Economic Analysis of the Final Phase II Storm Water Rule


SEPA
United States
Environmental Protection
Agency
Office Of Water
(4204)
EPA 833-R-99-002
October 1999
             Economic Analysis Of The
             Final Phase II Storm Water Rule

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             ECONOMIC ANALYSIS
                      OF THE
    FINAL PHASE H STORM WATER RULE


                     Final Report


                     October 1999
                     Prepared for:
           U.S. Environmental Protection Agency
            Office of Wastewater Management
                   401 M Street, S.W.
                Washington, D.C.  20460
                     Prepared by:
       Science Applications International Corporation
                11251 Roger Bacon Drive
                   Reston,VA 20190
EPA Contract No. 68-C4-0034; Work Assignment No. IM-5-4(P)
          SAIC Project No. 01-0833-08-2995-XXX

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                                                                                                i'i1'
                                                DISCLAIMER
                                                  "'',            j,,  , •  >'      ,  ,|
                                       . ,         .          , •     „,   ,iii,    '    I	
                          This document was prepared with technical support from Science
                          Applications International Corporation in partial fulfillment of EPA
                          ContractNo. 68-C4-0034, Work Assignment IM-5-4(P). Themention
                          of company or product names is not to be considered an endorsement
                          by the U.S. Government or by the Environmental Protection Agency.
                          !, '      'IK     "'      .   , • '	"" ,      ' i,1,!, |  ,  ' •   IE1 Ill" '      I ft »l,'!! ''

                          In addition, this document includes a discussion of the National
                          Water Pollution Control Assessment Model (NWPCAM) developed
                          by Research Triangle Institute (RTI). EPA has incorporated findings
                          from the assessment model into Chapter 6. The NWPCAM report is
                          included in its entirety hi Appendix E.
1

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        ECONOMIC ANALYSIS
                OF THE
FINAL PHASE H STORM WATER RULE
               Final Report
               October 1999
      U.S. Environmental Protection Agency
       Office of Wastewater Management
             401 M-Street, S.W.
           Washington, D.C.  20460

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                              TABLE OF CONTENTS

EXECUTIVE SUMMARY	ES-1
       ES.l   Environmental Concerns Addressed by the Rule ,	ES-1
       ES.2   Statutory Background for the Rule	ES-1
       ES.3   Description of the Rule 	.....	ES-2
       ES.4   Baseline for the Analysis	ES-2
       ES.5   Potential Costs for Municipalities	ES-3
       ES.6   Potential Costs for Construction Operators			  ES-3
       ES.7   Potential Costs for Federal and State Program Administrators	ES—4
       ES.8   Summary of Potential Costs	ES-5
       ES.9   Pollutant Loading Reductions from Municipalities	ES—5
       ES.10  Reduced Sediment Delivery from Phase II Construction Starts	ES-6
       ES.l 1  Cost Effectiveness	ES-6
       ES.12  Anticipated Benefits of the Phase II Rule	ES-6
       ES.13  Benefits Estimation Comparison	ES-13
       ES.14  Comparison of Benefits and Costs	ES-14
       ES.15  Impact on Small Entities	ES-14
       ES.16  No Exposure	ES-15
1.0 INTRODUCTION	1-1
       1.1    Statutory Background	1-1
       1.2    Description of the Rule	1—1
       1.3    Economic Analysis of the Rule	1-2
       1.4    Structure of the Report	1-3
2.0 ENVIRONMENTAL CONCERNS ADDRESSED BY THE RULE	 2-1
       2.1    Storm Water Discharges from Urban Areas and Construction Sites	2—1
             2.1.1   Urban Area Storm Water Discharges	,	2—1
             2.1.2   Construction Site Storm Water Discharges	: 2-2
       2.2    Potential Adverse Effects of Storm Water Discharges to Humans, Aquatic
             Life, and Wildlife	2-2
             2.2.1   Human Health Impacts 	..	,	2-3
             2.2.2   Aquatic Life and Wildlife Impacts	2-5
             2.2.3   Small Stream Impacts 	„	2-9
       2.3    Summary		2-9
3.0 BASELINE FOR ESTIMATING BENEFITS AND COSTS  	3-1
       3.1    Existing Storm Water Programs	3—1
             3.1.1   Phase I Storm Water Program	3-1
             3.1.2   CZARA Program	3-1
             3.1.3   State and Local Erosion and Sediment Control Programs	3-2
       3.2    Population	,	3-2
       3.3    Phase II Construction and Land Development Activities	-. 3—4
       3.4    Water Quality	3-5
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             3.4.1  Water Impaired by Urban Wet Weather Events  	3-6
             3.4.2  Waters Impaired by Phase II Sources	3-8
       3.5    Potential Limitations Associated with the Baseline Assumptions	3-10
 4.0    POTENTIAL COSTS, POLLUTANT LOAD REDUCTIONS,
       AND COST EFFECTIVENESS ....	4-1
       4.1    Overview of Methodology	4-1
             4.1.1  Municipalities  	4—1
             4.1.2  Construction Site Runoff Controls 			4-2
             4.L3  Post-Construction Runoff Controls ...	4-3
             4.1.4  Phase I Industrial Activities	4-4
       4.2    Analyses of Potential Costs	4-4
             4.2.1  Municipal Costs	4-4
             4.2.2  Construction Costs	.	 4-8
             4.2.3  Federal Costs	"		.. 4-46
             4.2.4  State Costs	.'....	..	 .4-27
       4.3    Summary of Results	4—27
       4.4    Potential Pollutant Loading Reductions Resulting from the Phase II Rule ... 4-28
             4.4.1  Pollutant Loading Reductions from Municipalities	4-28
             4.4.2  Pollutant Loading Reductions from Phase II Construction Starts	4-29
             4.4.3  Summary 	4-31
       4.5    Cost Effectiveness	.'	,	4-32
       4.6    Sensitivity Analyses	4—32
       4.7    Conclusion	4-36
5.0 QUALITATIVE ASSESSMENT OF BENEFITS	5-1
              ii        i1;                             ; m ,n ,   i   |    •	  ,             i
       5.1    Municipal Minimum Measures	5-1
             5.1.1  Description of Measures  	5-1
             5.1.2  Anticipated Benefits from the Municipal Minimum Measures	5—4
       5.2    Construction Site Controls	5-8
             5.2.1  Model of Construction Site BMP Effectiveness	5-8
             5.2.2  Anticipated Benefits of Construction Site Controls	5—9
       5.3    Conclusions	5-12
6.0 QUANTITATIVE ASSESSMENT OF BENEFITS  	--•-•••	6-1
       6.1    Framework for Estimating Benefits	6-2
             6.1.1  Definition of Benefit Categories  	6-2
             6.1.2  How Benefits Arise from Water Quality Improvements	6-3
       6.2    National Water Quality Model Approach	6-6
             6.2.1  Potential Fresh Water Quality Improvements	6-7
             6.2.2  Potential Value of Improved Fresh Waters	6-10
             6.2.3  NWPCAM Sensitivity Analysis  	'.	6-13
      6.3    National Water Quality Assessment Approach	6-13
             6.3.1  Potential Benefits of Municipal Measures	 	6-14
             6.3.2  Potential Benefits of Avoided Water Quality Impairments	6-16
             6.3.3  Potential Value of Improved Marine Waters		6-21
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             6.3.4  Potential Benefits of Construction Site Controls	6-27
             6.3.5  Summary of Benefits	6-34
             6.3.6  Sensitivity Analysis	6-34
       6.4   Limitations and Uncertainties Associated with the Benefits Analyses	6-35
       6.5   Conclusion	6-37
 7.0 COMPARISON OF BENEFITS AND COSTS	7-1
       7.1   Total Annual Monetized Benefits	7—1
       7.2   Total Annual Monetized Costs	7—1
       7.3   Comparison of Benefits and Costs	7-2
 8.0 REVISED SMALL ENTITY ASSESSMENT  	8-1
       8.1   Revised SBREFA Analysis of Impacts on Small Entities	8-1
             8.1.1   Background	8-2
             8.1.2   Small Entities Affected by Rule  	8-3
             8.1.3   Compliance Requirements	8—4
             8.1.4   Revised Analysis of Potential Economic Impact	8-8
       8.2   Environmental Justice	 8—15
       8.3   Unfunded Mandates			8-16
 9.0 NO EXPOSURE	9-1
       9.1    Background	9-1
       9.2   No Exposure Cost Savings	9-5
             9.2.1   Number of Facilities Eligible for the No Exposure Provision   	9-6
             9.2.2   Industrial Facilities With and Without Exposure	9-8
             9.2.3   Industrial Compliance Cost Savings	9-8
             9.2.4   Total Industrial Cost Savings	9-13
       9.3    No Exposure Certification Cost	9-13
       9.4   Net Compliance Cost Savings	9-14
       9.5    State and Federal Costs 	9-14
             9.5.1   Total State Costs	9-15
             9.5.2   Total Federal Costs 	9-16
       9.6    Data Limitations	9-16
 10.0   REFERENCES	'	10-1
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                             LIST OF APPENDICES

Appendix A — Literature Related to the Potential Impacts of Storm Water Discharges
Appendix B — Data and Methods Associated with the Municipal, Construction., and Post-
              Construction, and Post-Construction Programs
Appendix C — Supplemental Benefits Calculations
Appendix D — Data Associated with the Phase II No Exposure Provision
Appendix E — The National Water Pollution control Assessment Model
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LIST OF EXHIBITS

Exhibit ES-1. Potential Annual Costs for Phase II Storm Water Regulation ES-5
Exhibit ES-2. Annual Local and Nonlocal Benefits Estimates Due to Phase II Controls .. ES-9
Exhibit ES-3. Potential Annual Benefits of the Phase II Storm Water Rule ES-13
Exhibit ES-4. Comparison of Annual Benefits to Costs for the Phase II
Storm Water Rule ES-14
Exhibit 2—1. Adverse Impacts Associated with Urban Runoff 2—4
Exhibit 2-2. Five Leading Causes of Water Quality Impairment 2—5
Exhibit 2-3. Impacts Associated with Sediment and Sediment-Related Pollutants 2-6
Exhibit 3—1. States and Territories Requiring Erosion and Sediment Controls at
Construction Sites of Less than Five Acres 3—3
Exhibit 3—2. Municipal Households Potentially Regulated Under the Phase II Rule 3—4
Exhibit 3—3. Estimated Number of Total Construction Starts and Construction Starts
Potentially Affected by the Phase II Soil Erosion Control Provision 3-5
Exhibit 3—4. Summary of Assessed Waters 3-6
Exhibit 3-5. Summary of Assessed Waters by Designated Use 3-7
Exhibit 3-6. Leading Sources of Water Quality Impairment Related to Human
Development .. 3-7
Exhibit 3-7. Major Impairment by Pollution Source '. 3-8
Exhibit 3-8. Percentages of Waters Impaired by Storm Water Sources by Designated Use . 3-9
Exhibit 3-9. Percent of Waterbody Impairment Potentially Attributable to Phase II
Sources 3-11
Exhibit 4-1. Annual Municipal Administrative Costs 4—6
Exhibit 4-2. Mean and Percentage Findings:
Estimated Annual Per Household Cost of Compliance for Phase II
Municipalities 4—7
Exhibit 4-3. Estimated National Phase II Municipal Annual Costs 4-8
Exhibit 4-4. Summary Characteristics of Municipalities Where
• Construction Start Data was Collected 4—10
Exhibit 4—5. Number of Construction Starts by Disturbed Area Size 4—11
Exhibit 4-6. BMPs Used for the Model Sites 4-12
Exhibit 4-7. Description of BMPs Used for 27 Model Construction Sites 4-13
Exhibit 4-8. Estimated Cost of BMPs for the Model Sites 4-15
Exhibit 4-9. Storm Water Pollution Prevention Plan Requirements and
Unit Cost Estimates 4-17
Exhibit 4-10. Estimated Other Administrative Phase II
Construction Costs Per Site 4-18
Exhibit 4-11. Estimated National Phase II Construction Compliance Costs by
Climatic Zones for Year 1998 4-19
Exhibit 4-12. Phase II Erosion and Sediment Control Annual Costs 4-20
Exhibit 4-13. Summary of Per-Site Average Total Costs by Acreage and by
Percent Imperviousness 4—21
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Exhibit 4-^14. Estimated Number of Construction Starts Potentially Affected by the
             Phase II Post-Construction Runoff Control Provision	4-21
Exhibit 4-15. Estimated Post-Construction Runoff Control Costs  	!.	4-22

Exhibit 4-16. Comparison of Site Development Costs Associated with Storm Water
             Management: Conventional Development vs. Conservation Development  .. 4—25
Exhibit 4-17. Estimated Range of Post-Construction Runoff Control Costs	4-25
Exhibit 4-18. Total Phase II Construction Program Costs	.		4-25
Exhibit 4-19. Estimated Federal Annual Costs	4-26
Exhibit 4-20. Estimated State Annual Costs	.	4-27
Exhibit 4-21. Potential Annual Costs for Phase n Storm Water Regulation		.. 4-28
Exhibit 4-22. Estimated Ranges of Daily TSS Reductions from EPA's Phase I and
             Phase H Storm Water Programs	................".	.....4-29
Exhibit 4—23. Estimated TSS Loading Reductions for Phase II Municipalities		4-30
Exhibit 4-24. Weighted Average Sediment Loadings and Loading Reductions (tons)
             from Phase II Construction Sites of Medium Soil Erodibility	4-31
Exhibit 4-25. National Reduction Estimates for Municipalities and
             Construction Starts (tons/year)	4—31
Exhibit 4-26a. Results of Sensitivity Analysis for Scenario One 	4-33
Exhibit 4—26b. Results of Sensitivity Analysis for Scenario Two	4—33
Exhibit 4—26c. Results of Sensitivity Analysis for Scenario Three	4—34
Exhibit 4—26d. Results of Sensitivity Analysis for Scenario Four	4—34
Exhibit 4—26e. Results of Sensitivity Analysis for Scenario Five 	4-35
Exhibit 4—26f. Results of Sensitivity Analysis for Scenario Six	4-35
Exhibit 6-1.   Potential Benefits of Water Quality Improvements	6-3
Exhibit 6-2.   The Production of Benefits from Improved Ambient Water Quality 	6-5
Exhibit6-3.   NWPCAM Water Quality Ladder	6-7
Exhibit 6-4.   NWPCAM Summary of Key Model Assumptions for the Storm Water
             Phase II Benefits Analysis	'.	6-9
Exhibit 6-5.   Summary of Miles Meeting Designated Uses Under Baseline and
             Scenario Phase II Conditions	6-10
Exhibit 6-6.   Mean Annual Household WTP Amounts for Different Levels of
             National Water Quality 	6-12
Exhibit 6-7.   Local and Nonlocal Benefits of Phase II Controls Estimated Using the
             NWPCAM	6-13
Exhibit 6-8.   Potential Annual WTP Estimates for Fresh Water Impaired by
             Phase n Municipal Sources	6-16
Exhibit 6-9.   Potential Annual Benefits of Improving Fresh Water Impaired by
             Phase n Municipal Sources to Support Their Designated Uses 	6-16
Exhibit 6-10. Mean Contaminant Concentrations in Storm Water Runoff from
             Developed and Nonurbanized Areas	  	6-17
Exhibit 6-li. Effectiveness of BMPs in Removing Contaminants from Storm Water
             Runoff	6-18
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Exhibit 6-12. Potential Annual WTP Estimates for Fresh Water Impaired by One
Year of New Development and Redevelopment Activities 6-19
Exhibit 6-13. Potential Annual Benefits of Avoiding Future Fresh Water Impairments
from New Development and Redevelopment Activities in Phase II
Urbanized Areas 6-21
Exhibit 6-14. Potential Annual Benefits of Reducing 'the Number of Beach Closures
in Phase II Communities 6-24
Exhibit 6-15. Cost of Illness Estimates for Gastrointestinal Illnesses 6-26
Exhibit 6-16. Summary of Potential Marine Health Benefits by Symptom, Exposure
Assumption, and Total Coliform Concentration at Outfall 6-27
Exhibit 6-17. Potential Annual Benefits of Avoided Health Impacts from Swimming hi
Contaminated Marine Waters in Phase II Communities 6-27
Exhibit 6-18. Potential Annual WTP for the Phase II Soil and Erosion Control Program .. 6-31
Exhibit 6-19. Assumptions Used to Derive Perimeter Shares 6-33
Exhibit 6-20. Potential Annual Benefits of the Phase II Storm Water Rule : 6-34
Exhibit 6-21. Results of Sensitivity Analysis 6-35
Exhibit 6-22. Key Limitations and Uncertainties in the Benefits Analysis 6-36
Exhibit 7-1. Comparison of Annual Benefits to Costs for the Phase II Storm Water Rule .. 7-3
Exhibit 8-1. Businesses and Municipalities Potentially Affected by the Phase II Storm
Water Regulations 8-4
Exhibit 8-2. Summary of Compliance Requirements and Estimated Costs of the Phase II
Storm Water Rule for Small Municipalities and Building Contractors 8-6
Exhibit 8-3. Revenue Test for Small Municipalities 8-9
Exhibit 8-4. Construction Start and Per-Home Compliance Costs by Site Size 8-10
Exhibit 8-5. Per-Home Compliance Costs as a Percent of Median and Mean Home
Sale Price 8-10
Exhibit 8-6. Best Management Practice Costs per Construction Site 8-11
Exhibit 8-7. Estimated Number of Multi-Family Residencies per Start by Site Size 8-12
Exhibit 8-8. Estimated Multi-Family Residential Sales and Compliance Costs by
Site Size 8-13
Exhibit 8—9. Estimated Commercial Office Space Sales and Compliance Costs by
Site Size 8-14
Exhibit 9-1. Industrial Facilities That Must Submit Applications for Storm Water
Permits (Phase I) .9-3
Exhibit 9-2. Total Facilities and Estimated Number of Regulated Industrial
Facilities hi Selected States 9-7
Exhibit 9-3. Estimated Number of Regulated Industrial Facilities
With and Without Exposure 9-9
Exhibit 9-4. Estimated Industrial Pollution Prevention Costs for All Regulated
Facilities 9-10
Exhibit 9-5. Estimated Incremental Industrial Pollution Prevention Costs for
EPCRA Facilities 9-10
Exhibit 9-6. Estimated Annual cost Savings per Facility 9-11
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 Exhibit 9-1.  Adjusted Annual Cost Savings per Facility	  	
 Exhibit 9-8.  State Costs to Implement the Industrial No Exposure Provision ..
 Exhibit 9-9.  Federal Costs to Implement the Industrial No Exposure Provision
                                             9-11
                                             9-15
                                             9-16
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EXECUTIVE SUMMARY

This document provides EPA's Economic Analysis of the Phase II Storm Water Rule, a
regulatory action which requires small municipalities and construction sites to implement best
management practices to control storm water discharges. This analysis updates the benefit-cost
analysis prepared for the proposed rule. The analysis is based on the final rule. Revisions have
been made in response to internal agency review and comments received during the public
comment period.

ES.l Environmental Concerns Addressed by the Rule

Storm water discharges have emerged as one of the leading causes of impairment of the Nation's
surface waters (US EPA, 1998a). Several studies reveal that storm water runoff from urban areas
and construction sites can include a variety of pollutants, such as sediment, bacteria, organic
nutrients, hydrocarbons, zinc, copper, cadmium, mercury, iron, nickel, oil, and grease (Barret et
al., 1996). In addition, the National Water Quality Inventory, 1996 Report to Congress, which
summarizes state §305(b) reports, provides documentation of water quality impairment resulting
from storm water discharges. The report shows that urban runoff/storm sewer discharges affect
13% of impaired rivers, 21% of impaired lakes, and 45% of impaired estuaries. Impaired waters
are those waters not meeting water quality standards or designated beneficial uses such as
drinking water supply, primary contact recreation, and aquatic life support. The report also
documents impairment to rivers, lakes, and wetlands resulting from construction (e.g., land
development, road construction).

Many studies provide documentation of the impacts of storm water discharges on humans,
aquatic life, and other wildlife, including impacts to small streams. The potential impacts of
these discharges include increased bacterial contamination, increased turbidity, increased toxic
sediments, decreased dissolved oxygen concentrations, and alterations in stream channel
morphology and habitat. In turn, these in-stream conditions can have a considerable impact on
human health and the abundance and diversity of aquatic species. The level of impact is site-
specific and depends on site imperviousness, the type of receiving waters, acreage of land
disturbance, topography, soil type, and resource sensitivity. The nature of the impact also varies
temporally throughout the land development process, with significant differences observed
between the site clearing phase, construction phase and post development conditions.

ES.2 Statutory Background for the Rule

In the 1987 amendments to the Clean Water Act (CWA), Congress established a tiered approach
for addressing certain industrial, municipal, and other storm water discharges. These
amendments provided for a phased program to address the most significant contributors first
(Phase I), and identify an appropriate second tier of sources at a later date. EPA published Phase
I application requirements for categories of storm water discharges recognized as the most
damaging to the environment in 1990 (55 Federal Register (FR) 47990, November 16,1990).
Generally, Phase I sources include storm water discharges associated with certain industrial
activities, medium and large municipal separate storm sewer systems (MS4s), and large
construction sites (greater than five acres).
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ES-1
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Executive Summary
in"
Phase II storm water sources were fo be identified based on EPA's findings as presented in its
Report to Congress (US EPA, 1995a). Based on this report, EPA published a direct final Phase
II storm water rule in 1995 (60 FR 40229, August 7, 1995). EPA published this rule in part to
protect Phase n dischargers from CWA citizen suit liability. However, it was recognized that the
Phase n regulatory program would undergo further development. The 1999 final rale, when
promulgated, will replace the August 1995 direct final rule.
•'• • ' '•'•;. ,,. : ./:. . i; " ' ' v ,!"•'• • '• • • ': < i ;,', ; ,' ;, > I,. ' •• •, S;f ... .'•(' " j ::
ES3 Description of the Rule

The Phase II rule will require storm water discharges from small MS4s and small construction
sites to be covered under a National Pollutant Discharge Elimination System (NPDES) permit.
Small MS4s include incorporated places, counties, and other places under the jurisdiction of a
governmental entity (rncluding Tribal and Territorial governments) that are located in an
urbanized area but are not included in Phase I. Phase I addresses larger and medium-sized MS4s
serving populations of 100,000 and more. Phase II generally pertains to systems serving less
than 100,000 people. Indian reservations located within urbanized areas and with a population of
less than 1,000 persons are excluded. And, the permitting authority can waive MS4s that serve a
population of less than 1,000 under certain conditions. Owners or operators of small MS4s
would be required to develop and implement a storm water management program designed to
reduce the discharge of pollutants to the maximum extent practicable and protect water quality.
The storm water management program would need to include a requirement for post-construction
runoff controls from new development and re-development.

Phase II small construction sites that will be designated by the rule are those that disturb between
one and five acres of land. In addition, sites disturbing less than one acre would be subject to
regulation if they are part of a larger common plan of development or sale. However, the
NPDES permitting authority could waive permitting requirements under certain conditions.
Small construction site owners or operators would be required to plan and implement appropriate
erosion and sediment control best management practices (BMPs) to control storm water
discharges.

ES.4 Baseline for the Analysis

Analysis of the incremental benefits and costs of the Phase II rale requires that EPA establish a
baseline for similar storm water programs, population, construction starts, and water quality.
EPA defined the universe of potentially affected municipalities as those located in urbanized
areas and construction sites by excluding corresponding construction sites in states that have
instituted erosion and sediment control programs in response to CZARA or other state ordinance.
Population estimates are based on 1998 US Census Bureau estimates of population, households,
urban population, and sewered population. To develop estimates of Phase II construction and
land development activities, EPA used construction start data gathered in 14 municipalities
across the country and 1994 US Census Bureau estimates of the number of building permits
issued nationwide.

Finally, EPA characterized existing water quality and the relative impact of Phase II sources on
water quality using the National Water Quality Inventory Report to Congress (US EPA, 1998J,
ES-2
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October 1999

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Executive Summary
also referred to as "305(b) data". However, the 305(b) data characterize waters based on
impairment of surveyed waterbodies. Therefore, to establish a baseline representing all waters
impaired by urban runoff/storm sewers, construction, and land use, EPA assumed that the 305(b)
survey data characterize 100% of all US waters. EPA approximated the proportion of
impairment specifically attributable to Phase II sources by multiplying the percentage
impairment by the percentage of the municipal population and construction activities (starts)
regulated under the rule.

ES.5 Potential Costs for Municipalities

EPA estimated annual per household program costs for automatically designated municipalities
using data from a 1998 survey conducted by the National Association of Flood and Stormwater
Management agencies which sought to identify current storm water spending levels in Phase II
municipalities (see Section 4.2.1). EPA also estimated an average annual per household
administrative cost for municipalities to address application, record keeping, and reporting
requirements of the final rule. The average per household cost of the rule is expected to be
$9.16.

To determine potential national level costs for municipalities, EPA multiplied the number of
households (32.5 million) by the per household compliance cost (S9.16)1. The annual estimated
national Phase II municipal cost is approximately $297.3 million.
»
ES.6 Potential Costs for Construction Operators

EPA developed a national level cost estimate for implementing erosion and sediment, controls on
sites that disturb between one and 5 acres. EPA estimated a per site compliance cost for sites of
one, three, and five acres and multiplied the cost by the total number of Phase II construction
starts expected to incur incremental cost in these size categories to obtain a national cost
estimate. EPA used construction start data from fourteen municipalities and 1994 Census
Bureau construction permit data to estimate the number of construction starts disturbing between
one and five acres of land. Of the estimated 129,675 construction starts likely to incur
incremental costs, EPA expects that 110,223 (85%) will require erosion and sediment controls to
comply with the regulation.

EPA used standard cost estimates from R.S. Means (R.S. Means, 1997a and 1997b) and the WEF
database to estimate construction BMP costs for 27 model sites of typical site conditions in the
United States. The model sites included three different site sizes (one, three, and live acres),
three slope variations (3%, 7%, and 12%), and three soil erosivity conditions (low, medium, and
high). EPA used the WEF database to determine BMP combinations appropriate to the model
site conditions. For example, sites with shallow slopes and a low erosivity require few BMPs,
while larger, steeper, and more erosive sites required more BMPs. Detailed site plans,
assumptions, and BMPs that could be used are presented in Appendices B-2 and B-3. Based on
the assumption that any combination of site factors is equally likely to occur on a given site, EPA
'Per household cost can be converted to per capita cost using the national average of 2.6246 persons per household.

October 1999 Final Report ES-3

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Executive Summary
averaged the matrix of estimated costs to develop an average cost for one-, three-, and five-acre
starts for all soil credibilities and slopes.

EPA then estimated administrative costs per construction site for the following elements required
under the Phase II rule: submittal of a notice of intent (application) for permit coverage;
notification to municipalities; development of a storm water pollution prevention plan (SWPPP);
record retention; and submittal of a notice of termination. The average total administrative cost
per site is estimated to be $937.
, '. , ' • " : ! fi r ;• I • ' ., !,:' • . .. J'.f
Summing the average BMP costs and the administrative costs yields a total compliance cost of
$2,143 for sites disturbing between one and two acres of land, $5,535 for sites disturbing
between two and four acres of land, and $9,646 for sites disturbing between four and five acres
of land, To estimate national level incremental annual costs for Phase II construction starts, EPA
multiplied the total costs of compliance for one to two acre, two to four acre, and four to five acre
sites by the total number of Phase II construction starts within each of those size categories. This
yielded an estimated annual compliance cost of approximately $499.8 million (based on 110,223
construction starts in 1998).

