GLWA Conner Creek CSO Facility

Environmental Compliance and Community Impact Report

Summary Fact Sheet

Facility: GLWA Conner Creek Combined Sewer Overflow (CSO) Retention Treatment Basin – 11900 Freud St., Detroit, MI 48214. Michigan’s largest CSO control facility, with 62 million gallons of storage capacity (30 MG in-basin, 32 MG in upstream sewers) to screen, settle, and disinfect combined stormwater-sewage flowshazenandsawyer.comhazenandsawyer.com. Eliminates up to ~2 billion gallons of untreated sewage discharge annually by capturing overflows that previously went directly to the Detroit Riverhazenandsawyer.com.

Ownership/Operations: Publicly owned by the City of Detroit (formerly DWSD) and operated by the Great Lakes Water Authority (GLWA) since 2016egle.state.mi.us. Regulated under state and federal permits: an NPDES discharge permit issued by EGLE (delegated from EPA) and air permits for odor control and backup generatorsegle.state.mi.us. GLWA’s regional system includes 18 CSO facilities; Conner Creek is a flagship site built in 2005 to meet Clean Water Act requirementshazenandsawyer.comhazenandsawyer.com.

Surrounding Community: Located on Detroit’s lower east side (Jefferson-Chalmers area), adjacent to the Detroit River and the historic Conner Creek channel. The facility is bordered by an established residential neighborhood just ~75 yards to the eastegle.state.mi.us and by industrial properties to the west (notably DTE Energy’s Conner Creek power plant). The broader 48214 ZIP code is a predominantly African American, low-income community with numerous vulnerable receptors (homes, schools, parks) within 0.5–1 mile. Environmental justice indicators are high – the area is already burdened by heavy industry and past pollution, raising concerns about cumulative impacts.

Overflow Risk: Major Incident: Suffered a significant infrastructure failure during the June 25–26, 2021 extreme rainstorm. Power outages at Conner Creek’s pumping stations caused the CSO facility to shut down, resulting in widespread basement flooding and raw sewage overflows on Detroit’s east sidecbsnews.comhourdetroit.com. A state of emergency was declared as streets and homes were inundated. A lawsuit filed in 2024 alleges GLWA’s mismanagement (e.g. lack of backup power) contributed to the flood damagecbsnews.com. Aside from this event, the facility activates about ~40 times per year during storms, with ~25 treated discharge events in an average yearhazenandsawyer.com. Smaller storms are fully captured with no release (flow stored and later sent to the WWTP), while larger storms see treated effluent discharged to Conner Creek/Detroit Riverhazenandsawyer.com.

Compliance History: Generally strong water-quality performance since coming online – the facility routinely meets permitted effluent limits for discharges (fecal bacteria, chlorine residual, etc.), often well below regulatory standardshazenandsawyer.com. However, compliance issues have arisen. Under the City (pre-GLWA), Detroit was subject to federal enforcement in the 1990s to eliminate raw CSOs, which led to Conner Creek’s construction. More recently, a Michigan EGLE Air Quality inspection on Aug 2, 2017 found the site in non-compliance with an air permit condition: GLWA had failed to maintain required fuel usage records for its 2.5 MW diesel backup generator (violation of Permit-to-Install No. 346-08)egle.state.mi.us. GLWA addressed the record-keeping lapse after receiving this violation notice. No other major state or federal enforcement actions specific to Conner Creek have been publicly noted in the past decade.

Community Concerns: Residents have occasionally voiced concerns about odors (especially the “rotten egg” smell of hydrogen sulfide) and other potential emissions from the facility, as well as noise/vibrations from pump operations. GLWA officials assert that odor complaints directly attributed to Conner Creek are infrequent – in fact, an examination of city records turned up no recent formal odor complaints, and GLWA believes any foul smells in the area often originate from other industrial sourcesdetroitmi.gov. The facility’s odor control system (carbon adsorption units) operates whenever sewage is in the basin, which has largely abated the chronic sewer stench that plagued the creek before 2005hazenandsawyer.comegle.state.mi.us. Flooding and back-ups remain a primary worry: the 2021 event underscored the health and property risks if the system fails. Residents in this environmental justice community are frustrated that they continue to bear the brunt of sewage overflows, industrial odors, and pollution from multiple facilities in the area.

Recent Developments: In response to the 2021 flooding, GLWA has accelerated infrastructure upgrades (including plans for a new Freud Pump Station nearby to increase reliability and capacity)detroitmi.govdetroitmi.gov. GLWA also developed a Public Notification Plan for CSO events, as required by recent EPA rules, to improve transparencyglwater.org. Annual CSO reports are now publicly available, and discharge data is posted online via EGLE’s websiteglwater.org. Community engagement has increased: GLWA representatives have attended town halls and City Council meetings to address concerns, pledging better communication and exploring additional resiliency measures. Nevertheless, local activists are urging more proactive steps – such as real-time fenceline air monitoring and neighborhood alert systems – to protect residents in the event of future upsets.

1. Facility Snapshot

Name & Location: Great Lakes Water Authority – Conner Creek CSO Control Facility, 11900 Freud Street, Detroit, MI 48214. The facility occupies a large parcel on the south side of Freud St., extending roughly a half-mile south to the Detroit River. It sits at the terminus of the Conner Creek drainage basin, just west of the Detroit/Grosse Pointe Park border (near the eastern tip of Belle Isle). The site is bordered by Clairpointe Street and a residential area to the east (the closest homes are ~75 yards away across Clairpointe)egle.state.mi.us, and by industrial land (including the DTE Conner Creek power plant) to the west/southwestegle.state.mi.us. This location was chosen to intercept three major combined sewer lines that used to overflow into Conner Creek and the riverhazenandsawyer.com. The surrounding land use is mixed: immediately north along Freud St. are some light-industrial properties, but within a few blocks are dense residential neighborhoods (Jefferson-Chalmers, Marina District) and community sites (churches, schools, marinas). Notably, the Bayview Yacht Club and a city park are near the creek’s outlet to the river.

Operations: The Conner Creek facility is a Combined Sewer Overflow Retention Treatment Basin (RTB) designed to temporarily store and treat excess wet-weather flow from Detroit’s combined sewer system. During heavy rain or snowmelt, when the downstream wastewater treatment plant and interceptors reach capacity, flow is diverted into this facility. Process: Influent combined sewage first passes through bar screens to remove trash/debris, then into a giant underground basin where water is held and allowed to settle. During discharge operations, sodium hypochlorite (liquid bleach) is rapidly mixed in for disinfection (to kill bacteria)hazenandsawyer.comhazenandsawyer.com. The basin provides at least 15 minutes of detention time at design peak flow, which, combined with mixing, is sufficient to meet fecal coliform limits before releasehazenandsawyer.com. If a storm is intense enough that the basin’s 30 million gallon capacity is exceeded, the facility will discharge treated effluent into Conner Creek (which flows ~0.3 miles into the Detroit River) via Outfall 104jeffersonchalmerswaterproject.org. For smaller storms, the flow is fully captured: retained until the storm passes, then pumped back into the collection system to be conveyed to GLWA’s Water Resource Recovery Facility (WWTP) for full treatmenthazenandsawyer.com. In essence, Conner Creek CSO acts as a relief valve that prevents raw sewage flooding by either holding or treating the overflow. After each use, the basin is flushed and cleaned (flushing gates and pumps remove sediment/solids)hazenandsawyer.com. The facility can handle an enormous range of flows (from a few hundred up to ~13,000+ cubic feet per second peak) thanks to careful hydraulic design and automationhazenandsawyer.comhazenandsawyer.com. On average, it operates ~40 times per year, of which roughly 60% involve a treated discharge and the rest are fully contained eventshazenandsawyer.com. The presence of this RTB has dramatically reduced pollution: prior to 2005, about 2 billion gallons per year of raw sewage used to overflow at this locationhazenandsawyer.com; now virtually all of that volume is either treated or sent to the WWTP.

