This type of study provides a holistic evaluation of the current stormwater program and future needs as well as organizational, legal, and financial issues (including operational facets, e.g., the billing system). It will also provide a plan for the robust engagement of stakeholders, which has often been vital to the ultimate success of such efforts in communities where SWUs have already been successfully implemented.
This study will provide in-depth information, surface the critical issues, and inform a multi-year financial roadmap for long term stormwater management and funding resilience. The review should also include an in-depth, parcel-level analysis of impervious area that can be used for billing purposes and robust stakeholder engagement. Such a comprehensive study typically requires a minimum of 8 to 10 months depending on the time needed for an in-depth analysis of impervious area. It will also be more costly than the preliminary feasibility study.
Some items that the Comprehensive Feasibility Study should address are as follows:
- Identify the Project Team & Process
It will be beneficial to have members on the project team with expertise in the following areas:
- Watershed Planning
- Regulatory Compliance
- Public Outreach Facilitation
- Program Funding Strategies
If there are no project team members that possess the expertise in these areas 'in house', it would be appropriate to hire professional consultants for those portions of this exercise. In fact, this step is often outsourced to professional consultants.
When selecting a professional consulting firm, it is advisable to select a group that specializes in developing stormwater management programs. It would also be helpful if the firm were familiar with local issues. An initial meeting, or series of meetings, will need to be held to establish the scope of work to be performed. Primary contacts to act as liaisons between the prospective utility and the project team should also be established at this point. The agendas for these earliest meetings should cover the overarching needs and goals of the stormwater management program, including MS4 permit requirements and compliance needs, stormwater projects already planned and/or underway for the municipality/service area, as well as other general stormwater concerns, such as those related to stormwater-related flooding, Combined Sewer Overflow (CSO) Long Term Control Plans, and Harmful Algal Blooms (HABS), if applicable.
Then, throughout the process, the prospective utility group should meet frequently on a predetermined schedule with project team to discuss progress being made toward milestones and outstanding questions/concerns that may have arisen from either party.
As you begin this process and begin setting goals, you may be interested in researching other communities across the country that have experience with conducting these types of Comprehensive Feasibility Studies. As of the end of 2020, there were nearly 2,000 SWUs that have been established across the country and Canada. As we have noted in other locations on this website, Western Kentucky University performs an annual survey of SWUs across the country and Canada and summarizes this information each year in Table A-1 of the survey posted here. Here is just a small sample of SWUs who have provided details on the process they followed to determine whether a Stormwater Utility was the right choice for them:
As noted above, this Comprehensive Feasibility Study should expand in much greater detail and precision on these issues mentioned in the Preliminary Feasibility Study above in Step 2.
During the conceptual discussion phase noted above, a preliminary high-level inventory of all stormwater assets including stormwater facilities and infrastructure, and other ancillary assets including equipment and personnel needs should have been conducted. At this step in the process, it is essential that the Comprehensive Feasibility Study include a complete inventory of all stormwater facilities owned or operated by the municipality(ies) within the potential service area. The same information should be gathered for privately owned facilities as well. This information is necessary to determine the current and future needs of the stormwater program.
As a reminder, the MS4 permits require municipalities to ensure proper operations and maintenance of all privately owned facilities.
Inventory details should include location, age, size/dimensions, material, as well as ownership information for the following:
- This inventory should include all stormwater facilities, including those that qualify as green infrastructure in accordance with the Stormwater Management rules at N.J.A.C. 7:8-5, and their condition, which includes but is not limited to:
- MS4 outfalls*
- storm sewer manholes
- storm drain inlets*
- catch basins*
- retention basins*
- detention basins*
- vegetative filter strips*
- riparian buffers
- infiltration basins
- sand filters*
- constructed wetlands*
- wet pond*
- bioretention systems*
- low flow bypasses
- green roofs
- blue roofs
- pervious pavement
- manufactured treatment devices (MTDs)*
- stormwater conveyances (channels, pipes, ditches, etc.)
- CSO outfalls
- CSS infrastructure
- and any other less common stormwater related facilities, such as stormwater pump stations, flood control devices, etc.
- Note that stormwater facilities with an “*” are included in the NJDEP stormwater infrastructure mapping tool. The Department has developed this free mapping and inventory tool for users to develop an inventory and map of their stormwater facilities. This tool utilizes mobile devices such as tablets and smart phones to allow the user to collect stormwater infrastructure feature locations and descriptive information. Information regarding logging inspections, routine maintenance, needed upgrades, and repairs can also be added via this tool. Much of this information is also required under the NJPDES MS4 general permit. For details, please visit https://www.state.nj.us/dep/dwq/msrp_map_aid.htm.
- Depicted above is a ‘generic’ example of a stormwater facility inventory. A ‘complete’ stormwater facility inventory should include relevant information for all stormwater facilities within the utility’s service area. Please visit the link to the mapping tool above for more information and to access templates created by the Department.
