HomeMy WebLinkAboutDTS-10-100 - Stormwater Rate By-law and Utility Implementation - AddendumJ
I~rTCi`~~~R ' •
Devefvpment &
Technical Services
REPORT TO:
DATE OF MEETING:
SUBMITTED BY:
PREPARED BY:
WARD(S) INVOLVED:
DATE OF REPORT:
REPORT NO.:
Finance and Corporate Services Committee
May 17, 2010
Grant Murphy, Director Engineering Services
Grant Murphy, Director Engineering Services - 741-2410
All
May 12, 2010
DTS-10-100
SUBJECT: STORMWATER RATE BY-LAW AND UTILITY
IMPLEMENTATION -ADDENDUM TO DTS 10-094 REPORT
RECOMMENDATION:
1. That the ten (10) year capital and operating forecast for the stormwater
management program be approved as outlined in staff report DTS-10-
094 ,subject to revision through the annual budget process;
2. That the stormwater rate schedule as specified in Appendix B of staff
report DTS-10-094 be approved and come into effect on January 1,
2011;
3. That the by-law enacting the stormwater rate be approved as an
amendment to the fees and charges by-law;
4. That a reduction in the following base budgets be implemented as of
fiscal 2011 resulting from a shift to a stormwater utility model:
Tax supported operating budget of $6,204,228
Water utility of $256,677
Sanitary utility of $259,414
Gas utility of $278,184
5. That City Staff meet with the Waterloo Region District School Board and
the Waterloo Catholic District School Board in order to clarify the
matter of a municipality's legal authority to apply storm water rates to
the Boards' properties.
6. That staff provide a report related to a stormwater rate credit policy for
Council's consideration prior to January 1, 2012;
7. That one (1) engineering manager position (full-time), one (1) operations
supervisor (full-time), one (1) engineering project manager position
(full-time), and one (1) revenue analyst position (full-time) be hired
beginning in June 2010 so as to enable the implementation of the
stormwater utility and advancing related stormwater projects;
8. That $100,000 be transferred from the Grand River Erosion Control
project (account numbers 11619 and 7367) and that $129,000 be
transferred from the Victoria Park Lake Environmental Assessment
project (account numbers 52000039 and 207) into the stormwater Utility
Implementation Plan (account number 701204027) and further;
9. That staff report to Council prior to January 1, 2013 on the viability of
transitioning non-residential properties from the approved "tiered flat
fee" stormwater rate structure to a method where these properties are
charged according to their actual measured impervious area.
EXECUTIVE SUMMARY:
On February 22nd, 2010, Council directed staff to present a stormwater rate and utility
implementation plan for consideration on or before May 31, 2010DTS report 10-100 provides
updated recommendations and additional information about DTS10-094 based on inquiries and
concerns raised by public and members of the Financial and Corporate Services Committee on
the May 10th 2010 related to the proposed stormwater rate structure and the implementation
plan.
BACKGROUND:
In November 2004, Council directed staff to proceed with undertaking a stormwater
Management Program and Funding Review Study (Study) collaboratively with the City of
Waterloo as part of the Shared Services Initiative. The purpose was to identify the City's current
level of service, compare this to the legislated requirements and guidelines, develop a
suggested level of service, and to evaluate appropriate funding mechanisms to support the
stormwater program needs. The Study recommended that a utility structure and user rate
approach be implemented in order to fully fund stormwater management programming within
the City of Kitchener.
On February 22nd, 2010, Council directed staff to present a stormwater rate and utility
implementation plan and present recommendations for consideration on or before May 31,
2010. DTS10-094 report recommends that a stormwater rate structure be implemented on
January 1, 2011. The rate methodology provides for a fair and equitable approach allocating
costs associated with stormwater management to all property owners in the City of Kitchener.
The report provides details associated with the 10 year stormwater programming capital and
operating forecast, the proposed rate structure and along with the enacting by-law for
implementation of the stormwater rate starting on January 1, 2011. Also included in the report
are recommendations relating to resource requirements for advancing stormwater programming
in 2010, along with a summary of the consultation process with "places of worship", the
Waterloo Region District School Board and the Waterloo Catholic District School Board.