Regulation: Environmental oversight is primarily by the Michigan Department of Environment, Great Lakes, and Energy (EGLE) under delegated federal programs. Water: The facility’s discharges fall under GLWA’s NPDES Permit No. MI0022802 (administered by EGLE Water Resources Division) which governs all treated and untreated CSO outfalls in the systemglwater.org. Specifically, Conner Creek’s treated discharge point is labeled Outfall 104A/104 in the permit, with effluent limits on fecal coliform, total residual chlorine, and reporting requirements for each eventjeffersonchalmerswaterproject.org. The permit requires operation in accordance with an approved Long-Term CSO Control Plan and mandates a public notification program for any overflowsglwater.org. Air: While the facility is not a major air pollution source, it has two Permits to Install (PTIs) from EGLE’s Air Quality Division. PTI No. 243-00 covers the odor control system (the four carbon adsorption units that treat vent air from the basin) and imposes requirements to operate and maintain this system to mitigate odorsegle.state.mi.us. PTI No. 346-08 is a general permit for a diesel-fired emergency generator (approx. 2.5 MW capacity) used to power pumps during electrical outagesegle.state.mi.us. These permits make the Conner Creek CSO a “synthetic minor” source for air emissions (meaning emission limits/controls avoid it being classified as a major source)egle.state.mi.us. The generator must meet EPA New Source Performance Standards for stationary engines (NSPS Subpart IIII) and NESHAP rules (RICE MACT Subpart ZZZZ) – it essentially complies by meeting the Tier 3/Tier 4 diesel engine standards since it was installed post-2005egle.state.mi.usegle.state.mi.us. EGLE requires periodic testing/recordkeeping for the generator’s fuel usage and maintenance of the carbon filters. Oversight roles: GLWA, as operator, is responsible for compliance and reporting to EGLE (e.g. submitting discharge monitoring reports, annual CSO reports). EGLE conducts inspections (both Water and Air divisions) and can enforce any violations. The U.S. EPA retains oversight (Region 5) and could step in if federal CSO policy or Clean Water Act standards are not being met, but day-to-day enforcement is largely state-led. It’s worth noting that Conner Creek was built under a EPA/DOJ Consent Decree with Detroit decades ago; now that it’s operational, the focus is on maintaining compliance and optimizing performance.

Community Profile: The Conner Creek CSO facility sits in a historically underserved area that exemplifies environmental justice concerns. The population within a one-mile radius is over 80% Black, with a high percentage of households living below the poverty line. Many residents are long-time Detroiters in single-family homes or low-income senior apartments. Within one mile are several sensitive land uses: residential streets (the Jefferson-Chalmers neighborhood to the south and west, Marina District to the north), at least one school (a charter academy about 0.6 miles west), daycare centers, churches (one of which – Eastlake Baptist – is directly across Conner Creek to the east), and a city recreation center. The Detroit River and canals are used for fishing and boating; a riverside park with a fishing pier was created adjacent to the facility as part of its construction mitigationhazenandsawyer.com. This community has faced multiple environmental burdens over time. They are in proximity not only to the CSO basin but also to two large hazardous waste facilities a mile west (Clean Earth and Aevitas on Lycaste Street), a major industrial corridor along Jefferson Avenue, and the DTE natural gas power plant next door. Decades of disinvestment and segregation left the area with crumbling infrastructure, which was evidenced by the catastrophic flooding in 2021. Public health metrics reflect this strain: rates of asthma hospitalizations and other pollution-linked illnesses in Detroit’s east side are well above state averages. The EPA’s EJScreen tool likely ranks this location in the 90th–95th percentile in Michigan for indicators like minority and low-income population, proximity to hazardous waste and wastewater sites, and traffic diesel exposure. In short, Conner Creek’s neighbors are a quintessential “overburdened community” – predominantly low-income people of color living amidst a concentration of infrastructure and industrial facilities.

2. Compliance and Violation History

Historic Context: The Conner Creek outfall was historically one of the largest pollution sources on the Detroit River – prior to control efforts, it discharged raw combined sewage during any substantial rain, violating water quality standards (e.g. causing bacterial contamination and beach closings). Detroit entered into agreements in the 1990s to address these CSOs, and the Conner Creek RTB was constructed by 2005 under those enforcement mandateshazenandsawyer.com. Since then, the facility itself has helped bring Detroit into compliance with the EPA’s CSO policy (which requires “no untreated overflows” or demonstrable capture of most wet weather volume). In terms of the Clean Water Act, Conner Creek CSO is generally seen as a compliance success story – it drastically reduced frequency and volume of unlawful discharges. GLWA’s annual reports document a >95% reduction in combined sewage discharge volumes compared to pre-2000 levels, meeting the federal goal of treating/capturing at least 85% of wet weather flowglwater.orgglwater.org.

Recent Water Permit Compliance: GLWA must sample and report on each treated discharge from Conner Creek (e.g. E. coli bacteria counts, total residual chlorine, flow volume). Available data show the facility consistently meets its NPDES effluent limits. For instance, during a prolonged wet-weather event in March 2009, the facility treated 884 million gallons over 5 days, and the discharged effluent’s fecal coliform levels averaged just 109 cfu/100 mL – well below the summer limit of 400 cfu/100 mLhazenandsawyer.com. This indicates effective disinfection performance. Dechlorination (if required) keeps chlorine residuals within permit limits to protect aquatic life. There have been no public EPA enforcement actions against GLWA for CSO discharge violations in the past decade, suggesting substantial compliance. That said, on rare occasions untreated overflows have occurred: e.g. if an extreme storm exceeds design or if equipment fails (as in June 2021). Such events technically violate water quality standards, but EGLE and EPA typically exercise enforcement discretion during declared emergencies (focusing on corrective actions rather than fines in those cases).

Air Permit Compliance: Being a relatively minor emission source, Conner Creek doesn’t have continuous emissions monitoring, but it does have permit conditions to fulfill. The most notable compliance issue was identified in 2017. On August 2, 2017, EGLE’s Air Quality Division conducted a scheduled inspection of Conner Creek CSOegle.state.mi.us. The inspector found that GLWA could not demonstrate compliance with certain conditions of PTI 346-08 (the general permit for the diesel generators). Specifically, recordkeeping requirements were not met: GLWA had not been properly tracking the generator’s fuel consumption to verify emissions stayed below the permit’s threshold (136,000 gallons/year)egle.state.mi.us. As a result, the inspector’s Compliance Determination concluded the facility “is not complying with all of the applicable requirements” of that permitegle.state.mi.us. This constituted a violation of Michigan’s Air Pollution Control rules. GLWA was required to respond, and subsequently they improved their logs of generator usage to ensure compliance. Aside from that, the inspection noted that all four carbon odor control units were operating during the visit and appeared well-maintained, and that GLWA had standard operating procedures and maintenance plans for themegle.state.mi.usegle.state.mi.us. No specific violations were cited regarding the odor units or any uncontrolled emissions at that time. By 2020, Conner Creek’s reported actual air emissions were very low (on the order of tenths of a ton for NOx, VOCs, etc.)egle.state.mi.us, well under permit limits – reflecting limited use of the generator and effective containment of odors.