EPA anticipates that 19,452 (15%) of the estimated Phase II incremental construction universe
will qualify for a waiver from program requirements by meeting one of two conditions.
Construction sites can be waived if they are either located in areas with low rainfall potential or
if water quality analyses show that there is no need for regulation. EPA estimates the
incremental administrative cost associated with preparing and submitting a waiver to be
approximately $665,000 (1998). Total costs (national compliance and waiver costs) resulting
from implementation of the Phase II erosion and sediment control provision are estimated to be
$500.4 million.

EPA also estimated incremental costs attributable to the post-construction runoff control
measure. The Phase II municipal program requires municipalities to develop, implement, and
enforce a program that addresses storm water runoff from new development and redevelopment
sites on which land disturbance is greater than one acre and that discharge into a regulated MS4.
To develop a cost estimate associated with this measure, EPA estimated a per site BMP cost,
including operation and maintenance, for 12 model sites of varying size (1,3,5, and 7 acres) and
imperviousness (35%, 65%, and 85%). The per site BMP cost was then multiplied by the total
number of multi-family, institutional, and commercial construction stalls that are located in
Phase II urbanized areas to obtain a national cost estimate. Using this total of 13,364 post-
construction starts, EPA estimated a range of national costs associated with this measure from
$44.6 to $178.3 million (see Appendix B-4).

EPA estimates total annual costs to construction operators, including implementation of erosion
and sediment controls and post-construction controls, to be between $545.0 - $678.7 million.
... ' ' i ,'} i K , *", , • " i ,: • I';1.' ' •' ' l"1 ' "

ES.7 Potential Costs for Federal and State Program Administrators

EPA estimated incremental costs associated with program administration for states that possess
NPDES permitting authority and for EPA within non-NPDES authorized states and territories.
ES-4
Final Report
October 1999

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                                     Executive Summary
 The storm water permitting authority must review and manage the application, certification,
 reporting and notice requirements for municipalities and construction sites. The estimated annual
 incremental Federal and State administrative costs are estimated to be $5.3 million.
 The permitting authority must also develop municipal designation criteria and use the criteria to
 determine whether municipalities that are not automatically designated should be regulated by
 the Phase II rule.  The costs associated with developing and applying these criteria are not
 included in the annual administrative cost estimates because they are considered a one-time-only
 start up cost.  However, these costs and other administrative start-up costs are considered in the
 sensitivity analysis, referred to as Scenario Six, in Section 4.6 of Chapter 4.

 ES.8   Summary of Potential Costs

 A summary of the potential costs from implementing the Phase II municipal measures and
 construction site erosion and sediment controls is presented in Exhibit ES—1. Once the Phase II
 storm water rule is fully implemented, EPA expects the total range of annual costs for
 implementing the rule to be $848 to $981 million.

               Exhibit ES-1. Potential Annual Costs for Phase II Storm Water Regulation
                           *';„ ^ -r -. • ,.,*, '• , • • V' i^^-^?'r*S'$$^&ffi>*^-%&3$
                                                                             •S'^v^. V •- 
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                                    Executive Summary
  ES.10 Reduced Sediment Delivery from Phase II Construction Starts
         	  ',,,11         •                            . •       .     • | ' . .  '	        • :.<   | ."i,
   Jiiir     „   . ' I'  •          .': '    MI.      ,.    ,       !,   .     '  ,      j  ' , ' i         ,  .    , j  ji,
  To estimate reduced sediment delivery from Phase II construction starts, the US ACE developed
  a model based on EPA's 27 model sites to estimate sediment loads from construction starts with
  and without Phase II controls (US ACE, 1998). The US ACE model uses the construction site
  version .of the Revised Universal Soil Loss Equation (RUSLE) to generate sediment delivery
  estimates for 15 climatic regions with each of the following variations: three site sizes (one,
  three, and five acres), three soil credibility levels (low, medium, and high), three slopes (3%, 7%,
  and 12%), and the BMP combinations from EPA's 27 model sites.  The 15 climatic regions
  represent the  various rainfall and temperature conditions throughout the United States.  Sediment
  delivery represents the quantity of sediment that BMPs placed at the base of the hill slope are
  unable to capture. EPA estimated that the average reduction in soil loss from the model sites
  implementing BMPs would be 89.6 tons per site.

  ES.ll  Cost Effectiveness

  Cost effectiveness is typically defined as the incremental annualized cost of a pollution  control
 option per incremental pound of pollutant removed annually by the control option.  Cost-
 effectiveness analysis can thus be used to compare pollutant removal costs across regulatory
 alternatives and across different industries. This type of analysis is limited for the Phase II rule
 because EPA  was only able to quantify potential reductions in TSS loadings (the reduced
 sediment delivery from construction starts would contribute to the reduced loadings from
 municipalities). EPA also anticipates that the rule will result in reductions of other pollutants.

 Based on the total cost of the rule and the estimated reduction in TSS from Phase II
 municipalities, EPA  estimates that Phase II municipalities may experience costs of between
 $0.04 (80% BMP efficiency; high end reduction) and $0.18 (20% BMP efficiency;  low end
 reduction) per pound of TSS removed.2  While EPA anticipates 80% effectiveness at reducing
 pollutant loading following program implementation, both low and high end reduction costs are
 very low compared to the $0.70 (1998 dollars) established for POTWs to remove BOD and TSS;
 thus, the requirements of the final Phase II rule may be cost effective.3 This is particularly true
 since EPA's analysis of cost-effectiveness is based solely on removal of one of many pollutants
 believed present in storm water discharges.

 ES.12 Anticipated Benefits of the Phase II Rule  '

 Storm water runoff from construction sites and urban areas can adversely affect aquatic systems.
 Runoff from these areas can include  litter, chemicals, metals, nutrients, pesticides, organics,
 bacteria, and sediment.  These pollutants can have a variety of detrimental effects on humans,
 aquatic ecosystems, and wildlife.  For example, bacterial contamination of waters used for
 swimming can threaten the health of swimmers. Sediment related pollution can degrade and
 Cost effectiveness is based on the total cost of the rule because the municipal component includes construction activity within
the watershed.

The technologies used for secondary treatment at POTWs removes both BOD and TSS at the same .time. Therefore, estimating
the tons of TSS removed from secondary treatment is not possible.
ES-6
                                       Final Report
October 1999
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                                    Executive Summary
  destroy benthic habitat and organisms, decrease photosynthetic activity, and reduce the viability
  of aquatic biota. Sediment can particularly detrimental to smaller streams, altering channel
  morphology and threatening critical aquatic habitat as well as human safety and property. Other
  pollutants such as metals, organics, pesticides, and nutrients can have chronic or acute effects on
  aquatic organisms and lead to bioaccumulation or eutrophication.

  Estimation of Benefits

  In the economic analysis for the proposed rule, a top-down approach was used to estimate
  economic benefits. Under this approach, the combined economic benefits for all wet weather
  programs were estimated first, and then were divided among various water programs on the basis
  of expert opinion. The use of an expert opinion in this manner rendered the benefits estimates
 for an individual program uncertain. In addition, the approach was inconsistent with the bottom-
 up approach used to estimate the cost of the proposed storm water rule, which aggregated costs
 across municipalities and construction starts. Researchers normally prefer to base cost and
 benefits analysis on a similar structure. Therefore, EPA decided to change the benefits analysis
 for the Phase II rule. To adequately reflect the quantifiable benefits of the rule, EPA used two
 different approaches, one that relied on a national water quality model and another that relied on
 the 305(b) national water quality assessment. Both approaches estimate benefits based on
 expected water quality improvements of the Phase II rule. Despite the difference in the
 estimates, both approaches show that benefits potentially exceed costs.

 National Water Quality Model Approach

 To estimate the benefits of the Phase II municipal and construction site controls, EPA used the
 National Water Pollution Control Assessment Model (NWPCAM).  This model estimates water
 quality and associated use support for the 632,000 miles of rivers and streams in the EPA Reach
 File Version 1 (RF1), which covers the continental United States.  The model analyzes water
 quality by stream reach based on point source and nonpoint source pollution loadings and
 geographic and hydrologic conditions.  The water quality parameters modeled in the NWPCAM
 are biological oxygen demand (BOD), total suspended solids (TSS), dissolved oxygen (DO), and
 fecal conforms (FC). The model  simulates the impact of loadings on water quality immediately
 below a point source in the down stream segment of a reach.

 The model projects improvements in water quality by comparing the simulation results of a
 baseline loadings  scenario with results for a scenario based on Phase II municipal and
 construction site controls. These improvements are characterized as  changes in modeled water
 quality classifications between four water quality use support categories: no support, boatable,
 fishable, and swimmable.  To calculate the economic benefits of change in water quality, the
 model overlays the water quality changes with estimates of households in the proximity of the
 affected stream reach. The household estimates are based on the 1990 Census of Populated
 Places and Minor  Civil Divisions, and updated 1998 population levels. Economic benefits are
 calculated multiplying number of households by household willingness-to-pay (WTP) values for
water quality improvements. The WTP values are based on a national valuation survey  (Carson
and Mitchell, 1993). The benefits are separately estimated for local and nonlocal waters on the
basis of WTP values.
October 1999
                                      Final Report
ES-7
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                                    Executive Summary
 Definition of Baseline Conditions
         ;,.                  .      .   ••     .....   '      . ..... •;   •:   \ ,   >
 To estimate economic benefits, NWPCAM compares given baseline pollution loadings
 conditions tq compliance with the Phase II program. The baseline conditions are described
 below.          ,     '  '        .         '      '    , '. ..... ' ,'       '      ,        ',  '.
                                                                                  .
         ll combined sewer overflows (CSOs) are controlled by detention basins and assume
        85% capture of the runoff (the 85% capture is based on NEEDS Survey assumptions)
        "  :'   i1 ,       ,       ,"        , " "     it,      ",   >,   • •'    •'  '", , : , j    ,    I  !"' ill1  ii1  ,  T •

 •      Detention basin controls are at each of the 1,723 individual NWPCAM Phase I urban
        sites and assume 85% capture of the runoff

 •      Construction start BMPs are in place based on existing state programs

 •      Construction start BMPs are in place at sites greater than five acres.

 Definition of Scenario Conditions — Phase II Controls in Place
    •  -   *;; •,".;  •     ,  " • :  ••        ••• •     :.    . ,  '   ,  .\,, ',  •? ,   j.    •;   .:••;.. • ,  .j " s,
 The Phase n conditions include the baseline conditions and are assumed to further impose:
         '^ . »|     '      . , •.          .   , '   '  •       '••   ,;;;"; '  >   . I  - "'I '  • • ............ ; .       '> I ;
 •      Detention basin controls at each of the 5,038 individual NWPCAM Phase II urban sites
        that assume 85% capture of the runoff4

 •      Construction starts BMPs are in place at sites between one and five acres.

 The model normally requires an engineering surrogate for treatment of specific pollutants
 contained in discharges, whereas the Phase II program includes both structural and nonstructural
 controls. The model uses detention basins as a proxy to represent the impact of the municipal
 ,:           •                     '      !'"   ' •.        • S"   i"      /  j, ,    .   . .L:   .....  »
 program.
                                                              • .  i  ,  •        •         i .,
,                                       , •'         •  '      '       ,.1        ./        '    . ! "
 EPA applied Carson and Mitchell's (1993) estimates of household WTP for incremental water
 quality improvements to the improvements simulated using NWPCAM. Carson and Mitchell
 estimate the WTP for three minimum levels of fresh water quality: boatable, fishable, and
 swimmable. EPA adjusted the WTP amounts to account for inflation, growth in real per capita
 income, and increased attitudes towards pollution control. The adjusted WTP amounts for
 improvements in fresh water quality are $210 for boatable, $158 for fishable, and $177 for
 swimmable.
         '":'!:      i 'i'4  •    "' "                     ,,n   ......  'i L,  I lllfc "        I      '         .'      I
 The NWPCAM valuation analysis assumes that households place a higher value  on local water
 quality improvements than on nonlocal water quality improvements. Thus, if improvement
 occurs in waters that are not close to population centers, the economic value is lower. Benefits
 are estimated for local and nonlocal waters, separately by apportioning the WTP  between local
 and nonlocal waters. Mitchell and Carson (1986) asked respondents to apportion each of their
                                                "it it"
                                                        "ffi,,
4The benefits analysis used 5,038 municipalities instead of 5,040 used for the cost analysis.
ES-8
Final Report
October 1999
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                                    Executive Summary
 stated WTP values between achieving the water quality goals in their own state and achieving
 those goals in the nation as a whole. On average, respondents allocated 67% of their values to
 achieving in-state water quality goals and the remainder to the nation as a whole. Mitchell and
 Carson argue that for valuing local (substate) water quality changes 67% of the WTP value is a
 reasonable upper bound for the local multiplier and 33% of the value is for nonlocal water
 quality changes.  For the purposes of this analysis, the locality is defined as urban sites and
 associated populations linked into the NWPCAM framework Using this methodology, the total
 benefits of Phase II controls are estimated to be $1.63 billion per year. The summary of the local
 and nonlocal benefits due to Phase II controls are presented in ES-2.

          Exhibit ES-2. Annual Local and Nonlocal Benefits Estimates Due to Phase II Controls
                                                                        •«/*«.?.•%>;>•«•."? w ;• <-.-»- ris*
  Swimming, Fishing, and Boating
 306.2
 60.6
 366.8
  Fishing and Boating
 395.1
 51.9
 447.0
  Boating
 700.1
114.6
 814.7
  Total
1401.4
227.1
1628.5
  1 To estimate nonlocal willingness to pay per household, the 33% of WTP is multiplied by the fraction of
  previously impaired national waters (in each use category) that attain the beneficial use as a result of the Phase II
  rule. To estimate the aggregate nonlocal benefits, nonlocal WTP is multiplied with the total number of
  households hi the United States.

Sensitivity Analysis

The benefit estimates are derived using conservative assumptions of the pollution control
effectiveness of the municipal component of the Phase II rule. The Phase I and Phase II urban
runoff controls used hi this analysis employ pollutant removals that would be characteristic of
detention basins.  To determine the impact of the alternative assumptions a sensitivity analysis is
conducted. Alternative analysis assumes different levels of control, such as 60% or 80%
pollutant removals in the storm water run off from municipal sources. Supplemental sensitivity
analysis in conjunction with the controls in the 60% to 80% range shows that the economic
benefits in NWPCAM increase by $200 million to $300 million from the estimate of $1.63
billion, respectively.

The benefit estimates can be considered quite robust because model sensitivity analyses have
consistently shown that the estimates are stable, even under assumptions of large changes hi
model input values. As an example, a sensitivity analysis was conducted assuming that the
construction starts loads are 25% higher and lower. The local economic benefits estimates
change by only +/- 5%. Moreover, a statistical groundtrathing of the model to storage and
retrieval ambient water quality data indicates that the NWPCAM produces reliable baseline
estimate can be considered as a reasonable predictor of the actual use support for 1990s.
October 1999
  Final Report
                          ES-9
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                                   Executive Summary
 National Water Quality Assessment

 This approach to estimating the benefits of the Phase II rule estimated benefits separately for the
 municipal minimum measure and the soil erosion control provisions. Furthermore, it estimated
 partial benefits associated with marine water quality improvements. Each component is
 described separately below and aggregate benefits are reported at the end of this section.

 Potential Value of the Benefits of Municipal Measures—Fresh Waters
    f '   ,i-,   " S         ,•      '    •   • .      :   •' '  •   ;., ; "	   '.-• |j', ,       ,   •    „   i. T
 Runoff from Phase II municipalities contribute loadings of nutrients, metals, oil and grease, and
 litter that result in impairment of the nation's rivers and streams, lakes, reservoirs, Great Lakes,
 estuaries, and oceans.  The benefits of implementation of the Phase II municipal minimum
 measures to remove impairment depend on a number of factors, including the number, intensity,
 and duration of wet weather events; the success of the municipal programs; the site-specific
 water quality and physical conditions; the current and potential uses of the receiving waters; and
 the existence of nearby "substitute" sites of unimpaired waters. Because all these factors will
 vary Substantially from municipality to municipality, data and information are not available with
 which to develop estimates of benefits measure by measure and water body by water body.

 EPA applied Carson and Mitchell's (1993) estimates of the household WTP for incremental
 water quality improvements to estimates of waters impaired by urban storm water discharges as
 reported by states in their 305(b) reports. Carson and Mitchell's 1993 study reports the results of
 their 1983 national survey of WTP for incremental improvements in fresh water quality. Carson
 and Mitchell estimate the WTP for three minimum levels of fresh water quality: beatable,
 fishable, and swimmable. EPA adjusted the WTP amounts to account for inflation, growth in
 real per capita income, and increased attitudes towards pollution control.  The adjusted WTP
 amounts for improvements in fresh water quality are $210 for beatable, $158 for fishable, and
 $177 for swimmable.

 To develop estimates for the potential value of the municipal measures (except storm water
 runoff controls for construction sites), EPA apportioned the WTP estimates for the different
 water quality levels based on the baseline level of water quality impairment potentially
 associated with Phase II municipalities. However, although the Carson and Mitchell estimates
 apply to all fresh water, it is not clear how these values would be apportioned among rivers,
 lakes, and Great Lakes. The 305(b) data indicate that lakes are the most impaired by urban
 runofi7sto;rm sewers, followed closely by Great Lakes, and then rivers. Therefore, EPA applied
 the WTP values to the categories separately and assumed that the higher resulting value for lakes
 represents the high end of the range (i.e., assuming that lake impairment is more indicative of
 national fresh water impairment) and that the lower resulting value for impaired rivers represents
 the low end of a value range for all fresh waters (i.e., assuming that river impairment is more
 indicative of national fresh water impairment).

 Summing the benefits across the water quality levels yields a low estimate of benefits ranging
from approximately $120.2 million to $145.2 million per year and a high estimate of benefits
ranging from approximately $270.1 million to $372.8 million per year, assuming 80% program
effectiveness, The fresh water benefit analysis does not include the prospective benefits that are
expected to accrue from the post-construction runoff control provision of the Phase II Storm
                                      Final Report
October 1999
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                                  Executive Summary
Water rule. This is because the benefit analysis was based on current water quality impairment
levels in the 305(b) report. The post-construction runoff control provision will mitigate future
impairment to water bodies by controlling contaminated storm water runoff from sites that are
developed or redeveloped in the future. This would happen because development increases the
amount of impervious surface. Such increases hi imperviousness alter runoff patterns and
reduces the effectiveness of natural water quality improvement mechanisms,  such as
groundwater infiltration and wetlands filtration.  Furthermore, development introduces new
sources of contamination to a watershed. Without this provision, national water quality
impairment from Phase II would increase relative to the impairment levels currently reported in
the 305(b). EPA estimated that annual benefits of avoided water quality impacts would range
from $1.7 million to $5.4 million. This analysis  is based on projections of current impairment
levels reported in the 305(b) that use disturbed area estimates for the affected construction starts
as a proxy for potential long-term future water quality impacts.

Potential Value of the Benefits of Municipal Measures—Marine Waters

The Phase II rule will impact all types of waters, fresh waters as well as marine.  In addition to
the fresh water benefits captured by the Carson and Mitchell study, EPA anticipates benefits as a
result of improvements to marine waters. Sufficient methods have not been developed to
quantify benefits for commercial or recreation fishing. EPA used beach closure data and
visitation estimates from its Beach Watch Program to estimate potential reductions in marine
swirnming visits due to storm water runoff contamination events in 1997. The estimated 86,100
trips that did not occur because of beach closures in coastal Phase II communities is a lower
bound because it represents only those beaches that report both closures and visitation data.
Using average consumer surplus value of $30 per day per trip (in 1998 dollars) from applicable
studies, which were summarized in two meta-analyses (Walsh et al., 1990 and Freeman, 1993),
EPA estimated potential swimming benefits for the rule as $2.6 million.  Assuming 80%
program effectiveness, the benefit estimate is $2.1 million.

EPA developed an analysis of potential benefits associated with avoided health impacts from
exposure to contaminants in storm sewer effluent. Based on a study of incremental illnesses
found among people who swam within one yard of storm drains in Santa Monica Bay, EPA
estimated a range of incremental illnesses (Haile et al., 1996). The Santa Monica Bay study
reported attributable illnesses for several health symptoms. The attributable illnesses
characterized incremental cases of illness found among those swimming close to the storm drains
compared to a control group swimming at least 400 yards away from the drains.  The benefits
analysis applied values to two of the symptom categories.  A WTP estimate of $24 per case was
multiplied by the additional cases of significant respiratory disease (SRD) (US EPA, 1997d), in
1998 dollars.  Assuming that each case was accompanied by one mild restricted activity day, and
additional $47 was multiplied by each case (US EPA, 1997d), in 1998 dollars. Cases of highly
credible gastroenteritis two were valued using a cost of illness value of $244, which was
estimated by Mauskopf and French (1991), in 1998 dollars for mild cases of salmonellosis—an
illness with symptoms similar to those in the Santa Monica Bay study. Depending on
assumptions made about number of exposures to contaminants and contaminant concentrations,
benefits ranged from $8.7 million to $37.4 million. Assuming 80% program effectiveness, the
benefit range is $7.0 million to $29.9 million.
October 1999                            Final Report                                 ES-11
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                                    Executive Summary
 Potential Value of the Benefits of Construction Site Controls

 Development activities increase the amount and types of contaminants that degrade water
 quality. During construction, soil erosion from disturbed areas increases sediment loads in water
 bodies, which leads to a variety of habitat impairments, increases flooding risks, and adds to
 dredging costs. In addition to sediment, construction activities also yield pollutants such as
 pesticides, petroleum products, and solvents. The national benefits of construction site storm
 water runoff controls will depend on a number of factors, including the number, intensity, and
 duration of wet weather events; the effectiveness of the selected construction site BMPs; the site-
 specific water quality and physical conditions of receiving waters; the current and potential uses
 of receiving waters; and the existence of nearby "substitute" sites of unimpaired waters. Again,
 because these factors will vary substantially from site to site, data are not available with which to
 develop estimates of benefits for each site.
                                                  	           i                  '
           „            .  .                          '            . .  r|                     1
                               11             ,  	       '    ,      "1    "     '          '  '
 Nonetheless, a survey of North Carolina residents (Paterson et al., 1993) indicated that
 households are willing to pay for erosion and sediment controls similar to those contained in the
 Phase n program. Paterson et al.'s (1993) analysis of the survey results indicated a mean WTP
 of $25 per year (in 1998 dollars). This study provides one way to develop national-level benefits
 estimates of the rule and, therefore, EPA chose to use benefit transfer methodology to apply the
 study results.  Paterson et al's. (1993) study is applicable to the construction component of the
 Phase n rule not only because North Carolina's program requires similar controls, but also
 because the median income of North Carolina residents is just below the median income for the
 United States. The similarity of the median incomes indicates that the WTP estimates developed
 by Paterson et al. (1993) may be appropriate for transfer to residents elsewhere in the United
 States.

 The impact of Phase II construction sites on overall construction soil erosion damages to water
 quality is uncertain. EPA developed a benefit range based on high and low impact assumptions.
 For the high impact assumption, EPA multiplied the updated mean WTP of $25 by the
 percentage of Phase II construction sites and the number of households in each state. For the low
 impact assumption, EPA used the percentage of total construction site perimeter affected by the
 Phase II rule father than the percentage of total sites.  Summing the low and high estimates
 across all states indicates that the WTP for the erosion and sediment controls of the Phase II rule
 may be approximately $487.7 million to $622.4 million per  year. This range reflects the
 potential benefits of erosion and sediment control programs  that protect all lakes, rivers, and
 streams. However, because construction can be especially harmful to small stream habitat, EPA
 is interested in the benefits that may be attributable to improvements in small stream ecology.
 Based on inventory data reported in state 305(b) reports and the distribution of streams by stream
 order (Leeden, 1990), approximately 2% of all water bodies are first order streams. This
 suggests that approximately $9.8 to $12.4 million of the total annual benefits from erosion and
 sediment controls may reflect a desire to protect small streams.

Summary of Monetized Benefits: National Water Quality Assessment

A summary of the potential benefits resulting from implementation of the Phase II municipal
measures and erosion and sediment controls for construction sites is presented in Exhibit ES-3.
ES-12
Final Report
October 1999
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                                      Executive Summary
 Total benefits from municipal measures and construction site controls are expected to be $671.5
 million to $1,096.2 million per year (assuming 80% effectiveness of municipal programs),
 including benefits of approximately $10.8 million to $13.7 million per year associated with small
 stream improvements.  The largest portion of benefits are associated with erosion and sediment
 controls for construction sites.

 As shown in the exhibit, some categories of benefits are not included in the WTP estimates from
 the research used. In particular, benefits for improving marine water quality such as fishing and
 passive use benefits are not included in the values used to estimate the potential benefits of the
 municipal mLnimum measures (excluding construction sites controls), and they are not estimated
 separately.

                Exhibit ES-3.  Potential Annual Benefits of the Phase II Storm Water Rule
                                     (Millions of 1998 dollars)


                               »|Munjc;ipa1!!MinimuMHVfeas\ires;}j
                               i£.?t^£^">-J/::-#'v.--r ^- -.v -. *~. .^-..r^i^^.C'V^ #;$,
Fresh Water Use and Passive Use2
Marine Recreational Swimming
Human Health (Marine Waters)
Other Marine Use and Passive Use
                                                                           $121.9 -$378.2
                                                                               $2.1
                                                                            $7.0-$29.9

 Fresh Water and Marine Use and Passive Use3
                                                                         $540.5-$686.0
 Total Use and Passive Use (Fresh Water and Marine)
                                                                       >$671.5->$1,096.2
 + = positive benefits expected but not monetized
 1 Includes water quality benefit of municipal programs, based on 80% effectiveness of municipal programs.
 2 Based on research by Carson and Mitchell (1993). Fresh water value only. Does not include commercial
 fishery, navigation, or diversionary (e.g.,municipal drinking water cost savings or risk reductions) benefits. May
 not tally capture human health risk reduction or ecologic values.
 3 Based on research by Paterson et al. (1993). Although the survey's description of the benefits of reducing soil
•  erosion from construction sites included reduced dredging, avoided flooding, and water storage capacity benefits,
  these benefit categories may not be fully incorporated in the WTP values. Small streams may account for over
  2% of total benefits.

