Agenda - 03-26-2009 - 4a2 - Laserfiche WebLink

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4a-15 only listed far a certain size of B[~P as well. It [s not calculatedldetermined whether an oversized BMP will perform better far these development cases that need so much mare nutrient removal. 9. In the section regarding new development Mpg. 4}, it is noted that credits can easily be generated far averkreating phosphorus, but that these credits could not be used to cover nitrogen reduction needs. However, for existing development Mpg. ~~} it is asserted that local governments would be able to trade excess phosphorus reduction credits in order to meet nitrogen reduction needs, cantradictir~g the methods used for calculating casts 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 peryear Mpg, 6}. ~ OF In the section regarding existing developr~ent, the calculation methodology assumes no costs until the fifth year Mpg. xxi and ~~}. ,However, local governments will need to s#art feasibility studies immediately upon l~u[e adoption, and will need to go through the lengthy process of writing and adapting nevu ordinances. The cost of conducting feasibility studies is completely absent. alcu~af~~n also assume That Df(~ will be the entity developing regulations, monitoring and recordkeeping, and inspection and enforcement, in addition to installation, operation, and maintenance of BI~P, when in fact these responsibilities are also the responsibility of the local gavernn~ents because they must keep track of these issues for their annual reports Mpg, ~~}. In any case, DC~ calculates these casts to be zero, when they mast cerkain[y will not be, 1 ~ . For calculating existing development retrofit casts for DST, Dv1lG~ used an area[ landing value supplied by DOT, of ~. ~ ~ l~ i~4~ac~yr Mpg. ~ ~~}. No other entities were allowed to estimate their nutrient contribution or loads in this way. This very likely significantly underestimates loads generated from DOT roads, as the supplied loading rate is~ust slightly less than that used for urban parklandlopen space ~.~~ Ib N~aclyr} calculated to have 4°l~ imperviousness forthe TetraTech model} and less than all residential values ~sewered, ranging frorr~ g.31 to ~~.g~ Ib Nlaclyr} except far very love density ~ewered only, more than 2 acres per dwelling unit}. ~~. The "ca-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. ]t proposes that DOT may sell treatment credits at hi her rates than it costs to DST to loco[ jurisdictions for treating their runoff {pg, 1 ~~}, This is a significantly laver estimate of costs for DOT ~~~~ million} compared to the estivate for putting a AMP on every autfall an all of their existing roads in.the watershed {~9~ million} {pg. ~9}. This suggests that DOT may transfer much of the BI~P casts to local governments, but this cast to governments is not included. DOT's lowest cost alternative ~8 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 FFP project criteria to offset al[ the miles of DST roads in the UNHA. ~ ~. fasts for regulation of new development are rolled into thane for riparian buffer protection, including estimates for plan review, permitting, variance process, etc. host estimates for these are all rolled into one value including inspection and enforcement, permitting, plan review, program development Mpg. 9~}. Some regulatory costs are presented, all based an the assumption that NPDE Phase ~ vuauld require riparian buffr~pratectian anyway ~pgF 7~} ~a dubious assurr~ption}, but they are likely significantly underestimated. [n our experience, inspection and enfarcerr~ent will likely be extensive as many properky owners Page 8 of 9