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Measurable goals have also not been provided in this handout. But'for each <br />BMP measure or program it will be necessary to develop some measurable <br />standard by which to judge success. The standard may be based on internal <br />activities where it cannot easily be based on external results. For example, <br />sending out brochures three times per year can-be measured. But, the" <br />effectiveness of those brochures can only be measured thr.0ugh phone <br />surveys of public knowledge before and after the brochure was sent, or <br />based on statistics on increased public participation .in whatever program.the <br />brochure was about. Neither measure is easy and reliable. And, should a <br />certain percent "effectiveness increase" be stated as the measurable goal,.if <br />it is not achieved the city would, technically, be'out of compliance.-Better to <br />make the goal controllable, especially in the first permit cycles, when little is <br />known on the effectiveness of certain (especially non,structural) BMP <br />measures. <br />In no case have the costs of structural BMPs been estimated or included. <br />Cost estimates are available in several references including the Center for <br />Watershed Protection (1 997) and Northern Virginia Planning District <br />Commission (1 994). The economic benefits o'f structural BMPs are discussed <br />in EPA (1 995). <br />Monitoring costs are developed for Midtown based on both receiving stream <br />monitoring and some pilot BMP program monitoring; they are non-existent <br />for Smallville. EPA estimates that about 50% of permittees may incur <br />monitoring costs in subsequent permit cycles. It is also assumed that there <br />are no TMDL or other types of watershed assessment actions going-on in the <br />watershed which may radically modify the permit conditions, and that there <br />are no regional or state-wide programs which could simply be. adopted by <br />reference for portions of the NPDES minimum, requirements. <br /> Table 3. Summary Results <br /> -, .',iI Annua! Pe.r-~(~a.pita. cos.t,,- $ <br /> <br /> First 5-year Permit Period <br /> <br /> 1 - Public Ed. 0.39 1.24 <br /> <br />2 - Public Inv. <br />'3 - Illicit (;onnections <br />4- Construction · <br />5 - Post Const. <br />6 - Hou~sekeeping <br />Totals <br /> <br />0.21 <br />0.24 <br />0.20 <br /> <br />1-.33 <br /> <br />0.62 <br />1.77 <br />0.9.6 <br /> <br />0.59 <br />10.96 <br /> <br />Subsequent 5,year'Permit Periods <br /> <br />38 -205- <br /> <br /> <br />