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Stormwater board flags five-year ERU review, monitoring and equipment needs

March 12, 2024 | White House, Coffee County, Tennessee


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Stormwater board flags five-year ERU review, monitoring and equipment needs
The Stormwater Advisory Board on March 11 discussed a required five‑year evaluation of Equivalent Residential Units (ERUs) under the city’s MS4 permit, staff funding set aside for that review and related monitoring work with the Tennessee Department of Environment and Conservation (TDEC).

A staff presenter (Speaker 4) told the board that “it’s been 5 years since the ERU evaluation has been done” and that scope and methodology for a new review remain under discussion. Speaker 4 said money has been budgeted for the next fiscal year should the board decide to hire an outside vendor to collect data and perform analysis. Speaker 2 pushed back on hiring consultants for routine revenue and rate calculations, saying the department typically does the enterprise fund math internally and that outside studies should be weighed against that need.

The discussion focused on how the city sets stormwater rates from enterprise‑fund revenue needs and whether a consultant is necessary. Speaker 2 described the typical rate‑setting approach: calculate operating needs, then divide by ERUs to determine whether rates should be increased or held steady. Speaker 4 said staff had contacted vendors to learn about processes and costs and that funding for a study is available if the board chooses to proceed.

Board members also discussed monitoring requirements under the MS4 permit. Speaker 4 said staff were talking with TDEC and other MS4 programs to identify optimal monitoring locations for waters leaving the city’s MS4 and to clarify testing requirements.

Operational capacity and equipment shortfalls featured in the conversation. Speaker 4 said seasonal operations strain the fleet when vehicles are repurposed for snow removal; he described being “really shorthanded when we have the snow plow set up for the winter” and identified a need for a dedicated truck better suited for inspector duties and snow operations. Speaker 4 added that the department has set aside funding for certain equipment in the coming budget.

Personnel changes factored into planning: Speaker 4 announced that Chris Keith, described as a long‑time operator, is expected to retire in September after about 30 years and staff will train additional operators on specialized equipment before his departure.

Procedural votes taken at the meeting were limited to adoption of the agenda and approval of prior meeting minutes (see votes at a glance below). No formal decision to hire an outside consultant or to change rates was taken; board members agreed to reconvene on ERU scope and to update the advisory board before the next meeting.

Votes at a glance: Agenda adoption — motion moved by Speaker 3, seconded by Speaker 2; approved. Approval of Dec. 11, 2023 minutes — motion made and seconded; voice vote in favor. Adjournment — motion made and meeting closed.

Next steps: Staff will meet with representatives (including Speaker 2 and Speaker 4) to refine the ERU review scope, report back on monitoring coordination with TDEC, and continue internal work on revenue and rate‑setting before the board makes any decision on hiring external vendors.

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