REPORT:
DTS report 10-100 provides additional information about DTS10-094 based on inquiries and
concerns raised by public and members of the Financial and Corporate Services Committee on
the May 10t" 2010. Questions and concerns are categorized into three (3) key topics:
1) Rate Structure and Methodology
2) Stormwater Rate Credit Policy
3) Stormwater Program - 10 Year Capital and Operating Forecast
Section 1 -Stormwater Rate Structure and Methodology
1. Why is the City switching from a tax based to a rate based approach to funding stormwater
system programming?
The rate methodology provides for a fair and equitable approach allocating costs associated
with stormwater management to all property owners in the City of Kitchener, instead of basing it
on property value.
Also, a rate based approach provides dedicated funding for the stormwater system, similar to
the water, sanitary and gas utility enterprise models which the City has had in place for many
years. The benefit of this approach is that programming can be effectively planned and
delivered through the sustaining influence of a rate base. Similar to other City-owned utilities,
the rates would be reviewed, scrutinized and approved by Council during the annual budget
review process.
A detailed discussion on the benefits and costs associated with various funding mechanisms is
described in DTS Report 09-042 and the approved Stormwater Feasibility Study. For more
information about the Council approved rate methodology, the "tiered flat fee" refer to DTS
Report 10-016, which can be accessed on the City's website.
Program costs are equitably and fairly distributed in accordance with the recommendations
based on estimated impervious area in these amongst four (4) broad property classes (i.e.
42.4% residential single detached, 13.8% multi-residential, 33.9% taxable non-residential, and
9.9% tax-exempt non-residential). The proposed rate structure would enable an approximate
17.9% shift in overall stormwater program costs from residential users to the non-residential
sector.
2. Does the City have the authority establish new fees for stormwater?
Yes. Under the authority of sections 9, 10 and 11 and part XII of the Municipal Act, 2001, the
City has the authority to pass a "fees and charges" by-law for the purposes of funding
stormwater management. A user fee may be charged to cover the cost of a service and a key
component is to ensure that there is a nexus between the amount of the user fee and the cost of
the service being provided, such that it is not categorized as a tax.
A rational nexus was been clearly established between the amount of the user fee and the cost
of the service being provided - in that the more impervious area an individual property owner
has, the greater the amount of runoff and pollutant loading from the property and, consequently,
the greater the demand on the City's stormwater management system, either for flood control or
water quality treatment purposes.
3. Why is the rate that Waterloo is charging so much different than what Kitchener is charging to
the average residential property owner?
There are two key differences between the rates that Waterloo and Kitchener are applying, the
annual funding requirements, and the pace at which the Cities are transitioning from the tax
base to the rate base.
Using Waterloo's $2.4M annual budget, it would result in Waterloo's stormwater rate being
$4.43/month (100% in effect in 2013) compared to Kitchener's $13M budget resulting in
Kitchener's stormwater rate being $10.50/month; for an average residential property.
The other key difference is that Waterloo has opted to phase stormwater program costs from
the tax base to the rate base over four (4) years, 2011-25%, 2012-50%, 2012-75%, 2013-100%
rate based. In 2011, as such the average residential property in Waterloo will pay $1.11/month
in the first year of implementation (2011) ramping up to $4.43/month (100% in effect in 2013) .
In the case of Kitchener the shift from the tax base to the rate base will occur in one (1) year,
resulting in Kitchener's stormwater rate being $10.50/month; for an average residential property.
Both Waterloo and Kitchener staff are recommending a reduction in the tax levy by the base
budget, but in Waterloo's case this will be phased in over four (4) years (i.e. reduced by 25% in
2011, etc.), whereas in Kitchener's case this reduction would take place in 2011, and for an
average residential property owner, amounting to approximately $5.50 per month or around $66
for the year.
