Council Fee Committee
Regular MeetingLawton, OK · April 23, 2025
Agenda
City of Lawton Lawton City Hall
212 SW 9th Street
Lawton, Oklahoma
City Council 73501-3944
Fee Committee Agenda
Wednesday, April 23, 2025 2:30 PM Lawton City Hall
3rd Floor Conference Room
Recommending Body
"Official action can only be taken on items listed on the agenda. As a recommending body, the
Committee may review and discuss agenda items, propose and enact floor amendments, and
then choose to make a recommendation to the City Council or provide direction to the City
Manager. The Committee may also defer items for further review, refer matters to the City
Attorney, or send items to standing committees, boards, commissions, or authorities for
additional study. In some cases, items may be postponed to a later date or removed from the
agenda entirely."
Meeting Called to Order
Statement of Compliance with Oklahoma Open Meeting Act, 25 O.S. 301-314
Roll Call
Introduction of Guests
Business Items
1. Receive a presentation and report on the Stormwater and Drainage Rate
Study, performed by Freeze and Nichols in 2024/2025, and consider
recommendation to City Council on the merger of the two fees in conjunction
with the merger of the two divisions being considered by the Budget and
Efficiency Committee for the FY2026 fiscal year budget.
2. Consider the recommendations of the Stormwater Utility rate Study regarding
fee rates and fee structure to determine fee calculations, and take action as
appropriate.
Adjournment
The City of Lawton encourages participation from all of its citizens. If participation at any
public meeting is not possible due to a disability, notification to the City Clerk at (580) 581-
3305 at least 48 hours prior to the scheduled meeting is encouraged to make the necessary
accommodations. The City may waive the 48 hour rule if interpreters for the deaf (signing) is
not the necessary accommodation."
[MEET_FOOT]
Packet
City of Lawton Lawton City Hall
212 SW 9th Street
Lawton, Oklahoma
City Council 73501-3944
Fee Committee Agenda
Wednesday, April 23, 2025 2:30 PM Lawton City Hall
3rd Floor Conference Room
Recommending Body
"Official action can only be taken on items listed on the agenda. As a recommending body, the
Committee may review and discuss agenda items, propose and enact floor amendments, and
then choose to make a recommendation to the City Council or provide direction to the City
Manager. The Committee may also defer items for further review, refer matters to the City
Attorney, or send items to standing committees, boards, commissions, or authorities for
additional study. In some cases, items may be postponed to a later date or removed from the
agenda entirely."
Meeting Called to Order
Statement of Compliance with Oklahoma Open Meeting Act, 25 O.S. 301-314
Roll Call
Introduction of Guests
Business Items
1. Receive a presentation and report on the Stormwater and Drainage Rate
Study, performed by Freeze and Nichols in 2024/2025, and consider
recommendation to City Council on the merger of the two fees in conjunction
with the merger of the two divisions being considered by the Budget and
Efficiency Committee for the FY2026 fiscal year budget.
2. Consider the recommendations of the Stormwater Utility rate Study regarding
fee rates and fee structure to determine fee calculations, and take action as
appropriate.
Adjournment
The City of Lawton encourages participation from all of its citizens. If participation at any
public meeting is not possible due to a disability, notification to the City Clerk at (580) 581-
3305 at least 48 hours prior to the scheduled meeting is encouraged to make the necessary
accommodations. The City may waive the 48 hour rule if interpreters for the deaf (signing) is
not the necessary accommodation."
[MEET_FOOT]
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Item Title:
Receive a presentation and report on the Stormwater and Drainage Rate Study, performed by
Freeze and Nichols in 2024/2025, and consider recommendation to City Council on the merger
of the two fees in conjunction with the merger of the two divisions being considered by the
Budget and Efficiency Committee for the FY2026 fiscal year budget.
Initiator: Michael Watrous, Director
Information Source: Michael Watrous, Director
Background:
There are two items being considered by the Fee and Rate Committee regarding this study. This
item is to consider the merging of the two current fees (Drainage Maintenance and Stormwater
Management Fee) into one fee, which will allow for the merger of the Drainage Maintenance and
Stormwater Management Divisions into one division. Currently, both fees are collected and
placed in a separate fund for separate purposes.
Currently, both the Stormwater Management Division and the Drainage Maintenance Division
are funded solely from the fees generated (self-funded). They receive no general funds for their
operation. Without the fee merger, inefficiencies managing the two funds will persist. Drainage
Maintenance will also need to further cut funding in FY26, reducing services provided for
citizens as funding for the division last year was pulled from reserves.
Lawton is the only city, when compared to our peer cities, that collects both a drainage and
Stormwater fee. Allowing the merger of these fees better aligns us with our peer cities.
Attached iin the exhibits is the study final report and presentation, as well as the original
resolutions establishing the two fees.
Correlation to the True North Statement:
The Citizen – Everything that we do is for the citizen, EVERYTHING
• Combining the two fees into a single utility fee provides clarity and simplicity for
citizens. It reduces confusion about charges on their utility bill and creates a more
straightforward, transparent process that serves the citizen first and foremost.
Transparency and Trust
• The merger of these fees into one clearly labeled and equitably assessed Stormwater
Utility Fee enhances financial transparency. It eliminates ambiguity about what citizens
are paying for, and how those funds are being used to improve infrastructure and comply
with federal regulations
Efficiency
• Managing stormwater and drainage services under one fee structure allows for
streamlined budgeting, staffing, and maintenance planning. This consolidation reduces
administrative duplication and provides a more efficient path for funding necessary
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services and improvements
Our Pursuit of Excellence
• Lawton’s decision to consolidate and refine its fee system demonstrates a forward-
thinking, no-excuses approach to public service. The new model reflects best practices
from peer cities and positions Lawton as a leader in municipal utility management.
Exhibit:
1.) Lawton SWU Report 2.) Stormwater Rate Study 3.) Stormwater Management Fund
Resolution 4.) Drainage Maintenance Fund Resolution
Key Issues:
Without the merger of these fees, drainage maintenance will need to further cut their budget in
FY25/26 by approximately $300,000, reducing the level of service provided to the citizens, such
as drainage canal vegetation management, mosquito fogging, and drainage structure
maintenance.
Funding Source:
N/A
Staff Recommended Council Action:
Approve a council recommendation to merge the Stormwater Management Fee and Drainage
Maintenance Fee into one fee.
ATTACHMENTS:
1. Lawton_SWU_Report_03142025
2. Stormwater Rate Study
3. storm water management fund
4. drainage maint fund 95
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STORMWATER UTILITY FEE REPORT
Prepared for:
City of Lawton
March 2025
Prepared by:
FREESE AND NICHOLS, INC.
3600 NW 138th Street, Ste 202, Oklahoma City, OK 73134
(405) 607-7060
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TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................................... 1
1.1 Description of the City of Lawton ................................................................................................... 1
1.2 Legal Basis and Limitations of a Stormwater Utility ............................................................... 3
1.3 Stormwater Utility Policy ................................................................................................................... 3
2.0 COST OF STORMWATER AND DRAINAGE SERVICES ................................................................. 5
2.1 Cost of Service Development Considerations ............................................................................ 5
2.2 Cost of Service Assumptions ............................................................................................................. 6
2.3 Storm System Maintenance ............................................................................................................... 6
2.4 CIP Identification ................................................................................................................................... 7
2.5 Operating Reserve ................................................................................................................................ 8
3.0 REVENUE ASSESSMENT ......................................................................................................................... 9
3.1 Basis for Fee Calculation .................................................................................................................... 9
3.2 Billing Method ..................................................................................................................................... 10
3.3 Determination of Property Impact to Storm System ........................................................... 10
3.4 User Fee Categories ........................................................................................................................... 13
3.4.1 Single-Family Residential Properties .................................................................................13
3.4.2 Commercial Properties ............................................................................................................14
3.4.3 Property Exemptions................................................................................................................14
4.0 MENU OF SERVICES .............................................................................................................................. 15
5.0 ALTERNATIVES AND RECOMMENDATIONS............................................................................... 16
5.1 Stormwater Needs ............................................................................................................................. 16
5.2 Fee Structure AND RATE RECOMMENDATION...................................................................... 16
5.3 Rate recommendation ...................................................................................................................... 17
6.0 UTILITY IMPLEMENTATION ............................................................................................................. 19
6.1 Stormwater Utility Ordinance Adoption ................................................................................... 19
6.2 Appeals Process .................................................................................................................................. 19
6.3 SWU Fee Billing Implementation ................................................................................................. 20
6.4 Utility Account Management ......................................................................................................... 20
7.0 REFERENCES ........................................................................................................................................... 22
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Table of Figures
Figure 1-1: City Limits...................................................................................................................... 2
Figure 3-1: Example of Impervious Area for Single-Family Residential Property......................... 11
Figure 3-2: Example of Impervious Area for Commercial Property ............................................. 12
Figure 3-3: City-Wide Impervious Area, by Stormwater Utility Classification .............................. 13
Table of Tables
Table 2-1: Annual Cost Factors ....................................................................................................... 6
Table 2-2: Potential Staff ................................................................................................................ 7
Table 4-1: Stormwater and Drainage Service Needs and Associated Cost, FYE 25 ...................... 15
Table 5-1: Summary of Single-Family Residential Properties ....................................................... 17
Table 5-2: Scenario 1 Operating Expenses without CIP ................................................................ 17
Table 5-3: Scenario 2 Operating Expenses with CIP ..................................................................... 17
APPENDICES (TO BE POPULATED WITH FINAL REPORT)
Appendix A Drainage Projects from City FY23-27 CIP Book
Appendix B Public Notice
Appendix C Stormwater Utility Ordinance and Fee Schedule
Appendix D Rate Committee Presentation
Appendix E Council Presentations
Appendix F Concept Maintenance Methodology
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1.0 INTRODUCTION
The City of Lawton retained Freese and Nichols, Inc. (FNI) to evaluate the components of a stormwater
management and drainage maintenance fee. FNI evaluated a stormwater management and drainage
maintenance structure and rates based on requirements of applicable state laws and the City of Lawton
(the City’s) identified storm system needs. FNI developed a menu of stormwater and drainage services
from which the City could choose to meet its stormwater and drainage programs goals, including
compliance with new federal water quality protection requirements. Through discussions within the City,
it was determined that ultimately merging the utility departments of Stormwater Management and
Drainage Maintenance into one utility was a consideration to evaluate during the study. The cost elements
of both utilities will be referenced throughout the report, however only one combined fee (a Stormwater
Utility Fee) will be referenced, as that is the recommended fee.
1.1 DESCRIPTION OF THE CITY OF LAWTON
Lawton is the largest city in Comanche County, located approximately 86 miles southwest of downtown
Oklahoma City. The City has a total area of approximately 81 square miles. Interstate 44 (I-44) is the main
thoroughfare through the City, running from the north limits to the south limits of the City. US Highway
62 (US 62) is a major highway running from east to west Lawton. State Highway 7 (SH 7) runs east to west
on the southern side of the City.
The 2023 population for the City is 90,245 [1]. The City has three major stormwater related waterways
including, East Cache Creek, Wolf Creek, and Nemu Creek accompanied by 10,914 acres of surrounding
floodplains.
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Figure 1-1: City Limits
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1.2 LEGAL BASIS AND LIMITATIONS OF A STORMWATER UTILITY
The State of Oklahoma provides municipalities the opportunity to establish a stormwater utility, which is
a legal mechanism used to generate revenue to finance the City’s cost to provide and manage stormwater
services in the City.[2] “Oklahoma Statues Title 11. Cities and Towns” section 11-22-104 grants cities in
Oklahoma the “Right to engage in business – Public utilities and improvements… for public improvement
purposes”. To provide these services, municipalities are authorized to assess fees to the users of the
stormwater utility system.
The stormwater utility fee is a service fee and must be based on the projected cost of providing
stormwater service within the City’s jurisdiction.
1.3 STORMWATER UTILITY POLICY
This stormwater and drainage report provides an overview of an assessment of the feasibility for the City
of Lawton to finance its stormwater and drainage-related activities through revenues from a stormwater
utility fee. Under the present system, necessary stormwater or drainage-related activities are financed
through a respective fund of either Stormwater Management or Drainage Maintenance. In addition,
significant capital and management improvements to the overall stormwater and drainage systems are
needed to protect existing and expected development and to meet ongoing regulatory requirements.
The City is one of many municipalities subject to federal stormwater quality regulations that require the
City to further protect and enhance water quality in creeks and lakes through the development of a
stormwater quality management program. As an operator of a municipal separate stormwater system
(MS4) as defined by the U.S. Environmental Protection Agency, the City is required to develop a multi-
faceted program to protect stormwater quality before it enters creeks, rivers, and lakes. The program
includes a number of measures to protect stormwater quality, such as the following:
• Storm system maintenance
• Structural and non-structural water quality protection measures
• Storm system mapping and inspections
• Public education, outreach, and involvement
• City ordinances regulating construction activity, illicit discharges, and post-construction
runoff
• City staff training and operations improvements
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The purpose of this study is to identify a fair and equitable stormwater utility fee and fee structure to
finance some or all of these measures, as well as associated administration, service, equipment and other
stormwater-related costs. The study strives to identify an appropriate fee based on the projected cost of
providing stormwater services in the City. To further protect rate payers from inequitable charges, a
means to appeal the rates for any property is currently in place through a Stormwater Hotline listed on
the City’s website.
The following general goals and policies were considered for the City’s stormwater utility. These goals
provided an initial basis for the potential purposes and benefits of the utility for the City of Lawton.
A. Serve as the primary stable source of new stormwater and drainage-related funding.
B. Finance some or all of the following specific activities:
1. Stormwater Ordinances and Design Criteria modifications
2. Ongoing implementation and maintenance of a Stormwater Quality Management
Program to comply with Federal and State MS4 regulations and permit requirements
3. Engineering studies and design
4. Capital improvements to the stormwater and drainage system infrastructure
5. Proactive maintenance for existing infrastructure
6. Equipment for drainage maintenance
7. Staffing for maintenance, compliance, engineering, and/or administration activities
8. Implementation and maintenance of the City’s Phase II MS4 stormwater management
program to comply with U.S. Environmental Protection Agency (EPA) and Oklahoma
Department of Environmental Quality (ODEQ) regulations and permits, as applicable
C. Provide a mechanism to benefit the quality of life in Lawton by improving and integrating the
management of water resources with other aspects of the City such as park systems
D. Encourage development in the City that minimizes adverse stormwater impacts through
better site design and proper management of the City’s stormwater resources
E. Provide a fair and equitable method to assess fees for developed properties’ impacts to the
City’s stormwater system
F. Allow for the issuance of bonds to finance stormwater capital improvement projects
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2.0 COST OF STORMWATER AND DRAINAGE SERVICES
The stormwater utility fee is a common method to address a significant portion of the financial burden
for stormwater and drainage management. This section includes considerations and options for services
the City may finance with stormwater utility fee revenues. A variety of options for staffing, equipment,
and services to provide are made available for reference. The City may choose to select from the list
provided, or additional options if the options are stormwater-related. Default values for several
parameters are provided in this report with input from the City. This includes rates for labor, equipment
purchases and rental, city growth, and inflation.
2.1 COST OF SERVICE DEVELOPMENT CONSIDERATIONS
Options were evaluated to determine an appropriate methodology for identifying the projected cost of
providing stormwater and drainage service in the City. It was determined that the following considerations
would be incorporated into the assessment of the cost of stormwater and drainage services for the
purpose of determining the revenues necessary for the stormwater utility:
• Identify expected stormwater and drainage-related costs. This includes prorated costs for
administration, equipment, and other expenses not dedicated to stormwater or drainage
activities.
• Evaluate a five-year period for projecting cost of service needs. Cost projections beyond five
years are inherently less reliable and may not provide the City with the quality information
desired for planning purposes.
• The fund balances for both Stormwater Management and Drainage Maintenance combine to
currently have a 180-day operating balance which will be maintained over the observation
period.
