Regional Stormwater Plan to Save Taxpayers Money in Luzerne County

This article is an excerpt from the December 2017 issue of The Authority, a magazine produced by the Pennsylvania Municipal Authorities Association (PMAA). It is the second in a series of 3 articles about an innovative approach to stormwater management and MS4 compliance being pioneered by 31 municipalities and the Wyoming Valley Sanitary Authority.  You can read the first article here: How Municipalities in the Wyoming Valley Are Cutting Stormwater Costs by Up to 90% )

 

Lower costs and increase value

Thirty-one municipalities in Luzerne County are piloting a regional approach to MS4 compliance that may revolutionize the way Pennsylvania responds to the growing challenges posed by stormwater.

They have signed cooperative agreements with the Wyoming Valley Sanitary Authority, which will serve as MS4 permit coordinator for the entire region. In our previous post, we discussed the many ways a regional partnership can lower the cost of stormwater management for municipalities.

In this post, we’ll discuss how:

Cooperation benefits the taxpayer.

If regional cooperation lowers the cost of stormwater management, it stands to reason those cost savings will be passed on to the taxpayer. But, make no mistake, replacing aging infrastructure and constructing Best Management Practices will cost money, and that money will have to come from somewhere.

With municipal budgets already stretched to the limit, communities may have to consider new revenue sources. That could mean a tax increase or a stormwater fee.

Stormwater fees are generally a better deal for the average constituent. This is because a fee structure ensures everyone pays their fair share.

If taxes were raised to cover the cost of stormwater management, many property owners with large amounts of impervious area would be exempt: hospitals, schools, and other non-profit institutions. However, these institutions can sometimes be the biggest contributors to a community’s stormwater issues because stormwater runoff occurs when the water runs along impervious surfaces and cannot infiltrate the ground.

If stormwater management is paid for through a property tax increase, these non-profit organizations won’t pay for the services they’re using, but someone will have to, and that burden will fall on homeowners and small businesses.

Studies show time and again that the average homeowner would pay less for stormwater management if he or she were charged a stormwater fee than if the municipality raised property taxes.

The regional cooperation being pioneered by the Wyoming Valley Sanitary Authority is an especially good deal for local taxpayers: Our analysis showed that the average residential property owner will save 70 – 93% by paying a regional stormwater fee instead of paying an increased property tax.

The Wyoming Valley Sanitary Authority’s estimated stormwater fee is between $3.00 and $4.50 per month. This is lower than the other stormwater fees currently being paid throughout Pennsylvania, which average between $6.50 and $8.50 per month.

By using a regional approach, WVSA is able to lower costs beyond what an individual municipal authority could likely achieve. These numbers are even more impressive when you consider that the fees for most of the other municipal authorities included in the average above were calculated before taking 2018 MS4 permit requirements into account. Therefore, those communities may actually have to raise fees higher to meet the stricter requirements coming in the next permit cycle.  WVSA’s estimated cost already accounts for the 2018 permit requirements.

Municipal leaders are stewards of the public’s money, but they are also stewards of the environment. In our next post, we’ll discuss how regional cooperation on stormwater management can more effectively keep our rivers and streams clean for drinking, agriculture, and recreation.


Do you want to learn more about how stormwater fees provide the best value for taxpayers? Download our guide:

Determining If a Stormwater Utility Is Right for Your Community

Stormwater Utility GuideIt includes
• Answers to common questions about stormwater utilities
• More advice for how to build public consensus for stormwater fees
• An outline of the early steps you should take when investigating the feasibility of a stormwater utility

Download the guide

 


 

Jim Tomaine has more than 30 years of engineering experience. He holds a bachelor’s degree in civil engineering from The Pennsylvania State University and a master’s degree in business administration from Wilkes University. He is the executive director of the Wyoming Valley Sanitary Authority and has been at WVSA for twenty seven years.  Prior to the WVSA, Mr. Tomaine worked in the private sector as a design engineer. He currently holds his A-1 Wastewater Treatment Plant Operators Certification in Pennsylvania and is also a registered professional engineer.

 

Adrienne Vicari is the financial services practice area leader at Herbert, Rowland & Grubic, Inc. (HRG). In this role, she has helped the firm provide strategic financial planning and grant administration services to numerous municipal and municipal authority clients. She is also serving as project manager for several projects involving the creation of stormwater authorities or the addition of stormwater to the charter of existing authorities throughout Pennsylvania.

 

How Municipalities in the Wyoming Valley are Cutting Stormwater Management Costs by up to 90%

This article is an excerpt from the December 2017 issue of The Authority, a magazine produced the Pennsylvania Municipal Authorities Association (PMAA). Contact us if you’d like a copy of the entire article.

Justify your rates with asset management

Thirty-one municipalities in Luzerne County are piloting a regional approach to MS4 compliance that may revolutionize the way Pennsylvania responds to the growing challenges posed by stormwater.

They have signed cooperative agreements with the Wyoming Valley Sanitary Authority, which will serve as MS4 permit coordinator for the entire region. The following are just a few of the ways that partnership will save them money over the next 20 years:

 

 

Less paperwork.