ES.13 Benefits Estimation Comparison

The two approaches to estimating the potential benefits of the rule generate a wide range of
benefits. The NWPCAM approach obtained a higher overall benefit estimate of $1.6 billion
compared to the range for the national water quality assessment approach ($671.5 million to $1.1
billion). Both approaches are based on expected water quality improvements of the rule and both
show that the benefits are likely to exceed costs.
October 1999
                                        Final Report
                                                                                        ES-13
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                                    Executive Summary
 ES.14  Comparison of Benefits and Costs

 Exhibit ES—4 provides an annual comparison of benefits and costs for a representative year in
 which the rule is implemented, one in which benefits from the minimum measures and
 construction controls are accruing. Because there is not an initial outlay of capital costs with
 benefits accruing in the future (i.e., benefits and costs are almost immediately at a steady state), it
 is not necessary to discount costs in order to account for a time differential. In addition, EPA did
 not vary the factors that comprise the benefits and costs to account for market changes over time.
 Therefore, the benefits and costs presented in Exhibit ES-4 reflect a constant and steady stream
 of annual benefits and costs.
        Exhibit ES-4. Comparison of Annual Benefits to Costs for the Phase tit Storm Water Rule
, , ,!-•-, , '3V " ~ » *
Monetized Benefits1 , » 4 «« „ * t •*•«/£ »rhj^
I""!*3 1 1 -I II « * « • "V "•**" 5* »K*Vj <»"\\\*
Municipal Minimum Measures
Controls for Construction Sites3
Federal/State Administrative Costs
Total Annual Costs
Millions of 1998 dollars2
$1,628.5
$131.0 -$410.2
$540.5 -$686.0
$671.5 -$1096.2
Millions of 1998 dollars2
$297.3
$545.0 - $678.7
$5.3
$847.6 -$981.3
  'National level benefits are not inclusive of all categories of benefits that can be expected to result from the
  regulation.
  ^Detail may not add to total due to independent rounding.
  3 Controls evaluated include both erosion and sediment and post-construction controls.
ES.15 Impact on Small Entities
               i'   ••                    '.          "	   : :••      j     : .      •>  '   . '   I.:
Because EPA revised its cost analysis, it reviewed the economic impact analyses for small
entities in its initial screening analysis.  The small entities affected by the rule include almost
4,500 municipalities with populations below 50,000 and potentially more than 180,000 building
construction businesses with revenues below $17 million. EPA revised its revenue test for small
municipalities using the updated municipal cost estimates, and concluded that its original finding
that the rule would not have a significant impact on a substantial number of small entities was
consistent with the analysis.

EPA also updated its proxy for a sales test for small construction companies by comparing its
revised per home compliance cost estimates for single family detached to the median and mean
ES-14
Final Report
October 1999
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                                   Executive Summary
 cost of a new home.  Compliance costs of approximately $400 to $650 per home equaled 0.22%
 to 0.43% of the price of a new home, and EPA concluded that it was unlikely that such costs
 would have a significant impact on a substantial number of small construction companies.

 Finally, EPA added similar analyses of costs for multi-family residential developments and
 commercial developments to evaluate the potential impacts of indirect costs such as those
 estimated for the post-construction runoff control element of the municipal program provision.
 For multi-family developments, the per-site compliance costs was compared with the estimated
 revenues from constructing condominiums or apartments on the site. The revenue estimates
 were determined by multiplying the estimated number of units per site by the median
 condominium price and mean apartment price, respectively. Compliance costs equaled 0.17% to
 0.91% of anticipated sales revenues. For commercial sites, the per-site compliance costs were
 compared to the estimated revenue from a commercial office development.  Compliance costs
 ranged from 0.38% to 0.47% of sales.  Based on the results from these three screening analyses,
 EPA concluded that typical construction firms, which build and sell residential or commercial
 sites, are unlikely to incur compliance costs which exceed 1% of expected sales.

 ES.16 No Exposure

 The Storm Water Phase II rule includes a conditional exclusion for no exposure for all categories
 of industrial activity covered by the Phase I program that can certify a condition of no exposure,
 except for discharges from construction and individually designated sources. "No exposure"
 means all industrial materials or activities are protected by a storm resistant shelter so that the
 materials or are not exposed to rain, snow, snowmelt, or runoff.  EPA estimates that
 approximately 181,885 facilities are eligible to take advantage of the no exposure provision.
 Potential cost savings are provided to these facilities in the form  of avoided  costs. These forgone
 costs include  the development and implementation of storm water pollution prevention plans that
 range from $3,661 to $24,147 annually, visual and analytical monitoring costs that vary, notice
 of intent costs of $3.25 annually, notification of municipalities cost of $3.25 annually, and record
 keeping costs of $91 annually. An annual no exposure certification cost of approximately $1.2
 million is expected for the 181,885 facilities. After this certification cost is subtracted from total
 industrial avoided costs, the resulting net cost savings range from $317.6 million to $1.86 billion
 annually.
October 1999
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                                                                                  ES-15
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«l
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                                1.0 INTRODUCTION
 In January 1998, the US Environmental Protection Agency (EPA, or the Agency) proposed a
 Phase II storm water rule that contained provisions for controlling pollutants in storm water
 discharges associated with certain municipalities and construction sites.  EPA's proposal was
 accompanied by an economic analysis of the potential economic effects of the rule in compliance
 with Executive Order 12866 and other statutory and legal authorities such as the Small Business
 Regulatory Enforcement Fairness Act (SBREFA). EPA is currently under court order to finalize
 the Phase II storm water rule by October 31,1999.

 1.1  Statutory Background

 The final rule has changed from the proposal in response to public comment and internal agency
 review. This document updates the benefit-cost analysis prepared for the proposed rule.

 In the  1987 amendments to the Clean Water Act (CWA), Congress established a tiered approach
 for addressing certain industrial, municipal, and other storm water discharges.  These
 amendments provided for a phased program to address the "worst offenders" first (Phase I), and
 identify an appropriate second tier of sources at a later date. EPA published Phase I application
 requirements for categories of storm water discharges recognized as the most damaging to the
 environment in 1990 (55 Federal Register (FR) 47990, November 16,1990). Generally, Phase I
 sources include storm water discharges associated with certain industrial activities, medium and
 large municipal separate storm sewer systems-(MS4s), and large construction sites (greater than
 five  acres).

 Phase II storm water sources were to be identified based on EPA's findings as presented in its
 Report to Congress (US EPA, 1995a). Based on this report, EPA published a direct final Phase
 II storm water rule in 1995 (60 FR 40229, August 7,  1995). EPA published this rule in part to
 protect Phase II dischargers from CWA citizen suit liability.  However, it was recognized that the
 Phase II regulatory program would undergo further development. Indeed, the 1999 final rule,
 when promulgated, will replace the August 1995 direct final rule.

 1.2  Description of the Rule

 The final Phase II rule requires storm water discharges from small MS4s  and small construction
 sites to be covered under a National Pollutant Discharge Elimination System (NPDES) permit.
 Small MS4s include incorporated places, counties, and other places under the jurisdiction of a
 governmental entity (including Tribal and Territorial governments) that are located in an
 urbanized area but are not included in Phase I.  Phase I addresses larger and medium-sized MS4s
 serving populations of 100,000 and more. Phase II generally pertains to systems serving less
than 100,000 people. However, the permitting authority could waive permitting requirements for
 systems serving less than 1,000 people. Indian reservations located within urbanized areas and
with a population of less than 1,000 persons are excluded.
Phase II small construction sites are those that disturb between one and five acres of land. In
addition,  sites disturbing less than one acre would be subject to regulation if they are part of a
October 1999
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                                       1.0  Introduction
   larger common plan of development or sale. However, the NPDES permitting authority could
   waive permitting requirements under certain conditions.

   The Phase II rule does not include any additional regulatory requirements for industrial
   establishments nor will it expand the universe of industrial establishments.
         V"""	   "?!  ;,     •  '• -     ,    •  •  •   ••;•:*"   	i -..,.•;•        1   .  •   • •'     •      | 	
   Owners or operators of small MS4s would be required to develop and implement a storm water
   management program designed to reduce the discharge of pollutants to the maximum extent
   practicable and protect water quality.  These programs would be required to include, at a
   minimum, control measures to address requirements for:

   •      Public education and outreach
   •      Public involvement and participation
   •      Illicit discharge detection and elimination
   •      Construction site storm water runoff control
   •      Post-construction storm water management in new development and redevelopment
         Pollution prevention/good housekeeping for municipal operations.

   Construction site owners or operators would be required to plan and implement appropriate
   erosion and sediment control best management practices (BMPs) to control storm water
   discharges from small  sites.

   1.3    Economic Analysis of the Rule

   The analysis presented here updates the benefit-cost analysis prepared for the proposed rule.
   Revisions have been made primarily in response to internal Agency review and comments
  received during the public comment period.
           '''  ,/      '           /        	   "':,      ;';        i;:« v  '.. '  .,•  '.   '•     i •;
  A number of issues were raised in the public comments regarding the economic analysis (EA)
  that accompanied the proposed rulemaking. One was the belief that the analysis was biased
  toward understating benefits because several of the benefits categories, such as reduced flood
  damage, were not reflected in the monetized benefits estimate. Another was the belief that the
  universe of affected municipalities and construction sites would be larger than estimated,
  resulting in an underestimation of costs. In contrast, commenters also suggested that reducing
  storm water pollutants would not be sufficient to restore waters (i.e., benefits were overstated)
  and that costs were overstated. Impacts on smaller municipalities and construction site operators
  were also discussed,  as well as the use of data collected from Phase I municipalities.

  Internal EPA review of the analysis resulted in questions relating to the accuracy and
".[completeness of the data underlying the analysis, including data used to estimate the cost of
  rnunicipal minimum  measures (e.g., data on start-up costs and changing costs  over time), the
  number of construction sites between one and five acres, the impairment of water bodies, the
  number of waivers expected, the amount and cost of monitoring, and the cost and extent of
  dredging. Another issue identified by EPA related to implementation of the Coastal Zone Act
  Reauthorization Act Amendments of 1993 (CZARA) and whether both costs and benefits
  associated with controls in these areas should be considered.
  1-2
                                        Final Report
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                                      1.0 Introduction
  To address the issues raised in the public comments and during internal review, EPA gathered
  additional data and information to refine the analysis of potential benefits and costs.  These data
  and analyses are described in detail in the chapters that follow.  A large part of the effort was
  directed to refining the estimates of the number of regulated MS4s and construction sites and
  better characterizing potential costs based on information from the Phase I storm water program.
  Efforts were also directed towards more fully capturing the potential benefits associated with the
  municipal and construction site components of the rule.

  1.4    Structure of the Report

  This report consists of the following chapters:

        Chapter 2, Environmental Concerns Addressed by the Rule, discusses the nature of
       the environmental problems caused by storm water discharges regulated by the rule.

       Chapter 3, Baseline for Estimating Benefits and Costs, describes the data and issues
       related to developing a baseline against which benefits and costs can be measured.

       Chapter 4, Potential Costs, Pollutant Load Reductions, and Cost-Effectiveness,
       provides revised estimates of the potential costs of compliance with the final rule, the
       anticipated reductions hi pollutants loadings anticipated, and the anticipated cost per
       pound of pollutant removed.

 •     Chapter 5, Qualitative Assessment of Benefits, provides a qualitative discussion of the
       benefits that are expected to result from the final rule.

       Chapter 6, Quantitative Assessment of Benefits, provides estimates of the potential
       magnitude of benefits, where feasible.

       Chapter 7, Comparison of Potential Benefits and Costs, presents a comparison of the
       estimated benefits and costs, and discusses uncertainties associated with the analyses.

       Chapter 8, Revised Analysis for Small Business Regulatory Enforcement Fairness
       Act, Environmental Justice, and Unfunded Mandates, provides an update to the
       screening analysis developed for the proposed rule.

       Chapter  9, No Exposure, provides estimates of the net cost savings that will result from
       implementation of the Phase I no exposure provision.

•      Chapter 10 provides references.

In addition, several appendices provide supporting materials and references.
October 1999
                                      Final Report
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     2.0 ENVIRONMENTAL CONCERNS ADDRESSED BY THE RULE

Storm water discharges have emerged as one of the leading causes of impairment of the Nation's
surface waters (US EPA, 1998a). This chapter takes a more detailed look at the environmental
problems resulting from storm water discharges that result hi a need for the Phase II regulation.
Specifically, Section 2.1 provides an overview of storm water discharges from construction sites
and urban areas and Section 2.2 describes the potential adverse impacts of these discharges on
humans, aquatic ecosystems, and wildlife.

2.1  Storm Water Discharges from Urban Areas and Construction Sites

Several studies reveal that storm water runoff from urban areas and construction sites can include
a variety of pollutants, such as sediment, bacteria, organic nutrients, hydrocarbons, zinc, copper,
cadmium, mercury, iron, nickel, oil, and grease (Barret et al., 1996). In addition, the National
Water Quality Inventory, 1996 Report to Congress, a summary of state §305(b) reports,
documents water quality impairment resulting from storm water discharges. The reports found
urban runoff/storm sewer discharges to affect 13% of impaired rivers, 21% of impaired lakes,
and 45% of impaired estuaries.  "Impaired" waters are those not meeting water quality standards
or designated beneficial uses such as drinking water supply, primary contact recreation, and
aquatic life support. The reports also found construction activities (e.g., land development, road
construction) to have a significant impact on rivers, lakes, and wetlands. The pollutants
associated with urban area and construction site discharges are discussed in more detail below.

2.1.1 Urban Area Storm Water Discharges

Urbanization has been shown to affect both the quantity and quality of storm water runoff. In
heavily populated areas, water quality impairment has been linked to human activity. Often,
individuals in residential communities improperly dispose of used oil, household toxic materials,
radiator fluids, and litter (e.g., disposable cups, cans, and fast food packaging) directly into storm
sewer systems or in open areas where the materials can be picked up and carried by storm water
runoff. Additional pollutants in runoff can include herbicides and pesticides, toxic heavy metals,
organic pollutants, fecal conform bacteria and pathogens, sediment, and air pollutants (Field and
Pitt, 1990; Marsh, 1993). Sediment is a primary pollutant from construction activity, as
discussed below, but it can also be contributed by urban areas as a result of road maintenance
activities such as street cleaning, road resurfacing, and deicing efforts (Rhoads, 1995).. Some
additional pollutants such as sanitary waste and sewer main construction materials (e.g., asbestos
cement, brick, cast iron, vitrified clay) are due to wastes and wastewater from non-storm water
sources, commonly referred to as illicit discharges.  These discharges are "illicit" because the
storm water systems are not designed to accept and discharge, or to process, such wastes.

Areas, associated with urban development, such as commercial and residential districts, parking
lots, and roads, are mostly paved so that storm water may not infiltrate into the ground. Such
surfaces are referred to as "impervious" surfaces. These areas speed runoff flows and pollutants
to receiving waters. In addition, urban areas are specifically designed to efficiently carry storm
water away from the community to reduce flooding and into receiving waters, further increasing
the rate at which waters receive runoff. The increase hi flow and frequency of high flows can
lead to changes in stream channel morphology such as the widening of banks and undercutting of
October 1999
Final Report
 2-1
-33
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                       2.0 Environmental Concerns Addressed by the Rule
    stream beds.  Indeed, Schueler (1995) notes that urban stream channels become unstable when
    10% of a watershed is impervious.

    A number of studies have determined that watershed development leads to increases hi peak
    storm water runoff, as well as to decreases in the time required for the peak to be reached.  Based
    on a compilation of studies, Hollis (1975) estimated that the frequency of small floods could
    increase 10 times as a result of imperviousness covering 20% of a watershed.  Small floods are
    described as those with a return period, or recurrence interval, of one year. For larger floods (i.e.,
   those with a return period of 100 years), the author estimated a possible doubling in size due to
    imperviousness covering 30% of a watershed. Barringer et al. (1994) also observed increases hi
    flow and flow variability hi two streams hi New Jersey as development occurred, although the
   authors could not statistically link the changes to specific causes.  Yorke and Herb (1978) were
   able to attribute observed increases hi peak flow to urbanization hi the Washington, D.C., area.
   In summary, the relative impact of development on storm water flows decreases as the recurrence
   interval of the flow (i.e., the flood size) increases (Hollis, 1975).

   2.1.2  Construction Site Storm Water Discharges

   Construction fundamentally alters natural landscapes (Toy and Hadley, 1987). During
   construction, earth is compacted, excavated and displaced, and vegetation is removed. These
   activities increase runoff and erosion, thus increasing sediments transported to receiving waters.
   Although erosion and sedimentation are natural processes, when land is disturbed by
   construction activities, surface erosion increases  10 fold on sites formerly used for crop
   agriculture, 200 times on sites formerly under pasture, and 2,000 times on sites formerly forested
   (Toy and Hadley, 1987).  In addition to sediment, construction activities also yield pollutants
   such as pesticides, petroleum products, construction chemicals, solvents, asphalts, and acids that
   can contaminate storm water runoff (Marsh, 1993).

   Numerous studies have examined the increases hi sediment loads resulting from storm water
   runoff. For example, Daniel et al. (1979) monitored three residential construction sites hi
   southeastern Wisconsin and determined that annual sediment yields were more than 19 tunes
   greater than yields from agricultural areas. Yorke and Herb (1978) studied nine sub-basins in the
   Maryland portion of the Anacostia watershed for more than a decade to determine the impacts of
   changing land use and land cover on runoff and sediment. Average annual suspended sediment
   yields from construction sites ranged from seven to 100 tons per acre, as compared to cultivated
   land and forest/grassland, which yielded 0.65 to 4.3 tons per acre and 0.07 to 0.45 tons per acre,
   respectively. A 1970 study conducted by the National Association of Counties Research
   Foundation found the potential impacts of urban and suburban development to be even more
   dramatic. The Foundation concluded that sediment yields from construction areas could be as
   much as 500 times the levels detected in rural areas.
              •"            .     '        ;     !    •'         : "• t      \        '           -  \ ',
              1 ""       .     	               •         •          -|         •            i -i
   2.2  Potential Adverse Effects of Storm Water Discharges to
       Humans, Aquatic Life, and  Wildlife
1 i      f       ""I               i. ' I ,1                     ,           'I                     I 'fill.:11
   The impacts of storm water runoff from developed and developing areas on humans, aquatic
   ecosystems, and wildlife can be explored within the context of the hydrologic cycle. When it
   rains, water is intercepted by vegetation and consequently, is absorbed by the soil. The water
   then infiltrates into soil pores,  subsurface flows, and groundwater aquifers.  When soils become
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Final Report
                                                                              October 1999
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                     2.0 Environmental Concerns Addressed by the Rule
 saturated, the water runs off land areas and into surface waters. As development of a watershed
 occurs, soils are compacted and covered with impervious surfaces such as roads, parking lots,
 and buildings. The vegetative cover that intercepts the initial portion of rainfall and enhances
 filtration is reduced. Together, the development activities reduce the filtration rates of soils, and
 subsequent rainfall onto these impervious areas is converted into runoff.

 Many studies provide documentation of the impacts of storm water discharges on humans,
 aquatic life, and other wildlife, including impacts to small streams. The potential impacts of
 these discharges include increased bacterial contamination, increased turbidity, increased toxic
 sediments, decreased dissolved oxygen concentrations, and alterations in stream channel
 morphology and habitat. In turn, these in-stream conditions can have a considerable impact on
 the abundance and diversity of aquatic species. The level of impact is site-specific and depends
 on site imperviousness, the type of receiving waters, acreage of land disturbance, topography,
 soil type, and resource sensitivity. The nature of the impact also varies temporally throughout
 the land development process, with significant differences observed between the site clearing
 phase and post development conditions.  Exhibit 2—1 summarizes environmental concerns and
 impacts associated with urban storm water runoff, as compiled by Homer et al.  (1994) and
 selected impacts are discussed in detail below.

 2.2.1  Human Health Impacts

 Bacterial  contamination of waters used for swimming can threaten the health of swimmers. A
 recent epidemiological study of Santa Monica Bay examined the incidence of disease among
 swimmers near storm drain outfalls and swimmers 400 yards away from the outfalls (Haile, et
 al., 1996). The results indicated that those who swam near storm drain outfalls experienced
 significant increases in the incidence of gastrointestinal and respiratory diseases, as well as
 related symptoms. The study found human pathogens to be the cause of the illnesses and related
 symptoms. The study also indicated that illegal connections, leaking sewer lines, malfunctioning
 septic systems, illegal dumping from recreational vehicles, or direct human sources such as
 campers or transients are possible sources of pathogen contamination into storm drain systems.

 Nationally, beach closings and swimming advisories are typically based on elevated levels of
 bacteria indicative of human pathogens that can cause illness.  These wastes  can enter the water
 via storm  sewer systems, sewage treatment plants, and polluted storm water runoff. In 1996,
 approximately 83% of beach closings and advisories were due to bacteria levels that exceeded
 beach water quality standards (NRDC, 1997). An estimated 14% of beach closings were in
 response to a known pollution event, and 4% were precautionary beach closures due to rain that
 carried pollution into coastal waters. Furthermore, 414 closings and advisories in 1996 were
 prompted  by urban storm water runoff.1 Five of these closings lasted more than 12 weeks.
 A closing may be due to one or more sources; therefore, the total number of closings in 1996 independent of source may be
less.

October 1999                            Final Report                                    2^3
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                       2.0  Environmental Concerns Addressed by the Rule
                         Exhibit 2—1. Adverse Impacts Associated with Urban Runoff
Resource/
Water Use
Ground Water
Aquatic Habitat
Public Water
Supply
Wildlife Habitat
Recreation and
Aesthetics
Agricultural,
Residential, and
Industrial Land
Use
Concern
Lower dry-season
reserves
Erosion
Fluctuating water
levels and
velocities
Low dry-season
base flow
Sedimentation
Turbidity
Low dissolved
oxygen
Metals, organic
contaminants,
chlorides
Increased water
temperature
Bacteria
Eutrophication
Lower dry-season
reserves
Flooding and
erosion
Nature enjoyment
Flooding and
erosion
... Potential Negative Impact on
• :. '. ^ " r ' Resource/Water Use: '
Lower dry-season base flow in water courses
Lower drinking-water reserves
Physical destruction of habitat
Altered thermal and mixing characteristics
Reduced habitat diversity
Erosion
Elimination of spawning beds
Reduced habitat
Reduced dilution capacity
Smothering of bottom communities and spawning
beds
Filling of storm water impoundments
Transport of paniculate-associated pollutants
Lower dissolved oxygen, reduced prey capture,
clogging offish gills
Lethal and nonlethal stress to aquatic organisms
Lethal and nonlethal stress to fish and other
aquatic organisms in water column and bottom
sediments
Lethal and nonlethal stress to sensitive cold water
aquatic organisms
Diseases of aquatic organisms
Shellfish contamination
Algae blooms and nuisance aquatic plant growth
Low dissolved oxygen
Odors
Reduced water supply
Physical destruction of environment
Dewatering and flooding of key habitat areas at
critical times
Reduction in streambank cover vegetation
See Aquatic Habitat and Wildlife Habitat under
the Resource/Water Use column
Public safety
Damage to crops and farmland
Damage to buildings and contents
Reduction of useable land area
Cause
Increased impervious catchment
surface area
Peak discharge, high runoff
volume
High peak discharges and
runoff volumes
Low dry-season groundwater
reserves
Low dry-season groundwater
reserves
Erosion
Suspended solids
Suspended solids
Biodegradable organic material
Urban pollution
Biodegradable organic material
Fecal contamination
Nutrient enrichment
Lower dry season groundwater
reserves
High peak discharges and
runoff volumes
Sedimentation
See Aquatic Habitat and
Wildlife Habitat
High peak discharges and
runoff volumes
Sedimentation
 Source: Homer et.aL (1994).
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Final Report
October 1999
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                     2.0 Environmental Concerns Addressed by the Rule
 2.2.2 Aquatic Life and Wildlife Impacts

 As noted earlier in this chapter, urban storm water runoff is a significant source of water quality
 impairment. As a result, pollutants carried in storm water or the impacts associated with
 increased flows are leading causes of impairment, as summarized in Exhibit 2-2. These
 pollutants and impacts in storm water can have a broad range of interrelated effects on aquatic
 habitats and organisms.


                  Exhibit 2-2. Five Leading Causes of Water Quality Impairment
Rank,
1
2
3
4
5
, Rivers . «"
Siltation
Nutrients
Pathogens
Oxygen-depleting substances
Pesticides
( * Lakes__
Nutrients
Metals
Siltation
Oxygen-depleting substances
Noxious aquatic plants
Estuaries " *t"'
Nutrients
Pathogens
Priority toxic organic chemicals
Oxygen-depleting substances
Oil and grease
  Source: US EPA (1998a).

 Aquatic habitats and organisms can also suffer as a result of changing physical and ecological
 conditions in watersheds. Prior to development, physical and ecological conditions in
 watersheds are in a state of dynamic equilibrium. This means that the physical and ecological
 systems have adjusted to the rainfall patterns and the natural landscape changes occurring in the
 watershed that define natural flows. These flows determine the shape and slope of waterways.
 However, when watershed disturbances occur, such as those associated with development, flows
 are altered. Typically, peak flows increase.  The increase in peak flow causes changes in the
 stream channel morphology and increases the amount of sediment and pollution transported to
 receiving waters. The effects of sedimentation, pollution, and excessive nutrients on habitat are
 discussed below.

 Sedimentation

 The National Water Quality Inventory 1996 Report to Congress identified sedimentation to be
 the leading pollutant or process affecting American rivers.  It is the third leading pollutant or
 process impacting lakes, and the ninth leading pollutant impacting estuaries. Exhibit 2-3
 summarizes the adverse impacts associated with sedimentation and sediment related pollutants as
 presented by Paterson et al. (1993).  The following discussion presents additional studies that
 identify various environmental impacts of sediment related pollution.

