Agenda - 05-24-2007-1 - Laserfiche WebLink

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~~ that subwatershed, reduce the probability of achieving the nutrient reduction targets for that subwatershed. 7. Division of Water Quality Rule Implementation -The fiscal analysis frequently assumes that the cost of implementation for the DWQ would be $0, because "tasks would be integrated into existing workloads" or "the Division would rely on existing resources to implement the rule" (e.g., FA Chapter 4, pp.45-46; FA Chapter 5, pp.69-70; and FA Chapter 6, pp.89-90). To my knowledge, the DWQ does not currently have idle staff. Implementing this rule will either require increasing staff and resources, redirection of staff and resources currently directed to other programs, or a failure to properly implement the rule. In any case, there is a cost. 8. Cost Calculations in General -The fiscal analysis calculates total costs for implementing rules .0264, .0265, .0266, .0267, .0270, and .0271 for the years 2009-2013. The fiscal analysis also calculates the "full cost" of implementing the stormwater rule for existing development (.0266) and the stormwater rule for state and federal entities (.0271), defining the full cost as a 30-year period. The fiscal analysis does not include an inflation rate in its calculations. The fiscal analysis also does not use a net present value approach, which could be particularly useful for analyzing the costs of long-term programs. In summary, the proposed rule for agriculture and the provisions for offset payments to the NC Ecosystem Enhancement Program seem to reduce the probability of achieving the nutrient reduction targets for Jordan Lake. The fiscal analysis seems to provide reasonable cost estimates for most of the rules, but may underestimate the cost of the stormwater management rule for existing development; I doubt that the fiscal analysis over estimates the cost.'We will not have a better idea of total cost until local governments have conducted feasibility studies and developed implementation plans. The proposed rules will certainly be costly to implement and there are elements within the rules that seem contrary to achieving the objectives. Should the Environmental Management Commission and the NC General Assembly choose to implement these rules, the state must provide financial assistance to local governments. Local governments throughout the watershed will bear significant costs in implementing these rules, yet most of the local governments and their citizens do not benefit directly from Jordan Lake. This disparity between who pays and who benefits provides a clear role for state government. Furthermore, the state and local governments will not be able to rely on funding from existing grant programs and trust funds, all of which have state wide demands and all of which are already over-extended. The NC General Assembly will have to appropriate funds from the general budget specifically for implementing the Jordan Lake nutrient rules, or dedicate a stream of revenue specifically for that purpose. If we accept the fiscal analysis costs as a starting point, local governments face a cost of implementation at a minimum of $611,598,000.1 The General Assembly should commit to building a fund for Jordan Lake nutrient management and contribute at least $40 Million per year to the fund over the first ten years of implementing the Jordan Lake nutrient rules. l Total local government implementation cost = $48,000 for new development + $403,000,000 for existing development + $1,550,000 for riparian buffer protection + $207,000,000 for wastewater (FA Executive Summary, pp.viii-ix) 4