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 TWO

PREFACE



*As we begin the second part of our continuing study WE PRESENT THE
TRUTH, BUT YOU DO NOT COMPREHEND, we give this warning for those that
desire wisdom and truth ... Let no one deceive you with shallow arguments and
weak understanding. For, it is for those reasons that the problems we face have
occurred.

Take no part in the desperate act of deception that those who failed us continue
to orchestrate. But rather, show them up for what they are. The things they wish
the public not to remember is like a mark of darkness descending upon their
entire being; and we the public should deserve better respect then that.

Our purpose and our goal in PART TWO remain the same as it was in PART
ONE; that is --- we initiated this study believing that we can come to a general
understanding concerning the chronology and decision-making that has led to
the planned or unanticipated destruction of the character of the Lehigh Valley's
landscape from largely rural to urban sprawl in the name of an idea called
Megalopolis.

A Megalopolis, of course, is an urban complex encompassing several major
cities. Its application in the Lehigh Valley region would be the Consolidated
Metropolitan Statistic Metropolitan Area (C.M.S.A) of Allentown, Bethlehem and
Easton (A-B-E). The A-B-E C.M.S.A comprising the Counties of Carbon, Lehigh
and Northampton in Pennsylvania and Warren County in New Jersey. Bureau of
Census, U.s. Department of Commerce statistics show that the estimated
percentage change in A-B-E C.M.S.A population between 1990 and 1994 was
2.8%. That is, the population grew from 595,208 in 1990 to an estimated 611,765
in 1994. Bureau of Census, U.S. Commerce Statistics show that the population
of Lehigh County rose from 291,130 in 1990 to an estimated 297,838 in 1995.
Bureau of Census, U.S. Commerce Statistics show that the population of
Northampton County rose from 247,105 in 1990 to an estimated 256,796 in 1995.
Bureau of Census, U.S. Commerce Statistics show that the population of
Carbon County rose from 56,973 in 1990 to an estimated 58,832 in 1995.

We add that in regards to this study we shall concentrate on considerations that
have impacted upon Lehigh County and its major City, Allentown; and we shall
only concern ourselves with Carbon, Northampton or Warren Counties should
developments there tie-in and match our field of consideration. Bureau of
Census, U.S. Commerce Statistics show that the population of Allentown rose
from 103,758 in 1980 to 105,301 in 1990.

Gerald F. Weber was appointed to the Board of Lehigh County Commissioners
by fellow Board Members January 1997 as a replacement for long-time
Commissioner, Emerich Stellar, who resigned. Weber soon thereafter
announced his intent to seek the District three seat he was appointed to in the
upcoming municipal elections of 1997. In his announcement, Weber said that
the decision to build an office complex in the former Leh's building in
downtown Allentown, made well before his appointment, was risky, but
required, It was Weber's belief that the Could never leave the City. Weber said:
"Whatever happens to the city, we're intertwined with it ... whether you ever set
foot in the city or not. That's why they couldn't put the building in some office
park (in the suburbs)."  But Weber was also quick to add that the outlying areas
should not be neglected. Weber reasoned that the County benefited from this
outlying area because both its tax base and the revenue this tax base brings
was growing. Therefore, Weber endorses current county policy to invest tax
dollars in the development of youth soccer fields in western Lehigh County and
in improvements at the Trexler-Lehigh County Game Preserve as long as costs
are kept in check.  To quote Weber: " All of these progressive things are doable
because the County is still growing. We have to make sure we don't stagnate
and become like Allentown, where they can't get new dollars into the City.  
Weber hoping that the new County Office, which actually takes tax base from
the City in its development, helps boost private development downtown. States
Weber: " hopefully, we can look back on these times and say, "Those were the
worse years when Bon-Ton closed" and other businesses deserted the City."

Touching comments from an individual who abandoned Allentown some years
ago as a resident for the greener confines of Salisbury Township. But to his
credit, Weber maintains his business interests in the City. Weber is Vice
President of Weber Funeral Homes, Inc., Allentown.

It is Upper Macungie Township at the juncture of Routes 22 and 78 in Western
Lehigh County where much of the County's growth is taking place. Here are
expected to locate the post industrial or high-tech industries, which hopefully
would keep the Lehigh Valley a growth area throughout the rest of the century
and beyond.  Please note --- Upper Macungie has always had a certain allure for
Industry. Kraft, Stroh's and Americold Inc. were there long before Nestle in 1995
started a new wave of development that put the Lehigh Valley on the
warehousing map. The Perrier Group, Milliard Refrigerated Services and Coca-
Cola arrived on Nestles heels. But note again, this growth has come at a cost.
The familiar fields of alfalfa, wheat and corn have been plowed under for this
development. And, the development that is occurring in the former farm belt of
Lehigh County is not really hi-tech,

Susan Todd of the Morning Call noted February 19, 1997 that the Lehigh Valley
is becoming synonymous with warehouses unlike the Delaware Valley which
has become an address for high-tech offices.

Spanning the distance of 9 1/2 football fields, the newly completed Liberty
Property distribution center in Upper Macungie Township will be the latest
addition to the Valley's huge distribution center infrastructure. Todd
appropriately said that the building, which is to be leased by DSC logistics Inc.
of Des Plaines, is " one of the latest additions to the valley's crop of huge
distribution centers.  The use of the word crop of course, alluding cleverly to the
storage and distribution of Kellogg and Pillsbury Products, not the acreage of
former crops that we previously said have been plowed under and lost forever.

Industrial Development also is taking hold in agricultural Northampton County
as well. At the Lehigh Valley Industrial Park, Federal Express Corp. completed
an 113,000 square foot distribution center. And not far away, just east of the
Industrial Park, Osram Sylvania, a Massachusetts-based light manufacturer, is
finishing a 525,000 square for eastern distribution center.

What is the lure for developers? First, they need Highway access. And routes
22, 78 and 309 make a fine network. Secondly, they need available and
inexpensive land. Which is available because of the farm busting governmental
policies of the past; Thirdly they need low operational costs and finally, they
need an available, inexpensive labor force. Which is available because of the
downsizing of heavy industry in the area. And almost looks like a conspiracy to
me to make this happen.

Gee whiz, the Career Development Coordinator of the USWA/Bethlehem Career
Development Program has sent me a note to choose a career in warehousing,
distribution and material handling. But I ask this question --- How many years
will the warehousing, distribution and material handling business remain a hot
item in the Lehigh Valley? Carl R. Grersbach, senior Vice President of Jackson-
Cross, assurance that the Lehigh Valley is unlikely to lose its appeal as a
location for major warehouses is less then reassuring. If he thinks that the
industry is going to continue strong throughout the 90's, the 90's if he hasn't
seen the calendar, will soon be over. And, in the event of the unlikelihood that
the warehousing industry ceases to perform strong in the Lehigh Valley, can we
convert these crops of buildings back to crops of ALFALFA, WHEAT AND
CORN?

****   ****   ****

The Borough of Emmaus became the first municipality to tie-in to Allentown's
wastewater treatment network. The fact was accomplished because Allentown
wished to protect its Little Lehigh Parkway Watershed from the threat of
contamination; a consequence that might occur should the Borough's
proposed wastewater3 treatment plant on the Little Lehigh Creek experience
temporary or permanent operational difficulties.

****   ****   ****

This Little Lehigh Parkway Watershed, of course, includes much of what we
know today as being the Lehigh Parkway --- a three mile scenic route
comprising 575 acres extending from center city Allentown southwest to Cedar
Crest Boulevard.

The beginnings of the Lehigh Parkway had its genesis in the first ever report of
the Allentown Planning Commission in 1927 that was chaired by General Harry
C. Trexler ... E.N. Donnecker, Robert Lange, John Bruckland and John Leh
comprised the remaining members of that commission.

To their credit, this commission foresaw the need to preserve for Allentown a
pure water supply; and the creation of a parkway watershed was their means of
accomplishing that end.

Just as important, their vision initiated the process that led to the development
of Allentown's well-known and superb park system. Today the Lehigh Parkway
consists of grassy meadows, woods and streams. It is a place where individuals
can fish, picnic, hike, enjoy nature, and history.

What is more, it is a place that Allentown, Lehigh County and the Lehigh Valley
Region can be proud of to share with the world. Indeed, we have heard the late
Gorge Restrum, a former Allentown businessman and his entertainer brother
Willie Restrum affirm that a well-known entertainer, also deceased, has visited
the parkway with his son and endorsed its beauty, solitude and its terrain. That
entertainer, interestingly enough, was the late John Lennon of past Beatle fame.
Lennon came to Allentown and the Parkway to escape the rigors of New York
City's metropolitan living and to seek seclusion from his many aficionados who
game him undue attention.

Unfortunately, this seclusion, peace, and beauty had been violated in 1985-86
by the Lehigh County Authority's laying of a 48" diameter wastewater treatment
relief interceptor through most of the most scenic Parkway areas.

And again, this seclusion, peace and beauty was violated at the tailend of 1996
and early 1997 according to neighbors living nearby the Parkway when the City
of Allentown inaugurated its initial Lights in the Park display. So to speak --- City
of Allentown officials discarded the seclusion, peace and natural beauty of the
parkway for a glizcy Times Square Display.

****   ***   ****

Personally, this author, as well, enjoys the solitude and beauty that the Parkway
in normal times offers. In fact, I have written the following poems which have
been influenced by and can be appreciated in the Parkway setting that existed
prior to the arrival of the bulldozers and the above ground line of concrete 48"
diameter sewerage piping that was to be buried under the Parkway's terrain:

People Scurrying About

Where are we going? What new directions do we move? The meaning of life is
so myriad ... We know that fortunes in the scheme of things are gained ... And
fortunes are equally lost ...  And through all of this, People are seen scurrying
about...

Look to the Book to see the Holy Word ... Understand the Love that we often
just meekly observe ... Nothing matters except what is divined and ordained....
The eternal is more important than the temporal...

In the scheme of things, some people live to be 100 years old or older, while
other people die before they are even born ... Some people achievements and
thoughts remain alive in our memories eventhough their earthly remains either
lie deteriorating in their graves or are committed to the fire and ultimately
scattered to the wind or water ... While other unfortunate people who remain
among the quick lead unremarkable lonely lifestyles to the extent that society
considers them dead eventhough they remain alive.

Where are we going? The new directions we move be for us to decide.... Will our
actions be constructive ... or ... will they lead to an eventual decline?  We know
that fortunes in the scheme of things are gained ... And fortunes are equally lost
...  And through all of this, People are still seen scurrying about...

Except in God's Gaze

What is the meaning of our activity? ... Where do we busy our days? ... Stressful
we are, we seek repose, seeking divinity...

Wherever we go we look like rats running through a maze ... We seek meaning,
but there is no meaning EXCEPT IN God’s FULL GAZE...

Ambitious we are, we seek power, but that is all so vain.... Power is fleeting, it
fades away, and it never comes taking full reign...

We destroy at will, no reason do we see, except for personal gain... Reputations
are attacked, Hard Work belittled, and why? Oh, what a shame.

****   ****   ****

Certainly, these accolades and expressed esteem for the Allentown Park
system are post mortem credits and tributes to the Parks Development Plan
drawn up by B. Artrim Haldeman in behalf of the city's Planning Commission.
Haldeman, we are told, was extremely excited about the unique possibilities in
landscaping design that the topography of the terrain of the proposed park area
would allow --- it being located on a plateau surrounded by pretty valley and
streams.

Today, this plateau is threatened by plans for residential development

****   ****   ****

One can imagine that Emmaus's threatened action was most disturbing to
Allentown officials forty or so years ago considering the historical and
environmental importance of the Little Lehigh Parkway Watershed.

Councilman Samuel S. Fenstermacher, the head of Allentown's Water
Department recognized that this watershed was the benefactor of Allentown's
Water treatment and distribution system; that, it was capable of supplying up to
50 million gallons daily if such volume was ever needed.

Naturally, at the time the City did not require such volume, nor did the filtration
plant have the capacity to handle such volume.

In 1979, the filtration plant which is operated twenty-four hours per day, seven
days per week pumped an average daily load of 28.3 million gallons, serving a
population of 140,000; and in 1982 this average daily load was reduced (*) to
approximately 26 million gallons.

TABLE 1 --- City of Allentown average daily water consumption (stated mgd's)
1974-1983
------------------------------------------------------------------------------------------------------------------------
1974 --- 25.7; 1975 --- 26.2; 1976 --- 26.8; 1977 --- 27.2;
1978 --- 28.9; 1979 --- 28.3; 1980 --- 27.6; 1981 --- 26.7;
1983 --- 26.6...
-----------------------------------------------------------------------------------------------------------------

(*) --- (City officials attribute this lower figure to an ongoing water conservation
effort promoted by the city.)

The filtration plants graded capacity before modernization in the 1990's was 30
million gallons daily. Additionally, with the use of unfiltered spring water it could
push out a maximum 40 M.G.D ... (A figure as much relevant in 1957 or 1962 as it
was in 1982) ...

****   ****   ****

Allentown, of course, wished to protect its $8 million investment in the Little
Lehigh Parkway Watershed and the filtration plant that treated the Creek's flow
from the harmful effects of possible contamination; and for this purpose,
Allentown agreed to accept wastewater effluent from Emmaus.

Unfortunately, the movement of the time continuum did not end the potential for
the disruption of Allentown's water supplies (whether they be percolating
ground water as the case of Schantz's and Crystal springs or surface waters as
the case of the Little Lehigh Creek) due to competing needs of municipalities
and other developments in the watershed.

Fenstermacher surely had to be aware that pressures were indeed building for
growth activities to begin in areas to the north and west of Allentown. If there
was any doubt or disbelief that this would occur, the creation of the Industrial
Development Corporation of Lehigh County and the Joint Planning
Commissions, Lehigh --- Northampton Counties would quickly dispel them ...
We note, Fenstermacher expressed a deep-seated concern related to the long-
term viability of Allentown's springs in addition to its surface waters. He said: "
Geologists tell us the valleys of the Little Lehigh and Cedar Creek have their
underground counterparts where waters join and come to a point to form the
flow of Schantz's Spring, Crystal Spring, and other outlets. Consequently, the
focus of Fenstermacher's activities related to his office primarily dealt with
seeking solutions to the long-range protection of Allentown's water supplies.

Fenstermacher was aware that the Emmaus agreement relating to wastewater
treatment service extension would open the door for further requests of service
from other communities. Therefore, before a group of Allentown real estate men
February 19, 1962 he presented a historical important question ... That is, the
question of extending the Allentown Wastewater Treatment Service was no
longer one of shall " we go beyond city limits, but how far?"

Such service extensions according to Fenstermacher would have to be made
by degrees to limited franchised areas where the need was greatest; and he
added: " There will be no isolated cases of services. Extension agreements will
be made between governments not individuals."

****   ****   ****

John P. Durr the regional engineer for the State Department of Health,
suggested at a 3/27/62 informational meeting of the Joint Planning Commission,
Lehigh --- Northampton Counties what area the Allentown Wastewater
Treatment District should comprise.

The state official advised that Allentown could enter into a Metropolitan
cooperation Wastewater Treatment disposal program with six to nine other
communities. One naturally would be Emmaus, for Allentown already by
agreement was processing that community’s wastewater in its Kline's Island
Plant. Another would be South Whitehall for negotiations had already begun for
service with that community. According to Durr, the remaining members of this
cooperative effort would be Coplay and Whitehall, Upper and Lower Macungie,
Salisbury, Macungie, Alburtis and perhaps Upper Milford Township.

INSTALLMENT ONE

*** Purpose is to state the source of what became a fixed reality***

When Samuel S. Fenstermacher, Allentown City Councilman and Water
Department Director, spoke before a group of Allentown real estate men
February 19, 1962 he expressed the truth concerning the new reality in regards
to Allentown Sewerage Service extension. The question was no longer whether
wastewater treatment service should go beyond city limits, but rather, the
question was one of how far should it extend?

It is the purpose of the present discussion to state the source of what became a
fixed reality. The source of this fixed reality, interestingly enough, was the
Emmaus - Allentown Joint Wastewater Agreement.

Concerning this agreement, it is important to know that Allentown and Emmaus
established a proprietor-customer relationship. That is, Allentown would bill
Emmaus for processing that community’s effluent. Emmaus would not be
responsible for or partner in the management and operation of the Kline's Island
Wastewater Treatment Plant in Allentown nor the carrier or interceptor system
routed to the Emmaus municipal line. But Allentown would, and this innocent
factor was the source that had established the fixed reality that Councilman
Fenstermacher spoke about at the February 19, 1962 meeting of real estate men
in Allentown.

****   ****   ****

From our perspective, we find it fascinating that at the time Fenstermacher
spoke; the City of Allentown was not the legal proprietor of its own Wastewater
Treatment Service system. Instead the city held a lease that allowed it to
function as operator and manager of the wastewater treatment plant and its
accessory carriers and interceptor systems. The above fact formally established
in an agreement between the City of Allentown and the Allentown Authority
made May 1, 1960.

*** The rejected bond issue***

The May 1, 1960 Agreement, of course, was the end-product of debate during
the Administration of Donald V. Hock that asked whether or not Allentown
should complete its sanitary sewer system through Authority financing.

The fixed reality was that the Allentown electorate rejection in November, 1956
of a $6 million dollar bond issue designed to fund the extension and completion
of Allentown's Sewerage system had upset public planning to accomplish that
net effect. The significance of the rejection meant that the Allentown City
Council did not have the legal authorization of the electorate to commit the City
of Allentown to a program of long-term debt amortization designed to provide
financing for the extension and completion of Allentown's sewerage system.

Of course, this defeat of the bond issue question shocked public officials for
they could not give any official explanation concerning the causal factor related
to the bond issue defeat. However, from our vantage point in the future we can
see the possible connection or correlation between the Emmaus
announcement that it might be willing to tie-in to the Allentown system and the
psychological impact it had on the Allentown electorate. Certainly the Emmaus
announcement caused confusion among the Allentown electorate as to where
the bond money was to be spent and this confusion caused the bond issue
rejection.

A proponent of authority financing was C. C. Collings and Co., Inc.,
Philadelphia, Pennsylvania. C. C. Collings appeared before the Allentown City
Council February 26, 1957 and advised City Council to utilize an authority to pay
for the completion of the sewer system. The logic of Colling's suggestion was
that Authority financing would be the means for City Council to overcome the
bond issue rejection of the electorate. That is, by engaging in Authority
financing, City Council would be avoiding the appearance of direct City of
Allentown commitment which was obviously against the public policy of the
Allentown electorate as determined by the rejection of the bond issue,
November, 1956.

As it happened, the Allentown (Water) Authority, was present at the February 26,
1957 meeting in which C.C. Collings spoke; and at the same meeting the
Allentown (Water) Authority agreed in principle to assume the responsibilities of
financing any sewer project if the city decided to work toward completion of the
sewer system. But we note, Council waited until August 22, 1957 to employ the
Allentown (Water) Authority to finance the completion of the city's sewerage
system ... And, reaffirmed this decision July 29, 1958 with the following
resolution:


" That City Council hereby agrees to convey all its Sanitary Sewer System,
Disposal Plant and extensions thereto, to the Allentown Authority
simultaneously with a lease from the Allentown Authority to the City of
Allentown of the Sewer System aforesaid in accordance with the terms to be
determined by both bodies.

*** Four thoughts from the role performed by the Allentown Authority***

Presently, we derive four thoughts from the role performed by the Allentown
Authority in facilitating both the completions of the Allentown sewer network
and the proposed tie-in with Emmaus.

1. It provided the city an opportunity to finance and construct its own sewer
extension.
2. It provided the city an opportunity to finance and expand the Kline's Island
Wastewater Treatment Plant without the fear of electorate disapproval.
3. It provided the city the means to finance and construct interceptor lines to
receive wastewater from sources outside city limits without fear of electorate
rejection.
And lastly, within the historical context it could have been the first step toward
establishing a joint authority with Emmaus.

But a Joint Authority with Emmaus although suggested and advised did not
develop and that failure too established the fixed reality, which Councilman
Fenstermacher expressed.

The opportunity for Emmaus and Allentown to form a joint authority did exist for
an Emmaus Authority was in the process of being established in 1957. The
purpose of the authority was to finance the development and construction of a
sewage carrier system that would either hook-up or tie-in with Allentown or
connect with a wastewater treatment plant that Gilbert Associates of Reading
was under contract to plan for the borough. Emmaus had long needed
wastewater treatment services; and with time this service became more of a
priority for Emmaus. State law required that when the population of a
municipality reached 10,000 that sewerage service should be provided; and
Emmaus expected within a short period to reach that figure.

*** Such a combination was not achieved***

We shall now enter a discussion as to why it was necessary for Allentown and
Emmaus to combine authorities as to prevent further uncontrolled demands on
Allentown's wastewater treatment service and then we shall try to understand
why such a combination of authorities was not achieved.

The borough of Emmaus announced October 26, 1956 its intention to construct
a wastewater treatment plant just 1/2-mile upstream from the water intake head
of the Allentown filtration plant. A few days later, (October 29, 1956) Emmaus
officials indicated in a meeting with officials from Allentown that their stated
intention was not absolute, that they would entertain a willingness to tie-in their
planned sewage carrier system into that of Allentown's. Allentown officials
reacted in the most part to the above suggestion with guarded interest.

It was not the policy of the city to provide sewer service outside the city line. It
had done so in regard to water service to outside communities and as a result
was forced to further extend its water service. This scenario the city did not
wish to repeat in regard to sewer or wastewater service.

Another factor was the assertion by Lloyd E. Grammes, Allentown City
Councilman, that Allentown citizen reaction was to be heard on the question. As
it was, forty percent of the city did not have sewer service in 1956 and their
viewpoints concerning any Allentown-Emmaus link was at the time unknown

Interestingly, Allentown City Councilman, Dr. Samuel S. Fenstermacher
expressed a strong desire to protect Allentown's watershed. Consequently, he
was the only Allentown Councilman and official that evening who gave a clear-
cut endorsement to the Emmaus tie-in request. Fenstermacher cited the fact
that Pittsburgh and ten to fifteen communities had their sewer systems linked
together.

Yet the legality of the Emmaus proposal did not escape Fenstermacher's
questioning.

R.J. Schatz, Assistant Sanitary Engineer for Gilbert Associates, Reading,
pointed out that since Allentown owned its system it might be in trouble with the
Public Utility Commission if it extended its service outside corporate limits. But
Schatz also pointed out a possible loophole which Allentown and Emmaus
could take advantage of if they so desired. The loophole could be met
according to Schatz by the two communities forming a joint authority defining
the corporate limits of each. " That way," the engineer maintained, "the two
communities wouldn't have to take in anybody else." Stated simply, Schatz
meant if Allentown and Emmaus formed a partnership in the management and
operation of all parts of the wastewater treatment system then they were safe
under PUC regulations from having to meet demands from surrounding
communities for services.

****   ****   ****

We note, however, that Emmaus and Allentown did not establish a joint
authority relationship. The Emmaus - Allentown Wastewater Treatment
Agreement of March 17, 1959 provided for a proprietor - customer relationship
between the two communities. Consequently, the "die was cast" that Allentown
as sole proprietor of the Kline's Island Wastewater Treatment Plant would be
subject to further demands from other communities for service.

Indeed, it would be expected after the Emmaus - Allentown Wastewater
Treatment Agreement of March 17, 1959 that industrial, commercial or
residential growth would occur in the agricultural areas of municipalities located
in western Lehigh County. After all, the Emmaus - Allentown Wastewater
Treatment Agreement of March 17, 1959 had opened the Pandora's Box 3that
contained such expectations and these expectations were sowed and
cultivated by many interests in government, the utilities, business or real estate.

