Strategies for Airports to Reduce Local Stormwater Utility Fees (2018) / Chapter Skim
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Pages 33-48
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From page 33... ...
33 This chapter provides guidance on fee mitigation options and strategies and is primarily geared toward airports currently being assessed stormwater fees (see Figure 10)
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34 Strategies for Airports to Reduce Local Stormwater Utility Fees This information may be verified through a point of contact at the stormwater utility and through information and manuals made available on the municipal or county website. Awareness of Fee Changes Finally, airports should remain up to date on any developments or news regarding the utility.
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Strategies for Fee Mitigation for Airports Paying Stormwater Fees 35 • Provide a basis for collaborating with the utility on strategies the utility may be able to help them with, working within the current structure of the utility. Optimizing Use of Utility Credit Programs Stormwater utility fee credit programs provide an effective and equitable option for reducing fees and have been used by several of the airports that participated in this study (see Examples 5–7)
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36 Strategies for Airports to Reduce Local Stormwater Utility Fees • Credit elements that are not easily applied in an airport envi ronment: Stormwater fee credit programs may focus on BMPs that are not applicable to airports and may conflict with FAA requirements regarding wildlife hazards (e.g., structural BMPs that promote standing water or involve vegetation that can attract wildlife)
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Strategies for Fee Mitigation for Airports Paying Stormwater Fees 37 Use of Credit Programs Example 5 One medium-hub airport pays fees to a stormwater utility with a credit program. The program offers credits for both control of peak flow and for stormwater quality improvement.
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From page 38... ...
38 Strategies for Airports to Reduce Local Stormwater Utility Fees are billed correctly. This may be particularly important for ensuring that impervious area is not double counted if the airport spans more than one jurisdiction and pays fees to more than one utility (see Example 8)
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Strategies for Fee Mitigation for Airports Paying Stormwater Fees 39 owned by the jurisdiction associated with the utility rather than another jurisdiction or a separate airport authority. In some cases, the utility may not be able to provide stormwater services to the airport because the airport is considered commercial property rather than public.
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40 Strategies for Airports to Reduce Local Stormwater Utility Fees There still may be challenges even if the utility can provide stormwater maintenance services to the airport. One airport acknowledged that they can submit projects to the utility but admitted that it can take a while for the utility to complete the project due to other demands.
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Strategies for Fee Mitigation for Airports Paying Stormwater Fees 41 3.4 Awareness, Outreach, and Communication Strategies at the Local Level This group of mitigation strategies focuses on awareness of fee-related developments and maintaining effective and collaborative communication with utilities, including education and outreach. This section also discusses strategies for working and negotiating with a stormwater utility or local jurisdiction to fairly and equitably mitigate fees that may place a financial burden on the airport.
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42 Strategies for Airports to Reduce Local Stormwater Utility Fees Airports should make sure to provide the utility information on the airport's stormwater management, including details of the stormwater system, runoff discharge locations, the system's performance for reducing runoff and peak flow, and water quality treatment. This will facilitate discussions with the utility about optimizing airport use of the utility's fee credit program (discussed in Section 3.2)
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Strategies for Fee Mitigation for Airports Paying Stormwater Fees 43 3.5 Governing and Enabling Law -- State Level Airport strategies to advocate for governing and enabling law at the state level usually involve extensive effort, resources, and outside legal expertise. Because these strategies are situationspecific and may be complex, they are addressed briefly in these sections.
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44 Strategies for Airports to Reduce Local Stormwater Utility Fees Engagement and Lobbying Strategies to Promote Exemptions (Including State Legislation) Airports should advocate for exemption of runways and taxiways, especially if the stormwater fee program is considering exempting or already exempts public roadways.
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Strategies for Fee Mitigation for Airports Paying Stormwater Fees 45 Establishment of an MS4 at an Airport Establishing a separate MS4 at an airport may allow it to better manage and mitigate NPDES stormwater permitting compliance and, as a result, lower its stormwater fees. However, this strategy could be politically sensitive and require intensive negotiation with state and local regulatory agencies.
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From page 46... ...
46 Strategies for Airports to Reduce Local Stormwater Utility Fees Establishment of an Airport Stormwater Utility Another option for an airport is to establish its own stormwater utility. However, this can be complex and will be dictated by state and local regulations.
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Strategies for Fee Mitigation for Airports Paying Stormwater Fees 47 3.6 Tools for Airports Paying Stormwater Fees Checklist for Understanding the Local Utilities and Fees Assessed Knowing the Utilities and the Fees Assessed Check when completed Document and verify basics about the stormwater utilities Document and verify basics about the stormwater fees assessed Routinely check for utility and fee updates affecting the airport Checklist for Facility/Infrastructure-Related Strategies Property Parcel Configuration Check when completed Determine if your fee is parcel-based Verify the records and locations of airport parcels Determine if parcels can be consolidated/restructured Get an estimate for the time and expense to consolidate parcels Determine if the reduction in fees will be sufficient to justify the expense of the restructuring Requesting Services from the Utility Check when completed Determine whether the utility has authority to provide stormwater maintenance services to the airport Clarify the types and frequency of services that the utility routinely conducts Determine activities most appropriate for the utility to perform (e.g., maintenance of BMPs on the landside) and whether any specialized knowledge is needed for the maintenance (e.g., care of certain types of vegetation)
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From page 48... ...
48 Strategies for Airports to Reduce Local Stormwater Utility Fees Checklist for Fee Recovery Fee Recovery Check when completed Verify whether your stormwater fee bill includes the entire airport, including tenants, or if tenants are billed separately by the utility Assess whether an increase in tenant fees would result in opposition from tenants and whether or not it may compromise competitiveness with other nearby airports Consider the amount that would be appropriate to recoup; determine portion of fees needed to recover from tenants to meet budgetary needs Evaluate options for recovering fees: • Included in lease agreements as part of general expenses (i.e., not as a line item) • Directly passed onto tenants according to case-specific measures (e.g., use of impervious area, use of stormwater system)
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