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Sunday, March 27, 2016

City's Stormwater Presentation



The City's slide presentation for the public consultation meetings (including the speaking notes) is on its web site at   Stormwater Presentation

 

Comments on the overall presentation and notes on individual slides are below

 

 Stormwater fees: Principles, Facts and Prescriptions
 
The City's proposal to initiate a stormwater fee separate from water and waste water charges has stirred
much passion. In the heat of the argument, the basic principle underlying a stormwater fee needs to be
reasserted: You pave, you pay.
These facts will also help clear the fog:
+ managing stormwater (run-off from rain or snowmelt) has nothing to do with providing drinking
water to residents and businesses or with managing their wastewater (formerly known as sewage);
+ roadside ditches and culverts are part of our stormwater infrastructure -- not to be confused with
municipal drains that benefit farmers' fields and fall under a totally separate financing and maintenance
regime;
+ a small but significant number of households and a smaller number of businesses, mostly in rural but
also in some urban areas, do not receive a water bill, yet many of them do have rainwater run off their
properties.
 
Two straightforward directives follow from the principle "you pave, you pay:"
1- paying for capital and operating costs of stormwater infrastructure (from ditches to pipes and ponds
to treatment devices) should be in proportion to the the amount of hard (impervious) surface on one's
property;
2- reducing the amount of run-off at one's property should be rewarded by seeing one's payments
lowered.
 
This means that setting stormwater fees in proportion to assessed property values may be
administratively simple but is neither fair nor logical, and offers no way to provide incentives for
reducing run-off.
We could be asked to pay for stormwater infrastructure either on the tax bill or on the water bill but the
water bill has the edge: We'll see what we pay every other month, not just twice a year; and we'll be
happy to see the reward for efforts at reducing run-off that much more often. Psychologically, seeing
the charge on the tax bill could suggest that assessed property values and stormwater management are
related, which they are not.
Is providing incentives to reduce run-off at the lot level, resulting in less pollution and less need for
infrastructure, an impossible dream? Not at all! Dozens of cities across North-America have done it.
Not all have succeeded, so getting the rate structure and incentive design right is important. A prime
example of a successful design is that of the City of Waterloo.
 
Waterloo example
Waterloo and Kitchener joined in a study that sampled 6,000 residences, allowing them to come up
with six categories of residential units, based on lot size, each with a "hard surface" factor and a factor
measuring the intensity of hard infrastructure needed to serve them. These factors led to a distribution
of the total cost of providing stormwater services. In 2016, a small residential lot (say, 90x48 feet)
would pay $5.61 per month, a large lot (say, 150x145 feet) would pay $18.61. Starting in January
2013, residents have been able to apply for credit if they have a rain barrel, trees, a cistern, an
infiltration gallery or an engineered landscape on their lot. How to calculate the credit is explained in
straightforward terms in a 3-page application form. The fee can be reduced by up to 45%.
The cost of providing stormwater services is shared by institutional, commercial and industrial
customers. They are divided into seven categories, again based on lot size, and their specific
impervious and infrastructure intensity factors are determined. For a small commercial lot (less than
22,000 square feet) the monthly charge is $21.63 per month. A very large commercial or industrial lot
owner (more than 10 acres) pays $824.49 per month. Credit of up to 45% can be earned based on
installed flood prevention controls (stormwater management pond, rooftop, parking, or underground
storage, a green roof, and more), pollution reduction controls (an oil/grit separator, pond, bio swale, salt
management plan, and more), and education plans.
 
To date, some 1,750 residents have received credit for their lot-level measures. Many of the initial
applications were of course by residents who had had their rain barrels all along, but increasingly the
uptake has been by residents who have taken such measures more recently, i.e., the program is
beginning to influence behaviour. Waterloo officials believe that this level of participation could easily
increase from the current 8% to 20%. On the non-residential side, some 60 businesses have earned
credit to date. While the incentive is not enough to persuade shopping malls to tear up their seas of
asphalt, as renovations take place the program is having an effect.
Waterloo's consultation process that led to these changes is impressive. Ideas that emerged from the
public became part of the final design. Transparency and clarity prevail to this date.
 