• Consider prorated costs for items not solely associated with stormwater or drainage but that
have an application for stormwater management and drainage maintenance. Examples
include engineering staff, maintenance crews, and maintenance equipment.
• Plan for stormwater and drainage revenues to finance all direct operating costs and
administrative costs for stormwater and drainage-related activities, including major capital
projects.
• Address as much of the City’s stormwater and drainage-related costs as practicable through
the stormwater utility fee.
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2.2 COST OF SERVICE ASSUMPTIONS
For the purposes of the five-year plan, several assumptions were identified and incorporated into the
planning process. Specifically, anticipated annual cost increases were identified and developed into cost
factors for both stormwater management and drainage maintenance, as shown in Table 2-1.
Table 2-1: Annual Cost Factors
FYE26 FYE27 FYE28 FYE29 FYE30
Expense Rate Inflation 5% 5% 5% 5% 5%
Interest Rate for Debt Service 4% 4% 4% 4% 4%
City Projected Growth Rate 0% 0% 0% 0% 0%
The expense rate inflation and interest rate for debt service are assumed to remain constant over the five-
year projection period. City growth is conservatively projected at 0% for the five-year projection period.
2.3 STORM SYSTEM MAINTENANCE
The City plans to establish a program to conduct routine operations and maintenance (O&M) activities
throughout the stormwater and drainage system to minimize flooding potential, protect life and property,
reduce creek erosion, and protect stormwater quality. The City may consider budgeting through the
stormwater and drainage utility to fund all or a portion of a storm system and drainage maintenance crew
to conduct stormwater and drainage O&M activities throughout the City. A list of the common crew
positions that the City is considering, including compensation with benefits for FYE 2026, is provided in
Table 2-2. Rates for all positions currently assume 100 percent financing by the combined utility of
stormwater management and drainage maintenance. Positions not fully dedicated to stormwater or
drainage-related services can be funded on a pro-rated basis if stormwater or drainage utility funding is
limited to stormwater or drainage-related services.
The seasonal labor and equipment operators would assume responsibility for routine storm sewer system
maintenance activities such as stormwater ditch cleanouts, inlet cleanouts, and drainage swale
landscaping. The projected cost to purchase equipment for the seasonal labor and equipment operators
is provided in Table 2-3. The purchase price of the equipment is amortized over its expected service life
to provide an annualized cost. Annual O&M costs include projected fuel and routine maintenance costs.
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Table 2-2: Potential Staff
Position Compensation Total Compensation
Position # of Positions
with Benefits (FYE26) (FYE26)
Equipment Operator 4 $57,570 $230,278
Seasonal Labor 6 $57,299 $343,791
Environmental Specialist 1 $105,793 $105,793
Construction Inspector 1 $70,150 $70,150
Table 2-4: Cost to Purchase Equipment for Stormwater Management and Drainage Maintenance
Capital Service Annualized Annual
Value Life Purchase Cost O&M Total Annual Cost
Equipment (FYE25 $) (Years) (FYE25 $) (FYE25 $) (FYE25 $)
1/2 Ton Pickup (F-450) $88,518 5 $17,704 $3,100 $27,244
Landscape Trailer $8,000 10 $800 $0 $800
Walk Behind Mower (3) $4,500 5 $900 $100 $1,600
Backpack Leaf Blower $400 10 $40 $100 $140
Assorted Hand Tools $500 10 $50 $0 $50
Zero Turn Mower $6,000 10 $600 $300 $2,100
Safety Items $300 10 $30 $0 $30
Uniforms and Boots $9,000 5 $1,800 $0 $1,800
Large Tractor Mower $250,000 10 $25,000 $8,800 $39,800
Small Tractor Mower $200,000 10 $20,000 $7,000 $30,000
Weed eater (6) $3,600 5 $720 $100 $220
Hydro mulcher $5,000 10 $500 $200 $700
Vacuum Truck $275,000 10 $27,500 $9,700 $40,200
Truck $65,000 5 $13,000 $1,000 $15,200
2.4 CIP IDENTIFICATION
The City’s Proposed Five-Year Capital Improvement Program (FY26 – FY30) identifies a suite of
improvements to the City’s drainage maintenance system. Most Capital Improvement Program
improvements are from a list of projects in the 2003 Stormwater Master Plan. The project costs have been
updated to 2024 values by the City’s stormwater consultant. Financing assumptions are a 20-year loan at
a 4 percent interest rate.
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2.5 OPERATING RESERVE
The fund balances for both Stormwater Management and Drainage Maintenance combine to currently
have a 180-day operating balance. Currently the Stormwater Management Utility has a fund balance equal
to approximately $557,000. The Drainage Maintenance Utility has a fund balance equal to approximately
$930,000.
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3.0 REVENUE ASSESSMENT
3.1 BASIS FOR FEE CALCULATION
By practice, the stormwater utility fee rate is calculated according to a basis that estimates a property’s
use of the stormwater and drainage system. As a result, fee rates are not based solely on certain readily
accessible information, such as property values or water usage rates. The City’s stormwater utility rate
will be based on the amount of impervious area for each property. Impervious surfaces do not provide
stormwater significant opportunity for infiltration into the soil and result in increased stormwater runoff
to the municipal storm sewer system.
The impervious area approach to stormwater utility rates is the most common basis for estimating a
property’s impact on the municipal stormwater system. This method is considered a reasonably equitable
approach and is used by many surrounding municipalities.
The residential approaches for stormwater utility fees of benchmark comparison cities for Lawton are
summarized in the table below:
Table 3-1: Comparison of Stormwater Utility Fees
City Basis Rate
Midwest City Meter Size $2.42
Stillwater Flat Rate $2.46
Edmond Flat Rate $3.00
Enid Per ERU $5.55
Broken Arrow Per ERU $10.22
Tulsa Flat Rate $12.22
Property improvements that are considered as impervious areas include buildings, paved parking lots,
driveways, patios, walkways, and pools. Gravel parking lots and driveways are also considered impervious
area because of the low infiltration rate of stormwater through their surface. Sidewalks within the City
ROW were not included in individual property impervious area calculations.
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The potential stormwater and drainage impact of impervious area to the storm system include the
following:
• Increased total volume of water required to be managed by the municipal storm system
resulting in flooding
• Increased peak flows from storm events resulting in flooding
• Increased flow velocities result in increased erosive actions in creek channels and adjacent
properties
• Increased pollutant load resulting in degraded water quality
Site-specific design and maintenance approaches may minimize one or more of these impacts. As noted
in Section 7.2 (Appeals), the City may determine to reduce the stormwater utility fee for a property by an
equitable amount to account for the beneficial stormwater impact of design and/or maintenance
approaches by a property owner.
3.2 BILLING METHOD
Fees for stormwater utilities are collected in a variety of ways throughout the country, including as line-
items on water bills, as yearly payments with property taxes, or as stand-alone bills. The most common
method to assess stormwater and drainage utility charges is through the City utility bill, which is the
method Lawton currently uses and will continue.
As part of the City utility bill, the stormwater utility fee will appear on the utility bill as a single line item
with the monthly dollar amount for the property shown. A stormwater utility charge will be assessed on
a utility account for each eligible property.
If the property can be linked to an associated property with a City utility account, the fee for the improved
property is included in the affiliated property’s utility account. A common example is a restaurant with a
parking lot located on an adjacent lot. If no existing utility account can be associated with the improved
property, a new utility account is established by the City for the purpose of assessing the stormwater
utility fee. Eligible improved property without an associated utility account still would be assessed a
stormwater utility fee, usually as a stand-alone “stormwater-only” charge on a specially developed
account for the property owner.
3.3 DETERMINATION OF PROPERTY IMPACT TO STORM SYSTEM
By practice, undeveloped properties in their natural state are not charged a stormwater utility fee.
Developed properties with impervious area increase the rate and/or volume of stormwater runoff to the
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municipal storm system. Infrastructure improvements, ongoing maintenance, inspections, and
evaluations are necessary to effectively manage the increase in stormwater discharge from impervious
area.
Impervious area includes rooftops, paved parking lots, paved driveways, gravel driveways, walkways,
outbuildings, patios, and pools. It does not include vegetated areas. Properties with less than 400 sq ft of
impervious are considered undeveloped. To determine the impact of each developed property on the
storm system, FNI delineated the impervious area for each residential and commercial property. The
resulting impervious area measurements were used to develop the equivalent residential unit (ERU),
which forms the basis fee for all developed properties. One ERU was determined to be 3,200 square feet
impervious area based on the mean value residential properties.
The impervious area amount is associated with the specific parcel or group of parcels for the development.
The parcel is associated with the appropriate utility billing accounts to allow for assessment of the proper
stormwater utility fee if implemented.
Figure 3.1 is an example of the impervious area determination for a single-family residential property, and
Figure 3.2 is an example for a commercial property. Figure 3.3 shows the impervious area for all
properties, City-wide.
Figure 3-1: Example of Impervious Area for Single-Family Residential Property
Total Impervious Area:
3,200 ft2 (Residential Average)
1 ERU
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Figure 3-2: Example of Impervious Area for Commercial Property
Total Impervious Area:
15,000 ft2 (Measured)
5 ERUs
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Figure 3-3: City-Wide Impervious Area, by Stormwater Utility Classification
3.4 USER FEE CATEGORIES
The stormwater utility fee system consists of several types of user accounts depending on the type of
property and the category of property owner. The stormwater utility fee rate structure is based on the
type of user account. The three general account categories include:
• Single Family Residential (includes duplexes)
• Commercial (includes apartments)
• Exempt (currently considering City property)
3.4.1 Single-Family Residential Properties
Single-family residential properties consist of all developed single-family residential properties within the
City. Apartment complexes are considered to be commercial properties for fee determination purposes.
Impervious area includes the footprint of the residence, including roof overhangs, driveways, walkways,
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patios, sheds, carports, gravel surfaces, and other impervious surfaces. It does not include the sidewalk
within the City ROW (if present), public streets, or swimming pools.
At the time of this study, 27,698 eligible, non-exempt Single-Family Residential properties were present.
2,911 properties were assigned the Commercial stormwater utility classification. The Single-Family
Residential properties account for approximately 90 percent of the total number of parcels and 41 percent
of the total impervious area measured for the City in this report.
FNI and the City evaluated numerous different fee structures and decided on a flat residential structure,
with the average impervious area per ERU being based on the mean of all residential properties. Each
residential account would pay the same amount, equal to one ERU. The fee structure was determined
based on feedback from the City as described in Section 6.
3.4.2 Commercial Properties
Any property that is not Single-Family Residential is considered to be Commercial. This includes what is
normally considered as commercial as well as apartments and tax-exempt religious organizations. Other
developed properties in the City that do not qualify as Single-Family residential and do not meet any of
the exemption criteria are also considered Commercial.
Stormwater utility and drainage maintenance fees for eligible commercial are individually calculated
based on the total amount of impervious area for the affiliated properties. Each Commercial property is
assessed a stormwater utility and drainage maintenance fee at a rate according to the stormwater utility
rate unit charge, expressed in whole ERU increments.
3.4.3 Property Exemptions
Many cities consider, and often adopt, exemptions for categories of the community. The City is
considering exempting City properties; however, they would be considered Commercial if they were not
exempted. The financial modeling contained in this report assumes City properties are exempted from
the stormwater utility fee. It is recommended that the City review with the City attorney legal allowances
and constraints in establishing exemptions for the stormwater utility fee to verify actions taken are in
accordance with applicable laws.
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4.0 MENU OF SERVICES
This section presents staffing, maintenance, and capital improvement projects that the City might
consider including in its stormwater program. Each new service or project has an associated cost.
Table 4-1 shows the stormwater and drainage needs and associated costs if they were funded through
the stormwater utility fee. This menu of services was presented to the City during the biweekly update
meetings throughout the year 2024. Table 4-1 does not include rate rounding/leveling, operating reserve
contribution, or administration reimbursement.
Table 4-1: Stormwater and Drainage Service Needs and Associated Cost, FYE 25
Expense Monthly Cost
Description Annual Cost
Category ($/ERU)
Total Salary, Fringe Benefits, Overtime,
Staffing $1,967,852 $2.63
Ancillary Supplies, Training, etc.
Equipment
Mowers, Trucks, Tools, Equipment, etc. $97,618 $0.13
Expenses
Recurring Materials and Supplies, Equipment
$406,451 $0.54
Expenses Replacement Fund, etc.
Rehab and
Ongoing maintenance $417,452 $0.51
Maintenance
Table 4-2 shows the services being paid for by the stormwater utility fee.
Table 4-2: Cost of Service Summary
Cost FYE25 FYE26 FYE27 FYE28 FYE29
Current Expenses $2,889,373 $2,940,899 $3,087,943 $3,242,340 $3,404,457
Labor Proposed $0 $175,943 $184,740 $193,977 $203,676
Equipment Proposed $0 $172,328 $180,945 $189,992 $199,492
Recurring Proposed $0 $348,600 $366,030 $384,332 $403,548
Total $2,889,373 $3,637,770 $3,819,658 $4,010,641 $4,211,173
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5.0 ALTERNATIVES AND RECOMMENDATIONS
This section documents the alternatives analyzed by FNI and the City and the resulting recommendations.
5.1 STORMWATER NEEDS
FNI and the City evaluated the stormwater needs across Lawton. These included the need for compliance,
preventive maintenance, corrective maintenance, and capital improvement projects. The menu of
services and their associated costs are shown in Section 4.
FNI and the City also evaluated various storm water capital improvement projects (CIPs) in Lawton. These
projects were identified in the City’s 2003 Master Plan, complete with preliminary cost estimates and
solutions, updated to 2024 value. The City did not select any projects specifically to be included in this
Stormwater Utility Fee Development Report.
FNI and the City identified a complete list of stormwater and drainage services that are needed but not
conducted due to a lack of funding. These services include preventative maintenance and various CIP
projects.
5.2 FEE STRUCTURE AND RATE RECOMMENDATION
In addition to the stormwater needs, various fee structure alternatives were presented to City staff. The
recommended fee structure is to charge all Single-Family Residential properties a flat rate. All Commercial
properties would be charged per ERU. FNI analyzed several other fee structures with a wide range of
variables including 1) numbers of residential tiers, 2) level of service options, 3) exemption assumptions,
4) administration reimbursement amounts, and 5) reserve contribution amounts.
The City chose a flat residential rate system with all single-family residential properties charged the same
rate. The proposed rate structure is summarized in Table 5-1. With this rate structure all developed
residential properties would be charged the same rate, equal to one ERU. Undeveloped single-family
residential properties would not receive a stormwater utility fee.
All developed commercial properties would receive a stormwater utility fee based on their impervious
area. For every 3,200 sq ft of impervious area or one ERU, a commercial property would receive the fee
charge for each ERU applied to the property.
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Table 5-1: Summary of Single-Family Residential Properties
Count of Mean Impervious
Residential Tier ERUs
Properties Area, sq ft
Residential Flat 27,698 3,200 27,698
5.3 RATE RECOMMENDATION
Based on the stormwater and drainage needs, two scenarios were presented to City staff. The scenarios
presented to staff summarized a range of rate possibilities for the stormwater utility fee. Scenario 1 shows
services largely limited to covering operating expenses, while Scenario 2 shows services covering
operating expenses and funding a portion of the identified capital improvements. The corresponding
stormwater utility rates for each scenario are in line with comparison cities in the state. Note that because
no growth is projected in these financial scenarios, the annual revenue is projected to be flat for the
projection period.
Scenario 1 proposes a flat fee of $5.25 per month for residential properties and $5.25 per ERU per month
for commercial properties. This scenario allows the stormwater utility to remain net revenue positive
through FYE29, however minimal funding is available to complete maintenance and CIP needs. Table 5-2
shows the proposed rates and projected annual revenue for Scenario 1.
Scenario 2 proposes a flat fee of $11.00 per month for residential properties and $11.00 per ERU per
month for commercial properties. This scenario allows the stormwater utility to remain net revenue
positive through FYE29 and allows for the City to complete more maintenance projects and complete one-
third of the CIP projects identified in the 2003 Master Plan.
