There’s a change coming to the City of College Place. In a letter dated October 25, 2017, the city received a notification from the Department of Ecology requiring the city to apply for a permit under the July 2019 National Pollutant Discharge Elimination System (NPDES) permit cycle. What does that mean? That means we will be required to comply with the Clean Water Act (Act), a storm water permit program, established by Congress in 1972. “Storm water” is surface run-off generated by rain storms that can carry pollutants (like oils, sediments, etc.) into creeks and water bodies. The Act regulates point sources (like outfalls from streets) that discharge storm water pollutants into the “waters of the United States”. “Waters of the United States” is broadly defined, so that means that our stormwater discharges to Garrison Village Way, Stone Creek, Military Springs…etc., trigger the requirements of the Act…and that means being on the hook to establish a stormwater program to comply with the Act.
The permit requires compliance in six different areas: Public Education and Outreach, Public Involvement and Participation, Illicit Discharge Detection and Elimination, Construction Site Stormwater Runoff Control, Post-Construction Stormwater Management for New Development and Redevelopment, Municipal Operations and Maintenance, and Total Maximum Daily Load (TMDL) levels established for our streams.
Without going into detail on each of those requirements, suffice it to say that we have our work cut out for us. For cities our size, annual program costs typically run about $1,000,000 a year. That’s a lot and would translate into having to charge residents, on average, about $23 each month. Instead, the city is looking at trimming costs by charging rates for only the operational activities (educational outreach, illicit discharge and elimination enforcement, construction site monitoring, testing, compliance tracking, etc.) and relying on grants to finance the construction of facilities. There are some risks to this approach. Aggressive compliance with the permit is what provides cover from third-party lawsuits by special interest groups seeking to preserve stream habitat and water quality. Still, we think this will cover our operational costs while mapping out a strategy for installing long-term stormwater infrastructure that should satisfy third-party concerns. Taking this approach, we are looking at a flat monthly rate of $9.20 for each of our residential customers with other customers paying based on how much stormwater they produce relative to an average residential lot. Some non-residential property owners have installed stormwater facilities and the rate structure we are exploring would provide a partial credit (up to $2.30 per month) to reflect their reduced contribution to the public system.
So when does this all happen? That’s still a bit up in the air, but right now the plan is to adopt a final rate structure by the end of September with an open credit application period between October to mid-November for those property owners who have installed storm water facilities on their property.
Stay tuned…when it rains, it pours.