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MSD proposes rate allocation changes and three pilot programs instead of an impervious‑surface fee

5405233 · July 16, 2025
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Summary

The Metropolitan Sewer District told Hamilton County commissioners it will pursue rate‑design changes and three targeted pilot programs to reduce wet‑weather impacts — a lower‑cost alternative to a complex impervious‑surface fee that MSD says would require millions in billing system upgrades.

The Metropolitan Sewer District presented alternatives on July 15 to a previously studied wet‑weather impervious surface charge, recommending changes to rate allocation plus three pilot programs to reduce stormwater impacts without the high administrative cost of a new countywide impervious‑surface billing system.

"Over 90% of the funds, the revenue that we bring in comes from our sewer service charge," Diana Christie, MSD director, told the Board of County Commissioners. Christie said the current rate design includes a monthly minimum charge based on meter size and a commodity charge for volume over 3 CCF. Residential winter averages are used to avoid billing customers for summer outdoor water use that does not reach the sewer system.

Christie said MSD and the county completed a feasibility study on a uniform wet‑weather impervious surface charge (WISC), but implementation would be operationally complex and expensive, involving large billing‑system changes for MSD's municipal billing partners. Christie said the WISC approach also risks rate instability because it would create a major charge category with many potential credit appeals.

MSD offered three near‑term alternatives:

1) Shift how unbilled inflow and infiltration (I&I) is allocated. MSD currently recovers 75 percent of unbilled I&I costs through the customer component and 25 percent through metered volume; MSD recommends moving to a 40/60 split (customer/volume). Christie said the visible effect would be removing the declining block rate so that volume above the minimum is charged at a single commodity rate. MSD expects a modest decrease for most residential bills and modest increases for commercial and industrial customers.

2) Evaluate further reduction of the monthly minimum charge (currently based on 3 CCF) to help low‑volume users such as seniors. Christie said MSD reduced the minimum from 5 CCF to 3 CCF in 2018 and will study the financial implications of reducing it further.

3) Study a transition from meter‑size billing to customer‑class billing, with additional study planned before any change that would likely be considered in 2027.

Christie said MSD favors these rate design changes because they can be implemented more quickly and with far lower administrative cost than the previously studied impervious surface charge.

Neil Frink, an MSD attorney, presented three programmatic pilots intended to directly reduce wet‑weather flows and localized backups (SBUs): a downspout‑disconnect pilot in combined‑sewer neighborhoods, a partnership pilot with municipalities to require I&I credits for new development in development‑constrained sanitary areas (proposed IGAs with Springdale and Sharonville), and a targeted program to work with the largest impervious‑site owners (properties with more than two acres of impervious surface) to offer mitigation options or phased charges. Frink said the district's monitoring, modeling and the impervious‑surface data now provide a basis to run focused pilots.

Frink noted the largest ~500 properties with more than two acres of impervious surface account for as much impervious area as about 47,000 residential properties; among the top 12 on that list are shopping centers, rail assets and Paul Brown Stadium. MSD would evaluate property‑level flows and offer options for mitigation or billing where sites send runoff to MSD's combined system.

Christie said MSD and the county will seek stakeholder feedback on these alternatives and return with budget/rate proposals this fall; some pilots and intergovernmental agreements could begin within months. Commissioners asked for stakeholder outreach, cautioned about impacts on small businesses and nonprofits, and requested clarity on timelines and potential legislation required to authorize pilots.

No rate ordinance was adopted at the meeting; MSD recommended the commissioners consider the described alternatives as more affordable and administratively feasible than the WISC studied previously.