 Degradation and destruction of benthic habitat and organisms. When sediment falls out of
 suspension in the water column it accumulates on stream and riverbeds. Many benthic
 organisms depend on certain habitat conditions for survival, such as small crevices between
rocks for protection of eggs and fry or hard substrates for attachment. When sediment covers
 streambeds, this critical habitat can be degraded or destroyed. Sedimentation can smother
organisms such as fish eggs and fry, shellfish, and insects. In addition, many benthic organisms
October 1999
                                       Final Report
2-5
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                                                .,  :    '  • >   ,   '  I!','1   ,    'I   "
                          2.0 Environmental Concerns Addressed by the Rule
               Exhibit 2-3. Impacts Associated with Sediment and Sediment-Related Pollutants
       l^pe of Impact
                                  Comments
  In-stream impacts
  Destruction or degradation
  of aquatic habitat and
  wildlife
 Aquatic wildlife may be adversely affected in a variety of ways. Benthic
 communities may be directly damaged when sediments fall out and blanket the
 community. Benthic macrophytes may be destroyed, and the diversity and
 productivity of such communities may be reduced as a result (Crawford and Lenat,
 1989). High concentrations of suspended sediments may abrade and damage fish
 gills, increasing their susceptibility to infection and disease (Abel, 1989). Survival
 rates for fish eggs may be reduced and spawning areas may be destroyed (West et
 al., 1982). High turbidity levels reduce both plankton and aquatic plant production.
 Nutrient and toxic enrichment of suspended sediments may adversely affect fish and
 other organisms directly and through secondary effects, including food chain
 disruptions, eutrophication, and toxic bioaccumulation/biomagnification effects
 (Simmons, 1987; Novotny and Chesters, 1989).  In addition, a variety of additive,
 antagonistic, and synergistic effects are possible, depending on the types and
 amount of sediment delivered, the physical condition of the water body (e.g., depth,
 temperature, pH, and salinity), and the existing biological conditions (e.g., richness
 and diversity) (Mason, 1981).
  Accelerated loss of storage
  in lakes and reservoirs
 Accelerated deposition of sediment may reduce the effective life of water storage
 reservoirs by filling dead and active storage areas more rapidly than anticipated
 (Crowder,  1987). This problem tends to be most pronounced in smaller reservoirs
 and in regions with naturally high rates of erosion (Bendy, 1968).
  Increased navigational
  obstruction and craft
  deterioration
 Sedimentation of harbors and navigational channels reduces the shipping and
 boating capacity of those facilities, increases the likelihood of accidents, and
 requires expensive dredging to keep those facilities usable. In addition, suspended
 sediments may accelerate the wear and maintenance requirements for ship
 propellers and cooling systems of marine motors (Clark et al., 1985).
  Diminished water
 recreational experiences
 Sediment pollution may dimmish, inhibit, or endanger water-related recreational
 activities. Excessive turbidity and sedimentation may contribute to boating,
 swimming, and diving accidents by obscuring submerged hazards or as a result of
 shoaling. In addition, sediment pollution may also decrease the quality of sport
 fishing by reducing fish populations, displacing more highly valued game fish with
 ess desirable but more sediment-tolerant species, and turbidity may decrease the
 opportunities for making a catch (Clark et al., 1985).
  deduced aesthetic and
 preservation values
Aesthetic and preservation values are those that people gain through indirect use
and the knowledge that uses are available for themselves, for future generations, or
 ust existent (Walsh et al., 1984).  Most water-related recreational activities involve
people picnicking, walking, or playing near the water.  Turbidity and sedimentation
may diminish the indirect water recreational experience as a result (Clark et al.,
1985). Likewise, people's preservation benefits are diminished when siltation and
turbidity degrade valued water bodies.
  ncreased hydroelectric
  acility impairment
The major concerns for hydroelectric facilities are the loss of storage capacity, the
 >lockage of inflow access for plant generation, and increased maintenance because
of wearing of plant structures and machinery (e.g., the penstock and turbine runner).
Additional concerns include downstream channel degradation and modification due
 o the interruption of natural bedload deposition (Fan and Springer, 1990).
2-6
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                        2.0 Environmental Concerns Addressed by the Rale
              Exhibit 2-3. Impacts Associated with Sediment and Sediment-Related Pollutants
       Type-of Impact
                               Comments
  Accelerated stream bank
  erosion
 Coarse sediment deposits in the form of channel bars often cause nearby bank
 erosion (Neil! and Yaremko 1989). In addition, hydrogeologic alterations caused
 by urbanization and agricultural activities may increase streambank erosion in
 several ways, including: increasing downstream flood peaks; increasing the duration
 of flood peaks (as a result of detention systems); concentrating runoff at unprotected
 points along the bank; and creating obstruction to the flow channel.
  Off-stream impacts
  Increased flood damages
 Sediment pollution can increase flood damages in at least three ways. First,
 aggrading stream and lake beds may increase the frequency and magnitude of flood
 events. Second, the effectiveness of structural flood control devices maybe reduced
 due to loss of flood storage or siltation in structures. Third, sediment may directly
 damage agricultural and urban areas when it is deposited by flood waters in
 structures or on productive lands (Simmons 1987, Clark and others 1985).
  Increased strormwater
  drainage system
  maintenance needs
 Sedimentation in storm water drainage systems and irrigation canals may increase
 localized flooding problems and require more frequent maintenance of such
 facilities (e.g., hydro-flushing) (Porter 1976).
  Reduced Infiltration
Suspended sediment in runoff and irrigation water sources can seal land surfaces,
thereby reducing the infiltration rates. The surface sealant effect and reduced
infiltration rates may have adverse impacts of surrounding vegetation by leaving the
soil too dry, and increase the rate of runoff which in turn accelerates erosion
potential, and reduces aquifer recharge (Guy 1972, Clark and others 1985).
  Increased water-treatment
  costs
Water treatment costs for municipalities and certain industries may be significantly
increased by higher concentrations of suspended sediments. Water treatment
operations may require greater use of chemical coagulants, greater maintenance
filters, and increased chlorination to purify the water (Mason 1981).
  Sedimentation damage due
  to adjacent properties
Property owners downhill of locations undergoing extensive erosion may be
adversely affected by the deposition of alluvium from runoff moving across their
property. Such deposits may damage existing vegetation, soil characteristics,
private drainage works, or structures (Guy 1972).
 Sowce: Paterson et al. (1993). Reproduced with permission.

are filter feeders and sedimentation can interfere with their ability to feed. Lemly (1982)
examined the effects of sedimentation on benthic insect communities in an Appalachian trout
stream. Results of the study show that sediments covered insect body surfaces and respiratory
structures, particularly affecting filter feeding species. Lemly also found a reduction in the range
of the size of benthic matter. Further, Lemly found a decrease of available living space due to
accumulation of sand and silt. Although not established as general water quality standards for
estuaries, biologically based recommendations for maximum total suspended sediment levels
have been made for the Chesapeake Bay (Chesapeake Bay Program, 1991). For example, the
recommendation for the health of the eastern  oyster is 250 mg/L.

Decrease in photosynthetic activity. Increases in turbidity levels not only cloud water, making
it visibly unattractive, but turbidity also decreases light penetration, impairing photosynthesis.  If
photosynthesis is unpaired, then the quantity  of plankton, a primary food source, is reduced. In
Oklahoma farm ponds, clear ponds (< 25 parts per million [ppm] of suspended sediment)
produced eight times as much plankton as did ponds with intermediate suspended sediment
October 1999
                                           Final Report
                                                                    2-7
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                                    2.0 Environmental Concerns Addressed by the Rule
Hi!"
                levels (25-100 ppm) and 12.8 times as much plankton as did ponds with high suspended
                sediment levels (>100 ppm) (Clark, et al., 1985). The recommended maximum total suspended
                sediment level to protect submerged aquatic vegetation in the Chesapeake Bay is 15 ppm
                (Chesapeake Bay Program, 1991).
                                      I:
                                                                	   M   :	,  , .
               Adverse effects on aquatic organisms. As part of an extensive literature review, Makepeace et
               al. (1995) found that turbid water can be detrimental to aquatic biota.  The authors found that
               total suspended solid (TSS) concentration between 25 and 100 mg/L "could reduce a river's
               primary biological productivity by 13% to 50%. Turbidity has also been found to affect the
               ability of organisms dependent on vision to feed. Tor example, in a controlled experiment,
               Gardner (1981) found that increases in turbidity (60 to 150 nephelometric turbidity units [NTU])
               reduced feeding rates of bluegills by 50%. The range hi turbidity studied encompasses that
               typical of North Carolina waters. However, stream turbidity in disturbed watersheds could likely
               exceed these levels (Gardner, 1981). Organisms that rely on vision for courtship may also be
               affected (Clark, et al., 1985). Additionally, turbidity can be abrasive to fish and clog gills,
               affecting mortality (Marsh, 1993).

               Pollutants

               Storm water contains a multitude of pollutants including metals, organics, pesticides, inorganic
               pollutants, and oil and grease.  These pollutants may have chronic or acute affects on aquatic
               organisms. Furthermore, these pollutants can be bound to sediment and accumulate on
               streambeds, leading to bioaccumulation. Field and Pitt (1990) reviewed a three-year monitoring
               study of a creek in San Jose, California and found that organics and heavy metals in the water
               column and sediments were likely responsible for the adverse biological conditions. For
               example, they found four to 60 times greater concentrations of sulfur., lead, and arsenic hi urban
               sediments than in nonurban sediments. In addition, Field and Pitt-found evidence of
               bioaccumulatipn of lead and zinc in many samples of algae, crayfish, and cattails.  The biological
               conditions of the urban creek included a reduction in native fish species, decreased diversity and
               abundance of aquatic taxa, and an abundance of pollutant tolerant species offish and benthic
              , organisms.  Finally, Field and Pitt indicate that the-long term impacts of such pollutants may be
               more important than the short term impacts. They attribute the long term impacts to toxic
               sediments and the inability of organisms to tolerate repeated exposure to toxic contaminants and
               high flow rates.                       .
                                                                 ' '        '     ;[        '            ;  i,
               Excessive Nutrients
                                              •    •                  •   ...  :  '    (.'  .v  •      ':      ':  I'd-1
               Nutrients such as phosphorous and nitrogen are often used as fertilizer and can be contained in
               Storm water runoff from urban areas and construction sites. When a water body receives an
               excessive amount of these nutrients, growth of algae and aquatic plants is stimulated. Like all
               plants, algae require oxygen and when abundant, can decrease the dissolved oxygen available for
               other organisms. In addition, when algae die they sink to the bottom of water bodies, where
               bacteria decompose the algae, depleting dissolved oxygen supplies (US EPA, 1995b). The
               overabundance of nutrients and resulting loss of oxygen, a condition known as eutrophication,
               leads to fish kills and mass mortality of benthic organisms (Water Environment Federation and
              the American Society of Civil Engineers, 1992).
              2-8
Final Report
                                                                                           October 1999
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                     2.0  Environmental Concerns Addressed by the Rule
2.2.3  Small Stream Impacts

Natural stream channel morphology is based largely on the quantity of water and sediment
delivered to the streams (Toy and Hadley, 1987).  Sediment loads can reduce stream depths,
decreasing their retention and conveyance capacity, which can increase flooding (Water
Environment Federation et al., 1992).  Because these changes in morphology increase as
development of a watershed increases, small streams are more susceptible to the adverse impacts
of increased sediments. This is because a given amount of urbanization will affect a greater
portion of small watersheds than large and thus have a greater impact.

Alterations in small stream channel morphology are of concern because they can pose significant
threats to human health and safety, and can also threaten property (Toy and Hadley, 1987).
Furthermore, the habitat provided by small streams can be critical to certain aquatic species.  For
example, small streams provide spawning and rearing habitats for several species of salmon
(Sovern and Washington, 1997).  Because of their size, small stream habitats are especially
sensitive to excessive flows, sediment, and pollution resulting from construction activities and
urban areas. Indeed, Sovern and Washington state that the destruction of small streams caused
by urbanization is one significant reason for the decline in salmon populations.

2.3  Summary

The literature provides substantial evidence that storm water runoff from construction sites and
urban areas can adversely affect aquatic systems. Runoff from these areas can include litter,
chemicals,  metals, nutrients, pesticides, bacteria, and sediment. In addition to contributing
pollutants,  construction sites and urban areas'contribute to increased flows to receiving water
bodies. The effects of pollutants and increased flows can be detrimental to aquatic organisms
and habitat as well as to human health. The costs and benefits associated with controlling runoff
from these  areas are discussed in greater detail in Chapters 4 and 5, respectively. The resulting
benefits are monetized in Chapter 6.
October 1999
Final Report
2-9
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          3.0 BASELINE FOR ESTIMATING BENEFITS AND COSTS

  Analysis of the potential benefits and costs associated with implementation of the Phase II Storm
  Water Rule requires that a baseline be established.  The baseline provides an initial starting point
  for measuring the incremental cost and benefit of regulatory compliance. This chapter describes
  the baseline EPA established for analyzing impacts to construction activities and municipalities
  regulated by the Phase II rule. It also discusses baseline water quality conditions, including
  water quality.imparrment potentially attributable to Phase II sources.

  3.1    Existing Storm Water Programs

  Analysis of the incremental costs and benefits requires that EPA identify regulatory programs
  that resemble the Phase II program at the federal, state, and local levels.  Those programs with
  the greatest likelihood of overlap with the Phase II program requirements include the Phase I
  storm water program implemented under the National Pollutant Discharge Elimination System
  program implemented by certain authorized states; the Coastal Zone Authorization
  Reauthorization Act Amendments of 1990 program for the control of nonpoint source pollution;
  and state and local erosion and sediment control programs.

 3.1.1  Phase I Storm Water Program

 Some states that are authorized to regulate storm water discharges under the National Pollutant
 Discharge Elimination System (NPDES) program have chosen to implement more stringent
 requirements than those required by the Phase I rule (55 FR 47990, November 16,1990).
 Specifically, a few states have expanded the Phase I storm water universe to include sources that
 would otherwise be regulated under the Phase II program. This includes lowering the five acre
 minimum size threshold for regulation of construction activity and designating certain "small"
 municipalities, thus mandating their participation in the Phase I storm water program. EPA does
 not include Phase I communities in the Phase II universe.

 3.1.2 CZARA Program

 The Coastal Zone Authorization Reauthorization Act Amendments of 1990 (CZARA)
 established requirements for states located in the coastal zone to implement controls that manage
 nonpoint source runoff. This includes the implementation of an enforceable erosion and
 sediment program for the control of runoff from construction sites disturbing less than five acres
 of land. The Phase II rule establishes similar requirements for owners and operators of
 construction sites that disturb between one and five acres.  The overlap between the two
 programs is restricted to the implementation of erosion and sediment controls, or storm water
 BMPs. Additional requirements established by the Phase II program include the development of
 a storm water pollution prevention plan, inspections and regular maintenance of the controls, and
the  submittal of a notice of intent to be covered by the general permit and notice of termination.

In the analysis that accompanied the proposed rule, EPA included costs for sediment and erosion
controls in coastal areas because programs developed under CZARA were not yet implemented.
Since the proposed rule, states have more fully implemented sediment and erosion control
programs recommended through CZARA. EPA assumed that where state programs are as

October 1999                           Final Report      ~
3-1
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                      3.0 Baseline for Estimating Benefits and Costs
stringent as Phase II and applied as the primary enforcement tool for regulating construction site
runoff the Phase II rule will not add incremental costs of benefits. Therefore, costs and benefits
associated with implementing Phase II have not been analyzed for the coastal zones in ten states
that have mstitute4 such sediment and erosion control programs in response to CZARA:
Delaware, Florida, Maryland, Massachusetts, Michigan, New Jersey, Pennsylvania, Rhode
Island, South Carolina, and Virginia.

3.1.3  State and Local Erosion and Sediment Control Programs

A number of states (including the District of Columbia) and one territory require erosion and
sediment controls, irrespective of CZARA, on construction sites that disturb less than five acres
of land. For example, North Carolina's Erosion and Sediment Control Act of 1973 requires
BMPs for all construction sites of one or more acres while West Virginia regulates sites that are
three or more acres hi size. States with established erosion and sediment control programs are
Shown in Exhibit 3-1.  EPA accounted for these programs by not estimating benefits or costs
associated with erosion and sediment controls for sites regulated by an equivalent program.

In addition to federal and state programs, some municipalities have developed local programs
that require the owners or operators of construction sites disturbing less than five acres of land to
implement erosion and sediment controls although the extent of these programs is unknown. A
recent study by the Center for Watershed Protection (1997) reported survey responses from 113
locaies with erosion and sediment control programs (a 52% response rate). This survey indicated
that 27% of the responding locales required erosion and sediment controls on construction sites
disturbing less than 0.5 acres of land and 43% required erosion and sediment controls at
construction sites disturbing between one and five acres of land.  However, EPA does not know
the extent to which these local programs are similar to Phase II. Therefore, EPA chose to assume
that there are no pre-existing local programs that duplicate Phase II requirements.

3.2    Population
      i ' '   'i   ,        |%1      '	li,;  ,. .• 	•••  : '   •   .  '•'   •:	! '  '.•?"!'       I  '••   !   i. '   ,     ,,-,,( ;:;"
To estimate the benefits of the Phase n rule, EPA used the most current estimate of the 1998 US
population: 270 million residents with 2.62 persons per household (US Census Bureau, 1998a).
These figures yield an estimate of 103 million households nationwide. However, to estimate the
potential compliance costs of the Phase II rule, EPA needed to identify the sewered population.
EPA used the most recent sewered population estimate from 1993 of 227.8 million persons (US
Census Bureau, 1993) and assumed that this population represents the 1998 sewered population.
In addition, EPA needed to estimate the population residing in automatically designated Phase II
communities. To accomplish this, EPA used 1990 estimates of the urban population and US
Census Bureau projections of the year 2000 population to arrive at  1998 estimates. The 1998
estimate Is 85.2 million persons which is equivalent to 32.5 million.households.  Assuming that
the automatically designated Phase II population is entirely sewered, EPA estimates that 37.4%
of the total sewered population resides hi these Phase II communities.  The estimates of the
population residing in Phase II communities excludes residents in communities with pre-existing
equivalent municipal programs. Exhibit 3-2 presents a summary of the above estimates. The
exhibit also reports the estimates for the potentially designated Phase II population which are
households in unurbanized areas.  These households represent an additional 5.2% of the US
sewered households.
        	f,.
3-2
Final Report
                                                                            October 1999
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                            3.0 Baseline for Estimating Benefits and Costs
               Exhibit 3-1. States and Territories Requiring Erosion and Sediment Controls at
                                 Construction Sites of Less than Five Acres
~ •£ * ,^» • ~ 5J& K^ * %. * V
,-r "" f - * v _ _- t i f t <
' ~ . ^. * ->,'""_ " *
*|^ „ J State or Territory
Connecticut
Delaware*
District of Columbia
Florida*
Georgia
Maryland*
Massachusetts*
Michigan*
New Hampshire
New Jersey*
North Carolina
Pennsylvania*
Puerto Rico
Rhode Island*
South Carolina*
Virginia*
West Virginia
Wisconsin
Minimum Construction Site Size
~ ' " -, Requiring ControfcT
* ;'^ ' (Acres, Unless Specified)
0.5
5,000 (square feet)
50 (square feet)
0
1.1
1
0.5
1
50,000 or 100,000 (square feet)
5,000 (square feet)
1
O1
900 (square meters)
0
O2
2,500 or 10,000 (square feet)
3
1.5 acres for residential development
3 acres for commercial development
  'All earth-moving activities.
  2Any activity.
  *denotes CZARA
October 1999
                                             Final Report
3-3
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                                                                                       ill-ill I'1""
                       3.0 Baseline for Estimating Benefits and Costs
                                    !' ' , 11 "    •  •  '.jiii  i. • '"     :  "    ' • I    'I      ' "i
           Exhibit 3-2. Municipal Households Potentially Regulated Under the Phase II Rule
< t *
.-','',' , Community Type - <
Urbanized Place, County, Minor Civil Division1

Unurbanized Place, County, Minor Civil Division3
Total
Households * /
32,458,3652

4,539,440
37,062,643
Percent of US Sewered
Households
37.4%

5.2%
37.4%-42.6%
 'Automatically designated.
 2Based on a population estimate of 85,189,912 and 2.6246 persons per household. EPA used this estimate of households in
 the cost analyses because it reflects those households which may bear the costs of implementing a municipal program.
 'Potentially designated.
 Source: US Census Bureau (1998a).

3.3    Phase H Construction and Land Development Activities

To estimate the percent of construction and land development activities (see Section 3.4 below)
that may be affected by the Phase II soil erosion control provisions, EPA first developed an
estimate of the percentage of construction starts on one to five acres using data collected from
fourteen areas of the country: Tucson, Arizona; Fort Collins, Colorado; New Britain,
Connecticut; Tallahassee, Florida; South Bend, Indiana; Gary and Raleigh, North Carolina;
Baltimore County and Prince Georges County, Maryland; Austin, Texas; Loudon County,
Virginia; and Lacey and Olympia, Washington; and Waukesha, Wisconsin.  EPA then multiplied
this percentage by the number of building permits issued nationwide to determine the total
number of construction starts occurring on one to five acres nationwide. Next, to isolate the
number of construction and land development activities regulated by Phase II, EPA subtracted
the number of activities regulated under equivalent programs. Exhibit 3-3 shows that
approximately 110,000 sites may be affected by this provision by site size; this estimate excludes
approximately 19,500 sites that EPA estimates will qualify for waivers. Dividing this number by
the estimated total number of 521,000 construction starts nationwide for 1998 indicates that
21.1 % of construction starts may be regulated under this provision of the Phase II rule.  This
methodology is presented in detail in Appendix B—2.

Exhibit 3—3 also shows the cumulative percentages for regulating all sites equal to or greater than
each of the size categories shown.  For example, if all sites regardless of size were regulated,
then 100% of disturbed area and sites would be regulated. By lowering the compliance threshold
from five acres to one acre of disturbed area, the Phase II rule effectively raises the share of
regulated sites from 36% to 75%, and the share of total  disturbed area from 78% to 98%.
3-4
Fined Report
October 1999
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                          3.0 Baseline for Estimating Benefits and Costs
       Exhibit 3-3. Estimated Number of Total Construction Starts and Construction Starts Potentially
                        Affected by the Phase II Soil Erosion Control Provision1
•s -T, ,
t~ ** b;
*" * ^t *" 2 * r _j * , •*•
- l','^ " * _<•"*.'  *" Y ^-fc'V.V
'' • ^vY '
i i ~- ^ * * ,
*' "-J'' i '*- * * *
Area Acreage
Less than one acre
One to two acres
Two to four acres
Four to five acres
More than five acres
Total

>• ,3- ™ f
•* v p.
*.
Total National,
' 'Starts '
130,328
93,063
79,322
32,557
186,198
521,467
\ ' Construction Starts (1998)*
j, - ^ -vs. -*> , ^
* V-
Incremental Starts
Potentially Affected '
. by the Phase H
Rule2^ " -' '
0
52,426
41,389
16,408
0
110,223
" Total-Percentage of
National Disturbed
Area Controlled by
, Regulating All
. - * Sites
100%
98%
92%
84%
78%
na
Total
Percentage of
National .,
Starts
Regulated
100%
75%
57%
42%
36%
na
  Detail may not add to total due to independent rounding.
  'The area acreage values reported in the table correspond to values established for the model sites described in Chapter 4, and
   represent the following acreage ranges: one acre, one- to two-acre starts; three acres, two- to four-acre starts; and five acres
   four- to five-acre starts.                                                                        '
  Starts in States with equivalent Erosion and Sediment Control Programs have been removed.
  3EPA estimates that of the approximately 129,675 Phase II construction starts estimated for 1998,19,452 (15%) would
  qualify for a waiver from program requirements. The remaining 110,223 would require erosion and sediment controls.

 3.4    Water Quality

 Analysis of the incremental benefits of the rule required that EPA characterize existing water
 quality and the relative impact of Phase II sources on water quality. The National Water Quality
 Inventory Report to Congress (US EPA, 1998a) is the only national comprehensive source of
 data characterizing the extent and sources of impairment of the nation's waters.  These data,
 often referred to as "305(b) data," are reported biennially by states, territories, and tribes as
 required under Section 305(b) of the CWA. The 1998 Report to Congress is based on water
 quality data from 1994-1995. For the purposes of this analysis, EPA assumed that current water
 quality is reflected in the current 1998 Report to Congress.

 The 305(b) data identify the designated uses of the waterbodies surveyed by the states.
 Designated use categories include aquatic life support, fish consumption, primary contact
 (swimming), secondary contact (boating), drinking water supply, and agriculture.  States then
 compare monitoring data with numeric criteria established for each designated use to classify
 these waters as fully supporting, threatened, or  impaired.  Threatened waters are defined as
 waters that support beneficial uses now but may not in the future unless action is taken.  Impaired
 waters are the sum of waterbodies partially supporting or not supporting then- designated use.
 Exhibit 3-4 presents a summary of the water quality data provided in the most recent 305(b)
 data. In addition to general water quality impairment, the National Water Quality Inventory
provides the percentage of surveyed waters considered impaired by designated use. These data
are presented in Exhibit 3-5.
October 1999
                                         Final Report
3-5
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                          3.0  Baseline for Estimating Benefits and Costs
  3.4.1 Water Impaired by Urban Wet Weather Events

  The 305(b) data also identify the sources of water quality impairment. As shown in Exhibit 3-6,
  urban storm water runoff ranks as the second leading source of impairment to estuaries, the third
  leading source of impairment to lakes, and the fifth leading source of impairment to rivers. In
  addition to this mformation, the 305(b) data also provide the percentage of all waters where
  various pollution sources cause major impairment The sources of pollution that are relevant to
  the Phase II rule are urban runoff/storm sewers, construction and land development. The
  contribution of these sources to water quality impairment are summarized in Exhibit 3-7.

                              Exhibit 3-4.  Summary of Assessed Waters
WaterbodyType ,-.
Rivers and Streams
Lakes, Ponds, and
Reservoirs
Great Lakes
Estuaries
Number of Miles'
Total
3,600,000
41,600,000
5,521
39,839
- Surveyed
693,905
16,800,000
5,186
28,818
Assessment of Designated Use Attainment2
-Supporting
56%
51%
2%
58%
Threatened
8%
10%
1%
4%
Impaired
36%
39%
97%
38%
i>
   'Lakes, ponds, and reservoirs are measured in acres; Great Lakes are measured in shoreline miles; Estuaries are measured in
   square miles.
   ^Percent of surveyed miles.
   Source: USEPA(1998a). Reflects monitoring from 1994 and 1995.
 3-6
Final Report
October 1999
      	£-/
-------
                         3.0 Baseline for Estimating Benefits and Costs
                     Exhibit 3-5. Summary of Assessed Waters by Designated Use
-.-'j.V* y*
Waterbody
Rivers
Lakes, Ponds, and
Reservoirs
Great Lakes
Estuaries

- , * Designated
" f i'r" --Use
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
Aquatic Life Support
7ish Consumption
>rimary Contact — Swimming
Secondary Contact — Boating
Aquatic Life Support
7ish Consumption
Shellfish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
Miles/Acres"
Assessed , >
641,611
316,811
332,152
200,641
14,200,153
10,896,449
15,369,354
8,306,333
5,186
5,186
5,186
• 4,844
23,921
15,821
16,567
24,087
14,086
Percent of Miles/
Acres Impaired
32%
17%
21%
20%
31%
35%
25%
25%
72%
98%
4%
4%
30%
24%
28%
16%
24%
 Source: US EPA (1998a).
       Exhibit 3-6. Leading Sources of Water Quality Impairment Related to Human Development
Rank
1
2
3
4
5
.'.., ' .. '- ^Rivers"*""/' .,!',, „•' ,
Agriculture
Municipal sewage treatment plants
Hydrologic/habitat modification
Resource extraction
Urban runon7storm sewers
:' : -Lakes __; ", "„ ^ _,"
Agriculture
Unspecified nonpoint sources
Urban runoftv'storm sewers
Municipal sewage treatment plants
Hydrologic/habitat modification
*> ' ",v . •-. H.,'-."- "•.-",'* •"*""-!- *-k_
-:« i '• - : ,-j!Estuanes .-/ C'- tf^-/
Induslrial point sources
Urban runon7storm sewers
Municipal sewage treatment plants
Agriculture
Combined sewer overflow
 Source: US EPA (1998a).
October 1999
Final Report
                                                                                           3-7
-------
                        3.0  Baseline for Estimating Benefits and Costs
                       Exhibit 3-7. Major Impairment by Pollution Source
">;:; , 	 !1 i '••• '
"1 : , 1 , " 1 It ,
! Source of Impairment
Urban RunofG'Storm Sewers
Construction
Land Development
•' " Percentage of Miles/Acres Impaired
Rivers and,
Streams
3%
1%
1%
Lakes, Reservoirs
and Ponds
6%
2%
0%
Great
Lakes
1%
1%
0%
Estuaries
11%
1%
0%
 Source: USEPA (1998a).