The City has the flexibility to consider rates that fall between the two identified scenarios above, with the
knowledge that operating expenses would be covered and somewhere between zero and one-third of CIP
projects could be funded.
Table 5-2: Scenario 1 Operating Expenses without CIP
Monthly Fee Annual
Category Parcels ERUs
($/ERU/month) Revenue
Residential 27,698 27,698 $5.25 $1,745,000
Commercial 2,911 40,229 $5.25 $2,534,000
Total 30,609 67,927 $4,279,000
*Note revenues are rounded to the nearest $1,000
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Table 5-3: Scenario 2 Operating Expenses with CIP
Monthly Fee Annual
Category Parcels ERUs
($/ERU/month) Revenue
Residential 27,698 27,698 $11.00 $3,656,000
Commercial 2,911 40,229 $11.00 $5,310,000
Total 30,609 67,927 $8,966,000
*Note revenues are rounded to the nearest $1,000
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6.0 UTILITY IMPLEMENTATION
6.1 STORMWATER UTILITY ORDINANCE ADOPTION
The stormwater utility fee rates are adopted by ordinance through a majority vote of the City Council. The
implementation ordinance declares the stormwater utility adoption and declares the stormwater system
of the City to be a public utility. The fee resolution sets the schedule of stormwater utility charges.
6.2 APPEALS PROCESS
By practice customers subject to stormwater utility fees should have the opportunity to appeal the
stormwater utility rates set for their properties. Valid reasons for protest include the following:
A. Undeveloped property is assessed a stormwater utility fee.
B. Property runoff is contained and does not contribute to the City’s stormwater system.
C. Property is improperly classified (i.e., Commercial instead of Residential), resulting in the
incorrect rate being applied.
D. Fee is charged on multiple utility accounts for the same physical property.
E. Fee is based on an incorrect impervious area determination for the property.
F. Fee is based on impervious area for property unrelated to the utility account under appeal.
A recommended appeals process is as follows:
A. Protests must be made in writing by the account holder and submitted to the stormwater
utility administrative staff (Utility Billing) for review. The specific reason for the appeal must
be provided, along with necessary information such as the account numbers under protest.
B. Stormwater utility administrative staff will conduct a review of the protest and is authorized
to correct utility fee rates for any of the above reasons, except for claims of incorrect
impervious area determinations. Claims of incorrect impervious area determinations will be
assessed by the City Engineer.
C. An initial determination will be provided by the City to the protesting party within 30 days of
the protest submission.
D. Appeals denied by the stormwater utility administrative staff may be appealed to the City
Engineer. The City Engineer will conduct a review of the appeal and provide a determination
in writing to the protesting party within 30 days of the appeal. Appeal determinations made
by the City Engineer may be appealed to the City Manager.
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E. Any adjustment to a stormwater system user’s fee must be made on a basis that remains
nondiscriminatory, equitable, and reasonable for all utility fee payers. Approved fee
adjustments will apply for future bills and will include credit for bills up to six months prior to
the appeal. No credit will be applied to bills prior to six months before the appeal was
submitted, and no credit will be applied to bills to prior owners of the property.
6.3 SWU FEE BILLING IMPLEMENTATION
Prior to implementation of the stormwater utility fee, the impervious area associated with each property
must be linked with the correct utility billing account. This is accomplished by matching address
information from the City’s utility billing database to address information contained within the
appropriate GIS parcel data.
6.4 UTILITY ACCOUNT MANAGEMENT
Each developed, non-exempted property must be assessed a stormwater utility fee and will require a
utility account. FNI recommends the utility fee be assessed on a single account per property to minimize
the City’s administrative burden.
Duplicate utility billing accounts for a property are not typically assessed a stormwater utility fee unless
the total stormwater utility fee is apportioned across multiple accounts. For administrative reasons,
associating the stormwater utility fee to a single account per property is recommended.
Strip shopping centers and apartment complexes typically have numerous accounts. A common utility
account scenario for these types of properties is to have one account for each business or apartment
building, respectively, as well as a management account and/or an irrigation account. FNI recommends
assigning the stormwater and drainage utility fee to the management or irrigation account to allow the
property management to determine the appropriate approach to assess the stormwater and drainage
utility fee to individual tenants.
It is recommended that impervious surface calculations for commercial properties be updated as work
permits are completed to ensure that data is kept current. This data maintenance responsibility would be
the requirement of the stormwater division to assess and provide as permits are applied for or completed.
Further information regarding how to maintain and ensure the accuracy of this data can be found in the
Appendices.
Some properties have no active utility account. Examples of such properties include those on well water,
those within City limits but provided service by other providers, and properties such as parking lots that
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have no need for a water account. For these developed properties, a new utility account will typically
need to be created specifically to assess the stormwater and drainage utility fee. Properties are not eligible
to be exempted from the stormwater and drainage utility fee for the reason of having no water, sewer,
or waste disposal service with the City.
Accounts in an exempt category are not assessed a stormwater utility fee. A variety of circumstances can
lead to a utility account and/or a property being exempt. A property meeting any of the mandatory
exemptions or the City’s selected optional exemptions are considered exempt. The associated utility
accounts for these properties are categorized in the exempt classification.
The City may determine that it is more efficient to assess stormwater fee for some developed properties
as a group. For example, a property that extends across multiple parcels may be assessed a single utility
fee but clarifying notes in the utility billing database are recommended to identify the parcels that are
aggregated to assess the single fee.
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7.0 REFERENCES
[1] US Census Bureau, "QuickFacts Lawton city, Oklahoma," [Online]. Available:
https://www.census.gov/quickfacts/lawtoncityoklahoma. [Accessed 20 August 2024].
[2] https://oksenate.gov/sites/default/files/2019-12/os11.pdf
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Appendix A: Drainage Projects from City FY23-27 CIP Book
Appendix B: Public Notice
Appendix C: Stormwater Utility Ordinance and Fee Schedule
Appendix D: Rate Committee Presentation
Appendix E: Council Presentations
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Appendix F: Concept Maintenance Methodology
Administrative Review Response Form Letter
[Your Name]
[Date]
[Recipient Name]
[Title]
[Company Name]
[Street Address]
[City, ST ZIP Code]
Dear [Recipient Name]:
Thank you for your request to review your Stormwater Utility Fee charge. We have
completed our review of your account and have determined your request to be:
☐ Approved
☐ Approved with Modifications
☐ Additional Information is Needed
☐ Denied
If your request was approved or modified, your updated charge will be based on the
following information:
Customer Account:
Property Address:
Property ID:
Property Type: Residential Commercial Exempt
Impervious Area sq.ft. [COM only]:
Equivalent Residential Units (ERUs) (Impervious area sq. ft. / 3,200) [COM
ONLY]:
Stormwater Utility Fee ($/month):
If your classification has been adjusted downward (to a lesser charge) you will receive a
credit on the next bill for the billing cycle which has been reviewed. Your charge going
forward will be based on the details listed above.
If your request was noted as additional information needed, please submit the requested
information to us so we may complete our review.
If your request was denied, we have listed the information we have verified as accurate for
your property.
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You have the right to appeal this decision to the Lawton Public Works Director. An appeal
application form is available on our website at:
Lawton, OK | Home
IMPORTANT DEADLINE: If you choose to appeal this decision to the Public Works Director,
you have 14 days from receipt of notice of that decision to file an appeal.
Please note that during the time your account is under review, stormwater charges will
continue to accrue. Any account that is unpaid and not classified as under review will accrue
late charges and be subject to disconnection under existing Lawton procedures.
If you have any questions, please contact me and we can discuss further.
Sincerely,
[Your Name]
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Appeals and Change Form
Owner/Applicant: Call if assistance
needed to fill out form.
Name: _____________________________________________ Daytime Phone:
__________________________
Mailing Address: ______________________________________ City: _________________ Zip:
______________
Email address: _______________________________________
Service Location Information:
Property Address: ______________________________________ Utility Billing Account ID:
Reason for Appeal: (Check all that apply and attach documents and descriptions as indicated)
Impervious Area Calculation
Owner shall provide a copy of a current survey or site plan specifying area in square feet of all impervious
surfaces on the parcel. All measurements are subject to verification by Storm Water Engineering staff.
Current Impervious Area if available (sqft) ________________________________________________
Proposed Corrected Impervious Area if available (sqft) ______________________________________
Current Property Classification Proposed Property Classification
Residential: Residential:
Commercial: Commercial:
Exempt: Exempt:
Incorrect Utility Billing Account Charged:
Current:
_______________________________________________________________________________________
Proposed: _____________________________________________________________________________________
Comments:_________________________________________________________________________________________________________
_
Additional Information:
If desired, provide additional details that will assist the Stormwater Utility Administrator in processing this appeal.
Email this form with any supporting documents to the Public Works Director, michael.watrous@lawtonok.gov.
_________________________________________________________________________________________
__
_________________________________________________________________________________________
__
City of Lawton USE ONLY
Date Received: Reviewed by:
☐ Approved ☐ Approved with Modifications ☐ Additional Info Needed ☐ Denied ☐ Credit to Apply
Notes:
Adjustments
SWU Category (circle one): RES COM EXEMPT Utility Billing Account ID:
Impervious Area (sf): SW Parcel ID:
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Public Works Director Utility Billing Administrator
(1) Date to Utility Billing:
(2) Date Notification sent to applicant: _______________ (3) Date Adjustment Applied:
Signature: Signature:
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STORMWATER UTILITY FAQS
1. WHAT IS A STORMWATER UTILITY FEE?
The stormwater utility fee is a user fee, like water, sewer, and garbage fees, that funds
operations, maintenance and improvements to the town’s drainage system.
The stormwater utility fee is an equitable method to assess a drainage charge based on
developed properties’ impact to the city’s storm system.
2. Why does Lawton have a stormwater utility fee?
The city maintains a drainage system that provides public health and safety through
protection from flooding, minimization of surface water stagnation, and prevention of
stormwater pollution.
Revenues from the stormwater utility fee are used solely for drainage-related purposes within
the town.
3. WHO RECEIVES A STORMWATER UTILITY FEE?
Only developed properties receive a stormwater utility fee.
Apartment complexes and commercial properties are charged at a Commercial rate based on
the total impervious area.
NOTE: Impervious area means a surface which has become compacted or covered with a
layer of material so that it is highly resistant to infiltration by water and includes, but is not
limited to, caliche and gravel surfaces subject to motorized vehicular traffic, walkways,
buildings, parking lots, pavement, and ingress/egress driveways.
Impervious Area does not include sidewalks located in the public right-of-way. For purposes
of this definition, a walkway is a pedestrian path in the interior of an Improved Lot or Parcel
that is not located in the public right-of-way.
4. HOW IS THE STORMWATER UTILITY FEE DETERMINED FOR EACH
PROPERTY?
Customers are charged based on their contribution to the stormwater system, determined by
the amount of impervious area for residential and commercial properties.
All residential accounts will receive the same fee. Based on 1 Equivalent Residential Unit (ERU,
or 3,200 sq ft of impervious area).
Impervious Area (sf*) Monthly Fee
N/A To Be Determine
*sf = square feet
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Non-Residential charges are based on a per-ERU basis.
Impervious area (sf) Monthly fee
Per ERU To Be Determined
/ERU/Month
5. HOW CAN A CUSTOMER LEARN MORE ABOUT THEIR STORMWATER UTILITY
FEE?
Any customer wishing to see impervious area or wanting more information about their
stormwater utility fee can refer to the Lawton Stormwater Management Website or contact
the Public Works Director.
Information is also available online. Upon request, the City will provide a property sheet by
e-mail that details the basis for the stormwater utility fee for that property.
Website: Lawton, OK | Home
Contact information: Michael Watrous - Public Works Director
michael.watrous@lawtonok.gov
6. WHAT IS THE APPEALS PROCESS FOR STORMWATER UTILITY FEES?
Customers wishing to appeal their fee may first contact the Public Works Director, who can
review their fee.
Customers who do not notify the City and who do not submit payment for fees will be subject
to late fees and disconnection procedures.
Appeals of the Assistant Public Works Director’s decision may be made to the Public Works
Director.
NOTE: The call center will not have the information required to modify a customer’s charge,
give stormwater utility fee refunds, or check the status of pending appeals.
7. WHEN WILL THE STORMWATER UTILITY FEE BE ADDED TO AN ACCOUNT
FOR A NEWLY DEVELOPED PROPERTY?
For property under development, the stormwater utility fee will be added to the utility bill
upon issuance of a Certificate of Occupancy or Residential Final Inspection (or equivalent
documentation) for the property.
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City of Lawton
Stormwater Management
Administrative Policies and Procedures
Effective Date:
Subject: Stormwater Utility Fee
Administrative Review, Adjustment, and Appeals Policy
Applies to: City of Lawton Public Works Director, GIS Department, Deputy Public
Works Director
Policy: Provide procedures for the City to comply with its Code of Ordinances, and
to establish both an internal administrative review process and a Public
Works Director appeal, which authorize corrections and adjustment of
water, wastewater, and stormwater utility bills.
Authority: City of Lawton Ordinances, Ord. No. 2005-92
Roles and
Responsibility: Public Works Director
- Has overall responsibility for implementation of the Stormwater
Utility Fee in accordance with the City of Lawton Code of Ordinances.
- Hears, reviews, and makes determinations regarding customer
appeals from the administrative review process as described in City of
Lawton Code of Ordinances, Ord. No. 2005-92.
- Exercises authority to make the final determination on an adjustment
to fee.
Assistant Public Works Director
- Reviews and makes determinations regarding overall policy and
adjustments made to accounts.
- Reviews and makes determinations on whether an adjustment to the
stormwater fee is justified during the administrative review process.
- Provides documentation regarding a customer’s account to the Public
Works Director if the customer desires to appeal the administrative
decisions.
- Notifies Lawton Utility Billing when a customer account is placed in
the Appeals Process.
- Notifies customer of date and time of the Public Works Director
Appeals Hearing.
- Supervises record keeping for the determination, appeals, final
decisions, adjustments made, and reasons for the adjustments.
- Retains records according to the City’s Records Retention Schedule.
- Serves as primary contact for customer questions regarding the
stormwater utility fee.
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City GIS Staff/Stormwater Staff
- Create one page information sheet for property, when requested,
that shows that property’s impervious area determination.
- At the request of the Assistant Public Works Director, reviews GIS
data for property under appeal, to determine if the property in
question is being charged appropriately, undercharged, or
overcharged.
- Reports results of verification back to Assistant Public Works Director
for use in appeals process.
- Make adjustments to GIS database when appeals are successfully
granted or when errors are discovered.
City of Lawton Customer Service Manager
- Maintains the correct billing rate and fees for each customer in
accordance with the rates and fees adopted by City ordinance.
- Bills each customer for services rendered on the utility bill.
- Maintains customer accounts that document charges and fees,
payments and account balances.
- Make corrections, as necessary, to record actual payments made by
the customer and to record the proper billing of charges and fees for
services rendered.
Procedures:
Parcel Classification
City GIS/Stormwater staff maintain the parcel classification information
within the Stormwater Utility (SWU) database. If a parcel classification
error is discovered, City staff takes steps to confirm whether the
classification is an error or not.
• If the classification is incorrect, the correct classification is assigned
in
the SWU database.
• If the classification is not an error, the City communicates the
correct classification to the landowner.
Impervious Area
City GIS/Stormwater staff maintain the calculated impervious area
information within the Stormwater Utility (SWU) database. If an
impervious area value is disputed, City staff takes steps to confirm whether
the impervious area is an error or not.
• If the impervious area is incorrect, the correct impervious area is
updated in the GIS SWU database.
• If the impervious area is not an error, the City communicates the
correct impervious area to the utility account holder.
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Internal Administrative Review Process
The administrative review process is conducted by the Assistant Public Works
Director with assistance from City GIS or Stormwater staff and Lawton Billing. The
scope of the administrative review process includes reviewing and considering
requests regarding:
• Charge to a property that should not receive a charge;
• Incorrect charge applied to a property
During the internal administrative review process, the following items will be reviewed to
provide consistency to customers.