****   ****   ****

*** Can we place blame***

We can not place blame on the Lehigh County Federation of Sportsmen's Clubs
for the above occurrence for we note that the Sportsmen in 1958 did seek to
end the delays that lengthened negotiations between the two communities.

Morton V.V. White of the Sportsmen called for the governing bodies of the two
communities to sit down and reach an agreement on the matter and if need be
bring in a third party or arbitrator to settle the issue. The Sportsmen were
concerned both about the protection of Allentown's water supply and the
recreational value of the Little Lehigh as a fishing stream.

White was aware of Allentown's misgivings concerning the tie-in and its
implications. In a report to the Sportsmen, White related that a city in giving
water to any community outside its borders as Allentown has done, comes
under the Public Utility Commission and is obligated to take in any community
that seeks to be connected with the water service; and, the same would be true
with sewage believed White. Nevertheless, White did not see this as a difficulty
because he believed that a solution laid in the advice of R.J. Schatz. Hence he
said: " I know Allentown wants to take on Emmaus not as a customer but as a
partner so that they do not come under the PUC." And in the end White decried
provincial attitudes concerning municipal boundary lines by asserting: " We've
got to stop thinking in terms of a Chinese Wall around Allentown."

****   ****   ****

White's "Chinese Wall" statement may best describe the initial attitude of
Allentown City Councilman Lloyd E. Grammes in the Emmaus - Allentown
Wastewater Treatment debate. Councilman Grammes did not favor any
Allentown - Emmaus hook-up. In fact, Grammes at one point in the negotiations
co-proposed with fellow Councilman William S. Ritter an idea that would allow
Emmaus to build its plant and dump its effluent into the Little Lehigh Creek
without touching the city's water supply.

The proposal would be to pipe Emmaus effluent downstream to a point below
the water works, thereby bypassing the watershed. The plan would be costly,
however, because of the five-mile haul from sewer plant to creek outlet --- from
Fink's Farm in Salisbury Township near Keck's Bridge to the vicinity of
Fountain Park.  (Please note --- Allentown has a holding dam at Tenth Street to
maintain water levels at its filtration plant even during periods of low Creek flow,
therefore an Emmaus outlet would have to be below the dam.)

From our viewpoint, it is obvious that Grammes did not consider Schantz's joint
Authority idea as the safe answer to the Emmaus disposal plant problem nor did
he want any Emmaus - Allentown tie-in. He was indeed aware of PUC
regulations and was concerned with future costs that future extension might
auger.

Councilman Grammes in discussing his by-pass proposal said: " If Allentown
goes for jointure and treats Emmaus sewage, the city will be setting a precedent
and open itself to similar service to all outsiders, just as happened with the
water system. Once that starts Allentown will be forced to continually expand
the facilities of its Kline's Island disposal plant. We'll be spending a million
dollars before we know it. Thus far we've held the line with sewer service to
outsiders. I think the by-pass warrants serious considerations as an alternate to
jointure; and furthermore, Allentown must see that it has sewer service for all
Allentonians before offering facilities to those outside the city."

Emmaus solicitor, Theodore R. Gardner did not share Grammes view on the tie-
in issue and neither was he concerned over the consequence of the failure of
the two communities to form a joint authority. At the same October 29, 1956
Emmaus - Allentown informational meeting in which Schatz expressed his
views, Gardner rather short-sightedly asserted that the only time the lack of a
joint authority would cause a legal problem would be if some request was made
in the future from another community." And from our vantagepoint in the future,
we know that such requests did come.

INSTALLMENT TWO

It is a perennial concern of municipal government to worry both in regard to
future source of income that would enable that municipality to continue its
present level of services and additionally, would enable that municipality to
meet the demands for additional services.

Former Allentown Mayor Donald V. Hock expressed such concern at a
conference in Reading of the Pennsylvania League of Cities September 30,
1957, with one question, " Where is the money coming from to run our cities
tomorrow?"

Hock's comment was said in the atmosphere of a nation searching after a great
depression, a world war, and a peace keeping action to redefine the roles and
responsibilities of the myriad of government units established, acknowledged,
or implied under the United States Constitution of 1787 and the various state
constitutional documents. That is, during the mid 1950's and early 1960's
systematic attention was given to determine what roles the state and national
governments would assume in forging programs of positive impact benefiting
both cities and their environs.

Of course, Hock spoke as the representative of a city that wanted to render the
image of a city on the move or on the march. In 1957, the City was in favor of
State and Federal Programs of aid for general public improvement; and of
course, to qualify for such aid, Allentown was willing to establish the required
infrastructure to meet program specifications with all its known and unknown
short-term and long-term advantages and disadvantages interlinked.
Successive City Administrations whether democratic or republican bought into
this policy as an article of faith through 1997.

Is Allentown better now then it was in 1957? Martha Falk, a democratic mayoral
wannabe, apparently doesn't think so for she has characterized the city as one
marching to drum of retreat. And of Course, her suspected Republican
opponent in the 1997 Mayoral race, Bill Heydt, gets critiqued by Falk's
supporters as the genius behind Allentown's apparent free fall. One should tell
Watson Skinner and Barbara Irvine that this free fall already started during their
tenure and the tenure of their mentor, Joseph S. Daddona. Realistically, Heydt,
just finishing his first term, has inherited what the fruits of their past labor has
reaped. To put it another way, he has inherited the heat that should have been
rendered onto his predecessors. Indeed it is appropriate to ask --- Did Mayor Bill
Heydt, as the successor of the Daddona regime, already succeed in sounding
the alarm that caused the retreating economic forces of Allentown to halt the
direction of their flight? Or did he fall short? Then too we equally ask --- Can
Martha Falk, as Daddona's understudy, be up to the job of sounding the alarm
that will cause the retreating economic forces of Allentown to halt the direction
of their flight? Or will that mission be left to Tony Frey, Emma Tropiano, Manny
Valesquez or someone else

Historically, the following steps were taken at one point by the Allentown City
Council to qualify for a "fair portion" of $150 million dollars of federal funds
assigned to the Commonwealth of Pennsylvania:

1. Council agreed to hire seven temporary employees to work with Robert E.
Moyer, Chairman of the Allentown Planning Commission, in drafting plans for
various projects and in preparing for the construction of a City Hall addition. We
note --- one such system contemplated would be the extension of the city's
storm sewer system to all parts of Allentown not then served.

2. Council authorized George Kistler, City Clerk, to advertise for bids for
construction of a $36,000 addition, a portion of which would be occupied by
Moyer's staff;

3. Council authorized Moyer to convert Council Chambers into an engineers'
planning and drafting room pending upon completion of a proposed addition. In
the interim, all meetings, of City Council would be conducted in the police court
room on the main floor of the then existing City Hall. (City Hall then located on
the South Side of Linden Street between 7th and 8th Street.)


Hock's statement provoked lively debate at the conference with the consensus
evolving upon the proposal of McKeesport Mayor Andrew J. Jackonis that
Pennsylvania's Mayors through the league should advocate that the national
government provide a kickback of income tax returns to the cities. The accepted
formula was that one percent of the federal income tax revert back to the cities
in which the taxpayer resided.

Without coining the term, we believe that the league was advocating an early
version of what became known later as revenue sharing --- a concept adopted
in a modified form by the administration of Richard M. Nixon (1969 - 1974).

Also, we note that the league's suggestion did not mark the beginning of inter-
governmental requests for aid. Such requests were made earlier then 1957 with
the result that federal grant programs were growing in numbers.

What we can determine from the league's action is that the mayors wanted to
increase the flow of federal dollars to avoid the political liability of imposing
additional real estate levies on their communities to meet expenditure
expectations; and that the resultant Revenue Sharing suggestion might be
more preferable to the mayors then the growing number of federal grant
programs in light of the conditions imposed on local government by their use.

Remember --- we said in PART ONE that whatever the reason, when local
government units come to the federal government for funds it gives up some of
its powers of decision-making and therefore, lessons its control over its own
situation or fate.

****   ****   ****

Just the same, this argument was generally ignored by cities looking for federal
aid. The fact being, it evolved that there would be growth of federally funded
grant programs. And, in the end the federal government and the academic world
would be interested in discovering the truth as to how these various programs
fared in meeting the established objectives of these programs.

Of importance, the advisory committee on Local Government of the Kestnbaum
Commission (1955) commented on the growth of federal grant programs. It was
their criticism that the growing number of federal grants received by local
governments lacked coordination, cohesion, and consistency.

Federal grants to local governments and states were given in such particular
fields as highways, public health, welfare, education, airports and natural
resources.

Created by an Act of Congress in 1953 and composed of appointees of the
President of the United States (Eisenhower), the President of the Senate, and
the Speaker of the House of Representatives, the Commission on Inter-
governmental Relations otherwise known as the Kestnbaum Commission was
charged with intensively studying national - state - local relationships. This
being the "first official undertaking of its kind since the Constitutional
Convention of 1787" according to documents filed by the Commission.

The Kestnbaum Commission made no attempt to delineate the specific details
of the state and national roles in the new metropolitan environment. This route
was taken by the Council of State Government with the tacit approval of the
Governor's Conference. But the Kestnbaum Commission did stress that both
government levels had important and unmet responsibilities to fulfill. The states
should naturally assume leadership in seeking solutions to their metropolitan
problem areas. Programs should be developed to deal with interstate S.M.S.A.'s.
Meanwhile the federal government should analyze the impact of its activities on
local communities and seek better coordination of national and state policy in
such areas.

A 1956 study sponsored by the Council of State Governments entitled " The
States and the Metropolitan Problem " and authored by John C. Bollens
provided a five-point program for action.

THE FIVE POINT PROGRAM

First, the states should provide authorization --- laws and where necessary
constitutional provisions and interstate compacts ---- to permit the creation of
general metropolitan units that are adequate in functions, financing ability, and
structure. These units may be one or more types: metropolitan multi-purpose
district, federation, and urban county. To be adequate in functions, they must be
permitted to perform a range of activities wide enough to eliminate or
substantially reduce area-wide service and regulatory deficiencies. As for
financing, they must be given a broad and equitable fiscal base, including the
powers to tax and issue bond. As for structure, they should be responsible to
and controlled by the metropolitan public.

Second, the states should determine the method --- legislation, local voter
decision, or administrative or judicial determination --- for putting the selected
type or types of general metropolitan units in effect.

Third, the states should provide suitable legal provisions for annexation and
interlocal agreements, which would generally be supplementary devices, and
for incorporation.

Fourth, the states should appraise the adequacy of local governments in terms
of area, financial ability, administrative organization and methods, and amount
of discretion in the exercise of powers; and they should make changes on the
basis of these appraisals.

Fifth, each state should establish a single agency to serve two major purposes:
it should aid in determining the present and changing needs of metropolitan
and non-metropolitan areas, and it should analyze the effects of current and
proposed programs, both of the several levels of government and major private
organizations. Such a state-level research and service agency would thus be
the focal point for information and evaluation about metropolitan and local
conditions and relations and would propose both remedial and preventive
programs. Moreover, such agencies would cooperate when parts of their states
were in interstate metropolitan areas.

In final analysis, this systematic attention in the mid 1950's and early 1960's to
redefine national - state and local roles in solving metropolitan problems
worked to produce changes in the Roosevelt " New Deal " programs that
targeted metropolitan problems. Whereas under the "New Deal " the federal
government passed on funds to meet program objectives through its own
bureaucracy, the programs of the mid - 1950's, early 1960’s, Lyndon B.
Johnson's " Great Society " and successive administrations increasingly made
the federal government a conduit of funds for the newly established state and
local bureaucracies.

Acceptance of federal grant programs did create problems for these newly
established bureaucracies for such acceptance brought certain liens on their
decision-making power.

In regard to the main issue we have been pursuing in this present study, we are
certain that the Emmaus - Allentown Wastewater Treatment Agreement and the
actions of the parties involved in this agreement were motivated by the
availability of national and state funds and this availability determined both
design and origin of said projects.

Also, with the information just presented, it is clear that Genevieve Blatt, the
Pennsylvania Secretary of Community Affairs in the George Leader
Administration, was redirecting on the local levels ideas that were developed
both on a state and national level when she spoke before the historic South
Mountain Conference of Lehigh Valley Governmental units October 7, 1957.


INSTALLMENT THREE

Will Rogers loved to pan Congress. He once said: " We have the best Congress
money can buy”.... " I don't make jokes; I just watch the government and report
the facts." And his words seem as relevant today as to the Twenties and
Depression era.

During the 1920's and 30's, the air we breathed was choked by unfiltered stacks
belching gritty coal smoke, rivers and streams were clogged by raw sewage
and untreated chemicals and metals. Today, thank goodness, we have laws
such as the Clean Air and Water acts to protect the air we breathe and the water
we drink and the parks that we all enjoy.

****   ****    ****

Because Pharaoh was obdurate and refused to allow the Hebrew people to
escape from their slavery in Egypt, God ordered his servant Moses to go to the
bank of the Nile and strike the water with his rod, thereupon turning the water
into blood.

The end result was that the fish in the Nile died, the river stank, and the Egyptian
people were unable to drink the water.

We can only believe there is no modern Moses instantly contaminating the
waters of the Commonwealth of Pennsylvania or the Lehigh Valley region. Yet,
in our lifetime quite a few communities have faced the same apparent
conditions in their water supplies (if only for a short - term basis) that
confronted Pharaoh.

The term we use to describe these conditions is pollution; and pollution shall be
defined to mean any noxious and deleterious substances rendering unclean the
waters of any governmental jurisdiction to extent of being harmful or inimical to
the public health, or animal or aquatic life, or to use of such waters for domestic
water supplies or industrial purposes or recreation.

Sewage and industrial wastes that is untreated or inadequately treated when
discharged into rivers, streams, rivulets, lakes, dammed water, ponds, springs,
and all other bodies of the surface and underground water can degrade the
purity of these waters.

Consequently, the Commonwealth of Pennsylvania in Public Law 394 (June 22,
1937) declared that the discharge of sewage and industrial wastes into the
waters of the Commonwealth to be against public policy and to be a public
nuisance.

Sewage discharges include any substance that contains any of the waste
products or excrementitous or other discharge from the bodies of human
beings or animals. Industrial waste discharges contain liquids, gases or solid
substances not of the consistency of sewage that is produced by
manufacturing or industry.

****   ****   ****

Importantly, Public Law 394 (June 22, 1937) gave the State Sanitary Water Board
the police power to halt the potentially harmful discharge of untreated or
inadequately treated sewage or wastewater into the Commonwealth's waters.
Section 210 of Public Law reveals that municipalities as well were impacted by
the police power provisions of the act:

" Any municipality upon whom an order of the Board (Sanitary Water Board) is
served to abate its discharge of untreated or inadequately treated sewage or
wastewater, shall take steps for the acquisition or construction of a sewer or
sewerage system or sewage treatment work or both or for repair, alteration,
extension or completion of an existing sewer, sewerage system or sewerage
treatment works, or both as may be necessary for the treatment of its sewage in
compliance with the order of law."

Section 210 also details how municipalities should finance the costs of Sanitary
Board ordered activities:

" The cost of the acquisition, construction, repair, alteration, completion or
extension of the sewers, sewage systems or sewage treatment works, as may
be necessary to comply with said order, shall be paid out of funds on hand
available for such purpose, or out of general funds of such municipality not
otherwise appropriated."

From the above, we entertain this thought --- Suppose municipalities under
order by the State Sanitary Water Board to eliminate their discharges into
Commonwealth waters do not have sufficient funds on hand or unappropriated
to finance the required corrective measures --- What does Act 394 (Section 210)
say about that?

Simply put: "If there be no sufficient funds on hand or unappropriated, then the
necessary funds shall be raised by the issuance of bonds, such bond issue to
be subject only to the approval of the Department of Internal Affairs."

****   ****   ****

In regard to our questioning as to the importance or role that Genevieve Blatt
played in the opening moves of the Lehigh Valley's rush to achieve a
metropolitan atmosphere and environment. It was no accident that Genevieve
Blatt, the Secretary of Internal Affairs during the George Leader Administration,
was asked to speak at the October 1957 Tri-City Conference sponsored
meeting. If the infrastructure for regional or municipal wastewater treatment
service was to be financed by the issuance of bonds, the one state official
whose approval was essential was that of the Secretary of Internal Affairs. We
suspect that during the occasion of Genevieve Blatt's visit to Allentown October
7, 1957 that Emmaus and even Allentown officials would want to talk to Mrs.
Blatt about finances required for construction of a new wastewater treatment
plant or an intercepting sewer system that would link up to an existing
wastewater treatment plant. Furthermore, Pennsylvania Public Law 275
(December 22, 1955) required municipalities to make application to Mrs. Blatt's
office if they desired easements under, across and in the beds of navigable
rivers or streams to facilitate the construction of wastewater treatment plants,
intercepting sewer systems and other facilities necessary and incidental to the
operation of the entire wastewater treatment system. Therefore, we conclude
that Allentown and Emmaus would have both motive and occasion to seek
such easements.

****   ****   ****

Almost eleven years after the passage of Pennsylvania Public Law 394 (June 22,
1937) the United States Congress enacted the Water Pollution Control Act of
1948 (Chapter 758  --- Public Law 845 --- June 30, 1948), it being the initial federal
legislation aimed at containing the public nuisance of water pollution.

Of importance --- a lasting monument to the Water Pollution Control Act of 1948
was the establishment of a United States Public Health Center in Cincinnati,
Ohio. The Taft Sanitary Engineering Center conducts research and performs
studies in connection with the pollution of interstate waters and, trains
personnel in work related to the control of pollution of such waters.

As it evolved, the Water Pollution Control Act of 1948 has since been extended
and strengthened by the Water Pollution Control Act Amendments of 1956
(Chapter 518 --- Public Law 660 --- July 9, 1956). Which in turn was amended by
the Water Pollution Control Act Amendments of 1965 and 1972. Please Note ---
that Congress in passing the amendment to the Water Pollution Control Act in
1972 known today as the Clean Water Act had the goal of making all of our
waterways "swimmable and fishable" by 1985. Unfortunately, in 1997, the goals
of the Clean Water Act still have not been met.

1997 marks the 25th anniversary of the Clean Water Act. In the 104th Congress
(1995 - 1996) there was a lot of pressure to reauthorize the Act. Thus, Clean
Water became the first environmental issue for the new Congress. The House
came up with H.R. 961, which essentially was a rollback of clean water
programs. The bill weakened enforcement of regulations, provided special deal
and exemptions for polluting industries, defined out of the universe of federal
protection 60-80% of the nations wetlands, and much more. Consequently,
detractors of H.R. 961 called it the "Dirty Water Bill."

When the bill hit the Senate, the Senate focused on wetlands instead of the full
Clean Water Act. However, due to an ongoing appropriations crisis, the Senate
never returned to work on CWA amendments and H.R. 961 died as Congress
ended.

Of importance --- The Water Pollution Control Act of 1956 determined that a most
meaningful existing need was for research to determine the impact of water
pollution on public health and other vital water uses; and furthermore, to find
more practical and economically feasible abatement measures to resolve the
existing water pollution problem. To this end the Water Pollution Control Act of
1956 provided for a broadened and intensified national research effort by
authorizing the Public Health Service to; (1) Supplement its direct research
operations at the Taft Center through contract research; thus making available
for special projects the assistance of other laboratories having specialized
personnel and equipment not needed by the Federal Government on a
continuing basis; (2) make research grants to universities and other research
institutions to stimulate essential studies and (3) award research fellowships to
attract scarce scientific talents to this field.

****   ****   ****

Of great historical and constitutional significance, the Water Pollution and
Control Acts of 1948 and 1956 also promoted as federal policy the concepts of
interstate cooperation and the avocation of uniform state laws to attack water
pollution problems. The fact is, Section 3 of the 1956 Water Pollution Control
Amendments Act provided financial incentive for the negotiation of regional
agreements or covenants (termed technically as federal/interstate compacts)
between two or more states to control water pollution problems of a regional
nature that transcended state lines. Please note --- one example of these
federal/interstate agencies was the establishment in 1961 of the Delaware River
Basin Commission (DRBC) comprising the Middle Atlantic States of
Pennsylvania, New Jersey, Delaware, New York and additionally, the federal
government. The federal involvement essential to overcome possible conflict
with provisions of the U.S. Constitution of 1787. The fixed reality of the DRBC
was the Commission had the authority to plan, manage, develop and regulate
the water resources and related land resources of the Delaware Basin. The
DRBC considered essential because the region had been involved in two major
interstate controversies in 1931 and 1954 over the use of waters of the
Delaware. In any case what was created was a quasi-government unit that
surely would be ruled unconstitutional if it did not have the approval of the
States that joined the unit and that of Congress. We note --- the quasi-
governmental units were roughly interpreted legally as a new State for
appropriation basis. To be exact, Article IV of the U.S. Constitution of 1787
stipulated that no new states shall be formed or enacted within the jurisdiction
of any other State; nor any State be formed by the junction of two or more
States, or Parts of States without the consent of the Legislature of the States
concerned as well as of the Congress.

Section 3 0f the 1956 act reads as follows:

" Sec. 3 (a) The Surgeon General shall encourage cooperative activities by the
States for the prevention and control of water pollution; encourage the
enactment of improved, and, so far as practicable, uniform State laws relating to
the prevention and control of water pollution; and encourage compacts
between States for the prevention and control of water pollution,"

(b) The consent of Congress is hereby given to two or more States to negotiate
and enter into agreements or compacts, not in conflict with any law or treaty of
the United States, for (1) cooperative effort and mutual assistance for the
prevention and control of water pollution and the enforcement of their
respective laws relating thereto, and (2) the establishment of such agencies,
joint or otherwise, as they may deem desirable for making effective such
agreements and compacts. No such agreement or compact shall be binding or
obligatory upon any State a party thereto unless and until it has been approved
by Congress."

Pennsylvania officials surely were interested in the Water Pollution Control Act
of 1956 for it provided for State grants for water pollution programs in addition
to grants for interstate agencies. Section 5 of the Act authorized to be
appropriated for the fiscal year ending June 30, 1957, and for each succeeding
year to and including the fiscal year ending June 30, 1961 $3 million for grants
to States and interstate agencies to aid in the establishment and maintenance of
adequate measures for the prevention and control of water pollution. Such
grants to be used for meeting costs, under approved plans, of establishing and
maintaining adequate water pollution prevention and control measures,
including costs of training personnel and administering the State and interstate
agency plans.

Allotments to the several States would be made by the Surgeon General of the
United States Public Health Service in accordance with regulations, on the
basis of population, extent of water pollution problem, and financial need of
respective States. Allotments for interstate agencies would be made in
accordance with regulations, on such basis, as the Surgeon General finds
reasonable and equitable. The process of the appropriations available for the
States and the portion available for interstate agencies were to be specified
separately in the appropriation costs.

The state allotments would be available for paying the Federal Share (described
below) of the cost of carrying Out State plans. The federal share was defined as
a percentage which equaled 1000 percent minus the percentage which bears
the same ratio to 50 percent as the per capita income of the State bears to the
per capita income of the continental United States  (excluding Alaska). However,
the Federal Share could not exceed a maximum of 66 2/3 percent nor could it be
less than 33 1/3 percent; and the Federal Share would be fixed at 50 percent for
Hawaii and Alaska, and at 66 2/3 percent for Puerto Rico and the Virgin Islands.