What about Ottawa's rural areas
Our extensive rural areas present a complex picture: Many rural residences have their own wells and
septic fields and therefore do not help pay for the cost of stormwater management in the way residents
who receive a water bill do; others have one but not the other. Some infrastructure elements such as
ditches and swales may be privately owned and controlled, or are financed by local improvement
charges. Certain road maintenance work also serves stormwater management but how the City is
accounting for this is not clear.
The City's proposals do not come to grips with this complexity and finding out who pays how for what
is fiendishly difficult. It would appear that the City has more homework to do to clarify the status quo
and seek consensus on a fair solution.
 
Why minimizing stormwater run-off is good for man and nature
The controversy over a stormwater fee is obscuring a key point: Controlling stormwater volumes at the
lot level delivers proven benefits. They come in addition to improved quality of the run-off and include
reduction of peak flows, reduced flooding, reduced erosion and sedimentation in receiving water
bodies, improved groundwater recharge, better aquatic habitat and greater resilience to climate change.
Reducing stormwater run-off at source is also good for the City's finances: Storm sewers suffer less
wear and tear, sediment in stormwater ponds accumulates less rapidly and creek erosion is reduced,
resulting in less maintenance and rehabilitation costs.
The current review of the City's water rate structure seems geared exclusively at tapping into new
revenue streams and ignores the opportunity to move us one step closer to a more sustainable way of
living. The opportunity should not be wasted.
Erwin Dreessen is co-chair of the Greenspace Alliance of Canada's Capital


Comments on Ottawa's
Water, Wastewater & Stormwater Rate Review
Residential Consultation

 
March 2016
[Available from here: http://ottawa.ca/en/residents/water-and-environment/water-and-sewer-bills/water-wastewater-and-stormwater-rate-structure]
Slides 3 - 13
This is factual information about Ottawa's water, wastewater and stormwater (W, WW, SW)
infrastructure, typical water consumption and rate structure. The basis for the assertion on slide 11 that
80% of the SW costs are for urban service and 20% for rural is not clear. Similarly, the assertion that
rural residents pay only $1.4 M of the $8.4 M rural cost of SW raises the question what the scope is of
these cost data: Is some of the capital and maintenance cost of roadside ditches and culverts not
covered by the road construction and maintenance budget, i.e. property taxes? For sure, it excludes the
costs that are covered by rural residents directly.
Note on slide 6 that the City delivers 289 M litres of W per year and collects & treats 393 M litres of
WW. Where does the 393 -289 = 104 M litres come from?
 
Slides 11 and 15
Likewise, the assertion that 90% of the cost of providing these services is fixed could be debated, but
there seems little point. Theoretically, fixed costs ought to be financed by a flat fee but that would
clearly, even if the fixed portion were less than 90% (but still high), lead to unaffordable rates for many.
 
Slide 17
The speaking note, "The proposed rate structures are revenue neutral for the City" is disingenuous: It is
plain that the City is experiencing a shortfall in revenues to cover W, WW and SW services and the
current proposals are designed to do something about that. The proposal may be designed to bring in
the same revenue for the current year but surely the objective is to extract more revenue in the future.
An assertion of revenue neutrality undermines the City's credibility.
Slide 19
One wonders why, for W and WW, no options are presented. Certainly various options are
conceivable. If there are no options, what's the point of asking "for your input on how well it aligns
with the principles and for feedback on the advantages and disadvantages of the proposed rate."
Slide 20
These are helpful figures: per cubic metre we pay $1.699 for W, $1.491 for WW and $0.497 for SW.
These numbers do not appear on our water bill. However, one suspects that the cubic metres in question
refer to consumption of W, i.e., are not per cubic metre of processed volumes in each stream.
Slides 21 and 22
These proposed rates for W and WW may be reasonable but would require more analysis to see what
their impact would be on various types of residents. (See slides 27-31 below.)

