Water Watch NYC

Everything you need to know about water in NYC.


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Ten Ways to Save the DEP – #2: Introduce Stormwater Fees

Almost any effective CSO mitigation plan that the city can possibly come up with will involve the creation of large multi-billion dollar retaining tanks and force our water/sewer rates to skyrocket. So here comes our out of the box thinking: How can we mitigate the negative effects of CSO without spending billions of dollars restructuring our sewer system?

The Citizens Action Committee (CAC), made up of industry experts, recommended that the city use water and sewer rates to incentivize owners to retain water on site. Currently, New York property owners do not pay to dump stormwater but by levying such charges the city can effectively incentivize owners to retain water on site and eliminate CSO occurrences, as the CAC recommended. More importantly, the administrative costs to the city would be minuscule compared to the billions that would be spent building huge tanks. As a bonus, on site retention can also have other environmental benefits (for example, green roofs mitigate the effects of urban heat island).

In recognition of the above, the mayor’s PLANYC Sustainable Stormwater Management Plan 2008, Initiative 10 states:

The City’s current water rate structure is comprised of a charge for consumption of water and an additional 159 percent for all sewer, stormwater, and wastewater services. Because this rate structure fails to reflect the true costs of stormwater generation and can lead to distortions, the City is currently undertaking a yearlong study to consider improvements. The City is analyzing its current expenditures, reviewing the rate and credit programs of other municipal water systems, and estimating the impacts of alternative stormwater rate structures on ratepayers and revenues. This effort will be coordinated with other ongoing efforts to map impervious areas in the City and to overhaul the program for water bills.

The “yearlong study to consider improvements” that the plan refers to is Booz Allen Hamilton’s (BAH) rate study, the results of which were released last week. (You may remember BAH from many of the other studies they performed for the DEP in the past. They are, after all, the DEP’s favorite go-to accounting firm when using the Water Board to bypass the contract bidding process.) The first thing worth mentioning is that this “yearlong study” took more than a year. Shocker.

But that’s not as important as the results. So let’s look at the results. The DEP paid BAH over a million dollars to “[analyze] its current expenditures, [review] the rate and credit programs of other municipal water systems, and [estimate] the impacts of alternative stormwater rate structures on ratepayers and revenues.” I would have thought that BAH would calculate the administrative costs involved and the feasibility of enacting a stormwater fee. Then they would project the savings as a result of on site stormwater retention and avoidance of the creation of stormwater retention facilities. I expected graphs indicating the relationship between the different possible stormwater rates and expected consumer response. (If we charge 5% of the water rate we need $2 million to implement the program but it’ll take us 20 years to recover that two million. If we charge 30% of the water rate  we need $2 million to implement the program and we’ll recover the costs in less than a year. Something like that.) In short, how large (or small) a fee would you have to implement to start seeing a savings.

What BAH did instead was what every college student does when the deadline is up and they haven’t done any of their work. They reiterated the question. Don’t get me wrong–they did it well. They included five pages of meaningless charts (fancy, but meaningless) showing which cities use which rate structures. But they didn’t address the crux of the problem. There is nothing in the report about the effectiveness of such a program, what it would cost the DEP to implement it and how much can be saved by stormwater avoidance.

The only thing BAH actually put forth in their conclusions (slide 30 of this presentation) is the following: “New billing system must be in place in order to fully implement a City-wide stormwater rate structure and credit program.” It’s subtle. Did you catch it? It sounds to me like BAH’s pitch to sell the DEP a new rate program, one that would no doubt take another few years and another few million dollars.

In summary, we hope that the good people at the DEP and the Water Board go ahead with stormwater rates and are not put off by the BAH report. To quote the mayor’s office in Appendix K to the Sustainable Stormwater Management Plan, Environmental Entrepreneurs, a national community of over 850 prominent business leaders who believe in protecting the environment while building economic prosperity, had the following to say about stormwater rates:

We strongly urge the City to include in the Plan a firm commitment to restructure the water rates to implement a separate stormwater fee, varying based on the imperviousness of a site, as soon as possible. We understand that a rate restructuring study is now underway and urge that the consultants conducting that study be asked not whether a separate stormwater fee is practicable – because we know it is, based on the experience of many jurisdictions around the country – but rather how to implement such a fee structure in New York City as soon as possible.

Again, special thanks to the good folks at SWIM for fighting for this one. We’ve even heard DEP Deputy Commissioner of Environmental Planning and Analysis Angela Licata advocating for stormwater fees at a few Water Board hearings.


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Ten Ways to Save the DEP – #1: Better CSO Notification Procedures

Like most older sewage systems, New York City’s sewage system is what’s known as a “combined sewer system.” This means that the system was never built to accommodate clean rainwater and dirty wastewater separately and therefore, when it rains, the clean rainwater is dumped into the sewer outfalls together with our dirty wastewater.

Sewer Systems

Top: Combined Sewer System. Bottom: Separate Sewer System.

In the image above you can see a perfect example of how NYC’s older sewer system (top)  differs from newer, “separate sewer systems” (bottom). As you see, during dry weather, all that happens in both cases is that wastewater goes to the publicly owned treatment works (POTW). But when it rains, new systems keep the wastewater and rainwater separate and send only the wastewater to the POTW while the clean rainwater goes to the river.

In NYC, when it rains, a mix of rainwater and wastewater goes to both the POTW and to the river. As a result, after heavy rains our sewer outfalls often experience what is called a “combined sewer overflow” or CSO. During a CSO it is dangerous to boat, swim, fish or conduct countless other activities around the heavily polluted water.

The existence of CSOs is in itself a problem that the DEP has to deal with. But it is a problem that will take years and years and billions and billions of dollars. What can we do to mitigate the dangers of CSOs right now?

