New York City's Department of Environmental Protection (DEP) has issued a Request for Proposals (RFP) for a Water and Sewer Rate Restructuring Study. Here is a link to the RFP. As far as we can tell, the City's RFP doesn't include a single word about the study being informed by the many stakeholders who will need to understand what the City is exploring and why.
SWIM has called for the study and the importance of convening a Citizens Advisory Committee to inform the study before it gets conducted so that stakeholders can weigh in on the considerations the study should include. A study on such an important issue should be not be conducted without public input!
Waterway stakeholders are watching the study carefully in regards to a couple of the objectives (noted in green below). Cities across the country have already restructured their water and sewer rates to address the impacts that stormwater runoff has on municipal sewer systems and create incentives for property owners to install green infrastructure to capture, store and reuse stormwater runoff on sight rather than allowing it to inundate and overwhelm the municipal systems during rain and snow events.
The purpose of study is to:
"conduct analysis of appropriate Water and Wastewater rate structure options, customer assistance and credit programs, and recommendations and implementation options for DEP to achieve a more predictable, equitable, and sustainable revenue stream, in light of several factors that place increasing pressures on DEP’s rate base. These factors include but are not limited to the following: decreasing consumption levels; increasing utility fixed costs independent of customer use; drinking water, wet weather, and related water quality investments; state of good repair; population growth; and enhanced level of service."
The objectives of the study are:
"The City intends to conduct a holistic rate structure study that builds upon past analysis and achieves the following objectives to the greatest extent practicable:
Balances competing needs, including State of Good Repair investments, climate resiliency, maintaining or enhancing DEP’s level of service, reinforcing ongoing conservation programming, and incentivizing green infrastructure;
Equity among customer classes, based on their respective characteristics of service;
Affordability, utilizing economic and demographic data (e.g., household income, housing cost burden, local
employment trends) and US Environmental Protection Agency (EPA) affordability information for guidance;
Reasonable correlation between cost of service and a parcel’s stormwater contribution to the sewer system and respective usage characteristics;
Compatibility with DEP’s billing system – Customer Information System (CIS) – and ease of
implementation from a billing and customer service perspective; and
Requirements for maintenance services, ongoing implementation needs, resources and flexibility.
Currently, New York City’s billing structure for municipal water and sewer costs is based on two charges: Water and Sewer
1. Water Charge: for potable water
2. Sewer Charge: for wastewater and stormwater
The sewer charge is calculated at 159% of the water charge:
Water Charge x 1.59 = Sewer Charge.
This calculation makes sense in terms of the wastewater portion of the charge but a property's stormwater impact is not based on how much potable water is used but rather how much stormwater runoff the property generates and how much the runoff impacts the sewer systems. For instance, a giant asphalt parking lot or a "big box" store will generate far more stormwater runoff than a single family house and may use very little potable water.
Why should the property that generates far more stormwater runoff pay the same rate as a single family property that impacts the system far less?
This is a complex issue and it's something that cities across the nation are grappling with as they become more and more densely developed and there are less green spaces and natural resources to soak up all the stormwater runoff from rain and snow events. Densely developed urban areas across the planet are struggling to cover the cost to maintain and update their water and sewer infrastructure to handle the ever growing loads on their antiquated systems from increased population, over-development, and increased storm intensity and sea level rise caused by climate change.
In New York City we've developed away all the land that used to soak up the rain and snow so, rather than being absorbed by a wetland or large green space, it runs off our streets and buildings and ultimately inundates our 100 - year old combined sewer system and causes a billions of gallons of a combined sewer overflow (a combination of raw untreated sewage from homes and businesses and polluted stormwater from our streets) to discharge into our waterways every year making them unsafe to touch after rain and snow events.
Cities around the country are implementing innovative programs to better manage the impacts of stormwater runoff from rain and storm events that overwhelm our antiquated systems. Many cities have already restructured their water and sewer rates as a means of addressing this pressing matter. Here is an issue brief describing the various approaches that other cities have explored.
SWIM will continue to call for the formation of a Citizens Advisory Committee to inform the City's study and for quarterly public updates on the status of the study as it gets developed along with a thorough review of the results with the public before any action is taken.
Here is a link to information about the impacts of stormwater runoff produced by Columbia University's Earth Institute in April 2018.
Here is an issue brief, produced by SWIM member NRDC, which provides information about how cities around the country are approaching the their stormwater and wastewater rate restructuring to ensure that their waterways meet federal health standards for safe contact.
Here is a link to a fact sheet, created by SWIM Coalition member, NYC Soil and Water Conservation District that talks about NYC water rates and some of the considerations that will need to be explored as the City develops solutions for how to manage stormwater and wastewater in order to ensure that our waterways meet federal health standards for safe contact.