Industrial site in
Salisbury Township. With that, the setting might be set for the phoenix-like
emergence of the Riverside Industrial Park Wastewater Treatment Plant on the
banks of the Lehigh River, A project that a local newspaper reporter said would
not come into being at an early date because of its expense.

But the evidence in the mid-eighties became more convincing that planning
would begin due to the following interrelated sequence of events.

1.        An announcement by cash strapped Bethlehem Steel Corporation that it
would be willing to sell a tract of land in Salisbury Township known as the
Riverside Industrial Park:
2.        The quick response in January 1986 by Aurel Ardnt, the new General
Manager of the Lehigh County Authority (LCA) upon the retirement of Raymond
Snyder, that the LCA was willing to develop the Riverside Park in Salisbury
Township as a wastewater treatment facility to service the future growth need of
Lehigh County.

Even so, another ingredient into this mix provided another alternative. Advocates
for the Preservation of South Mountain worked very hard to preserve the natural
beauty of South Mountain by seeking to purchase large chunks of its terrain and
protect it from development. One of these groups, the Wildlands Conservancy,
founded in 1973, is dedicated to preserving precious land, keeping waterways
healthy, teaching the community about nature and caring for injured or orphaned
wildlife. Wildlands Conservancy is membership supported and its programs are
accomplished largely through volunteer efforts. Located at the 72-acre Pool
Wildlife Sanctuary in Emmaus, the Conservancy has helped protect over 31,000
acres in Eastern Pennsylvania


***                        ***                        ***


In any case, we did emphasize that in the mid-eighties the scenario we discussed
in regard to the phoenix-like emergence of the Riverside Industrial Wastewater
Treatment Plant would not necessarily come unto being overnight or the
immediate future. But we knew that the idea was out of the box and lurking for
the right moment to catch us by surprise. The fact was, the Lehigh County
Authority in order to implement its long-range plan had to arrange for its
financing, and this project would prove to be difficult given the uncertainty of
federal, state and private funds then available. The fact being, David Bausch,
Lehigh County Executive, as early as February 5, 1985 (on the surface) had set
aside options relating to the construction of a Riverside Wastewater Treatment
Plant and a full scale wastewater treatment plant near Trexlertown. Bausch
electing to pursue the construction of a $32 million pre-treatment plant near
Trexlertown possessing the capability to be expanded to service what the
Executive termed “moderate growth” needs in the western part of Lehigh
County. The first decision, of course, had been made by the Board of
Commissioners who also were given the option to expend $24 to $27 million for a
basic pre-treatment operations serving only contracted clients like Stroh
Brewery and Kraft Foods but possessing no capability to be expanded. Of
course, liability wise, the latter option was all that was required of the County to
meet its 1969 contractual obligations to Stroh Brewery and Kraft Foods; and
also; to meet the requirements of the City of Allentown – Signatory Sewerage
Agreement of 1981.

Please note – historically, it was announced August 12, 1986 that the County
Executive of Lehigh County, David Bausch had agreed to increase the design
capacity of the County’s proposed pre-treatment plant to meet projected
production increases by the Stroh Brewery in Upper Macungie Township. The
agreement when implemented would pave the way for construction activities to
begin in spring of 1987 with completion scheduled in 1991. By agreement, the
County paid any capital costs that accrued under $25 million for pre-treatment
plant construction and engineering costs related to initial pre-treatment design.
Then too, the County would additionally be expected to finance any costs
accrued over $40 million. The brewery expected to pay all capital costs accrued
above $25 million but under $40 million for necessary construction expenditures
and an estimated $1.3 million for re-engineering costs relating to the design of
the plant.

***                        ***                        ***

In the end we must stress, whether Riverside ever becomes a fixed reality
depends upon future battles between those who favor unbridled growth and
those who wish to halt the transformation of the Lehigh County from its historical
agricultural and rural base to that of urban sprawl.

It also expected that given their resources that Lehigh University and AT & T
Technologies would play a key role in Lehigh Valley future economic
development. A.T & T Technologies would in time be spun off from its parent to
become a part of Lucent Technologies and in time the Microelectronic Division of
Lucent in Allentown and the Lehigh Valley would be spun off to form the new
corporation Agere Systems.

***                        ***                        ***

Important too, this process could also be impacted by what might become a
counter balancing trend of industrial abandonment by older Lehigh Valley
industries as exhibited by the announcement of Mack Trucks, Inc. January 22,
1986.

In analysis, it was revealed that officials for Mack Trucks, Inc. and economic
development personnel for the State of South Carolina were in contact for
fourteen months to work out the deal that was announced January 22, 1986 to
the regret of those individuals employed by Mack Trucks, Inc. and to of
“responsible” local, state and federal officials in the Allentown-Lehigh Valley
region of Pennsylvania.