1. Review account information
a. Proper account selected per prioritization policy
i. Owner account
ii. Single tenant account
iii. Adjacent affiliated parcel owner account
iv. Adjacent affiliated parcel tenant account
v. Stormwater-only account
2. Review GIS info
a. Verify SWU Category for parcel
i. EXEMPT
1. Undeveloped (impervious area less than 400 square feet total)
2. City, state, and federal roads, bridges, highways, streets, and
rights-of-way
3. City parks, city buildings, city facilities and open spaces owned
or operated by the city
4. Property under development (prior to issuance of CO or
equivalent)
ii. RES
1. Single family
2. Duplex
3. Triplex
iii. COM
1. Multi-family (4 units or more)
2. Retail
3. Commercial
4. Industrial
5. All other properties not meeting definition of RES or EXEMPT
b. Verify impervious area for parcel
i. RES = impervious area greater than 400 square feet
ii. COM = total impervious area
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3. Review Billing
a. RES
i. Flat rate for residential
ii. For duplexes, triplexes, divide one (1) ERU (Equivalent Standard Unit)
by the number of accounts to receive a bill, then assign the calculated
ERU to each account
b. COM
i. For Commercial, divide the Impervious Area by one (1) ERU to
calculate the ERU for the account (round up to nearest whole
number). Multiply the rounded up ERUs calculated by the residential
rate to determine monthly rate.
c. EXEMPT
i. Verify no charge is being applied
4. Notify GIS
a. Update SWU classification
b. Update impervious area
c. Update billed account (obtain correct account in coordination with Utility
Billing)
5. Notify Utility Billing
a. Update billed account (obtain correct account in coordination with Utility
Billing)
b. Update SWU Category
6. Obtain from Utility Billing
a. Fee refund amount
b. Fee refund period
c. Fee refund account(s)
d. Fee refund recipient(s)
7. Notify customer
a. Complete form letter with findings and details
8. Billing
a. Verify fee refund applied
Appeals Process – Public Works Director
After the completion of the internal administrative review process, the Customer
may appeal the administrative determination to the Public Works Director. The
appeal must be filed within 14 days of the notification of the decision being
appealed. Once requested, an appeal must be held within 21 days of the request.
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The Customer may request a hearing as part of the appeal, or a “paper-based”
appeal session may be held. The scope of the Public Works Directors authority
includes reviewing and considering requests regarding:
• Charge to a property that should not receive a charge;
• Incorrect charge applied to a property
The following requirements will be considered and applied in determining the
appeal:
1. The Public Works Director must render a decision on the appeal
within 48 hours of the hearing or “paper-based” appeal session.
2. Applicable City records will be compared to information provided by
the Customer.
3. Issues appealable include:
a. Charge on a property that is thought to be undeveloped or
ineligible for SWU charges, consistent with City ordinance.
b. Determination of billable impervious area as applicable.
Utility Account Adjustments (non-billing rate changes)
The City of Lawton City will have the authority to make corrections to
customer account information and billing information, as necessary, to
ensure that the information is correct and accurate. A record will be made
to document all adjustments or changes to an account to correct errors.
The City of Lawton will ensure that the ability to pull reports from the
system is in place at all times. The City’s Customer Service office will pull
monthly reports of adjustments made to stormwater accounts.
A copy of all records on adjustments will be maintained and available for
internal audit purposes.
The Assistant City Works Director will have the authority to make
administrative determinations to direct City Utility Billing to adjust a
stormwater utility bill after review of available information. City Utility
Billing will make and keep a record of all adjustments made. Records of
any adjustments made will be kept in accordance to the City’s Records
Retention Schedule.
A copy of all records on adjustments will be maintained and available for
internal audit purposes.
Required Documents:
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The Utility Billing supervisor will sign off on all adjustments or corrections. Utility
Billing will maintain records and documentation for all corrections, adjustments
and changes made to customer billing information. Such reports may be system
generated or generated by hand, as necessary.
The Deputy Public Works Director will maintain a record of all administrative
reviews and determinations made. The record may be system generated or
generated by hand. The City Engineer will sign off on all determinations made.
The Deputy Public Works Director will direct the creation of minutes of any
appeals hearings and decisions made. The minutes will be approved by the Public
Works Director and kept in accordance with the City’s Records Retention
Schedule.
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City of Lawton
Stormwater Management
Administrative Policies and Procedures
Effective Date:
Subject: Stormwater Utility Fee Customer Inquiries
Applies to: City of Lawton Public Works Director, GIS Department, Deputy Public
Works Director
Policy: Provide procedures for the City to comply with its Code of Ordinances, and
to establish the response to Customer Inquiries by various departments.
Authority: City of Midwest City Ordinances, Ord. No. 2005-92
Roles and Responsibility:
Public Works Director
- Has overall responsibility for implementation of the Stormwater
Utility Fee in accordance with the City of Lawton ordinance.
Deputy Public Works Director
- Reviews and coordinates updates to the Customer Service Discussion
Points and FAQ’s document used to implement this procedure.
- Ensures that the Customer Service Department is supplied with the
latest version of the Customer Service Discussion Points and FAQ’s
document.
- Serves as primary contact for customer questions regarding the
stormwater utility fee that are not listed in the Customer Service
Discussion Points and FAQ’s document.
City Customer Service Management
- Reviews and checks for appropriateness the Customer Service
Discussion Points and FAQ’s document used to implement this
procedure.
- Ensures that the Customer Service Department has the latest version
of the Customer Service Discussion Points and FAQ’s document.
- Ensures that Customer Service Representatives have been trained on
this procedure and on the Customer Service Discussion Points and
FAQ’s document.
- Ensure that Customer Service Representatives have the opportunity
to ask questions and receive answers to strengthen their
understanding of the Stormwater Utility Fee.
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City Customer Service Representatives, Receptionist, Public Information
Office
- Review the Customer Service Discussion Points and FAQ’s document
used to implement this procedure.
- Receive training on this procedure and on the Customer Service
Discussion Points and FAQ’s document.
- Ask questions and receive answers to strengthen their understanding
of the Stormwater Utility Fee.
- Answer inquiries as stated below in the Procedure.
- Document interactions as directed.
Procedure:
1. When a call is received concerning the Stormwater Utility Fee, listen carefully to
the Customer’s question.
2. Look for the question/answer on the Customer Service Discussion Points and
FAQ’s
3. If the answer exists, provide that information to the Customer.
4. If the answer to a Stormwater Utility Fee question is not on the Customer Service
Discussion Points or FAQ’s, then forward the caller to the Public Works Director
at: michael.watrous@lawtonok.gov
5. Document the interaction with the Customer on the provided Stormwater Utility
Fee Inquiry tally sheet.
Documentation:
A tracking document will be used to document the questions received. Record time/date
and nature of the question, and whether call forwarded to the Assistant Public Works
Director or not.
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Stormwater Utility Fee Report
City of Lawton
City of Lawton
Stormwater Management
Administrative Policies and Procedures
Effective Date:
Subject: Stormwater Utility Fee Development and Re-development
Applies to: City of Lawton Public Works Director, GIS Department, Deputy Public
Works Director
Policy: Provide procedures for the City to comply with its Code of Ordinances, and
to establish the audit process for the Stormwater Utility Fee accounts.
Authority: City of Lawton Ordinances, Ord. No. 2005-92
Roles and Responsibility:
Public Works Director
- Has overall responsibility for implementation of the Stormwater
Utility Fee in accordance with the City of Lawton Code of Ordinances.
Deputy Public Works Director
- Ensures new or modified SWU accounts are added in a timely
manner.
- Serves as primary contact for internal questions or concerns
regarding the Stormwater Utility Fee program.
City Community Development Department
- Receive applications for development/re-development
- Review applications
- Resolve differences between new GIS data and site plan submittal
- Once application approved, notify GIS and Utility Billing via the
tracking system
City Utility Billing
- Create billing accounts as needed for new developments or re-
developments.
- Ensure SWU fee bills are timely sent once Certificate of Occupancy,
Temporary Certificate of Occupancy, or Final Inspection as applicable
is completed.
- Use the Change Process (contained in the Administrative Review
workflow) to make corrections to existing accounts.
GIS Department
- Create new GIS account information for development/re-
development, including:
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Stormwater Utility Fee Report
City of Lawton
o Parcel address
o Parcel boundary
o Impervious area (sq. ft.)
o SW Parcel ID
- Review the documentation and ensure complete and accurate.
Procedure:
6. When an application for development/re-development has been submitted,
Community Development Department will perform the initial review and enter
into the development tracking system. The tracking system will notify Billing and
GIS that a new application has been entered.
7. When notice that an application for development/re-development has been
submitted, GIS Department will complete the following steps:
o Network folder to verify and update (City Parcel and Impervious Area
layers):
▪ Parcel address
▪ Parcel boundary
▪ Impervious Area (sq. ft.)
o Assign:
▪ SW Parcel_ID
▪ Utility Billing Account ID
▪ SWU Classification
o New GIS Parcel and IA information sent to database
▪ Parcel address
▪ SW Parcel_ID
▪ Utility Billing Account ID
▪ SWU Classification
8. Community Development Department will review new GIS information against
site plan submittal and resolve differences with applicant.
9. Once differences resolved, and application approved, Community Development
Department will send information to GIS and to Billing.
10. GIS will update City Parcel layer:
o MCAD Parcel Address
o MCAD Number
o SW Parcel_ID
o SWU Classification
11. Billing will add utility billing record for the development.
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Stormwater Utility Fee Report
City of Lawton
12. Billing will create notification of utility billing updates with Location ID into the
tracking system.
13. GIS will update City Parcel and SWU Area layer:
o MCAD Parcel Address
o MCAD Number
o SW Parcel_ID
o SWU Classification
o Utility Billing Account ID
14. GIS will push out updated City Parcel and SWU Area layers to GIS web mapping
applications for internal and external clients.
15. When a Certificate of Occupancy (or equivalent) is issued for a parcel,
Community Development Department will notify Billing through the
development tracking system, so that Billing may begin billing the account
associated with the parcel.
Documentation:
Applications for development/re-development are entered into the development
tracking system.
Documentation in the billing system will add the Stormwater Fee to existing bills or
establish a “Stormwater Only” account for the new development/re-development.
The GIS system will contain parcel data such as Location ID, Impervious Area, etc.
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Stormwater Utility Fee
Evaluation Study Update
March 18, 2025
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Stormwater/Drainage
Management Overview
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Stormwater/Drainage Management and Maintenance
Stormwater runoff enters
streams, rivers, and
collection systems without
treatment.
Impervious surfaces increase
stormwater runoff to be
managed.
Stormwater systems consist
of constructed infrastructure
(e.g., storm pipes) and
natural features (e.g., creeks)
3
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Stormwater/Drainage
Program Goals Reduce Flood
Risk
Protect
Maintain
People &
Infrastructure
Property
Stormwater/
Drainage
Program Goals
Erosion
Water Quality
Control
Capital
Improvements
4
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Lawton’s Current Stormwater/Drainage Structure
• Monthly Charge/Account: $1.25 • Monthly Charge/Account: $2.30
• Annual Revenue: $903,002 • Annual Revenue: $1,086,452
Per Annual Budget (FYE25) Per Annual Budget (FYE24)
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Stormwater Needs
December 13, 2024
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Stormwater Drainage Issues
Flooding Water
Quality
Maintenance
Erosion
7
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Stormwater/Drainage Infrastructure
8
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Stormwater/Drainage Infrastructure
9
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Stormwater/Drainage Infrastructure
10
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Construction
11
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Identified CIP Projects to Complete
Projected Cost Projected Cost
Rank Project Name Rank Project Name
(2024 $) (2024 $)
East Branch Numu Creek from Ferris to SW
1 $34,146,728 Unranked Wolf Creek north of Gore N/A
F Ave
Unranked Numu Creek from I-44 north to Lee Blvd. $8,466,355 9 Garden Village Subdivision $11,643,061
2 Numu creek from Sheridan Rd to Cache Rd $48,700,815 10 Channel on Dearborn and NE Euclid $2,453,638
3 Numu Creek Channel from 9th St to 11th St. $4,328,260 11 Greer Addition 200’ North of Gore Blvd $2,392,376
SW Jefferson from SW 24th St to Sheridan
4 $9,203,430 Unranked S 11th St. Bridge on Wolf Creek south of I-44 $2,822,646
Rd.
Unranked Santa Fe Bridge on NW 41st St $4,234,844 Unranked SW Lee Blvd. on SW 52nd St. $146,906
5 Ferris Ave to Gore Blvd $9,972,014 12 Lincoln Ave to Cherry Ave $18,322,050
Tributary A from NE Flower Mound Rd to
6 $3,550,743 13 NW 81st St. and NW Taylor Ave. $463,847
East Cache Creek
7 Prentice & Floyd $17,468,770 14 NE Bell Ave to SE Randolph on NE 51st St $679,726
Numu Creek and Tributary from Railroad St.
8 Wolf Creek north of Gore $4,170,039 15 $10,195,221
west to US 281
Total Cost = $193,361,000
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Lawton’s Current Stormwater/Drainage Structure
• Monthly Charge/account: $1.25 • Monthly charge/account: $2.30
• Annual Revenue: $903,002 • Annual Revenue: $1,086,452
Per Annual Budget (FYE25) Per Annual Budget (FYE24)
Current rate structures have combined revenue shortfall of $890,818 in FYE25
for both Stormwater Management and Drainage Maintenance
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Proposed Updates
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Combine Programs and Fees
Drainage Stormwater
Maintenance Management
Stormwater Utility Program and Fee
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Stormwater Utility Refinements
Meter-Based Impervious Area-Based
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Impervious Area Less Impervious More Impervious
Surface Surface
Impervious surfaces limit stormwater = =
the opportunity for infiltration into Less Runoff More Runoff
the soil and result in increased
stormwater runoff.
Examples
• Rooftops
• Parking lots
• Driveways
• Patios
• Walkways
Equivalent Residential Unit = ERU
3,200 square feet impervious area
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Residential and Commercial ERUs
Typical Residential Typical Small Commercial Typical Large Commercial
3,200 sq ft impervious area 28,213 sq ft impervious area 178,508 sq ft impervious area
28,213/3,200= 8.8 178,508/3,200= 55.7
1 ERU 9 ERU 56 ERU 18
.
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Proposed Rates
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Scenario 1 – Limited Cash-Funded CIP
Residential Rate: $5.25 / Month
Revenue positive through FYE29
Exempting City property reduces funding by
$80,000 per year
Funds FYE26-FY29 current and proposed
operating expenses
Commercial Rate: $5.25 / ERU / Month Cash-funds identified CIP below $1M by
Example property FYE28
9 ERUs * $5.25 = $47.25
Paygo CIP funding:
$660,000 FYE26
$80,000 FYE29
Loss of funding capacity due to inflation,
zero growth shown through FY29
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Scenario 2 – Moderate Debt-Funded CIP
Residential Rate: $11.00/ Month
Revenue positive through FYE29
Exempting City property reduces funding by
$168,000 per year
Funds FYE26-FYE29 current and proposed
operating expenses
Commercial Rate: $11.00 / ERU / Month
Example property $4.7M available annually for CIP
9 ERUs * $11.00 = $99.00
Debt-funds identified CIP list under $11M
$63M for 14 CIP projects
1/3 of identified CIP projects
$4.7M note, 20 years, 4% interest
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Comparison to Other Cities
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Comparison Residential Stormwater Utility Fees
$14
$12.22
$12 $11.00
$10.22
$10
$8
$6 $5.25 $5.55
$4 $3.55
$3.00
$2.42 $2.46
$2 $2.30
$1.25
$0
Midwest City Stillwater Edmond Lawton Lawton Enid Broken Lawton Tulsa
Current Proposed Arrow Proposed
Combined Scenario 1 Scenario 2
**No dedicated stormwater
*All benchmark cities are flat residential fees fee:
Single fee that covers both Stormwater and Drainage. Moore – partially funded through
1/8th sales tax and general fund
Fees are for Stormwater only.