4. Should Kitchener consider phasing of the stormwater rate, similar to Waterloo?
It is not feasible to adjust and defer other capital projects in order to accomodate Victoria Park
Lake remediation and upstream stormwater management facilities projects, which requires an
approximate total capital expenditure of $16M. These issues were described in DTS Report 10-
023 and presented during 2010 budget deliberations. Council directed staff to seek ways to fund
Victoria Park Lake projects through a stormwater rate based approach.
If Kitchener were to move to multi-year phase-in of the rate, insufficient funds would be available
to in the next four (4) years to address this key priority for Council.
5. What is the revenue distribution within the tax exempt classification (ie PILOT versus other)?
Under the proposed stormwater rate structure, the revenue distribution among tax-exempt
entities is summarized in Table A1- Revenue Distribution in Tax Exempt Sector (i.e., relative to
the total rate revenue of $11.56M/yr and assuming a 95% collection rate).
Table A1- Revenue Distribution in Tax Exempt Sector
Tax Exempt Property Description # of
Properties Projected
Revenue % Total
Stormwater
Rate Revenue
Places of Worshi 134 $220,000 1.9%
Waterloo Catholic District School Board 24 $91,500 0.8%
Waterloo Region District School Board 50 $216,300 1.9%
Private School 6 $22,400 0.2%
Public College 1 $24,400 0.2%
City-Owned 1115 $551,300 4.8%
Other tax-exempt institutions (non-
residential ro erties onl 65 $24,400 0.2%
TOTAL for all tax-exem t ro erties 1,395 $1,150,300 9.9%
6. Can a special rate category be created to accommodate `places of worship" properties?
No. It is recommended that the rate schedule as proposed in AECOM's May 5t" technical memo
be adopted by Council as per recommendation #2 (refer to Appendix D of DTS 10-094) and
enacted through the stormwater charges by-law as per recommendation #3 (refer to Appendix C
of DTS 10-094).
Staff are not recommending an exemption exclusively for the "places of worship" from paying
the stormwater charge, as this would not be fair to other property owners in different rate
categories. The implication is that funding not generated from the "places of worship" sector
would have to be reallocated to the other rate categories, thus increasing the rates in those
other categories. Essentially, the utility would be viewed as subsidizing certain users within a
specific rate category, and would make the rate structure susceptible to legal challenges by
other users.
The methodology used to calculate the stormwater rate for these properties would remain the
same, based on measured impervious area and a separate tax-exempt category has been
created. There are readjusted rate tiers and this influences not only the non-residential tax
exempt property rate tables but also the non-residential tax exempt.
7. Can non-residential stormwater rates be based on actual measured impervious area?
Yes. In the future, if so directed by Council, the rate structure can be transitioned from the
approved "tiered flat fee" stormwater rate structure to a method where non-residential properties
would be charged according to their actual measured impervious area. Staff recommend
returning to this matter in approximately two (2) years and presenting a report to Council for
their consideration (recommendation #9).
DTS10-094 report recommends that a "tiered flat fee" stormwater rate structure be implemented
on January 1, 2011 (recommendation #2). The rate methodology provides for a fair and
equitable approach allocated costs associated with stormwater management to all property
owners in the City of Kitchener and is defensible.
However, to provide further equity and fairness, the City could adopt the methodology as
identified in the Stormwater Feasibility Study (2008) where charge non-residential properties
would be charged on their actual measured impervious area. For example if we consider a
property that has 2452 square metres of impervious area. According to the proposed rate
schedule it would be assigned a rate code 10 (1641 to 7676 square metres of impervious area)
or $140.70 per month. If the City were to adopt this approach then the stormwater rate charge
for the abovementioned example property would be calculated the following way:
Number of billing units = 2452 sq m / 259 sq m per billing unit = 9.5 billing units
Monthly amount = 9.5 billing units X $10.50 per month per billing unit = $99.40 per month
(One base billing unit is 259 square metres of impervious area at $10.50 per month)
Section 2 -stormwater Rate Credit Policy
1. Will Kitchener implement a stormwater rate credit program include and when will it start?
Yes. However, additional work is required to fully develop the credit policy manual and staff
have proposed that this policy be developed during 2011 for implementation in 2012.