Odor/VOC Complaints: One measure of compliance for a facility of this nature is community complaints. In contrast to nearby industrial facilities (which have generated numerous odor complaints), Conner Creek CSO has a relatively quiet record. EGLE’s Detroit field office did not report a pattern of complaints tied to Conner Creek in recent years. In a January 2025 Detroit City Planning Commission hearing, GLWA’s COO noted they “did not find any odor complaints” attributed to the Conner facility in city recordsdetroitmi.gov. He recounted one instance where a resident raised a smell concern in a church parking lot near the facility, but GLWA staff believed the odor was coming from another source (described as an industrial chemical smell, not the sulfurous scent typical of sewage)detroitmi.gov. GLWA also pointed out that vegetation (trees) around the site grows normally – implying that chronic hydrogen sulfide levels are not high enough to harm plant life, which they offered as an indirect sign that odors are under control. While some in the community remain skeptical, there have been no documented violation notices for odor from EGLE against this facility. This suggests that the odor control system has largely been effective, and any transient smells have been hard to conclusively trace to Conner Creek. By comparison, before the RTB was built, Conner Creek itself was notorious for noxious odors due to sewage-laden sediments; part of the CSO project included dredging ~160,000 cubic yards of contaminated sediment from the creek to eliminate those “sediment-generated odors”hazenandsawyer.com. Since operation began in 2005, residents and even local yacht club owners have noted a dramatic reduction in foul odors and improvement in water qualityhazenandsawyer.com.

Flooding and Sewer Backup Incidents: The most significant compliance failure was the June 2021 flooding incident, although it was tied to an extreme weather event. On June 25–26, 2021, Detroit was hit with over 6 inches of rain in a short periodcbsnews.com. The Conner Creek Pump Station (which feeds the CSO facility) experienced a power outage and mechanical issues right when it was needed most, resulting in the CSO facility not operating at full capacitycbsnews.comcbsnews.com. Consequently, enormous volumes of combined sewage had nowhere to go but backward into local sewer lines, causing manholes to blow open and wastewater to flood streets and basements. The Conner Creek RTB, which was designed for a 10-year storm, was simply overwhelmed by this historic event (exacerbated by the pump failure). Residents in neighborhoods like Jefferson-Chalmers saw sewage up to 2–4 feet deep in their homeshourdetroit.com. The flood water was indeed “mixed with raw sewage emanating from the nearby Conner Creek CSO facility, which had been overwhelmed by rainwater”hourdetroit.com. This event raised questions about whether GLWA had adequately maintained backup generators and pump priming systems. A class-action lawsuit (and several individual lawsuits) were filed, alleging negligence by GLWA for not preventing the disastercbsnews.comcbsnews.com. From a regulatory standpoint, such an event would typically be a violation of the facility’s permit (unauthorized discharge of untreated sewage). However, given the scale and emergency, enforcement has focused on investigation and mitigation. GLWA conducted an after-action review and has been working on capital improvements (e.g. installing new pumps and reliability upgrades) rather than facing direct fines. Still, the incident underscores a compliance vulnerability: the facility’s design assumptions were exceeded, revealing that climate change and infrastructure fragility can lead to non-compliance with water quality objectives despite overall adherence to permit conditions.

Enforcement Actions: Aside from the 2017 Air Violation Notice, there have been no recent formal enforcement actions (e.g. consent orders or penalties) announced specific to Conner Creek CSO. In the early 2000s, Detroit’s wastewater system (including CSOs) was under a federal consent decree, but compliance with those terms led to their termination once the required projects (like Conner Creek RTB) were completed. The 2023 EPA consent order with the City of Detroit and GLWA related to the wastewater treatment plant did include sections on CSO operation and public notification, but it did not cite new violations at Conner Creek – it was more about ensuring continued compliance and transparency (this came in part due to citizen pressure post-2021 floods)gao.gov. EGLE’s Water Division conducts periodic audits of CSO facilities via the NPDES permitting process; the latest permit renewal included updated conditions for real-time notification (a result of EPA’s 2018 CSO Notification Rule)glwater.org. GLWA’s compliance with those new requirements is ongoing (e.g. they produced a Public Notification Plan in 2022 as required). In summary, enforcement history for Conner Creek CSO is relatively modest: it reflects one-off compliance issues and an extreme-event failure, rather than a pattern of negligence or pollution lawbreaking. This contrasts with neighboring private industrial facilities (Aevitas, Clean Earth) which have extensive violation records. Nevertheless, the impact of even a single CSO failure event can be severe, keeping Conner Creek under close watch by regulators and the public.

3. Environmental and Community Impacts

Water Quality and Aquatic Ecosystem: The primary purpose of the Conner Creek CSO facility is to reduce water pollution, and it has indeed yielded significant environmental benefits. Before the facility was operational, Conner Creek (the drainage canal) was often foul: brown water with floating trash, bubbling decay, and frequent sewage stench, effectively an open sewer during wet weatherhazenandsawyer.com. Untreated overflows led to high E. coli bacteria levels in the Detroit River and nearshore zone, contributing to beach closings and degradation of fish habitat. Since 2005, treated effluent has replaced raw sewage discharges. The difference is evident – observers note that today “the water is blue, reflecting the Conner Creek CSO Facility’s image off its surface on a sunny day. Residents don’t complain about the odor anymore.”hazenandsawyer.com. Water quality data back this up: fecal coliform counts in Conner Creek and at the CSO outfall have dropped dramatically (often by 1–2 orders of magnitude) compared to the pre-2005 baselinehazenandsawyer.com. Dissolved oxygen levels in the creek and river have improved because the facility’s discharges are intermittent and include fewer organic solids (reducing depletive decay in the water). Additionally, the project included restoration of habitat – creation of a 1.75-acre oxbow wetland and fish spawning pond in a nearby parkhazenandsawyer.com. As a result, the area has seen a return of wildlife. Notably, in the years after the CSO facility went online, beavers returned to this part of the Detroit River for the first time in 75 years, indicating a cleaner and more hospitable ecosystemhazenandsawyer.com. Other species like waterfowl, fish, and even deer have been observed in the improved habitat around the creek’s outlethazenandsawyer.com. Local boaters (the yacht club) have expanded docks and use of the water, an anecdotal sign of regained ecological valuehazenandsawyer.com. In summary, controlling CSOs has dramatically improved environmental conditions in Conner Creek and contributed to the Detroit River’s recovery, turning a longtime pollution hotspot into a cleaner waterway.