Norman – partially funded
Drainage expenses are covered through the General Fund or Drainage Maintenance Fund for Lawton. through a Public Safety Sales
Fees are for Drainage only. Tax Fund as well as general fund
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Stormwater and Drainage/Streets Personnel per 10,000 Residents
7
6 6 6
5
4 4
3 3
2 2
1 1
0.4
0
Stillwater Edmond Lawton Broken Arrow Tulsa Enid Midwest City
Current
Combined
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Next Steps
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Schedule
Prepare
City Council
City Council draft
Rate meeting for Billing Go-live
work ordinance
Committee rate preparation billing
session and fee
approval
schedule
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Stormwater Utility Fee
Evaluation Study Update
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Item Title:
Consider the recommendations of the Stormwater Utility rate Study regarding fee rates and fee
structure to determine fee calculations, and take action as appropriate.
Initiator: Michael Watrous, Director
Information Source: Michael Watrous, Director
Background:
The study contains two recommendations regarding the fee structure and fee charges for the
Stormwater Utility Rate. These both assume that the merger of the two fees are approved and the
Stormwater and Drainage Divisions are merged into one division.
1.) Fee Structure. Various fee structure alternatives were presented to City staff. The
recommended fee structure is to charge all Single-Family Residential properties a flat rate. All
Commercial properties would be charged per Equivalent Residential Unit (ERU).
Public Works recommended a flat residential rate system with all single-family residential
properties charged the same rate. This was to reduce the administrative burden of analyzing
every residential property on a regular basis to see what the current impervious surface was.
With this rate structure all developed residential properties would be charged the same rate,
equal to one ERU. Undeveloped single-family residential properties would not receive a
stormwater utility fee.
All developed commercial properties would receive a stormwater utility fee based on their
impervious area. For every 3,200 sq ft of impervious area or one ERU, a commercial property
would receive the fee charge for each ERU applied to the property.
2.) Fee Rate. Based on the stormwater and drainage needs, two scenarios are presented. The
scenarios presented summarizes a range of rate possibilities for the stormwater utility fee.
Scenario 1 shows services largely limited to covering operating expenses, while Scenario 2
shows services covering operating expenses and funding a portion of the identified capital
improvements. The corresponding stormwater utility rates for each scenario are in line with
comparison cities in the state. Note that because no growth is projected in these financial
scenarios, the annual revenue is projected to be flat for the projection period.
Scenario 1 proposes a flat fee of $5.25 per month for residential properties and $5.25 per ERU
per month for commercial properties. This scenario allows the stormwater utility to remain net
revenue positive through FYE29, however minimal funding is available to complete maintenance
and CIP needs.
Scenario 2 proposes a flat fee of $11.00 per month for residential properties and $11.00 per ERU
per month for commercial properties. This scenario allows the stormwater utility to remain net
revenue positive through FYE29 and allows for the City to complete more maintenance projects
and complete one-third of the CIP projects identified in the 2003 Master Plan.
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The City has the flexibility to consider rates that fall between the two identified scenarios above,
with the knowledge that operating expenses would be covered and somewhere between zero and
one-third of CIP projects could be funded.
The current combined fee is $3.55 each month. In order to remain in the red through FY2029, the
rate would need to increase to at least $5.25, with no capital improvement performed. If capital
improvement projects are performed to reduce flooding potential in the city, rates would need to
increase up to $11.00/month. Currently, no capital improvement is performed.
Correlation to the True North Statement:
The Citizen – Everything that we do is for the citizen, EVERYTHING
• The new structure ensures that each property pays a fair share based on its impact on the
stormwater system. For residents, the flat rate offers predictability and fairness. For
commercial users, the ERU model ensures equity by charging based on impervious area.
This reflects a strong commitment to citizen equity and service.
Efficiency
• A uniform, measurable rate structure allows for streamlined billing, more accurate
revenue forecasting, and better resource planning. This change simplifies administration
while also enabling efficient scaling of services to match actual stormwater impacts
across all property types.
Safe Community
• By aligning fees with real-world usage and infrastructure impact, the new structure
ensures sustainable funding for critical stormwater services—like drainage maintenance,
flood prevention, and regulatory compliance. This promotes a cleaner, safer, and more
resilient city.
Our Pursuit of Excellence
• By benchmarking against other cities and adopting a fee model based on best practices,
Lawton demonstrates a commitment to excellence. This shift reflects a deliberate choice
to innovate, modernize, and lead by example, rather than settling for outdated or
inequitable systems.
Exhibit:
1.) Stormwater Utility Report 2.) Stormwater Utility Presentation
Key Issues:
Changing the fee structure will result in higher costs to commercial businesses, but will ensure a
fair share of costs on water runoff into the stormwater system. Larger businesses will pay more,
as more water runs off their properties than small businesses.
Increasing the fees will allow for improved capital improvement in the city's stormwater system,
resulting in less flooding risks for citizens and less damage to infrastructure during flooding
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events. Without a rate increase, services provided to citizens will gradually reduce to keep within
the established funding provided by the fees.
Funding Source:
N/A
Staff Recommended Council Action:
Consider recommending the approval of the fee structure, and consider a gradual increase in the
fee over the course of 3 years so that continued services can be provided for citizens.
ATTACHMENTS:
1. Lawton_SWU_Report_03142025
2. Stormwater Rate Study
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STORMWATER UTILITY FEE REPORT
Prepared for:
City of Lawton
March 2025
Prepared by:
FREESE AND NICHOLS, INC.
3600 NW 138th Street, Ste 202, Oklahoma City, OK 73134
(405) 607-7060
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City of Lawton
TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................................... 1
1.1 Description of the City of Lawton ................................................................................................... 1
1.2 Legal Basis and Limitations of a Stormwater Utility ............................................................... 3
1.3 Stormwater Utility Policy ................................................................................................................... 3
2.0 COST OF STORMWATER AND DRAINAGE SERVICES ................................................................. 5
2.1 Cost of Service Development Considerations ............................................................................ 5
2.2 Cost of Service Assumptions ............................................................................................................. 6
2.3 Storm System Maintenance ............................................................................................................... 6
2.4 CIP Identification ................................................................................................................................... 7
2.5 Operating Reserve ................................................................................................................................ 8
3.0 REVENUE ASSESSMENT ......................................................................................................................... 9
3.1 Basis for Fee Calculation .................................................................................................................... 9
3.2 Billing Method ..................................................................................................................................... 10
3.3 Determination of Property Impact to Storm System ........................................................... 10
3.4 User Fee Categories ........................................................................................................................... 13
3.4.1 Single-Family Residential Properties .................................................................................13
3.4.2 Commercial Properties ............................................................................................................14
3.4.3 Property Exemptions................................................................................................................14
4.0 MENU OF SERVICES .............................................................................................................................. 15
5.0 ALTERNATIVES AND RECOMMENDATIONS............................................................................... 16
5.1 Stormwater Needs ............................................................................................................................. 16
5.2 Fee Structure AND RATE RECOMMENDATION...................................................................... 16
5.3 Rate recommendation ...................................................................................................................... 17
6.0 UTILITY IMPLEMENTATION ............................................................................................................. 19
6.1 Stormwater Utility Ordinance Adoption ................................................................................... 19
6.2 Appeals Process .................................................................................................................................. 19
6.3 SWU Fee Billing Implementation ................................................................................................. 20
6.4 Utility Account Management ......................................................................................................... 20
7.0 REFERENCES ........................................................................................................................................... 22
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Stormwater Utility Fee Report
City of Lawton
Table of Figures
Figure 1-1: City Limits...................................................................................................................... 2
Figure 3-1: Example of Impervious Area for Single-Family Residential Property......................... 11
Figure 3-2: Example of Impervious Area for Commercial Property ............................................. 12
Figure 3-3: City-Wide Impervious Area, by Stormwater Utility Classification .............................. 13
Table of Tables
Table 2-1: Annual Cost Factors ....................................................................................................... 6
Table 2-2: Potential Staff ................................................................................................................ 7
Table 4-1: Stormwater and Drainage Service Needs and Associated Cost, FYE 25 ...................... 15
Table 5-1: Summary of Single-Family Residential Properties ....................................................... 17
Table 5-2: Scenario 1 Operating Expenses without CIP ................................................................ 17
Table 5-3: Scenario 2 Operating Expenses with CIP ..................................................................... 17
APPENDICES (TO BE POPULATED WITH FINAL REPORT)
Appendix A Drainage Projects from City FY23-27 CIP Book
Appendix B Public Notice
Appendix C Stormwater Utility Ordinance and Fee Schedule
Appendix D Rate Committee Presentation
Appendix E Council Presentations
Appendix F Concept Maintenance Methodology
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Stormwater Utility Fee Report
City of Lawton
1.0 INTRODUCTION
The City of Lawton retained Freese and Nichols, Inc. (FNI) to evaluate the components of a stormwater
management and drainage maintenance fee. FNI evaluated a stormwater management and drainage
maintenance structure and rates based on requirements of applicable state laws and the City of Lawton
(the City’s) identified storm system needs. FNI developed a menu of stormwater and drainage services
from which the City could choose to meet its stormwater and drainage programs goals, including
compliance with new federal water quality protection requirements. Through discussions within the City,
it was determined that ultimately merging the utility departments of Stormwater Management and
Drainage Maintenance into one utility was a consideration to evaluate during the study. The cost elements
of both utilities will be referenced throughout the report, however only one combined fee (a Stormwater
Utility Fee) will be referenced, as that is the recommended fee.
1.1 DESCRIPTION OF THE CITY OF LAWTON
Lawton is the largest city in Comanche County, located approximately 86 miles southwest of downtown
Oklahoma City. The City has a total area of approximately 81 square miles. Interstate 44 (I-44) is the main
thoroughfare through the City, running from the north limits to the south limits of the City. US Highway
62 (US 62) is a major highway running from east to west Lawton. State Highway 7 (SH 7) runs east to west
on the southern side of the City.
The 2023 population for the City is 90,245 [1]. The City has three major stormwater related waterways
including, East Cache Creek, Wolf Creek, and Nemu Creek accompanied by 10,914 acres of surrounding
floodplains.
1
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Stormwater Utility Fee Report
City of Lawton
Figure 1-1: City Limits
2
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Stormwater Utility Fee Report
City of Lawton
1.2 LEGAL BASIS AND LIMITATIONS OF A STORMWATER UTILITY
The State of Oklahoma provides municipalities the opportunity to establish a stormwater utility, which is
a legal mechanism used to generate revenue to finance the City’s cost to provide and manage stormwater
services in the City.[2] “Oklahoma Statues Title 11. Cities and Towns” section 11-22-104 grants cities in
Oklahoma the “Right to engage in business – Public utilities and improvements… for public improvement
purposes”. To provide these services, municipalities are authorized to assess fees to the users of the
stormwater utility system.
The stormwater utility fee is a service fee and must be based on the projected cost of providing
stormwater service within the City’s jurisdiction.
1.3 STORMWATER UTILITY POLICY
This stormwater and drainage report provides an overview of an assessment of the feasibility for the City
of Lawton to finance its stormwater and drainage-related activities through revenues from a stormwater
utility fee. Under the present system, necessary stormwater or drainage-related activities are financed
through a respective fund of either Stormwater Management or Drainage Maintenance. In addition,
significant capital and management improvements to the overall stormwater and drainage systems are
needed to protect existing and expected development and to meet ongoing regulatory requirements.
The City is one of many municipalities subject to federal stormwater quality regulations that require the
City to further protect and enhance water quality in creeks and lakes through the development of a
stormwater quality management program. As an operator of a municipal separate stormwater system
(MS4) as defined by the U.S. Environmental Protection Agency, the City is required to develop a multi-
faceted program to protect stormwater quality before it enters creeks, rivers, and lakes. The program
includes a number of measures to protect stormwater quality, such as the following:
• Storm system maintenance
• Structural and non-structural water quality protection measures
• Storm system mapping and inspections
• Public education, outreach, and involvement
• City ordinances regulating construction activity, illicit discharges, and post-construction
runoff
• City staff training and operations improvements
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The purpose of this study is to identify a fair and equitable stormwater utility fee and fee structure to
finance some or all of these measures, as well as associated administration, service, equipment and other
stormwater-related costs. The study strives to identify an appropriate fee based on the projected cost of
providing stormwater services in the City. To further protect rate payers from inequitable charges, a
means to appeal the rates for any property is currently in place through a Stormwater Hotline listed on
the City’s website.
The following general goals and policies were considered for the City’s stormwater utility. These goals
provided an initial basis for the potential purposes and benefits of the utility for the City of Lawton.
A. Serve as the primary stable source of new stormwater and drainage-related funding.
B. Finance some or all of the following specific activities:
1. Stormwater Ordinances and Design Criteria modifications
2. Ongoing implementation and maintenance of a Stormwater Quality Management
Program to comply with Federal and State MS4 regulations and permit requirements
3. Engineering studies and design
4. Capital improvements to the stormwater and drainage system infrastructure
5. Proactive maintenance for existing infrastructure
6. Equipment for drainage maintenance
7. Staffing for maintenance, compliance, engineering, and/or administration activities
8. Implementation and maintenance of the City’s Phase II MS4 stormwater management
program to comply with U.S. Environmental Protection Agency (EPA) and Oklahoma
Department of Environmental Quality (ODEQ) regulations and permits, as applicable
C. Provide a mechanism to benefit the quality of life in Lawton by improving and integrating the
management of water resources with other aspects of the City such as park systems
D. Encourage development in the City that minimizes adverse stormwater impacts through
better site design and proper management of the City’s stormwater resources
E. Provide a fair and equitable method to assess fees for developed properties’ impacts to the
City’s stormwater system
F. Allow for the issuance of bonds to finance stormwater capital improvement projects
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2.0 COST OF STORMWATER AND DRAINAGE SERVICES
The stormwater utility fee is a common method to address a significant portion of the financial burden
for stormwater and drainage management. This section includes considerations and options for services
the City may finance with stormwater utility fee revenues. A variety of options for staffing, equipment,
and services to provide are made available for reference. The City may choose to select from the list
provided, or additional options if the options are stormwater-related. Default values for several
parameters are provided in this report with input from the City. This includes rates for labor, equipment
purchases and rental, city growth, and inflation.
2.1 COST OF SERVICE DEVELOPMENT CONSIDERATIONS
Options were evaluated to determine an appropriate methodology for identifying the projected cost of
providing stormwater and drainage service in the City. It was determined that the following considerations
would be incorporated into the assessment of the cost of stormwater and drainage services for the
purpose of determining the revenues necessary for the stormwater utility:
• Identify expected stormwater and drainage-related costs. This includes prorated costs for
administration, equipment, and other expenses not dedicated to stormwater or drainage
activities.
• Evaluate a five-year period for projecting cost of service needs. Cost projections beyond five
years are inherently less reliable and may not provide the City with the quality information
desired for planning purposes.
• The fund balances for both Stormwater Management and Drainage Maintenance combine to
currently have a 180-day operating balance which will be maintained over the observation
period.
• Consider prorated costs for items not solely associated with stormwater or drainage but that
have an application for stormwater management and drainage maintenance. Examples
include engineering staff, maintenance crews, and maintenance equipment.
• Plan for stormwater and drainage revenues to finance all direct operating costs and
administrative costs for stormwater and drainage-related activities, including major capital
projects.
• Address as much of the City’s stormwater and drainage-related costs as practicable through
the stormwater utility fee.
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City of Lawton
2.2 COST OF SERVICE ASSUMPTIONS
For the purposes of the five-year plan, several assumptions were identified and incorporated into the
planning process. Specifically, anticipated annual cost increases were identified and developed into cost
factors for both stormwater management and drainage maintenance, as shown in Table 2-1.
Table 2-1: Annual Cost Factors
FYE26 FYE27 FYE28 FYE29 FYE30
Expense Rate Inflation 5% 5% 5% 5% 5%
Interest Rate for Debt Service 4% 4% 4% 4% 4%
City Projected Growth Rate 0% 0% 0% 0% 0%
The expense rate inflation and interest rate for debt service are assumed to remain constant over the five-
year projection period. City growth is conservatively projected at 0% for the five-year projection period.