It is important to recognize that a rate credit policy is rewarding "good actors" in the area of
stormwater management and tax exempt property owners can also take advantage of this credit
program in order to reduce their monthly stormwater charges, just like other non-residential
property owners.
A review of credit policies was completed as a part of the stormwater Feasibility Study (2008)
and was recommended that a stormwater rate credit policy be adopted based on the following
details:
• Credit eligibility to be determined based on the SWM practices and facilities on site;
• All non-residential properties, regardless of tax status, and communal stormwater
facilities that serve large residential subdivisions (e.g., >250 lots) would be eligible for
credits;
• The maximum credit is to be determined in the implementation phase; and
• Property owners must apply fora credit and certify that all facilities have been
constructed, operated, and maintained as designed. Property owners would also be
responsible for recertification, according to a process to be determined in the
implementation phase.
A stormwater rate provides incentives for property owners to provide on-site controls that
reduce their individual contributions of stormwater runoff and pollutant loading to the municipal
SWM system. Encouraging such source controls supports the Cities' SWM policies and water
quality initiatives. Property owner incentives can be achieved through the adoption of a
stormwater rate credit policy (refer to Appendix A of this report).
2. What are the benefits of implementing a stormwater rate credit program?
In municipalities that have implemented a stormwater rate, a credit policy has motivated
property owners to reduce their impervious cover. Some jurisdictions offer credits to properties
that are below defined impervious cover targets. Generally, knowledge of the credit system has
impacted the way new developments are built. However, with existing developments, the main
effect is for property owners to reduce their directly-connected impervious area (i.e., removing
impervious area reduces the charge more so than an increase in their credit scores). Typical
examples include treatment train approaches, such as redirecting parking drainage into
vegetated swales that absorb, evaporate runoff and reduce runoff volume and pollutant loading
to the outlet.
Based on the consulting team's experience with numerous stormwater rate implementation
throughout North America, there has been a noticeable relationship between the attractiveness
of credits (as determined by the number of credit applications) and the stormwater rate charge.
At low rates (e.g., below $3 per billing unit per month) there does not appear to be much interest
or motivation to apply for a credit. Ratepayers are generally motivated to take advantage of
stormwater rate credits when the rate is high (e.g., above $6 per billing unit per month).
It is difficult to quantify the "pay off" to municipalities that adopt a credit policy as part of their
rate program. Encouraging source controls supports many municipalities stormwater
management policies and water quality initiatives and is therefore a benefit from an
environmental perspective. Cost payoffs are less apparent and can vary with the density of
development. Implementing measures that reduce total runoff volume and pollutant loading
discharge to the SWM system will minimize the municipality's capital expenses. From the
property owner's perspective however, the pay off (i.e., return on their capital investment) will
depend on their unique site characteristics.
3. Can a stormwater rate credit policy be established for residential property owners?
Yes, however staff are not recommending that a residential stormwater rate credit program be
established at this time, due to the additional administrative costs of establishing the policy and
diminished benefits associated with it.
The link between incentive programs and the behavior of property owners is more obvious in
the water and wastewater industries, where incentives for people to install water-saving devices
have drastically reduced their water consumption and wastewater generation quantities. Credit
policies started in the 1970s, first with big industrial users who could achieve significant
reductions in water use and thus yield a corresponding reduction in the size requirements for
the municipality's treatment facilities. Incentives for the smaller commercial and residential users
came along in the 1980s, and although this reached out to more customers they did not achieve
the same water volume reductions as the few, large water users.