Because the municipalities are submitting their permit requirements as part of a regional approach, the Department of Environmental Protection (DEP) is allowing them to submit just one Cheasapeake Bay Pollution Reduction Plan (PRP) for the region and a single PRP for each impaired watershed (for a total of seven Pollution Reduction Plans).

If each municipality had chosen to work alone, the region would’ve submitted more than 100 Pollution Reduction Plans to DEP. When the cost of producing one Pollution Reduction Plan can be more than $20,000, the cost to produce more than 100 would simply have been out of reach for this region.

But, by working together, the municipalities reduce the amount of paperwork that must be produced to comply with state requirements.  Fewer plans cost less money, and that lower cost is then divided among the participating municipalities.  At the end of the day, each municipality’s share of the Pollution Reduction Plan preparation cost is just $3,000.

 

Fewer, more efficient construction projects

Submitting the Pollution Reduction Plan is just step 1 of the compliance process. Once the plan is accepted by DEP, municipalities must implement it, and that typically involves the construction of Best Management Practices (BMPs) that reduce the quantity and/or improve the quality of stormwater runoff.

The most expensive part of constructing BMPs is acquiring the land on which to build them. When municipalities work alone, they are limited to constructing their BMPs within their own borders, and most municipalities don’t have an abundance of publicly owned land available for BMP construction. If they partner with other municipalities on a regional approach, they can get credit for constructing BMPs anywhere within the watershed.  With that flexibility, communities can install projects that yield the greatest pollutant load reduction for the lowest cost.  This often means they can meet their goals with fewer construction projects.

According to our analysis, municipalities in the Wyoming Valley would’ve had to construct approximately 200 projects to meet the pollution reduction goals individually (at a cost of $69 million). As a group, the municipalities will only need to construct 65 projects to meet those goals (at a cost of just $12 million).  This will save the municipalities more than $50 million on the cost of implementing their Pollution Reduction Plans.

 

Lower O&M costs through economies of scale

There are a lot of fixed costs in managing stormwater.  When you spread those costs over a larger number of users, the cost to each user gets smaller.  A feasibility study conducted by WVSA’s engineer determined that, as a group, cooperating municipalities would save $274 million on operations, maintenance, and improvements over the next 20 years by working together on a regional approach to stormwater management.

 

Increased purchasing and borrowing power

Generally, you can negotiate lower unit costs for items when you buy them in larger quantities, so, for example, pipelines could be replaced or slip lined for a lower cost if the work was completed as part of a larger, regional project.

 

Increased access to government grants and loans

Funding agencies tend to favor entities that are cooperating regionally to streamline costs, and politicians tend to support projects benefitting a larger constituent base.  Therefore, funding applications submitted by a regional cooperative are more likely to be awarded a grant or loan than those submitted by individual municipalities. These funding awards can save a community significant sums of money versus funding a project out of its own revenues.

 

When municipalities save money like this, it stands to reason they can pass those savings on to residents and business owners. In a follow-up post next week, we’ll discuss how the regional partnership model being pioneered in the Wyoming Valley is benefitting taxpayers in the region.


Jim Tomaine has more than 30 years of engineering experience. He holds a bachelor’s degree in civil engineering from The Pennsylvania State University and a master’s degree in business administration from Wilkes University. He is the executive director of the Wyoming Valley Sanitary Authority and has been at WVSA for twenty seven years.  Prior to the WVSA, Mr. Tomaine worked in the private sector as a design engineer. He currently holds his A-1 Wastewater Treatment Plant Operators Certification in Pennsylvania and is also a registered professional engineer.

Adrienne Vicari is the financial services practice area leader at Herbert, Rowland & Grubic, Inc. (HRG). In this role, she has helped the firm provide strategic financial planning and grant administration services to numerous municipal and municipal authority clients. She is also serving as project manager for several projects involving the creation of stormwater authorities or the addition of stormwater to the charter of existing authorities throughout Pennsylvania.

MS4 Audit: Resolve to be organized and ready in 2018

Happy New Year!

Most people use this time of year to get organized, so that they can put their best foot forward over the next 12 months. Ads for your local hardware store are jam-packed with sales on storage bins and closet organizers.

But the need to be organized extends beyond the home into the office, too. With MS4 permit requirements on the rise, many municipalities have seen their program grow in complexity over the past 5-10 years. With that added complexity comes a lot of paperwork: mapping, inspection and maintenance reports, etc.

PA DEP and the EPA both conduct periodic audits of MS4 programs, and the first step of the audit is to review the municipality’s records. So it’s a good idea to make sure your files are complete and well-organized now – in case 2018 is the year an auditor knocks on your door.

Most audits occur at random.

DEP uses the audit process as a way of educating local municipalities about what the MS4 program requires and answering municipalities’ questions about compliance. It is not meant to be an adversarial experience; it’s an opportunity to see whether your program is working and what you can do – if anything – to improve it.  Because it is mostly an educational outreach, fines are rare at this time, but, in the coming years, audits will focus more on program results, and fines will be more likely.  That’s why it’s important to get your MS4 program audit-ready now.

MS4 audit

What documentation do you need to have for an MS4 audit?