CSO Outfall Sign

CSO Outfall Sign at Wallabout Bay

The answer is better CSO notification procedures. NYC currently has about 500 CSO outfalls according to the New York Water Environmental Association. In 1999, the city began putting signs up at their CSO sites like this one at Wallabout Bay. The signs say “IF YOU SEE A DISCHARGE DURING DRY WEATHER PLEASE CALL! 311.” Now, I ask you: if you hadn’t read the first three paragraphs of this post, would you know what this means? I wrote the first three paragraphs of this post and I’m still not sure what this means!

Here’s another problem: If it just rained last night and this afternoon your son or daughter wants to go swimming in, say, Paedergat Basin, how are you supposed to know whether or not they are about to climb into a toxic cesspool?

Thanks to pressure from our friends over at SWIM (Storm Water Infrastructure Matters), the DEP (with a little help from HydroQual Environmental Engineers) recently created a web page where you can check on the status of CSO sites around the city. I include a link here so that you can take a look yourself and decide if this is sufficient for a system that has 500 CSO outfalls that your child can be swimming in, that your husband can be fishing in or that the entire family can be taking a boat ride in.

We live in an age obsessed with notifications. The federal government requires notifications on every single pack of cigarettes and bottle of alcohol. The mayor requires calorie counts to be posted in every donut shop in NYC. Why are we more concerned with what we put inside our bodies than with what we put our bodies into? A large, easy to read sign near every single CSO outfall into New York that says something to the effect of “IF YOU SEE WATER COMING OUT OF THIS PIPE, DO NOT SWIM HERE. ALL WATER COMING FROM THIS PIPE IS TOXIC AND DANGEROUS TO YOUR HEALTH” is the best way to keep us safe from the unfortunate, unavoidable effects of CSO.


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Green Roof – Blue Roof

The environmental community is rallying behind efforts to reduce combined sewer overflow (CSO). CSO occurs in New York City when rainfall overwhelms sewage treatment plants resulting in raw sewage being dumped into the adjacent estuary. The city’s solution has been to build huge retention tanks to store the rainfall until the sewage plants can process the load. Unfortunately, retention tanks are extremely costly and the city can not afford to complete construction of the proposed tanks anytime soon.

In response to NYC’s procrastination, the environmental movement has proposed a myriad of best management practices including point of use retention and detention systems. The most popular solution is green roofs. Green roofs are simply roof top gardens that retain rain water to irrigate planting on the roof, hence retaining rainwater on the site. They have the added benefit of eliminating heat island effect, reducing CO2 and literally making the city a greener place. Green roofs are a very elegant solution when intelligently designed and maintained. The drawback is that in cash strapped properties green roofs would be the first system to be neglected. Since environmental realists do not want their solution dependent on building management, they have proposed blue roofs. The concept is quite simple; store rainfall on the roof and slowly allow it to trickle out of the building. In this manner you mitigate the effects of excessive rainfall on the sewage treatment plant.

Recently, many groups have been proposing mandating green and blue roofs. Proponents recommend that all buildings with flat roofs be required to install either a green or blue roof. I wholeheartedly encourage the proliferation of green and blue roofs. However, I oppose any efforts to mandate green or blue roofs. They are just one tool in a plumbing engineer’s toolbox to combat CSO but the toolbox also includes retention tanks, water reuse, irrigation, gray water and a myriad of other design choices. Do we really want to prohibit the installation of rooftop playgrounds and swimming pools? Do we want to find architects specifying sloped roofs solely to exempt a building from green roof requirements? I propose that we require any building applying for sewer permits (SD1&2) to demonstrate that they will retain enough water on site so as to eliminate local CSO occurrences. The DEP should specify retention/detention parameters to accommodate the local infrastructures. Some neighborhoods may not require any retention while other locations with poor sewer infrastructure may have to retain a large percentage of their rainfall. This customized solution might appear to be cumbersome but in reality it is similar to the current procedure used by the DEP to minimize storm water flooding. All the DEP has to do is enhance their requirements for storm water retention. With these requirements in hand, the plumbing engineer can devise an ingenious solution to meet the DEP’s parameters. After careful consideration the engineer might decide on a green roof, blue roof or devise a new solution and term it a yellow roof. The field of study is too new for the city to mandate a specific solution that applies across the board. The DEP should mandate specific requirements and allow the plumbing engineers to do their job.


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New Stormwater Control Techniques Planned

James GennaroOn November 8, City Council Member James Gennaro will be joined by representatives of the Storm Waters Infrastructure Matters (SWIM) environmental coalition to announce the introduction of three stormwater management bills aimed at reducing the amount of raw sewage that flows into New York Harbor.

“The development and implementation of a Sustainable Stormwater Management Plan is essential to reducing stormwater runoff into the City’s sewers, which directly results in massive amounts of pollutants and pathogens being dumped into our waterways due to combined sewer overflows,” Councilman Gennaro said. “Introducing ‘green’ stormwater control techniques, such as maximizing the use of parks and other green spaces to capture and store water, building green roofs, and protecting wetlands, will not only take the strain off our over-taxed sewer system, it can also reduce flooding, which is a big deal in Queens, where flooding has repeatedly destroyed people’s homes and businesses. This progressive legislation will improve the City’s water quality, allowing for expanded recreational uses of our water; add new green spaces; mitigate flooding; and add capacity to a sewer system that, frankly, is in dire need of help.”

Water Watch NYC thanks SWIM for their press release about the press conference and hearing. More info can be found at the SWIM website here.

Water Watch NYC also wishes to commend Council Member Gennaro for his efforts to build a better economic and environmental stormwater management system for NYC’s home and business owners.

All are encouraged to attend tomorrow’s hearing, which begins at 1:00 pm, and to the press conference on the steps of City Hall which will take place prior to the meeting.

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