In comparison, credit policies for stormwater rates are in the early stages of development. Like
water and wastewater, incentive programs should target the critical property owners first (i.e.
large industries, shopping malls, colleges, schools, places of worship, etc.) before addressing
the individual single family homeowners (e.g., credits for rain barrels, rain gardens, etc.). For the
numerous though smaller impervious footprint of residential property owners, experience has
shown that a bigger overall impact can be achieved through public education on good
stormwater management housekeeping practices than through a credit program for individual
homeowners.
4. How does the user rate influence intensification?
The proposed stormwater rate schedule includes five categories representing high-density
multi-residential properties. The corresponding rate charges range from 0.2 - 0.7 times the
charge that would be assessed to the average single-detached home. These categories reflect
the principle that properties with a lower impervious area footprint would contribute less runoff
and pollutant loading and therefore be assessed a lower charge.
By assessing the charge in this manner, developments are encouraged that feature a lower
impervious area per unit area of development. That is, tall buildings with underground parking
and a smaller impervious footprint are encouraged over buildings with larger rooftop areas and
surface parking. nth the adoption of a credit policy, developments that feature on-site
stormwater management facilities are also encouraged (e.g., low impact development, or best
management practices).
In the long term, staff could consider changes to parking requirements or design standards that
would allow:
Redirect runoff to pervious areas. Rather than traditional curb/gutter drainage of parking
areas into catchbasins, runoff could be allowed to discharge into vegetated areas,
effectively disconnecting the impervious area from the collection system.
Reduce the impervious area requirements for parking. This can include such measures
as allowing overflow parking on pervious/vegetated surfaces, temporary and shared
parking areas.
Retain runoff on site. A future credit policy could reduce the charge for new
developments or developments that include retrofit controls that retain runoff volume on
site either as a minimum threshold amount (e.g., first 5 mm of runoff) or by restricting
discharge below pre-development levels (e.g., additional storage volume beyond
traditional pre-/post-development discharge control).
Section 3 -stormwater Program - 10 Year Capital and Operating Forecast
1. Can more detail be provided about the stormwater program 10 year capital and operating
forecast?
Yes. A detailed summary of the key aspects, which include Operation and Maintenance,
Environmental Compliance, Capital Improvement Projects, and General program areas of the
10 year operating and capital forecast are included in Appendix B of this report.
2. What are the potential cost adjustments in the base budget in each of the categories of the
forecast?
As identified in DTS 010-094 Table 1 -stormwater Program Comparison of 2007 Estimated
Expenditures and 2010 Updated Expenditures, there is an adjustment of $3.1 M in the base
budget for the stormwater management program, and as such the current service level estimate
(base budget) has been revised from $5.8M to $8.9M annually.
The updated base budget of $8.9M includes inflationary adjustments, refined construction cost
estimates not originally considered in the 2007 Feasibility Study, and the inclusion of
administrative and support service overheads. These adjustments are summarized in Table A2 -
Stormwater Program Base Budget Comparison.
Table A2 -Stormwater Program Base Budget Comparison
Activity 2007 Base Budget 2010 Base Budget Variance % Variance
O eration and Maintenance 1,591,015 1,882,109 291,094 18%
Environmental Compliance $90,000 $492,564 $402,564 447%
Capital Improvement Projects $4,085,380 $5,938,577 $1,853,197 45%
General Administration 54,515 593,252 538,737 988%
rogram ota °
The City allocates administrative overheads to operating units to better reflect the full cost of
providing service and to assist in setting appropriate user fees and charges. To be consistent in
developing the operating projections for the stormwater utility, staff have allocated a reasonable
share of corporate overheads to the Utility consistent with the approach for other enterprises.
These allocations do not reflect new costs to the rate payer; rather they are reflected in the shift
from taxes and other utility rate support and the corresponding reduction in the property tax
rates and other utility rates.
These overheads amount to approximately $1 million and are allocated to the various program
activities. The following existing functions: billing, collecting, customer service, facilities
management, dispatch, engineering management, human resources, finance/accounting,
purchasing, information technology, etc.
3. What are the potential cost adjustments in the sustainable level of service budget in each of
the categories of the forecast?