DEP provides an Inspection Report, which lists the documentation inspectors typically will ask to see. However, the inspector can ask to see other documentation not specifically listed in the Inspection Report.

Is your stormwater mapping complete and MS4 audit ready?

Is your stormwater mapping complete and MS4 audit ready?

In addition to the actual permit and program document, you should keep all monitoring data and reports for at least one year after the permit expires. You should also keep meeting minutes, inspection schedules and records, as well as documentation of illicit discharges and the methods used to resolve them.

You should have a thorough inventory (with mapping) of the location and function of all your stormwater facilities and any municipal facilities that impact your stormwater program. This includes:

  • All of your outfalls with an outline of their drainage area.
  • Inlets
  • All of your post-construction BMPs (even those that are privately maintained. The MS4 is ultimately responsible for ensuring these facilities are maintained properly, even if private owners have agreed to perform that maintenance. Make sure you have a copy of the maintenance agreement you made with the private owner.)
  • Maintenance and storage yards
  • Composting sites
  • Wastewater treatment facilities
  • Streets and parking lots

Furthermore, you should assemble your policies and completion records for street sweeping and snow removal, lawn care and vehicle fueling and washing.

DEP says that poor or unavailable mapping is one of the main problems encountered in an MS4 audit. Even if you haven’t received notification of an impending audit, it’s a good idea to speak with your engineer about whether your existing mapping is adequate. By the time an audit notification arrives, it will probably be too late to update the mapping then.

 

DEP has gone on record saying that it hopes to audit each MS4 program once during its five-year permit term, so it isn’t a question of “if” you will be audited but “when.”

The list of records an auditor can request is extensive, so it is not the kind of information you can pull together quickly (particularly if your mapping needs updated). You ought to make sure your records are in order now.

In addition, your staff should be knowledgeable of the program and able to answer questions about it effectively. Your engineer can provide training to prepare your staff for MS4 audits, if desired.

With a little advance preparation, you can be sure you’re ready when DEP comes knocking on your door.


Alex GreenlyAlex Greenly is a staff professional in HRG’s civil group. He regularly assists clients with MS4 permit compliance and has additional expertise in erosion and sedimentation control, hydrologic and hydraulic modeling, construction observation and municipal review of subdivision, land development, and stormwater management plans.

WEBINAR: Cutting Stormwater Management Costs Through Partnerships

Photo by Aaron Volkening. Used under a Creative Commons license.
Stormwater inlet

Stormwater management costs are on the rise.
MS4 requirements continue to become more stringent.
Aging infrastructure is nearing its useful life and will need replacement.
Can your community afford to address these issues?

 Yes, and this webinar can help.

In it, we provide real-world examples of how municipalities are working together to reduce the cost of regulatory compliance and infrastructure O&M. We also provide guidance on how to successfully negotiate intergovernmental agreements that protect everyone’s interests.

Adrienne M. VicariThe presenter, Adrienne Vicari, is our Financial Services Practice Area Leader. Her regional approach to stormwater management is projected to save municipalities in the Wyoming Valley more than $200 million over the course of 20 years. PA DEP Secretary Patrick McDonnell praised the initiative, saying “By working together, these municipalities are reducing pollution less expensively than they could if they were making these efforts separately. I am certain that the rest of the state will be looking at their exemplary leadership.”

The webinar was produced in partnership with the Pennsylvania State Association of Township Supervisors (PSATS) and is eligible for 1 secondary credit to PSATS Municipal Government Academy (PMGA) enrollees.

PSATS members can view the webinar for $20. Non-members can view it for $25.

 

WEBINAR: Manage Your Infrastructure Easily and Cost-Effectively

Do you know the location of your infrastructure assets?

Do you know what needs inspected and when?

Do you know which assets are most critical and carry the highest risk to the community if they fail?

 

The answers to these questions are crucial to protecting the safety of people and property in your community.

You’re responsible for miles of infrastructure, and your job is to make sure it continues to function for the people you serve. Whether it be pipes and inlets, roadways, or bridges, you have to keep them performing at an acceptable level of service, and, more importantly, you must protect local residents and business from the consequences of failure.

This has always been a complex job, but new regulatory requirements, aging infrastructure, and tight municipal budgets make it even harder.

An asset management program can make it easier and more cost-effective, and this webinar will show you how.

Asset management is a proven methodology for determining where to best allocate your infrastructure dollars. It helps you cut through the questions and prioritize exactly what needs repaired or replaced. It can also help you effectively plan and mobilize the money to address those needs.

In this webinar, we’ll discuss:

  • What asset management is and how it works
  • What types of technology is available to assist with asset management and how to determine your particular needs
  • The many benefits of asset management for better targeting O&M dollars; providing justification for rates, fees or budget allocations; addressing government reporting requirements; and communicating with the public.

Howard HodderThe presenter Howard Hodder is our Director of Geomatics. He has worked with dozens of communities to create asset management solutions for water, sewer, stormwater and other infrastructure assets. He has also published several articles on the topic and spoken extensively at industry conferences.

The webinar was produced in partnership with the Pennsylvania State Association of Township Supervisors (PSATS) and is eligible for 1 secondary credit to PSATS Municipal Government Academy (PMGA) enrollees.