****   ****   ****

Certainly, it was inevitable that sometime in the future Emmaus borough
officials would seek or be forced to provide sewage service in the borough for
Pennsylvania Public Health Laws required that all communities having a
population of more than 10,000 should provide such service to their
communities. In 1956, the population of Emmaus was nearing that prescribed
number and this, compounded with the availability of state and federal funding
provided the proper incentive for the borough council to begin planning for
sewage service in March of 1956.

Title VII of the Housing Act of 1954 (Chapter 649 --- Public Law 560 ---- August 2,
1954) encouraged Emmaus planners to proceed with preliminary planning
activity.

Section 702 provided for federal aid to assist in advance planning of State and
Local non-federal public works. The Housing and Home Finance Administrator
was empowered to make advances to the States, their agencies, or political
subdivisions for the planning of public works (other than housing) which
conform to an overall State, Local or Region plan approved by a competent
State, Local or Regional Authority. Any such advance becomes repayable in full,
without interest, if and when the construction of the public works contemplated
by the advance was undertaken or started. However, if payment was not made
promptly when due, the unpaid amount of the advance would bear interest at
the rate of four- percent annum from the date the Federal government made
demand for repayment.

****   ****   ****

Also, may we suggest, the United States House of Representatives Public
Work's Committee hearing (July 20, 1955) in regard to a proposed Water
Pollution Control Act Amend may have served as another catalyst to spur
Emmaus borough planning activities.

Indeed the following provisions of the Water Pollution Control Act of 1956
served as a siren lure which beckoned Emmaus borough officials to answer:


" Section 6 --- (a) The Surgeon General is authorized to make grants to any
State, Municipality, or intermunicipal or Interstate agency for the construction of
necessary treatment works to prevent the discharge of untreated or
inadequately treated sewage or other waste into any waters and for the purpose
of reports, plans, and specifications in connection therewith.

(b) Federal grants under this section shall be subject to the following limitations
(1) No grant shall be made for projects pursuant to the section unless such
project shall have been approved by the appropriate State water pollution
control agency or agencies and by the Surgeon General and unless such
project is included in a comprehensive program developed pursuant to this Act;
(2) No grant shall be made for any project in an amount exceeding 30 per
centum of the estimated reasonable cost as determined by the Surgeon General
or in the amount exceeding $250,000, whichever is smaller; Provided, that the
grantee agrees to pay the remaining cost; (3) No grant shall be made for any
project under this section until the applicant has made provision satisfactory to
the Surgeon General for assuring proper and efficient operation and
maintenance of the treatment works after completion of the construction
thereof; And (4), no grant shall be made for any project under this section
unless such project is in conformity with the State water pollution control plan
submitted pursuant to the provisions of Section 5 and has been certified by the
State water pollution control agency as entitled to priority over other eligible
projects on the basis of financial as well as pollution control needs."

****   ****   ****

Note --- it was the intent of Congress that the term "treatment works " be
understood as the various devices used in the treatment of sewage or industrial
wastes of a liquid nature, including the necessary intercepting sewers, outfall
sewers, pumping power, and other equipment, and other appurtenances, and
includes any extensions, improvements, remodeling, additions, and alterations
thereof.

****   ****   ****

P.S. ---- Section 6 (c) of the Water Pollution Control Act of 1956 provided
guidance for the Surgeon General in selecting projects in which federal financial
aid would be given.

Section 6 (c) states:

" In determining the desirability of projects for treatment works and approving
Federal Financial aid in connection therewith, consideration shall be given by
the Surgeon General to the public benefits to be derived by the construction
and the propriety of Federal aid in such construction, the relation of the ultimate
cost and to the public necessity for the works, and the adequacy of the
provisions made or proposed by the applicant for each Federal financial aid for
assuring proper and efficient operation and maintenance of the treatment works
after completion thereof."

INSTALLMENT FOUR

Emmaus publicly announce its preliminary engineer plans October 26, 1956 and
quickly entered into official discussions with the City of Allentown. Unofficially,
Emmaus had consulted officials from Allentown since the beginning of the
project in March 1956; and, Allentown cooperated to the extent of helping
Emmaus obtain an engineer.

The engineering survey conducted by Gilbert Associates, Inc. of Reading
recommended the placement of the borough's wastewater disposal plant along
the Little Lehigh Creek in Salisbury Township, about 1,000 feet east of Keck's
Bridge. Of course, at that time Allentown's Little Lehigh Parkway, the city's
watershed, terminated at Rathburn's Bridge less than a half mile downstream
from the proposed site if the treatment plant. (Allentown since then has
extended its ownership of land along the Little Lehigh up to the vicinity of
Keck's Bridge.)

Engineers told Emmaus officials that the Little Lehigh would be the only place
to erect the plant. It is the only outlet because of the terrain of the borough and
the fact that there are no other streams in the area.

The alternative would be Allentown handling of Emmaus Sewage through
physical connection of the borough collection main with the city's existing
underground stream.

The rated capacity of Allentown's wastewater treatment plant (Kline’s Island) in
1956 was 17 million gallons of sewage daily with the city outpost constituting 13
million gallons. Emmaus's expected output would be less than a half a million
gallons a day, on the experience basis of 40 to 43 gallons per capita flow. The
Emmaus population was approximately 9,560 at the time.

Allentown city engineers assured the Allentown City Council that the addition of
wastewater from Emmaus would not overload the Allentown trunk system nor
its treatment plant, nor would this addition cause the rated capacity of the
Kline's Island facility to be exceeded, but they warned that increased flow might
force the need for construction of additional rock beds in the future.

Concerning the proposed Emmaus treatment plant, its function would be to
treat effluent material in such a manner as to make it free of all disease
producing bacteria and all suspended solids which might settle and
decompose along the creek bed. The discharge must have no oxygen demand
least it deplete the creek of oxygen and kill fish and plant life.

Whichever alternative Emmaus chose --- that is, building its own plant or
delivering its wastewater to Allentown's plant for treatment, the cost of either
system would be extensive. The preliminary study pegged the price at about
$3.3 million dollars including $700,000 for a treatment plant. Nearly $.6 million
would have to be spent for the underground collection system alone. Clearly,
Emmaus would save $700,000 if it delivered its wastewater to Allentown for
treatment.


In regard to the Allentown connection former Emmaus Burgess Fred D. Balse
maintained that such a connection should be economically feasible to both
communities; that, it was not the objective of the borough to place any burden
on the city of Allentown.

To this, R.J. Schatz, sanitary engineer for Gilbert Associates of Reading offered
that Emmaus would inevitably bear part of any addition (present or future) to the
Allentown plant; and that he expected the borough to pay either a flat fee or rate
per thousand gallons yearly. However, it was his preference that Emmaus be
allowed to contribute toward the operation and maintenance of the city's
treatment plant rather then pay a rate.

(The Emmaus consultant replied to both Allentown and Emmaus officials that
should the City of Allentown receive a federal grant for a trunk line to carry
Emmaus sewage then the established rates or charges for the Allentown
sewage service would be adjusted to meet the city's construction cost.)

We have already detailed in INSTALLMENT ONE of PART TWO R.J. Schatz's
recommendation for a joint Allentown - Emmaus enterprise to operate the entire
wastewater treatment system.

****   ****   ****

Concerning finances, R. W. Simpson of Gilbert Associates kept the Emmaus
borough council current as to what federal or state funds could be sought by
the borough to assist in the establishment of the borough's treatment works
system. The Emmaus Council was told October 27, 1958 that the borough could
qualify for two percent of the cost of its disposal plant and for some of the
interceptor lines from the state under a program established by the Water
Pollution Act of 1956. Federal aid could go as high as $250,000 depending upon
the requests by other municipalities for public work projects.

At another point, Simpson stressed that a federal grant based on 30% of some
of the construction cost might be available. As an example, he said that if the
cost was $200,000 then the borough could receive 30 percent or $60,000.

The cost would be based on a trunk sewer from the borough line to the Little
Lehigh Creek, a force main and two or three pumping stations.

(Note --- when negotiations between Allentown and Emmaus bogged down,
Emmaus became concerned at the possibility of not meeting on April 1, 1959
deadline for application; therefore the borough authorized its engineer to draw
up and detail specific plans in relationship to the development of its own plant.
Interestingly, when Allentown and Emmaus achieved a breakthrough in
negotiations the April 1, 1959 deadline was put off to May 1, 1959 with the
Emmaus engineer required to submit specifications for the Allentown - Emmaus
connection April 15, 1959. )

****   ****   ****

As an aid for planning, the borough received in November 1957 a $60,000
advance from the Federal Community Facilities Administration (CFA) for the
performance of preliminary plans.

Preliminary plans included field surveys, topography and profile maps,
preliminary design and layout, outline specifications and test borings. The
Gilbert Associates preliminary plans called for the placing of trunk lines in alleys
wherever possible. Sewer lines needed for the borough would total 15,140 feet.
Preliminary studies estimated that the probable rate for installation of lines on a
front-foot and hook-up basis would be $9.50.

Despite the availability of federal and state funds, much of the Emmaus project
would be financed through a bond issue. The borough created the Emmaus
Municipal Authority in 1957 to handle the financing of the system.

Another CFA advance of $80,380 was received February 1959 by the borough to
prepare plans and specifications for a sanitary sewer system.

The Emmaus project was assisted under the program of advances for public
works planning authorized by the Housing Act of 1954. The program provided
interest-free advances for planning essential public works and community
facilities.

****   ****   ****

Emmaus borough officials, of course, welcomed the availability of these
federally sponsored loan programs. After all, these federal advances enabled
borough engineers to proceed with their preliminary planning activities in
advance of the immediate necessity to withdrawal funds from the community
treasury. But just the same, eventually the community treasury had to be tapped
to settle the borough's account with the federal government. Federal law
provided that these advances were repayable with the start of construction
activities.

So often have we heard local officials justify the acceptance of federal tax
dollars for locally planned projects as a means to alleviate the tax burden that
payment of debts for such projects would cost if financed by the local tax base.
But we wonder whether these same local officials ever considered the reality
that their citizens are also taxpayers of the federal government. If federal money
is utilized by local government for good purposes and is properly utilized ---
very good. But if the same money is utilized by local authorities improperly or
for wasteful projects --- that is not good.

In the case of Emmaus's proposed project the federal agency responsible for
providing local communities with such advances thought the project
worthwhile. The agency took note of the fact that Emmaus depended on
cesspools in the congested areas and septic tanks in the residential sections,
both of which were said to be unsatisfactory. The proposed sewerage system
for the borough had been approved by the State Department of Health under
the assumption that it would relieve the above conditions.

SUMMATION

Allentown and Emmaus reached agreement concerning Emmaus's request to
Allentown for wastewater treatment service on March 17, 1959. Consequently,
the Emmaus Authority was able to finalize its plans for the construction of a
underground collection system serving the borough and for the construction of
the Emmaus Interceptor (a 24 to 36 inch Interceptor trunk line with the capacity
of 8,0 to 14.5 MGD) that would tie into the Allentown system near the vicinity of
Keck's Bridge in Salisbury Township.

With historic importance, by May 1961 sewage from the borough of Emmaus
was processed by the Allentown sewer system; and with such processing
Allentown established precedent that allowed for other communities to seek the
services provided by its Kline's Island Wastewater Treatment Plant.

The wastewater treatment plant located on Kline's Island was initially placed in
operation in 1929. (Metcalf & Eddy, however, in its Feasibility Report to the City
of Allentown, Pennsylvania on Additional Waste Treatment facilities at Kline's
Island  ---- December 8, 1969 maintains that the original wastewater treatment
plant located on Kline's Island was completed and put into operation in 1932)...
In 1961, the plant provided complete treatment of waste flows and consisted of
Imhoff Tanks, Standard-rate trickling filters, final settling tanks, and open sludge
drying beds. The plant was designed for an average flow of 17.3 mgd (the
average flow in 1962 was 16.55 mgd.) and a maximum flow of twice the 17.3
figure.

This 17.3 average flow capacity since 1961 has subsequently been upgraded in
steps to allow for an average flow of 40.0 mgd to meet demands for service by
additional communities. Unfortunately, this expansion of capacity has been
achieved at a severe environmental cost.

William J. Engle, Allentown's Water Resource Manager, gives attention to an
aspect of this environmental cost in the following memo to Allentown Mayor
Joseph S. Daddona and Public Works Director Harry Bisco dates May 23, 1984:


" The Kline's Island Wastewater Treatment Plant is a biological type process
prone to odor generation. The creation of these odors is a function of loadings,
waste stream characteristics, ambient conditions (temperature/humidity) and of
plant operations. These do not necessarily have to be in combination for an
odor to arise, anyone of these can create a problem. The nature of the product
processed gives off odorous compounds offensive to sensitive individuals.
Therefore, it is management’s objective to mitigate these the best way possible
for the least cost, recognizing the weather is beyond its control."

Odorous pollutants from a wastewater stream can be emitted from many
locations in the collection and treatment system. This occurs because organic
material containing sulfur and/or nitrogen in domestic wastewater can, in the
absence of oxygen, undergo incomplete oxidation resulting in the emission of
odor. Therefore, our efforts have been towards limiting the type and
concentration of the waste stream entering the collection system, towards
controlling the wastes as they proceed through the collection system, and
towards mitigating the generation of odors as the waste is processed through
the plant."

*** The Emmaus - Allentown Sewer Agreement of March 17, 1959***

Clearly we understand the problems that Engle dealt with on an almost daily
basis has evolved over a period of years. That each decision or agreement in
this ongoing saga has created its own impacts or marks. We have already
acknowledged the historic significance that the Emmaus - Allentown
Wastewater Agreement of March 17, 1959 is accorded in the genesis of
wastewater treatment saga, let us now present the main points of this
agreement:

1) Cost --- Emmaus will be a " customer " of Allentown. During the first five (5)
years of the agreement minimum quarterly payments of five thousand ($5,000)
dollars or at a rate of 83 mills per 1000 gallons discharged by the borough
through the recording meter would be assessed. The official rate would be
whichever amount represented the greater amount ---- During the next five (5)
years of this agreement the minimum quarterly payments of $8,350 or a rate of
83 mills per 1000 gallons discharged by the borough through the record meter
shall be assessed. The official rate determined again at whatever amount
represented the greater amount.

The above charges were subject to change as provoked by the contract.
Contract charges were established on the basis of the estimated construction,
operation and maintenance cost for facilities required to serve the borough and
further, on the estimated values of future flows to be discharged by the city and
the borough to the treatment plant. The estimated rate would be reviewed every
five years during the period of agreement with rates revising either downward
or upward. These were provisioned to reflect actual cost conditions as they are
determined. All such revisions were subject to approval of both the city and
borough.

The basis for all such revisions were and shall be the following:

Sewage Plant Operation

a. Salaries and wages
b. Material and supplies
c. Repairs to the plant;
d. Fuel and light;
e. Electric power;
f. Equipment;
1. Maintenance and repair
2. Operation - motor equipment
3. Purchase of motor equipment
g. Maintenance of trunk sewer through which borough of Emmaus sewage
flows.

Trunk Sewer Operation

a. Interest and amortization of Allentown trunk sewer from borough of Emmaus
to Scrieber's Bridge;
b. Interest and amortization of Allentown Sewage Plant expansion, such
expansion contemplated in 1965 and made to accommodate Emmaus Sewage.
No costs for additional expansion beyond 1965 expansion now contemplated
shall be included in the rate base, unless made specifically for the benefit of the
borough of Emmaus;
c. In the event financing costs for the present plant facilities are used in the
base, no depreciation shall be used.

State and Federal Aid

All state and federal aid grants received by the city for the construction of the
city trunk sewer and any enlargement to the city treatment plant shall be
reflected in the actual cost used in determining the borough sewer rate.

2) Capacity --- the borough would agree to use the city trunk system 40 years
from the date of the agreement. The borough would have the right and
privileges to extend its sewer system to newly annexed areas of the borough
provided the average daily flow from the borough did not exceed 1.4 million
gallons per day. In the event that the average daily flow did exceed 1.4 million
gallons per day, the borough would pay to the city such additional costs as are
incurred by the city due to the increased flow.

3) Timing and location --- The city promised not later than January 1, 1961 to
provide a trunk line from its sewage works along the Little Lehigh Creek, in and
through the city of Allentown and a portion of Salisbury Township to a point
located on the Clarence W.R. Keck farm (also known as Fink's Farm) near the
Little Lehigh Creek at the site selected by Emmaus for the construction of its
proposed sewage treatment plant. The city trunk sewer shall be of sufficient
capacity to receive and convey sanitary waste from the borough at the rate of
flow of at least 6.5 cu. ft. per second. The actual point of connection shall be
made at a manhole or junction chamber to be constructed by the city as part of
the trunk sewer.

4) Meter --- Emmaus will install, maintain and operate, at its own expense a
recording meter at a point located on the boundary line of the borough to
measure the flow discharge to the city works. The record of sewage flow
through the recording meter operated and maintained by the borough will be
forwarded to the city on or before the 5th day of the first month of each quarter
showing the total and daily sewage flows discharge during the previous month.

5) Termination --- in the event that Emmaus should desire to discontinue the
discharge of its sewage into the City system prior to the expiration of forty years
from the date thereof, then the borough will pay to the city such sums or sums
of money as may be required to retire outstanding bonded indebtedness
incurred from and after the date of this agreement for the purpose of
constructing that part of the city collection works along the Little Lehigh Creek
--- Keck Farm to Cedar Creek --- required by the jointure of the borough to said
system.

****   ****   ****

We must add --- at one point during the discussion between Allentown and
Emmaus in regard to the matter of pending linkage of the Allentown and
Emmaus sewerage systems, the Emmaus Borough Council was under the
impression that the Allentown City Council wished that the connection of the
two systems be made on Emmaus Avenue, as the city was extending its Trout
Creek Interceptor Sewer to the building being erected by L.F. Grammes and
sons. But in the end, the consulting engineers involved in the project convinced
the politicians to agree to an Allentown --- Emmaus hook-up at Keck's Bridge.
As a result, Allentown found it necessary to disturb the serenity of its Lehigh
Parkway by laying the Little Lehigh Collector Sewer (also known as the
Emmaus Interceptor) from Shrieber's Bridge in the vicinity of the Cedar Creek to
Keck's Bridge.

****   ****   ****

Of historical importance --- the construction of the Little Lehigh Collector Sewer
with its tie-in into the Kline's Island Wastewater Treatment Plant via the lower 2
sections of the Little Lehigh Creek Interceptor Sewer would also serve as a
convenient conduit or highway for sewerage from communities located in
western Lehigh County that would eventually be served by the Lehigh County
Authority.

This reality was guaranteed by the sewerage agreement made the 22nd day of
December 1969 between the City of Allentown and the Lehigh County Authority.
But surely, the Emmaus - Allentown Wastewater Agreement of March 17, 1959
can be credited for making this reality inevitable; whatismore, the city of
Allentown recognized the inevitability by adopting an "Open Door " policy May
14, 1963 for the handling and treatment of sewerage from other communities
contingent upon the negotiation of mutually satisfactory agreements.

An example of such was the December 22, 1969 agreement between the City of
Allentown and the Lehigh County Authority wherein the City of Allentown
granted to the Authority the perpetual rights to convey sewage and wastes into
the Allentown system contingent on the following stipulations found in section
2E of the agreement:


" City does hereby grant to the 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 City's Interceptor Sewer known as the Emmaus Inceptor which
Interceptor Sewer runs from a point at Keck's Bridge to a point at Shrieber's
Bridge, subject to the condition that the 10 c.f.s limit nay be exceeded by 20 per
cent for a period of 2 hours per day for not more than one day per week. Should
the limits heretofore set forth be exceeded, the County will either (1) make plans
to reduce the maximum flow or (2) relieve such sections of the said Emmaus
Interceptor as shall be necessary."

****   ****   ****

o mitigate these the best way possible for the least cost, recognizing the
weather is beyond its control."

Odorous pollutants from a wastewater stream can be emitted from many
locations in the collection and treatment system. This occurs because organic
material containing sulfur and/or nitrogen in domestic wastewater can, in the
absence of oxygen, undergo incomplete oxidation resulting in the emission of
odor. Therefore, our efforts have been towards limiting the type and
concentration of the waste stream entering the collection system, towards
controlling the wastes as they proceed through the collection system, and
towards mitigating the generation of odors as the waste is processed through
the plant."

*** The Emmaus - Allentown Sewer Agreement of March 17, 1959***

Clearly we understand the problems that Engle dealt with on an almost daily
basis has evolved over a period of years. That each decision or agreement in
this ongoing saga has created its own impacts or marks. We have already
acknowledged the historic significance that the Emmaus - Allentown
Wastewater Agreement of March 17, 1959 is accorded in the genesis of
wastewater treatment saga, let us now present the main points of this
agreement:

1) Cost --- Emmaus will be a " customer " of Allentown. During the first five (5)
years of the agreement minimum quarterly payments of five thousand ($5,000)
dollars or at a rate of 83 mills per 1000 gallons discharged by the borough
through the recording meter would be assessed. The official rate would be
whichever amount represented the greater amount ---- During the next five (5)
years of this agreement the minimum quarterly payments of $8,350 or a rate of
83 mills per 1000 gallons discharged by the borough through the record meter
shall be assessed. The official rate determined again at whatever amount
represented the greater amount.

The above charges were subject to change as provoked by the contract.
Contract charges were established on the basis of the estimated construction,
operation and maintenance cost for facilities required to serve the borough and
further, on the estimated values of future flows to be discharged by the city and
the borough to the treatment plant. The estimated rate would be reviewed every
five years during the period of agreement with rates revising either downward
or upward. These were provisioned to reflect actual cost conditions as they are
determined. All such revisions were subject to approval of both the city and
borough.

The basis for all such revisions were and shall be the following:

Sewage Plant Operation

a. Salaries and wages
b. Material and supplies
c. Repairs to the plant;
d. Fuel and light;
e. Electric power;
f. Equipment;
1. Maintenance and repair
2. Operation - motor equipment
3. Purchase of motor equipment
g. Maintenance of trunk sewer through which borough of Emmaus sewage
flows.

Trunk Sewer Operation

a. Interest and amortization of Allentown trunk sewer from borough of Emmaus
to Scrieber's Bridge;
b. Interest and amortization of Allentown Sewage Plant expansion, such
expansion contemplated in 1965 and made to accommodate Emmaus Sewage.
No costs for additional expansion beyond 1965 expansion now contemplated
shall be included in the rate base, unless made specifically for the benefit of the
borough of Emmaus;
c. In the event financing costs for the present plant facilities are used in the
base, no depreciation shall be used.

State and Federal Aid

All state and federal aid grants received by the city for the construction of the
city trunk sewer and any enlargement to the city treatment plant shall be
reflected in the actual cost used in determining the borough sewer rate.

2) Capacity --- the borough would agree to use the city trunk system 40 years
from the date of the agreement. The borough would have the right and
privileges to extend its sewer system to newly annexed areas of the borough
provided the average daily flow from the borough did not exceed 1.4 million
gallons per day. In the event that the average daily flow did exceed 1.4 million
gallons per day, the borough would pay to the city such additional costs as are
incurred by the city due to the increased flow.

3) Timing and location --- The city promised not later than January 1, 1961 to
provide a trunk line from its sewage works along the Little Lehigh Creek, in and
through the city of Allentown and a portion of Salisbury Township to a point
located on the Clarence W.R. Keck farm (also known as Fink's Farm) near the
Little Lehigh Creek at the site selected by Emmaus for the construction of its
proposed sewage treatment plant. The city trunk sewer shall be of sufficient
capacity to receive and convey sanitary waste from the borough at the rate of
flow of at least 6.5 cu. ft. per second. The actual point of connection shall be
made at a manhole or junction chamber to be constructed by the city as part of
the trunk sewer.

