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In the final regulations USEPA took a different approach.in making estimates <br /> of the costs of compliance using both the NAFSMA information and past <br /> experience with Phase I (EPA, 1 999). EPA estimated annual costs for the <br /> municipal programs based on a fixed cost component and'a variable cost <br /> component. The fixed cost component included costs for the municipal <br /> application, record keeping, and reporting activities. On average, EPA <br /> estimated annUal costs of $1,525 per municipality. Variable costs include the <br /> costs associated with annual operations for the six minimum measures and <br /> are calculated at a rate of $8.93 annually per household (assuming 2.62 <br /> persons per household). Thus the cost estimating equation is: <br /> Annual cost = $1,525 + population/2.62*$8.93 <br /> Finally, rule of thumb estimates based on the author's experience working in <br /> over t00 communities indicate that comprehensive stormwater programs <br /> that include advanced stormwater quality programs cost between $7.00 and <br /> $20.00 per capita per year - above the EPA estimates. The quality portion is <br /> normally between twenty and thirty percent of the total average program <br /> cost, <br /> Estimating Costs from Anticipated Programs <br />The methods used above do not provide details of the components of the <br />stormwater programs resulting in the costs, and thus are not very helpful in <br />assisting other communities in their thinking about the regulationS. An effort <br />was made to develop cost estimate ranges based on a direct, interpretation of <br />the stormwater regulations as app led to example communities at each end <br />of the spectrum, in terms of size and intensity of water quality program. This <br />has an advantage in that it deals directly with the stormWater regulatory <br />requirements and illustrates specific program components so that we can <br />control and define all details. The following sub-sections will develop two <br />hypothetical permit appli,cations for the six minimum controls. <br />· The Two Perrnittees <br />Permittee one ("Smallville") is a communil~.y of 10,000 that is adjacent to a <br />larger city that has obtained a Phase I permit or that can assist Smallville in <br />many of its permit responsibilities. It is a small bedroom.community <br />interested in compliance with minimum disruption and cost. It.does not .really <br />have an engineering or planning component of its city staff, but relies on a <br />city administrator and hired consultants. <br />Permittee two ("Midtown") is a larger and more self-contained community <br />with a population of 50,000 located within an urbanizing county whose total <br />population makes it a designated "urbanized area." It is aggressively <br />annexing growth areas, and has a thriving economy. It has a City <br />Engineer/Public Works director, road maintenance staff, and other municipal <br />capabilities and resources. It also has a growing stormwater quantity <br />program and wishes to bring quality together with quantity in a <br />comprehensive and integrated approach. It wants to take advantage of its <br />GIS database and capability. <br /> <br />33 <br /> <br /> <br />