PSATS members can view the webinar for $20. Non-members can view it for $25.

 

Flood Control Article Advice from Erin Letavic in Borough News

Erin Letavic, a project manager in HRG’s civil group, published an article in the July issue of Borough News magazine about flood control entitled “Mitigating Flood Risk in Your Borough.”  In it, she discusses the costs municipalities face when flooding occurs and offers  tips for how to minimize the risk of flood damage as much as possible.

Topics she discusses in the article include

  • Understanding your community’s flood risk
  • Improving floodplain management in your community
  • Expanding vegetation that absorbs flood waters and filters pollutants
  • Promoting the construction of green infrastructure
  • Obtaining funding for flood mitigation measures
  • Gaining public support for flood mitigation measures

Flood control strategies can help communities manage their flood risk and lower the potential cost of flood damage

Severe floods can happen in any community, and, when they do, they can wreak serious havoc: destroying homes and businesses, threatening people’s safety, temporarily shutting down the economy, and damaging infrastructure.

Communities can manage flood risk by implementing a flood mitigation strategy. The first step in flood control is to determine what areas of your community are most vulnerable to flooding and model exactly how those areas would be impacted by particular flood events. The next step is to make sure your ordinances and codes limit development in flood-prone areas and promote the planting and preservation of vegetation that will absorb flood waters and reduce flood intensity.

Successful flood control plans require cooperation among all stakeholders in a community, so it is essential to involve them throughout the planning and implementation stages. Obtaining grants and loans to support the initiative will help reduce opposition and lessen the impact on tight municipal budgets.

While the risk of flood damage cannot be completely eliminated, municipalities can greatly enhance the safety of their communities with a forward-thinking approach. The planning a municipality does today is key to weathering the storms tomorrow may bring.

Read the entire article here or in the print edition of Borough News magazine.

 

Watch Erin and other HRG personnel discuss the flooding that occurred around Harrisburg after Tropical Storm Lee and the measures local communities are taking to prevent similar damage in the future.

 

 

How EPA’s Stormwater Management Planning Guide Can Help with MS4 Compliance, Aging Infrastructure

EPA's planned guide on stormwater management planning can help municipalities address aging infrastructure and regulatory challenges under tight budget constraints.

Today, communities must address aging infrastructure and stricter stormwater management regulation (like MS4 permitting) under tight budget constraints. In order to be successful, they will need to take a long-term approach to stormwater management planning.  EPA’s new guide can help.

Recently, the Environmental Protection Agency published Community Solutions for Stormwater Management: A Guide for Voluntary Long-Term Planning. The current version is a preliminary draft (the final guide will not be published until later in 2017), and, when it is, it will be accompanied by a website and toolkit that helps communities navigate the recommended planning process.

But even in its preliminary form, the guide provides valuable advice about how to implement a long-term approach to stormwater management planning. Many of the steps outlined in the guide are an integral part of HRG’s approach to assisting our municipal stormwater clients.  Here are the major highlights:

Figure out where you want to go.

EPA recommends that you begin by identifying the goals you have for your stormwater management program.  This could include reducing runoff or improving water quality.  It could also include reducing flooding impacts or protecting natural resources like the floodplain and wetland areas.

The process for determining these goals includes talking to municipal staff as well as residents and business owners. One of your first steps should be to identify potential stakeholders in the community and a process for engaging them.  This could be the formation of a stakeholder advisory committee or open public forums.  At this time, you should also identify groups you can ally with as partners: watershed alliances, environmental groups, schools, businesses and community organizations, etc.

Throughout the entire planning and implementation process, you will need to communicate with the public, so now’s the time to establish how communication will take place: what media you will use, how often you will distribute information, and exactly what information will be communicated.

Determine where you are right now.

Before you can locate the path to success, you need to know your true starting point.  An early step in any long-term planning process is a thorough assessment of the current condition of your facilities. This includes finding and mapping your infrastructure, then documenting its condition and analyzing its performance.  It means determining the origin and destination of your stormwater management flows and considering future events that could threaten your facilities (significant weather events, new regulation, or the level of development in an area, for example).

This documentation could be made in the form of a paper map or a computerized geographic information system, depending on your goals and budget.

Chart a course.

Now that you know where you are and where you want to go, you can begin to evaluate the best possible way to get there.  In the previous two steps, you’ve identified your goals for an optimal level of service, and you’ve determined what your current level of service is.  In this phase of the process, a qualified consultant will help you identify the improvements you need to meet the desired level of service, including capital improvement projects and their associated cost.  He or she will also help you prioritize which projects should be tackled first.

In order to do so, the consultant will work with you to establish objective criteria for comparing various improvement alternatives. Some of the criteria you’ll want to consider include cost (not just construction cost but also life cycle costs associated with operation and maintenance), the potential burden on the community, the ability to reduce pollutants, improvement of receiving water quality, and public health benefit.

These steps are really just crucial components of an effective asset management and capital improvement plan.

Put it in gear.

This is the phase where you begin to implement the improvements you’ve selected.  It includes the creation of a detailed implementation schedule and the development of financial strategies to make sure the program is fully funded.

