Operationalizing Equity in Long Term Control Plan (LTCP) Planning: Case Study of the Buffalo Sewer Authority

The Buffalo Sewer Authority (The Authority), established in 1935 as a New York State public benefit corporation, is tasked with alleviating pollution in the Niagara River, Buffalo River, and Lake Erie caused by the discharge of city's sewage and waste. It aimed to address insufficient sanitary and stormwater drainage by constructing the Bird Island WWTP in 1938, followed by secondary treatment facilities in 1980, aligned with the Clean Water Act. Covering around 850 miles, the Authority's collection system consists of 790 miles of combined sewers and 60 miles of storm sewers, including 52 permitted combined overflows. In the 1990s, regulatory changes prompted the Authority to develop a combined system overflow (CSO) abatement plan. The first Long Term Control Plan (LTCP) was submitted to NYSDEC and US EPA in 2004. After prolonged negotiations, in 2012 an Administrative Order from the US EPA mandated an updated LTCP. Although the LTCP of 2014 was approved, subsequent adjustments were made to the collection system hydraulic model after the initial LTCP phase. This led to revised simulations indicating unfeasibility of certain LTCP projects and optimization potential for others, birthing new selected alternatives. Since the adoption of the LTCP, shifting priorities in outcomes for and impact on communities has become key considerations in planning. Federal expectations aligning funding with environmental justice, as well as the City's emphasis on social, economic and environmental equity have guided the Authority's capital and operating projects. As a result, the LTCP implementation schedule prioritizes benefits for Buffalo communities with an emphasis on communities that have been historically underserved and overburdened. Several factors were used to create a framework to prioritize projects with these equity considerations: SPP Overflow Volume Rank; Water Body Ranking; SPP Project Rank; Construction Priority, CSO Cost Effectiveness, and environmental justice . When assessing environmental justice factors, vital queries emerged: how do we identify equity gaps in the community? What analysis resources are available? Several resources, including the Climate and Economic Justice Screening Tool, City of Buffalo Rain Check 2.0 Equity Index, EPA EJ Screen, and NYS Potential EJ Areas, were explored to evaluate equity and environmental justice consideration. Collaborative efforts between the consultant team and the Authority honed in on critical factors and established parameters. As a result, a comprehensive set of metrics was chosen, culminating in a disadvantaged community map onto which project locations were plotted to assess their rankings. The approach to ranking calculation differed for Green Infrastructure (GI) Projects and Other Projects (OLS, RTC, ILS, SPP Modifications). For GI projects, the disadvantage ranking derived from a weighted average of census tracts with GI projects. Conversely, for other projects, a quarter-mile radius buffer zone around each project gauged its influence area, with the project's disadvantage ranking being based on the highest-ranking census tract within the buffer zone. Analyzing the distribution of project disadvantage rankings revealed that 67% of the 51 projects exhibited a ranking greater than 4, predominantly located in the southern city areas. Meanwhile, 24% of projects had rankings between 2 and 4, and 9% possessed rankings below or equal to 2, characterizing less vulnerable neighborhoods. Conclusively, evaluating disadvantage rankings provided valuable insights into project effects on disadvantaged communities, which will help the Authority to create targeted community engagement and promote an equitable implementation of projects.