 3.4.2  Waters Impaired by Phase II Sources

 To establish the baseline water quality impairment potentially attributable to Phase II sources,
 EPA. first nee,4ed *9 determine the percentage of the nation's waters impaired by the three
 relevant sources of pollution. However, the 305(b) data characterize only the impairrnent of
 surveyed (assessed) waterbodies. Therefore, to establish a baseline representing all waters, EPA
 assumed .that:|he 305(b) impairment data characterize all US waters. EPA then multiplied by the
 percent of waters that suffer impairment where the major cause of that impairment is due to
 urban runpfi7storm sewers, construction, and land development as presented in Exhibit 3-7.  As a
 result, the percent of aquatic life impairment in rivers and streams for which Phase II urban
 runofiv'storm sewers are the major cause of impairment is as follows:

        (% of waters impaired) x (% of waters impaired by urban runoff/storm sewers) or
                                  (32%) x (3%) = 0.96%

 The results of these equations are presented in Exhibit 3-8.
3-8
Final Report
October 1999
                                                                                      ! "
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                          3.0 Baseline for Estimating Benefits and Costs
         Exhibit 3-8. Percentages of Waters Impaired by Storm Water Sources by Designated Use
„ ^T. M Designated
A ** * , ^ 7Jc^
S- -j. T*J w ^i £ -r
, Urban Runoff,4"
Storm Sewers" * '
i,~) ,. * ™> r „. * * \
"Construction
y
f
Land
Development
Rivers and Streams
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact— Boating
0.96%
0.51%
0.63%
0.60%
0.32%
0.17%
0.21%
0.20%
0.32%
0.17%
0.21%
0.20%
„ * " _ * ",~" Lakes, Ponds, and Reservoirs ^ ' 4 "t
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
1.86%
2.10%
1.50%
1.50%
0.62%
0.70%
0.50%
0.50%
N/A
N/A
N/A
N/A
**A *jr "r-J ' -*" ' -1-- "GreatI^kesShore|me; '^ ''.*•% , - *" ' ^^!4^J:1
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
0.72%
0.98%
0.04%
0.04%
. 0.72%
0.98%
0.04%
0.04%
0.00%
0.00%
0.00%
0.00%
.,. i, .>."',. . ., *.-v ^BA«fcS;/,,:/v^-;. -\ \ v. , ;.fc:&tf*t.
Aquatic Life Support
Fish Consumption
Shellfish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
3.30%
2.64%
3.08%
1.76%
2.64%
0.30%
0.24%
0.28%
0.16%
0.24%
N/A
N/A
N/A
N/A
N/A
 Source: US EPA (1998a).
 Note: N/A = Not Available

Using the percentages of impairment presented in Exhibit 3-8, EPA approximated the proportion
of impairment specifically attributable to Phase II sources by examining the relevant municipal
population and construction activity. Phase II municipal programs may be instrumental in
improving waters impaired by urban runoff and storm sewers.  As discussed in Section 3.2,
37.4% of the population resides in automatically designated Phase II municipalities. Multiplying
the percent of waters impaired by urban runoff and storm sewers, shown in Exhibit 3-8, by
37.4% yields estimates of impairment caused by those Phase II municipalities.1  The equation for
1 To the extent that potentially designatedmunicipalities do indeed become part of the Phase II municipal universe, the
percentage of the population residing in Phase II municipalities  will increase. This will increase the percentage of
waters impaired by the Phase II municipalities as well as both the benefits and costs of the rule. Likewise, to the extent
that Phase II municipalities with populations less than 1,000 are waived from the Phase II rule, the percentage of
population residing in Phase II municipalities will decrease. This will decrease the percentage of water impaired by the
Phase II rule as well as both the benefits and costs of the rule. EPA expects that the increases or decreases hi the
benefits and the costs will be proportional.
October 1999
Final Report
                                                                                            3-9
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                                                                   i	:	
                         3.0 Baseline for Estimating Benefits and Costs
   the impairment of aquatic life support in river and streams caused by Phase II urban runoff/storm
   sewers is:
	in"       i   ,    ••          	            „,         ,  .£     ',.   . . . 	 , _ | ,.,;•-,] <•, ,   ;,   ,  ,	  t   \ -'•
   (% impairment caused by urban runoff/storm sewers) x (% of population residing in Phase II
   municipalities) or
                                 (0.96%) x (37.4%) = 0.36%
Si11              I"    I	   ,!                     :;           '.       ' 1 '• i  ', ,'    ,!      !,„   '   j 'I..'1"
   The results are presented in Exhibit 3-9.
              1 ;i      '   ' ••.' • . •<             ,      , v i    .  • ,"•'•"    ,  )••'   • •      •'    	 •'  i .Jin
   Similarly, Phase II construction site controls may be instrumental in improving waters impaired
   by construction and land development activities. Multiplying the percent of waters impaired by
   construction and land development shown hi Exhibit 3-8 by 24.9% (the percentage of Phase II
   construction starts, see Section 3.3) results in estimates of impairment caused by Phase II land
   disturbing activities. For example, the calculation for the impairment of aquatic life support hi
   river and streams caused by Phase ll construction is:

           (of impairment caused by construction) x (% of Phase II construction starts) or
                                 (0.32%) x (24.9%) = 0.08%.

   These results are also shown in Exhibit 3-9.

   3.5    Potential Limitations Associated with the Baseline Assumptions
                 11.      •	             .,   •    >:•:. ••.,••.  .•    ,	  : i  -       :•  „      , ••,.   )•,...
               P1, '      ,  	I	 ,       •               I    .''• '  !::' ,   •,   I    ' .   . .      v •  .   |
   There are a number of potential limitations associated with the analysis of existing programs and
   water quality in terms of providing a baseline for estimating benefits and costs. Although
  uncertainties exist in terms of defining the potentially regulated universe, the most difficult
   issues may be associated with assessing water quality.  One limitation associated with use of the
  305(b) data is that they are collected by numerous individuals with, varying levels of expertise.
  That is, each individual applied his or her own judgment concerning interpretation of the survey
  instructions and findings.  Another limitation is that the 305(b) surveys cover only a portion of
  the nation's waters, as indicated in Exhibit in 3-4.  Therefore, EPA's assumption that 305(b) data
  characterizes the impairment of unassessed waters may or may not be accurate! In addition,
  these data reflect water quality in  1996 which may not be fully representative of current
  impairment levels.
                                                                                        i11	'
                                                                                  ') "    1  ,i,l!lk 'II
  3-10
Final Report
October 1999
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                          3.0  Baseline for Estimating Benefits and Costs
        Exhibit 3-9. Percent of Waterbody Impairment Potentially Attributable to Phase II Sources
•t &: *
* v ' -
~ DesTgnatedJOtee^
Urban Runoff/
Storm Sewers1
- * * -
Construction2
Land
Development2
Total
Phase n3
„'_-*- * ** " ' L o s*4 ' Rivers and Streams * * ^ J*/^ " „ *
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
0.36%
0.19%
0.24-%
0.22%
0.08%
0.04%
0.05%
0.05%
0.08%
0.04%
0.05%
0.05%
0.52%
0.28%
0.34%
0.32%
_,,.,,; -,-1 > _t ».! _ ^ * - 1 . Lakes, Ponds^andHeserypirs ^ jj #, ^ ^ s t
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
0.70%
0.79%
0.56%
0.56%
0.15%
0.17%
0.12%
0.12%
N/A
N/A
N/A
N/A
0.85%
0.96%
0.69%
0.69%
y* '-..-•'•' K^^rt^^A' i»:it&vt ; - 7/i
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
0.27%
0.37%
0.01%
0.01%
0.18%
0.24%
0.01%
0.01%
0.00%
0.00%
0.00%
0.00%
0.45%
0.61%
0.02%
0.01%
•, •>* ~ -^^-F-"-!^ ' I I *
i, -- - ' * -Estuaries _ ,--» i ^, , »
Aquatic Life Support
Fish Consumption
Shellfish Consumption
Primary Contact — Swimming
Secondary Contact — Boating
' 1.23%
0.99%
1.15%
0.66%
0.99%
0.07%
0.06%
0.07%
0.04%
0.06%
N/A
N/A
N/A
N/A
N/A
1.31%
1.05%
1.22%
0.70%
1.05%
 'Calculated by multiplying the percentages in Exhibit 3-9 by 37.4%.
 to aquatic life support in river and streams is: (0.96% ) x (37.4%) =
 Calculated by multiplying the percentages in Exhibit 3-9 by 24.9%.
 to aquatic life support in river and streams caused by construction is:
 to rounding.
                 For example, the calculation for impairment
                0.36%.  Results subject to rounding.
                 For example, the calculation for impairment
                (0.32%) x (24.9%) = 0.08%. Results subject
October 1999
Final Report
3-11
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'11' ;;
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        4.0  POTENTIAL COSTS, POLLUTANT LOAD REDUCTIONS,
                           AND COST EFFECTIVENESS

 Based on internal review and comments received from the public on the EA that accompanied
 the proposed Phase II rule, EPA initiated several additional data collection activities and analyses
 to enable it to better estimate the incremental costs and pollutant loading reductions associated
 with the Phase II rule.  This chapter describes these activities and analyses and presents revised
 estimates of costs and pollutant loading reductions. Specifically, Section 4.1 provides an
 overview of the methodology and discusses changes from the EA that accompanied the proposed
 rule. Section 4.2 discusses the revised analyses for estimating potential costs and presents the
 total costs-for the Phase II rule, and Section 4.3 provides a summary of the results.  Section 4.4
 presents the potential pollutant loading reductions reflected in the revised analyses.  Section 4.5
 presents the results of an analysis of the cost effectiveness of the final rule. Section 4.6 presents
 the results of sensitivity analyses performed to evaluate the potential impact of several major
 assumptions used for the cost analysis. Finally, section 4.7-provides conclusions.

 4.1   Overview of Methodology

 This section provides an overview of the methodology used to estimate costs and pollutant
 loading reductions for both municipalities and construction sites subject to the final Phase II
 rulemaking. In general, the same approach that was used to estimate costs for the proposed rule
 was used for the final rule.  However, additional data were collected, the methodology changed,
 and supplemental analyses were performed to strengthen and facilitate the analysis of the final
 rule.  The specific components of the analysis are discussed below.

 4.1.1  Municipalities

 Municipalities that will be automatically designated by the Phase II rule are those that are legated
 in an urbanized area and have a municipal separate storm sewer system (MS4) that serves a
 population of less than 100,000.  The permitting authority may grant a waiver to automatically
 designated MS4s that serve a population of less than 1,000 (see sensitivity analysis number # 5,
 in Section 4.6 for the potential affect of the waiver on the cost analysis). In addition, other
 municipalities with MS4s may be designated by the permitting authority particularly if they have
 a population of at least 10,000 and a population density of at least 1,000 persons per square mile.

 EPA estimated annual per household program costs for 5,040 automatically designated
 municipalities using data from a 1998 survey of municipalities conducted by the National
 Association of Flood and Stormwater Management Agencies (NAFSMA).1 The survey obtained
 cost information from communities that currently conduct activities required by each of the
 Phase II minimum measures. Per household costs were developed by multiplying costs by
 minimum measure per MS4 by the number of persons/household (as indicated by US Census
 data), then dividing by population per MS4. Average costs were calculated for each minimum
'EPA did not include the 27 Federally-recognized Native American Indian Tribes and 39 municipios (Puerto Rico) in
the municipal cost and benefit analysis.  If EPA were to add these Tribal and Territorial governments to the analysis,
costs and benefits would likely increase proportionately.

October 1999                             FinalReport                    '
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              4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	

   •measure, then summed across all minimum measures to estimate costs for whole program
   implementation.
           ,i!   i, ,     •••   ,   ;:  '  ,:•!' ',  . .• • .      •   "  v1  . •  .'. ,: ;,    ' i  •	 .V '   ,     1,1	i. iMt,
   These findings were verified by comparing them to actual storm water program expenditures
   reported by 26 Phase I municipalities. The Phase I municipalities studied were selected because
   of their tenure in the Phase I program and their detailed cost information for Phase I program
   elements! In addition, many of the municipalities examined were smaller cities that more closely
   reflect the population of Phase II municipalities.

   An average annual per household administrative cost was also estimated to address application,
   record keeping, and reporting requirements of the final rule. The average annual administrative
   per household cost was added to the program per household cost to derive a total average per
   household cost. To obtain the national estimate of compliance costs, EPA multiplied the total
   per household cost by the expected number of households in Phase II municipalities.
;', .  ,    '     •  "Ii,      •  ,i»  „ " ,    ,„    i, ,•        ' '  '.',         „  .M.,   •:  , • '!l        • '      '" '    i ', '''

   4.1.2  Construction Site Runoff Controls   .

   The final Phase II rule regulates construction starts disturbing one to five acres of land.
   Specifically, small construction site owners or operators will be required to plan and implement
   appropriate erosion and sediment control BMPs.

   In estimating incremental costs attributable to the final rule, EPA estimated a per-site cost for
   sites of one, three, and five acres and multiplied the cost by the total number of Phase II
   instruction ^fairts in these size categories to obtain a national cost estimate. Several steps were
   involved in obtaining the national estimates and are summarized below.
'••       •     '            '"•     '            "              '
          ':)'
     . , ,       ,            ,      „  ,               ,     .  „,,         .                 .
  EPA use4 building permit information from the US Bureau of the Census and construction start
  data from fourteen municipalities around the country to estimate the number of construction
  starts that would be affected by the Phase II rule. From this information, EPA estimated the
  number of construction starts-disturbing between one and five acres of land.2 EPA reduced the
  construction site universe by 15% to account for those starts that are anticipated to qualify for
  waivers (63 FR 1583).3

  For analysis of per-site costs, EPA created 27 model sites of typical site conditions in the United
  States. The model sites considered three different site sizes (one, three, and five acres), three
  slope variations (3%, 7%, and 12%), and three soil erosivity conditions (low, medium, and high).
  EPA used the WEF database to develop and apply BMP combinations appropriate to the model
  site conditions. BMP costs for erosion and sediment control were estimated for each model site
  using standard cost estimates from RS Means (RS Means, 1997a and 1997b). Based on the
  assumption that any combination of these site factors is equally likely to occur on a given site,
                                                                                         ••,	ii  a
  ''Based on public comments received on the proposed rule, EPA considered including oil and gas exploration sites but,
  upon further review, determined that few, if any, such sites actually disturb more than one acre of land.

  * It should be noted mat to obtain a waiver, construction site owners/operators must certify that they meet certain criteria,
  e.g., the construction activity occurs in an area of negligible rainfall or the permitting authority has completed wasteload
  allocations that are part of total maximum daily loads that address the pollutants of concern.
  4-2
Final Report
October 1999
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 	4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	
 EPA averaged the matrix of estimated costs to develop an average cost for sites disturbing one,
 three, and five acres of land.

 Administrative costs for the following elements required under the Phase II rule were estimated
 per construction site and added to each BMP cost: submittal of a notice of intent (application)
 for permit coverage; notification to municipalities; development of a storm water pollution
 prevention plan; record retention; and submittal of a notice of termination. The total per-site
 costs were then multiplied by the total number of Phase II construction starts disturbing one to
 two, two to four, and four to five acres of land to obtain the national cost estimate.

 EPA also estimated per-site administrative costs for that portion of the construction universe
 expected to qualify for a waiver. These are costs associated with completing and submitting a
 waiver certification form. The per-site waiver costs were then multiplied by the total number of
 Phase II construction sites mat are expected to be waived from the construction program.

 4.1.3   Post-Construction Runoff Controls

 The Phase II municipal program requires municipalities to develop, implement, and enforce a
 program that addresses storm water runoff from new development and redevelopment sites on
 which land disturbance is greater than one acre and that discharge into a regulated MS4. On new
 development and redevelopment sites, EPA recommends that post-development runoff
 conditions should not be different from predevelopment conditions in a way that adversely
 affects water quality.

 While implementation of this rule will likely include a mix of planning, site design, and
 structural approaches, the cost analysis focused on structural controls (installation and
 maintenance of structural best management practices, or BMPs) because development of
 nationally-applicable planning and site design measures was infeasible.

 EPA developed average annual BMP costs for sites of one, three, five, and seven acres. The
 analysis accounted for varying levels of imperviousness that characterize residential,
 commercial, and institutional land uses (i.e., per-site BMP costs are highest for intensely used
 commercial sites (85% impervious coverage), lowest for residential sites (35% impervious
 coverage), and moderate for a mixed category including institutional, commercial, and residential
 uses (65% impervious coverage).

 Using information presented in an EPA Office of Science and Technology study (Preliminary
 Data Summary of Urban Storm Water Best Management Practices, US EPA, Office of Science
 and Technology, December 1998b), EPA developed a combination of BMPs for the model sites
 and calculated costs based on the amount of storm water runoff expected from sites of varying
 imperviousness. EPA then calculated a weighted average BMP cost for each of the model sites.
Per-site costs were adjusted to reflect two factors: 1) a cost reduction associated with the
anticipated use of a nonstructural practice, the redirection of rooftop runoff, and 2) anticipated
cost savings because the new BMPs will reduce peak  storm water flows, allowing developers to
save on construction costs when they build sewer connections.
October 1999
                                       Final Report
4-3
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  	     4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
'( '      ''•..?'	'    ,„,  ..   '" "'.-I!.     ,:  !>         , »•   , :,' 	If.;.  '5'tit	"TTl'.•. •'   """•     j    " 	
  The adjusted per site BMP cost was then multiplied by the total number of construction sites that
  are located in Phase II urbanized areas to obtain a national cost estimate. EPA did not include
  sites that disturb greater than 10 acres in the analysis because the construction general permit
  (CGP) already requires post-construction controls on those sites (63-FR 7858).

  4.1.4  Phase I Industrial Activities
              ;:i        ,.  „ .    I..",,  .   tt.. ;      .....    '  ''  '        li      "'   .'..'"     "'      I
  The proposed Phase n rule included a no exposure exemption for Phase I industrial sources
  which stated that if an industrial facility could show that no materials or material
  handling/processing activities were exposed to storm water, then the industry would be exempt
  from Phase I permit requirements (63 FR 1536).  EPA assumed that no costs would be associated
  with this exemption provision. EPA included this exemption in the final Phase II rule and
  maintained the same assumption. Estimated cost savings resulting  from the no exposure
  exemption are presented in Chapter 9.

  4.2    Analyses of Potential Costs

  This section provides a detailed description of the procedures used to estimate the potential
  incremental costs of the Phase n rule and presents per household municipal costs, per site
  construction costs, per site costs for post-construction controls, costs to state and federal
  agencies,  and national cost estimates. Assumptions used and limitations of the analyses are also
  described

  4.2.1  Municipal Costs

  National Phase II municipal cost estimates are a function of the number of entities to be regulated
  and unit costs. EPA estimated national municipal costs by determining the number of
  municipalities that would need to apply for a Phase II storm water permit, estimating the number
  of households m the Phase II municipalities, and developing unit costs for compliance. The .
  following section discusses how EPA estimated national compliance costs for municipalities.

 Phase II Municipal Universe

 EPA verified the Phase II municipal universe by reviewing a current list of US Bureau of the
 Census municipalities meeting the definition of a Phase IIMS4, i.e., a municipality located in an
 urbanized area that has an MS4 serving less than 100,000 people, and associated populations.
 All Phase  I co-permittees that meet the definition of a Phase IIMS4 were identified from EPA's
 Phase IMS4 database and removed from the Phase II municipal universe to ensure that no
 double counting of municipalities occurred. The final list is presented in the final rale (citation
 when available). It is important to note that the Phase II universe is dynamic since populations
 change and Phase n municipalities often become co-permittees with Phase I MS4s as individual
 'Phase I permits are issued. Following review of the Census data, EPA estimated the Phase II
 municipal universe to be 5,040 MS4s with a total population of 85 million people and 32.5
 million households (see Chapter 3, Section 3.2).
 4-4
Final Report
                                                                             October 1999
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	   4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	
Establishing Per Household Costs

In order to obtain incremental cost estimates for Phase II municipalities, EPA reviewed a survey
of the Phase II community provided by the National Association of Flood and Stormwater
Management Agencies (NAFSMAO).4 Using the list of potential Phase II designees published hi
the Federal Register (63 F.R. 1616 - 32), NAFSMA contacted more than 1,600 jurisdictions in a
survey mailed on July 31,1998 (see Appendix B-l, Exhibit B-la). The goal of the survey was to
solicit information from those communities about the proposed Phase IINPDES storm water
program. The survey sought to identify current storm v/ater spending levels in Phase II
municipalities as well as to identify future needs for these communities. One hundred twenty-one
surveys were returned to NAFSMA. Fifty-six of those surveys reported cost information that
was used to develop a national snapshot of potential costs for Phase II municipalities.
                          •
Several of the survey questions correspond directly to the minimum measures required by the
Phase II storm water rule. Communities were asked whether they currently conduct those
activities required by the minimum measures, and, if so, annual costs were also obtained. These
costs form the basis for the municipal cost estimate used in this analysis. The survey data covers
the following five minunum measures: public education/outreach, illicit discharge detection and
elimination, construction site storm water runoff control, post-construction storm water
management in new development and redevelopment, and pollution prevention/good
housekeeping for municipal operations. (The NAFSMA survey did not specifically address
municipal costs for public participation. It is EPA's belief that respondents considered public
participation costs as part of public education and outreach efforts.)

The following steps were followed to conduct the analysis:

•     . Raw data was keyed hi from the NAFSMA Phase II Raw Data Report, and re-ordered by
       municipal population sizes. Those respondents without population data were omitted
       from the analysis. Subsets of the respondents were able to provide cost data for each of
       the minimum measures, as shown in Appendix B-l, Exhibit B-lb.
•      Per household costs were calculated by dividing costs per minunum measure per MS4 by
       the population of that MS4, then multiplying the result by 2.62 persons/household.
       Average and percentile costs (0,25%, 50%, 75%, 95%, 100%) were calculated for each
       minimum measure, then summed across all minunum measures to determine hypothetical
       average and percentiles for whole program implementation (see Appendix B-l, Exhibit
       B-lc).
•      One municipality's response to the survey question on municipal runoff control costs
       (question 6) was removed from the data set as a disproportionately huge "outlier" (almost
       15 times the mean cost for all other municipalities and 4 times greater than the next
       highest per capita cost). This is documented hi Appendix B-l, Exhibit B-lb.
4The National Association of Flood and Stormwater Management Agencies is an organization of public agencies whose
function is the protection of lives, property and economic activity from the adverse impacts of storm and flood waters.
The mission of the Association is to advocate public policy, encourage technologies and conduct education programs
which facilitate and enhance the achievement of the public service functions of its members.

October 1999               "              Final Report
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                                                       	'	•'	'•""	I	'	'	
             4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
 The average annual household cost (before accounting for administrative costs) was found to be
 $8.93.     _ :	   ,          '"       .	;"    ,  '   ^       '         '';;'"
  F "••¥  . "*V  1J|"'!      •" ,/' ''    , i*  '   J.-   .'     •   ->  ':    • • *'••••  •'• .  I "  .  "   -it '  .   ,'    • • i "
   „: 	 .  ; i   'iii    ,        .1 "             , ' • ,          ,„   •,;	i .  .  •  ih- •   •              .'•!.•'
 In addition to expenditures associated with implementing Phase II program elements, Phase II
 municipalities will have to comply with administrative requirements.  These include submittal of
 art application for coverage under the Phase II program, record keeping, and reporting. While
 some municipalities may have incorporated these costs into the figures reported in the NAFSMA
 survey, this was not assumed, and EPA therefore developed an additional estimate of
 administrative costs. EPA used estimates provided in the EA for the proposed rule, which were
 based on, US Department of Labor (US DL) wage rates (US DL, 1995) and EPA's "Information
 Collection Request (ICR) for Revisions to the NPDES: Storm Water Discharges" (US EPA,
 1990). EPA used labor hours reported in the ICR and matched the hours to US DL wage rates.
 The wage rates were adjusted to 1998 dollars using the Consumer Price Index. EPA estimated
 municipal application costs, over a five-year permit cycle, to be $805, record keeping  costs to be
 $375, and reporting costs to be $6,445 per municipality.  EPA estimated costs per household
 based on the Phase II municipal population of 85 million, 5,040 Phase II municipalities, and 2.62
 persons per household. Costs were averaged over the five year NPDES permit term to obtain an
 annual administrative cost of $0.23 per household (Exhibit 4-1).
         "              	                         i         I                     i
                           1                                     ii
                  Exhibit 4-1. Annual Municipal Administrative Costs (1998 dollars)
r
Administrative
Requirement
Municipal application
Record keeping
Reporting
Total5
Estimated
Hours Over
Five Years
30
14
240
284
Estimated Annual
Cost Per "
Municipality1'2 ^
$161
$75
$1,289
$1,525
" **
/
Total Annual Cost2-3
$811,440
$378,000
$6,496,560
$7,686,000
Annual CostTer
Household4*,
$0.02
$0.01
$0.20
$0.23
 'Based on a wage rate of $26.86 per hour.
 ^psts were averaged over the permit term of five years.
 3Based oji a universe of 5,040 municipalities.
 4Based on a population of 85 million people and 2.62 persons per household.
 ^Totals subject to rounding.

The annual administrative costs per household were added to the annual per household costs for
the Phase II program elements to obtain a total annual per household cost ranging from $0.42 to
$54.91 for the survey respondents. The mean and percentile range of total annual per household
costs is presented in Exhibit 4-2^

Alternative Approach for Establishing Per Household Costs. As an alternative method and
point of comparison with the NAFSMA-based approach described above, EPA reviewed annual
reports from 35 Phase I MS4s to obtain incremental cost estimates for Phase II municipalities.
Cost data was only available for 26 of those MS4s; EPA calculated annual per household cost
estimates for each of these Phase I MS4s by using actual expenditures reported in their individual
annual reports.  The initial 35 Phase I MS4s were targeted because they had been in the Phase I
program for nearly one NPDES permit term, were smaller cities that more closely reflected the
population of Phase II municipalities, and had detailed data reflecting actual program
4-6
Final Report
October 1999
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 	4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	
 implementation costs.5 EPA extracted costs from the Phase I annual reports for comparable
 Phase II program elements. EPA calculated a total annual cost for each municipality for the
 Phase II program elements.  EPA then divided the annual costs by the relevant number of
 households in each Phase I municipality based on household data from the US Bureau of the
 Census to obtain a per household estimate. After adding annual per household administrative
 costs (see discussion above), annual per household program costs ranged from $0.62 to  $60.43,
 with an average of $9.08, for the 26 Phase I MS4s. The range of costs obtained using this method
 is shown in Exhibit 4-2. The cost range and mean values obtained using this method are similar
 to those found using the NAFSMA survey data.

                            Exhibit 4-2. Mean and Percentage Findings:
       Estimated Annual Per Household Cost of Compliance for Phase n Municipalities (1998 dollars)
^ s^ -*^ > •**&» \ i ^ J* £-
*~~£**v28ff&€~*.* v
^%J55toM««r - ". -,
100m (Maximum)
95th
75th
Mean
50th (Median)
25lh
Oth (Minimum)
_*'»*„" >" -Tg/"""5*?
rv miSMAAiroualPer '^
: iHouiehoireost^f T ^
$54.91
$36.57
$10.40
$9.16
$4.19
$1.32
$0.42
>JPhaseI*Adjusted^ ^
c ^^^ Annual Per
sSt JBfouseholdCost*4 f ± t
$60.43
$42.10
$10.51
$9.08
$2.86
$1.46
$0.62
 'Calculated from NAFSMA 1998 Phase II Survey responses that reported costs associated with implementing one or
 more of five Phase II minimum control measures. Percentiles were each determined per measure, then percentiles
 were added across all measures and sums multiplied by 2.62 people/household.
 2These estimates removed the effect of one disproportionately huge "outlier" (almost 15 times the mean cost for all
 other municipalities and four times greater than the next highest per capita cost) in one municipality's estimate of its
 annual municipal runoff control costs.