When looking for a consultant to assist you with a long-term stormwater management planning process, you’ll want to find one with ample financial expertise – someone who has extensive knowledge of the financing options available to municipalities, including grants and loans or user fees (among others).


HRG can help you evaluate whether stormwater user fees could benefit your community. Check out our guide:

Stormwater Utility Guide

Determining If a Stormwater Utility Is Right for Your Community

It includes:

• Answers to common questions about stormwater utilities
• Advice for how to build public consensus for stormwater fees
• An outline of the early steps you should take when investigating the feasibility of a stormwater utility

Download the guide at

www.hrg-inc.com/stormwater-utility-guide


Perform a check-up.

You’re not done yet! Once you’ve started implementing your plan, you’ll want to periodically assess how it’s working and make adjustments, as needed. Your consultant should clearly outline the metrics you will use to measure results. You’ll also want to track any cost savings your improvements produce.  This is important for providing the buy-in to keep the program going.  It will also help you identify ways to reinvest those savings.

As regulation and MS4 permitting requirements increase, municipalities will find that the historically reactive approach they have taken to stormwater management will not be enough to comply. They will need to take a more proactive approach to stormwater management planning based on their long-term vision for the community.  These tips are great place to start for creating that vision.

(If you’d like to learn more about stormwater management planning, visit our Water Resources page for a list of services we provide, more of our Insights on stormwater and MS4, descriptions of example projects we’ve completed, and profiles of our stormwater design professionals.)

 


Matthew Bonanno, P.E., Matt Bonannois the civil services practice area leader at Herbert, Rowland & Grubic, Inc. He has 15 years of experience in stormwater management, water resources engineering, and municipal retainer services throughout Central Pennsylvania. He can be reached at (717) 564-1121 or mbonanno@hrg-inc.com

 

Adrienne Vicari, P.E.,Adrienne M. Vicari is the financial services practice area leader at Herbert, Rowland & Grubic, Inc. In this role, she has helped HRG provide strategic financial planning and grant administration services to numerous municipal and municipal authority clients. She is also serving as project manager for several projects involving the creation of stormwater authorities or the addition of stormwater to the charter of existing authorities throughout Pennsylvania.

 

 

Utility Asset Management: Maximizing ROI

Money being washed down the drain

 

Each year, water and wastewater utilities send uncalculated dollars down the drain because of leaks and system failures, but asset management could provide the savings they need to respond to the creeping threats of aging infrastructure, water shortages, and increasingly stringent regulations.

Last year, UCLA filed a lawsuit against the Los Angeles Department of Water and Power for $13 million in damages sustained during a water main break on campus in 2014. This break released 20 million gallons of water onto Sunset Boulevard, flooding the street, campus buildings, and athletic facilities.

The lawsuit is just one of many claims the utility has received from people and businesses impacted by the water main failure; and it’s a reminder of the often hidden and forgotten costs utilities face when their infrastructure fails.

Every day, U.S. utilities produce 34 billion gallons of water, and 22% of it is lost through leaks. That’s billions of dollars in treatment, energy, labor and operations costs that cannot be recouped. These leaks cost the average utility more than $100,000 per year in revenue, but water main breaks like the one at UCLA can be even more costly.

Each year, there are approximately 240,000 water main breaks in the U.S., costing utilities an average $500,000 per break.

Much of our water and wastewater infrastructure is old and has far exceeded its life expectancy. Some pipes date back to the Civil War era! The cost to replace this infrastructure will be high, but, as these examples demonstrate, so is the cost of doing nothing.

As utilities struggle to budget for the replacement of aging systems, they continue to face increasing cost pressures from federal mandates. While the EPA establishes new limits on different contaminants (often requiring utilities to acquire new technology or improve their facilities), funding has not kept pace with these new demands. A report by the Water Infrastructure Network indicates that federal funding on water and wastewater systems has declined by more than 70% since 1980. As a result, local utilities have had to shift more of their revenue from operations and maintenance to new capital expenditures, leaving them even more ill-equipped to respond to an aging system.

At the same time, conservation efforts and improved technology have led many Americans to reduce their water consumption. While this is great for the environment, it translates into lower revenues for utilities – even as water acquisition costs increase (because utilities must turn to more expensive water sources once the least costly sources run dry).

With rising costs and shrinking revenues, utilities need to carefully manage every dollar to ensure the maximum return on their investment. The American Society of Civil Engineers estimates that the cost to make the improvements our water and wastewater system needs to keep functioning over the long term is more than $1 trillion. While there is plenty of work to be done, there is simply not enough funding to do it all at once. Therefore, ASCE recommends assessing the condition of every pipe and valve to determine the risks of failure and properly allocate funds where they are needed most. The need for asset management and capital improvement planning in the water utility industry has never been greater.

What is asset management?

Asset management is a systematic approach to minimizing the cost of owning, operating, and maintaining your infrastructure at acceptable levels of service.

It is not a computer system or GIS, though these are often valuable tools employed in an asset management program for record-keeping and data analysis. Depending on the needs of your utility, an effective asset management system could be as simple as an Excel spreadsheet or as robust as an enterprise level solution integrating all of your inventory, operations and maintenance, billing, and document management functions.  The solution can include mobile interfaces for supporting field crews and even interactive applications to enhance and promote public interaction and transparency.