4) Meter --- Emmaus will install, maintain and operate, at its own expense a
recording meter at a point located on the boundary line of the borough to
measure the flow discharge to the city works. The record of sewage flow
through the recording meter operated and maintained by the borough will be
forwarded to the city on or before the 5th day of the first month of each quarter
showing the total and daily sewage flows discharge during the previous month.

5) Termination --- in the event that Emmaus should desire to discontinue the
discharge of its sewage into the City system prior to the expiration of forty years
from the date thereof, then the borough will pay to the city such sums or sums
of money as may be required to retire outstanding bonded indebtedness
incurred from and after the date of this agreement for the purpose of
constructing that part of the city collection works along the Little Lehigh Creek
--- Keck Farm to Cedar Creek --- required by the jointure of the borough to said
system.

****   ****   ****

We must add --- at one point during the discussion between Allentown and
Emmaus in regard to the matter of pending linkage of the Allentown and
Emmaus sewerage systems, the Emmaus Borough Council was under the
impression that the Allentown City Council wished that the connection of the
two systems be made on Emmaus Avenue, as the city was extending its Trout
Creek Interceptor Sewer to the building being erected by L.F. Grammes and
sons. But in the end, the consulting engineers involved in the project convinced
the politicians to agree to an Allentown --- Emmaus hook-up at Keck's Bridge.
As a result, Allentown found it necessary to disturb the serenity of its Lehigh
Parkway by laying the Little Lehigh Collector Sewer (also known as the
Emmaus Interceptor) from Shrieber's Bridge in the vicinity of the Cedar Creek to
Keck's Bridge.

****   ****   ****

Of historical importance --- the construction of the Little Lehigh Collector Sewer
with its tie-in into the Kline's Island Wastewater Treatment Plant via the lower 2
sections of the Little Lehigh Creek Interceptor Sewer would also serve as a
convenient conduit or highway for sewerage from communities located in
western Lehigh County that would eventually be served by the Lehigh County
Authority.

This reality was guaranteed by the sewerage agreement made the 22nd day of
December 1969 between the City of Allentown and the Lehigh County Authority.
But surely, the Emmaus - Allentown Wastewater Agreement of March 17, 1959
can be credited for making this reality inevitable; whatismore, the city of
Allentown recognized the inevitability by adopting an "Open Door " policy May
14, 1963 for the handling and treatment of sewerage from other communities
contingent upon the negotiation of mutually satisfactory agreements.

An example of such was the December 22, 1969 agreement between the City of
Allentown and the Lehigh County Authority wherein the City of Allentown
granted to the Authority the perpetual rights to convey sewage and wastes into
the Allentown system contingent on the following stipulations found in section
2E of the agreement:


" City does hereby grant to the 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 City's Interceptor Sewer known as the Emmaus Inceptor which
Interceptor Sewer runs from a point at Keck's Bridge to a point at Shrieber's
Bridge, subject to the condition that the 10 c.f.s limit nay be exceeded by 20 per
cent for a period of 2 hours per day for not more than one day per week. Should
the limits heretofore set forth be exceeded, the County will either (1) make plans
to reduce the maximum flow or (2) relieve such sections of the said Emmaus
Interceptor as shall be necessary."

****   ****   ****

Of more historical importance ---- predicated by the Allentown " Open Door "
policy of May 14, 1963, Arthur Wiesenberger in business as Arthur L.
Wiesenberger Associates was engaged first by the Coplay-Whitehall Sewer
Authority and next by the communities of the Little Lehigh Sewer Complex to
proceed with the design of comprehensive sewer systems intended to be either
self-sustaining or connected with the Allentown system. Wiesenberger's efforts
were facilitated by sewer agreements Allentown negotiated in 1965 and 1969.


PART THREE

PREFACE

Odors are the major pollutants from wastewater treatment facilities, and
depending on the nature, intensity and duration of the odor and atmospheric
conditions the following problems may occur:

... Damage to structures;
... Danger to persons;
... Legal action;
... Personnel problems;
... Poor work efficiency;
... And, public relations difficulties.

MEMORIES OF A ROOKIE COUNCILMAN

For former Allentown Mayor Joseph S. Daddona and other public officials, the
occurrence of severe odor conditions in and around a wastewater treatment
plant in Downtown Allentown would be a major point of contention with the
public for years. The public would not be content to remain silent on the
presence of long-term objectionable odors, which had plagued their
neighborhoods. In fact, for many, an added objective in the ensuing battle was
to find the truth concerning the motivations and actions of the many public
officials caught up in the stinking affair.

Harrison E. Forker as one of the leaders in this battle, used many forums and
vehicles in his campaign against the Lehigh County Sewer Authority and the
City of Allentown to present his case concerning then existing sewage
problems.  Harry in his exuberance would write letters to a wide range of public
officials that included the President of the United States, U.S. Senators and
Representatives, The Governor of Pennsylvania, PA. Senators and
Representatives, as well as local officials and officials of various regulatory
agencies and industries related to the issue. Additionally, Harry sought
assistance in this battle from people of all age brackets. We note that on
October 10, 1979 Harry brought two young sisters from East Allentown to speak
before the Lehigh County Commissioners with a request for the County to do
something about the odor from Allentown's Kline's Island Wastewater treatment
plant near the girls' home. One of the sisters told the Commissioners: "As
children we are concerned about our community being a nice place to live and
wish you luck in cleaning up the bad smells around our house this past
summer." That same evening Dorothy Hontz of 22 S. Carlisle St., Allentown
challenged the Board of Commissioners " to work with the city in rectifying our
sewer problems."

From 1968 though 1993, Joe Daddona was the political leader most involved in
the design and funding of expansion projects at the Kline's Island Wastewater
Treatment Plant. A fact that put Daddona in the position of being the one
political figure whom presided the longest and most consistently over the
events and decision-making that established the metropolitan area disposal
system. This also means that Joe Daddona must bear the weight of public
scrutiny for whatever decisions he made.

It appears that Joe Daddona would like the public to forget or playdown his long
involvement with decision-making that has gone awry. Decision-making that
has burdened large segments of Allentown and other communities with
unpleasant gases or vapors. But such loss of memory or forgiveness is difficult
for the truth is that Joe Daddona and his advisors have built a tower without
first calculating all the circumstances and possibilities that would arise. They
sought the cheap way out and looked for short-term political oriented solutions,
which at the time may have been cheaper. But look at the added cost in ensuing
years that we paid time after time for our tower built upon sand foundations.

What is truly remarkable in this stinking affair is that the public in 1981, four
years after turning him out of office in 1977, once again turned to Joe Daddona
to undo the mistakes that he made

TENURE BEGAN

It was in 1968 that Joe Daddona's office tenure in municipal and regional
decision-making began when he became a member of the Allentown City
Council in the last days of the old commission form of government. The
commission form of government was administered by a Mayor who was a
member of Council and who shared equal powers with the remaining members
of Council. The four councilmen and the Mayor being full-time officials assumed
extra duties as department heads.

By chance or design rookie councilman Joe Daddona was assigned the
Department of Streets and Public Improvements.

It was in this capacity that Daddona's involvement with the Kline's Island
Wastewater Treatment Plant and its Interceptor System began. Also, it was in
this capacity that the future Mayor involved himself in the politics of facilitating
economic development growth schemes in western Lehigh County.

THE CONFERENCE

On September 17, 1968, Daddona attended a conference related to sewerage
designed specifically for those communities located on the Little Lehigh
Watershed.  ... (That is, the townships of Upper and Lower Macungie, and the
boroughs of Macungie and Alburtis)... City Engineer William A. Jacoby and C.J.
Hitchcock of Metcalf & Eddy joined Daddona as the Allentown delegation
attending the conference,

Allentown's interest was pre-determined by Resolution 19574 dated May 14,
1963 in which Allentown agreed "to accept into its sanitary sewerage system for
handling and treatment, sewage from 11 municipalities and townships or parts
thereof which have or may signify their interest in such an arrangement.
"Among the eleven municipalities included in this resolution were the four
subject municipalities we stated above. The resolution also stipulated that the
commitment was contingent upon the negotiation of a mutually satisfactory
agreement providing for a method and payment of services

As evidenced by Harry Forker's appearance before the Lehigh County
Commissioners October 10, 1979, a decade later, there was still much regional
wrangling related to water and sewer issues over what constituted a mutually
satisfactory agreement providing for a method and payment of services.

Forker, that evening, in brief remarks attacked the latest request by the Lehigh
County Authority for financial backing by the Board of Lehigh County
Commissioners for water systems. He repeated his charge that the LCA owed
the city hundreds and thousands of dollars in utilities billings. To which LCA
Officials responded that the amounts were unpaid because the rates were
under dispute.

Resolution 19574 originated in the administration of Jack Gross, a little more
than a year after John P. Durr, the regional director for the state sanitary water
board, called for the development of a regional wastewater treatment district
with Kline’s Island as the site for a central disposal plant.

Predicated upon the City of Allentown's promised commitment to treat the
effluent from western Lehigh County communities, the Little Lehigh Watershed
Sewer Complex was formulated and A. L. Wiesenberger Associates was
entrusted to proceed with the design of the comprehensive system.

In this design process, A. L. Wiesenberger Associates contacted Allentown's
engineering consultant, Metcalf & Eddy of Boston, in regard to what capacity
the city would leave in reserve in the expanded plant for future use by the
engineering firms’ client municipalities.

Metcalf & Eddy responded May 20, 1964 that 1.7 million gallons per day would
be set aside for future use by the four municipalities. The figure was duplicated
in all subsequent memoranda and drafts of the " proposed agreement for STP
Enlargement between Allentown and the Townships." But we must emphasize
that no formal commitment between Allentown and the four western Lehigh
County communities was mutually agreed upon by the time Joseph S. Daddona
assumed the position of Director of the Allentown Department of Streets and
Public Improvements.

Certainly we believe that Wiesenberger contacted the Allentown delegation
during the September 17, 1968 Little Lehigh Watershed Conference; and,
followed up this contact with a letter dated September 20, 1968.

Arthur L. Wiesenberger had two motives behind his communication.

First, he sought from Daddona a firm and unequivocal commitment of the 1.7-
mgd reserve capacity already promised. And second, he wanted Daddona to
provide his continuing assistance in facilitating an additional 2.8 million gallons
per day capacity for Wiesenberger's client municipalities.

THE STRATEGY

Wiesenberger's strategy was to underscore the urgency of the first motive --
that is, the necessity to reach a definitive agreement on allocations so as to
allow the Little Lehigh Watershed Sewer Complex to go to bid on schedule.
Secondly, Wiesenberger focused on the impending industrial development
projects in the industrial park of Upper Macungie Township.

He maintained that the 1.7-mgd per day promised allocation would be sufficient
only until 1972 when the Kraft Food and Schaefer Brewing projects would begin
sending effluent into the Allentown Metropolitan Wastewater System. After that,
an additional 2.8-mgd allocation would be required.

EXPANSION NEEDED AGAIN

Metcalf & Eddy, the engineering consultant for Allentown, informed
Wiesenberger that such additional allocation would ultimately require further
expansion of the Kline's Island Wastewater Treatment Plant above and beyond
what capacity was already planned and under construction. Especially when
the needs of all customers of the Metropolitan Wastewater Treatment District
was considered.

Wiesenberger in his letter of September 20, 1968 duly informed Joe Daddona,
the Allentown Director of Streets and Public Improvements, of this fact.

DADDONA'S RESPONSE

Joe Daddona in response wrote September 24, 1968; "We (Mayor and Council)
as you know are well aware of the benefits to all concerned that can be derived
through a "Little Lehigh Watershed Sewer Complex." We are already cognizant
of the great potential impact on our area of the proposed industry in Upper
Macungie Township. Therefore, we shall do whatever we can to cooperate and
assist in effort to resolve the problems inherent in such a venture."

Importantly --- Daddona's response did in fact concur with the position of
Allentown Mayor Ray B. Bracy. Please note --- Bracy in public comments made
September 18, 1968 before the Lehigh County Board of County Commissioners
stated: "That what is good for the County is good for the City, new industries,
new jobs are good for the entire local economy."

A CRITIQUE

Sadly, for Joe Daddona the problems inherent in such a venture were not just
administrative but were technical as well.

The tie-in of industrial wastewater from western Lehigh County into the
Allentown wastewater disposal system eventually presented problems.
Problems that former City Engineer Earle Meckley anticipated in 1957 when he
opposed the move to introduce industrial waste into a system designed
primarily for residential usage. Meckley was convinced that steps would have to
be taken to neutralize and equalize the waste before any connection would be
allowed with the disposal system. It was his concern that the waste might
contain properties that would cause harm to either the sanitary system of
interceptors, the disposal plant or both.

Another statement in regard to what is and what might have been prevented
comes from Ray Snyder, the General Manager of the Lehigh County Authority.

Ray Snyder said that the City in 1976 should have been more involved in the
negotiations that led to the County agreement to pre-treat the effluent from Kraft
Foods and Schaefer Brewery in 1969.

We believe this statement delineates the fact that the City with Joe Daddona as
both City Councilman and Streets and Public Improvements Director did not
pay attention to the special BOD's and Suspended Solids of the wastewater
characteristics and loadings that would enter the Allentown system in decision-
making that allowed the proposed industries in Upper Macungie Township to
tie-in into the Allentown system.

Because of this, whatever benefits the region and the city accrued because of
the location of huge and vital industries in the area was tempered by the
enhancement of unpleasant gases or vapors in neighborhoods and
communities surrounding the metropolitan wastewater treatment plant.

In other words, the newly created metropolitan wastewater disposal system
located on a major water artery, in a district which for most part was and still is
densely populated, and which also routinely discharged unpleasant gases or
vapors into the air of this surrounding community could not help but be
noticed; and what is more, the surrounding public would demand that steps be
taken to alleviate these conditions, and that such disorders could only be
resolved through extensive expenditures even if the work was performed
correctly,

THE NATURE

We shall end the PREFACE INSTALLMENT OF PART THREE with a discussion
of the possible nature of the unpleasant gaseous odor or vapor problem.

Compounds that create odors in wastewater may be broadly classified as either
inorganic or organic. Inorganic gases or vapors are produced through the
action of extremely small sized living organisms more commonly known as
microbiological activity. The organic vapors not only are produced by the
microbiological activity but also are added directly to the wastewater by
discharge of organic chemicals by various interests.

Of inorganic gases produced by microbiological activity only ammonia and
hydrogen sulfide are bad smelling gases.

Those organic chemicals added to wastewater by industries that might emit
malodorous gases include alcohols, aldyhydes, amines, ethers and sulfides.
Additionally, industries may also discharge acids or alkalides to the wastewater,
which might cause a shift in the chemical balance and cause the release of
odors.

INSTALLMENT ONE

.... The Decision to Expand Capacity ....

When the Boston Engineering firm of Metcalf & Eddy, Inc. worked with former
Allentown City Engineer Earle W. Meckley in planing of the Kline's Island
Wastewater Treatment Plant in 1929, design specifications were written to
service a population of 128,000 or in flow values treat an average 17.3 million
gallons of raw sewage a day. As early as 1963, the Kline's Island plant was
approaching capacity. In addition to Allentown's 110,000 residents, sewage was
processed from Emmaus, which had a population of 11,000 and from parts of
Salisbury and South Whitehall Township.

On February 20, 1963, the Allentown City Council and the Allentown (Public
Works) Authority passed resolutions authorizing a feasibility study for the
expansion of the sewage disposal plant at Kline's Island. The Boston
engineering firm of Metcalf & Eddy was named to conduct the study.

The action was taken in anticipation of further possible requests for wastewater
treatment service by outlaying communities.

The feasibility study would determine whether a regional authority would be
formed to take over the sewer system and to install new facilities or whether this
responsibility would remain with Allentown.

The latter position being the one that Councilman Lloyd E. Grammes, the head
of the Allentown Sewer Bureau, interestingly preferred.

He said: " We'd got the land in Allentown, loads of it on Kline's Island, and the
existing plant can be duplicated. It was decided in 1929 with the view toward
expansion. There's no reason why we shouldn't reach amicable agreements
(with other communities) - preliminary at this point --- on getting together.
They'd build and own their own collection sewers. We'd process the sewage at
a central point.

... A Change in Viewpoint ...

We add that the above statement by Grammes seemingly represents a change
in position from what his attitude was when the Emmaus wastewater treatment
tie-in was debated by City Council. Grammes at that time was concerned about
what additional tie-in requests the Emmaus tie-in would stimulate and the
financial cost these tie-in requests would incur for the City for necessary
expansion projects.

We ask - Why did Grammes' position seemingly change? We can only suggest
that such change of attitude be induced by public comments of John P. Durr.
The idea of a regional sewerage system with Kline's Island as the site for a
central sewerage disposal plant was advanced by John P. Durr, regional
director for the state sanitary water board at a special meeting of regional
government units sponsored by the Joint Planning Commission, Lehigh ---
Northampton Counties in the Lehigh Valley Dairy Auditorium March 27, 1962.
And this idea was again pushed by John P. Durr at a gathering of ten
subdivisions held February 26, 1963 in the community room of the First National
Bank.

... Application for federal subsidization ...

Allentown which had authorized Metcalf & Eddy to conduct a feasibility study
aimed at the eventual expansion of its Kline's Island Wastewater Treatment
Plant wanted firm commitments from the communities represented of their
willingness to participate in an area sewage collection and disposal system.

Allentown was especially concerned because it planned to apply to the federal
government for funding authorized by the Water Pollution Control Act of 1956
(also known as the " Clean Water Act"). The Clean Water Act established a
relatively small $50 million construction grant program to assist communities
with treatment systems needs.

... Odors once produced present great problems for elimination ...

Allentown's project design was aimed more toward increasing wastewater
capacity and meeting federal government specks for clean air instead of
seeking to maintain the chemical balance of wastewater at all times.
Consequently, environmental problems related to odor emerged in 1968 after
the newly expanded 28.5-mgd wastewater treatment plant went on line. These
odors once produced presented great problems for elimination; consequently
specialists in the field are quick to stress that wastewater treatment is an
experimental art not a science. Experimental is of course defined as a process
in which a plausible solution is found through trial and error. However, we can
also assume that such assertions provide easy excuses for work inadequately
performed and also, it could mean that the so-called experts are weak in the
understanding of the fundamentals of odor production and control.

Michael H. Gerardi, the manager of the wastewater division for the Williamsport
Sanitary Authority writes in the January-February 1983 issue of the Water
Pollution Control Association of Pennsylvania Magazine:

" The control of wastewater odors by physical, chemical, and biological
measures has been explored endlessly and various combinations of control
measures have been tried at one time or another. Still many plants remain
subject to the most complex mixture of odors. There is no easy solution for
odor problems. Although some of a wastewater facility's odor problem can be
anticipated and eliminated in collection system and treatment design, much
(odors) is due to a weak understanding of the fundamentals of odor production
control."

According to Gerardi, Hydrogen Sulfide (H2S) is probably the most destructive
malodorous gas produced from wastewater degradation. Being a gas,
hydrogen sulfide may be released into the atmosphere by wastewater
turbulence such as a change in the direction of flow causing a "rotten egg
smell" or it may remain dissolved in wastewater.

In wastewater the breakdown of hydrogen sulfide into sulfuric acid (H2S04) can
corrode and weaken cement or concrete. In the atmosphere a 30-minute
exposure to hydrogen sulfide at 0.1 percent concentration by volume can prove
fatal. In small concentrations it can cause nausea.

Hydrogen Sulfide production rates are enhanced by high temperature, low pH’s,
high sulfide concentrations, slow velocity of sewage, strong sewage strengths,
the presence of anaerobic conditions, and long detention time of wastewater
handling.

INSTALLMENT TWO

... A regional solution is needed

The November 1980 Allentown-Lehigh County Greater Community Council
Sewerage Task Force report " Analysis of the Issues and Recommendations"
summarized:

" The sewerage problem is the greatest individual conflict confronting Lehigh
County's urban-suburban integrity. The resolution of this issue is key to many
other physical, social, and economic matters having regional significance. A
long term regional solution is needed to resolve the present sewage treatment
capacity impasse and the future provision of facilities and capacity."

How true are these sentiments! They are especially true when tied together with
the water resources and waste management issues. Nevertheless we question
whether our public officials, past or present, really understand the nature of
these problems or are really free of controlling forces that would allow them to
make decisions that would clearly be of long-range benefit not just to Allentown
but to the Lehigh Valley Region.

... The catharsis of subclinical historic error

On February 20, 1963, the Allentown City Council and the Allentown (Public
Works) Authority passed resolutions authorizing a feasibility study for the
expansion of the sewage disposal plant at Kline's Island. The Boston
engineering firm of Metcalf & Eddy was named to conduct the study.

The action came a few days prior to a February meeting arranged by the City of
Allentown to discuss the establishment of a regional wastewater treatment
system.

During on-going negotiations with Emmaus (1956-59), Allentown's
determination to maintain title and ownership in both its existing treatment plant
and its principal intercepting sewers that extended more or less radically from
the treatment plant to points ranging outward but within city limits (Little Lehigh
Lower 1 and 2 --- 10,000 feet long and consists of 5,350 feet of 30 inch pipe and
4,650 feet of 36 inch pipe; Jordan Creek Interceptor --- 3,150 feet; Trout Creek
Interceptor --- 6,550 feet) proved a fatal final obstacle to the establishment of a
Joint Authority with Emmaus. Regretfully the price the city paid for the
establishment of a proprietor-customer relationship with Emmaus opened the
door for additional suburban demands and additional problems. This catharsis
of subclinical historic error brought upon Allentown's Kline's Island Wastewater
Treatment facility the status of being a public utility. Henceforth, Allentown had
to abide by state Public Utility Commission regulations. As a consequence,
Allentown became obligated to meet the demands of suburban political units for
service as long as adequate reserve capacity existed. This the repercussion of
precedent established by the Emmaus-Allentown Wastewater Treatment
Agreement of 1959

...It will cost millions

Allentown Councilman Lloyd Grammes disliked initially the idea of opening the
doors of Allentown's wastewater service to outsiders. (That’s "Auslanders" in
German folks) He commented: " Once that starts Allentown will be forced to
continually expand the facilities of its Kline's Island disposal plant. We'll be
spending a million dollars before we know it."

How true Grammes' fears turned to reality! Nevertheless, Grammes along with
the other members of Council share responsibility for what happened because
Grammes seemingly changed gears and became a promoter of official policy,
which facilitated customer basis service to outside political subunits.

The idea of a regional sewerage system, with Kline's Island as the site for a
central disposal plant was discussed March 25, 1962 at a special meeting in the
former Lehigh Valley Dairy Auditorium located at 7th Street/MacArthur Road in
Whitehall Township. Advocated by John P. Durr, Regional Director for the
Pennsylvania State Sanitary Water Board, the meeting was a catalyst for
continuing Allentown activity toward expansion of plant capacity.

Allentown Mayor John T. Gross opened a February 26, 1963 meeting of area
political subdivisions at the First National Bank located at the Northeast corner
of 7th & Hamilton Street in Allentown with a call for action: " I feel that at long
last we're making progress in the matter of providing sewerage for the drainage
areas of Allentown and vicinity. We reached the time when we should get down
to specifics."

Nine area political subdivisions were asked that evening to give firm
commitments in short order on their willingness to participate in a regional
sewer and collector system.

