The Boston Water and Sewer Commission (Commission) hired Raftelis to study the feasibility of developing a stormwater management fee and to also help them implement the fee. The Commission, which is a separate unit of local government, owns and maintains the sewer and storm drainage systems within the City of Boston. The Commission’s stormwater discharges are regulated under a NPDES permit to which it is the sole permit holder; and the Commission’s combined sanitary system is regulated by a joint NPDES permit with the Massachusetts Water Resources Authority (MWRA). The Commission, under its obligations of its NPDES permit and Consent Decree to ensure compliance with the Clean Water Act, is obligated to develop, implement, and maintain stormwater-related management and best management practices (BMPs). In addition to ongoing activities related to stormwater compliance (tracking sanitary sewer overflows, implementing CMOM, illicit discharge detection, etc.), the Commission submitted a BMP Recommendations Report in fall of 2016. This plan was accepted by the EPA and outlines the Commission’s plan to implement structural BMPs, Green Infrastructure (GI), and Low Impact Development (LID) city wide over the next 30 years to improve stormwater water quality and comply with the Consent Decree and Clean Water Act. The program requires substantial increases in capital and operating expenses, and those expenses are added to the ongoing maintenance obligations of the stormwater drainage system, which should be differentiated from the City’s wastewater system.
Raftelis developed a 30-year cost projection for the stormwater program, determined the optimal fund structure and billing mechanism, conducted a study of comparable organizations’ fee practices, provided analysis of and recommendations on rate structure, developed the draft rate base including consideration of the impacts of other large governmental entities in the service area, made recommendations on a credit or incentive program, developed a public fee portal, and provided assistance with public outreach. Raftelis also developed a cost allocation model that laid out the financial plan for water, sewer, and stormwater. The model, in use by the Commission’s finance department, includes the functionality to allocate Commission costs on a detailed level and to model fixed cost allocation scenarios developed by Raftelis and staff.
Raftelis worked with the Commission’s implementation team and billing system vendor on incorporating stormwater billing capabilities in its new billing system that went live in September 2019. Due to the global COVID-19 pandemic and shifting Commission priorities, the implementation of a stormwater fee has been put on hold.