While utility managers often reject implementing a large-scale asset management program because they think it will cost too much, the truth is: asset management is an investment designed to cut  inefficient or wasteful spending and stretch your budget further.

It is about optimizing how you spend your budget dollars in order to make sure they are providing the largest possible return on investment: reducing the life cycle costs of each asset you own while maximizing the service that asset provides over time.

A proper asset management and capital improvement program will help a utility identify areas where money is not being spent wisely and reallocate those funds where they can be most beneficial.

It will also help you recognize and evaluate options for keeping your assets functioning for a longer period of time, so that you don’t need to invest in expensive upgrades or replacements as frequently.

An asset management program involves:

Creating an inventory of what you have and its condition

Establishing your goals.

Prioritizing what’s most critical and directing resources to those needs first.

Measuring the results.

Analyzing those results and repeating or revising the cycle.

Circular Nature of Asset Management

 

It is a circular process that never ends. Many things change over time: the condition of your assets, regulations and the business climate you operate in, the number of users you serve, etc.  A good asset management and capital improvement program helps you plan for these changes in advance and respond proactively before they become threats to your bottom line.

Because of the tight financial constraints under which most utilities operate, they often take a reactive approach to budgeting for maintenance and replacements. As an asset fails, they make room in the budget to fix it or replace it, but this reactive approach will not be sustainable over the long-term.  Our infrastructure is too old, and too much work will be needed to be able to pay for it all at once.  Utilities need to plan for this inevitable future now, so that they can begin saving the money they will need in the coming decades.

 

Photo by Connie Ma. Published here under a Creative Commons license.

crews working overnight at a water main break
Proactive approach vs. Reactive: By monitoring the condition of your assets and planning for their maintenance and replacement in advance, you avoid the high costs associated with failures like this middle-of-the-night water main break.

Though the financial obligations associated with aging infrastructure, increasingly stringent regulation, and shrinking grant programs can seem overwhelming, asset management and capital improvement planning can help. Asset management helps you find the waste in your spending programs and put those dollars to better use. It helps you recognize potential threats to your system and minimize risk (thereby minimizing the financial damage those threats can do). It also helps you improve service to your customers and achieve buy-in from them when the case must be made for rate increases.

Investing in asset management and capital improvement planning can be hard to justify when utility budgets are stretched so thin, but the savings an asset management program can produce will more than pay for the program over time. Those savings, in fact, may be crucial to meeting the coming challenge of replacing our aging water systems and addressing the possibility of spreading water shortages.

In business, there’s an old saying: Sometimes you have to spend money to make money. With asset management, you spend money to save   money.

 

Asset management can also be a valuable tool for municipalities managing a stormwater system. As MS4 permit requirements continue to grow, municipalities need to know more and more about the location and condition of their stormwater infrastructure. HRG has extensive experience creating asset management systems for stormwater systems, and we offer a wealth of advice about meeting MS4 permit requirements and funding stormwater program needs through user fees. Check out these Insights for additional information:

Tips for Preparing Your 2018 MS4 Permit Application
Learn more about: the specific deadlines associated with the 2018 MS4 permit application, how to apply for a waiver from the new Pollution Reduction Plan requirements, what details must be added to the 2018 mapping, and how municipalities can collaborate with others to improve the effectiveness (and reduce the cost) of their MS4 program.


Paperwork

 

Stormwater Utility Guide
Get answers to frequently asked questions about stormwater user fees and advice on how to build public support for a fee in your community. This guide provides an overview of a user fee’s benefits and an outline of the steps one must take to decide if a user fee is right for their municipality.

Stormwater Utility Guide

Also check out these examples of our project experience with asset management for water, wastewater, and stormwater systems:

 

Capital Region Water, Harrisburg, Dauphin County, PA
Herbert, Rowland & Grubic, Inc. (HRG) is developing/customizing a Geographic Information System (GIS) database for Capital Region Water (CRW) potable water, storm sewer and public sanitary sewer infrastructure networks.

CRW Logo


HodderHoward Hodder, GISP, is the manager of HRG’s Geomatics Service Group. As such, he oversees the delivery of surveying and geographic information system services to all of our clients firm-wide. He has extensive experience in asset management for municipal clients, particularly in the areas of sanitary and storm sewer systems. Contact Howard with your questions about asset management and GIS.

 

Tips for Preparing Your 2018 MS4 Permit Application

Learn more about:

  • the specific deadlines associated with the 2018 MS4 permit application,
  • how to apply for a waiver from the new Pollution Reduction Plan requirements,
  • what details must be added to the 2018 mapping, and
  • how municipalities can collaborate with others to improve the effectiveness (and reduce the cost) of their MS4 program.

Get started now on all that 2018 MS4 permit paperwork

The 2018 MS4 permit cycle may seem far away, but the time to start preparing your permit application is now. Submission deadlines for portions of the application process begin as early as this December, and the final deadline for submission of your permit application is next September (2017).

If your municipality is one of the many subject to a new permit, new waiver, or new Pollutant Reduction Plan or TMDL requirements, you will need plenty of time and resources to produce the required documentation for your application.