Additional needs related to stormwater management should also be considered, including but not limited to:
- salt storage
- maintenance yards and buildings
- vacuum trucks
- computers, smart phones, and/or tablets, etc.
This information is also essential to the functioning of the stormwater utility and is important to account for in your Asset Management Program and to be factored into the utility’s fee calculation.
As inspections are conducted to verify inventory, it is also advisable to conduct assessments at that time of the condition of those stormwater facilities as that information will be necessary for the next step of the study.
For each stormwater facility in your inventory listed above, identify and describe how they fit into any of the following categories, if applicable:
- green infrastructure
- combined sewer system (CSS)
- CSO long-term control plan
- owned, operated, or used by another entity (be sure to include the name of that other entity).
Identify Needs & Expenses
Based on the information gathered through the previous steps, it is necessary at this point to review the stormwater operations (as they relate to any MS4 requirements, CSO permits or any LTCP requirements, and community stormwater goals) and identify gaps to determine the resources needed to bridge them.
Areas to review to identify these gaps include, but are not limited to:
- What new infrastructure or infrastructure repairs, upgrades, or replacements are overdue, as well as those that will likely be necessary for the next 5 years, 10 years, and beyond.
- What continuing and additional maintenance activities will be needed for each facility.
What areas in the town(s) experience stormwater-related flooding (be sure to consider a residential complaint log).
- What additional resources will be necessary to address the following, if applicable:
- MS4 and CSO Permit Requirements
- CSO Long Term Control Plans
- Total Maximum Daily Loads (TMDLs)
- Other water quality impairments in the potential service area
- Community stormwater goals
For more information about HABs, please visit https://www.state.nj.us/dep/hab/. For more information on TMDLs, please visit https://www.nj.gov/dep/dwq/msrp-tmdl-rh.htm.
Now, you will need to evaluate whether current staffing and associated budget levels are sufficient to support the operation of stormwater program, including the concerns noted above, and meet community goals. If these current resources are not sufficient, what additional resources are needed to bring the stormwater management program into compliance with the MS4 (and/or CSO) permit requirements and/or to meet the full goals of the community?
Define the current status of all the aspects of the stormwater program (including those aspects to meet the MS4 permit requirements, CSO permit requirements and community stormwater management goals) by detailing:
- the age and condition of all the infrastructure noted above
- the required routine maintenance activities
- current and upcoming capital projects
- standard operating procedures
- community stormwater goals
- current and future compliance needs with regulatory/MS4 permit requirements and/or Combined Sewer Overflow Long Term Control Plans (CSO LTCPs)
- associated budget and staffing
You should carefully review the MS4 Stormwater Permit and the CSO permits and contact NJDEP to determine if the stormwater program is in full compliance with those permit requirements.
Much of this process is also part of developing an Asset Management Program. See Asset Management for additional information .
Analyze Impervious/Pervious Surface:
As discussed in further detail in the Determining Fees and Credits, the Act requires fees to be based on a fair and equitable proportion of the amount of stormwater runoff from properties in the service area. To develop an appropriate Rate Structure, this portion of the feasibility study will need to at least include an analysis of the impervious surface coverage of properties in the service area, including a breakdown of various residential property sizes, as well as commercial and other non-residential properties.
Develop Level of Service Options
The project team should then establish at least 3 levels of service along with multiple options for fees and credits to see which approach is best suited to the municipality potential service area.
The associated funding needs for each of these options will need to be developed to be presented, along with various rate structure and fee options (as discussed below), for the decision-makers and community stakeholders to evaluate.
Prepare materials to share with the public in the municipality, or larger service area, that will show how the fees will be utilized to pay for various aspects of the stormwater utility. See Using SWU Fees to determine the allowable expenses. Be sure to include:
- costs to get the program started
- capital expenses
- ongoing operations and maintenance
- asset management
- activities related to permit compliance for the MS4 permit, and the CSO permit, if appropriate
- costs for public education/outreach
Click here to read more about utilizing fees appropriately.
Fee & Credit Structures
Once the Levels of Service have been laid out, next the Fee and Credit/Rate structure options need to be developed to match the budgets for those levels of service discussed above. Remembering, of course that regardless of which Rate Structure option is chosen, fees must be based on a fair and equitable proportion of the amount of stormwater runoff from properties in the service area.
As noted in step E above, the Comprehensive Feasibility section, there will be different fees associated with the different Levels of Service. Prospective SWUs should also consider developing more than one Rate Structure option to demonstrate how the different options affect fees for various types of property owners.
The municipal or service area executive(s) will examine the results of the feasibility study and come to agreement about how to proceed. If the study outcome demonstrates that A) there is a need for funding beyond what is available through the current stormwater management budget and B) a Stormwater Utility is a potentially viable option to the problem, then this information should be developed into materials to proceed with engaging all stakeholders, including governing body(ies) and other municipal commissions, boards, or councils (planning boards, environmental commissions, etc.) and community members.
Prepare matierals to share with the governing body(ies) and other municipal commissions, boards, or councils (planning boards, environmental commissions, etc.).