The City of Columbus, Ohio is under two consent orders from the Ohio Environmental Protection Agency (OEPA) related to wet weather issues. One order deals with combined sewer overflows (CSO) while the other addresses sanitary sewer overflows (SSO). The City recognized that these two issues were related and needed to be dealt with in an integrated approach. This decision led to the development of a Wet Weather Management Plan that addressed both CSO and SSO issues. A critical component of the plan was the affordability analysis. Consistent with United States Environmental Protection Agency (USEPA) guidance, OEPA required that an affordability analysis be performed which followed USEPA, “Combined Sewer Overflows – Final Guidance for Financial Capability Assessment and Schedule Development”. The City wanted an approach to affordability that was specific to Columbus within the overall framework of the guidance. The City also established that the analysis had to be dynamic and be useful in the future as economic conditions and project considerations change.
The City had a choice regarding affordability. One option was to establish a completion schedule and then define projects that would be affordable given that schedule. This approach had the potential to limit the scope of the improvements. The second approach was to establish the projects necessary to achieve a set of reduction goals (service level) and then to test the affordability of this solution set against a variety of schedules using a set of affordability criteria. The City adopted this latter approach and established the following goal for the analysis: “To ensure that any schedule for improvements is as expeditious as possible while maintaining affordable rates for all consumers”
The City engaged stakeholders to help develop a robust set of measures that could be used to test for affordability in a dynamic and comprehensive manner. The adopted measures included the following:
- Overall Impacts
- Vulnerable Population Impacts
- Local Economy Impacts
- Housing Impacts
- Maximum Aggregate Bill Increase
- Percent of Customers in Advanced Delinquency
- Maximum % HHI Impact for Vulnerable Population
- Housing Starts
- Number of Households Mortgage Eligibility Impacted
- Number of Renters Driven over the Housing Cost Burden Threshold
For each of the components, a trigger level was established based on local demographic data. For some, the target was sensitive to the implementation period (i.e., maximum aggregate bill increase). Others were more a measurement of potential effects of the program costs on the economy (i.e., housing starts). If any one of the trigger levels is exceeded in any given year, the City will propose modifications to the implementation schedule to get the measure back in line with the trigger level.