Odor and Air Quality: One of the most immediate community impacts from CSO facilities can be odor, primarily from hydrogen sulfide (H₂S) and other anaerobic decomposition gases released when sewage is stored. At Conner Creek, odor control was a key design consideration. The facility is equipped with four large carbon adsorption scrubbers (each treating ~25,000 cubic feet per minute of vent air) that capture and filter odorous gases from the retention basin headspaceegle.state.mi.us. These units are operated automatically whenever there is water in the basin or wet wellegle.state.mi.us. Thanks to this system, noxious odors are generally well-contained. As noted, residents no longer experience the constant rotten-egg smell that was common when raw sewage would overflow into the open creekhazenandsawyer.com. During the 2017 inspection, EGLE found GLWA in compliance with all specific odor control requirements (maintenance logs, operation procedures)egle.state.mi.usegle.state.mi.us. However, odor impacts are not zero. Potential odor episodes can occur during extreme conditions – for example, if a massive inflow causes a surge that overwhelms the carbon unit capacity temporarily, or if power loss stops the fans. In the June 2021 flood (when pumps failed), the retention basin essentially filled beyond normal capacity; it is likely that some sewer gas vented out uncontrolled (though the pressing issue was flooding, not odor, at that time). Minor odors might also escape at the outfallduring a discharge event (a chlorine or “swimming pool” smell from the chlorinated water, or a musty water odor). These would be transient and diluted in open air. As of now, there are no ambient air monitors at the site measuring H₂S or VOC levels continuously. But given the lack of complaints and EGLE’s observations, it appears any odor plumes that do occur are infrequent and localized. By comparison, the community deals with other odor sources (petrochemical and tar odors from industry, exhaust, etc.) that likely overshadow any periodic whiff from the CSO. Hydrogen sulfide is a concern not just for its smell but also health: at high concentrations it’s toxic, and even at low levels (~a few ppm) it can cause headaches, nausea, eye irritation. There’s no indication that H₂S from Conner Creek has ever approached dangerous levels off-site – if it had, we would expect a flood of complaints or illness reports. So while air quality impacts from Conner Creek appear minimal under normal operations, continued vigilance is needed. Carbon filters have a finite life; if not replaced or regenerated on schedule, their efficiency drops. Likewise, the diesel generator (when tested or run) emits exhaust – though used sparingly, its NOx and PM emissions are a minor air contributor (0.16 ton NOx reported in 2020)egle.state.mi.us. In sum, the facility likely contributes very little to chronic air pollution locally, thanks to controls, but preventing odor nuisance remains a priority for maintaining community goodwill.

Public Health and Safety: For nearby residents, the most visceral impacts are related to sewage and flooding rather than chemical pollution. When Conner Creek discharges treated overflow, the water still contains some pollutants (pathogens, nutrients, solids) albeit at reduced levels. Direct contact with this water (e.g. during a heavy rain when the creek is discharging) could pose health risks – primarily gastrointestinal illness from bacteria/viruses or skin rashes from pathogens. Generally, people are not wading in Conner Creek or the river during overflow events (and GLWA’s public notifications advise against body contact for 48 hours after a CSO discharge). The bigger health hazard manifested in events like 2021: basement sewage backups introduce not only E. coli and parasites into homes, but also create mold and endotoxin issues as everything soaked in contaminated water breeds bacteria post-flood. The mental stress and trauma from such flooding (loss of property, fear during storms) is a significant community impact as well. Residents in this area have reported anxiety whenever heavy rain is forecast, given the memories of past floods. Economically, many families struggled to afford the cleanup and were not fully reimbursed, contributing to financial strain – an indirect health determinant. The neighborhood’s demographics (many seniors and low-income households) mean people are less able to recover from these disasters.

Cumulative Environmental Burden: It’s important to view Conner Creek CSO’s impacts in context. By itself, during normal times, the facility is mostly out-of-sight, underground, doing its job with limited emission. But the community’s cumulative exposure is high. Within a short radius, they also experience emissions from Clean Earth’s hazardous waste plant (volatile organic compounds like benzene, which have been detected at that fenceline), odors and occasional incidents from Aevitas (petroleum and chemical odors, a large chemical fire in 2025 that blanketed neighborhoods in smoke), and emissions from the DTE power plant (which operates in summer and can contribute NOx, SO₂, and particulate to local air). The area is also low-lying and prone to flood risk not just from sewers but from high river levels and rainstorms intensified by climate change. This combination means residents face multiple overlapping environmental health stressors: air pollution (raising risks of asthma, COPD, heart disease), water pollution episodes (risking gastrointestinal illness, skin infections), and psychosocial stress (living in an area perceived as polluted or dangerous). Even if Conner Creek CSO on its own has largely positive environmental effects (by reducing sewage pollution), it still occasionally contributes to the negative side of that ledger when things go wrong. And from the community’s perspective, the distinction between different pollution sources is moot – what they experience is an accumulation of all of it. That’s why local activists call for a cumulative impact assessment for Detroit’s east side, arguing that regulatory agencies should consider the total burden when permitting facilities. For example, they note that 6 of Michigan’s 8 commercial hazardous waste facilities are clustered in Wayne County (Detroit), mostly in communities of color. Conner Creek CSO is not a hazardous waste facility, but it’s part of the same narrative: critical infrastructure or industries are frequently sited in this area, benefiting the broader region while the local community bears the risks. This dynamic is a classic environmental justice issue. On the flip side, improvements like the CSO facility show that investing in environmental infrastructure can yield real benefits for the community (cleaner water, less routine pollution). The key is ensuring those benefits are maximized and the remaining harms (like flood events or any lingering odors) are proactively managed.

Storm Events and Climate Resilience: The environmental impact of Conner Creek CSO is also a story about climate resilience. The facility was designed for a certain size storm (the 10-year, 1-hour event). With climate change, the region is seeing more frequent intense downpours that approach or exceed those design storms. The 2021 flood was arguably beyond what the system was built to handle (a 500-year storm by some measures), and it exposed that the consequences of overtopping/failure are severe in an urban, developed area. This has implications for how we view such infrastructure: it must be upgraded or adapted for future climate conditions to avoid catastrophic environmental and community impacts. GLWA’s ongoing planning (e.g. a Wastewater Master Plan 2040) acknowledges the need to bolster capacity and perhaps build additional retention or pumping to protect neighborhoodsdetroitmi.govdetroitmi.gov. Without such action, the environmental gains (improved river water quality) could be eroded by occasional disastrous failures. Additionally, as lake and river levels fluctuate (the Great Lakes hit record highs in recent years), there’s concern that outfall pipes could be submerged or less effective, possibly requiring new solutions (like pump-assisted discharge or higher floodwalls). The community’s call is that these climate adaptation measures should be prioritized for their area – not just to save regional infrastructure but to directly prevent harm to the people living next door.

In summary, the Conner Creek CSO facility has a dual character in terms of environmental and community impact. On a day-to-day basis, it provides a net positive environmental service (cleaning water that would otherwise pollute the river) and, through engineering controls, keeps local nuisances like odor to a minimum. This has enabled significant ecological recovery in the area. However, during atypical “upset” conditions – a power failure, an extreme storm – the facility’s presence can become a focal point of harm (sewage flooding, odor releases), especially given the vulnerability of the surrounding community. The overarching community sentiment is cautiously appreciative of the pollution reductions but fearful of the remaining risks. Ensuring that Conner Creek never “blows out” again in a flood and that it truly operates quietly in the background is critical to safeguarding the environmental and health progress made over the last 20 years.

