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Three Rivers to make second attempt at state funds for lead line replacement

Three Rivers Department of Public Services Director Amy Roth addresses the city’s project plan for potential funding through the state’s Drinking Water State Revolving Fund during Tuesday’s Three Rivers City Commission meeting. (COMMERCIAL-NEWS | ROBERT TOMLINSON)

By Robert Tomlinson
News Director

THREE RIVERS — The City of Three Rivers will be trying again to receive funds from the state for lead line replacement, but a note from their previous application could be a speed bump to getting funding in their newest attempt.

On Tuesday, the Three Rivers City Commission approved a 2024 project plan submittal for the state’s Drinking Water State Revolving Fund (DWSRF) through the Michigan Department of Environment, Great Lakes and Energy (EGLE). The proposed plan, with a total estimated project cost of $14.586 million, would include the replacement of approximately 336 lead service lines throughout the city, which equates to approximately 19,420 feet (3.7 miles) of water mains.

The plan would replace lead service lines on Spring Street (17 lines), Sixth Avenue (25), Pine Street (13), King Street (1), Eighth Street (46), Hooker Avenue (68), Oak Street (18), Ninth Street (43), Eighth Avenue (11), Middle Street (22), Grant Avenue (45), Pealer Street (11) and Mechanic Street (16).

According to the project plan, the project cost of the project will be reimbursed through the life of the debt “through customers’ water billings.” The plan anticipates that Three Rivers will be eligible to receive a “disadvantaged community low-interest (2 percent) loan,” and are anticipating funding it with a $14.586 million DWSRF loan at 2 percent interest over a 20-year period.

A table is included with the application that shows what the readiness-to-serve (RTS) charge per residential equivalent unit (REU) percentage increase would be if the city receives funding, based on how much of the funding comes from the loan and how much would come from grants or principal forgiveness that the city could receive from the application by distributing the cost of the project evenly among the 5,143 REUs served by the city’s water system. According to the table:

  • If the city gets 100 percent loan and 0 percent grant funding/principal forgiveness, the RTS charge would increase by approximately 52 percent.
  • If the city gets 75 percent loan and 25 percent grant funding/principal forgiveness, the RTS charge would increase by approximately 34 percent.
  • If the city gets 50 percent loan and 50 percent grant funding/principal forgiveness, the RTS charge would increase by approximately 16 percent.
  • If the city gets 25 percent loan and 75 percent grant funding/principal forgiveness, the RTS charge would not increase.

Department of Public Services Director Amy Roth said, reading from the project plan’s fact sheet, that approval of the project plan “does not obligate the city to implement the project described.”

“The city may choose to implement the project once financing terms have been offered by EGLE and approved by the City Commission,” Roth said.

Roth said the plan is similar, if not identical, to the plan submitted to the state last year, which was not scored high enough for funding. She predicted that because of the practically identical application, the scoring the state gives will be the same as it was last year.

“The only way we will have a better opportunity is if everyone scores in the lower group when they’re scoring,” Roth said. “Our score was a 65 last year, and it didn’t reach that funding level, but the top scores were in the 90s and 85. If this round of applicants only scores 75, then we might make that cutoff. It also depends on how much funding is available, and that changes every year.”

With that said, however, a potential speedbump could hinder the application for a second straight year: The non-existence of an active wellhead protection plan.

According to the Water System Reliability Study included in the city’s 2023 and 2024 application, it states that the city has a wellhead protection program that was approved by the Michigan Department of Environmental Quality (DEQ; now EGLE) back in 2006, with a Source Water Assessment last updated in 2007.

However, in an EGLE ranking worksheet for the city’s 2023 application, obtained by the Commercial-News, the city was docked 10 points by EGLE for what they said in its comments was “no active WWHP [sic] on file.” (WWHP was confirmed by an EGLE spokesperson to be a typo for WHPP, a Wellhead Protection Plan.) Because of the docked points, Three Rivers scored 65 points out of 100 instead of 75 points, which would’ve given their application a better shot at receiving funding in 2023.

A spokesperson for EGLE gave more clarity to the situation, saying wellhead protection programs have to be renewed or reapproved every six years to be considered active. According to the spokesperson, Three Rivers had one in place in 2006, but it was not renewed in 2012 or beyond, thereby making it an inactive program in the eyes of the state.

When asked about the comment in the EGLE worksheet following Tuesday’s meeting, Roth said there was “not currently a plan to have [a wellhead protection plan].”

“As I have been told, and I wasn’t here when the last wellhead protection plan was presented, the commission at the time was not interested in implementing that program,” Roth said.

However, when asked about whether or not a wellhead protection plan was in place, Mayor Tom Lowry said that he recalled the city having a plan in place.

“We have one. So, I don’t know why we got dinged for it. We’ve had one ever since I’ve been up here,” Lowry said, adding that he would check in to the situation. On Wednesday, Lowry said in a text that city staff, including City Manager Joe Bippus, were researching the issue.

The plan was adopted unanimously by the city commission, 7-0. According to the plan, it is anticipated that final financial terms would be offered this fall, and if the city elects to move forward, design for the project could begin in the fall of 2024 and construction contracts would be awarded and may commence in 2025.

In other business…

  • Commissioners set a public hearing for June 18 regarding a Brownfield Redevelopment Plan for 5.62 acres of land at 611 Coolidge Place in Three Rivers, where a 38-house rental unit subdivision is proposed to be built. Commissioners were wary about a number of things regarding the proposal, including the number of houses and available parking space, the prices of the rentals (just under $3,200 a month for a regular house and around $1,800 for income-qualified units), and the tax money or lack thereof the city would receive.
  • Commissioners set a public hearing for June 4 for the city’s user fee ordinance update, which includes a four-cent increase in the city commodity rate per 100 cubic feet for water and a 12-cent increase in the city commodity rate per 100 cubic feet for sewer, along with other fee changes.
  • Commissioners approved ordinance amendments for police animal control regulations, which includes additional restrictions on dangerous dogs and dogs at large in the city; updated references for the DDA and Appeals boards; and district wall sign regulations.
  • Commissioners approved an MDOT Category B grant application for street project funding for 11th Avenue and Washington Street. If the grant is awarded, the direct cost to the city for the budgeted project would be reduced by approximately $250,000.
  • Commissioners received a presentation on the Three Rivers Housing Development Corporation and its work in the past year.

Robert Tomlinson can be reached at 279-7488 or

One Reply to “Three Rivers to make second attempt at state funds for lead line replacement

  1. Once again residents are being asked to fund necessities due to the failed policies of Lowry and Bippus. The city can’t continue to fund operations and services by continuing to break the backs of individuals while approving tax free projects. The sad part is that, evidently, no one cares enough rid themselves of these frauds.

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