2.3 STORM SYSTEM MAINTENANCE
The City plans to establish a program to conduct routine operations and maintenance (O&M) activities
throughout the stormwater and drainage system to minimize flooding potential, protect life and property,
reduce creek erosion, and protect stormwater quality. The City may consider budgeting through the
stormwater and drainage utility to fund all or a portion of a storm system and drainage maintenance crew
to conduct stormwater and drainage O&M activities throughout the City. A list of the common crew
positions that the City is considering, including compensation with benefits for FYE 2026, is provided in
Table 2-2. Rates for all positions currently assume 100 percent financing by the combined utility of
stormwater management and drainage maintenance. Positions not fully dedicated to stormwater or
drainage-related services can be funded on a pro-rated basis if stormwater or drainage utility funding is
limited to stormwater or drainage-related services.
The seasonal labor and equipment operators would assume responsibility for routine storm sewer system
maintenance activities such as stormwater ditch cleanouts, inlet cleanouts, and drainage swale
landscaping. The projected cost to purchase equipment for the seasonal labor and equipment operators
is provided in Table 2-3. The purchase price of the equipment is amortized over its expected service life
to provide an annualized cost. Annual O&M costs include projected fuel and routine maintenance costs.
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Table 2-2: Potential Staff
Position Compensation Total Compensation
Position # of Positions
with Benefits (FYE26) (FYE26)
Equipment Operator 4 $57,570 $230,278
Seasonal Labor 6 $57,299 $343,791
Environmental Specialist 1 $105,793 $105,793
Construction Inspector 1 $70,150 $70,150
Table 2-4: Cost to Purchase Equipment for Stormwater Management and Drainage Maintenance
Capital Service Annualized Annual
Value Life Purchase Cost O&M Total Annual Cost
Equipment (FYE25 $) (Years) (FYE25 $) (FYE25 $) (FYE25 $)
1/2 Ton Pickup (F-450) $88,518 5 $17,704 $3,100 $27,244
Landscape Trailer $8,000 10 $800 $0 $800
Walk Behind Mower (3) $4,500 5 $900 $100 $1,600
Backpack Leaf Blower $400 10 $40 $100 $140
Assorted Hand Tools $500 10 $50 $0 $50
Zero Turn Mower $6,000 10 $600 $300 $2,100
Safety Items $300 10 $30 $0 $30
Uniforms and Boots $9,000 5 $1,800 $0 $1,800
Large Tractor Mower $250,000 10 $25,000 $8,800 $39,800
Small Tractor Mower $200,000 10 $20,000 $7,000 $30,000
Weed eater (6) $3,600 5 $720 $100 $220
Hydro mulcher $5,000 10 $500 $200 $700
Vacuum Truck $275,000 10 $27,500 $9,700 $40,200
Truck $65,000 5 $13,000 $1,000 $15,200
2.4 CIP IDENTIFICATION
The City’s Proposed Five-Year Capital Improvement Program (FY26 – FY30) identifies a suite of
improvements to the City’s drainage maintenance system. Most Capital Improvement Program
improvements are from a list of projects in the 2003 Stormwater Master Plan. The project costs have been
updated to 2024 values by the City’s stormwater consultant. Financing assumptions are a 20-year loan at
a 4 percent interest rate.
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2.5 OPERATING RESERVE
The fund balances for both Stormwater Management and Drainage Maintenance combine to currently
have a 180-day operating balance. Currently the Stormwater Management Utility has a fund balance equal
to approximately $557,000. The Drainage Maintenance Utility has a fund balance equal to approximately
$930,000.
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3.0 REVENUE ASSESSMENT
3.1 BASIS FOR FEE CALCULATION
By practice, the stormwater utility fee rate is calculated according to a basis that estimates a property’s
use of the stormwater and drainage system. As a result, fee rates are not based solely on certain readily
accessible information, such as property values or water usage rates. The City’s stormwater utility rate
will be based on the amount of impervious area for each property. Impervious surfaces do not provide
stormwater significant opportunity for infiltration into the soil and result in increased stormwater runoff
to the municipal storm sewer system.
The impervious area approach to stormwater utility rates is the most common basis for estimating a
property’s impact on the municipal stormwater system. This method is considered a reasonably equitable
approach and is used by many surrounding municipalities.
The residential approaches for stormwater utility fees of benchmark comparison cities for Lawton are
summarized in the table below:
Table 3-1: Comparison of Stormwater Utility Fees
City Basis Rate
Midwest City Meter Size $2.42
Stillwater Flat Rate $2.46
Edmond Flat Rate $3.00
Enid Per ERU $5.55
Broken Arrow Per ERU $10.22
Tulsa Flat Rate $12.22
Property improvements that are considered as impervious areas include buildings, paved parking lots,
driveways, patios, walkways, and pools. Gravel parking lots and driveways are also considered impervious
area because of the low infiltration rate of stormwater through their surface. Sidewalks within the City
ROW were not included in individual property impervious area calculations.
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The potential stormwater and drainage impact of impervious area to the storm system include the
following:
• Increased total volume of water required to be managed by the municipal storm system
resulting in flooding
• Increased peak flows from storm events resulting in flooding
• Increased flow velocities result in increased erosive actions in creek channels and adjacent
properties
• Increased pollutant load resulting in degraded water quality
Site-specific design and maintenance approaches may minimize one or more of these impacts. As noted
in Section 7.2 (Appeals), the City may determine to reduce the stormwater utility fee for a property by an
equitable amount to account for the beneficial stormwater impact of design and/or maintenance
approaches by a property owner.
3.2 BILLING METHOD
Fees for stormwater utilities are collected in a variety of ways throughout the country, including as line-
items on water bills, as yearly payments with property taxes, or as stand-alone bills. The most common
method to assess stormwater and drainage utility charges is through the City utility bill, which is the
method Lawton currently uses and will continue.
As part of the City utility bill, the stormwater utility fee will appear on the utility bill as a single line item
with the monthly dollar amount for the property shown. A stormwater utility charge will be assessed on
a utility account for each eligible property.
If the property can be linked to an associated property with a City utility account, the fee for the improved
property is included in the affiliated property’s utility account. A common example is a restaurant with a
parking lot located on an adjacent lot. If no existing utility account can be associated with the improved
property, a new utility account is established by the City for the purpose of assessing the stormwater
utility fee. Eligible improved property without an associated utility account still would be assessed a
stormwater utility fee, usually as a stand-alone “stormwater-only” charge on a specially developed
account for the property owner.
3.3 DETERMINATION OF PROPERTY IMPACT TO STORM SYSTEM
By practice, undeveloped properties in their natural state are not charged a stormwater utility fee.
Developed properties with impervious area increase the rate and/or volume of stormwater runoff to the
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municipal storm system. Infrastructure improvements, ongoing maintenance, inspections, and
evaluations are necessary to effectively manage the increase in stormwater discharge from impervious
area.
Impervious area includes rooftops, paved parking lots, paved driveways, gravel driveways, walkways,
outbuildings, patios, and pools. It does not include vegetated areas. Properties with less than 400 sq ft of
impervious are considered undeveloped. To determine the impact of each developed property on the
storm system, FNI delineated the impervious area for each residential and commercial property. The
resulting impervious area measurements were used to develop the equivalent residential unit (ERU),
which forms the basis fee for all developed properties. One ERU was determined to be 3,200 square feet
impervious area based on the mean value residential properties.
The impervious area amount is associated with the specific parcel or group of parcels for the development.
The parcel is associated with the appropriate utility billing accounts to allow for assessment of the proper
stormwater utility fee if implemented.
Figure 3.1 is an example of the impervious area determination for a single-family residential property, and
Figure 3.2 is an example for a commercial property. Figure 3.3 shows the impervious area for all
properties, City-wide.
Figure 3-1: Example of Impervious Area for Single-Family Residential Property
Total Impervious Area:
3,200 ft2 (Residential Average)
1 ERU
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Figure 3-2: Example of Impervious Area for Commercial Property
Total Impervious Area:
15,000 ft2 (Measured)
5 ERUs
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Figure 3-3: City-Wide Impervious Area, by Stormwater Utility Classification
3.4 USER FEE CATEGORIES
The stormwater utility fee system consists of several types of user accounts depending on the type of
property and the category of property owner. The stormwater utility fee rate structure is based on the
type of user account. The three general account categories include:
• Single Family Residential (includes duplexes)
• Commercial (includes apartments)
• Exempt (currently considering City property)
3.4.1 Single-Family Residential Properties
Single-family residential properties consist of all developed single-family residential properties within the
City. Apartment complexes are considered to be commercial properties for fee determination purposes.
Impervious area includes the footprint of the residence, including roof overhangs, driveways, walkways,
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patios, sheds, carports, gravel surfaces, and other impervious surfaces. It does not include the sidewalk
within the City ROW (if present), public streets, or swimming pools.
At the time of this study, 27,698 eligible, non-exempt Single-Family Residential properties were present.
2,911 properties were assigned the Commercial stormwater utility classification. The Single-Family
Residential properties account for approximately 90 percent of the total number of parcels and 41 percent
of the total impervious area measured for the City in this report.
FNI and the City evaluated numerous different fee structures and decided on a flat residential structure,
with the average impervious area per ERU being based on the mean of all residential properties. Each
residential account would pay the same amount, equal to one ERU. The fee structure was determined
based on feedback from the City as described in Section 6.
3.4.2 Commercial Properties
Any property that is not Single-Family Residential is considered to be Commercial. This includes what is
normally considered as commercial as well as apartments and tax-exempt religious organizations. Other
developed properties in the City that do not qualify as Single-Family residential and do not meet any of
the exemption criteria are also considered Commercial.
Stormwater utility and drainage maintenance fees for eligible commercial are individually calculated
based on the total amount of impervious area for the affiliated properties. Each Commercial property is
assessed a stormwater utility and drainage maintenance fee at a rate according to the stormwater utility
rate unit charge, expressed in whole ERU increments.
3.4.3 Property Exemptions
Many cities consider, and often adopt, exemptions for categories of the community. The City is
considering exempting City properties; however, they would be considered Commercial if they were not
exempted. The financial modeling contained in this report assumes City properties are exempted from
the stormwater utility fee. It is recommended that the City review with the City attorney legal allowances
and constraints in establishing exemptions for the stormwater utility fee to verify actions taken are in
accordance with applicable laws.
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4.0 MENU OF SERVICES
This section presents staffing, maintenance, and capital improvement projects that the City might
consider including in its stormwater program. Each new service or project has an associated cost.
Table 4-1 shows the stormwater and drainage needs and associated costs if they were funded through
the stormwater utility fee. This menu of services was presented to the City during the biweekly update
meetings throughout the year 2024. Table 4-1 does not include rate rounding/leveling, operating reserve
contribution, or administration reimbursement.
Table 4-1: Stormwater and Drainage Service Needs and Associated Cost, FYE 25
Expense Monthly Cost
Description Annual Cost
Category ($/ERU)
Total Salary, Fringe Benefits, Overtime,
Staffing $1,967,852 $2.63
Ancillary Supplies, Training, etc.
Equipment
Mowers, Trucks, Tools, Equipment, etc. $97,618 $0.13
Expenses
Recurring Materials and Supplies, Equipment
$406,451 $0.54
Expenses Replacement Fund, etc.
Rehab and
Ongoing maintenance $417,452 $0.51
Maintenance
Table 4-2 shows the services being paid for by the stormwater utility fee.
Table 4-2: Cost of Service Summary
Cost FYE25 FYE26 FYE27 FYE28 FYE29
Current Expenses $2,889,373 $2,940,899 $3,087,943 $3,242,340 $3,404,457
Labor Proposed $0 $175,943 $184,740 $193,977 $203,676
Equipment Proposed $0 $172,328 $180,945 $189,992 $199,492
Recurring Proposed $0 $348,600 $366,030 $384,332 $403,548
Total $2,889,373 $3,637,770 $3,819,658 $4,010,641 $4,211,173
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5.0 ALTERNATIVES AND RECOMMENDATIONS
This section documents the alternatives analyzed by FNI and the City and the resulting recommendations.
5.1 STORMWATER NEEDS
FNI and the City evaluated the stormwater needs across Lawton. These included the need for compliance,
preventive maintenance, corrective maintenance, and capital improvement projects. The menu of
services and their associated costs are shown in Section 4.
FNI and the City also evaluated various storm water capital improvement projects (CIPs) in Lawton. These
projects were identified in the City’s 2003 Master Plan, complete with preliminary cost estimates and
solutions, updated to 2024 value. The City did not select any projects specifically to be included in this
Stormwater Utility Fee Development Report.
FNI and the City identified a complete list of stormwater and drainage services that are needed but not
conducted due to a lack of funding. These services include preventative maintenance and various CIP
projects.
5.2 FEE STRUCTURE AND RATE RECOMMENDATION
In addition to the stormwater needs, various fee structure alternatives were presented to City staff. The
recommended fee structure is to charge all Single-Family Residential properties a flat rate. All Commercial
properties would be charged per ERU. FNI analyzed several other fee structures with a wide range of
variables including 1) numbers of residential tiers, 2) level of service options, 3) exemption assumptions,
4) administration reimbursement amounts, and 5) reserve contribution amounts.
The City chose a flat residential rate system with all single-family residential properties charged the same
rate. The proposed rate structure is summarized in Table 5-1. With this rate structure all developed
residential properties would be charged the same rate, equal to one ERU. Undeveloped single-family
residential properties would not receive a stormwater utility fee.
All developed commercial properties would receive a stormwater utility fee based on their impervious
area. For every 3,200 sq ft of impervious area or one ERU, a commercial property would receive the fee
charge for each ERU applied to the property.
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Table 5-1: Summary of Single-Family Residential Properties
Count of Mean Impervious
Residential Tier ERUs
Properties Area, sq ft
Residential Flat 27,698 3,200 27,698
5.3 RATE RECOMMENDATION
Based on the stormwater and drainage needs, two scenarios were presented to City staff. The scenarios
presented to staff summarized a range of rate possibilities for the stormwater utility fee. Scenario 1 shows
services largely limited to covering operating expenses, while Scenario 2 shows services covering
operating expenses and funding a portion of the identified capital improvements. The corresponding
stormwater utility rates for each scenario are in line with comparison cities in the state. Note that because
no growth is projected in these financial scenarios, the annual revenue is projected to be flat for the
projection period.
Scenario 1 proposes a flat fee of $5.25 per month for residential properties and $5.25 per ERU per month
for commercial properties. This scenario allows the stormwater utility to remain net revenue positive
through FYE29, however minimal funding is available to complete maintenance and CIP needs. Table 5-2
shows the proposed rates and projected annual revenue for Scenario 1.
Scenario 2 proposes a flat fee of $11.00 per month for residential properties and $11.00 per ERU per
month for commercial properties. This scenario allows the stormwater utility to remain net revenue
positive through FYE29 and allows for the City to complete more maintenance projects and complete one-
third of the CIP projects identified in the 2003 Master Plan.
The City has the flexibility to consider rates that fall between the two identified scenarios above, with the
knowledge that operating expenses would be covered and somewhere between zero and one-third of CIP
projects could be funded.
Table 5-2: Scenario 1 Operating Expenses without CIP
Monthly Fee Annual
Category Parcels ERUs
($/ERU/month) Revenue
Residential 27,698 27,698 $5.25 $1,745,000
Commercial 2,911 40,229 $5.25 $2,534,000
Total 30,609 67,927 $4,279,000
*Note revenues are rounded to the nearest $1,000
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Table 5-3: Scenario 2 Operating Expenses with CIP
Monthly Fee Annual
Category Parcels ERUs
($/ERU/month) Revenue
Residential 27,698 27,698 $11.00 $3,656,000
Commercial 2,911 40,229 $11.00 $5,310,000
Total 30,609 67,927 $8,966,000
*Note revenues are rounded to the nearest $1,000
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6.0 UTILITY IMPLEMENTATION
6.1 STORMWATER UTILITY ORDINANCE ADOPTION
The stormwater utility fee rates are adopted by ordinance through a majority vote of the City Council. The
implementation ordinance declares the stormwater utility adoption and declares the stormwater system
of the City to be a public utility. The fee resolution sets the schedule of stormwater utility charges.
