Concerned citizen digs into Toll Brothers sewage planning claims

Concerned citizen writes:

I read the most recent post regarding the upcoming SCBWA meeting and something got my attention.

The number of wastewater gallons referred to in the article (47,950 gallons per day/gpd) seemed a little suspicious to me given that the limit for DEP approval without public notice is 50,000 gallons.

I spent a few hours digging around and have determined that Toll Bros. left out a few key factors in their calculation, namely their outbuildings, offices, and swimming pool.

According to the UAJA updated flow rate sheet, the following amounts should have been included in the application to DEP:

Additional buildings including clubhouse and pool maintenance building equal to 19,499 sq. ft. according to the proposed plan.

UAJA counts one EDU per 3,000 feet of building = 6.5 EDU

If the clubhouse has showers, there should be an additional 2 EDU added.

Office space that employs fewer than 10 people should be included as 1 EDU.

The swimming pool should be calculated at 2 EDU per filter (I could not find information on the number of filters) but there is also a hot tub so probably two or more filters involved. In addition to the 2 per filter, swimming pool EDUs are added for the average number of patrons x 10 gpd.

There is an outdoor bar which, I assume has a water supply but I couldn’t find any info on how that would be calculated by UAJA.

The number of 5 bedroom units is total b.s. as the joint authority calculates all EDUs the same regardless of number of bedrooms.

This is very convenient for Toll Brothers.

These additional EDUs may or may not add up to 50,000 but either way, if their application is incorrect, it should be brought to the attention of the DEP.

The DEP website states that it will not review the applicants information for accuracy and relies on the truthfulness of the applicant. I think we all can agree that Toll is less than trustworthy.

I am attaching a few screen shots from my research.


The amount of gpd (175) that was used for calculation is coming from the UAJA rate sheet which is used to calculate utility cost.

However, Pennsylvania code calculates the rates of wastewater usage much differently.

For the purposes of building a new sewer or septic, the calculations are 100 gpd per person plus additional for out buildings, swimming pools, etc. [Editor’s Note: The citation is to state law for on-lot sewage systems, not connections to regional sewage treatment systems. Act 537 covers community wastewater treatment rules.]

This number – 1oo gpd –  is consistent with many other communities [i.e. Pittsburgh] and with the EPA estimate.

Here is the breakdown of units at The Cottages:

  • 1 bedroom apartments = 0
  • 2 bedroom = 17
  • 3 bedroom = 35
  • 4 bedroom = 126
  • 5 bedroom = 90

I would not put it past Toll Brothers to increase the number of high bedroom units knowing that no matter how many bedrooms, they are only required to count each apartment as 1 EDU….for the purposes of billing.

Now, considering that college students typically double and even triple up on occupancy and that PA code requires calculating 100 gpd of wastewater usage per person…the math is scary.

At 1,093 people, which is the total number of bedrooms, they are already at least double the volume of wastewater usage than what they reported to DEP. [1,093 x 100 gpd = 109,300 gpd to Cottages + WRRP sewage pump station, wet well and high-pressure force main]

If their bedrooms become double occupancy (very likely that many of them will) The Cottages sewer pump and new pipeline will need to handle 218,600 gallons of wastewater per day.

A pump that is built to handle just a fraction of that, only 47,950 gpd, doesn’t stand a chance.

And with no contingency plan in place in case of failure…you know the rest.