Capitol Park IV Condo. Ass'n, Inc. v. District of Columbia Water and Sewer Authority

CourtDistrict of Columbia Court of Appeals
DecidedSeptember 18, 2025
Docket24-CV-0504
StatusPublished

This text of Capitol Park IV Condo. Ass'n, Inc. v. District of Columbia Water and Sewer Authority (Capitol Park IV Condo. Ass'n, Inc. v. District of Columbia Water and Sewer Authority) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Capitol Park IV Condo. Ass'n, Inc. v. District of Columbia Water and Sewer Authority, (D.C. 2025).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 24-CV-0504

CAPITOL PARK IV CONDOMINIUM ASSOCIATION, INC., APPELLANT,

V.

DISTRICT OF COLUMBIA WATER AND SEWER AUTHORITY, APPELLEE.

Appeal from the Superior Court of the District of Columbia (2021-CA-000878-B)

(Hon. Danya A. Dayson, Trial Judge)

(Argued May 29, 2025 Decided September 18, 2025)

Brian R. Fellner for appellant.

Emil Hirsch for appellee.

Before BECKWITH, EASTERLY, and MCLEESE, Associate Judges.

MCLEESE, Associate Judge: Appellant Capitol Park IV Condominium

Association, Inc. (Capitol Park) sued appellee the District of Columbia Water and

Sewer Authority (D.C. Water), challenging the way in which D.C. Water calculates

a portion of Capitol Park’s water bill. The trial court granted summary judgment to 2

D.C. Water. We affirm in part, vacate in part, and remand the case for further

proceedings.

I. Factual and Procedural Background

A. Statutory Background

D.C. Water is required by statute “to plan, design, construct, operate,

maintain, regulate, finance, repair, modernize, and improve water distribution and

sewage collection, treatment, and disposal systems and services, and to encourage

conservation.” D.C. Code § 34-2202.02(c). D.C. Water has the authority “[t]o

make, adopt, and alter . . . regulations for the administration and regulation of its

business and affairs” and “[t]o establish, adjust, levy, collect, and abate charges for

services, facilities, or commodities furnished or supplied by it.” Id. § 34-2202.03(3),

(11).

In 2005, a consent decree required D.C. Water to develop a long-term plan to

reduce stormwater overflow into the Anacostia River. See Report on Bill No.

17-0935 before the Committee on Public Works and the Environment, Council of

the District of Columbia at 2-3 (Nov. 21, 2008). To cover the costs of implementing

the plan, the D.C. Council authorized D.C. Water “to determine sanitary sewer

service charges to include a charge for the amount of impervious surface area on [a] 3

customer’s property.” Id. at 3; see also D.C. Code § 34-2202.16(c-1)(1)(A) (“[D.C.

Water] shall assess an impervious area charge on any property in the District . . . .”);

CRIAC Clarification Temporary Amendment Act of 2024, D.C. Law 25-285, § 3,

71 D.C. Reg. 14108 (2024) (temporarily adding Subsection (c-1)(1) to Section

34-2202.16). An impervious surface “either prevents or retards the entry of water

into the ground as occurring under natural conditions, or [] causes water to run off

the surface in greater quantities or at an increased rate of flow, relative to the flow

present under natural conditions.” D.C. Code § 34-2202.16(c-1)(1)(A). “[T]he term

‘surface’ includes rooftops, footprints of patios, driveways, private streets, other

paved areas, athletic courts and swimming pools, and any path or walkway that is

covered by impervious material.” Id. § 34-2202.16(c-1)(1)(B).

The impervious-surface charge is referred to as the Clean Rivers Impervious

Area Charge (CRIAC). The CRIAC must be assessed “based on a billing

methodology that takes into account the amount of impervious surface on a

property.” D.C. Code § 34-2202.16(c-1)(1)(A).

D.C. Water assesses the CRIAC based on the Equivalent Residential Unit

(ERU) of each property, which “is defined as [1,000] square feet . . . of impervious

surface area, taking account of a statistical median of residential properties.” 21

D.C.M.R. § 4101.4. D.C. Water has divided its customers into three categories to 4

calculate each customer’s ERU: residential, multi-family, and nonresidential. Id.

§ 4104.1. A residential customer is defined as

a customer whose premises is a single-family dwelling unit used for domestic purposes, whether as a row, detached or semi-detached structure, or as a single dwelling unit within an apartment building, or as a single dwelling unit within a condominium, or as a single dwelling unit within a cooperative housing association, where each unit is served by a separate service line and is individually metered and used for domestic purposes; or a multi-family structure or development of less than four (4) single-family, apartment, condominium, or cooperative housing association dwelling units where all the units are used for domestic purposes and served by a single service line that is master metered; excluding a premises operated as a nursing home, dormitory or transient housing business, including, but not limited to a bed and breakfast, hotel, motel, inn, boarding house or rooming house.

Id. § 4104.1(a) (emphasis added). A multi-family customer is defined as

a customer whose premises is a multi-family structure or development (such as an apartment, condominium, or cooperative housing association) used for domestic purposes, with four or more single-family, apartment, condominium, or cooperative housing association residential dwelling units served by the same service line that is master metered; excluding a premises operated as a nursing home, dormitory or transient housing business, including, but not limited to a bed and breakfast, hotel, motel, inn, boarding house or rooming house.

Id. § 4104.1(b) (emphasis added). Nonresidential customers are all other customers

that do not fall within the residential or multi-family categories. Id. § 4104.1(c). 5

Residential customers are assessed a CRIAC based on a system that divides

customers into six tiers based on the square footage of the impervious area on the

property at issue. 21 D.C.M.R. § 4101.5. Each tier is assigned an ERU, which is

then used to calculate the amount of the CRIAC. Id. That ERU does not precisely

correspond to the square footage of the impervious area. Id. For example, a

residential customer with 1,800 square feet of impervious area would be placed in

Tier 2 and would be assigned an ERU of 1.0, even though an ERU is defined as

1,000 square feet of impervious area. Id.; id. § 4104.1. In contrast, the ERUs for

multi-family and nonresidential customers are “based upon the total amount of

impervious surface area on each lot.” Id. § 4101.6. There is no tier system for

multi-family and nonresidential customers.

B. Factual Background

The following facts appear to be undisputed, except as indicated. Capitol Park

is an association that owns and operates a condominium complex located in

Southwest D.C. The complex spans over fifty acres and includes over 200

individually owned townhomes that are separated into blocks of four to five units

and surrounded by courtyards, playgrounds, and parking lots.

Although each townhome in the complex is owned separately, water comes

into the complex through several service lines that each have their own meter. D.C. 6

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Capitol Park IV Condo. Ass'n, Inc. v. District of Columbia Water and Sewer Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/capitol-park-iv-condo-assn-inc-v-district-of-columbia-water-and-sewer-dc-2025.