Start now: the first submission deadline is just 3 months away.

As described in our previous post on the 2018 MS4 permit requirements, the new permit cycle adds requirements for Pollution Reduction Plans and TMDLs for many municipalities.  But it is possible for some of these municipalities to skip the submission of a Pollutant Reduction Plan altogether.

Municipalities may be eligible for a waiver from submitting a Pollution Reduction Plan if:

  • Their population size is small enough. (i.e. They have less than 1,000 people in their urban area or less than 10,000 in their entire municipality.) AND
  • They can show that none of their outfalls discharge to a locally impaired water OR
  • They discharge to impaired water, but DEP determines that they are not contributing to the impairment.

Deadlines are rapidly approachingIf you think your municipality might be eligible for a waiver, you will need to submit an advanced waiver request by December 31, 2016 at the latest. (In order to have time to review all applications thoroughly, DEP is requesting that you submit your applications even earlier, if possible.)

Mapping and paperwork are required for a waiver request, so you will need time to work with a consultant or government agency with GIS support staff to develop these materials.

 

Preparing an Advanced Waiver Request

Waiver requests must include:

  • A detailed map of the MS4, which includes all outfalls, storm sewers, surface waters, land uses, and any connections to other MS4s.
  • An outline of the drainage area for each outfall that discharges to impaired waters.
  • A written explanation of why your waiver is justified.

There is no application fee for an advanced waiver request. If your waiver is granted, you must include two copies of it with your completed permit application in September 2017.

NOTE: You must submit your waiver request by December 31 to avoid submitting a Pollutant Reduction Plan. Even if you qualify for the waiver, you will have to submit the plan if you didn’t apply for an advanced waiver by December 31 in case, upon review, a General Permit is actually issued by DEP.

 

Even if the advanced waiver deadline does not apply to your municipality, it is still imperative to begin planning for your 2018 permit cycle now. The pollutant reduction plans for the permit application are due next September, but the plan(s) must be completed and posted for public comment at least 45 days in advance, which is less than a year away.

Review/complete/update your map: New information is required.

MS4 permit requirements are moving from a qualitative approach to a quantitative approach: Instead of just implementing BMPs in a good faith effort to improve stormwater quality, municipalities are increasingly being asked to determine the exact nature of their discharge and specifically demonstrate how they are reducing the quantity and concentration of pollutants. Good mapping is essential to this task because you cannot eliminate illicit discharges if you do not know where they originate.

Accordingly, DEP has clarified what permittees must map and submit with the 2018 permit application. This includes:

  •  The location of privately owned storm sewers and other government-agency-owned facilities that connect to the municipal system.
  •  A delineation of the storm sewershed for each stormwater outfall.

What is a storm sewershed?

It is the entire land area that drains to a particular regulated MS4 outfall. (Outfalls are any discernible, confined conveyance of stormwater that discharges to surface waters. This includes pipes, ditches, channels, etc.)

Why are storm sewersheds relevant?

Municipalities subject to Pollutant Control Planning are required to develop an inventory of pollutant sources within their MS4. The storm sewershed will define the areas to be investigated in order to identify and investigate potential pollutant sources.

Municipalities with Pollution Reduction Plan requirements have specific goals for reducing their pollutant contributions. The storm sewersheds will minimize the planning area for existing base loads, and identify locations of BMPs that will provide the necessary pollutant reduction in those areas. (Municipalities with Pollutant Reduction Plan requirements include Chesapeake Bay watershed contributors, municipalities with watershed impairments attributed to nutrients and/or sediment, and TMDLs.)

In the current PAG-13, municipalities are expected to ensure the proper operation of all stormwater facilities within their MS4 (even privately owned facilities), some of which are not accessible (feasibly, legally, etc.). For this reason, DEP will now accept observation points on the mapping which indicate where municipal staff can inspect facilities that are not accessible due to safety or legal concerns.

Collecting data for mappingFor existing permittees, the 2018 mapping should include:

  • Municipal boundary lines.
  • 2010 Urbanized Area.
  • The location of all regulated outfalls – even those that are privately owned but connect to the public system. (Each outfall should be numbered for reference and should include observation point locations, where applicable.)
  • Surface waters that receive drainage from the MS4.
  • The entire storm sewer collection system that is owned or operated by the permittee including roads, inlets/catch basins, piping, swales/channels, and storm sewersheds.

The purpose of this map is to track illicit discharges and map storm sewersheds for pollutant reduction planning. While digital mapping functions best for suburban municipalities and cities, boroughs may exist at a scale where less sophisticated mapping techniques may be more cost efficient and equally effective.

Watershed crossing municipal boundaries

Watersheds often cross municipal boundaries, so cooperation can be very beneficial when controlling stormwater.

Consider the value of working with others:

Stormwater does not recognize municipal boundaries. It continues to flow down slope, regardless of where the borders of an MS4 regulated area may lie.  But a municipality working on its own can only manage that stormwater as it flows through its boundaries.  With the new emphasis DEP is placing on pollutant reduction, municipalities may need to work together with their neighbors in order to meet their regulatory obligations.

Recognizing this, DEP is strongly encouraging collaboration in the 2018 permit cycle and in statewide training sessions provided in 2016.