The 2007 Feasibility Study recommended an additional $4.1 M annually be added to the base
budget of $5.8M (2007) for a sustainable service level of $9.9M annually. As such, this same
service level was incorporated into the updated 2010 base budget figures fora $13M annual
sustainable service level. Table A3 -Stormwater Program Sustainable Service Level -Budget
Comparison. reviews 2007 program costs with the 2010 updated information in each of the
program areas.
Table A3 -Stormwater Program Sustainable Service Level - Budget Comparison
Activity 2007 Sustainable
Level of Service 2010 Sustainable
Level of Service Variance % Variance
Operation and Maintenance 2,523,615 2,596,808 73,193 3%
Environmental Compliance $97,000 $551,500 $454,500 469%
Capital Improvement Projects $6,862,869 $8,799,887 $1,937,018 28%
General 427,106 1,054,447 627,341 147%
SWM Program Total $9,910,590 $13,002,642 $3,092,052 31%
These costs include operational costs such as preventive and reactive maintenance, spill
response, stormwater monitoring, operation and maintenance costs, administration and
environmental compliance costs. Capital costs include significant increases due to system
rehabilitation projects, software upgrades, consolidated maintenance facility, accelerated
infrastructure renewal projects, and Victoria Park Lake remediation related expenses.
For more information about the Operation and Maintenance, Environmental Compliance, Capital
Improvement Projects, and General program areas of the 10 year operating and capital forecast
please refer to Appendix B of this report.
4. Are capital and operating costs being transferred from the tax levy to the rate base?
Yes. Staff reiterated that all attributable costs associated with the stormwater program would be
transferred from the tax levy to the rate base, as part of the recommendations of the stormwater
Management Feasibility Study and subsequent reports to Council during 2010 budget process,.
There would be transfer from the tax supported operating budget of $6,204,228 along with other
transfers occurring from the water, sanitary and gas utilities as identified in recommendation #4
of DTS report 10-100. The shift from the tax supported operating budget will be partially offset
by stormwater utility internal recoveries.
FINANCIAL IMPLICATIONS:
As stated in DTS report 10-094
COMMUNICATIONS:
Consultation Process -Update
As directed by Council, staff initiated additional public consultation with the school boards and
the "places of worship" during March, April and May 2010.
School Boards
Both the Waterloo Region District School Board and the Waterloo Catholic District School Board
have raised concerns as to a municipality's authority to apply stormwater rates to their
properties.
Council has directed staff to meet with the Boards as soon as possible in order to resolve this
matter.
Places of Worship
It is apparent that there are concerns around the financial impact that the rate will have on the
congregations at these "places of worship". Representatives from the "places of worship" sector
have reiterated that they provide certain community benefits, such as social support programs.
Most feedback either sought to reduce the stormwater charge, phase in the charge or eliminate
the charge completely.
Additional meetings have been arranged with the Kitchener-Waterloo Council of Churches and
a verbal report will be presented on May 17t" for Council's information.
CONCLUSION:
The purpose of the stormwater Management Program and Funding Review Study has
demonstrated and concluded that an equitable and defendable rate structure for stormwater is
feasible.
It is proposed that the stormwater rate by-law and its accompanying rate schedule be adopted
such that the applicable stormwater rate can be applied to all City of Kitchener property owners
starting on January 1, 2011.
ACKNOWLEDGED BY: Jeff Willmer, General Manager, Development and Technical Services
List of Attachments:
DTS 10-094 - STORMWATER RATE BY-LAW AND UTILITY IMPLEMENTATION
Appendix A -Concepts of a Stormwater Rate Credit Policy
Appendix B -Details Stormwater Program - 10 Year Capital and Operating Forecast (2011 to
2020)
Appendix A -Concepts of a Stormwater Rate Credit Policy (for discussion)
This section presents the general concepts of a stormwater rate credit policy for non-residential
properties that could be considered by the City of Kitchener.