It was our understanding at the time that as part of the package, Mack would be
granted an earning credit amounting to $500 per job created at the soon to be
built state-of-the-art (that is robotic) Winnsboro, South Carolina plant. It was
announced that an estimated 1,000 new jobs would be created in South Carolina
and that South Carolina would assist in the training of resident South Carolinians
to fill these positions.

Unfortunately 1,800 jobs were lost in the Allentown-Lehigh Valley region of
Pennsylvania and nobody in South Carolina (especially Governor Riley) talked
about giving reparations to those individuals the actions of the South Carolina
government have destroyed. And, since officials in that South Carolina
community had additionally hoped to attract suppliers of parts to the new Mack
plant in Winnsboro, South Carolina, we must add the 1,150 Mack jobs already
lost in 1984 to the reparations list as well.

Indeed it would be interesting to learn whether the good people of South
Carolina made the first contact with Mack officials. If this were the case, then the
government of South Carolina has involved itself in economic warfare against
the Allentown-Lehigh Valley region of Pennsylvania. A shock to the Allentown-
Lehigh Valley region of Pennsylvania that will ring as a “Day of Infamy”
achieving the emotional level of a “Pearl Harbor” or a “Fort Sumpter.”

We ask – How can any government unit in the United States justify the use of
“Corporate Welfarism” tactics to harm directly or indirectly another governmental
unit of the United States?

But the truth is, this is done regularly on the State and local level in the name of
industrial development and leads to the financial enrichment of certain
individuals in one community to the detriment of individuals in other
communities.

We would be angrier at this occurrence of Peter robbing Paul, except that the
masterminds of growth in the Allentown-Lehigh Valley region have made their
own raids on other economies as well. Indeed they have fell victim to the siren
lure of what industrial development programs may offer primarily in the short-
range for a community.

In the year 2001 some of the agents in promoting economic development
programs in the Lehigh Valley are: The Lehigh Valley Convention & Visitors
Bureau, The Lehigh Valley Economic Development Corporation, The Lehigh
Valley Industrial Park, The Lehigh Valley Planning Commission, The
Northampton County Development Corp, The Pennsylvania Economic
Development Association.

The fixed reality being that South Carolinian Governor Riley’s comments to Mack
Truck President John Curcio January 22, 1986 at the University of South
Carolina brought back remembrances of a supposedly happier day in the
Allentown-Lehigh Valley region of Pennsylvania when then Governor Ray
Schafer of Pennsylvania made similar welcoming remarks to a new corporate
citizen, F & M Schaefer Brewing Company of New York City.

The day was December 8, 1970, and upon completion of a scheduled
cornerstone –laying ceremony on-site for the $60-million Schaefer Brewery,
Rudolph J. Schaefer III thanked a group of 200 Lehigh Valley leaders at a noon
luncheon at the Lehigh County Country Club for accepting his company both as
a resident and property owner in the Lehigh Valley community. Among the
honored guests were former Allentown Democratic State Representative James
P. Ritter and former Macungie Republican State Representative Marian E.
Markley whom jointly sponsored state legislation allowing breweries with out-of-
state ownership to locate in Pennsylvania. Also in attendance were the Board of
County Commissioners George Stahl, Donald Hoffman, and Harley Steward Jr.
whom can be tagged as the public officials most responsible for granting major
concessions to the brewery in exchange for its relocation into the Allentown-
Lehigh Valley region of Pennsylvania.

Unfortunately, negatively, we can describe a litany of environmental and financial
problems that these concessions have directly or indirectly left the good old
boys of the Allentown-Lehigh Valley region in both the short and long-range as
the region enters the second half of the 1980’s.

And, as they say, those who play with fire are bound to get burnt.

With that having been said, allow us to ask the good people of South Carolina
this important question --- What measures did you take to prevent the Monsieur’s
from Mack from leaving your community high and dry when your special
enticement programs come to an end?

Additionally – How prepared were you for the possible influx of new people into
your community? And, for that fact, was your already existing building stock and
utility infrastructure prepared to meet any problem that occurred due to this new
fixed reality?

The fact being, it is not public policy of the United States to restrict its citizens
from traveling or choosing to relocate any where in this common economic
market of North America known as the United States of America for pursuit or
continuance of economic security.

The implication being, the moment we lose this right we also forfeit our status as
free human beings.

Indeed – We are told there is a time and method to every enterprise, but just the
same, man is greatly troubled by ignorance of the future and what it will bring ---
industrial development in one area, industrial abandonment the next