6.2 APPEALS PROCESS
By practice customers subject to stormwater utility fees should have the opportunity to appeal the
stormwater utility rates set for their properties. Valid reasons for protest include the following:
A. Undeveloped property is assessed a stormwater utility fee.
B. Property runoff is contained and does not contribute to the City’s stormwater system.
C. Property is improperly classified (i.e., Commercial instead of Residential), resulting in the
incorrect rate being applied.
D. Fee is charged on multiple utility accounts for the same physical property.
E. Fee is based on an incorrect impervious area determination for the property.
F. Fee is based on impervious area for property unrelated to the utility account under appeal.
A recommended appeals process is as follows:
A. Protests must be made in writing by the account holder and submitted to the stormwater
utility administrative staff (Utility Billing) for review. The specific reason for the appeal must
be provided, along with necessary information such as the account numbers under protest.
B. Stormwater utility administrative staff will conduct a review of the protest and is authorized
to correct utility fee rates for any of the above reasons, except for claims of incorrect
impervious area determinations. Claims of incorrect impervious area determinations will be
assessed by the City Engineer.
C. An initial determination will be provided by the City to the protesting party within 30 days of
the protest submission.
D. Appeals denied by the stormwater utility administrative staff may be appealed to the City
Engineer. The City Engineer will conduct a review of the appeal and provide a determination
in writing to the protesting party within 30 days of the appeal. Appeal determinations made
by the City Engineer may be appealed to the City Manager.
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E. Any adjustment to a stormwater system user’s fee must be made on a basis that remains
nondiscriminatory, equitable, and reasonable for all utility fee payers. Approved fee
adjustments will apply for future bills and will include credit for bills up to six months prior to
the appeal. No credit will be applied to bills prior to six months before the appeal was
submitted, and no credit will be applied to bills to prior owners of the property.
6.3 SWU FEE BILLING IMPLEMENTATION
Prior to implementation of the stormwater utility fee, the impervious area associated with each property
must be linked with the correct utility billing account. This is accomplished by matching address
information from the City’s utility billing database to address information contained within the
appropriate GIS parcel data.
6.4 UTILITY ACCOUNT MANAGEMENT
Each developed, non-exempted property must be assessed a stormwater utility fee and will require a
utility account. FNI recommends the utility fee be assessed on a single account per property to minimize
the City’s administrative burden.
Duplicate utility billing accounts for a property are not typically assessed a stormwater utility fee unless
the total stormwater utility fee is apportioned across multiple accounts. For administrative reasons,
associating the stormwater utility fee to a single account per property is recommended.
Strip shopping centers and apartment complexes typically have numerous accounts. A common utility
account scenario for these types of properties is to have one account for each business or apartment
building, respectively, as well as a management account and/or an irrigation account. FNI recommends
assigning the stormwater and drainage utility fee to the management or irrigation account to allow the
property management to determine the appropriate approach to assess the stormwater and drainage
utility fee to individual tenants.
It is recommended that impervious surface calculations for commercial properties be updated as work
permits are completed to ensure that data is kept current. This data maintenance responsibility would be
the requirement of the stormwater division to assess and provide as permits are applied for or completed.
Further information regarding how to maintain and ensure the accuracy of this data can be found in the
Appendices.
Some properties have no active utility account. Examples of such properties include those on well water,
those within City limits but provided service by other providers, and properties such as parking lots that
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have no need for a water account. For these developed properties, a new utility account will typically
need to be created specifically to assess the stormwater and drainage utility fee. Properties are not eligible
to be exempted from the stormwater and drainage utility fee for the reason of having no water, sewer,
or waste disposal service with the City.
Accounts in an exempt category are not assessed a stormwater utility fee. A variety of circumstances can
lead to a utility account and/or a property being exempt. A property meeting any of the mandatory
exemptions or the City’s selected optional exemptions are considered exempt. The associated utility
accounts for these properties are categorized in the exempt classification.
The City may determine that it is more efficient to assess stormwater fee for some developed properties
as a group. For example, a property that extends across multiple parcels may be assessed a single utility
fee but clarifying notes in the utility billing database are recommended to identify the parcels that are
aggregated to assess the single fee.
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7.0 REFERENCES
[1] US Census Bureau, "QuickFacts Lawton city, Oklahoma," [Online]. Available:
https://www.census.gov/quickfacts/lawtoncityoklahoma. [Accessed 20 August 2024].
[2] https://oksenate.gov/sites/default/files/2019-12/os11.pdf
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Appendix A: Drainage Projects from City FY23-27 CIP Book
Appendix B: Public Notice
Appendix C: Stormwater Utility Ordinance and Fee Schedule
Appendix D: Rate Committee Presentation
Appendix E: Council Presentations
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Appendix F: Concept Maintenance Methodology
Administrative Review Response Form Letter
[Your Name]
[Date]
[Recipient Name]
[Title]
[Company Name]
[Street Address]
[City, ST ZIP Code]
Dear [Recipient Name]:
Thank you for your request to review your Stormwater Utility Fee charge. We have
completed our review of your account and have determined your request to be:
☐ Approved
☐ Approved with Modifications
☐ Additional Information is Needed
☐ Denied
If your request was approved or modified, your updated charge will be based on the
following information:
Customer Account:
Property Address:
Property ID:
Property Type: Residential Commercial Exempt
Impervious Area sq.ft. [COM only]:
Equivalent Residential Units (ERUs) (Impervious area sq. ft. / 3,200) [COM
ONLY]:
Stormwater Utility Fee ($/month):
If your classification has been adjusted downward (to a lesser charge) you will receive a
credit on the next bill for the billing cycle which has been reviewed. Your charge going
forward will be based on the details listed above.
If your request was noted as additional information needed, please submit the requested
information to us so we may complete our review.
If your request was denied, we have listed the information we have verified as accurate for
your property.
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You have the right to appeal this decision to the Lawton Public Works Director. An appeal
application form is available on our website at:
Lawton, OK | Home
IMPORTANT DEADLINE: If you choose to appeal this decision to the Public Works Director,
you have 14 days from receipt of notice of that decision to file an appeal.
Please note that during the time your account is under review, stormwater charges will
continue to accrue. Any account that is unpaid and not classified as under review will accrue
late charges and be subject to disconnection under existing Lawton procedures.
If you have any questions, please contact me and we can discuss further.
Sincerely,
[Your Name]
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Appeals and Change Form
Owner/Applicant: Call if assistance
needed to fill out form.
Name: _____________________________________________ Daytime Phone:
__________________________
Mailing Address: ______________________________________ City: _________________ Zip:
______________
Email address: _______________________________________
Service Location Information:
Property Address: ______________________________________ Utility Billing Account ID:
Reason for Appeal: (Check all that apply and attach documents and descriptions as indicated)
Impervious Area Calculation
Owner shall provide a copy of a current survey or site plan specifying area in square feet of all impervious
surfaces on the parcel. All measurements are subject to verification by Storm Water Engineering staff.
Current Impervious Area if available (sqft) ________________________________________________
Proposed Corrected Impervious Area if available (sqft) ______________________________________
Current Property Classification Proposed Property Classification
Residential: Residential:
Commercial: Commercial:
Exempt: Exempt:
Incorrect Utility Billing Account Charged:
Current:
_______________________________________________________________________________________
Proposed: _____________________________________________________________________________________
Comments:_________________________________________________________________________________________________________
_
Additional Information:
If desired, provide additional details that will assist the Stormwater Utility Administrator in processing this appeal.
Email this form with any supporting documents to the Public Works Director, michael.watrous@lawtonok.gov.
_________________________________________________________________________________________
__
_________________________________________________________________________________________
__
City of Lawton USE ONLY
Date Received: Reviewed by:
☐ Approved ☐ Approved with Modifications ☐ Additional Info Needed ☐ Denied ☐ Credit to Apply
Notes:
Adjustments
SWU Category (circle one): RES COM EXEMPT Utility Billing Account ID:
Impervious Area (sf): SW Parcel ID:
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Public Works Director Utility Billing Administrator
(1) Date to Utility Billing:
(2) Date Notification sent to applicant: _______________ (3) Date Adjustment Applied:
Signature: Signature:
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STORMWATER UTILITY FAQS
1. WHAT IS A STORMWATER UTILITY FEE?
The stormwater utility fee is a user fee, like water, sewer, and garbage fees, that funds
operations, maintenance and improvements to the town’s drainage system.
The stormwater utility fee is an equitable method to assess a drainage charge based on
developed properties’ impact to the city’s storm system.
2. Why does Lawton have a stormwater utility fee?
The city maintains a drainage system that provides public health and safety through
protection from flooding, minimization of surface water stagnation, and prevention of
stormwater pollution.
Revenues from the stormwater utility fee are used solely for drainage-related purposes within
the town.
3. WHO RECEIVES A STORMWATER UTILITY FEE?
Only developed properties receive a stormwater utility fee.
Apartment complexes and commercial properties are charged at a Commercial rate based on
the total impervious area.
NOTE: Impervious area means a surface which has become compacted or covered with a
layer of material so that it is highly resistant to infiltration by water and includes, but is not
limited to, caliche and gravel surfaces subject to motorized vehicular traffic, walkways,
buildings, parking lots, pavement, and ingress/egress driveways.
Impervious Area does not include sidewalks located in the public right-of-way. For purposes
of this definition, a walkway is a pedestrian path in the interior of an Improved Lot or Parcel
that is not located in the public right-of-way.
4. HOW IS THE STORMWATER UTILITY FEE DETERMINED FOR EACH
PROPERTY?
Customers are charged based on their contribution to the stormwater system, determined by
the amount of impervious area for residential and commercial properties.
All residential accounts will receive the same fee. Based on 1 Equivalent Residential Unit (ERU,
or 3,200 sq ft of impervious area).
Impervious Area (sf*) Monthly Fee
N/A To Be Determine
*sf = square feet
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Non-Residential charges are based on a per-ERU basis.
Impervious area (sf) Monthly fee
Per ERU To Be Determined
/ERU/Month
5. HOW CAN A CUSTOMER LEARN MORE ABOUT THEIR STORMWATER UTILITY
FEE?
Any customer wishing to see impervious area or wanting more information about their
stormwater utility fee can refer to the Lawton Stormwater Management Website or contact
the Public Works Director.
Information is also available online. Upon request, the City will provide a property sheet by
e-mail that details the basis for the stormwater utility fee for that property.
Website: Lawton, OK | Home
Contact information: Michael Watrous - Public Works Director
michael.watrous@lawtonok.gov
6. WHAT IS THE APPEALS PROCESS FOR STORMWATER UTILITY FEES?
Customers wishing to appeal their fee may first contact the Public Works Director, who can
review their fee.
Customers who do not notify the City and who do not submit payment for fees will be subject
to late fees and disconnection procedures.
Appeals of the Assistant Public Works Director’s decision may be made to the Public Works
Director.
NOTE: The call center will not have the information required to modify a customer’s charge,
give stormwater utility fee refunds, or check the status of pending appeals.
7. WHEN WILL THE STORMWATER UTILITY FEE BE ADDED TO AN ACCOUNT
FOR A NEWLY DEVELOPED PROPERTY?
For property under development, the stormwater utility fee will be added to the utility bill
upon issuance of a Certificate of Occupancy or Residential Final Inspection (or equivalent
documentation) for the property.
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City of Lawton
Stormwater Management
Administrative Policies and Procedures
Effective Date:
Subject: Stormwater Utility Fee
Administrative Review, Adjustment, and Appeals Policy
Applies to: City of Lawton Public Works Director, GIS Department, Deputy Public
Works Director
Policy: Provide procedures for the City to comply with its Code of Ordinances, and
to establish both an internal administrative review process and a Public
Works Director appeal, which authorize corrections and adjustment of
water, wastewater, and stormwater utility bills.
Authority: City of Lawton Ordinances, Ord. No. 2005-92
Roles and
Responsibility: Public Works Director
- Has overall responsibility for implementation of the Stormwater
Utility Fee in accordance with the City of Lawton Code of Ordinances.
- Hears, reviews, and makes determinations regarding customer
appeals from the administrative review process as described in City of
Lawton Code of Ordinances, Ord. No. 2005-92.
- Exercises authority to make the final determination on an adjustment
to fee.
Assistant Public Works Director
- Reviews and makes determinations regarding overall policy and
adjustments made to accounts.
- Reviews and makes determinations on whether an adjustment to the
stormwater fee is justified during the administrative review process.
- Provides documentation regarding a customer’s account to the Public
Works Director if the customer desires to appeal the administrative
decisions.
- Notifies Lawton Utility Billing when a customer account is placed in
the Appeals Process.
- Notifies customer of date and time of the Public Works Director
Appeals Hearing.
- Supervises record keeping for the determination, appeals, final
decisions, adjustments made, and reasons for the adjustments.
- Retains records according to the City’s Records Retention Schedule.
- Serves as primary contact for customer questions regarding the
stormwater utility fee.
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City GIS Staff/Stormwater Staff
- Create one page information sheet for property, when requested,
that shows that property’s impervious area determination.
- At the request of the Assistant Public Works Director, reviews GIS
data for property under appeal, to determine if the property in
question is being charged appropriately, undercharged, or
overcharged.
- Reports results of verification back to Assistant Public Works Director
for use in appeals process.
- Make adjustments to GIS database when appeals are successfully
granted or when errors are discovered.
City of Lawton Customer Service Manager
- Maintains the correct billing rate and fees for each customer in
accordance with the rates and fees adopted by City ordinance.
- Bills each customer for services rendered on the utility bill.
- Maintains customer accounts that document charges and fees,
payments and account balances.
- Make corrections, as necessary, to record actual payments made by
the customer and to record the proper billing of charges and fees for
services rendered.
Procedures:
Parcel Classification
City GIS/Stormwater staff maintain the parcel classification information
within the Stormwater Utility (SWU) database. If a parcel classification
error is discovered, City staff takes steps to confirm whether the
classification is an error or not.
• If the classification is incorrect, the correct classification is assigned
in
the SWU database.
• If the classification is not an error, the City communicates the
correct classification to the landowner.
Impervious Area
City GIS/Stormwater staff maintain the calculated impervious area
information within the Stormwater Utility (SWU) database. If an
impervious area value is disputed, City staff takes steps to confirm whether
the impervious area is an error or not.
• If the impervious area is incorrect, the correct impervious area is
updated in the GIS SWU database.
• If the impervious area is not an error, the City communicates the
correct impervious area to the utility account holder.
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Internal Administrative Review Process
The administrative review process is conducted by the Assistant Public Works
Director with assistance from City GIS or Stormwater staff and Lawton Billing. The
scope of the administrative review process includes reviewing and considering
requests regarding:
• Charge to a property that should not receive a charge;
• Incorrect charge applied to a property
During the internal administrative review process, the following items will be reviewed to
provide consistency to customers.