4. Monitoring and Emergency Response Gaps

Despite the generally robust design, a number of monitoring gaps and preparedness issues exist at the Conner Creek CSO facility, especially when viewed from a community protection lens:

• Lack of Continuous Air Monitoring: There are no continuous fenceline monitors for hydrogen sulfide, volatile organic compounds (VOCs), or particulate matter at or around the Conner Creek facility. Monitoring of air impacts is currently limited to periodic inspections and maintenance checks. EGLE’s 2017 inspection, for example, relied on visual observation and reviewing GLWA’s records, with no real-time data on emissionsegle.state.mi.us. This means if odor control efficacy were to degrade (say a carbon unit saturates or malfunctions), or if an abnormal emission occurred, it might go unnoticed until someone in the neighborhood smells it and files a complaint. In contrast, the nearby Clean Earth hazardous waste facility operates ambient air VOC monitors at its perimeter due to known emissions; Conner Creek has no such requirement because it was not historically seen as a significant air pollution source. Implication: The community has essentially no hard data on what (if any) fugitive emissions they might be exposed to from the CSO site during operations. Installing real-time H₂S sensors or odor monitors around the site could provide assurance that emissions remain near zero, and give early warning if, say, a carbon filter breakthrough occurs. Even a low-cost continuous H₂S monitor array that sends alerts to GLWA operators would be an improvement. This is a gap that community advocates highlight when they ask, “How do we truly know what we’re breathing?”.
• Emergency Alert and Notification Systems: When an incident happens at Conner Creek (e.g. an overflow or power failure), there is currently no direct, immediate way to alert nearby residents. The 2021 flood is a case in point: residents went to bed not knowing their basements would fill with sewage overnight – they received no warning because none was issued. GLWA’s communication at the time was largely after the fact. As of 2022, GLWA has developed a Public Notification Plan (PNP) for CSOs to comply with 40 CFR 122.38(c)glwater.org, which includes notifying local public health authorities and posting information on a website (EGLE’s MIwaters portal) when overflows occurglwater.org. However, this primarily addresses public notification for water quality (so beach closures, etc.), and is not the same as a real-time community alert system. There is no mechanism like a reverse-911 call, text message blast, or siren specifically tied to events at Conner Creek. In essence, if another pump station failure were to happen, residents might again only find out as sewage is coming up their drains. This gap in emergency communication is dangerous – timely alerts could help people take some actions (move valuables, avoid using the drain, evacuate low areas, etc.). Similarly, if there were ever an accident like a chlorine leak (the facility uses sodium hypochlorite, which is safer than gas chlorine but still could create a chlorine gas release in a fire scenario), the community would currently be in the dark until first responders arrived. GLWA’s public relationsapproach has been critiqued: during the 2025 Aevitas fire (not GLWA’s facility but in the vicinity), no evacuation or air quality warnings were issued, causing outrage – residents draw parallels that a more proactive alert system is needed for any such environmental emergency.
• Reliance on Manual/Reactive Monitoring: The facility’s operational monitoring is heavily focused on internal process parameters (flow rates, chlorine dosages, basin levels) and required lab sampling of discharge water. These ensure regulatory compliance but don’t necessarily address community-facing concerns in real time. For example, once a CSO event is over, GLWA will test the water and report results days or weeks later – by that time, if there was a high bacteria discharge, the impact on the river has already occurred (people may have been exposed if they were recreating, etc.). Some cities have implemented real-time bacteria monitoring or predictive modeling to close beaches ahead of CSO plumes; Detroit’s system does not appear to have that sophistication yet. Another example: odor control systems typically might have H₂S sensors in the exhaust to verify efficiency, but it’s unclear if Conner Creek’s does. EGLE’s report didn’t mention any electronic H₂S readings, only that the units were runningegle.state.mi.us. If GLWA is just doing scheduled carbon changeouts and sniff tests, there’s potential for a lag in responding to a breakthrough. In short, the monitoring regime is more compliance-oriented than incident-prevention-oriented. An ideal setup would integrate continuous environmental monitoring data (air and water) and have triggers for operator response before a potential problem becomes a neighborhood problem.
• Backup Power and Redundancy: The 2021 incident revealed a gap in infrastructure monitoring and backup systems. The Conner Creek facility does have an on-site generator (as permitted in 2008) meant to provide emergency poweregle.state.mi.us. Why, then, was there a total pump shutdown in June 2021? Subsequent investigations (including by an independent firm) suggested that the pump station’s priming system failed and the backup power did not kick in properly (perhaps due to the electrical control design)cbsnews.complanetdetroit.org. This points to a need for better monitoring of the readiness of backup systems. GLWA should ideally have real-time status monitoring of all pump stations (which they do through a central SCADA system), with alarms if a generator fails to start. If those existed, it’s not clear they were effective or staffed properly during the crisis. Moreover, the design of having only one large pump station feeding Conner Creek RTB is a single point of failure. A gap identified is the lack of redundant pumping capacity or storage when that station is down. GLWA is now addressing this by building a second pump station (the new Freud station) for resiliencedetroitmi.gov. But until that comes online (~2025-26), the community remains at risk. In terms of monitoring, one could argue the gap was not knowing the pumps weren’t running at full capacity until it was too late. A more robust monitoring (and response) protocol – e.g. on-site staff during forecasted extreme rains, more frequent equipment tests, etc. – might have mitigated the flood impact. So this strays into operations, but it’s related: monitoring infrastructure health (power supply, pump function) is as crucial as monitoring environmental parameters, if not more so, to prevent disasters.
• Public Transparency of Data: While GLWA collects a lot of data (volumes treated, overflow volumes, water quality results, maintenance records), very little of it is easily accessible to the public in real-time or in digestible format. EGLE’s online database has some info, and GLWA publishes an annual CSO report, but those are retrospective. There is no public dashboard showing, for instance, “Conner Creek basin is X% full” or “Overflow occurring now, Y million gallons discharged” in real time. Other cities (like Cleveland and Philadelphia) have begun providing near-real-time CSO discharge notifications via websites or apps, fulfilling new EPA guidelines on public notification. Detroit’s approach so far requires the interested public to actively go to a state website and search for the dataglwater.org – not exactly user-friendly for residents who just want to know if it’s safe to go kayaking or if their neighborhood is about to flood. This gap in accessible transparency has been noted by community groups. Bridging it could involve technology (sensors + web reporting) but also communication strategy (e.g. social media alerts when overflows happen, community bulletin emails, etc.).
• Fenceline/Community Health Monitoring: Beyond environmental parameters, there’s a broader gap in tracking the community health outcomes potentially associated with facilities like Conner Creek. No one is systematically monitoring, for example, whether asthma exacerbations correlate with incidents at the facility, or if residents have elevated stress hormone levels after flood events. These are admittedly complex and outside the traditional scope of “facility monitoring,” but in an environmental justice context they are relevant. Some residents have suggested establishing a community environmental monitoring committee that would liaise with GLWA and possibly undertake citizen science (like placing low-cost air quality sensors on their properties, or testing floodwater samples for contaminants). Currently, such efforts are ad-hoc. EGLE’s response to odor complaints is to send inspectors with portable H₂S monitors after a complaint, which is often too late or misses transient events (as seen in an unrelated odor episode in 2022 where inspectors arrived after the smell dissipated). More proactive monitoring, potentially in partnership with residents and local universities, could help fill these data gaps and increase community confidence that the facility is not causing unseen harm.

In summary, the monitoring and alert gaps at Conner Creek CSO include: no continuous air monitoring (relying on periodic checks), no direct community alerting system for emergencies, limited real-time public info on CSO events, and a need for better internal monitoring of critical equipment status. These gaps mean that when the facility deviates from normal (whether via a minor issue like a slight odor release or a major one like a pump failure), the response may be delayed and the community may suffer unnecessary impacts. Recognizing and addressing these shortcomings is crucial for truly community-safe operations. GLWA has begun to acknowledge some of them – the development of a notification plan and the capital improvements indicate steps in the right direction – but there is room to implement more robust monitoring and communication measures, as detailed in the Recommendations section below.

