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Concord staff outline stormwater utility options, propose $118 ERU and $1.1M revenue target

Public Works Commission, Town of Concord · October 9, 2024
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Summary

Public works staff and consultants presented options for a new stormwater enterprise driven by EPA MS4 compliance, proposing an initial Equivalent Residential Unit (ERU) rate of $118, a target program budget of about $1 million (roughly $1.1M gross), and a credit policy with a typical maximum of 50%.

Town of Concord Public Works staff and Weston & Sampson consultants presented an introductory plan for a stormwater enterprise that would fund stormwater management and compliance with the EPA’s MS4 permit.

At the meeting the consultant explained the fee concept centered on an Equivalent Residential Unit, or ERU, defined as the average impervious surface on a single-family parcel (presented as 5,570 square feet for Concord). "We're starting out by setting the ERU rate at a hundred and $18," the consultant said. Staff said the program would aim to net roughly $1,000,000 for implementation, with a gross collection target of about $1,100,000 assuming typical crediting of 10 percent back to property owners.

Why it matters: the MS4 permit requires communities to invest in stormwater quality and quantity controls; staff warned that failing to meet permit obligations can trigger federal enforcement and costly fines. The commission’s discussion emphasized that creating a dedicated enterprise is intended to distribute costs more equitably than the general tax levy because tax‑exempt properties currently do not pay property taxes but would be included in a stormwater fee.

Details and options: presenters outlined three approaches to residential billing: a single flat fee for all 1–3 family residences, a tiered structure that groups residential properties by impervious-area bands, or a mixed model that bills larger nonresidential parcels directly by measured impervious surface. The consultants said the measured approach can be more equitable for large parcels but increases administrative tracking; a flat fee simplifies billing. The presentation included examples using aerial imagery and the town’s GIS to show delineated impervious surfaces and parcel-level data.

Credits and administration: staff said a credit program would be part of the design to encourage property owners to reduce or manage runoff on-site. "Typically there would never be a credit that would be more than like 50%," the consultant said, noting credits require inspections and administrative capacity. Commissioners raised questions about administrative costs of tiered billing versus flat rates and whether smaller communities have adopted hybrid approaches; consultants said some towns begin with simpler fees and revise later.

Timeline and next steps: staff emphasized the two-step process: (1) include a budget placeholder for the enterprise at town meeting and (2) hold a statutory rate-setting hearing after town meeting once the budget and enabling bylaw are in place. The consultant and finance staff said they will provide a draft report, sample credit policies used by other communities and parcel‑level data for public review before a public hearing.

What was not decided: commissioners did not set final rates or adopt the credit policy. Staff said fees may not be billed until at least July 1, 2025, per the enabling bylaw timeline presented, and that additional public outreach and analysis of administrative needs will continue.

Next procedural step: staff will circulate the draft report and comparative community examples, continue public outreach, and return to the commission with a recommended structure ahead of the public rate hearing after town meeting.