1. Review account information
a. Proper account selected per prioritization policy
i. Owner account
ii. Single tenant account
iii. Adjacent affiliated parcel owner account
iv. Adjacent affiliated parcel tenant account
v. Stormwater-only account
2. Review GIS info
a. Verify SWU Category for parcel
i. EXEMPT
1. Undeveloped (impervious area less than 400 square feet total)
2. City, state, and federal roads, bridges, highways, streets, and
rights-of-way
3. City parks, city buildings, city facilities and open spaces owned
or operated by the city
4. Property under development (prior to issuance of CO or
equivalent)
ii. RES
1. Single family
2. Duplex
3. Triplex
iii. COM
1. Multi-family (4 units or more)
2. Retail
3. Commercial
4. Industrial
5. All other properties not meeting definition of RES or EXEMPT
b. Verify impervious area for parcel
i. RES = impervious area greater than 400 square feet
ii. COM = total impervious area
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3. Review Billing
a. RES
i. Flat rate for residential
ii. For duplexes, triplexes, divide one (1) ERU (Equivalent Standard Unit)
by the number of accounts to receive a bill, then assign the calculated
ERU to each account
b. COM
i. For Commercial, divide the Impervious Area by one (1) ERU to
calculate the ERU for the account (round up to nearest whole
number). Multiply the rounded up ERUs calculated by the residential
rate to determine monthly rate.
c. EXEMPT
i. Verify no charge is being applied
4. Notify GIS
a. Update SWU classification
b. Update impervious area
c. Update billed account (obtain correct account in coordination with Utility
Billing)
5. Notify Utility Billing
a. Update billed account (obtain correct account in coordination with Utility
Billing)
b. Update SWU Category
6. Obtain from Utility Billing
a. Fee refund amount
b. Fee refund period
c. Fee refund account(s)
d. Fee refund recipient(s)
7. Notify customer
a. Complete form letter with findings and details
8. Billing
a. Verify fee refund applied
Appeals Process – Public Works Director
After the completion of the internal administrative review process, the Customer
may appeal the administrative determination to the Public Works Director. The
appeal must be filed within 14 days of the notification of the decision being
appealed. Once requested, an appeal must be held within 21 days of the request.
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The Customer may request a hearing as part of the appeal, or a “paper-based”
appeal session may be held. The scope of the Public Works Directors authority
includes reviewing and considering requests regarding:
• Charge to a property that should not receive a charge;
• Incorrect charge applied to a property
The following requirements will be considered and applied in determining the
appeal:
1. The Public Works Director must render a decision on the appeal
within 48 hours of the hearing or “paper-based” appeal session.
2. Applicable City records will be compared to information provided by
the Customer.
3. Issues appealable include:
a. Charge on a property that is thought to be undeveloped or
ineligible for SWU charges, consistent with City ordinance.
b. Determination of billable impervious area as applicable.
Utility Account Adjustments (non-billing rate changes)
The City of Lawton City will have the authority to make corrections to
customer account information and billing information, as necessary, to
ensure that the information is correct and accurate. A record will be made
to document all adjustments or changes to an account to correct errors.
The City of Lawton will ensure that the ability to pull reports from the
system is in place at all times. The City’s Customer Service office will pull
monthly reports of adjustments made to stormwater accounts.
A copy of all records on adjustments will be maintained and available for
internal audit purposes.
The Assistant City Works Director will have the authority to make
administrative determinations to direct City Utility Billing to adjust a
stormwater utility bill after review of available information. City Utility
Billing will make and keep a record of all adjustments made. Records of
any adjustments made will be kept in accordance to the City’s Records
Retention Schedule.
A copy of all records on adjustments will be maintained and available for
internal audit purposes.
Required Documents:
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The Utility Billing supervisor will sign off on all adjustments or corrections. Utility
Billing will maintain records and documentation for all corrections, adjustments
and changes made to customer billing information. Such reports may be system
generated or generated by hand, as necessary.
The Deputy Public Works Director will maintain a record of all administrative
reviews and determinations made. The record may be system generated or
generated by hand. The City Engineer will sign off on all determinations made.
The Deputy Public Works Director will direct the creation of minutes of any
appeals hearings and decisions made. The minutes will be approved by the Public
Works Director and kept in accordance with the City’s Records Retention
Schedule.
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City of Lawton
Stormwater Management
Administrative Policies and Procedures
Effective Date:
Subject: Stormwater Utility Fee Customer Inquiries
Applies to: City of Lawton Public Works Director, GIS Department, Deputy Public
Works Director
Policy: Provide procedures for the City to comply with its Code of Ordinances, and
to establish the response to Customer Inquiries by various departments.
Authority: City of Midwest City Ordinances, Ord. No. 2005-92
Roles and Responsibility:
Public Works Director
- Has overall responsibility for implementation of the Stormwater
Utility Fee in accordance with the City of Lawton ordinance.
Deputy Public Works Director
- Reviews and coordinates updates to the Customer Service Discussion
Points and FAQ’s document used to implement this procedure.
- Ensures that the Customer Service Department is supplied with the
latest version of the Customer Service Discussion Points and FAQ’s
document.
- Serves as primary contact for customer questions regarding the
stormwater utility fee that are not listed in the Customer Service
Discussion Points and FAQ’s document.
City Customer Service Management
- Reviews and checks for appropriateness the Customer Service
Discussion Points and FAQ’s document used to implement this
procedure.
- Ensures that the Customer Service Department has the latest version
of the Customer Service Discussion Points and FAQ’s document.
- Ensures that Customer Service Representatives have been trained on
this procedure and on the Customer Service Discussion Points and
FAQ’s document.
- Ensure that Customer Service Representatives have the opportunity
to ask questions and receive answers to strengthen their
understanding of the Stormwater Utility Fee.
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City Customer Service Representatives, Receptionist, Public Information
Office
- Review the Customer Service Discussion Points and FAQ’s document
used to implement this procedure.
- Receive training on this procedure and on the Customer Service
Discussion Points and FAQ’s document.
- Ask questions and receive answers to strengthen their understanding
of the Stormwater Utility Fee.
- Answer inquiries as stated below in the Procedure.
- Document interactions as directed.
Procedure:
1. When a call is received concerning the Stormwater Utility Fee, listen carefully to
the Customer’s question.
2. Look for the question/answer on the Customer Service Discussion Points and
FAQ’s
3. If the answer exists, provide that information to the Customer.
4. If the answer to a Stormwater Utility Fee question is not on the Customer Service
Discussion Points or FAQ’s, then forward the caller to the Public Works Director
at: michael.watrous@lawtonok.gov
5. Document the interaction with the Customer on the provided Stormwater Utility
Fee Inquiry tally sheet.
Documentation:
A tracking document will be used to document the questions received. Record time/date
and nature of the question, and whether call forwarded to the Assistant Public Works
Director or not.
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City of Lawton
Stormwater Management
Administrative Policies and Procedures
Effective Date:
Subject: Stormwater Utility Fee Development and Re-development
Applies to: City of Lawton Public Works Director, GIS Department, Deputy Public
Works Director
Policy: Provide procedures for the City to comply with its Code of Ordinances, and
to establish the audit process for the Stormwater Utility Fee accounts.
Authority: City of Lawton Ordinances, Ord. No. 2005-92
Roles and Responsibility:
Public Works Director
- Has overall responsibility for implementation of the Stormwater
Utility Fee in accordance with the City of Lawton Code of Ordinances.
Deputy Public Works Director
- Ensures new or modified SWU accounts are added in a timely
manner.
- Serves as primary contact for internal questions or concerns
regarding the Stormwater Utility Fee program.
City Community Development Department
- Receive applications for development/re-development
- Review applications
- Resolve differences between new GIS data and site plan submittal
- Once application approved, notify GIS and Utility Billing via the
tracking system
City Utility Billing
- Create billing accounts as needed for new developments or re-
developments.
- Ensure SWU fee bills are timely sent once Certificate of Occupancy,
Temporary Certificate of Occupancy, or Final Inspection as applicable
is completed.
- Use the Change Process (contained in the Administrative Review
workflow) to make corrections to existing accounts.
GIS Department
- Create new GIS account information for development/re-
development, including:
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o Parcel address
o Parcel boundary
o Impervious area (sq. ft.)
o SW Parcel ID
- Review the documentation and ensure complete and accurate.
Procedure:
6. When an application for development/re-development has been submitted,
Community Development Department will perform the initial review and enter
into the development tracking system. The tracking system will notify Billing and
GIS that a new application has been entered.
7. When notice that an application for development/re-development has been
submitted, GIS Department will complete the following steps:
o Network folder to verify and update (City Parcel and Impervious Area
layers):
▪ Parcel address
▪ Parcel boundary
▪ Impervious Area (sq. ft.)
o Assign:
▪ SW Parcel_ID
▪ Utility Billing Account ID
▪ SWU Classification
o New GIS Parcel and IA information sent to database
▪ Parcel address
▪ SW Parcel_ID
▪ Utility Billing Account ID
▪ SWU Classification
8. Community Development Department will review new GIS information against
site plan submittal and resolve differences with applicant.
9. Once differences resolved, and application approved, Community Development
Department will send information to GIS and to Billing.
10. GIS will update City Parcel layer:
o MCAD Parcel Address
o MCAD Number
o SW Parcel_ID
o SWU Classification
11. Billing will add utility billing record for the development.
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12. Billing will create notification of utility billing updates with Location ID into the
tracking system.
13. GIS will update City Parcel and SWU Area layer:
o MCAD Parcel Address
o MCAD Number
o SW Parcel_ID
o SWU Classification
o Utility Billing Account ID
14. GIS will push out updated City Parcel and SWU Area layers to GIS web mapping
applications for internal and external clients.
15. When a Certificate of Occupancy (or equivalent) is issued for a parcel,
Community Development Department will notify Billing through the
development tracking system, so that Billing may begin billing the account
associated with the parcel.
Documentation:
Applications for development/re-development are entered into the development
tracking system.
Documentation in the billing system will add the Stormwater Fee to existing bills or
establish a “Stormwater Only” account for the new development/re-development.
The GIS system will contain parcel data such as Location ID, Impervious Area, etc.
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Stormwater Utility Fee
Evaluation Study Update
March 18, 2025
Page 137 of 163
Stormwater/Drainage
Management Overview
Page 138 of 163
Stormwater/Drainage Management and Maintenance
Stormwater runoff enters
streams, rivers, and
collection systems without
treatment.
Impervious surfaces increase
stormwater runoff to be
managed.
Stormwater systems consist
of constructed infrastructure
(e.g., storm pipes) and
natural features (e.g., creeks)
3
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Stormwater/Drainage
Program Goals Reduce Flood
Risk
Protect
Maintain
People &
Infrastructure
Property
Stormwater/
Drainage
Program Goals
Erosion
Water Quality
Control
Capital
Improvements
4
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Lawton’s Current Stormwater/Drainage Structure
• Monthly Charge/Account: $1.25 • Monthly Charge/Account: $2.30
• Annual Revenue: $903,002 • Annual Revenue: $1,086,452
Per Annual Budget (FYE25) Per Annual Budget (FYE24)
Page 141 of 163
Stormwater Needs
December 13, 2024
Page 142 of 163
Stormwater Drainage Issues
Flooding Water
Quality
Maintenance
Erosion
7
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Stormwater/Drainage Infrastructure
8
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Stormwater/Drainage Infrastructure
9
Page 145 of 163
Stormwater/Drainage Infrastructure
10
Page 146 of 163
Construction
11
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Identified CIP Projects to Complete
Projected Cost Projected Cost
Rank Project Name Rank Project Name
(2024 $) (2024 $)
East Branch Numu Creek from Ferris to SW
1 $34,146,728 Unranked Wolf Creek north of Gore N/A
F Ave
Unranked Numu Creek from I-44 north to Lee Blvd. $8,466,355 9 Garden Village Subdivision $11,643,061
2 Numu creek from Sheridan Rd to Cache Rd $48,700,815 10 Channel on Dearborn and NE Euclid $2,453,638
3 Numu Creek Channel from 9th St to 11th St. $4,328,260 11 Greer Addition 200’ North of Gore Blvd $2,392,376
SW Jefferson from SW 24th St to Sheridan
4 $9,203,430 Unranked S 11th St. Bridge on Wolf Creek south of I-44 $2,822,646
Rd.
Unranked Santa Fe Bridge on NW 41st St $4,234,844 Unranked SW Lee Blvd. on SW 52nd St. $146,906
5 Ferris Ave to Gore Blvd $9,972,014 12 Lincoln Ave to Cherry Ave $18,322,050
Tributary A from NE Flower Mound Rd to
6 $3,550,743 13 NW 81st St. and NW Taylor Ave. $463,847
East Cache Creek
7 Prentice & Floyd $17,468,770 14 NE Bell Ave to SE Randolph on NE 51st St $679,726
Numu Creek and Tributary from Railroad St.
8 Wolf Creek north of Gore $4,170,039 15 $10,195,221
west to US 281
Total Cost = $193,361,000
Page 148 of 163
Lawton’s Current Stormwater/Drainage Structure
• Monthly Charge/account: $1.25 • Monthly charge/account: $2.30
• Annual Revenue: $903,002 • Annual Revenue: $1,086,452
Per Annual Budget (FYE25) Per Annual Budget (FYE24)
Current rate structures have combined revenue shortfall of $890,818 in FYE25
for both Stormwater Management and Drainage Maintenance
Page 149 of 163
Proposed Updates
Page 150 of 163
Combine Programs and Fees
Drainage Stormwater
Maintenance Management
Stormwater Utility Program and Fee
Page 151 of 163
Stormwater Utility Refinements
Meter-Based Impervious Area-Based
Page 152 of 163
Impervious Area Less Impervious More Impervious
Surface Surface
Impervious surfaces limit stormwater = =
the opportunity for infiltration into Less Runoff More Runoff
the soil and result in increased
stormwater runoff.
Examples
• Rooftops
• Parking lots
• Driveways
• Patios
• Walkways
Equivalent Residential Unit = ERU
3,200 square feet impervious area
Page 153 of 163
Residential and Commercial ERUs
Typical Residential Typical Small Commercial Typical Large Commercial
3,200 sq ft impervious area 28,213 sq ft impervious area 178,508 sq ft impervious area
28,213/3,200= 8.8 178,508/3,200= 55.7
1 ERU 9 ERU 56 ERU 18
.
Page 154 of 163
Proposed Rates
Page 155 of 163
Scenario 1 – Limited Cash-Funded CIP
Residential Rate: $5.25 / Month
Revenue positive through FYE29
Exempting City property reduces funding by
$80,000 per year
Funds FYE26-FY29 current and proposed
operating expenses
Commercial Rate: $5.25 / ERU / Month Cash-funds identified CIP below $1M by
Example property FYE28
9 ERUs * $5.25 = $47.25
Paygo CIP funding:
$660,000 FYE26
$80,000 FYE29
Loss of funding capacity due to inflation,
zero growth shown through FY29
Page 156 of 163
Scenario 2 – Moderate Debt-Funded CIP
Residential Rate: $11.00/ Month
Revenue positive through FYE29
Exempting City property reduces funding by
$168,000 per year
Funds FYE26-FYE29 current and proposed
operating expenses
Commercial Rate: $11.00 / ERU / Month
Example property $4.7M available annually for CIP
9 ERUs * $11.00 = $99.00
Debt-funds identified CIP list under $11M
$63M for 14 CIP projects
1/3 of identified CIP projects
$4.7M note, 20 years, 4% interest
Page 157 of 163
Comparison to Other Cities
Page 158 of 163
Comparison Residential Stormwater Utility Fees
$14
$12.22
$12 $11.00
$10.22
$10
$8
$6 $5.25 $5.55
$4 $3.55
$3.00
$2.42 $2.46
$2 $2.30
$1.25
$0
Midwest City Stillwater Edmond Lawton Lawton Enid Broken Lawton Tulsa
Current Proposed Arrow Proposed
Combined Scenario 1 Scenario 2
**No dedicated stormwater
*All benchmark cities are flat residential fees fee:
Single fee that covers both Stormwater and Drainage. Moore – partially funded through
1/8th sales tax and general fund
Fees are for Stormwater only.
Norman – partially funded
Drainage expenses are covered through the General Fund or Drainage Maintenance Fund for Lawton. through a Public Safety Sales
Fees are for Drainage only. Tax Fund as well as general fund
Page 159 of 163
Stormwater and Drainage/Streets Personnel per 10,000 Residents
7
6 6 6
5
4 4
3 3
2 2
1 1
0.4
0
Stillwater Edmond Lawton Broken Arrow Tulsa Enid Midwest City
Current
Combined
Page 160 of 163
Next Steps
Page 161 of 163
Schedule
Prepare
City Council
City Council draft
Rate meeting for Billing Go-live
work ordinance
Committee rate preparation billing
session and fee
approval
schedule
Page 162 of 163
Stormwater Utility Fee
Evaluation Study Update
Page 163 of 163