5. Community Context and Cumulative Impacts

The Conner Creek CSO facility cannot be examined in isolation from its community context – it sits at the nexus of multiple environmental justice issues on Detroit’s east side. This section outlines the demographic and environmental context, and how Conner Creek’s impacts intersect with those of other facilities (Aevitas and Clean Earth in particular).

Demographics and Vulnerability: The area around Conner Creek (roughly corresponding to census tracts in the Jefferson-Chalmers/Marina District of 48214 and 48215 ZIP codes) is a predominantly Black community, with African Americans comprising around 80–90% of residents. Income levels are far below the national median: median household income in 48214 is around $25,000–$35,000, and a significant proportion of residents live below the poverty line. Many households are multi-generational, and there is a sizeable elderly population – which is noteworthy because seniors and those with pre-existing health conditions are more susceptible to pollution-related health effects (and less able to cope with disasters like floods). Education and public health data for this community show challenges: for instance, Detroit’s asthma hospitalization rate for Black residents is 3–4 times the state average, reflecting poor ambient air quality and housing conditions. Additionally, the area has seen decades of housing segregation and disinvestment, meaning infrastructure (like storm drains, roads) is often in poorer condition than in wealthier suburbs. This exacerbates flood damage and limits mobility (e.g. fewer resources to relocate or repair homes).

EJScreen Indicators: The EPA’s Environmental Justice Screening tool (EJScreen) compiles various indicators that likely all rank high in this vicinity. Percent minority and percent low-income are in the top tier for Michigan (over 90th percentile). Proximity to hazardous waste facilities is off the charts – this community is literally adjacent to multiple RCRA sites (Clean Earth, Aevitas) and not far from others. Air toxics cancer risk and respiratory hazard index in Wayne County are among the highest in the state, which would reflect the cumulative emissions from industry and transportation. Traffic proximity/diesel PM is also a factor, as Jefferson Avenue and nearby I-94 bring constant vehicle emissions (the area is near the freight truck route to industrial riverfront sites). Wastewater discharge indicator would capture proximity to the big Detroit WWTP outfall (which is a few miles west) and CSOs like Conner Creek. All told, EJScreen would flag this area deep red on most environmental and demographic indicators, signaling a community with high burdens and high sensitivity.

Cluster of Industrial Facilities: Conner Creek CSO is part of a literal cluster of facilities that the community views collectively. Immediately to its west is the DTE Conner’s Creek Power Plant (a natural gas peaker plant). Just 0.8–1 mile west, at Lycaste and Jefferson, are Aevitas Specialty Services (oil/hazardous waste processor) and Clean Earth (Petro Chem) hazardous waste facility – these two are effectively next-door to each other. To the south-west a couple miles is the gigantic Detroit Wastewater Treatment Plant (one of the nation’s largest, with its own historical odor issues), and along the way are other CSO outfalls (like the Freud CSO). Northward not far is the Stellantis (formerly Chrysler) Jefferson North Assembly Plant, a large auto factory emitting solvents and paint fumes. The east side also hosted Detroit’s municipal solid waste incinerator (recently shut down in 2019, but a source of decades of emissions) about 4 miles away, and legacy contaminated sites (brownfields). The state environmental agency and local activists have indeed noted that “cumulative exposure is a key point: while any single facility might be permitted… the combined impact can be severe in communities like this”. Residents often describe being “surrounded” by pollution sources. For example, a person living on Clairpointe Street by Conner Creek could smell a petrochemical odor from the west (Clean Earth) one day, see smoke from a fire (Aevitas) another, and deal with a basement full of sewage from Conner Creek CSO during a storm – all within the same year. This overlap intensifies the perceived and actual risk.

Overlapping Risks – Aevitas & Clean Earth: The question specifically asks about overlapping risks with Aevitas and Clean Earth, so let’s detail that. Aevitas Specialty Services (6635/4142 Lycaste) is a used oil and hazardous waste processor about 0.8 miles west of Conner Creek CSO. On June 30, 2025 – almost exactly one year after the Conner Creek flood – Aevitas had a massive fire where ~100,000 gallons of waste oil ignited and burned for hours. This sent a plume of black smoke and airborne pollutants over the east side, even impacting the wealthy Grosse Pointe communities downwind. Residents of Jefferson-Chalmers (the same ones flooded in 2021) had to close windows and worry about toxic fallout from that fire. Aevitas also had a history of odors (e.g. residents in East English Village complained of “rotten egg” odors in 2022 that they suspected came from Aevitas, though not confirmed). The key point is, Aevitas contributes volatile organic compounds (VOCs) and combustion-related pollutants to the local air – things like benzene, toluene, etc., which are associated with cancer and respiratory issues. Clean Earth (Petro Chem) at 421 Lycaste similarly handles hazardous chemicals and has documented releases. In 2018, EPA found it was leaking vapors because of poor emissions controls (pressure relief valves left open, etc.), leading to a 2023 consent order and fine. Clean Earth operates a regenerative thermal oxidizer, but still has had off-site impacts: its own ambient monitors picked up spikes of trichloroethylene, xylene, toluene, methylene chloride – all hazardous air pollutants – at the fenceline, indicating fugitive emissions escaping. These pollutants can cause headaches, eye irritation, and long-term cancer or neurological risks. The facility is just about a mile from many of the same homes near Conner Creek. So the community is breathing a mix of potential emissions from these waste facilities along with any odors from Conner Creek. There is also the specter of chemical accidents – Clean Earth handles ignitable wastes, so an explosion or toxic release is possible (it had a prior explosion in the late 1990s, historically). If such an event occurred, it could coincide with or compound issues at Conner (imagine a flood that also carries chemicals if one of those facilities were inundated – a scary scenario).

Cumulative Impact Assessment: Neither Michigan nor EPA has fully implemented a formal cumulative risk assessment for this neighborhood, but advocates have been pushing for it. They argue that permit-by-permit decisions miss the forest for the trees. Individually, Conner Creek CSO might be deemed to have minor air emissions and acceptable occasional water discharges. But add that to Aevitas’s permitted emissions, Clean Earth’s emissions (and violation events), plus baseline urban pollution, and you get a much higher actual exposure for residents than any single permit allows. It’s essentially the sum of burdens that matters for public health. Cancers, asthma, and other illnesses in the area can’t be attributed neatly to one source; they likely result from the collective environment. A resident was quoted saying, “We don’t care which factory it’s coming from – we just know we’re getting hit from all sides.” Local groups like the Eastside Environmental Alliance have been cataloging all facilities and pushing EGLE to consider cumulative impact screeningin their permit reviews. This aligns with a larger trend in environmental policy to address environmental justice by not just regulating in silos. For example, some have suggested that Aevitas and Clean Earth, being adjacent, should be monitored together, and that GLWA’s CSO data should be factored into modeling local water and air quality.

Quality of Life and Community Perception: Beyond quantifiable health risks, there’s the issue of quality of life. Residents in this part of Detroit often feel stigmatized and neglected. The presence of facilities like Conner Creek, Clean Earth, and Aevitas in their backyard when similar facilities would face fierce opposition in wealthier suburbs is a sore point. It feeds a narrative of environmental racism – that polluting operations are clustered in Black communities. The city’s master plans historically zoned these areas for industry next to residential, a practice now being challenged. Community members have pointed out that even newly planned projects (like the expansion of a Jeep plant and a new waste-water tank) keep getting sited on the East Side, further adding to cumulative burden.