Allentown, the 10th community, wanted such commitments so that it would be
able to apply to the federal government, under public law 660, for financial aid in
building a new wastewater treatment plant. The plant would be constructed on
Kline's Island, on the banks of the Lehigh River.

Five of the nine outside communities (that is, Whitehall, South Whitehall and
Salisbury Townships and Macungie and Coplay Boroughs) had already filed
notices of intent on Allentown, expressing a desire to be part of a regional
system.

Allentown with the expressed goal of protecting its water resources from
pollution also requested that Upper and Lower Macungie and Upper Milford
Townships and Alburtis Borough participate in the program as well.

... Local resolutions and commitments required

Lloyd E. Grammes told this gathering of public officials that local resolutions
and commitments were required within the month sot that Metcalf & Eddy,
Boston Consulting Engineers for the City of Allentown, would be able to
complete a feasibility study by the May of that year. If accomplished, contract
specifications would be prepared by February 1964 and federal approval could
be had by April 1964. The aim, he said, was to award construction contacts for
the new wastewater treatment plant no later than June 1964. Target date for
completion was to be a time frame somewhere between December 1965 and
June 1966.

Interestingly, construction was not actually completed until 1968 when Joseph
S. Daddona assumed the Allentown Department post of Streets and Public
Improvements. Why? It is quite possible that the Metcalf & Eddy feasibility study
did not at first consider the perceived potential requirements of the four invited
municipalities and had to be reworked. Additionally, Allentown in 1965 and 1966
had been caught up in a movement to change its governance.

Other then the stated reasons, why then were Upper and Lower Macungie and
Upper Milford Townships and Alburtis Borough invited? May we suggest to
sweeten Allentown's application for federal grant money. And historically, this
invitation may account for the delay in final construction of the plant for the
federal government may have required a better accounting of the wastewater
needs of the four municipalities before releasing any federal grant money to
Allentown

Significant too was Allentown's decision to promote the use of its wastewater
facility as the hub of regional wastewater treatment processing. Allentown
officials perhaps thought it better to seek clients all at once by its own initiative
rather to wait for wastewater treatment requests periodically down the road.
Allentown indeed had recognized that it opened the Pandora's Box when it
made its wastewater agreement with Emmaus.

City officials made it clear that each participating unit would install its own
interceptor line and would have local control over its own collector system. The
only joint operation would be the disposal plant, which would be owned by
Allentown, which would finance operations and amortize debt through sewer
rentals.

In the interim between plant construction and the plant being on line the
participants were advised by state official John P. Durr to develop plans for
installing sewage collection systems, so they'll be ready to hook up when the
disposal plant was ready.

On May 14, 1963, the Allentown City Council formally resolved "that the City of
Allentown, as the operator under a lease agreement with the Allentown
Authority, intends to accept into its sanitary sewage system, for handling the
treatment, sewage from the following municipalities and townships or parts
thereof which have or may signify their interest in such arrangements: Whitehall
Township, Coplay Borough, South Whitehall Township, Salisbury Township,
Upper Macungie Township, Lower Macungie Township, Emmaus Borough,
Alburtis Borough, Upper Milford Township, Hanover Township, Macungie
Borough. Contingent upon a mutually satisfactory agreement negotiated as to
method and payment of such service:

... Feasibility Study

Metcalf and Eddy's Feasibility Report on Sewage Treatment Plant Enlargement
and Appurtenant Interceptor Relief was received by Lloyd Grammes, the
Allentown Director of Streets and Public Improvements, April 29, 1963.

The purpose of the report was to determine the feasibility of enlarging the City
of Allentown's Sewage Treatment Plant located on Kline's Island and
constructing required principal relief interceptors in order to permit treatment at
the Kline's Island facility of sewage wastes that originated in Allentown and
certain surrounding townships and boroughs.

The report used much of the data contained in an earlier report of January 5,
1961, but added to it by extensively investigating the concept or engineering
model of extending sewage treatment to communities outside the city limits of
Allentown. (1961 being the year that Emmaus wastewater began to be
processed by Allentown.) The weakness of the report being that its
investigation was limited in scope to the townships and boroughs that had filled
their notice of intent to have their wastewater processes and treated in
Allentown. Thus, the field of investigation or engineering model being limited to
Coplay and Macungie Boroughs, and Whitehall, South Whitehall and Salisbury
Townships.

Please note --- The important findings of the report are:

1. Allentown's principal interceptors have sufficient capacity to handle sewage
flows from the City and certain townships and boroughs for several years, but
in the future, relief interceptors will be required for certain reaches of the Little
Lehigh Interceptor, Jordan Creek Interceptor, and Trout Creek Interceptor as a
result of discharge of sewage of surrounding townships and boroughs into the
Allentown system. Costs of the relief interceptors should be shared
proportionately between users on the basis of allocated design flows.

Table II - Basic Design Data for Relief Interceptor Construction
___________________________________________________
Name                                Size       Length    Design          Approximate
                                  Inches   Feet        Capacity       Year
                                                                                      Required

Little Lehigh Interceptor         30          10,000          10.6          1970
Relief (Lower 1 and 2)

Jordan Creek Interceptor       24            3,150            6.1          1980
Relief (Lower 1)

Trout Creek Interceptor         18             6550           4             1990
Relief (Lower 1)

______________________________________________________________

2. If the municipalities designated herein elect to participate, the existing sewage
treatment plant at Kline's Island should be enlarged to a capacity of about 27.3
mgd (million gallons per day) and the cost of this enlargement should be shared
proportionately between the users again on the basis of allocated design flow


TABLE III - Sewage Treatment Plant --- Basis of Design Average Flow 1990
_____________________________________________________________
Municipality          population        Connected  Ave.        Expansion, mgd
                                                   Flow  Allocated flow
                                                 mgd   Based on 10mgd
______________________________________________________________

Allentown                        113,000                  19.36                       19.42
Coplay Borough                  4,100 *                 0.41                        0.42
Emmaus Borough              14,200                    1.42                        1.47
Macungie Borough              1,700                    0.17                        0.18
Salisbury Township            13,600                   1.36                        1.41
South Whitehall Township  23,600                   2.36                        2.44
Whitehall Township            19,000 *                1.9                          1.96
Totals                              189,200                  26.98                        27.3

* From letter to Lloyd E. Grammes, Director, Dept. of Streets and Public
Improvements, City of Allentown, from A.L. Wiesenberger Associates, Inc.,
Consultants for Township of Whitehall and Borough of Coplay, dated March 30,
1962

3. An increase of 25 percent in Allentown's sewer rental rates will be requested
to cover the City's portion of the cost of the treatment plant enlargement and
interceptor relief.

INSTALLMENT THREE

Currently, the City of Allentown meets its daily water needs and the needs of its
suburban subscribers by tapping into the surface waters of the Little Lehigh
Creek and other water sources such as the Crystal Spring and Schantz Spring
whose aquifers are underlain primarily by carbonate rock. Additionally, as a
reserve, the City of Allentown can tap into the Lehigh River.

Historically, the development of hydrologic features such as springs, solution
sinks, disappearing streams, artesian groundwater conditions, deep soils,
saprolite and large volumes of groundwater in storage being the end result of
extensive faulting, folding and fracturing of carbonate rock, together with the
fact that annual precipitation in the region normally exceeds natural losses by
evaporation.

The data from the drought of 1999 is not fully in yet, but if past data is of any
indication, Allentown has been extremely fortunate that even in years that
nature has turned off its spicket the Little Lehigh Creek, Crystal Spring and
Schantz Spring were still reliable sources of water for Allentown.

Despite past data, we found it very interesting that the second Daddona
Administration (1982-1985) achieved its goal of constructing a water intake line
in the Lehigh River to supply the regular or emergency water supply needs of
Allentown and its suburban subscribers.

The line was not needed at the time, but I guess redundancy is worthwhile to
protect against worst case scenarios in the future. Perhaps the not finished
drought of 1999 providing a test case for those whom thought the Lehigh River
adventure a wasteful monetary folly.

... Such talk is wearisome

At the time Harry Forker and myself were very skeptical about the Daddona
Administration fast track plans concerning the Lehigh River. Harry Forker
believing the time had not yet arrived to tap the Lehigh River. Even in 1999, the
Lehigh River intake's main use is for shakedown practice runs rather then
normal day to day operations.

When such plans were formulated, our position was that such talk was
wearisome for historically we have heard all this before. What has been
proposed before has been proposed again.

Truly we realized that everything has its season ----- A time to seemingly
develop new ideas or schemes ... A time to court community acceptance ... And
finally, a time to put new ideas or schemes into implementation.

But let us emphasize that this path towards fulfillment of the cycle is hardly
easy. In between is a series of battles, retreats, cease-fires, regroupings and
renewal of contention; and this too is not new under the sun.

Let us review the classic battle to place fluoride into Allentown's drinking water.

Since the 1950's, Allentown has been divided on whether to add fluoride to its
drinking water supply or not. Over the years, many Lehigh Valley region
communities have elected to do so. However Allentown up to 1999 has been a
major hold out Over the years, many arguments have been made for and
against placing Fluoride into Allentown's drinking water during city electoral
battles and at City Council. In 1999, City Council voted to fluoridate Allentown
water. Opponents say the battle is not over.

No one knows whether this current round of action will satisfy the desired ends
of the elected and appointed officials involved in such decision determination;
but we do know that severe conditions of drought' joblessness, and
additionally, public health and safety concerns provide opportunities for
decision-makers to push their master plan which ironically can serve to further
exaggerate or exacerbate the problem.

Thus far, in our study of the decision-making that has led to the planned or
unanticipated destruction of the character of the Lehigh Valley's landscape
from largely rural to urban sprawl in the name of an ideal called Megalopolis, we
have amassed a great wealth of information. We have appointed our minds to
understand wisdom and knowledge, madness and folly, and like King Davis in
Eccleasiastes we have come to see that this can be very difficult. For in wisdom
is much vexation; and it follows that the more a man knows, the more he tends
to suffer in light of that knowledge.

... A supply that will be yours

At this point we think it appropriate to interpret the significance or meaning of
Allentown solicitor Bernard Naef's comments made February 26, 1963 at a
meeting called by the City of Allentown of regional political units.

Allentown, characteristically, sought to receive the cooperation of its suburban
neighbors in procuring $2.4 million from the federal government, or thirty
percent of the cost of constructing a regional sewage disposal system. The
financial aid was dependent upon filing application prior to 1965 and federal
approval of all plans.

Attorney Naef was questioned as to Allentown's motive by a delegation from
South Whitehall Township that included Harley S. Frantz, chairman of the
township supervisors and Attorney Robert V. Ritter, township solicitor. South
Whitehall's aim was to verify or disprove speculation that Allentown was using
the expansion of its wastewater treatment system as a "scheme to induce
annexations." The position of South Whitehall naturally being that the Allentown
program ought to be "an open door program, available to everyone."

Naef responded that every resident of every township could be served,
provided each township established a collection system to reach all residents,
and all properties were connected. Then defended Allentown's position with the
response: "Allentown's only interest in this is the protection of its water supply
--- a supply that will probably be your water supply, some day."

This last response of Naef presents interesting speculation in itself especially
relating to the statements: "A supply that will probably be your water supply,
some day."

What did Naef mean by that? Did he mean that South Whitehall would share in
this water supply as a result of its participation in the regional system? This
makes sense for purposes of preservation of Allentown's water supply.

Or, did he mean that Allentown one day would abandon or ceded its proven
water resources to the townships as they become economically more
developed? The consequence being that Allentown had to look for new water
sources to replace the old.

From our prospective, we prefer to think that the former case was the actual
intent of Naef's statement. But in a region influenced by growth interests who
may or may care about Allentown's position in the new status quo, we dare not
dismiss the latter.

... Riparian rights are subject to constant change

A discussion relating to the riparian rights doctrine may add additional meaning
to Naef's statement presented above.

R. Timothy Westin, Associate Deputy Secretary for Resources Management of
the Pennsylvania Department of Environmental Resources in testimony dated
August 13, 1981 relating to a proposed Water Resources Management Code for
the State of Pennsylvania maintained:

" Use of waters in streams and lakes is governed by the riparian rights doctrine.
Owners of lands bordering watercourses may withdraw and use water on their
riparian lands. Waters drawn from streams may only be used on riparian lands
adjoining the watercourses. Unlimited withdrawals are allowed for domestic
(drinking, bathing and livestock) purposes, but diversions for irrigation,
industrial and other uses are restricted to "reasonable" amount which do
materially diminish streamflow or affect downstream uses. It should be
emphasized, however, that riparian owners gain no right to use a subject
quantity of water for a given period. Riparian owners are subject to constant
change depending on competing needs and other development in the
watershed."

"While use of the rare "subterranean" stream may be subject to riparian
doctrines, withdrawals from percolating ground water are governed by
drastically different rules. Pennsylvania common law permits a landowner to
withdraw ground water beneath his land for "natural and ordinary" uses located
on that land regardless of the consequences to his neighbors. Included within
the term "natural and ordinary" uses are virtually all economic enterprises,
including domestic water use, mining, irrigation and manufacturing. Thus as
late as 1957 the Pennsylvania Courts ruled a mine operator could dewater and
lower water tables throughout a valley with no responsibility for injuries to
owners of domestic wells whose water supply was thereby cut off. Liability can
only arise where the withdrawal is malicious or negligent, and causes
foreseeable harm to adjacent lands. However, withdrawals to uses off the land
containing the well --- such as public water supply in a nearby community --- are
considered "Unreasonable" and "Unlawful;" liability for damages will be
imposed if the withdrawal interferes with other users."

"... The Commonwealth's current authority to regulate water allocations is
extremely narrow and fragmented. The Department of Environmental
Resources, under the 1939 Water Rights Act, only oversees withdrawals from
springs, lakes and streams by public water supply entities. Public water supply
diversions only account for nine percent of the total withdrawals from
Pennsylvania surface waters. These diversions are relatively nonconsumptive,
with approximately 90 percent of waters taken being returned through public
sewage systems. The largest consumptive water uses, including manufacturing
and power takings, are not subject to regulation. Moreover, groundwater
withdrawals are not covered by any existing State regulatory program.

... Water sources for the future

For years, Allentown's water resources were indeed adequate. From Schantz
Spring and Crystal Spring and the Little Lehigh Creek flowed sufficient water to
meet the needs of a growing city. Indeed, this water supply not considering
water quality was just as adequate in 1986 as it was in 1963. These water
resources during periods of minimum flow being capable of producing an
estimated 42 million gallons per day, with the Little Lehigh Creek being available
for 33 million gallons and two springs --- Crystal and Schantz at their nadir still
capable of providing a combined flow of at least nine million gallons per day.

Interestingly, as reported by Dames & Moore July 8, 1985 to James M.
Montgomery Engineering Consultants, Schantz Spring alone has the capacity
of producing a total flow of 8.2 million gallons per day.

Then too, important insurance in regard to the continuation of Allentown water
service to the public is provided by two enclosed concrete reservoirs having
combined storage capacity of 40 million gallons per day. The South Mountain
and East Side reservoirs having been constructed by the City of Allentown in
1937.

Statistically, normal daily consumption in 1963 was 21 million gallons. However,
during heat waves and other occasions the demand could be higher. The
impact being that the system could come close to pumping capacity, which
differs from distribution capacity. During a two day period in 1963 the city's
consumption exceeded 37 million gallons, requiring pumping in excess of 38
million gallons. But importantly --- it should be noted, however, that included in
these 1963 consumption data was water used to replenish depleted reservoir
storage reserves. The Allentown filtration plant graded capacity being 30 mgd
but could exceed 40 mgd with the use of unfiltered spring water when proper
conditions prevail.

Allentown had experienced record drought conditions between 1962 and 1966.
Interestingly, as early as 1962 Allentown showed an interest to study its present
and future water requirements. Morris Knowles, Inc. of Pittsburgh being
authorized by the Allentown City Council in February of 1962 by Resolution
Number 18892 to prepare a report pertaining to the same. Initially such interest
had more to do with the push effect of the Joint Planning Commission, Lehigh
--- Northampton Counties' emphasis on water supply and possible economic
development then realization of drought conditions. But the length and severity
of drought conditions became useful tools to solicit public support.

Morris Knowles examined both the Jordan Creek and the Lehigh River as
sources of future supply and settled on the river as the most feasible because
of economies in pumping. The Jordan is known to disappear into underground
crevices and otherwise run dry at some points. Even with the construction of
the controversial Trexler Dam, an intake for pumping would have to be situated
in the vicinity of Guthville, where the stream's behavior is said to be most
reliable. The Lehigh River, in contrast, could be tapped in the heart of the city, in
the vicinity of Hamilton Street. The river, with its Francis Walter Dam on Bear
Creek and the Corps of Engineers project dam at Beltzville and Aquashicola
(never built) would have the most reliable flow. Additionally, water sample tests
made in the course of the study demonstrated that the river's turbidity to be less
than either the Jordan's or the Little Lehigh's, thus the treatment of its waters for
public consumption would be more cost-effective.

(Please note - in 1984 citizen activist Harrison E. Forker raised a question
whether the turbidity findings of Morris Knowles as detailed in its 1964 report
remain accurate)

Importantly, Morris Knowles in its "Report Upon Future Water Requirements ---
1964" delivered to the City of Allentown, Department of Parks and Public
Property, Bureau of Water estimated that $24 million would be needed to
expand the Allentown system to accommodate future water supply needs.
Expenditures would include:

1. The cost of construction for a suggested Huckleberry Ridge Reservoir in
South Whitehall Township and a force main leading to the same;
2. The cost of construction to upgrade processing capacity at the Allentown
Filter Plant an additional 30 million gallons per day;
3. The cost of construction of both a Lehigh River water intake and a Lehigh
River pumping station to allow for City of Allentown water withdrawals from the
Lehigh River;
4. The cost of construction for the laying of a raw water force main from the
Lehigh River Pump Station to the Filter Plant Area as required by point three;
And finally, 5. The cost of construction for the development of additional
distribution and storage facilities as envisioned within the next half century.

... A peculiarity of the Lehigh River

In making it suggestions, however, Morris Knowles apparently did not consider
the special status of the Lehigh River. A peculiarity of the Lehigh River was that
it was the only known river in the United States privately owned. Thus the
Lehigh (Valley) Coal & Navigation Company owned rights to its water supply
and that of its tributaries as well. Additionally the company owned all islands in
the river except Adams Island, which formerly was part of the mainland until the
canal was cut in back of it.

It is important to note that this special status first granted by the Commonwealth
of Pennsylvania to three private individuals ( Josiah White, George F.A. Hauto,
and Erskine Hazard, all of Philadelphia ) in 1818 and transferred to the Lehigh
Valley Coal & Navigation Company in 18222 had to be overcome before
Allentown could legally go to the Lehigh River as a water source.

In May of 1963, Allentown Councilman Samuel Fenstermacher, Park
Commissioner, announced a plan by which Allentown might buy the Lehigh
Canal within city limits and join with Bethlehem and Easton as an inter-city
project. One proviso, however, was very important. Included with the sale of the
Lehigh Canal from the Lehigh (Valley) Coal & Navigation Company must be the
right to withdrawal water from the Lehigh River or its basin in event of future
water emergencies affecting the Allentown water supply. The plan had the full
acceptance of the Allentown Chamber of Commerce and the Joint Planning
Commission, Lehigh --- Northampton Counties.

Fenstermacher expressed the hope that the canal once restored would become
a tourist attraction in addition to becoming a park for boating and other sporting
activities. Charles H. Naef in a Sunday Call-Chronicle article dated July 23, 1963
stated

" Restoring the Lehigh Canal as visioned by the boaters would provide the
Lehigh Valley with a cruising outlet to the Inland Sea which skirts the Atlantic
from Florida northwest through Long Island Sound and going in the Cape Cod
Canal into Boston."

Pleasure boaters from any of the lower Lehigh River marinas could move on a
vacation cruise to Florida if they wished. With home bases here in the valley an
entirely new industry could be born. Maintaining and repairing pleasure craft,
some of which are now housed in the Chesapeake Bay or New Jersey coast,
could be done here under closer supervision of boat owners."

(Note --- From Boston boaters could go into the Gulf of Maine to Nova Scotia
and set sail into the Gulf of St. Lawrence and the river by the same name to
Montreal. From Montreal boaters could transverse the Great Lakes via the St.
Lawrence Seaway.)

Morris Knowles, Allentown's water consultant, estimated that Allentown's
system ultimately would serve a population of 242,000 by the year 2020
compared to 115,000 in 1965. Therefore, on the advice of its consultant,
Allentown during the summer of 1963 mad application to the State Forest and
Waters Department headed by Dr. M. Goddard to reserve for Allentown a daily
water allotment up to 70 million gallons from two possible sources. If approved,
the effect would be the tripling of Allentown's available water supply. The
application called for an allotment of 40 to 50 million gallons from the Lehigh
River and 20 million gallons from the Jordan Creek --- if and when the proposed
Trexler Dam was constructed and a steady flow in the Jordan assured.

We note --- this action was taken by the City of Allentown before agreement of
land sale or agreement of water withdrawal rights received the tacit approval of
the Lehigh Valley Coal & Navigation Company. To us this action seemed rather
unethical and rather high-handed, an arrogant display of government power.

Allentown's push also extended to the state legislature. State representative
Sammuel W. Frank with the assistance of the Legislative Reference Bureau
initiated legislation February 24, 1965 designed to repeal the special status
granted to the Lehigh Valley Coal & Navigation Company by the
Commonwealth in 1822 so as to return ownership of the Lehigh River to the
Commonwealth. The action, in effect, would further pave the way for Allentown
receiving rights to withdrawal water from the Lehigh River. In his efforts, Frank
claimed the support of area sportsmen and boaters (Examples being --- the
Lehigh County Federation of Sportsmen's Clubs and Frick Boat Club,
Allentown). As expected, Frank also noted support from area Chambers of
Commerce and industry.

INSTALLMENT FOUR









In 1961 the Federal government and the states of Delaware, Pennsylvania, New
Jersey, and New York agreed to form a partnership in a 100-year building
program under the supervision of the Delaware River Basin Commission. This
so-called Delaware River Basin Compact sought the utilization and
development of the water resources of the Delaware River basin. Consequently,
numerous dams and reservoirs furnishing hydroelectricity flood control, and
water conservation on the Delaware River or tributaries were planned.
Additionally, this planning also provided for the development of new recreation
areas and wildlife refuges. Of importance for the Delaware River, a minimum
flow rate was established to prevent saltwater intrusion in the lower river.

Of much interest and concern to the citizens of the Lehigh Valley, the proposed
Trexler Dam became entangled in this planning process.

The project as advanced by the U.S Army Corps of Engineers for water
resources of the Delaware River Basin in December, 1960, and revised May
1961, called for the construction of a proposed concrete dam to be located in
the Trexler Game Preserve in Lowhill Township. The dam would be located
about one-half mile from the mouth of Mill Creek and approximately eight miles
northeast of Allentown.

The drainage area of the Jordan Creek above this site is approximately forty-
one square miles. The proposed dam was to be a concrete gravity type
structure approximately 800 feet long, with a rise of 120 feed above the Creek
bed. The reservoir at the spillway elevation of 492 would extend about eight
miles up the Jordan Creek with various bays and prongs extending about three
miles up Lyon Creek and about two miles up Mill Creek. The long-term storage
elevation was indicated to be 479 and at that elevation 24,000-acre feet or 7,885
million gallons of active long-term storage was estimated to be available.
Importantly, at the elevation of 479, estimated to provide 24,200 feet of active
long-term storage, a net yield of approximately 55 cubic feet per second or a
flow of 35.5 million gallons per day would be provided.

