Agenda - 03-17-2009 - 7a - Laserfiche WebLink

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23 only listed for a certain size of BMP as well. It is not calculated/determined whether an oversized BMP will perform better for these development cases that need so much more nutrient removal. 9. In the section regarding new development (pg. 45}, it is noted that credits can easily be generated for overtreating phosphorus, but that these credits could not be used to cover nitrogen reduction needs. However, for existing development (pg. 55) it is asserted that local governments would be able to trade excess phosphorus reduction credits in order to meet nitrogen reduction needs, contradicting the methods used for calculating costs for new development. That credit value is used towards reducing the estimated costs for existing development retrofits. By their calculation this comes to $5.4 million per year (pg. 66}. 10. In the section regarding existing development, the calculation methodology assumes no costs until the fifth year (pg. xxi and 69). ,However, local governments will need to start feasibility studies immediately upon Rule adoption, and will need to go through the lengthy process of wrrting and adopting new ordinances. The cost of conducting feasibility studies is completely absent Calculations also assume that DWQ will be the entity developing regulations, monitoring and recordkeeping, and inspection and enforcement, in addition to installation, operation, and maintenance of BMPs, when in fact these responsibilities are also the responsibility of the local governments because they must keep track of these issues far their annual reports (pg. 70}. In any case, DWQ calculates these costs to be zero, when they most certainly will not be. 11. For calculating existing development retrofit costs for DOT, DWQ used an areal loading value supplied by DOT, of 3.17 Ib N/ac/yr (pg. 129). No other entities were allowed to estimate their nutrient contribution or loads in this way. This very likely significantly underestimates loads generated ftom DOT roads, as the supplied [oading rate is just slightly less than that used for urban parklandlopen space (3.57 Ib Nlaclyr) (calculated to have 0% imperviousness far the TetraTech model) and less than all residential values (sewered, ranging from 9.37 to 15.03 Ib N/ac/yr) except for very low density (sewered only, more than 2 acres per dwelling unit). 12. The °co-mingled drainage treatment' scenario for DOT refers to the treatment of runoff from both DOT and non-DOT land in order to be most efficient in runoff treatment. It proposes that DOT may sell treatment credits at hiaher rates than it costs to DOT to local jurisdictions for treating their runoff (pg. 130). This is a significantly lower estimate of costs for DOT ($71 million) compared to the estimate for putting a BMP on every outfall on all of their existing roads in.the watershed {$595 million) (pg. 129). This suggests that DOT may transfer much of the BMP costs to local governments, but this cost to governments is not included. DOTs lowest cost alternative ($58 million) was to use only EEP offsets. There is concern whether there are a sufficient number of sites in the Upper New Hope Arm that meet the EEP project criteria to offset all the miles of DOT roads in the UNHA. 13. Costs for regulation of new development are rolled into those for riparian buffer protection, including estimates for plan review, permitting, variance process, etc. Cost estimates for these are all rolled into one value including inspection and enforcement, permitting, plan review, program development (pg. 94). Some regulatory costs are presented, all based on the assumption that NPDES Phase 2 would require riparian buffer protection anyway (pg. 78) (a dubious assumption), but they are Likely sign~cantly underestimated. In our experience, inspection and enforcement will likely be extensive as many property owners Page 8 of 9