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NPDES Phase 11 Cost Estimates <br /> Andrew J. Reese, P.E. <br /> Ogden Environmental and Energy Services, Inc. <br /> 3800 Fzell Rd., Suite 1 00, Nashville, TN-, 37211 <br /> Introduction <br /> The United States Environmental Protection Agency (EPA) has published .final <br /> rules expanding the existing stormwater NPDES permkting program to <br /> smaller cities and other urban areas throughout the United States. Due both <br /> to external pressures and directives from the current and past. <br /> administrations, EPA is conscious of attempting to make the current <br /> stormwater NPDES program "cost-effective." For example' <br /> "EPA believes this rule will cost significantly less than the existing 1995 rule that is <br /> currently in place, and will result in significant m'0r~e'tized' financial, recreational' and <br /> health benefits, as well as benefits that EPA has been unable to monetize, including <br /> reduced scouring and erosion of streambeds, improved aesthetic quality of waters, <br /> reduced eutrophication of. aquatic systems, benefit to wildlife and endangered and <br /> threatened species, tourism benefits, biodiversity benefits.and reduced siting costs of <br /> reservoirs." <br />"... the Agency recognizes the continuing imperative to assure that envlronmenta <br />regulations accomplish statutory obiectives in the least burdensome and most' cost-. <br />effective fashion. As explained further in.this preamble,, the form and substance of <br />NPDES permits to address the sources designated in today's-proposal would provide <br />greater flexibility for the newly covered sources' than the existing "standard" NPDES <br />permit." <br />While the "benefit" side of the proposed regulations, exists in the realm of <br />gross estimates, the "cost" side is also' filled with unknowns. What will .the <br />mandated and negotiated stormwater program cost a local community? Are <br />there ways to reduce costs? What should a local community be doing now <br />to prepare for this regulatory program? This paper seeks to address these' <br />related questions. <br />The final regulations, were published on December 8'h:,. and. the changes from. <br />the draft.regulations are only minor. But it is still not possible to say'wha.t <br />the regulations will cost everyone in toro. This is so because:' <br /> · there is great flexibility' inherent in the regulations, to create-a . <br /> stormwater quality program tailored to meet an individual community's <br /> needs and situation; ' <br /> · each permit writer has preferences and. "hot. buttons" that will color <br /> what' any particula'r.program will look. like; and ' <br /> · each community setting s different in terms-of Climate, topography, <br /> pollutants of'0oncern, and current condition of local waters. <br />Basic Approach to Permitting <br />Under proposed § 123.35(g)~ an NPDES permitting authori.t¥ issues a general <br />permit to authorize stormwater discharges from regulated small municipal' <br />separate storm sewer' systems. The NPDES permitting authority will also. <br />provide a menu of regionally appropriate and field-tested Best Management <br /> <br /> I <br /> I <br /> ! <br />.I <br />I <br /> <br /> I <br /> I <br /> <br />I <br />I <br /> <br />-196- <br /> <br />291 <br /> <br /> <br />