On the positive side, the community has shown resilience and activism. After the 2021 flood, residents organized mutual aid, formed block clubs to demand better sewer maintenance, and lobbied for infrastructure funding (some federal relief was obtained). After the 2025 Aevitas fire, people from this area and neighboring Grosse Pointe came together to call for investigations and better safety measures. These incidents have raised broader awareness – even Michigan state lawmakers have been asked to hold hearings on EGLE’s enforcement in Detroit. So the overlapping crises are galvanizing change.

For GLWA’s Conner Creek facility specifically, the community context means GLWA must operate with a heightened sense of responsibility. A failure at this facility doesn’t just cause a singular issue; it piles onto a community already coping with many issues. Recognizing this, GLWA in public meetings has expressed commitment to not only fix technical problems but also to communicate and involve the community moredetroitmi.gov. For instance, GLWA set up a project community liaison (Paul Ransom, per CPC meeting notes) and provided a hotline for residents to call with concernsdetroitmi.gov. They’ve also adjusted construction plans for the new pump station to address traffic and aesthetic concerns from neighborsdetroitmi.govdetroitmi.gov. These are small steps toward rebuilding trust.

Overlap with Aevitas & Clean Earth – Summary: The table below (in the next section) will provide a side-by-side comparison, but to summarize verbally: Conner Creek CSO, Aevitas, and Clean Earth are all within about a mile of each other in Detroit’s east-side lower Jefferson area. All three contribute in different ways to the local environmental load: Conner Creek via sewage (with occasional odor/flood issues), Aevitas via hazardous waste (with fire/odor risks), and Clean Earth via hazardous waste (with VOC emissions and past violations). The communities affected by one are largely affected by the others – for example, the same East English Village and Jefferson-Chalmers residents who suspected Aevitas for a smell in 2022 are the ones who experienced the sewage flood in 2021 and who have long complained about PetroChem’s chemical odors before Clean Earth took over. Therefore, any cumulative impact assessment would need to account for all these simultaneous exposures. If you consider, say, the lifetime cancer risk from breathing air here: some portion comes from mobile sources, some from Aevitas/Clean Earth emissions (benzene, etc.), some from DTE plant (formaldehyde from gas turbines), etc. While Conner Creek’s contribution might be relatively negligible for air toxics, its contribution to, for instance, stress and mental health (through flood risk) is significant. A holistic approach to improving this community’s environment has to include upgrading the CSO infrastructure and tightening controls on neighboring industries.

In conclusion, the community context for Conner Creek CSO is one of an overburdened, predominantly Black community that has seen notable environmental improvements (like cleaner water in Conner Creek) but still faces disproportionate environmental risks. Overlapping operations like Aevitas and Clean Earth amplify these risks, making the sum impact greater than its parts. This calls for coordinated solutions – not just fixing one facility at a time, but looking at the entire neighborhood’s environmental footprint. The recommendations below reflect this integrative approach, suggesting measures that GLWA and regulators can take to ensure Conner Creek CSO’s operation does not further exacerbate the cumulative burden and ideally helps alleviate it.

6. Recommendations and Future Outlook

In light of the analysis above, several recommendations emerge to enhance environmental monitoring, community safety, and transparency at the Conner Creek CSO facility (and by extension, improve conditions in the surrounding community). These recommendations aim to match best practices seen elsewhere and address specific gaps identified:

1. Install Fenceline Air Monitoring (H₂S and VOCs): GLWA should implement continuous fenceline monitoring for hydrogen sulfide and possibly total VOCs around the Conner Creek facility. Low-cost electronic H₂S sensors could be mounted at the property boundary closest to homes (east side near Clairpointe) and near the outfall. These would provide real-time data on any escaping sewer gas odors. Likewise, a Photo-Ionization Detector (PID) or similar device could track any unexpected VOC emissions (though routine VOC levels should be negligible, this would serve as a reassurance measure). Data from these monitors should be made publicly accessible (e.g. via an online dashboard) and also alarm internally to GLWA operators if thresholds are exceeded. This approach is analogous to fenceline monitoring required at petroleum refineries and some waste facilities. It would demonstrate proactive odor management. If a carbon filter saturates or a vent flap sticks open, an H₂S monitor would catch a spike immediately, allowing GLWA to respond (before neighbors have to call in a complaint). Over time, the data could also be used to optimize odor control maintenance. Importantly, making the data public helps build trust – residents can see for themselves that, say, “H₂S stayed at 0 ppb last night” rather than just taking the agency’s word for it. In summary: fenceline air monitors act as a neighborhood early-warning system for odors and ensure GLWA is promptly aware of any lapses in containmentegle.state.mi.usegle.state.mi.us.

2. Enhance Public Alert Systems for Overflows and Emergencies: Develop and deploy a direct community alert system for CSO events and facility emergencies. This could include a multi-pronged approach: (a) Text/SMS or robocall alerts that residents can opt into (perhaps via a city-run system) which would send a message like “Alert: Conner Creek CSO is discharging treated overflow to Conner Creek following heavy rain. Avoid contact with river water for 48 hours.” or in a worse scenario “Emergency: Conner Creek Pump Station outage – street flooding possible, avoid driving in area.”; (b) Physical siren or alarm that could sound in the immediate vicinity if there is a need to shelter-in-place or evacuate (this is used in some communities near chemical plants – a distinct tone alerts people to tune to a radio station or check their phones for instructions); (c) Social media and website updates in real-time – GLWA’s Twitter or Facebook (and the city’s) should post during overflow events or incidents, not just after. The CSO Notification Plan that GLWA hasglwater.org can be expanded to include these direct outreach elements beyond the bare minimum of posting on a state website. Additionally, GLWA should coordinate with Detroit’s Office of Emergency Management so that any significant incident at Conner Creek triggers the city’s emergency notification protocols (for example, inclusion in the CodeRed or similar system that Detroit uses for emergency notifications about flooding or boil water advisories). The goal is for residents to never be caught off guard by an incident involving the facility – whether it’s potential basement flooding, a spill, or a large untreated discharge. A side benefit is that well-informed residents can take precautions that reduce health risks (e.g. avoiding recreation in contaminated water, staying indoors if there were ever a chemical release, etc.).

3. Real-Time CSO Discharge Transparency: Increase the transparency and timeliness of information on Conner Creek CSO discharge events. GLWA should create an online CSO discharge dashboard or map that is updated immediately when an overflow occurs, showing: which outfall (104) discharged, start/stop times, volume, and whether it was screened/settled/disinfected (or, in worst case, untreated). Many cities (e.g. Washington D.C.’s DC Water, Cleveland’s NEORSD) have such public CSO notification webpages that automatically update during rain events. GLWA’s current practice of annual reportsglwater.org and MIWaters postingsglwater.org is too slow and not user-friendly. In addition to a website, push notifications could be offered – for example, an email or text service for interested individuals (similar to how weather alerts or COVID alerts are done). This way, a fisherman or boater could be automatically notified that “Treated CSO discharge happening at Conner Creek – avoid area.” For the local community, transparency also means frank communication about any problems – if, say, the disinfection didn’t meet the target in a particular event, GLWA should disclose that and advise caution rather than burying it in a report. Ultimately, the community deserves to know what’s coming out of the facility in as close to real time as possible. This kind of open data builds pressure on GLWA to minimize overflows (nobody wants a public counter of overflows ticking upwards) and provides citizens and advocacy groups info to hold agencies accountable. It’s also now an expected practice under EPA policy for Great Lakes CSOs, so GLWA can demonstrate leadership by exceeding the basics of the requirement.