The language of the permit instructions specifically addresses the formation of regional stormwater authorities:

“If a regional authority is created to administer stormwater management programs throughout multiple municipalities, the authority may apply on behalf of its municipalities using a single [form]. If DEP approves the [form], the permit will be issued in the name of the regional stormwater authority.”

DEP recognizes that collaboration between municipalities requires an agreement, which clearly outlines the rights and responsibilities of each member. The formation of a stormwater authority is an effective means of forming this agreement, but many municipalities have historically questioned who would be responsible for permit compliance: the municipality or the authority.

By clearly stating that the permit responsibility will be issued to the authority, DEP eliminates this concern, clearing the path for authorities to form. This makes it possible for multiple municipalities to truly share responsibility equitably.

DEP suggests working with local sportsmen’s groups, environmental groups, colleges, and others on public education efforts required by MCMs 1 and 2 and long-term implementation of BMP installation.

Such collaboration is already occurring in some areas. For example:

The Paxton Creek Watershed Education Association, Manada Conservancy, and Penn State Extension have extended their services to municipalities for educational workshops on rain gardens, rain barrels, stream buffers, etc.

Lower Swatara, Middletown Borough, Royalton Borough, and Conewago Township have partnered together to identify similar stormwater program issues, opportunities for collaboration, and a funding plan to realize achievable goals. This effort is being fundedthrough a grant received by the Alliance for the Bay.

DEP encourages municipalities to check with their county government and other entities for mapping data. Many counties have mapping available that could provide a foundation for the MS4 mapping the permit requires.  Other sources for mapping layers include DEP, USGS, and the US Census Bureau.  (Note that these entities can provide general basemap-type layers, but municipalities will still most likely need to supplement this with specific data about their stormwater infrastructure.)

Municipalities can also work with their local sanitary sewer authority.

Some sewer authorities have pretreatment requirements for businesses that discharge sewage with contaminants that cannot be treated by the sewage plant. If a property like this has pretreatment requirements for its sewage, there is a chance its stormwater runoff may also be contaminated. If the sewer authority shared its list of businesses subject to pretreatment requirements with the municipality, it could help municipal staff identify potential pollutant sources (a new requirement associated with Pollution Control Measures and Pollutant Reduction Plans).

DEP continues to encourage cooperation with the county conservation district on construction and post-construction stormwater management plans.Many municipalities have been working with their county conservation district on this for several permit cycles.

In general, the paperwork associated with construction and post-construction stormwater management is now understood to be subject to Chapter 102 regulations. If those regulations are delegated to the conservation district, the municipality will not have to track anything for MCM 4 under its MS4 program.  (Illicit discharges will still be handled on a case-by-case basis, but they would likely be addressed under Chapter 102.)  BMP operation and maintenance continues to be a long-term responsibility for municipalities to track, but not necessarily perform, specifically.

silt fence at construction site

In Summary, Get Ready

The Commonwealth of Pennsylvania must meet federal water quality goals, and MS4 permittees are one piece of the overall watershed improvement plan. Wastewater improvements have been invested in for decades, agricultural accountability continues to improve, and urban stormwater (until proven to not be part of the water quality “problem”) continues to be a regulatory target.

The 2018 permit will require municipalities to more closely identify pollutant sources and begin mitigating them. New MS4s will have a steep learning curve, depending on their impaired watershed status and proximity to the Chesapeake Bay.  This is over and above the job of getting acquainted with the new acronyms they need to “speak” and other permit obligations to perform.

The new permit application requires existing MS4s to complete their maps (if not completed to date) and requires many MS4s to create and publicly vet Pollutant Reduction Plans. It will take time to compile this information, so municipalities should begin preparing their 2018 permit application components now.

Some municipalities may be able to obtain a waiver that eliminates the Planning requirement, but they should preliminarily apply for that waiver before December 31, 2016.

Collaboration with other municipalities, the county, and local community groups can help a municipality meet the more stringent requirements of the 2018 permit cycle. DEP encourages this collaboration but does not require it.  Still, the language of the 2018 permit cycle specifically clears a path for collaboration by allowing regional authorities and less rigid coalitions to assume ownership of the MS4 permit obligations.  Local governments can stretch their tax dollars if they think less locally.

If you have questions about the 2018 MS4 permit requirements and pollutant reduction planning, please contact Erin Letavic.


As MS4 permit requirements continue to increase, many municipalities are wondering where they will find the funding to meet these requirements. A stormwater user fee program is one option to consider, and HRG can help you decide if it is the right choice for your municipality. Download our guide:

Determining If a Stormwater Utility Is Right for Your Community

Stormwater Utility GuideIt includes
• Answers to common questions about stormwater utilities
• Advice for how to build public consensus for stormwater fees
• An outline of the early steps you should take when investigating the feasibility of a stormwater utility

Download the guide at

www.hrg-inc.com/stormwater-utility-guide


Erin LetavicErin G. Letavic, P.E., is a project manager in HRG’s Civil Group. She guides municipalities and cooperative groups throughout Pennsylvania through the management of their MS4 permits, provides grant application development and administration services, and provides retained engineering services to local government.