Non-residential customers may qualify for stormwater rate credits when they can demonstrate
that their existing or proposed stormwater facilities or applied best management practices
provide the municipality with a cost savings that the municipality otherwise would incur as part
of their efforts to manage stormwater. The amount of reduction will be determined by the
municipality on a case-by-case basis. The specific policy would be developed during the
implementation phase of a stormwater rate.
Typically, credits are defined as percent (%) reductions applied as a credit adjustment to the
rate category that is applied to the property in question. Credits would be additive for each
credit category described below. As long as the BMPs are functioning as approved, as
demonstrated by self-certification reports and municipality inspections, the credit will be applied
to the charged fee. Credits would be applied retroactively for the first year of the revised fee
program, and for the next billing cycle for the applications received after that.
Stormwater Rate Credit Calculation
Best Management Practices (BMPs) may provide a single benefit or a combination of benefits,
in which case credits will be additive. The credit options have a maximum additive credit
capacity of 50% and the key areas are summarized below:
Credit Category Credit Points
Stormwater Volume Control Credit (maximum 30%)
Stormwater Qualit Control Structural BMP Credit maximum 20%
Integrated Non-Structural BMP Credit (maximum 10%)
Education Credit (maximum 5%)
CREDIT SUBMITTAL add 1, 2, 3 & 4 maximum 50% of total rate char ed
Stormwater Volume Control Credit
Stormwater volume control can be achieved through infiltration by two primary mechanisms:
a) Careful installation of approved structural BMPs (ex. infiltration ponds), or
b) Preservation of significant vegetated open spaces.
If flows generated on-site and from upstream areas greater than 1.3 km2 (for example) are
directed through the BMP or are controlled with on-site vegetated open spaces, then a site is
eligible for up to a maximum of 30% credit. This credit will be based upon hydrologic data, water
quality data, design specifications, and other pertinent data supplied by qualified, licensed
professionals on behalf of property owners.
On-site volume control credits awarded for structural BMPs shall be generally proportional to the
benefit that such systems have on complementing or enhancing the water quality and quantity
benefits to the municipality's stormwater management system.
Stormwater Quality Control Structural BMP Credit
BMPs identified in the MOE Stormwater Management Planning and Design Manual will be
eligible for a maximum credit of 20% if flows generated on-site are directed through the BMP.
This credit will be based upon hydrologic data, water quality data, design specifications, and
other pertinent data supplied by qualified, licensed professionals on behalf of property owners.
Credits for on-site stormwater facilities shall be generally proportional to the benefit that such
systems have on complementing or enhancing the water quality benefit to the municipality's
stormwater management system. Quality Control Structural BMPs that are eligible for credits
include, but are not limited to the following:
a) Vegetated Swales and Filter Strips,
b) Infiltration and Percolation Basins,
c) Infiltration Trenches,
d) Buffer Strips and Swales,
e) Porous Pavement,
f) Extended (Dry) Detention Basins,
g) Retention (Wet) Ponds, and
h) Constructed Wetlands.
Integrated Non-Structural BMP Program Credit
Credits may be issued for a site with ongoing implementation of an integrated suite of
fundamental non-structural BMPs that will help the municipality meet its permit objectives.
BMP1: Landscaping for Run-Off Rate Control and Water Quality
BMP2: On-Site Refuse Control Program
BMP3: On-Site Stormwater System Maintenance and Cleaning Program
BMP4: Paved Area Sweeping Program
BMP5: Used Motor Oil Recycling Program
BMP6: Sanitary Sewer/Storm Sewer Cross-Connection Inventory
BMP7: Employee Educational Program
BMP8: Storm Drain Stenciling Program
BMP9: Designated Vehicle Washing Area
Education Credit
Schools, public or private, would receive a credit if four (4) hours annually were dedicated to
educating one grade level of students about water quality awareness and protection.
Educational institutions would submit agendas to the municipality for environmental education
sessions that will include information concerning number of attendees, times), place(s), and
topic(s) covered during each session.
Appendix B -Details Stormwater Program - 10 Year Capital and Operating Forecast (2011 to
2020)