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Township weighs changing RGB/SSA rules to allow sewer for public parks after Hess Field raises access questions
Summary
Ferguson Township discussed a COG/CRPA proposal to consider different criteria for public parkland and facilities (Hess Field) in the regional growth boundary/sewer service area process, including whether parks should be eligible for sewer without triggering developer‑oriented DRI rules; engineering estimates to bring sewer to Hess Field were cited at $1M–$1.5M.
Cam Adams, regional planning director, briefed the Board of Supervisors on Nov. 18 about recent Center Region Planning Agency (CRPA/COG) and Lucy Committee discussions prompted by a request from Harris Township about allowing COG‑owned facilities (and, secondarily, public parkland) to access public sewer under certain policy criteria.
Adams explained that the region uses a regional growth boundary and sewer service area (RGB/SSA) with an implementation agreement that defines how municipalities may request expansions. Most development requests are treated as developer‑driven DRIs (developments of regional impact) and fall into minor (1–50 EDUs) or major (greater than 50 EDUs or otherwise noncontiguous) categories. Public parkland typically counts as 1 EDU, so the current DRI thresholds and procedures don’t map well to a municipal park that is not growth‑oriented.
COG’s Lucy Committee declined to grant an exception to the existing rules but asked staff to draft a policy process and criteria for public facilities to be considered by the municipalities and CRPA. Adams said the only existing exception in the implementation agreement is if DEP determines a public health threat (septic failure) and that Tussey Mountain and the Meijer dairy store are earlier examples where sewer occurred outside the RGB/SSA for technical reasons.
Board members raised concerns about setting a precedent that could erode the RGB and create pressure for additional expansions. One supervisor said using parkland as an exemption “is so broad that it will defeat the purpose of having our RGB.” Adams responded that a defined criteria and process could include protections to avoid incremental boundary creep and cited Pine Grove Mills as an example where an exception did not open the boundary to additional growth.
Adams cited engineering study figures for Hess Field sewer connections in the range of $1,000,000 to $1,500,000 and explained that until the implementation question is resolved, Harris Township cannot pursue grants or capital work because it would be illegal for them to connect to sewer today. CRPA will collect municipal responses to the policy questions and Lucy Committee will deliberate on next steps; Ferguson will return the town’s answers to Lucy and the item will be on the board’s Dec. 2 agenda for further deliberation.
No formal action was taken on Nov. 18; staff and the Lucy Committee will continue to work on criteria and a process to be considered regionally.
