DEP Environmental Protection Invoices, 1999-2001

NYC 9/11 Public Portal Document

THE COMMUNITY PRESERVATION CORPORATION

5 West 37th Street New York, NewYork 10018 Tel (212) 869-5300 Fax (212) 719-9374

December 18, 2000

Letters to the Editor The New York Times 229 West 43rd Street New York, NY 10036

To The Editor:

In your December 15 article on flat rate water billing, the City is not given due credit for developing a mechanism that reasonably balances water revenue needs and the economic health of affordable housing. In fact, The Community Preservation Corporation, one of the State's major affordable housing lenders, along with over 100 banks, non-profits, and multifamily owners, urged the City to pass such a policy. The flat rate option resulted from several years of discussion on ways to mitigate the burden of escalating water/sewer costs on the affordable housing sector.

Without this change, water/sewer bills in many low- and moderate income apartment buildings would immediately double or triple, or worse. This is because of a key fact your article misunderstood: consumption by each tenant cannot be metered. An apartment building has one meter in its cellar, and the owner pays a lump sum bill for the building's total consumption. For tenants, the "pay for what you use" price signal is broken.

Numerous studies since the late-1980's have proven higher-than-average consumption in lower-income buildings. Larger family size and higher daytime occupancy are among the causes. By contrast, luxury buildings have actually seen bills decline under metering.

Billing in proportion to consumption would therefore disproportionately allocate water system costs from high-income buildings to low-income ones. This is not only inequitable, but would starve long-term mortgage investment in necessary rehabilitation of aging buildings.

truly yours,

Vice President

NYC-WTC 000137759