Please note --- The Trexler Dam project was deauthorized by the U.S. Congress
in 1984, many years after citizen opposition to the project seemingly forced
abandonment of plans to pursue the project.

The fact is, Henry C Messinger, Pennsylvania State Senator - Lehigh County
expressed surprise in a letter dated November 5, 1979 to Mr. Clifford H.
McConnell, Deputy Secretary of the Office of Resources Management in the
Department of Environmental that the Delaware River Basin Commission Level
B Study had retained Trexler Dam for possible inclusion in the new DRBC
Comprehensive plan.

Stated Messinger:

" I most strongly recommend that you do everything within your power, as
Pennsylvania's representative on the DRBC, to have Trexler Dam deleted from
the comprehensive plan."

Referring to an earlier advisory referendum, Messinger continued:

" I most strongly recommend that you do everything within your power, as
Pennsylvania's representative on the DRBC, to have Trexler Dam deleted from
the comprehensive plan.

Any proposal to retain Trexler Dam in the DRBC comprehensive plan is in direct
conflict to the expressed will of the citizens of Lehigh County and many of their
elected officials at the local, state and federal levels.

The results of the 1977 advisory referendum, in which Lehigh County residents
voted 3 to 1 against construction of the Dam, cannot and must not be ignored."

In earlier public testimony dated June 1, 1979 in regard to the Level B Process,
J. Bruce Mordaunt, as President of the Northwestern Lehigh Citizens Coalition,
wrote to Mr. David Longmaid, Manager of Level 'B' Study Delaware River Basin
Commission concerning a Preliminary Draft Report of the DRBC which as
Messinger had indicated included comment concerning the construction of the
Trexler Dam.

" The Northwestern Lehigh Citizens Coalition wishes to thank the entire Level
"B" Study staff for their effort and diligence in obtaining public input throughout
the entire study. We trust the final plan adopted by the Commission will reflect
those concerns, which will result in the greatest good for the greatest number.

The Coalition will not comment on the Preliminary Draft Report on an item-by-
item basis, but offers the following general comments for your consideration in
preparing the final draft of the study.

The Delaware River Basin is an extremely diverse area, from the rural and
forested northern area to the densely populated and industrialized southern
portion. Each area has different needs, concerns, and problems, which should
be solved at the most local level possible.

The northern area, now widely used for recreation and food production, must
be maintained for these purposes. The long term ability and skill to produce
food must not be sacrificed for the short-term goal of providing a few additional
industrial jobs. Fairly local food sources must be maintained near large
metropolitan centers to reduce energy consumed in transportation, and to
diminish the effects of flood, drought, plant disease or insect damage in various
geographical areas. Preservation of the farm and forestland will reduce flood
possibilities and damages by absorbing precipitation. This will prevent rapid
run-off and flash flooding while recharging underground aquifers.

Prudent long range planning dictates that no more farmland be destroyed for
industrial construction because the most sophisticated machines in the world
will never produce an egg, a peach or an ear of corn.

The coalition is a firm proponent of conservation of all natural resources. In this
light, one of the first steps must be to create an extensive public awareness of
all the natural and historic resources with which the Basin has been blessed.
Increased emphasis should be placed on water and energy conservation as
well as recycling of various materials. In addition to metering and rate revisions,
a school educational program and public advertising campaign should be used
to explain and encourage conservation measures.

The generation of electrical power and some other industrial processes usually
produce some form of heat, which must be disposed of. Most industries and/or
small businesses require some type of heat input. Would it be possible for the
DRBC or various industrial development groups to list how much waste heat is
available at different locations and attempt to locate industries requiring heat
near industries having heat available? This, of course, would have to be done
within practical engineering limits.

In the light of accidents, malfunctions and design defect uncovered at various
nuclear plants, the Coalition advocates that any commitment of Basin resources
to nuclear power should be re-evaluated. It is conceivable that in the near future
there could be a moratorium on the construction and operation of nuclear
power plants in the Basin area.

One of the most often cited reasons for continued dam construction is the need
to maintain a river flow of 3000 CFS at Trenton for salinity control and waste
assimilation. What flow rate would be required if the following suggestions were
to be implemented?

1. Move Torresdale potable water intake upstream beyond any conceivable salt-
water intrusion.
2. Institute improved secondary treatment or tertiary treatment for municipal
sewage effluent discharges into the Delaware River.
3. For the New Jersey area dependent on deep wells, construct a river intake
station similar to the one at Torresdale.
4. Enforce industrial compliance with clean water ordinances.

With the drinking water(s) out of danger and the waste load considerably
reduced, it would seem that a much lower river flow rate would be sufficient.

Industries in the estuary are, for the most part, prepared and equipped to use
salt water for cooling purposes, so major disruptions or expenditures in this
area should not be expected.

The possibilities of desalination to provide potable water seem to have been
dismissed too quickly in the preliminary report, and we feel that some time in the
future this technique may be required.

For many reasons we recommend an end to dam planning and construction
within the Basin Area. Enlightened water resource planning has shown that the
concept of the dam as a water conservation and flood control device is archaic
and is economically, environmentally and socially unacceptable. The Basin area
has many desirable alternatives available. Opposition to the Commission's
promotion of Tocks, Trexler, Merrill Creek and other dams clearly indicate the
public and governmental attitude towards impoundment of any type.

We appreciate the opportunity to participate in the Level B Study, and
understand the broad scope and complexity of your task





INSTALLMENT FIVE

Gerald M. Hansler, Executive Director, Delaware River Basin Commission, at a
public hearing before the Pennsylvania House of Representatives Conservation
Committee, on August 13, 1981, testified in regard to a proposed Water
Resources Management Code for the State of Pennsylvania:

" A major problem in water resources management dealing with meting out
available water resources for water withdrawals --- be it to serve municipalities,
industry, commerce, electric utilities, individual home owners or agricultural ---
is the necessity to maintain adequate minimum flow in surface streams. Such
flow is needed for fish, wildlife recreation, waste assimilation capacity, and
downstream water supply If each small tributary to a stream were dried up
below stream levels, or an excessive amount of surface water had been
withdrawn higher up on the watershed and evaporated, then the hundreds of
millions of dollars spent for adequate waste treatment by municipalities and
industries would not be sufficient to protect instream water municipalities and
industries would not be sufficient to protect instream water uses. This is
because the available clean water flow in the stream is the basis for
determining, in many cases, the degree of treatment needed by municipalities
and industries for water pollution control. Or, in other words, the flow in the
stream is the main factor in determining the waste assimilation capacity of that
stream. If we dried up the fresh water flow in our smaller streams and the larger
tributaries which they serve, then the basin and the Commonwealth could be
confronted with treated effluents as their surface waters, not healthy streams
with the quality to serve many useful purposes such as water supply sources,
fish, wildlife, recreation and agriculture."

... Need to protect water supply

It was for the stated purpose of protecting its water supply that Allentown
agreed to accept effluent from Emmaus into its wastewater system. For the
same purpose did the City entertain seriously requests for hook-ups from
certain districts in Salisbury and South Whitehall Townships. After all, actions in
these communities could conceivably effect Allentown's water supply which
comprised the Little Lehigh Creek Watershed Basin, Crystal and Schantz
Springs.

For years these water sources accommodated Allentown's needs very nicely.
Even during the severe drought of 1962-66, these water sources were capable
of maintaining a minimum flow of 42 mgd, more then enough to meet
Allentown's consumptive needs during hot periods.

... Allentown leaves itself vulnerable

Fatefully, Allentown on the advice of its water consultant, Morris Knowles, Inc.
of Pittsburgh, wanted to guarantee continued available water sources in the
future. This is why the City looked at the Lehigh River and the proposed Trexler
Dam on the Jordan Creek as water sources. Because of this interest, Allentown
became concerned when Hazleton, located 30 some miles north of Allentown
along route 309, went to the Delaware River Basin Commission (DRBC) in late
1964 for permission to dump wastewater treatment effluent into the Lehigh
River.  Allentown City Engineer William A. Jacoby and Donald Lichty,
representing the City, presented the City's concerns before the DRBC.
However, in doing so, Allentown left itself vulnerable to a political card game
closer to home base/ The Coplay-Whitehall Sewer Authority took advantage of
the fact that Allentown showed its hand in its desire to protect the Lehigh River
as a future water source for the City by perpetrating what we might call today as
a bluff or sting. The Coplay-Whitehall Sewer Authority half-heartily announced
its intention to construct a wastewater treatment plant on the banks of the
Lehigh River which Allentown by its position was forced to take seriously. Such
being the case, Allentown virtually faced a replay of the Little Lehigh Creek
Wastewater Treatment Plant showdown with Emmaus that ended with a
negotiated agreement which innocently opened the barn door for additional
requests for wastewater treatment service.

... Gaggle of political opportunists, bureaucrats, lawyers, bond agents and
consulting engineers

We note, however, that this wastewater treatment drama or sewerage war was
not one on one competition. Rather, Coplay-Whitehall had allies in South
Whitehall and Salisbury Township whose plans for community development
also elicited Allentown's attention in regard to the continued quality of
Allentown's Schantz Spring and Little Lehigh Watershed in light of this
development. In other words, Allentown had a second front to consider during
the years that nature turned off the spicket --- that is, the drought years of 1962 -
1966.

This so-called sewerage war was not fought by guns, armor, or infantry but
instead by a gaggle of political opportunists, bureaucrats, lawyers, bond
agents, and consulting engineers who engaged in endless barrage of political
rhetoric and legalism that was stilled only by political considerations and the
siren lure of grant money that filtered down to the cities from Lyndon Baines
Johnson’s "Great Society" and from Harrisburg.

There was no question whether these political entities would be allowed to
hook-up to the Allentown Wastewater Treatment System; this was already
established by an Allentown City Council resolution dated May 14, 1963. The
question was how and when a mutually satisfactory agreement would be
negotiated establishing the "Method and payment of such service."

... Seeking the answer to how and when

The answer to the question "how and when" did not occur soon enough for
members of the Coplay-Whitehall Sewer Authority, The Whitehall Township
Commissioners and the Coplay Borough due to federal acceptance of township
sewer plans. Consequently, the lack of progress in negotiations with Allentown
officials caused concern and forced emergency action.

The township of Whitehall and the Borough of Coplay had spent years of study
and planning before establishing the Coplay-Whitehall Sewer Authority
February 26, 1963 to finance a mammoth multimillion-dollar system for the two
municipalities.

Therefore, the three entities served an ultimatum on the City of Allentown
December 13, 1964 to achieve a binding agreement by December 31 of that year
or plans would be formulated to construct a wastewater disposal plant just
north of the Allentown city line on the Lehigh River to service Whitehall and
Coplay.

The Ultimatum read:

" The two boards jointly went on record with the Coplay-Whitehall Sewer
Authority as establishing December 31, 1964, as the absolute and final deadline
for the signing of the agreement for sewerage treatment. If this deadline is not
met, the Coplay-Whitehall Sewer Authority will have no recourse bit to order its
consulting engineers (Arthur L. Wiesenberger) to prepare plans and
specifications on a cash basis for the sewage treatment plant to be constructed
along the Lehigh just North of the Allentown city line. The location for such a
plant is mandatory to meet present day engineering standards for sewage
collection systems."

Officials for the three entities seemed frustrated for they expressed grave
concern over the delay, which did occur in getting the project under
construction. Working plans and specifications were completed for an entire
year, and the federal government approved a grant of $302,000 towards the
project under provisions of the Federal Water Pollution Act.

The ultimatum continued:"

" The Coplay-Whitehall Sewer Authority --- which will construct the project, has
worked tirelessly to bring the project to the point where the only remaining step
to be completed is the culmination of negotiations with the city of Allentown for
the treatment of sewage from the two communities.  Despite every effort on the
part of the Joint Authority, these negotiations with the city have been prolonged
for more than a year with no finalization date."

Upon contemplation, the three entities expressed deep displeasure that the
necessary agreement with the City of Allentown was not consummated, being
that the two municipalities and the Authority were among the initial advocates of
a metropolitan sewage treatment district, which had as its main purpose the
protection of the Lehigh River as a future source of water supply for the City.
The entities claimed that the delay produced hardship on Coplay and Whitehall
because construction costs rose steadily since negotiations began, and the
growth and development of the area will be impeded by the lack of sewer
facilities. As expected, the three entities finally resorted to the standard line of
political rhetoric, that is, that the "health, welfare and safety of the residents of
both communities (Coplay and Whitehall) had been placed into jeopardy by this
long delay.

Et Tu South Whitehall

South Whitehall authorities, too, wanted city wastewater treatment service.
Harley S. Frantz, President of the Board of Supervisors, resorted to a parallel
with Emmaus by commenting: "It just boils down to this: If we can't be taken
into the City's service. We have to build our own plant."

Quite naturally, this eventuality would pose the same threat to Allentown's water
supply, as would have an Emmaus plant.

South Whitehall's request for service effected 750 acres in Cetronia, Bungalow
Park, Sterling worth, the Haine's Tract, Parkway Manor and Parkway Court.
Benefiting from installation of the South Whitehall system would be 3,000
residents. However, the drainage area, which would take in parts of Macungie
and Lower Macungie Townships, could serve more than 7,000 people. Also, the
township wanted an answer from the City because of service decisions to the
Parkland School District's James W. Good School at Cetronia where expanded
facilities were under construction and would be completed by the fall of 1962.
The school required sewer service to operate and could no longer depend on a
septic system.

Interestingly, the comments of Frantz preceded a meeting sponsored by the
Joint Planning Commission, Lehigh --- Northampton Counties by a month and a
half (March 25, 1962) in which John P. Durr, Regional Director for the
Pennsylvania State Sanitary Water Board, promoted a metropolitan wastewater
treatment district.

On March 17, 1965 the City of Allentown reached agreement with Coplay
Borough and Whitehall, South Whitehall and Salisbury Townships on the use of
the city's treatment plant in a metropolitan sewer program. The Allentown City
Council approved this historic agreement March 23, 1965. Allentown Mayor F.
Williard Harper willingly signed the agreement into law April 12, 1965.

The agreement dealt primarily with Allentown's treatment plant, its expansion
for metropolitan service and how and who is to pay what amounts for the debt
incurred by Allentown for necessary enlargement of its facilities.

INSTALLMENT SIX

...Whitehall, Coplay map mammoth sewer system

The Whitehall Township Commissioners and Coplay Borough Council  
approved the creation of a joint authority to finance a mammoth multimillion
dollar sewer system February 26, 1963. The action taken at separate meetings of
the two governmental bodies climaxed four years of study and planning. The
project called for the linking the huge` Coplay-Whitehall sewer network with
Allentown's for treatment in the city's plant.

Interestingly, the decision of Whitehall and Coplay to form a joint authority met a
March 1, 1963 deadline for federal funds. Failure to reach agreement would have
meant that the two municipalities would have been forced to apply for funds
individually. The desirability of a joint authority was two-fold:

1.More federal funds would proportionately be available with such status and,
2. Construction costs would be cut by the elimination of at least two metering
chambers.

Note --- under the joint operation there would be a metering chamber where the
system entered Coplay and where it left Whitehall. Separately, they would need
those two --- plus a metering station leaving Coplay and another one entering
Whitehall.

The estimated cost of the Coplay-Whitehall project was $5,680,000 with annual
operating costs of $106,087. The consulting engineer for the township and
borough, Arthur L. Wiesenberger Associates, Inc. provided the estimate.

... Work performed in three phases

Coplay-Whitehall sought to implement the project in three phases.

Work performed in the first phase would include the Lehigh River Interceptor
from Allentown to Coplay; Coplay Creek Interceptor from Hokendauqua to West
Coplay; collectors of that portion of Fullerton draining into the Lehigh River,
and the Coplay collection system.

Work performed in the second phase would include the balance of the Coplay
Creek Interceptor from West Coplay to Egypt; Hokendauqua collection system
and the West Coplay and the West Catasauqua collection systems.

Work performed in the third phase would include the Lehigh River Interceptor
from Coplay to Cementon; Jordan Creek Interceptor from Fullerton to Helfrich's
Spring; remainder of the Fullerton collection system; all of Cementon and all of
Egypt collection systems.

... Coplay-Whitehall ultimatum debate

However, planning decisions did not proceed as smoothly as Coplay and
Whitehall officials desired. A quick agreement to link the two sewer systems
was not achieved; consequently the Coplay-Whitehall Sewer Authority in
conjunction with the borough and township felt compelled to serve an
ultimatum on Allentown December 13, 1964. The three political units threatened
to construct their own treatment plant just north of the Allentown city line on the
Lehigh River if no agreement was achieved by December 31, 1964

Considering the added cost to the Sewer Authority and the municipalities we
wonder if they were really serious.

We have already said that the estimated cost of the Coplay-Whitehall Interceptor
and Collector project was $5,680,000 with annual operating costs of $106,087.
Surely, construction of a wastewater treatment plant to serve Whitehall and
Coplay would cost Whitehall and Coplay additional money. Construction of a
wastewater treatment plant would cost $5,900,000 with annual costs of $46,390.
($5,900,000 with annual costs of $46,390)

As it played out, the ultimatum of three political units allegedly surprised
Allentown Mayor F. Williard Harper for he reported that "Whitehall and Coplay
have had an agreement in their hands for two months and have never sent it
back to us."

Then the mayor added: "I can't understand why they haven't asked us for a
meeting."

Which in rebuttal, Whitehall solicitor Richard C. Buss said: " What the mayor
says is true but the agreement submitted hasn't been a satisfactory agreement.
The authority had reached an informal understanding with Allentown about
sewage processing service, but it was never satisfactorily drawn." Additionally,
Buss questioned the Allentown mayor's accusation that Whitehall was
responsible for the fact that no meeting was held to clear up outstanding points
of contention. Buss maintained that such a meeting was sought by Whitehall,
but that Allentown wouldn't negotiate.

Next, Buss reiterated the Coplay-Whitehall position: "So it's now or never.
Either we get an agreement before the end of the year, or we build our own
treatment plant as decided by the Whitehall Commissioners, the Coplay
Borough Council and the Authority."

Concerning the agreement proposal that was submitted for Coplay-Whitehall
signature, Harper stressed that the agreement was a formula established by
Allentown's engineering consultant, Metcalf & Eddy, Inc., Boston. He
maintained that if Coplay-Whitehall was unhappy: "Why haven't they told us?"

Buss said that his clients were not looking for a fight with Allentown, but that
Coplay-Whitehall was in a bad position that demanded action. The Coplay-
Whitehall Authority's bond counsel would not approve a bond issue for
construction of a sewer collection system unless it had a written agreement
with a firm figure on processing costs from Allentown. Additionally, without
approval, it could not go ahead --- unless it built its own treatment plant. He
further maintained that Coplay-Whitehall could not wait beyond the year
because of the forced necessity to build a plant, therefore much work would
have to be done between December 31 and March 23, the new deadline to
qualify for a grant of $302,000.

Councilman Lloyd Grammes, under whose department the Allentown Sewer
Bureau was operated also involved himself in the debate. He said that Coplay-
Whitehall had not complied with requests for signing of an agreement as
proposed by Metcalf & Eddy, Boston. Whatismore, he charged that Allentown
Engineer William Jacoby had correspondence to bear this out.

Arthur L. Wiesenberger Associates, Inc., the Coplay-Whitehall Sewer Authority
engineers, countered Grammes' charges with a litany of correspondence of its
own suggesting otherwise. The Wiesenberger firm sought to prove that the city
at no time committed itself to a permanent agreement for Allentown treatment of
Coplay-Whitehall sewage.

The Allentown wastewater treatment plant at Kline's Island would have to
process sewage for an estimated 20,000 persons in Coplay-Whitehall.

The earliest chronological contact according to Wiesenberger Associates was
made March 30, 1962.

Councilman Grammes had received a letter from Coplay and Whitehall asking
that Allentown process sewage from their communities. The letter contained
data on sewage flows from both communities.

Significantly, this correspondence was made just three days after John P. Durr,
the regional director for the state sanitary water board, in a meeting sponsored
by the Joint Planning Commission, Lehigh --- Northampton Counties advocated
the creation of a metropolitan wastewater treatment district with the Allentown
plant processing sewage from nine to ten communities.

The last contact presented was December 3, 1964.

Allentown transmitted reply by Metcalf & Eddy to objections raised by the
Authority --- The Authority objected to references to Emmaus and South
Whitehall, acting in belief that Allentown wanted all of these communities to join
the metropolitan sewer system at the same time.

The controversy continued after the December 31 deadline established by
Coplay-Whitehall passed. Consequently, the Kline's Island soap opera that also
involved an assortment of production teams from South Whitehall and
Salisbury Townships dragged on.

...Rhetoric and decision

Whether it was input from public officials, lawyers, bureaucrats or technical
experts, each new day was enlightened by new or retreaded rhetoric and
debate.

One such meeting occurred January 6, 1965, Allentown was represented by its
consulting firm, Metcalf & Eddy, Boston as well as City Engineer William A.
Jacoby and Sewer Engineer Hubert Schmaunch. The Coplay-Whitehall
Authority had Wiesenberger Associates, Allentown, at the session, while South
Whitehall was represented by G. Edwin Pidcock Co., Allentown, and Salisbury
Township by Gilbert Associates, Reading.

By February 4, 1965, Allentown officials began to lose patience in this political
gamesmanship. In one particular period when sewer negotiations were
conducted at various hours for six or seven days, Allentown Mayor F. Willard
Harper inferred that the debate would be endless, especially in the view of the
large number of attorneys, engineers, consultants and financial advisors who
took part in each of the talks.

Significantly, the Allentown City Council decided February 4, 1965 that it would
set the terms on sewage treatment for outlying communities. Council agreed on
this take it or leave it stand after rejecting a proposed agreement related to the
metropolitan sewer system worked out earlier that week by representatives of
the Coplay-Whitehall Sewer Authority, South Whitehall and Salisbury
Townships. Interestingly, the city turned the tables on Coplay-Whitehall by
asserting that speed was needed in reaching an agreement in order to meet a
March 1 deadline request for federal aid in regard to plant expansion. (Note ---
Coplay-Whitehall implied the same when it issued its ultimatum on Allentown.)
Consequently, the Allentown City Council forewarned the prospective
signatories of its intent to set its own service rates.

Like Whitehall's ultimatum deadline, the deadline established by Allentown
likewise passed with no agreement. But channels of communication remained
opened for agreement on service costs and sewage disposal plant enlargement
between Allentown, Coplay-Whitehall, South Whitehall, and Salisbury was
achieved March 17, 1965. On March 23, 1965, the Allentown City Council
formally passed a resolution allowing the Mayor to execute the agreement. The
agreement was officially executed April 12, 1965.

INSTALLMENT SEVEN

The sewage agreement, executed the 12th day of April 1965, by and between
the City of Allentown, and the Coplay-Whitehall Sewer Authority, the South
Whitehall Township Authority, and the Salisbury Township Authority gave these
adjacent municipalities the perpetual right to discharge their sewage wastes
into the city's system as soon as necessary collector systems for each
community became functional.

Allentown reached agreement with Coplay Borough and Whitehall, South
Whitehall and Salisbury Townships on the use of the city's treatment plant in a
metropolitan sewer program March 17, 1965. Negotiations relating to the
agreement proceeded at a frustrating pace since mid-December 1964.

Note --- for the Coplay-Whitehall Sewer Authority the agreement came just in
time for the Authority to submit an application for $302,000 in grant aid from the
federal government to finance part of the estimated $5 to $6 million cost for its
wastewater collection system. The Authority's target date for application being
March 23, 1965. Interestingly, on March 23, 1965, the Allentown City Council
gave its approval for the pact.