 3Costs extracted and adjusted from 26 Phase IMS4 annual reports, considering only those minimum measures for
 which comparable cost estimates could be derived. Thus, the annual per household costs reported for each MS4 is
 the sum of only those measures which the MS4 was implementing when the report was prepared.

 "All costs incorporate administrative costs of $0.23/household, based on Exhibit 4-1.

National Municipal Costs

 To determine potential national level costs for municipalities, EPA divided the Phase II
population (85 million) by the number of persons per household to determine the number of
households in the Phase II universe. The number of households was then multiplied by the per
household compliance cost ($9.16). Exhibit 4-3 shows the annual estimated national Phase II
municipal costs to be approximately $297 million.
5EPA evaluated the annual reports submitted by 35 Phase I MS4s. The 35 annual reports included one MS4, Orange
County, California, with 31 co permittees. Twenty percent of the 35 MS4s have populations of less than 100,000 people
and 74% of the Orange County permittees have populations of less than 100,000 people.
October 1999
Final Report
                                                                                          4-7
-------
              4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
                    Exhibit 4-3.Estimated National Phase II Municipal Annual Costs
'.' '. • "'•'.•-- "I < r , \ %->
Per Household Costs L ^ '
(1998 Dollars) """ ' *
$9.16
- • » « .
Total Number of Households in
- Phase H Municipalities1
32,458,365
Estimated National Phase U
Municipal Annual Cost
(1998 Dollars) ''"_]'
$297,318,623
   1 See Chapter 3, Section 3.2, for description of methodology used to determine the Phase II municipal universe.
  4.2.2  Construction Costs

  The Phase II rule includes two provisions that may result hi additional costs to the construction
  community. The first provision requires the owners and operators of construction sites
  disturbing one to five acres of land to plan and implement erosion and sediment control BMPs.
  Similar tjp the national municipal cost estimates, EPA first estimated the universe of construction
  starts that would be required to submit an application for a storm water permit and then estimated
  unit costs (compliance costs) for each site to comply with the regulatory requirements. EPA also
  estimated the universe of construction starts that would qualify for a waiver and then estimated
  per site administrative costs (waiver costs) associated with obtaining a waiver. The following
  sections describe how'"EPA estimated national construction costs for sites disturbing between one
  and five acres of land and provide cost estimates for this measure.
'T. '        	t'i  'v1   	        >: ."   '••    ' ;•"  "    .  ' . . '" :i''  :PI;	   ' I. "     . • ,  '   i  •   ., :..  t
  The second provision requires the implementation of post-construction storm water runoff
  controls on construction sites located hi Phase II municipalities. The Phase II municipal program
  requires municipalities to develop, implement, and enforce a program that addresses storm water
  runoff from new development and redevelopment sites on which land disturbance is greater than
  one acre and mat discharge into a regulated MS4  EPA estimatecl uicreniental costs attributable
  to the post-construction runoff control measure. To develop a cost estimate associated with this
  measure, EPA estimated a per site BMP cost, rncluding operation and maintenance, for 12 model
  sites of varying size and imperviousness. The per site BMP cost was then multiplied by the total
  number of multi-family, institutional, and commercial construction starts that are located in
  Phase II urbanized areas to obtain a national cost estimate.

  Erosion and Sediment Control Costs

  Phase II Construction Universe. For the final Phase II rule, EPA expanded the Prince
  George's County estimates of construction starts by collecting additional data. EPA conducted
  an extensive search to identify municipalities that record the area disturbed for each construction
  site and the number and types of structures (single family dwelling, townhouses, etc.) constructed
  in each development. The municipalities contacted include:
     Amarillo,TX
     Arvada, CO
     Atlanta, GA
     Austin, TX
     Baltimore County, MOD
     BeUrngham, WA
     Bismarck, ND
Boise, ID
Boulder, CO
Bozeman, MT
Canton, OH
Cape Girardeau, MO
Carbondale, IL
Cary,NC
Cedar Rapids, IA
Cheyenne, WY
Columbia, MO
Dane County, WI
Davenport, IA
Denver, CO
Douglas County, CO
  4-8
      Final Report
               October 1999
                        f&
-------
           4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
   Duluth, MN
   Durham, NC
   Eureka, CA
   Eugene, OR
   Fairfax County, VA
   Flagstaff, AZ
   Fort Collins, CO
   Great Falls, MT
   Henrico County, VA
   Jefferson County, CO
   Kansas City, MO
   Kenosha City, WI
   Kenosha County, WI
   Lacey, WA
   LaCrosse City, WI
   LaCrosse County, WI
   Leon County, FL
   Lexington, KY
   Longmont, CO
Loudoun County, VA
Madison, WI
Marion County, OR
Milwaukee, WI
Monroe County, NY
New Britain, CT
North Kansas City, MO
Ogden, UT
Oklahoma City, OK
Olympia, WA
Omaha, NE
Overland Park, KS
Owensboro, KY
Peoria, IL
Prince George's County,
MD
Racine City, WI
Racine County, WI
Raleigh, NC
Reno, NV
Rochester, NY
Rochester, MN  .
Rutland, VT
St. Louis County, MO
Salem, OR
Sante Fe, NM
Santa Rosa, CA
Spokane, WA
Springfield, MO
Stark County, OH
Tallahassee, FL
Tulsa, OK
Tuscon, AZ
Waukesha, WI
Waukesha County, WI
Wichita, KS
Of the municipalities listed above, the following fourteen had sufficient data to support the
analysis: Austin, TX; Baltimore County, MD; Gary, NC; Fort Collins, CO; Lacey, WA; Loudoun
County, VA; New Britain, CT; Olympia, WA; Prince George's County, MD; Raleigh, NC; South
Bend, IN; Tallahassee, FL; Tucson, AZ; and Waukesha, WI.

Data collected from these municipalities varied widely in the total number of construction starts
and in the distribution of starts by size category (one- to two-acre, two- to three-acre, etc.).
Municipalities with large land areas and population (Baltimore County, Maryland and Prince
George's County, Maryland) generally recorded a greater number of construction starts than
those with small land areas and population (Lacey, Washington and Waukesha, Wisconsin).
Exhibit 4—4 provides data for some of the factors influencing this range, including population,
percent population growth, median household income, and municipal land area for these
communities.

The Phase II construction start universe was estimated using the number of construction starts
and corresponding disturbed area data collected from the 14 municipalities. The number of
construction starts indicating a disturbance of one to five acres for the 14 municipalities was
totaled and divided by the total number of building permits for those areas (see Appendix B-2).
The resulting ratio was then used to estimate the Phase II construction start universe as described
in Appendix B-2. Exhibit 4—5 shows the results of the data collection effort.
October 1999
      Final Report
                      4-9
-------
                                                                                          	r::,:,:,:	
                                                                                           :i i1.  j.,V'  *••
                4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
                       Exhibit 4-4.  Summary Characteristics of Municipalities Where
                                  Construction Start Data was Collected
i , 4 t j 1 , . t
• i" i » : . • • • , ,-
i| \ i , • ' /' :
Municipality
Austin, TX
Baltimore County, MD
Cary,NC
Fort Collins, CO
Lacey, WA
Loudoun County, VA
New Britain, CT
Olympia, WA
Prince George's County, MD
Raleigh, NC
South Bend, IN
Tallahassee, FL
Tucson, AZ
Waukesha, WI
United States
, },$ ,-s, t~-i « A
Population 1996 /
(Estimates)1 ' ,', '
541,278
720,662
75,676
104,196
27,381
133,493
71,512
39,006
770,633
243,835
102,100
136,751
449,002
60,197
265 million
-'Population
/Growth^
1990 to 1996
+14.7%
+4.1%
+70.5%
+19.1%
+42.0%
+54.9%
-5.3%
+15.6%
+5.6%
+15.0%
-3.2%
+9.6%
+9.1%
+5.8%
+6.6%
Median
Household
Income (1989)
$25,414
$38,837
$46,259
$28,826
$29,726
$52,064
$30,121
$27,785
$43,127
$32,451
$24,131
$34,764
$21,748
$36,192
$35,225
Area •
(Sq.ML)
217.8
599.0
31.2
41.2
10.1
520.0
13.3
16.1
486.0 '
88.1
36.4
63.3
156.3
17.3

IIIJ,
    Source: US Department of Commerce, Bureau of the Census, [http://www.census.gov].
    1 US Census Bureau Data (1996).

  EPA estimates that there were 123,145 Phase II construction starts whicli would incur
  incremental costs for Phase II in 1994.6 The number of potential construction starts was
  increased 1.3% annually to estimate the potential number of starts in year 1998.7 This yields a
  construction start universe of 129,675 (123,145 x l .0134).  As in the EA for the proposed rule,
  15% or 19,452 of those starts are expected to take advantage of the waiver provision in the Phase
  n rule. The construction starts that take advantage of the waiver provision will incur
  administrative costs associated with the waiver. The other 110,223 starts would incur costs
  associated with obtaining a storm water permit.
       methodology for estimating the number of construction starts is provided in Appendix B-2.
          :  . '   ,:.	[          "'I	  ..,•"           ,  <     -	,'i  ;":V"!""!; •„ •?.. ;,:.,	;• ii   s.1	M:1;>••
  permits issued fix>m 1980 to 1994 was 1.3%. This growth rate is used to estimate future construction starts from the
  1994 baseline. However, EPA recognizes the growth rate for construction starts fluctuates yearly and does not
  necessarily increase each year.
  4-10
FinalReport
October 1999
-------
              4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
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                                         Final Report
4-11
   /:
-------
            4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	
       ,1 '•!.	 "",,"1	 •  . •   :,'"'  v  ":-,: ;	K,,:"  ,       "!	i     . •,   ';5'  '. i- ,	'!•••• • „',( •     •• .;• l|; " ,i	•;':'•         . . • I »:',
Per-Site Compliance Costs: Installation and O&M.. To estimate Phase II construction site
     1 !!•«:!!:  	III"!1 I',<„!"yil"" •     ,    	         .. .. ,     ,„..,,  ,    ,,   	i   	     ,    , .  f   		
compliance costs, EPA developed 27 model construction sites in an effort to reflect site
conditions and erosion and sediment control practices throughout the country. The model sites
varied in size (one, three, and five acres), soil erosivity (low, medium., and high), and slope (3%,
1%, and 12%)™  Using guidance contained in US EPA" (1992a), EPA developed combinations of
BMPs for the model sites to.mimic commonly accepted erosion and sediment control practices.
BMPs were selected feased on guidance contained in Brown and Caraco (1997). The types of
BMPs placed on each site varied based on the unique conditions of the site. For example, for
sites with ishallow slopes and low erosivity, few BMPs are required. In contrast, on larger,
steeper, and more erosive sites, more BMPs are needed. Exhibit 4-6 shows the mix of BMPs
selected for the various model sites. In developing the mix for each model site, EPA assumed
that entities, when faced with the need for installation of BMPs, would select the most cost
effective mix of BMPs.  Detailed drawings of the model sites (i.e., site plans), assumptions, and
BMPs that could be used under the Phase II rule are found in Appendix B-3.

Following the development of the model sites, EPA estimated the BMP costs for each site using
RS Means (RS Means 1997a and 1997b).  A description of each BMP used for the model sites,
average price, and efficiency are summarized in Exhibit 4-7. Based on the mix of BMPs
assumed for each model site presented in Exhibit 4-6,  combined with the costs provided for each
BMP hi Exhibit 4-7, EPA derived total estimated costs for each model site (Exhibit 4-8).

                          Exhibit 4-6. BMPs Used for the Model Sites
t f
Site Size (acres)
1
3
5
Soil Erodibility
low
med
high
low
med
high
low
med
high
'Slope _ ' ^ _"/_ ',!"/.,*'„, J,
3%
a
a,b
a,c,e
a,b
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a,c,e
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c,d,e,f,g3
7% ,
a,b
a,c,e
a,c,e
a,c,e
a,c,e
c,d,e,f,g2
c,d,e,f,g3
c,d,e,f,g3
c,d,e)f5g3
12%
a,c,e
a,c,e
c,e,f,gl
c,d,e,f,g2
c,d,e,f,g2
c,d,e,f,g2
c,d,e,f,g3
c,d,e,f,g3
c,d,e,f,g3
 a ** sjlt feijce
 b mmulch
 c = seed and mulch
 d - stabilized construction entrance
 e * stone check dam
 f - earthen dike directing runoff to sediment trap
 g = sediment trap (1=1,800 cf; 2=5,400 eft 3=9,000 cf)
4-12
Final Report
October 1999
                                                               -A.
-------
             4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
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Used to establish a temporary stand of grass. Grass
reduces the velocity of runoff and increases
infiltration while its roots hold soil in place. Mulch
is used to reduce rainfall impact and to hold seeds in
place. Seed and mulch are used on a majority of the
study sites.



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                      4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
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usually on a bed of geotextile fabric. Cause watei
pond behind the structure, thereby reducing the
velocity and force acting on the soil.
Source: US DOT. (1995).
Capture sediment entering the swale from project
grading (activities and serve as a backup to the
stabilized construction entrance, capturing any
sediment washed into the swale from the street.
Superior in removal efficiency and cost to hay bal
check dams because hay bale dams need constant
maintenance, are difficult to install properly, and
frequently fail.
Source: Brown, W. and Caraco, D (1997).


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The dikes appearing on the study
sites are used in place of silt
fence where soil type (clay) or
steepness preclude its use. The
dikes direct flow from the entire
site to either a sediment trap or
detention pond.

0
Ridges of soil constructed to direct the flow of
sediment-laden storm water to a treatment device
area. Usually seeded and mulched if expected to
remain in service for an extended period of time.
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Sediment traps appear on study
sites with steep sites and clay
soils. The traps are placed in the
southeast corner of the site.
Earth dikes convey runoff to the
sediment trap from the upland
areas of the site. The discharge
from the sediment trap is
stabilized with a stone apron.
•8 1 - a
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Designed to intercept and retain runoff from distu
areas for a long enough period of time to allow
suspended sediment to settle out. Best suited for s
construction sites with a maximum drainage area <
five acres. Relatively inexpensive and easy to insi
comparison to other frequently used practices sue!
silt fencing.
Source: Brown, W. and Caraco, D. (1997).


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                                                  -F/na/ Report
October 1999
-------
            4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
                Exhibit 4-8. Estimated Cost of BMPs for the Model Sites (1998 dollars)
#*»? -f »«•¥ rjr-.'Vi V
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•••«1&',*.'.,/<.^;«S. l' .? i'^* ','*
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r £ ^ • * •; . ?" ? sjT* •%*''?*
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•jSoflfErodiBUitjfe
low
med
high
low
med
high
low
med
high
iSls^fc^^^^S^i^SS^SisSiA^Jvrs
'isJ- .; •*. ;•..£ :,?^.% ••' 'V ;,
$1,422
$1,422
$1,799
$6,047
$6,047
$6,047
$9,519
$9,519
$9,519
'\.-.k ". < :• ;•; :•.. .;" v « >i
•.".V';.~, '%.•./-.*••;• * « £ <.*
i :A ra^verage .Cost ^;
$1,206
$4,598
$8,709
EPA attempted to match construction start data collected from the fourteen municipalities to the
model sites; however, data was unavailable on soil credibility or slope. So, EPA calculated an
average cost for each model site size by soil credibility level across the slope categories. To
obtain the average cost for a site size, all values were added across each soil credibility category
(low, medium, or high) for each site size and divided by the number of slope and soil credibility
cost categories.  These values are presented hi Exhibit 4-8.8

EPA developed an average BMP cost for one, three, and five acre starts for all soil credibilities
and 3%, 7%, and 12% slopes. The average BMP cost was estimated to be $1,206 for a one acre
site, $4,598 for a three acre site, and $8,709 for a five-acre site.

Per-Site Compliance Costs: Administrative.  Additional construction costs resulting from
compliance with the final Phase II rule include the following: costs to submit a notice of intent
(NOI)  for coverage under the existing Construction General Permit (63 FR 7858); costs to notify
municipalities about the project; costs for the development of a storm water pollution prevention
plan (SWPPP); costs for record retention; and costs to submit a notice of termination (NOT) at
the completion of the project.  For purposes of estimating costs of the final Phase II rule, these
other administrative costs were based on those presented in the EA for the proposed rule. Each
of these other costs, estimated on a per-site basis, are discussed below.  In analysis of the final
rule, each other per-site cost was summed and added to the average site cost for a total
compliance cost estimate per construction site.
8EPA considered estimating construction costs by weighted average, unfortunately the number of construction starts
for each acre size, soil credibility, and slope is unknown. In the fourteen municipalities in which data was collected
few record slope, but none included soil credibility.
October 1999
Final Report
4-15
-------
                                                                                    •I	I	•
             4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	
  EPA used labor categories and'hourly rates to estimate labor costs for activities by construction
  sources, Trie fully loaded rates in 1998 dollars are $34.19 for engineering assistant, $33.27 for
  drafter, and $22.57 for clerical support (US DL, 1993), (ENR, 1998), (RS Means, 1998). It is
  assumed that an engineering assistant and drafter would work on the development of SWPPP. An
  engineering assistant is assumed to work on the NOI, Notification of Municipalities, and NOT.
  Clerical support is assumed for record keeping.
       '!•:„',,,!lll „. 5.'"3'1'1"1  '''   .Hi1'"'1'    ' 'i'"!!" ''    "            '     ' '   ,     . '        'I .     '   '       i.     | H,l ',„!
                                           -             , ,   „      ,j       •        ,     ; „
  •   NOI Under the Construction General Permit (CGP), owners/operators of construction sites
     must complete an NOI to obtain coverage. EPA estimated the burden for completing the
     NOI form to be 3.7 hours with an associated labor cost of $126.50 (adjusted to 1998 dollars)
     (63 FR 7858).
   „      ,1,    '"I  'I •         ,              •            . i,    , ''i'"'!h   , ,  i  || , , ,      » ,     .1  , ,  | »,,,,  |hii,
                                                                 i
  •   Notification of Municipalities Under the CGP, owners/operators of construction sites must
     notify tihie local municipality that they are operating an NPDES permitted construction site
     within their jurisdiction. EPA estimated the burden to be 6.5 hours and the cost of this
     notification to be $17.10 (adjusted to 1998 dollars).
      	".  "in,-!      '    (i,i ,            .  i,i; i        ,-	  . "...	inn '    ,.",,(      . ":,,, •  ,•  • , , " ,: •: i .,;  ",„
 •   SWPPP Under the final Phase II rule, all construction site owners/operators will be required
     to develop and implement a SWPPP. The requirements for the SWPPP are identical to those
     included in the CGP, except for making the plans available for public review. The SWPPP
     requirements include the following: description of site conditions; identification of controls
     to be used to reduce the offsite transport of pollutants; regular maintenance of controls; and
     biweekly inspections of controls.  Because Phase II construction sites are smaller than those
     regulated under the CGP, EPA assumed inspections will occur on a monthly, rather than a
     biweekly, basis.

 Exhibit 4-9 presents the specific requirements for development and implementation of a SWPPP,
 associated low and high costs to complete each element, and an average cost for development
 and implementation of the SWPPP. In implementing the SWPPP, EPA assumed the life of a.
 construction site to be six months (NAHB telecommunication, July 1998).
                                                                                  1 '' 'I'lrf I ,• :l
                                                                                  .-Vn'ii' I :1,!l,
         ... I1   I' ill „!...
4-16
Final Report
                                                                             October 1999
-------
              4.0  Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
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October 1999
                                          Final Report
      4-17
-------
             4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness _

  •   Records Retention Under the CGP, the owner/operator of a construction site must retain all
     records required under the permit for three years from the date of final stabilization. EPA
     estimated ^the cost for record retention to be $4.51 per site. This assumes that approximately
     0.2 hours would be spent filing documents relevant to the site.

  •   NOT Under the CGP, upon final stabilization of the site, the owner/operator must submit an
     NOT to the permitting authority. EPA estimated the cost for submitting an NOT to be
     approximately $17.10 (adjusted to 1998 dollars) and the burden to  be 0.5 hours to complete
     tEeform.

 From this analysis, EPA estimated total average compliance costs (BMP plus other costs) for a
 Phase II construction site of $2,143 for sites disturbing between one and two acres of land,
 15,535 for sites disturbing between two and four acres of land, and $9,646 for sites disturbing
 between four and five acres of land. A summary of the other administrative construction per-site
 costs is presented in Exhibit 4-1 0.
                      Exhibit 4-10. Estimated Other Administrative Phase II
                            Construction Costs Per Site (1998 Dollars)
; Administrative Requirement
' '"* '" 1' " "' "" m . 	 -'"'l' -«• "it ™" ' l -•-..' - *« VJUW^ ¥** 1
NOI
Municipal Notification
SWPPP
Record Retention
NOT
Estimated Total Cost (per site)
-Cost. , ,f :
$126.50
$17.10
$772.25
$4.51
$17.10
$937.46
       fe ^aijer Cosfs, The permitting authority may waive permitting requirements for Phase
II construction sites under two conditions. Construction sites can be waived if they are either
located in areas with low rainfall potential or if water quality analyses show that there is no need
for regulation. EPA estimated the cost for preparing and submitting a written waiver
certification to be approximately $34.19. The corresponding hour burden is one.

National Construction Costs. EPA's estimate of national level incremental annual costs
combines compliance costs for construction starts that disturb between one and five acres and
administrative costs for construction starts that are expected to qualify for a waiver. To estimate
national level incremental annual compliance costs, EPA multiplied the total cost of compliance,
for one to two acre, two to four acre, and four to five acre sites by the total number of Phase II
construction starts within each of those size categories. Exhibit 4-11 indicates the estimated
construction compliance cost by climatic zone (climatic zones reflect regional variations in
rainfall intensity and amount.) To estimate national level incremental annual waiver costs, EPA
multiplied the total cost of preparing and submitting a waiver certification form by the
Construction universe that is expected to qualify for a waiver. Exhibit 4-12 summarizes the
estimated national construction compliance and waiver costs.
4-18
                                       Final Report
October 1999
-------
             4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
42
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               4.0  Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
                    Exhibit 4-12. Phase II Erosion and Sediment Control Annual Costs
f* ^
» * 41 ( It- tt
Construction Costs
Compliance Costs
Waiver Costs*
Total
* i
- - 7.» 1 *
Universe
110,223
19,452
129,675
Estimated Total National Annual"
Costs (1998 dollars)
$499,771,558
$665,064
$500,436,622
   *Based on an engineering assistant's wage of $34.19 per hour. U.S. Department of Labor, 1996.
i ''!>:   "       iii '   < jiiniii!  ,   i  it ',
'• "i, Post-Cpnstructiotts Costs
  EPA developed an analysis of potential costs to the construction and land development sector
  that may result from post-construction runoff control measures in municipal storm water
  management programs. The analysis and results are described in this section and Appendix B-4.
 ;  ,       , fi «  !„.',«; • ;.   ',,•",  " *  : , .  ,   ',:  ,*!:.;!'   "   ;,i,; "  « ..... .T ,„; ........... in": , •' '. I|!i ..... -if •    I1!"1 i  , ^ ....... ,.' ', ,r  / -   ,i „  •" .....  i., ,i IIP
   '  • '   • i " ....... "  ...................     '!'»  '•  •"" ....... "i" - '»'  •••   " ......... •"   • '" • ......    1'""' 'ui'i!' ......   ••'"•  •" i • ...... •  "'''    • '" ' »  - "•    ..... • »•• J ....... .....
  Cost Analysis Summary. The Phase II municipal program requires municipalities to develop,
  implement, and enforce a program that addresses storm water runoff from new development and
  redevelopment sites on which land disturbance is greater than one acre and that discharge into a
  regulated MS4. EPA did not include sites that disturb greater than 1 0 acres in the analysis
  because the construction general permit (CGP) already requires post-construction controls on
  those sites (63-FR 7858). On new development and redevelopment sites, EPA recommends that
  post-development runoff conditions should not be different from predevelopment conditions in a
  way that adversely affects water quality. Municipalities may select from an array of structural
  and non-structural options in implementing this measure.
       ^               of this rule will likely include a mix of planning, site design, and
  structural approaches, the cost analysis focused on structural controls (installation and
  maintenance of structural BMPs) because development of nationally-applicable planning and site
  design measures was infeasible.' As detailed in Appendix B-4, EPA developed average annual
  BMP costs for sites of one, three, five, and seven acres. The analysis accounted for varying levels
  of imperviousness that characterize residential, commercial, and institutional land uses (i.e., per-
  site BMP costs are highest for intensely used commercial sites (85% impervious coverage),
  lowest for resi4ential sites (35% impervious coverage), and moderate for a mixed category
  including institutional, commercial, and residential uses (65% impervious coverage). Exhibit
  4-13 summarizes the weighted average total per-site costs for each of the modeled sites.
  4-20
Final Report
October 1999
-------
             4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness

   Exhibit 4-13. Summary of Per-Site Average Total Costs by Acreage and by Percent Imperviousness
Average BMP Costs (1998 dollars) :
Area (Acreage)
1 Acre
3 Acres
5 Acres
7 Acres
35% Impervious
(Multi-Family Residential)
$2,277
$5,172
$8,760
$15,865
65% Impervious
(Multi-Family/Commercial)
$4,867
$12,068
$14,389
$29,248
85% Impervious
(Commercial)
$10,192
$15,260
$17,497
$68,996
 Average per-site costs were multiplied by the number of construction starts for each category to
 determine national post-construction runoff control costs. Exhibit 4—14 summarizes the number
 of construction starts by acreage category that may be affected by the Phase II rule. In developing
 this estimate, EPA removed construction starts that were located in counties with roughly
 equivalent programs under CZARA in the following states: Rhode Island, Delaware, Maryland,
 Pennsylvania, Florida, South Carolina and Alaska. However, this is not a complete list of all the
 potentially equivalent programs that are in effect in Phase II municipalities and so the estimated
 number of construction starts should be considered a conservatively high estimate of the number
 of potentially affected by the post-construction runoff control provision.

           Exhibit 4-14. Estimated Number of Construction Starts Potentially Affected by the
                        Phase n Post-Construction Runoff Control Provision
                      K ?
 feaa-^y-sa^^
                                          .-JmmerciaWlp
  1 Acre
221
                                             2,942
                                   2,505
 5,668
  3 Acres
287
                                             2,451
                                   1,939
 4,677
  5 Acres
228
                                              822
                                    523
                                                                               1,573
 7 Acres
244
                                              818
                                    384
                                                                               1,445
 Totals
981
                                             7,033
                                  5,351
13,364
  1 Totals may not add due to rounding.