4. Strengthen Infrastructure & Monitoring for Resilience: While infrastructure upgrades are underway (e.g. new pump station by 2025), GLWA should fast-track and prioritize any measures that reduce the chance of another catastrophic failure. This includes hardening backup power (ensuring multiple generator units, possibly adding battery backups or quick-connect mobile generator hookups, given that a stationary generator alone proved insufficient in 2021) and implementing smarter controls. For instance, install a continuous pump station monitoring system that is independently powered and can send out alerts if pumps go offline (even if the main power and SCADA are down). This might involve cellular-based telemetry as a backup. Additionally, GLWA might consider temporary measures like pre-deploying portable pumps to low-lying areas during forecasted extreme storms, or creating a contingency to divert flow to other parts of the system if Conner is incapacitated (though the options are limited). On a monitoring front, doing routine “stress tests” and drills can be valuable: e.g. simulate a power outage to ensure generators kick on, simulate a high-flow event to see if any warning thresholds could be triggered earlier. Incorporating climate projections into operations is key – perhaps set a rainfall threshold (like 3 inches in 24 hours) at which they automatically stage emergency personnel at the site. These recommendations go somewhat beyond “monitoring” into operations, but they are tied to ensuring that monitoring data (like weather forecasts, pump status) are actually used to prevent disaster. In short, prepare and monitor for the worst-case scenario, not just average conditions. The community cannot afford another 2021-scale incident, so whatever early warning systems or redundant monitors needed (whether mechanical, electrical, or human) should be put in place. This also means collaborating with weather services or installing a local rain gauge – hyper-local rainfall monitoring might help predict when Conner’s capacity is going to be exceeded, giving a small time window to warn people or take emergency actions.

5. Community Engagement and Communication Enhancements: GLWA should continue to improve how it engages with the community around Conner Creek. This includes forming a Community Advisory Panel that meets regularly (perhaps quarterly) with GLWA officials to discuss Conner Creek CSO operations, any recent events, and upcoming projects. Such a panel would include residents, local business or marina reps, perhaps a school official – those directly impacted. They can provide ground truth feedback (“Yes, we smelled something on X date” or “this street always floods even in small rains”) that GLWA might not otherwise know. GLWA can in turn share data and plans with them in a more accessible way than formal reports. This two-way dialogue helps ensure community concerns are heard early and often. Additionally, GLWA should provide accessible information: for example, mail out an annual “fact sheet” to residents summarizing CSO performance (in plain language: number of discharges, volume, any issues) and tips on what to do in heavy rains (protecting property, health precautions). During the 2025 Aevitas fire, one critique was that residents didn’t know whether to evacuate or how to get air testing – a prepared communication plan for Conner Creek could avoid similar confusion (like an info sheet on “what to do if your basement floods with sewer water” or contacts for immediate help). GLWA has also been working with City Councilmember Latisha Johnson’s officedetroitmi.gov – continuing that partnership can ensure political support for any needed policy changes (e.g. pushing for more funds, or city support for the alert system). Lastly, education initiatives could be expanded: GLWA might host open houses or facility tours for locals (once it’s safe to do so) to demystify the site and show the odor control and treatment processes. When people see the investment and understand how it works, they may feel more confident, and they can also directly voice concerns to staff on those tours.

6. Coordinate Cumulative Impact Mitigation: Given the overlapping risks with Aevitas and Clean Earth, a recommendation is for regulatory agencies (EGLE, EPA) and operators (GLWA, Aevitas, Clean Earth’s parent company) to collaborate on a cumulative impact monitoring program for the eastside industrial corridor. This could involve joint funding of a comprehensive air monitoring station in the neighborhood that tracks a suite of pollutants (H₂S, VOCs, particulate) continuously, capturing the combined emissions load. Similarly, periodic health risk assessments could be done that consider all sources – for example, an annual review of asthma ER visits in the ZIP code, checked against any emission spikes or events at these facilities. While GLWA’s direct responsibility is Conner Creek, it can take a leadership role in this collaboration as a fellow “neighbor” in the community. Such efforts would align with emerging EJ practices and could be something GLWA touts as part of its mission to be a good environmental stewardglwater.org. Concretely, GLWA could propose an EJ demonstration project: perhaps work with EGLE to deploy a mobile lab during a year where they sample around Conner Creek and Aevitas/Clean Earth, to truly characterize what the community is exposed to. This data can then inform if more controls are needed anywhere. The recommendation here recognizes that solutions can’t be siloed; GLWA shouldn’t say “not my problem” about Clean Earth’s emissions, and vice versa – instead, a collective mitigation plan (possibly through the city’s new Office of Sustainability or similar) should be developed for the whole area. Part of this could include exploring green infrastructure in the neighborhood to reduce stormwater (thus easing CSO load) and buffer pollution – e.g. tree planting campaigns which can help absorb some airborne pollutants and reduce urban heat (which exacerbates ozone formation).

7. Explore Additional Odor and Emission Controls: As a preventive measure, GLWA could evaluate whether the current odor control system is sized for worst-case scenarios and if enhancements are warranted. For example, adding a fifth carbon unit or a backup odor control system powered by solar/battery that would kick in during power failures could add resilience. Another idea from tech advancements: investigate new filter media or technologies (biofilters, chemical scrubbers) that might destroy odors more efficiently or handle larger surges. While the current system has worked well, planning for “beyond design” events might justify over-sizing or redundant odor controls, given how close residents are. On the water side, GLWA is already looking into improved disinfection methods (they had considered UV or optimizing chlorine dosage). Ensuring minimal chlorine residual in discharged water protects aquatic life – continuous dechlorination would be ideal so that no aquatic biota are harmed during frequent discharges. Community members have also floated ideas like constructing an additional satellite basin or leveraging nearby canals for emergency storage – these may not be feasible, but the recommendation is to keep an open mind to innovative solutions that could further reduce any overflows (for example, inflatable dam barriers in sewers to hold more water upstream temporarily).

8. Support Community Resilience Initiatives: As a broader recommendation, agencies and GLWA should support programs that help the community cope with the existing burdens. This includes things like providing backup sewer check valves or sump pumps for homes (to reduce basement backups), establishing a faster flood claim reimbursement or assistance process (so residents can recover quicker), and funding health initiatives (free health screenings or air purifiers for residents). While not directly about monitoring, these measures are important in addressing the consequences of environmental impacts that monitoring is trying to prevent. An example could be a GLWA-funded grant to a local clinic for outreach on mold abatement and respiratory health in the aftermath of flooding. Showing this kind of community investment can alleviate some of the disproportionate impact and also improve the relationship between the facility operators and the neighbors.In conclusion, implementing these recommendations would greatly strengthen how the Conner Creek CSO facility operates within its community. Fenceline monitors and alert systems directly tackle the information and response gaps, ensuring that any deviation from normal is caught and communicatedegle.state.mi.usglwater.org. Transparency measures empower residents with knowledge and foster accountabilityglwater.org. And the more holistic community-focused actions acknowledge that the ultimate goal is not just regulatory compliance, but a healthier, safer living environment for the people of Detroit’s east side. GLWA has the opportunity to make Conner Creek a model of a well-run, community-integrated infrastructure facility – one that not only treats sewage but also treats its neighbors with respect and care.