Allentown was interested in federal aid as well for on March 3, 1965, the
Allentown Authority submitted plans to the Philadelphia Office of the Federal
Housing and Home Finance Administration for expansion work at Allentown's
wastewater treatment plant on Kline's Island.

***   ***   ***

These perpetual rights, however, were subject to certain limitations and charges.

For example, the discharge of sewage and waste containing storm water, roof
or surface drainage by any user into a municipal sewer line was forbidden.

Interestingly, this limitation was questioned indirectly by scientists at the U.S.
Public Health service main laboratory located in Cincinnati a little more than a
month after the before mentioned agreement was executed.

S.R. Weibel, an engineer at the Public Health Service's Taft Sanitary Engineering
Center, explained that: "In a typical urban area, about 37 percent of the land
surface is impervious to rain. It is either roof tops or paved areas like streets,
parking lots and driveways.

Consequently, more than a third of this precipitation has to run off, and as it
runs off, it collects a wide variety of the wastes that are the "products of urban
civilization --- everything from the oil on roadways to the excretion of animals,
birds and insects, and the new long lasting pesticides that are being widely
used in laws and gardens."

Therefore, we can expect that each downpour unleash on a typical city a
temporary flood of transient sewage that contains everything that has
accumulated since the last rain.

Such being the case, the U.S. Public Health Service's main laboratory in
Cincinnati concluded that storm water run-off seemed to be as polluted in some
critical respects as the sewage itself and therefore, should be treated.

Equally forbidden by the April 12 agreement, with or without pre-treatment, was
the discharge of industrial waste, chemicals or other matter into the wastewater
that conformed to the following conditions:

a. Temperatures being higher than 150oF;
b. Weight of fat, oil, or grease containing more than 100 milligrams per liter
(mg/l);
c. Contents include any gasoline, benzene, napltha, fuel oil or other inflammable
or explosive liquid solid or gas;
d. Contents include any unground garbage;
e. Contents contain any ashes, cinders, sand, mud, straw shavings, metal,
glass, rags, feathers, tar, plastics, wood, paunch, manure, or any other solid or
viscous substance capable of causing obstruction or other inference with the
proper operation of the treatment plant:
f. Contents having a "pH" 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 or personnel operating the treatment plant.
g. Contents containing a toxic or poisonous substance in sufficient quantity to
injure or interfere with any sewage treatment process, constituting a hazard to
humans or animals or creating any hazard in the receiving waters of the
Treatment Plant, toxic wastes shall include wastes containing cyanide copper
and/ or chromium ions;
h. Contents containing suspended solids in excess of 3 pounds per 1,000
gallons and of such character that unusual attention or expense is required to
handle such materials at the treatment plant;
i. Contents containing noxious or malodorous gas or substance capable of
creating public nuisance;
j. Contents containing B.O.D. (biochemical oxygen demand) in excess of 2.5
pounds per 1,000 gallons and be of such character that unusual attention or
expense is required to handle such materials at the treatment plant; unless
otherwise agreed to by all parties in the agreement and permitted by the
Commonwealth of Pennsylvania or any duly constituted board, commission or
department of the same;
k. Contents having chlorine demand excess of 0.1 pound per 1,000 gallons;
l. Contents prohibited by any permit issued by the Commonwealth of
Pennsylvania.

We must backtrack a little to establish that Allentown's sewage agreement with
the townships of Whitehall, Salisbury and South Whitehall and the Borough of
Coplay was more inclusive and less general in regard to expressed limitations
and sewage discharges into the Allentown wastewater treatment system then
those limitations agreed to with Emmaus March 17, 1959. But this is
understandable for Emmaus was the first community Allentown had established
a sewage link. Consequently, the Emmaus agreement was the base from which
all subsequent agreements would evolve.

Let us note that the sewage limitations granted Emmaus roughly were similar to
points a through i we just presented. The difference in the April 12, 1965
agreement is in point’s b and h.

In analysis point b, whereas the 1965 agreement measured weights of fats, oil or
grease in milligram per liter, the 1959 agreement measured in parts per million.
In analysis point h, whereas the 1965 agreement recognized the measurement
when the acceptance of suspended solids into the Allentown system would be
troublesome, the 1959 agreement did not establish exact measurement, but
established the general principle.

Interestingly, although not party to the 1965 agreement, Emmaus was expected
to adhere to some of its contents by provision of the 1959 agreement. That is,
the borough agreed that the limitations placed on its discharge of sewage and
wastewater into the city collection system is more or less "with respect to the
contents or components of sewage" as required from other sources treated by
the City of Allentown.

We note --- if Allentown enforcement of new limitations as established by the
1965 agreement caused any misunderstanding with Emmaus it was indeed
cleared up with the passage by Allentown in 1973 of its first comprehensive
sewage ordinance.

***   ***   ***

The 1959 sewage agreement between Allentown and Emmaus did not make it
necessary for Allentown to enlarge and notify its existing treatment plant, but it
certainly made Allentown officials aware of the future possibility.

Consequently, with the dual aim of flood control and providing additional room
at Kline's Island for future expansion, Allentown, in the second administration of
Donald V. Hock (1958-1961), embarked on a project in cooperation with the U.S.
Corps of Army Engineers to construct a dike in the Lehigh River.

The stated purpose of the dike was to alleviate the possibility of floods
throughout the lower Jordan Valley at the time of high water. The Jordan enters
the Lehigh at Kline's Island at an angle allowing for floodwaters of the Lehigh to
rush into the Jordan as backwater.

Interestingly, we commonly think of Kline's Island as being an island located in
the middle of the Lehigh River. However, while this may have been true in the
past, this is no longer the case. From the vantagepoint of the Hamilton Street
Bridge, looking south, we can clearly see a peninsula jutting out into the middle
of the Lehigh River, being the end product of dike construction activity

Such activity helped enlarge Kline's Island, which is actually located below the
dike, by 12 acres with fill taken from the channel on the east side of the island,
thus providing room for future enlargement of the wastewater treatment plant,
located on the island.

Additionally, the dike made it possible for the Jordan to enter the Lehigh at the
southern tip of what in reality became Kline's peninsula. City officials had hoped
that the dike would prevent future flooding of the flatlands between the Lehigh
River and 4th Street; and more specifically, they hoped it would prevent future
flooding in the vicinity of what was the old Lehigh Valley Railroad Station but
has since been reconverted in the fiscal Administration as the short-lived
Gingerbread Man Restaurant and more currently as The Gillian's.

***   ***   ***

This awareness became reality with the sewage agreement of April 12, 1965.

By agreement, it was recognized that in order to treat the quantity of sewage
contemplated, " it was necessary to enlarge and modify the existing treatment
plant and to make additions and improvements " accordingly.

Thus, the existing daily capacity of 17.3 million gallons was upgraded to 28.5
million gallons under normal operating conditions with each party to the
agreement receiving allocation as prescribed in TABLE IV. In an emergency the
plant would be capable of handling 31 mgd.

The $3.27 million price tag for the expansion of Kline's Island and the future
need to install all interceptor lines to handle the increased volume of flow from
outside would be financed by the Allentown Authority.

***   ***   ***

The Allentown Authority, by agreement, was authorized to apply for and accept
any grants or contributions from any federal, state, or other government
agency, such grants or contributions to be based on the proportion of the
capacity being provided in the project for each of the several municipalities. The
proceeds of such grants or contributions would be applied against charges in
connection with costs related to modifications, improvements and additions to
the existing plant and charges related to reasonable and necessary operating
and maintenance expenses of the treatment plant and jointly used interceptor
sewers.

As in the case of the Emmaus agreement, Allentown in its agreement with
Coplay-Whitehall, South Whitehall, and Salisbury Township established a
proprietor: customer relationship.

By agreement, the adjacent municipalities were charged with payment of .01
cent per 1,000 gallons for use of the City interceptors.

Additionally, a temporary charge of .14 cents per 1,000 gallons for use of the
City's wastewater facilities was imposed until such time the Allentown Authority
incurred debt for new acquisitions and construction; then it was provided that a
charge be made annually until 1995 to each adjacent municipality for the use of
existing treatment facilities as follows:

Coplay-Whitehall --- $4,100;
Salisbury --- $2,100;
South Whitehall --- $3,600.

______________________________________________________________
TABLE IV- Capacity Allocated in Existing Treatment Plant after Enlargement
______________________________________________________________

                              Total Treatment                         Percent of reserved
                              capacity reserved                       capacity to nearest
                              average daily mgd.                     tenth.

City of Allentown                                 21.1                                   74
Borough of Emmaus *                            1.4                                     4.9
South Whitehall Twp. *                          0.5                                     1.8
Total Capacity Chargeable
to Allentown                                         23.0                                   80.7
Coplay-Whitehall Authority                     2.3                                     8.1
Salisbury Township Authority                  1.2                                     4.2
South Whitehall Township Authority      2.0                                     7.0
                                                      28.5                                100.0
* These capacities are included with Allentown's reserved capacity in
accordance with the Agreements set forth in section 1
______________________________________________

INSTALLMENT EIGHT

Allentown's plans to expand its Kline's Island Wastewater Treatment Plant was
aired at a public hearing October 7, 1965 before the Delaware River Basin
Commission (DRBC) and approved. Thus, paving the way for the Pennsylvania
Sanitary Water Board to release the City's permit for plant expansion, and also
for the U.S. Health Service to give Allentown a $980,000 grant toward the $3.27
million expansion project. The commission had authority because of
Allentown's intent to discharge an additional flow of treated effluent from its
outlet (outfall) into the Lehigh River, a Delaware River tributary --- a fact that
caused some commission concern. Allentown was represented at the hearing
by William A. Jacoby, City Engineer, Hubert F. Schmaunch, Sewer Engineer,
and Charles Hitchcock Jr., a project engineer for Metcalf & Eddy, the Boston
firm serving as the City consultant for sewage.

These plans, we believe were similar to such information contained in a Metcalf
& Eddy report to the Allentown Authority on Enlargement of Sewage Treatment
facilities dated May 1964. The report (see TABLE V) contains information
relating to expected 1964 and 1990 basic design data relating to the treatment
plant. In addition, the report contains a discussion on the proposed future
operation of the standard rate trickling filters.

TABLE V --- Basic Design Data Kline's Island Plant
______________________________________________________________


                                                                   Year 1964  Year 1990
Sewage Pumps
Constant Speed Unit
4,000 gpm., 60 hp.                                                      1                 0
8,000 gpm., 125 hp.                                                    1                 0
15,000 gpm., 200 hp.                                                  0                 2
Variable speed unit
12,000 gpm., 140 hp.                                                  1                 0
   2-speed unit
12,000 gpm., 200 hp.                                                  0                 2
   3-speed unit
10,000 gpm., 125 hp.                                                  1                 0
Total number of Pumping units                                            4                4

Grit removal
Number of detritus tanks                                                  2               2
Tank diameter, ft.                                                           30             30
Side water depth, ft.                                                       16.33        16.33
Cone depth, ft.                                                                 2               2
Detention period, minutes                                               15             11
Surface loading, sq1. ft./ mil. gal                                      82            50
Pumps ( replacement )                                                       2             2

Grit Dewatering
Number of detritus screens                                                 2            0
Slot width of drum screens, in.                                        1/8           X


TABLE V --- Continued

                                                                               Year 1964  Year 1990

Number of Cyclone grit separators                                        X               2
Size of unit, in.                                                                    X             12
Flow rate of unit, gpm                                                         X           200
Number of Classifiers                                                             X              2
Width of unit, ft.                                                                   X             3
Length of unit. ft.                                                                  X           15

Sewage Flow Meters
Venturi
Influent, in. diameter                                                             36          36
Throat, In. diameter                                                              21          21
Range,mgd                                                                   3.5 - 60         3.5 - 60
Magnetic flow meter                                                                  X             2
Orifice Meter                                                                             X             1
Open flow nozzle                                                                       X             1
Parshall flume                                                                            X             1
Flow tube                                                                                 X              1

Imhoff Tanks
Number of Units                                                                        6             0
Total surface  area, sq. ft.                                                   25200             X
Surface loading, gal./sq. ft./day                                               690             X
Total volume, mil. gal.                                                                5.8           X

Primary Setting Tanks
Number of Units                                                                       0              6
Total surface  area, sq. ft.                                                          X     27600
Surface loading, gal./sq. ft./day                                                  X       1000
Detention time, hours.                                                                X            5.8
Sludge draw-odd, mgd                                                              X            0.5

Imhoff Efluent Water Screens
Number of units                                                                         1            1
Unit capacity, mgd.                                                                  60          60
Mesh, in.                                                                                   0.25        0.25

Trickling Filters
Number of units                                                                         4             4
Depth of stone, ft.                                                                    10           10
Total area, acres                                                                         5.32        5.32
Total volume, mil./cu. ft.                                                              2.32        2.32


TABLE V --- Continued

                                                                                  Year 1964 Year 1990
Trickling Filters Cont'd
Number of dosing chambers                                                      8             8
Capacity of dosing unit., gal.                                               20200     20200
Number of fixed nozzles, total                                               1560       1560
BOD loadings, lb./1,000 cu. ft/day                                           10.7        13.8
Hydraulic loadings, mgd (ave)                                                     3.3          6.1
Recirculation ratio 0 0.1

Final Settling Tank
Number of circular units                                                            4              0
Number of rectangular units                                                       0              2
Circular units
Diameter, ft.                                                                         70              X
Sidewater depth, ft.                                                                8              X
Cone depth, ft.                                                                       5              X
Surface area, sq. ft.                                                         15400              X
Surface loading, sq. ft                                                       1130              X
Total volume, mil. gal                                                               1.11         X
Detention time, hours                                                              1.5           X
Rectangular units
Width, ft.                                                                                X             0
Length,ft                                                                                 X         225
Sidewater depth, ft.                                                                 X            9
Surface area, sq. ft.                                                                  X    36000
Surface loading, sq. ft.                                                              X        770
Total volume, mil. gal.                                                              X            2.42
Detention time, hours                                                               X            2

Secondary Pumps
Secondary Sludge and scum pumps                                            2           13
Capacity of each, gpm                                                            X         600
Efluent pumps                                                                            0             2
Capacity of each. gpm                                                            X        225
Chlorinator injector pumps                                                         0            2
Capacity of each. gpm                                                            X       100
Efluent flushing water pump                                                        0           2
Capacity of each. gpm                                                            X      200

Sludge Thickening Tanks
Number of tanks                                                                       X          4
Diameter, ft.                                                                              X        30
Sidewater depth, ft.                                                                   X        10

TABLE V --- Continued
                                                                                Year 1964 Year 1990
Sludge Thickening Tanks Cont'd
Total  area, sq. ft.                                                                        X            2830
Total volume,. gal.                                                                      X        116600
Solids, loadings, lb./sq. ft/day                                                     X                13
Overflow rate, gal./sq.ft./day                                                      X              600
Sludge pumps                                                                            X                  4
Sludge density meter                                                                  X                  1

Sludge Digestion Tanks
Number of tanks                                                                        X                 2
Diameter, ft.                                                                               X               90
Sidewall operating depth, ft.                                                        X               23
Cone depth, ft.                                                                           X                 9
Tank capacity, cu. ft.                                                                  X       116600
Total detention days                                                                   X               45
Primary digestion ***                                                                 X                 1

( *** Concentrated primary and secondary sludge at 8.)% total solids and 75%
volatile solids from thickeners)

Detention, day                                                                          X             23
Dry solids loading, lb./1000cu.ft/day                                         X           220
Volume solids loading, lb./1000cu.ft./day                                  X           165
Floating cover                                                                          X               1
Scum control                                                                           X                1
Heat exchanger                                                                        X                1
Recirculation pumps                                                                    X                2
Transfer pumps                                                                           X                1
Secondary digestion                                                                    X                1
Gas holder cover                                                                         X               1
Digested sludge density meter                                                                       X
Gas production
Cu. ft. gas per day unknown                                                             220000
Cu. ft./lb volatile solids added                                                                     8

Elutriation
Number of tanks                                                                          X               2
Diameter, ft.                                                                                 X             30
Sidewater depth, ft.                                                                      X             10
Total area, sq. ft.                                                                          X         1400
Total volume, gal.                                                                        X       58300

TABLE V --- Continued

                                                                                 Year 1964  Year 1990
Elutriation Cont'd
Washwater ratio                                                                          X           `3:!
Surface loading, lb. solids/sq. ft./day ***                                     X             10
Overflow rate, gal./sq. ft./day                                                      X            800
Sludge pumps                                                                             X                3
(*** Digested sludge at 4.5% total solids)

Vacuum Filtration
Number of Units                                                                          X               2
Unit surface area, sq. ft.                                                               X           500
Filtering rate, lb./sq. ft./day                                                           X              4
Vacuum pumps                                                                            X              2
Filtrate pumps                                                                              X              2

Sludge Drying Beds
Number of Units                                                                         68            34
Unit length, ft.                                                                              80            80
Unit width, ft.                                                                               18           18
Unit area, sq. ft.                                                                        1440       1440
Total area, acres                                                                             2.5          1.12

Electric Power requirements
Power required, kWh/mil. gal                                                    2600         9900
kWh/day                                                                              94300     281000
Average load, kWh                                                                      175          570

Chlorination
Existing circular settling tanks to be used as chlorine contact tanks
Number of contact tanks                                                                  X             4
Total volume. mil. gal.                                                                      X              1.11
Contact time at mgd., minutes                                                          X            26
Number of chlorination units                                                            X        7250
Total capacity, lb/ day                                                                  X        5000
Number of evaporators                                                                   X              2
Number of scales                                                                            X              2
Number of ton containers in service                                                 X              4
Supply available at all tines                                                              X            10
______________________________________________________________
The following is a Metcalf & Eddy proposal in regard to the standard rate
trickling filters:

" It is proposed to recirculate trickling filter effluent to the main pumping station
where it will be combined with the raw sewage and pumped to the primary
settling tanks prior to being returned to the trickling filters. If for some
unforeseen reason the hydraulic loadings should exceed 6 mgd without
recirculation prior to the year 1990, we believe that the fixed nozzle distribution
system should then be replaced with rotary distributors to enable the units to be
operated as high rate trickling filters."

Operationally, Metcalf & Eddy said that adequate treatment would be provided
using the existing trickling filters without recirculation during the colder months
and with recirculation during the warmer months.

We note --- mention of the term primary settling tank represented a change in
the status of the Imhoff tanks (an evolution in function so to speak). These tanks
were originally built in the early 1930's serving as part of a natural dormant
treatment system which required comparatively little attention and thus saved
money in operation and maintenance. By 1968, however, they were converted
to settling tanks. The purpose of these tanks were to settle out the sloughing
from the trickling filter. The filter effluent flows across the tanks and through a
channel into the dosing chambers of the rock media truckling filters. Settled
sludge is withdrawn from the bottom of the P.S.T's by means of sludge
withdrawal pipes. The sludge from the pipes flow to the valve boxes and then to
sludge thickening tanks which also was a modification in the 1968 expansion.

______________________________________________________________
FIGURE ONE ---General Plan of Kline's Island Proposed Plan for Enlargement
______________________________________________________________
FIGURE ONE clearly shows the major changes or modifications that the
proposed enlargement of the Allentown plant would entail. Jay S. Grumbling,
Metcalf & Eddy Project Engineer in a letter to John P. Durr, P.E., Regional
Sanitary Engineer, Region VI, Department of Health noted that this enlargement
and other aspects relating to the modification of existing facilities and the
installment of new equipment was described in the basic data.

" In summary," Grumbling said, " the existing sewage treatment facilities are to
be enlarged and modified to provide for separate sludge handling facilities and
more efficient final settling facilities."

According to Grumbling, nearly all the existing mechanical equipment would
need to be replaced plus a majority of electrical appurtenances.

***   ***   ***

At the time of the DRBC hearing, the disposal plant's then existing graded
capacity was 17.3 mgd under normal operating conditions, but in wet weather
or under emergency conditions the plant could process 20 mgd.

We note --- this is the same graded capacity that the plant was designed to
eventually service when it went into line November 29, 1929 at a cost of $1.5
million.

Thus, Allentown in going before the DRBC sought approval for an anticipated
graded capacity of 28.5 mgd at its expanded plant which could possibly reach
31 mgd under wet and emergency conditions. We have already learned that this
expansion of graded capacity was necessitated by commitments Allentown
made with its adjacent municipalities.

A point that provoked DRBC inquiry was the City's plan to pierce its protective
flood control dike with a 72-inch outfall pipe.

The pipe would convey treated sewage to a point along the west bank of the
Lehigh River. A 150-foot berm or diversion wall would be constructed in the
river at a 40o angle to direct the effluent to deep and fast moving water.

The DRBC wanted assurance that this pipe was properly engineered to provide
for or assure proper dilution. The berm would be needed particularly as
insurance to aid in the guarantee of proper dilution when the river becomes low
during dry weather or the level is generally lowered as a result of the collapse of
dams downstream.

***   ***   ***

A special note concerning the Treatment plant's original design. Basically, the
original designers of the Allentown Sewer System (City Engineer Earle Meckley
and Consulting engineers Metcalf & Eddy of Boston) used gravity feed sewage
technique to convey wastewater to the plant.

The City began with the gravity feed plan for two reasons:

1. It was cheaper to operate; and
2. It was adaptable to the terrain of Allentown.

The location of the treatment plant was decided upon due to the geographic fact
that a natural vein of rivers and creeks run "downhill" as they flow through the
city toward the Kline's Island site which incidentally was just about the lowest
point in the city.

As stated in a Morning Call report of June 9, 1963: "The larger the city grew, of
course, the more difficult became the engineer's job of surveying the slope,
figuring the height or depth of the pipe, ascertaining where trunk lines could be
placed in the proper direction --- toward the disposal plant --- and working out
connecting lines."

The report also demonstrated that preliminary "paper work" contributes the
chief headache in the development of gravity feed or flow systems. The impact
of twisting and uneven terrain often leads to strange decision-making
concerning solutions to flow problems. Sometimes sewage lines are placed in
an alley instead of along the front street. Sometimes pipes run in apparently
illogical fashion to effect the right flow toward the treatment plant. Example, to
effect a south flow, pipes may have to start going north until they can connect
with a line which runs along the proper slope of the terrain.

INSTALLMENT NINE

Historically, Genevieve Blatt was the main speaker at a meeting held October 7,
1957 and sponsored by the still existing Tri-City Conference. Her appearance
being calculated by the organizers to stimulate regional interest in regard to
inter-governmental cooperation in the development of necessary economic
development infrastructure.

This thought being acted upon regionally the last thirty years, not without
problems and disputes.

Clearly, if Allentown, Lehigh County and the region fail to responsibly find
solutions to existing environmental and economic problems related to
economic development, utility infrastructure development and operations, then
the following scenario not considered by Blatt as a possible end result in
regional development might become an unfortunate reality.

That is, this sudden rush of the Lehigh Valley from infancy to adolescence to
premature adulthood could lead to a dramatic decline into maturity and senility
in rapid succession if the destruction of moral considerations from uncontrolled
and mismanaged economic development schemes become too severe to be
corrected within acceptable monetary limits. Thus, in the end the region could
see a downward turn in population both in the City and the suburbs. The end
result being that higher taxes of services forced upon us by ambitious and
short-sighted individuals would demand a higher burden of support from those
individuals and business establishments that remain in the area.