Slide 23
Here it is proposed that a new SW fee be put on the property tax bill. That is a "how or where do I pay
for it" question. The first question should be: "What should I pay, on what basis." How/where you pay
for it is secondary.
Slide 24
Here is where the presentation goes off the rails. Suddenly, the non-residential component pops up;
small businesses are lumped in with any size business, never mind that they "may be closer to a
residential property."
This and following slides are way too crude in characterizing the non-residential sector. A more
disaggregated analysis is called for.
 
Slide 25
"We conducted an analysis of the total of all impervious surfaces in the City based on GIS
data." If you believe this, that bridge in Brooklyn is still for sale.
Apart from that, this slide does make a key point, also borne out in other cities: Most
businesses generate more stormwater than most residences, relative to their water consumption.
Therefore, under the current system, where everything is based on water consumption, most
businesses do not pay their fair share of the cost of stormwater management.
Based on the data presented, the shift in the name of greater fairness is relatively small: $4 M.
If the non-residential sector were more differentiated we'd likely see far more significant shifts
in certain categories, especially regarding business that are surrounded by seas of parking
spaces.
Slide 26
This presentation is billed as a consultation with residents but it is a strategic mistake to not
also discuss the non-residential side. Residents want to know whether the businesses pay their
fair share.
The speaking notes recognize that setting a SW fee based on assessed value of the property is
flawed: A small house in the Glebe could end up paying more than a large, 3-garage-door
suburban house.
The speaking notes recognize that basing the fee on the amount of hard surface on a property is
the fairest. But then the option is muddled by a calculation that is too high-level in two
respects: All residential properties are lumped together and the rate is based on an average
property size. Contrast that with Waterloo, which differentiated residential properties by size of
the parcel, sampled them to determine how much impervious surface they have and how much
pipe is needed to serve them. That is a far more sophisticated compromise and, obviously, quite
doable.

Mercifully, the speaking notes say that, for non-residential properties, the actual amount of hard
surface would be calculated, "since there is such a variety in total impervious area." Right.
 
Slide 27
Here again, the distinctions made between types of residential properties are way too crude,
look at irrelevant parameters (assessment value) and make crude assumptions about the amount
of hard surface. The failure to correctly characterize the scope of SW costs comes back to bite
here, with a rural home showing it pays $0.00.
Slides 29-31
The crudeness of the analysis carries through in these slides and they are therefore of little help.
Slide 32
The comparison with other Ontario cities is interesting, if true.
Slide 33
Note the very consumer-friendly email address: "WWSRSR-EBRE@ottawa.ca" - oh boy.
0000
 
The biggest flaw in this SW proposal is that it does not grasp the opportunity to reduce SW
runoff at the lot level. That ought to be the prime reason for moving to a separate fee and it is
why setting the fee relative to the amount of hard surface is the way to go. Consumers then
have to be given the opportunity to reduce their charge if they take certain actions. As my op-ed
concludes:
 
"Why minimizing stormwater run-off is good for man and nature
The controversy over a stormwater fee is obscuring a key point: Controlling stormwater volumes at the
lot level delivers proven benefits. They come in addition to improved quality of the run-off and include
reduction of peak flows, reduced flooding, reduced erosion and sedimentation in receiving water
bodies, improved groundwater recharge, better aquatic habitat and greater resilience to climate change.
Reducing stormwater run-off at source is also good for the City's finances: Storm sewers suffer less
wear and tear, sediment in stormwater ponds accumulates less rapidly and creek erosion is reduced,
resulting in less maintenance and rehabilitation costs.
The current review of the City's water rate structure seems geared exclusively at tapping into new
revenue streams and ignores the opportunity to move us one step closer to a more sustainable way of
living. The opportunity should not be wasted."