Demand equitable water rates for New York City

water rates Photo: Steve Johnson, CC

Despite grave needs to improve the New York City’s sewer infrastructure, the Water Board has proposed a rate increase of 2.31%, much less than increases in other cities. In the face of the largest sewer overflow problem in the country, New York City’s rate is 15.5% less than the average of the 30 largest American cities. While continuing to implement and strengthen protections for low- and moderate-income ratepayers, the Water Board should raise New York’s rates on par with other large cities to help address our failing infrastructure needs.

The Water Board should also consider the potential to make rates more equitable. Other cities like Philadelphia and Washington, D.C. have structured their water rates to separate water consumption costs from stormwater treatment costs. New York City has no separate stormwater fee. This means big box stores with large roofs and parking lots pay nothing for their polluted stormwater runoff, sticking the rest of us with the bill.

New York can do better. Send comments to the Water Board today and ask your City Council representative to do the same.

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Honorable Alfonso Carney, New York City Water Board, DEP

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Dear [Decision Maker],

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I urge you and your fellow members of the New York City Water Board to reject the Department of Environmental Protection's (DEP) proposed Fiscal Year 2020 water and sewer rate increase, and instead set the water rates commensurate with the city's pressing needs for stormwater and sewage infrastructure. I further urge you to eliminate the rental payment and direct DEP to expedite its stormwater fee feasibility study and solicit meaningful public participation.
 
The rate increase must be at least on par with other cities, which have averaged 6.1% growth over the past 10 years. New York City's stormwater and sewage waste needs are greater than any other city's. Each year, more than 20 billion gallons of raw sewage mixed with polluted stormwater pour into New York City waterways. While it is crucial that rate protection programs continue and expand for low- and moderate-income families, New York City must acknowledge that its current Long Term Control Plans and Green Infrastructure Program--even when completed 30 years from now--will be insufficient to meet the goals set forth by the Clean Water Act for fishable and swimmable waters throughout the city. Additional investments are necessary.
 
The map of city waterways presented to the Water Board by DEP staff on May 1, 2019, insinuates that water quality is safe. It is not. That map is based on outdated science, which the federal Environmental Protection Agency no longer accepts as safe for human health. New York still uses the outdated method of measuring fecal coliform as an indicator of fecal contamination in waterways. Measuring instead for Enterococci bacteria, a scientifically defensible method, shows that city waterways are often too polluted for human contact following rainfall. The poor water quality that prevents our communities from utilizing these resources should be a priority concern in setting water rates.
 
New York should eliminate the Water Board's rental payment to the city. We appreciate the Mayor's decision to forgo the rental payment once again in Fiscal Year 2020. By avoiding diversion of ratepayer funds to the City's general fund, this provides an opportunity to direct additional, necessary resources toward improving our water infrastructure. Given these necessities, the rental payment should be eliminated for good. The Water Board should petition Mayor de Blasio, who has the power to amend the lease agreement, to permanently eliminate the rental payment.
 
City DEP should expedite its stormwater fee feasibility study and commit to meaningful public participation. Other cities like Philadelphia and Washington, D.C. have structured their water rates to separate water consumption costs from stormwater treatment costs. New York City has no separate stormwater fee. This means big box stores with large roofs and parking lots pay nothing for their polluted stormwater runoff, sticking the rest of us with the bill.
 
The rate structure should incentivize responsible stormwater management that reduces the burden on the city's sewer system and lowers overall costs for ratepayers. And it should ensure that all New Yorkers have affordable access to water and sewer service sufficient to meet their basic needs, even as rates rise over time to maintain and improve the system.
 
Specifically, call on the Water Board to, in connection with your approval of 2020 rates, direct DEP to conduct a study and develop recommendations for rate restructuring that simultaneously promote:

(i) equitable generation of needed revenues
(ii) widespread use of green stormwater infrastructure
(iii) water conservation practices
 
The study should address at least three new rate structure components: separating the stormwater charge from the wastewater charge; tiered water and wastewater rates; and expanded low-income assistance programs. The Water Board should require DEP to complete this study in time to present recommendations for the Water Board's consideration at the next rate setting cycle, in the spring of 2020. We highly recommend that the Water Board require DEP to facilitate early and meaningful stakeholder participation in this study, such as through the creation of an equitable rate restructuring advisory committee. DEP's current plans for such a study would drag on for more than three years, with no guarantee of public participation. That leaves our polluted waters to languish in the interim. The study must not be delayed any longer.
 
Thank you for your consideration of these requests.

Respectfully submitted,
[Your Name]
[Your Address]
[City, State ZIP]