Enhanced Affordability Analysis of Combined Sewer Overflow Long-Term Control Plans – Omaha’s CSO! Program

The City of Omaha has an Administrative Order of Consent with the State of Nebraska, which has been negotiated with the Nebraska Department of Environmental Quality (NDEQ). The Order requires the City to meet the requirements of the Combined Sewer Overflow (CSO) Control Policy of the Clean Water Act by 2027. More than 90 projects identified in the City’s Long Term Control Plan (LTCP) are scheduled to improve water quality in area rivers and streams at a cost of approximately $2.0 billion, with over $400 million spent since the LTCP was implemented, beginning in 2010.For local communities engaged in consent decree negotiations with federal or state regulators related to compliance with the Clean Water Act and/or Safe Drinking Water Act, completion of a Financial Capability Assessment (FCA) is standard requirement (USEPA, 1997). The FCA is both a quantitative and qualitative benchmark that is intended to provide a basis of comparison between communities. The components of the FCA are defined by USEPA guidance promulgated twenty years ago; comprising a variety of demographic and economic metrics, and a single key quantitative metric: the Residential Indicator. The Residential Indicator compares an imputed cost per household for sewer service to the community’s median household income. Since promulgation of these requirements, based on input from the US Conference of Mayors, National Association of Clean Water Agencies (NACWA), and various other parties, USEPA has advised consent decree communities to submit additional information to enhance the understanding of financial issues. The FCA is extremely important in USEPA’s determination of the compliance schedule imposed in these cases.The results of an enhanced affordability assessment approach applied in the City of Omaha, called the Weighted Average Residential Index or WARi™ are intended to demonstrate the financial burden of the City’s LTCP on its residents, as well as fairly reflect the benefits of the City’s existing rate assistance programs. Results of this analysis better characterize the financial burdens of Order on Consent compliance for the City. WARi provides the City with a valuable analytical tool to precisely identify the neighborhoods where financial burdens are most pronounced, and to focus its limited financial assistance resources in ways that can achieve measurable results that further reduce financial burdens of the LTCP.