Exhibit 4-15 summarizes the estimated costs that construction site operators could incur
nationally when complying with requirements established by municipalities for the post-
construction runoff control minimum measure. This approach to estimating costs on a per-site
basis implicitly assumes that this measure is implemented by installing structural BMPs on a
site-by-site basis. As noted above, however, the Phase II Storm Water rule allows flexibility hi
how MS4s design and implement their post-construction runoff control programs. Consequently,
October 1999
                                        Final Report
                                                          4-21
-------

 f
             "	". ''.'   .  ..'.'.   "1    '  .'.  	   ,'..      '         ,'.'   ' ..   '	"  ,[,      "	'..  "  ......
                           4.p Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
             .jig  it , •• '  ; ifi  ....HO  •     '  \ ,{!,,,.' •	,      • ,,  .a.  ',  ... •• .',;  ..,; • ;.-.  	  •'.  ,, 	*\\\ \fo*>-. r • •,    '••, ••,  :V ?-,• .; •'•
               s,pme programs may adopt alternative approaches that may be more cost effective than site-by-
             	u	siteBMPs^	
         	II1' *	iRhiiiinii
                                                                                account
possible site size limitations for use of certain BMPs for the four site size categories, however,
&s is not a cqmpiete list of potential structural BMPs. Therefore, many developers have
considerable flexibility to either implement structural or nonstructural BMPs.  This flexibility
cannot be readily incorporated into the weighted average. Given a construction operators
incentives to minimize overall project costs, it is reasonable to assume that construction
operators will use the most cost-effective approach to comply with any post-construction runoff
program enacted by a municipality. The most cost-effective BMP is site dependent^ and so cost-
effectiveness could not be considered in the cost analysis either. Therefore, the weighted national
   !l<  '''i  ii'1'	, * ! „ jii',14"!! .j'1 ,    '' ,'   i	nl;,'ii,!   !*l i'i' i,lll! " , , • Jill, ,  !,	:   • ''",	 i  "i  ,,,"^ii" iihii, w linn 	"•'  ,, « •  ' •  ,i"	 jhi'.j,1 ,"ir i"'i  ' • ,  IK   n^L ,    • 	,i    ,'  ,111 'iiiiiii
average should be considered the high end of a potential range of costs. The following section
explains how EPA accounted for cost savings and uncertainties related to these costs.
| •
  - 1
                                                                                                       ""	I-•
                                 Exhibit 4-15. Estimated Post-Construction Runoff Control Costs
I "»!
'. " *
, ' 1
ir r
Area
lAcre
3 Acres
5 Acres
7 Acres
Total Cost
35% ImpervioiEr
(Multi-Family
Residential)
$503,163
$1,486,961
$2,001,641
$3,863,272
$7,855,037
65% Impervious
(Multi-Family/
Commercial/
Institutional)
$14,318,035
$29,571,535
$11,835,630
$23,910,571
$79,635,771
85% Impervious
(Commercial)
$25,530,478
$29,588,931
$9,151,038
$26,494,414
$90,764,861
> ~ S 'J '"
Total Cost , i *,
"(1998 dollars) "
$40,351,676
$60,647,426
$22,988,309
$54,268,258
$178^55,669
              Additional Options for Post-Construction Control. The post-construction control provision
              allows for an array of structural and non-structural options for municipal implementation. These
              options include:
                                                                                   ... „,,

              •   improved site/construction design that minimizes impervious areas or redirects runoff to
                  grassy surfaces
             ", '  Illlll  ^^   **  nil   ,,            .                          ,,
             liliilli
   site-based ]pcal controls, such as buffer strips and riparian zone preservation
   ;	:';""; i'li'ti^j.y?'  'I1'.-';.!;,,1"",  '     	          ]        „        ,                ••;  >   '
   other municipal regulatory approaches, such as reduced parking requirements for commercial
   facilities and changes to zoning and comprehensive plans, and

   requiring structural BMPs for new development and redevelopment sites.
       . . -, ','	in , ••   „     ,i:  ' .IKI   ,: '   " ,  '•     r  ••' i,,: . . •„  i	itA	•..,••• • -i u ,  ,: , •    i
                                                       Final Report
                                                                                October 1999
                                                                                                         •	
-------
  	4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness

  Some of these options may result in cost savings to municipalities and land developers. In this
  section, several site-specific examples of cost savings associated with post-construction storm
  water management are presented. For example, reductions in levels of imperviousness through
  reducing roadway travel widths, minimizing setback requirements, using looped roads, and
  providing compact car spaces are all strategies that may also lower site development costs
  (Ewing, 1998). With the exceptions noted in Appendix B-4, however, these types of savings are
  not incorporated into the national cost estimate because they depend on site-specific conditions
  and municipal ordinances.

  Examples compiled by NRDC (1998) of how structural and nonstructural BMPs can reduce costs
  associated with traditional storm sewers include:

  •   Design changes for a new vehicle maintenance facility at Fort Bragg reduced parking lot
     paved surfaces from 19.1 acres to -14.3 acres with grassed islands and detention basins to
     reduce the size of storm water conveyance pipe.  Cost savings included a $800,000  reduction
     m paving expenditures, $400,000 in storm drain costs, and $400,000 in excavation costs.

  •   A planned mall expansion in Farmington, Connecticut required an additional 4.7 acres in
     parking for peak shopping periods. The developer installed reinforced turf instead of asphalt,
     which allowed water infiltration, thereby avoiding any costs to expand the existing storm
     drain system and build a $ 1 million detention pond.

 •   Vegetated swales, percolation beds and ponds make up the surface drainage system  of the
     Village Homes residential subdivision in Davis, California. The surface drainage system
     saved $800 per lot in infrastructure costs over a traditional subsurface drainage system.
     Furthermore, the system was able to handle the retention and infiltration needs of a 50-year
     storm, including overflow from nearby conventional drainage systems.

 •   Storm water redesign elements for the Oregon Museum of Science and Industry in Portland,
     Oregon, redirected storm water into parking lot medians, which were enlarged to create mini-
    wetlands.  These changes generated construction cost savings of $78,000 by reducing the
    number of manholes and catch basins, and the amount of piping and trenching needed to
    handle storm water.

 Other  examples of potential cost savings of structural and nonstructural BMPs include:

 •   Cluster developments for housing subdivisions can reduce capital costs by 10% to 33% by
    reducing the length of the required infrastructure; reduce grading costs substantially by
    avoiding the need to clear and grade 35% to 60% of total site area; and lower the cost of
    storm water conveyance and treatment by reducing site impervious cover from 10% to 50%
    depending on size/layout (Schueler, 1997).

•   A comparison between conventional development plans and alternatives that decreased
    impervious surface in three Delaware counties showed development cost savings ranging
    from 39% to 63%; conservation techniques included reducing street widths, reducing lot size,
October 1999
                                       Final Report
                                                                                   4-23
-------
             ^|	4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	

                 plu§te,r developments, woodland preservation, and vegetated BMPs (DE DNRED, 1997 as
                 cited in Center for Watershed Protection, 1998).

             •   Some types of well-designed structural or nonstructural BMPs can increase nearby property
                 values because of the amenities associated with by a nearby open space, greenbelt, or year-
                 round pond, or they can serve a dual purpose such as providing water for irrigation (Schueler,
                 1997).
                      •   •• '   •        	       •  •           	   ' •       	i     -    -       •     v ••
             Exhibit 4^16 presents results of a study conducted by the Delaware Department of Natural
             Resources and Environmental Control and the Brandywine Conservancy that examined
             comparative site development costs associated with storm water management (Delaware
             Department of Natural Resources and Environmental Control, 1997). Four case study sites were
             selected; these sites had actual development proposals with conventional storm water
             Management designs. Conservation design alternatives  were developed for these sites, and
             associated costs were compared to the conventional approaches. These alternatives used such
             approaches as concentrating development to reduce road lengtfis and impervious coverage, using
             naturalsite hydrology for conveying and treating storm  water, careful selection of water
             infiltration areas based on soils, and revegetating key infiltration areas. Costs for such
             nonstandard items as revegetation were included.'in the cost comparison!

             The average cost per lot for conventional development approaches was $ 16,464. The average
             cost per lot for conservation development approaches was $8,611, or just over half of the
             conventional development costs for storm water management systems. While these case study
             sites were larger than sites addressed by Phase II rule, the results nonetheless point to the
             jTOSsibility of significant cost savings resulting from creative planning and site design
          ".''	approaches.
          if1;,,, I ,"'il,|||! •  , "Jl ' i , !! il i fjillt'l'l  »   MM	    •,  •'' i, > ;     •   'ill' ' I1'1'  i'    • ii	'ii! '  ,' ' il,,T ' ,i I":" "•   •' h   ' ij, '   "'"'''  'MI.' 'i1  ,r '   "     • I iltiii,"
             Based on the flexibility offered by these potentially lower-cost BMP and development options,
             EPA considers the estimated annual cost for the post-construction runoff control provision,
             shown in Exhibit 4-15, to be the high end of a range of potential costs. This is due to the great
             deal Qf uncertainty in the number of potential starts, the  flexibility in the types of post-
             construction runoff control measures adopted by each Phase II municipality, and the wide array
             of potential control options available to  construction operators. As a result, EPA has chosen to
             present pjSst-construction runoff control costs may range from 25% of the site-by-site costs
             represented in Exhibit 4—15, resulting in a range of costs from $44.5 to $178.2 million, as shown
             in Exhibit 4—17 below.  Exhibit 4—18 shows the total estimated costs for the Phase II
             construction program, which consists of erosion and sediment control provision costs and post-
             construction runoff control provision costs.
                      ;•<  ,	ji •?•
             4-24
Final Report
October 1999
iliitil	;,i	;„	i,;;,1    illijj: „	„;	; ...'jiilil;	.-.LJ.*.)!	BUKn.luiiMt* .1:..',   ii'iJilin ..iil'1 '   ,	'.i'":1" ..'IV	;.' l!i, .1':.' I";, ."
                                                              II  II
                                              ...... I ..... In
-------
     	4.0 Potential Costs, Pollutant Load Reactions, and Cost Effectiveness

      Exhibit 4-16. Comparison of Site Development Costs Associated with Storm Water Management:
                        Conventional Development vs. Conservation Development
^f&i^f/^'M^
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:$ii9^$m&0
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7 - " <_ *
Erosion and Sediment Control Costs
Post-Construction Runoff Control Costs
Total Construction Costs
Cost Estimate ^ ^ ^~* ~s ,/„-*• ^; A
$500,436,622
$44,563,917 -$178,255,669
$545,000,539 - $678,692,291
October 1999
Final Report
                                                                                            4-25
-------
                             4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
i'
                 4.23  Federal Costs
                 	I' '»! "Hi ;  ,l!'PI|iii'"S   M| '."'i, t-.VtJH '»,
                                                                         . 'If..
 In administering the Phase II storm water program, the EPA will incur costs in its role as the
 permitting authority for the affected entities within non-NPDES authorized states and territories.9
 EPA must £fview and manage the application, certification, reporting, and notice requirements
 for these affected entities, The associated costs are based upon the amount of annual labor the
 agency will need to devote to these tasks.

 There are approximately 10,711 construction starts which will have the EPA as the NPDES
 permitting authority; and of these starts 85% will need to come into compliance with Phase II
Awhile the oth|r 15% wil{ likely qualify for a waiver.'0 Using data from the 1990 Census, it was
 estimated that there are 357 MS4s, located in non-NPDES authorized states, that will come under
the jurisdiction of the Phase H rule. This number includes incorporated places, counties, and
minor civil divisions (i.e., unincorporated towns and townships), Federally-recognized Native
American Indian Tribal lands, and municipios (Puerto Rico).  Exhibit 4-19 reports the estimated
costs to EPA as a result of Phase n permitting authority requirements.

                    Exhibit 4-19. Estimated Federal Annual Costs (1998 dollars)
Phase II Program Activity
Respondents
Per Year1
Burden
".: Hours per :
Respondent2
Hourly
Labor
Costs3
Estimated
Cost4
Construction Program
Waiver Cert. Processing & Review
NOI Processing & Review
NOT Processing
1,607
9,104
9,104
1
1
0.5
$28.37
$28.37
$28.37
$45,590
$258,280
$129,140
Small MS4 Program
NOI Processing & Review
Report Processing & Review
Annual Total
357
357
0.8
1.6
$28.37
$28.37
$8,102
$16,205
$457,318
                1 The number of respondents per year was based on the 1990 Bureau of Census data for small MS4s and 8.26% of
                to^Utarts that aie in non-NEDES states and territories in exhibit B-2-3 and B-2-4 for construction.
                2Burden hours per respondent was estimated by EPA.
                'Hourly labor costs are based upon an average annual Federal employee salary of $39,338, divided by 2,080 labor
                hours per year and then increased 50% to represent overhead costs (US Office of Personnel Management, 1998).
                ^Estimated cost is the product of the respondents per year, hours per respondent, and hourly labor costs.
             "•  ;      '       '                       '    ":     "'        '-    "'    !"    "   " ' ;;:'  "      • '  "' '' '•'''
                                                                      Oil ..... ;."!:," I,:" I'
               9 These states and territories are expected to be Maine, New Hampshire, Massachusetts, Puerto Rico, District of
               Columbia, New Mexico, Arizona, Idaho, and Alaska.

               10 Using the information provided in Exhibits B-2-3 and B-2-4 from Appendix B, it was determined that 8.26% of the
               total starts are in the states and territories that EPA will be the NPDES permitting authority for the Phase II rule
               129,675*0.0826=10,711.
               4-26
                                        Final Report
                                                                                                October 1999
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	4.0  Potential Costs, Pollutant Load Reductions, and Cost Effectiveness  	
4.2.4   State Costs

Those states and territories that possess NPDES permitting authority, will incur costs related to
the review and management of the application, certification, reporting, and notice requirements
for the Phase II MS4s and construction starts under their jurisdiction. Based on 1990 Bureau of
the Census data calculations, there are 4,749 Phase II regulated small MS4s located in NPDES-
authorized States and Territories. This number includes incorporated places, counties, and minor
civil divisions (i.e., unincorporated towns and townships). For the activity of developing
designation criteria and using them to assess small MS4s located outside of an urbanized area, a
respondent universe of 44 is used to represent each of the NPDES-authorized States and
Territories for which this activity must be done. Exhibit 4—20 provides an estimate of the cost
burden to the states and territories for administering the Phase II rule.

                     Exhibit 4-20. Estimated State Annual Costs (1998 dollars)
Phase II Program Element
Respondents
Per Year1-2
, Burden,
Hours per
Respondent3
Hourly
Labor
Costs4
'Estimated
Cost
Construction Program
Waiver Cert. Processing & Review
NOI Processing & Review
NOT Processing
17,845
101,119
101,119
1
1
0.5
$26.87
$26.87
$26.87
$479,495
$2,717,068
$1,358,534
Small MS4 Program
NOI Processing & Review
Report Processing & Review
Annual Total
4749
4749
0.8
1.6
$26.87
$26.87
$102,085
$204,169
$4,861,350
 1 The number of respondents per year was based on the 1990 Bureau of Census data for small MS4s and 91.7% of
 total starts that are in NPDES states and territories in exhibit B-2-3 and B-2-4 for construction
 2The number of respondents in each category represents the estimated respondents located within the 44 NPDES-
 Authorized States and Territories.
 3Burden hours per respondent was estimated by EPA.
 "The hourly labor rate for NPDES Authorized States and Territories was based on the average hourly rate for state
 and municipal employees as determined by the U.S. Department of Labor, Bureau of Labor Statistics (US DL,
 1997).

4.3    Summary of Results

A summary of the potential costs from implementing the Phase II municipal measures and
construction site erosion and sediment controls is presented in Exhibit 4-21. Once the Phase II
storm water rule is fully implemented, the total annual cost for implementing the rule is expected
to range from $847.6 to $981.3 million (assuming 129,675 construction starts, 13,364
construction starts relevant to the post-construction analysis, and 32.5 million households in
5,040 municipalities).  The largest portion of the total cost is associated with erosion and
sediment controls at construction sites.
October 1999
Final Report
4-27
-------
            4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
              Exhibit 4-21. Potential Annual Costs for Phase II Storm Water Regulation
'« '1 ' 	 , -;, it "', (* i (• -• \ V ;• ;. >• i
F »• 	 'JVlOt I"':1! V5t;! J ,M
Phase n Element
Municipal
Construction
Federal and State
- • • i, -- , ';.'•',„, •' .< ^!_-w I'1 •^-•'';-v:>^«.1-fc^-^^-^' ^Mt-^-t ':?"«'.
-• •"-'• • -; ^ .> i ^l^^^^fiiss&^ife^SS
32,458,000 Households
129,675 Erosion & Sediment Control Starts
and 13,364 Post-Construction Starts
53 States and Territories
Total
Estimated Total National Annual
iS'V'^ste'C1??8'*10113")- ':!>•.;• t
$297,318,623
$545,000,539 - $678,692,291
$5,318,668
$847,637,830 - $981,329,582
4.4
Potential Pollutant Loading Reductions Resulting from the Phase II Rule
From the new data collected and the revised and new analyses conducted for the final Phase II
rule, EPA developed two estimates of potential pollutant loading reductions from municipalities
and construction starts.
4.4.1
Pollutant Loading Reductions from Municipalities
It is widely accepted that there are many different types of pollutants in storm water runoff
depending on land use activities. The Nationwide Urban Runoff Program (NURP), a study
conducted! by EPA from 1978-1983, monitored the levels of pollutants in storm water runoff
from 28 municipalities (US EPA, 1983). NURP found the following pollutants in the municipal
storm water runoff: oil and grease, TSS, nitrogen, phosphorus, pathogens, lead, copper, zinc,
other metals, biological oxygen demand (BOD), and chemical oxygen demand. However, there
are no national studies to date that estimate pollutant loading reductions due to the
implementation of municipal storm water controls.

To estimate municipal pollutant loading reductions for the final Phase II rulemaking, EPA used
the results from a 1997 EPA draft report that calculated national municipal loading reductions for
TSS base4 on results of the NURP study (Hagler Bailly Services, 1997).  Each aspect of the
municipal pollutant loading reduction methodology used in analysis of the final Phase II rule is
explained in more detail below. While estimating the pollutant loading reduction for TSS does
not capture the full extent of potential loading reductions that result from implementing
municipal storm water controls, this provides a minimum estimate of the reductions that may
result from the Phase II rule.
                                                                                    : ,
EPA conducted a draft study in 1997 to determine the benefits of all NPDES wet weather
programs including storm water, combined sewer overflows, and sanitary sewer overflows
(Hagler Bailly Services, 1997). The study uses NURP monitoring data as a baseline, and
estimates lpa
-------
  	4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	
  (CSO) exempt cities) are included in Phase I and Phase II of the storm water program. Runoff
  was estimated using population density and rainfall data.

  The baseline TSS concentrations in storm water runoff in the 1997 EPA draft study were
  obtained from Table 6-4 of the EPA manual entitled, "Urban Runoff Pollution Prevention and
  Control Planning" (US EPA, 1993b).  Baseline concentrations were found to range from 141
  mg/L to 224 mg/L for TSS. The storm water data in the manual were taken from the NURP
  study (US EPA, 1983). The NURP data have been widely accepted and referenced as reasonable
  estimates of pollutant concentrations in urban storm water runoff.

  Based on a review of literature on BMP effectiveness, EPA determined that BMPs are 20% to
  80% effective. Therefore, EPA assumed that BMPs would reduce pollutants in storm water by
  between 20% to 80%. Exhibit 4-22 shows the resulting estimates of TSS reductions attributable
  to the implementation of BMPs required under the NPDES storm water program.

                    Exhibit 4-22. Estimated Ranges of Daily TSS Reductions from
                        EPA's Phase I and Phase II Storm Water Programs
"»•"• "^ „
* -W- >*Sy, -
* ' "BMP ^ *X
-Efficiencjr(%) "
20
80
% ' "^ ,*
Volume
(mgd)
27,584
27,584
s
Baseline Cone. (mg/L)
Low
141
141
High
224
224
Baseline Loads
(tons/day) """
Low
16,219
16,219
* High -
25,766
25,766
* * y,
V ** *™ I*
Reductions (tons/day)
f 'iiOW
3,244
12,975
High
5,153
20,613
  Source: US EPA, 1997a.

 It should be noted that removal efficiencies depend on how much of the estimated runoff actually
 is affected by structural and nonstructural BMPs. At this time, no supporting data has been
 collected and analyzed to indicate how much of the total runoff in urban areas will be affected by
 storm water BMPs. Therefore, this analysis assumes that all runoff is controlled by BMPs which
 may not accurately reflect the actual reduction attributable to the storm water programs.

 For analysis of the final Phase II rule, EPA developed a TSS reduction for Phase II by comparing
 total municipal populations between Phase I and Phase II and distributing the loading reductions
 proportionally. The total population for the 405 urbanized areas evaluated in the 1997 study was
 estimated at 160 million (US EPA, 199Sa). Of the 160 million, the total Phase IMS4 population
 is 75 million while the total Phase II municipal population is 85 million (US EPA, 1995a). This
 results in 54% of the loading reduction attributable to implementation of the Phase II program.11
 Exhibit 4-23 shows the proportion of TSS loading reductions EPA attributed to Phase II
 municipalities on a daily and annual basis for both 20% and 80% BMP effectiveness. EPA
 anticipates that municipalities will strive to achieve 80% effectiveness when implementing their
 storm water programs.
"EPA considered comparing Phase I and Phase II storm water loadings by miles of infrastructure but was unable to
determine the miles of storm water sewers in the municipal universe.
October 1999
                                      Final Report
4-29
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               4.0  Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
               "i'                 „     i           . '	,:        '	   i    '.I i"
               Exhibit 4—23. Estimated TSS Loading Reductions for Phase II Municipalities
I
T " i i
BME» Efficiency (%)
20
80
A i Tons/Day ' " , "' ' ' *
Low
1,751
7,006
High
2,783
11,131
Tons/Year
Low
639,115
2,557,190
High;
1,015,795
4,062,815
    Source: J|S EPA, 1997a.
        : "'   .'"•          ',  , i Ii •  	II  ,,i „ I  • .   ,!' i'    , i',      "„„   »i ,   ,,  ,'''i|'|. '  |i,  'in1  IP ,  ' ' ' '         ' '   '• ,!",'!"
•ill's'   1|l!   i1     ':' ii  „""   "ifii    •    lil, "!'  i ' Ji1 • ',  '  in   ••'   J      .'    ,„  ,i...| i. '  ' , " 'Ii  ,„   r"  i 'II 'i1   '•„ • ,''i,',         ' .     A, I '','i'ii|
   4.4.2         Pollutant Loading Reductions from Phase II Construction Starts
,'••''•'  ;     "i   :'"" i  Si	  "l •  .'  'I":,, •'  "'  ,1, ,i.,,    '  .,	",   ;,        .;.'•. 1.1	'<"•  ","  : ' •. I •   " : .  "liu	 ' " I .•:	"
       I,   '„[',:  .11 i  t'  .  '	.,• •   , : .  ;	,1F   ' ;  	V   .    ,   .,.,,..'.  ,"».•  .  "  i  I    ,    "V, 	    :• ." ' . [.'Mil
 1  ;   ....   B, i,.|! lip1 li,!!..!.,,;;n  , ,  ' ,!!|.|.  i|.  i, j ,|iu ....i1 ,'     ,„     |»H!|	'"',„, ,„ .,"    ' ,  „ 	 , ,11"!    ,',,,' || ,„	 , ,   i i,1 '    	•'''   „  | '''"I
   To estimate pollutant loading reductions from Phase II construction starts, the US ACE
   developed a model based on EPA's 27 model sites to estimate sediment loads from construction
   starts with and without Phase II controls (US ACE, 1998).  The US ACE model uses the
   construction site version of the Revised Universal Soil Loss Equation (RUSLE) to generate
   sediment delivery estimates for 15  climatic regions with each of the following variations: three
   site sizes (one, three, and five acres), three soil credibility levels (low, medium, and high), three
   slopes (3%, 7%, and 12%), and the BMP combinations from EPA's 27 model sites? The15
   climatic regions were used in an effort to represent the various climatic conditions throughout the
   United States. Sediment delivery represents the quantity of sediment that bypasses the BMPs
   placed at the base of the hill slope.
                                                                    i
   Pollutant loading reductions for the Phase II construction universe were determined using an
   average for one, three, and five acre sites with medium credibility and slopes ranging from 3% to
   12%. This approach is consistent with that used in the construction cost analysis.

(I"'.To determine the weighted average sediment load per Phase II construction site, the sediment
   loads developed by the US ACE for one, three, and five acre sites of medium soil credibility
   were multiplied by the number of construction starts disturbing between one and two, two and
   four, and four and five acres of land in each climatic zone.  The total loadings were summed and
   then multiplied by the ratio of construction starts in each size category by the total number of
   each construction sites, for each climatic zone. This provided an average sediment load per
   climatic region for Phase II construction sites with moderately credible soil. Then, the average
   loads per climatic region were multiplied by the ratio of total Phase II construction starts in each
   climatic zone to the total Phase II construction starts nationwide to obtain a national weighted
   average sediment load per site. This methodology was used to calculate sediment loads from
   consfruction starts with and without Phase II controls. The  US ACE model was also used to
   derive an estimate of potential sediment load reductions attributable to soil erosion controls.
  These values, as presented in  Exhibit 4—24, indicate that the weighted average soil loss per start
  was 96.1 tons and the potential reductions in soil loss could be 89.6 tons^ The sediment loss
  calculation used in the analysis is based on a version that was developed to model construction
  sites. Actual soil loss may vary from site to site due to the pattern and extent of soil disturbance
   as well as the placement of building materials and the buildings on the site.
  4-30
Final Report
October 1999
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             4.0  Potential Costs, Pollutant Load Reductions, and Cost Effectiveness

         Exhibit 4-24. Weighted Average Sediment Loadings and Loading Reductions (tons) from
                        Phase II Construction Sites of Medium Soil Erodibility
Climatic
Region
A
B
C
D
E
G
G
H
I
K
M
N
P
R
T
Representative *"
'Community
Portland, OR
Boise, ID
Fresno, CA
Las Vegas, NV
Denver, CO
Bismarck, ND
Helena, MT
Amarillo, TX
San Antonio, TX
Duluth, MN
Des Moines, LA
Nashville, TN
Atlanta, GA
Hartford, CT
Charleston, SC
Weighted Average1
Average Loading — <
, No Controls (tons) v
52.3
9.1
9.2
6.0
30.9
37.0
10.4
78.3
202.5
61.6
124.3
176.5
213.0
100.7
294.7
96.1
Average Loading — «,
With Controls (tons)
1.8
0.7
0.3
0.1
1.9
2.2
0.7
5.8
16.3
4.0
9.8
12.4
15.5
4.4
16.9
6.5
Average Loading „
Reduction (tons)
50.5
8.4
8.9
5.9
29.0
34.8
9.8
72.5
186.2
• 57.6
114.5
164.0 .
197.5
96.2
277.9
89.6
 Source: Derived from US ACE (1998).
 'EPA estimated the weighted average loads based on the slope, erosivitity of the soil, and the number of
  construction starts in each size category.

To determine the reduction in soil loss using the estimated 80% effectiveness rate, EPA
multiplied the weighted average soil loss per start (89.6 tons) by 80%. This resulted in an
estimated reduction in soil loss of  71.7 tons per-site.  Multiplying this reduction by the 110,223
construction starts expected to implement erosion and sediment controls for the year 1998,
results in an estimated 7.9 million ton reduction in soil loss annually.
4.4.3
Summary
A summary of the total annual national loading reduction estimates attributable to the Phase II
rule, for both municipalities and construction starts, is presented hi Exhibit 4-25.
     Exhibit 4-25. National Reduction Estimates for Municipalities and Construction Starts (tons/year)
- t Phase njElement" % ,
Municipal TSS Loading
Soil loss from Construction Sites
?" 20% Reduction - ,
J ^- V >^ v f~
639,115
1,975,196
^ v * 80,%:Reducfi6n ""' """l ~
/> f, ir m, w^s^i y sj. **gf V -Wisy*rx ff*t> 
-------
                            4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
                4.5
 Cost Effectiveness
• i
                                                                               t;
                For purposes of this regulatory analysis, cost effectiveness is defined as the incremental
                annualized cost of a pollution control option per incremental pound of pollutant removed
                annually by the control option. Cost-effectiveness analysis can thus be used to compare pollutant
                removal costs across regulatory alternatives. This type of analysis is limited for the Phase II rule
                because EPA was only able to quantify potential reductions in "TSS loadings! EPA also
                anticipates that the rule will result in reductions in oil and grease, nitrogen, phosphorus,
                pathogens, lead, copper, zinc, and other metals.