The truth being, many are earning their living today financed by local bond
issues and obligations, which are probably paid from the pocket books of
mortals not yet born.

***   ***   ***

However, in the year 1967, the above was of little concern or consequence to
officials in responsible Lehigh County regional public positions. Their thoughts
being primarily attuned to the prospect of Lehigh County's present and future
economic expansion, giving little thought as to the negative alternatives.

Certainly overlooked for the time-being was the outward expression of
disappointment and determination that overtook certain individuals upon
learning that the Lehigh Valley region had been passed over as a site for a
important multi-dollar federal health center in January, 1965.

Please note --- a nineteen member working committee was hastily created to sell
United States Department of Health, Education and Welfare officials concerning
the advantages and desirability of locating the $25 million federal health center
in the Lehigh Valley area. The committee comprised representatives of the
Lehigh Valley Industrial Park, the Industrial Development Corporations of both
Lehigh and Northampton Counties, the Chambers of Commerce's in Allentown,
Bethlehem and Easton, and from various industrial firms.

But as analyzed by John W. Traunch, Executive Director of the Industrial
Development Corporation of Lehigh County, the valley's concerted effort came
much too late. He said:

"We were coming into the ballgame in the last half of the ninth inning. We know
we were late) in applying) and (consequently) at a disadvantage with areas that
(already) had been under consideration. We thought it meant so much to
whatever (area) community (that) gets it that we felt we had to (go ahead and)
get it in this area."

Trauch, of course, was referring to the fact that 40 localities in nine states had
made bids for the health center project since it was first advance in 1961. The
fixed reality being that the working committee that promoted the Lehigh Valley
bid was belatedly organized in November 1964.

Inevitably the thought would occur to disappointed committee members that the
area's Washington based representatives had been negligent in informing
proper authorities early concerning the status of the federal health center
project. For example, Frank L. Marcon, President of the Lehigh Valley Industrial
Park, stated:

" We have representatives in Washington who should know these things are
going on. They should have let us known so the good citizens of the Lehigh
Valley could have done something about it."

Marcon, of course, believed that the Lehigh Valley had everything the health
center would require. Marcon went as far to suggest that the Lehigh Valley was
the "hot" area in terms of growth in the entire eastern United States.

I. Cyrus Gutman, President of the Industrial Development Corporation of the
Lehigh County, agreed with Marcon. But on an upbeat note he stated:

" I am grateful for and enthusiastic about the manner in which all segments of
our great Lehigh Valley community reacted and can only feel that the continued
collective spirit will help develop the full potential of our growing and fertile area.
I want to thank every member of the committee for the work he has done."

This belief also supported by John W. Trauch who stated:

"The extraordinary fine cooperation exhibited by the Chambers of Commerce’s,
the ID agencies and many other (individuals and agencies) throughout the
Lehigh Valley area is certainly tangible reward for our efforts in endeavoring to
attract the health center in our area. All of us, I am sure will continue to work
together to attract new industry to the Lehigh Valley."

***   ***   ***

As it happened, these concerned individuals and agencies continued their
efforts to bring new industry into the Lehigh Valley despite the setback of the
location of the new federal health center in the Raleigh-Durham-Chapel area of
North Carolina. This long-range objective quite naturally being pursued by
promoting the construction and availability of utility infrastructure necessary for
enhanced industrial, residential and commercial development.

Importantly, such activity provided the incentive for economic development
utility infrastructure planning in western Lehigh County. For example, the
Lehigh County Authority was quietly formed by the Lehigh County
Commissioners in 1966 as an agency to prepare plans to transmit water from
the then proposed Trexler Dam to serve anticipated western Lehigh County
water needs.

In 1966,County and local officials additionally provided the need to coordinate
local government activities to achieve important regional economic
development objectives and have in place necessary economic development
utility infrastructure. Consequently, the Lehigh County League of Local
Governments was formed to provide an important exchange of information
between local governmental units’ inorder to facilitate the above stated
purposes.

Please note --- the first President of the Lehigh County League of Local Officials
was South Whitehall Township Supervisor and PP & L Executive Ralph C.
Swartz.

Of historical importance, elected officials of Allentown, eight boroughs, and 15
townships attending the first annual meeting of League February 20, 1967 in the
Lehigh County Courthouse were given a hastily delivered preview of a massive
plan for water supply and sewage treatment as prepared by the Joint Planning
Commission of Lehigh --- Northampton Counties.

According to the plan, 533,000 people would be served by water and sewer
systems by the year 2020 in Lehigh County. This was double the County's then
existing population in 1967. Financially the systems would cost an estimated
$71 million for water and $116 million for sewers.

The plan taking into account supplies of water which would be made available
to Lehigh County with the construction of the Trexler Dam by the U.S. Army
Corps of Engineers. The best engineering estimates on the water supply from
the dam being 50 million gallons a day.

League President Swartz, also serving as chairman of the Lehigh County
Authority, informed League members what steps the authority had taken to
advance or bring the dam project into reality:

1. A request by the Authority was made to the Delaware River Basin Authority to
guarantee future water withdrawals from the dam's reservoir for the Lehigh
County community:
2. A request by the Authority was made for federal grants to conduct a
preliminary feasibility study to justify the County's immediate and future needs
for dam water withdrawals so as to give the Trexler Dam greater priority for
construction and satisfy Delaware River Basin Commission regulations; and
3. A request would be made by the Authority March 9, 1967 to initiate
engineering studies and address the issue of financing required water utility
infrastructure.

Swartz then informed League members that when the above steps are
completed, the Authority would then be in a position to meet with local
governments on their water needs.

***   ***   ***

Please note --- in regard to needed water resources, Lehigh County fell under
the regulations of the Delaware River Basin Commission. In October 1964 the
Delaware River Basin Commission proposed changes and additions to its
comprehensive plan that could delay or conceivably hasten construction of
three major water control projects affecting the Lehigh Valley area.

The three projects --- Trexler Dam, a flood control reservoir projected by the
Army engineers for the Jordan Creek northwest of Allentown --- Aquashicola
Dam, proposed at the junction of the Aquashicola and Buchwha Creeks, and
originally proposed for completion in 1981 --- Francis E. Walter Dam, located on
the Lehigh River northwest of White Haven, scheduled to be enlarged by 1989.

The proposed amendments would set up a priority list for its major reservoir
projects in place of using uncertain target dates. The objective of the
Commission being to eliminate unnecessary workload by pursuing projects
when justified instead of as determined by arbitrary dates, which might have
been based on wrong assumptions. Then too, the Commission under new
regulations would require sanitary wastes discharged into the ground or
surface waters in the 13,000 square mile basin be treated at least to remove all
solids or materials which could reduce oxygen content of streams.

As explained by James F. Wright, Executive Director of the Delaware River
Basin Commission, the Army Corps of Engineers in its original study put some
dates on which certain projects might be undertaken. But Wright states:

"These are statistical projections of water supply requirements which need to
be backed up by the development of genuine demand for water. This takes a lot
of doing. We have to talk to enough prospective customers (individual,
industrial, institutional and a variety of other types) so that it can be determined
that the nonfederal costs can be reasonably be expected to be undertaken by
the direct beneficiaries."

Interestingly --- the proposed DRBC regulation to remove the target date for the
construction of Trexler Dam and build it when justified was objected to at a
public hearing in Philadelphia January 13, 1965 by Donald S. Lichty, an
engineer for the Allentown Water Bureau and Kenneth E. Harte of the Lehigh
River Restoration Association and the Federation of Sportsmen’s Clubs of
Lehigh, Northampton and Carbon Counties fearing a delay in the project.

The Commission rebutted by claiming its proposed changes and additions to
the plan could conceivably hasten the start of construction of the Trexler Dam
(originally planned for completion by 1972) if found justified.

But according to Lichty, while agreeing that construction activity for the Trexler
Dam should follow the completion of the Beltzville Dam project, Allentown still
wished to have a more definite assurance of a target date for the Trexler project.
Lichty stated:

" The flood control aspects of this project are of vital interest to this city in as
much as one of its industrial areas is located on the Jordan Creek, downstream
from the proposed dam and remains vulnerable to and has experienced severe
flood damage."

Harte told the Commission the dam could conceivably be delayed to a point
where water shortages would result along the Lehigh River and its tributaries.
But he spoke in favor of the Commission proposal to stiffen requirements for
sanitary waste dischargers into waters that feed the Delaware. His main
concern was that these regulations did not go far enough. Harte believed that
Commission regulations have provided for the treatment of "all other forms of
waste" which can be discharged into the surface or ground waters of the Basin
and which would operate to nullify the benefits of the proposed DRBC water
quality program of mandatory primary treatment of all sanitary wastes
discharged into basin waters,

SUMMATION

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.

With great anticipation concerning the benefits of promised economic growth in
the region, the City of Allentown and its Authority with the aid of Metcalf & Eddy,
Boston completed design work for the enlargement of its Kline's Island
Wastewater Treatment Plant.

However, before actual construction activities could begin, the City was
required by law, regulations or compacts between the States to receive
approval or permits from the following federal and state agencies:

*** The U.S. Housing and Home Finance Agency which would provide
Allentown with a $108,000 design loan;
*** The U.S. Public Health Service which would provide Allentown with a
$981,000 grant;
*** The U.S. Army Corps of Engineering;
*** The Pennsylvania State Sanitary Water Board;
*** The Pennsylvania State Department of Forests and Water;
*** And, the Delaware River Basin Commission.

The receipt of a permit from the State Sanitary Water Board (transmitted by
Floyd O. Collins Jr., Chief of the Staff, Service section, Division of Sanitary
Engineers, Harrisburg) constituted the final of six authorizations needed in
order to move the project. Consequently, Lloyd E. Grammes, Allentown City
Councilman and Director of the Allentown Department of Streets and Public
Improvements announced October 21, 1965 that the City was in a position to
advertise for bids for expansion of the sewage treatment plant at Kline's Island.

Construction work at the facility was completed in 1968. Interestingly, Grammes
was no longer on Council or Director of the Department of Streets and Public
Improvements for the dedication of the new wastewater treatment facilities with
its added capacity. In Grammes's place was rookie councilman and electrical
engineer Joseph S. Daddona.

The 1968 construction activity included: addition of a mechanically cleaned bar
grit; the replacement of four pumps in the main pumping station; the addition of
a new grit dewatering facilities; the conversion of the former Imhoff Tanks to
Primary Settling Tanks with sludge withdrawal and scum skimming equipment;
the addition of sludge thickening digestion, conditioning, and dewatering
facilities; the addition of new Final Settling Tanks; and the addition of
chlorination facilities.

Surely, one would think that with all the required review by federal and state
agencies that problems in design and motivation would be uncovered and
corrected. But as they say, it is always the ignored or the overlooked that
causes problems.

One must wonder if these six federal and state agencies were ever told that the
1968 expansion work would most likely be a building block for future
enlargement in light of plans that would be developed by state, county, borough
and township officials in communities to the west of those who entered
agreements with Allentown in 1959 and 1965. If not, then that might be the
source of the lack of vision that affected the future.

***   ***   ***

The involvement of political neophyte Joseph S. Daddona in the regionalization
of the Allentown wastewater treatment system and his contact with Arthur L.
Wiesenberger was introduced in the PREFACE of PART THREE of this work We
Present the Truth, But You Don't Comprehend. Daddona was in the first year as
Director of the Allentown Department of Streets and Public Improvements (1968).

The progressing installments, of course, in no way, involved any discussion of
Joe Daddona who in 1965-66 was building a political base by serving as the
President of the Allentown Jaycees. The Jaycee platform for those years
included the concept of bringing Shad back into the Lehigh River, Fluoridation
of the Allentown drinking water, and surveying the needs of the City's children.
Still, the installments are relevant and logical to this study because these years
were the years that Joe Daddona's political interest and political philosophies
were incubated; and more importantly, these years established the base from
which Joe Daddona proceeded in guiding water and sewer requests and
solutions which up to this day continue to cost millions of dollars for corrective
odor control and storage measures.

***   ***   ***

The ambitious, upward moving young professionals that comprised the
Jaycees under Daddona's stewardship regarded themselves as the visionaries
of Allentown's future development. For better or worse, these visionaries
sought to reshape the City.

An important element in this reshaping was the successful Jaycee petition
campaign that forced on the November 1966 ballot the following referendum
question: " Shall a Charter Commission of 12 members be elected to study the
Charter as to form of government of the City of Allentown and to consider a new
Charter to make recommendations therein?"

It is no secret that the petition campaign in support of an Allentown Government
Charter Study Commission did not have the tacit approval or the cooperation of
the seated Allentown government.

In November 1966, the Allentown electorate approved the creation of an
Allentown Charter study Commission by a margin of 4 to 1. At the same time two
slates of candidates vied for the non-paying post of Allentown Government
Charter Study Commissioner.

The slate known as Citizens for Efficient City Government (CEFG) included:
Joseph S. Daddona, George Feldman, Nicholas C. Fragnito, James M. Huebner,
Erling N. Jenson, John Marushak Jr., William J. O'Donnell Jr., Dr. Conrad N.
Raker, Anthony R. Thompson, Dr. Clifton H. Trexler, J. Bowling Wills and Mrs.
Vivian W. Zeitz.

The CECG campaigned on the claim that it had no preconceived notion on what
system would be best for Allentown.

Opposing the CECG was a slate of candidates said to have the blessing of City
Council and the political forces of the community. This slate believed the
members of the CECG were politically naive and asserted that such an
important discussion that the CECG desired affecting the city government
should be delegated to those who are conversed with the political facts of life.

This slate included the following individuals: Attorney Robert C. McFadden,
Clayton O.P. Werley, Arthur L. Wiesenberger, Irving L. Sherman, Alan F.
Weinsheimer, Harry C. Weisel Jr., Sol R. Coller, Frank Toman, Theodore T.
Trexler, Arthur H. Marshall, Paul W. Rubrecht and Frances L. Hobbs.

Interestingly, the entire CEFG slate captured all the Commissioner seats despite
the fact that the two slates were intermixed on the ballot rather then appearing
separately.

The Commissioners ultimately recommended that the existing Commission
form of government be scrapped in favor of a Strong Mayor form of government.

The Commission form of government called for an elected Mayor with no
special voting powers on City Council and whose function was not separate
from Council. Council would comprise the Mayor and four at-large elected
Councilmen whom also serve as full-time department heads. The Strong Mayor
form of government on the other hand consisted of an Executive Branch of
government headed by the Mayor and a Legislative Branch comprising Council,
but he has the power to veto Councilmatic legislation. Council consisting of
seven part-time elected at-large representatives known as Councilmen (excuse
me -- Councilpersons) can override the Executive veto by 2/3rds vote.
Department heads are appointed by the Mayor with approval by Council.

***   ***   ***

As we look from our vantage point in the future and view the so-called political
maturity of those whom advocated the Strong Mayor form of government, we
can't help but recall the wisdom of Franklin Kuhns, now deceased but at one
time an active member of the neighborhood movement and a former President
of the Allentown Community of Neighborhood Organizations. At a convention of
the National Association of Neighborhoods in Pittsburgh Kuhns mused
concerning the neighborhood movement the following statement:" " Accepting
the fact that yesterday's liberals become tomorrow's conservatives, we face the
fact that legalizing and institutionalizing community groups will only hasten that
development. Today's community groups will become tomorrow's
establishment. But thank God, tomorrow's liberals will arise to challenge us."

Franklin Kuhn's axiom certainly holds true on the municipal level for the
reformers of 1966-67 and the allies past and present have become the
establishment. The Strong Mayor government in which they embraced has
become highly bureaucratic and has fallen prey to the siren lure. This is ---
program and financial decisions are often based upon the known availability of
grant money whether the source be federal, state or foundations rather then the
acknowledged and real long-term needs of the community. In other words, if
money is available it will soon follow that an excuse or rationale for a given
program will be developed by city planners and grants people.

What then is the bureaucracies’ attitude toward citizen involvement in municipal
decision-making? Citizen participation in decision-making although publicly
encouraged by political leaders and there fore a policy obligation for the
supposive vassal-like bureaucracy is at the same time meant to be controlled to
meet short-term purposes of both the political leadership and the bureaucracy.

Quite naturally, it was by necessity to meet the terms of the new established
Community Development Block Grant Program that an Ad Hoc Committee for
Citizen Participation established by Allentown Mayor Joseph S. Daddona
created the Allentown Community of Neighborhood Organizations. Logistically,
the organization was supposed to be a front for Allentown's acquirement of
federal CDBG entitlement fund and a constructive advisor related to other
proposed city projects and decision-making that required citizen input. The
established political leadership and its necessary bureaucracy had not
anticipated the evolutionary development in CNO's function and purpose might
produce difficulties in maintaining the City's control over the citizen group's
agenda and also, its expressed positions on pertinent issues affecting the City.
Therefore, inorder to preserve its populist image and by political necessity the
inheritors of the reform movement of 1966/1967 aided and abetted the initial rise,
the mid-course turbulent interlude, and the neutralized re-establishment of CNO.

As a former President of CNO I can well remember the turbulent interlude period
of CNO. After all, my Presidency of CNO did not survive the 1981 turbulent
interlude. The turbulent interlude began when the City bureaucracy (many of
who had entered their Allentown government service by virtue of the federal
Comprehensive Employment Training Act grants program) attempted to control
the leadership of CNO Issue Committees out of displeasure with CNO publicly
expressed positions. It continued with the punitive but common sense correct
attempt by the then Republican Administration of Frank Fischl to cut CDBG
supported CNO funding. And, the interlude reached its culmination when
Joseph S. Daddona politicized his support for CNO by using it as an issue in his
campaign to regain the Mayor's office he had lost four years earlier to Frank
Fischl.

In regard to Daddona's destabilization of the CNO, I can remember a meeting of
the West Park Civic Association in March 1981 where candidate Daddona
openly promised to form a committee that would both look into the problems
that CNO had experienced since October 1980 and implement remedial action.
At the time, I mentioned to Daddona that with the CNO becoming incorporated it
was independent in function from the City. Daddona's remark then was that if
he could control who was on the board that he could control CNO. In my mind,
this suspected attempt by Joe Daddona to control the leadership of CNO began
with his primary victory. A mid-summer meeting of CNO Presidents in regard to
CNO's future structure was part of the Daddona effort to control CNO and
facilitate future policies as Mayor. It may not have occurred to Daddona nor the
people that helped Daddona organize the mid-summer meeting that the Mid-
Summer Meeting violated the CNO Bylaws. The responsibility for reorganizing
the CNO rested in its Board of Directors not the President's Council The
functions of the President's Council and its place within the CNO chain of
command established the Bylaws of April 1981 which were not recognized by
the Organizers of the Mid Summer 81 meeting.

To sum it up, if CNO (a government associated and created entity) was to exist
as an independent organization subsidized by CDBG entitlement funds, it was
to exist on Daddona's terms or not at all. CNO established in 1976 was formally
dissolved in 1987.

***   ***   ***

Joe Daddona more than any other political or civic leader can be associated
with the reform group or political machine that established the Strong Mayor
government. After all, as Jaycee President he involved himself strongly in the
campaign to put a Charter Study Commission question on the ballot. Becoming
part of the CECG team, the future Mayor was elected to the Allentown
Government Charter Study Commission. But quite interestingly, Joe Daddona
served but three months before seeking a City Council post in the old
Commission form of government claiming to be "the best choice for Council."

Responding to a 1983 question relating to his 1967 City Council bid, Daddona
recalled that he ran for City Council upon the urging of the Jaycees, the
leadership of the Democratic Party, and others active in the community. The
resignation from the Allentown Government Charter Study Commission was
prompted by a desire to avoid the appearance of a conflict of interest that would
negatively affect his candidacy. To explain --- Daddona was running for a
position that the Commission might choose to abolish or change when it made
its final report. Indeed --- Daddona had a point --- it would have been confusing
for a Candidate connected with the Charter Study Commission to run for a
council seat in the Commission form of government when the electorate would
be asked to approve a Study Commission recommendation to switch over to
the Strong Mayor system.

Interestingly, Daddona's early association with the Charter Study Commission
did not deter his supporters in political ads (November, 1997) from asking the
Allentown voter to " Let Joe Daddona Work full-time for them."

It was apparent that the Lehigh County Democratic Committee, whose chairman
was then Glenn R. Moyer, thought something special of Joe Daddona. Certainly,
the Committee went to great strides to assist the future Mayor's first council
campaign. In fact, the Committee suggested the prospect of greatness in its
candidate with the claim: " Every so often a man steps forward to lead, a man
who has the ability and experience expected of a great public servant. Labeling
Daddona as "such a man" it also labeled the candidate as "outstanding" and a
"proven leader."

Unfortunately, the man given credit has not performed up to expectations. The
legacy of Joe Daddona's years on council and his first Administration as Mayor
suggests a City that has suffered a loss of population and inadequate growth in
real estate base promoted by outside development operations that Daddona
promised to facilitate. A development which in the course of time has affected
the City's ability to provide services in such areas as parks and recreation,
health delivery, and police and fire protection.

Better that Joe Daddona never had met or heard the likes of Arthur L.
Wiesenberger and others whose disastrous growth schemes worked to spoil
Allentown's air and now threaten its water supply.

Why? They destroyed the promise that Daddona offers

Note --- After attending a September 1968 Conference related to sewerage
designed specifically for those communities located on the Little Lehigh
Watershed (Upper and Lower Macungie and the Boroughs of Macungie and
Alburtis) and exchanging communications with Arthur L. Wiesenberger,
Daddona used the services of his office to facilitate the western Lehigh County
venture. It was obvious that Daddona in his capacity as Allentown Director of
Stree6ts and Public Improvements asked Metcalf & Eddy, Boston, Allentown's
Engineering Consultant to prepare a feasibility study related to the need for
additional waste treatment facilities at Kline's Island. This report was received
December 9, 1969. Additionally, Daddona desirous that Wiesenberger's project
go forward requested the Allentown Authority to enter into an agreement with
Metcalf & Eddy, Inc. relative to the proposed enlargement of the existing sewage
treatment plant by Resolution No, 23222, adopted by City Council on December
16, 1969, and reached accord relating to wastewater treatment plant expansion
and reserved capacity allocation with the newly formed Lehigh County
Authority, December 22, 1969.

***   ***   ***

In analysis - let me now present the following analysis of Joe Daddona's place
in Lehigh Valley history as he began his third term as Mayor of the City of
Allentown.

The probability is good that Daddona's second term as Allentown Mayor did not
change is eventual status in Lehigh Valley history. The reason for this is
obvious. Preoccupied by political necessity to make repairs to a defective
system (that is, the Kline's Island Wastewater Treatment Plant) that has impaired
the quality of living in certain environmentally impacted areas, the Daddona
Administration would only expect to alleviate the damage not erase the damage.
The fact is, the second Daddona Administration by following a comprehensive
plan (whether conceived internally or externally or by a predecessor) could only
expect to return things as they were before Daddona started his service in
Allentown government. But this concept does not allow for enhanced livability,
which might have occurred had Daddona's original efforts or judgment been
adequate to deal with developments occurring in western Lehigh County. Nor
will it recover the tax dollars expended regardless of the source. To sum it up,
the second Daddona Administration has not constructed a new tower built
upon foundations of rock, rather it has made repairs to a tower set in
foundations of sand. Hopefully, such repairs would add strength to the sand
foundations of the tower, but such repairs will never produce granite from
cement.

Daddona, in fact, is one politician by clever manipulation of the media has
created an image that certainly does not stand up to historical evaluation. We
are told that there is time and method to every enterprise, but just the same, man
is greatly troubled by ignorance of the future and what it will bring.