                EPA compared the potential costs per pound of TSS removed from Phase II municipalities to the
                costs estimated for publicly owned treatment works (POTW) to remove this same pollutant. This
                approach is parallel to the cost reasonableness test established by EPA in developing technology-
                based effluent limits for conventional pollutants (see 51 FR 24982).  Under this approach, EPA
                compares industry costs with that of an "average" POTW with a flow of 2.26 million gallons per
                day (mgd) and costs of $0.70 (1998 dollars) per pound of pollutant removal (BOD and TSS).
              I     H' ™i i i":"V? i  uij1;;! , '"    ''I:''  •    '; ',, ,  ,, ' /ft,;;' : '"  n ; '  1*',!l;;'ll'"!!r,'''i''1 ' j'  	i '       i"1      » I            ,'l|ll! •••!;,!•! • ,1	;' '..i! \Vfv. . "'

                Based on this cost effectiveness analysis, the rule may result in Phase II  municipalities
                experiencing costs of between $0.04 (80% BMP efficiency; high end reduction) and $0.18(20%
                BMP efficiency; low end reduction) per pound of TSS removed.12  While EPA anticipates 80%
                effectiveness at reducing pollutant loading following program implementation, both low and
                high end reduction costs are low compared to the $0.70 (1998 dollars) established for POTWs to
                remove BOD and TSS.13  Thus, the requirements of the final Phase II rule appear to be cost
                effective. This is particularly true since EPA's analysis of cost-effectiveness is based solely on
                removal of one of many pollutants believed present in storm water discharges.
                4.6
Sensitivity Analyses
                Due to the diversity of municipalities and various conditions of construction sites nationwide, the
                analysis of costs will likely reflect some uncertainty. A sensitivity analysis identifies the
                assumptions that may bias the final cost estimates.  The purpose of this sensitivity analysis is to
                examine the importance and magnitude of the key assumptions used in the analysis.  In its
                analysis, EPA may have overestimated municipal costs because municipalities that are currently
                implementing some components of the Phase II municipal program were not considered. EPA is
                uncertain of the activities municipalities will take to achieve compliance with the regulation,
                therefore; estimating compliance costs is difficult. For example, EPA is uncertain about the
                number of municipalities that will be designated, by the permitting authority, to apply for a Phase
                n municipal permit. The potential also exists for construction activities to occur on areas with
                slopes greater than 12%; however, the number of starts, and for that matter the number of starts
                at any given slope is unknown. To determine the sensitivity of costs to the assumptions used in
                the analysis, EPA performed six sensitivity analyses as presented below. To be conservative,
               12Cost effectiveness is based on the total cost of the rule because the municipal component includes construction activity
               within the watershed.
                    ,  ,.-:..	•••  rv.,.        ••  i.,   :  . ;    •,	 :	'	  i : ,	.• , ;-,• ,,.:,;,>,;,'i-j ,„ • .,  L; .   . i  -••   ,   	= , \ ,.,
               "The technologies used for secondary treatment at POTWs removes both BOD and TSS at the same time. Therefore,
               estimating the tons of TSS removed from secondary treatment is not possible.
               4-32
                         Final Report
October 1999
-------
	4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness	
EPA used the higher potential cost estimates for post-construction controls in the sensitivity
analyses (see Exhibit 4—15).

Scenario One. As discussed in Section 4.2.1, the annual per household costs for the Phase II
program elements ranged from $0.42 to $54.91.  Estimated costs of the municipal program,
presented in Section 4.2, are based on the mean of $9.16 per household. For this sensitivity
analysis, EPA estimated national annual Phase II municipal costs using the median of $4.19 per
household.  The results are presented in Exhibit 4-26a.

                   Exhibit 4-26a. Results of Sensitivity Analysis for Scenario One
:~cr^v ,--r*
? •» j -O A. 4&W.,, •¥
Original Estimates as Presented in Section 4.3
Scenario One — Estimate of Municipal Program Cost
adjusted to Reflect Median1
Percentage Change from the Original Estimate
, "" Estimated Total National Annual Costs
_*^ -' r\f' ' -~ '"*, *
"* *V Js. * ** """ ,&&* °* ,#> h«v ^ ^
$981,329,582
$820,011,508
-16.44%
 'Based on per household costs of $4.19.

Scenario Two. As discussed in Section 4.2.1, the annual per household costs for the Phase II
program elements ranged from $0.42 to $54.91. Estimated costs of the municipal program,
presented in Section 4.2, are based on the mean of $9.16 per household. For this sensitivity
analysis, EPA estimated national annual Phase II municipal costs using the 75th percentile of
$10.40 per household.  The results are presented in Exhibit 4—26b.

                   Exhibit 4-26b. Results of Sensitivity Analysis for Scenario Two

 Original Estimates as Presented in Section 4.3
                       $981,329,582
 Scenario Two—Estimate of Municipal Program Cost
 adjusted to Reflect 75th Percentile1
                       $1,021,577,955
 Percentage Change from the Original Estimate
                          4.10%
 ^ased on per household costs of $10.40 and 129,675 construction starts.

Scenario Three.  To estimate municipal costs in Section 4.2.1, EPA used estimates of the
number of households located in automatically designated Phase II communities. To develop
this scenario, EPA estimated annual Phase II municipal costs by increasing the number of
households to include 10% of the 4,539,440 potentially designated municipal households (see
Exhibit 3—2). The results are presented hi Exhibit 4-26c.
October 1999
Final Report
                                                                                     4-33
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     if  '.; «',,,, i , III    , '    '! •' V"",'  ",|  '  '  '                        ! '

             4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
                   Exhibit 4-26c. Results of Sensitivity Analysis for Scenario Three
' * V' ' V • * "*" r*f T-* i
. , , Assumption ^
Original Estimates as Presented in Section 4.3
Scenario Three — Estimate of Municipal Program Cost
Adjusted to Include 10% of the Households Located in
Potentially Designated Communities1
Percentage Change from the Original Estimate
Estimated Total National Annual Costs
(1998 dollars)
$981,329,582
$985,487,709
0.42%
  'Based on per household costs of $9.16,129,675 construction starts, and an increase of 453,944 households.
 Scenario Four. As presented in Section 4.2.2, to estimate Phase II construction site costs, EPA
 developed 27 model construction sites in an effort to reflect site conditions and erosion and
 sediment control practices throughout the country. The model sites varied in size (one, three, and
 five acres), soil erosiviry (low, medium, and high), and slope (3%, 7%, and 12%). Many
 municipalities do not allow construction on very steep slopes, therefore slopes greater than 12%
 were not considered for the main analysis. However, for this sensitivity analysis, EPA included a
 slope value of 18%. The methodology used to develop the cost for this analysis is consistent
 with that used in Section 4.2.2. The results are presented in Exhibit 4-26d.
                   Exhibit 4-26d. Results of Sensitivity Analysis for Scenario Four
. '"'"i " . . •'. /- 'I".^,r;.i^:*^«/"££5?'j'>r{;.!tlS:fc;i;:i-"gAVsX!l'lt
• .. ^•~^-V\-^^^*^^j^v;i.^,£^-v;??.ir,;-Jf
i ••• : I'M -r^TAssamptoon;;: '•;-.;- -.. .^-.i- ••••:•:..- •;•?{-,
,..- . ' -,-• 'L 	 •••••. - .-•-..- •"..• vVi>.'-'i.;B',rv'jv>_'., ••• -•::•<- ;! ^
Original Estimates as Presented in Section 4.3
Scenario Four — Estimate of Construction Program Cost
Adjusted to Include 18% Slope Variable1
Percentage Change from the Original Estimate
. : Estimated Total National Annual Costs
-/V;; *• -- (1998 dollars) ^ "^ *
$981,329,582
$1,077,118,232
9.76%
 'Based on per household costs of $9.16 and 129,675 construction starts.

Scenario Five. To estimate municipal costs in Section 4.2.1, EPA used estimates of the number
of households located in automatically designated Phase II communities. However, if all the
municipalities that could potentially receive a waiver from the permitting, did receive a waiver,
the number of households would be reduced. For this scenario,  EPA estimated annual Phase II
municipal costs by first subtracting those municipalities that serve less than 1,000 people from
the list of Phase JI municipalities. This subtraction represents the maximum number of
municipalities"'(1,001) that could potentially qualify under the waiver provision. As a result, the
total number of Phase U households are reduced by 107,539. The adjusted number of households
Was then multiplied by the average per house hold cost to determine total municipal costs. The
results are presented in Exhibit 4-26e.
        i,	niif
4-34
Final Report
                                                                              October 1999
-------
              4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
                     Exhibit 4-26e. Results of Sensitivity Analysis for Scenario Five
  Original Estimate as Presented in Section 4.3
                         $981,329,582
  Scenario  Five—Estimate  of Municipal  Program  Cost
  Adjusted to Reflect the waiver provision for municipalities
  serving less than 1,000	
                         $980,343,435
  Percentage Change from the Original Estimate
                           -0.10%
  1. Based on a Phase II municipal population of 84,908,666 people (32,350,707 households) and 129,675 construction
  staits.

 Scenario Six. To estimate state and federal administrative costs in Sections 4.2.3 and 4.2.4, EPA
 only considered those costs that are likely to be incurred on an annual basis. There, are start-up
 costs associated with the administration of Phase II by the permitting authorities. However, it is
 uncertain how often these costs will be incurred. As described in Appendix B-5, some of the
 start-up activities may occur only once while others may be done each permit cycle. For
 example, the incorporation of 401 certification language into the general permit language is
 likely to only need to be done once, while the designation of additional MS4s may occur
 occasionally at the beginning of each new permit cycle. Due to this uncertainty, and the
 relatively small magnitude of these costs when annualized (see Appendix B-5), EPA decided
 against including these costs within the cost analysis. However, to assess the potential impact of
 these costs a sensitivity analysis was conducted. Scenario six assumes that all start-up costs are
 incurred once every permit cycle of five years. The results are presented in Exhibit 4-26f.
                     Exhibit 4-26f. Results of Sensitivity Analysis for Scenario Six
 Original Estimate as Presented in Section 4.3
                        $981,329,582
 Scenario Five - Estimate of Federal and State administrative
 costs adjusted to include annualized start-up costs.'	
                        $981,381,188
 Percentage Change from the Original Estimate
                          0.005%
 1A description of start-up costs can be found in Appendix B-5.

As demonstrated in Scenario One, selection of mean versus median makes a significant
difference (16%) in national costs results. Scenario Two shows that use of the 75th percentile per
household cost in estimating national municipal costs closely approximates the national
municipal costs for the mean value, differing by just 4%. In Scenario Three, the change in
assumptions regarding the municipal universe did not make a significant difference in cost
outcome. The sensitivity analysis for construction costs (Scenario Four) shows that national costs
may increase by $96 million annually when assumptions regarding construction activities on
slopes are reconsidered. The sensitivity analysis for the municipal waiver provision showed that
the waiver provision is unlikely to have a significant effect on the total costs. Finally, the
sensitivity analysis for federal and state administrative start-up costs demonstrates that these
costs will have no significant effect on total costs.
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               4.0 Potential Costs, Pollutant Load Reductions, and Cost Effectiveness
SL  4.7
Conclusion
    EPA estimates the totel annual costs of the rale to be between $847 and $981 million. This
    estimate includes approximately $297 million attributable to the municipal component,
    approximately $545 to $678 attributable to construction controls, and $0.46 million and $4.9
    million for federal and state administrative costs, respectively. The cost-effectiveness analysis
    shows the Phase n rule to be, cqst effeptiye. For• muiiicipalities, costs are expected to range from
    $0.04 to $0.18 per pound ofTSS removed compared to $0.70 per pound of TSS removed for
    POTWs.In addition, only TSS was considered in the municipal pollutant loading reduction
    analysis and it is well known that many other pollutants are found in storm water discharges,
    elg!,' mtrogen, phosphorus, lead, copper, and zinc. The municipal minimum measures required
    by the final Phase fl rule are expected to assist in removing these other pollutants as well.  Other
    increases in cost effectiveness may result if certain assumptions used in this analysis were
    adjusted with respect to the results of the sensitivity analysis (mean municipal costs versus mean
    values, etc.).
        ; ,• " Jllll'lii;	'!ii(l
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               5.0  QUALITATIVE ASSESSMENT OF BENEFITS

 The Phase II rule requires regulated municipalities to develop a storm water management
 program comprising six minimum measures that are expected to reduce the impact of storm
 water runoff on the nation's waters. The rule also requires owners of construction sites that
 disturb between one and five acres to implement erosion and sediment controls.  This chapter
 qualitatively assesses the potential benefits of both the municipal measures and construction
 controls. Chapter 6 presents an analysis of those benefits quantified for this Economic Analysis.

 A number of potential problems are associated with assessing the benefits resulting from the
 municipal program, including identifying the regulated municipalities as sources of current
 impairment to waters and determining the likely effectiveness of the various measures.  Water
 quality modeling may assist in the identification and determination of the relative sources of
 impairment; however, past experience may be the only source of information on program
 effectiveness. The assessment presented here relies on existing literature for the evaluation of
 both the municipal program and construction runoff program effectiveness, as well as for the
 anticipated environmental impacts.  The construction site controls discussion is further
 supplemented by EPA's model of the potential effectiveness of these controls and anticipated
 sediment loads during wet weather events.

 5.1  Municipal Minimum Measures

 Under the Phase II rule, municipalities with storm sewer systems serving populations of less than
 100,000 located in Census-designed "urbanized areas" will be required to control storm water
 runoff through the implementation of six municipal minimum measures.  EPA expects that these
 measures will reduce storm water flows and loadings of pollutants including BOD, oil and
 grease, metals (lead, copper, nickel, cadmium, zinc), phosphorus, nitrogen^ some pathogens from
 illicit discharges, street debris, and construction sites.  These reductions will lead, in turn, to
 improved water quality and habitat in receiving waters, resulting in a range of benefits.

 5.1.1 Description of Measures

 The six municipal minimum measures are described below. The anticipated benefits of these
 measures are discussed in Section 5.1.2.

 Public Education and Outreach

 The public education measure requires municipalities to inform citizens, organizations, and
 businesses about local water quality problems, how storm water runoff affects local water bodies,
 and how detrimental effects can be prevented. The benefits of a public education program could
 be measured by the number of households, organizations, or businesses that alter their behavior
 in an attempt to reduce the impacts of storm water runoff. EPA expects that public education
 will result in reduced pollutant loadings due to an increased awareness of the causes of water
 quality impairment. For example, a BMP education program in the Lake Tahoe watershed used
a newsletter to educate residents about the cause and effect relationship between land use
practices and water quality, and provided "how to" information on specific BMPs
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      	i	S.
                             5.0 Qualitative Assessment of Benefits
,1:
   (Christopherson, 1995). The results of this program, documented through a telephone survey of
   newsletter readers and nonreaders, showed that readers were better able to correctly identify the
   causes of declining water quality (37% versus 26%) and increased algae growth (65% versus
   45%), and were more familiar with the term "BMPs" (38% versus 14%). Readers also accounted
   for 80% of the reported implementation of BMPs.

   In another example, Montana State University conducted a voluntary private well water testing
   program involving instructional videos, written instructions, and well water sample collection
   and submission (Bauder, 1993).  The impact of the program was assessed through a
   questionnaire that was mailed out 1 year after results of the water testing program were
   distributed to program participants. Forty-four percent of program participants returned the
   questionnaires with 65% indicating that they understood the test results that they had received
   the previous year; only 3 5% did not understand the test results. Seventy percent of respondents
   reported an improved ability to make decisions about water quality, and 84% rated the program
   as moderate to very effective at increasing public awareness of water quality issues. The average
   value placed on the program information and testing opportunity was $108 per person, nearly
   nine times more than the cost of participation. By the end of the program, 12% had purchased
   point-of-use treatment equipment and 8% had made changes in land use practices. Twenty-five
   percent thought they should initiate a regular sampling and testing program compared to 15% of
   respondents that, prior to the program, had indicated occasional testing (once every five years or
   less) of their water supply.

   The Tillamook Bay Rural Clean Water Project in Oregon also conducted a public education
   program to educate the local agricultural community about water quality issues (Ryan, 1989).
   The program involved one-on-one contact between Soil Conservation Service employees and
   farmers, visits and tours of successful BMPs, newsletters, brochures, and presentations.  Public
   participation in local water quality problem solving was encouraged through workshops and the
   actiyjjjy of the Citizen.Advisory Committee. The program earned the participation of 98% of the
   farmers in the critical areas; 73% of whom implemented BMPs. Four years after the program
i!!'' «'i ,,,, „'   VillK ,i, ,j'i"!iS!iiii ' 'I:1''  '"'I1, n'., " !!	:h:, I : i!!'1'! ''.iill 	,,,'"H 'ill • V.	 it JIU 	• ' hi1. . I " i"'C:	••',• ».. H ,,n », •«	11	 «  m , I»M , 	 . ,   i •   	•„,, .•
   began, there was a 40% to 60% improvement hi bacteria conditions in the Bay and a 50% to 80%
   improvement in the rivers (Ryan, 1989).

   Public Involvement and Participation
                                                                                                 ,'i'1"1,	, •!„', .I! '
               The public involvement and participation measure requires municipalities to involve members of
               a commiinity in the development, implementation, and review of a municipality's -storm water
               management program; for example, acting as citizen representatives on a local storm water
               management panel, attending public hearings, working as citizen volunteers to educate other
               indiyiduals aHout the programmer participating hi volunteer monitoring efforts. £PA expects
               public participation to increase the awareness of water quality problems, increase the acceptance
               of storm water control programs by the: local community through participation hi ffle decision-
               making process, and improve water quality as a result of greater public involvement in storm
               water management.  The benefits of public participation programs are difficult to measure
               because it is hard to value an increase in participation or an improvement of program design.
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                           5.0  Qualitative Assessment of Benefits
 Illicit Discharge Detection and Elimination

 The illicit discharge detection and elimination measure requires the owner or operator of a
 regulated small municipal separate storm sewer system to demonstrate awareness of the system;
 to develop a storm sewer map showing the location of major pipes, outfalls, and topography; to
 effectively prohibit illicit discharges into the separate storm sewer system; to implement
 appropriate enforcement procedures; to develop and implement a plan to detect and address illicit
 discharges, including illegal dumping into the system; and to inform public employees,
 businesses, and the general public of hazards associated with illegal discharges and improper
 disposal of waste, through programs such as storm drain stenciling. EPA expects that the
 identification of illicit discharges and their subsequent elimination will reduce the flows and
 pollutant loadings entering small  streams and storm sewer systems.

 For example, during a 12-month period, the Houston, Texas, Public Utilities Department
 identified 132 sources of discharges leading to Buffalo Bayou, the local drinking water source,
 with estimated flow rates ranging from 0.3 to 31.5 liters per second.  Houston's program
 involved monthly sampling from  bridge crossings; analysis of samples for carbonaceous
 biochemical oxygen demand, ammonia and nitrate nitrogen, pH, TSS, DO, temperature, fecal
 coliform, and chlorine residual; comparison of samples to baseline flow concentrations; weekly
 sampling of temperature, dissolved oxygen (DO), and fecal coliform in stream reaches suspected
 of contamination; boat sampling to identify the contaminating outfall along the reach; and,
 finally, a land-based search to pinpoint the source. Of the flows identified during the program,
 85% were due to broken or clogged wastewater lines and  10% were due to illicit connections
 (Glanton et al., 1992). Eight months after an illicit discharge detection and elimination program
 began, fecal bacteria log mean concentration was reduced from 20,000 colonies/100 mL to 2,000
 colonies/100 mL. In this example, the impacts of illicit discharge programs can be measured by
 reduced flows and pollutant loadings resulting from the elimination of discharges.

 Construction Site Storm Water Runoff Control

 Municipal separate storm sewer system operators are required to develop, implement,  and
 enforce programs that will result in the reduction of pollutants, particularly sediment and site-
 generated wastes, in storm water runoff from construction activities.  Program requirements
 include preconstruction review of site management plans, regular inspections during
 construction, and provisions for receipt and consideration of information provided by the public.
 Construction site operators will implement on-site controls that include BMPs, such as silt fences
 or detention basins.  EPA expects  that implementing such programs will result in reduced
 pollutant loadings and flows entering small streams, with  benefits including improved water and
 habitat quality. These impacts, which EPA has modeled (see Section 5.2.1), can be measured
 through performance measures for construction site controls (i.e., BMP effectiveness).

Post-Construction Storm Water Management in New Development and Redevelopment

 The new development and redevelopment measure requires that land developers attempt to
maintain predevelopment runoff conditions through controls that prevent or minimize water
quality impacts from runoff and through adequate long term operation and maintenance of
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                            5.0 Qualitative Assessment of Benefits
  BMPs. Examples of these controls include minimization of site disturbance-and vegetative cover
  preservation, minimization of impervious areas, maintenance or restoration of natural infiltration,
  wetland protection, and use of vegetated drainageways or riparian buffers. EPA expects that
  such foresight during development will result hi the prevention of sediment and flow runoff.  The
  impacts can be measured through the loadings reductions based on performance estimates for the
  implemented controls.
         1 lii"»ii'  ',„ , "i    ,|      '!"  „ . lili"  ', ,!  „ ""    "3  '          '   IF   'i*   '  ' '"|l' ' i|
  '      :' 'L1!!1!!!!, T"  '!ll,!!!|'111"   n! ',','"'  /   '"' •, i1' ''"J"!!*'  ', '",!!""  '    ' "!' •             '     I':!!'1!1! !° T '  , ' ,i!n,I ! ' B| ' • "i
  Pollution Prevention/Good Housekeeping for Municipal Operations

  The good housekeeping measure requires that storm sewer systems and storm water pollution
  control structures are properly operated and maintained with the goal of preventing or reducing
  pollutant runoff from municipal operations. Examples include long term inspection procedures
  for structural storm water controls to reduce the discharge of floatables and other pollutants from
  the separate storm sewers and controls in an attempt to reduce or eliminate the discharges of
  pollutants from streets and other municipally controlled paved areas. An example of a pollution
  prevention procedure is training municipal employees regarding the reduced application of
  pesticides on municipally-owned golf courses or parks.  EPA expects that activities such as street
  or storm drain cleaning will reduce the pollutant loads carried 'in storm water flows, with benefits
  measured as the loadings reductions.
 reducing the loading of pollutants that tend to adhere to very small particles. For example, the
 city of Bellevue, Washington, found that street cleaning three times per week removed about
 pnly 10% of urban runoff pollutants; catch basin cleaning twice a year was estimated to be about
 25% effective (Pitt and Bissonnette, 1984).  Thus, the benefits of good housekeeping measures
 may be predominantly those associated with reduced floatables, such as enhanced recreation
 resulting from improved aesthetics (e.g., swimming, beach use, and hiking along the water).

 5.1.2  Anticipated Benefits from the Municipal Minimum Measures
 The Phase II rule is intended to reduce the harmful pollutant loadings and flows carried in storm
 water runoff These reductions will affect the quantity and quality of storm water runoff,
 improve water quality, and result in a variety of benefits to users of affected waters. The types of
 bengfi|s associated with the Individual measures depend on the specific pollutants that are
 reduced. ..........................
 ..... • ...... !,.  •.. iliiiijiiPi1!!1 -  ;""•' n ' •  i;  '.  .. i ".    ,    •.;"   ' •      .  i-                    i     ..   ••:• ,  •: ; ......   • ,i , \ w
                   "  '"      '                                               ""    '
            JIlilL
 Enhanced Commercial Fisheries
i'i": ............... i"1 ........ :li:!i!P'1': ..... ...... i;.; ..... »; : ...... :;::ij";" ;-i;;; ..... ...... :i ..... i:  ,.'. '.w\ :•«••' •. ,  ' ,             i        11        >•<;' r   .   ;,v ^ i. ...... i.
 Pollutants in storm water (e.g., bacteria, solids, toxics) can adversely affect fisheries by reducing
 tie possibilities of reproduction and survival, leading to lower yields, contamination and closure,
 or the elimination of a species. Approximately 27% of the square miles of estuaries surveyed for
 sheHfishing use violated shellfishing harvesting criteria (US EPA, i998a).  Of the estuaries
 surveyed, 18% identified storm water as a source of impairment (US EPA, 1998a). The
 reduction of pollutant's and the resulting unprovement in water quality from public education,
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                          5.0 Qualitative Assessment of Benefits
 public participation, and illicit discharge detection and elimination may contribute to the
 recovery of these fisheries. Good housekeeping and street sweeping may also contribute to these
 benefits, although to a lesser extent due to the lower effectiveness of reducing pollutants that
 adhere to small particles, such as metals.

 Enhanced Opportunities for Recreational Fishing

 Pollutants in storm water runoff may result hi decreased numbers or size of sport fish or shellfish
 species, or eliminate specific species from receiving waters.  Fish or shellfish caught in unpaired
 waters also may be unsafe to eat. As of September, 1996, there were 2196 fish consumption
 advisories in 47 states, the District of Columbia, and American Samoa—65% of these advisories
 restrict the consumption offish caught hi lakes (US EPA, 1998).  Approximately 24% of
 estuaries, 17% of rivers and streams, 35% of lakes, ponds, and reservoirs, and 98% of Great
 Lakes shoreline are not/partially supporting or in nonattainment for fish consumption use (US
 EPA, 1998a). The public education, public participation, and illicit discharge detection and
 elimination measures are expected to result hi reduced pollutant loadings and improved water
 quality that may increase the number, size, and quality offish hi receiving waters, thereby
 opening up new areas to fishing, enhancing the experience for existing users, and possibly
 increasing activity associated with recreational fishing (e.g., nonconsumptive wildlife users often
 accompany individuals engaged hi recreational fishing). Good housekeeping and street
 sweeping, by improving aesthetics associated with recreational fishing sites, may also contribute
 to enhanced opportunities for recreational fishing and related activities.

 Enhanced Opportunities for Subsistence Fishing

 Pollutants in storm water runoff may decrease the numbers or size of edible fish species or
 eliminate specific species from receiving waters. Fish caught hi unpaired waters also may be
 unsafe to eat, or may have low recommended limits for consumption.  Through water quality
 improvements, the number, size, and quality offish may improve, thereby opening up new  areas
 to fishing, enhancing the experience for existing users, and increasing the safe consumption
 limits.

Enhanced Opportunities for Hunting

Pollutants in storm water runoff may decrease the habitat quality for waterfowl species, resulting
hi reduced numbers, reduced breeding, or the elimination of specific species from receiving
waters. Additionally, birds feeding from impaired water bodies also may be unsafe to eat.
Through water quality improvements, the number and quality of waterfowl may improve,
thereby opening up new areas to hunting and enhancing the experience for existing users.

Enhanced Opportunities for Boating

Although boating does not necessitate human contact with water, boaters are sensitive to water
quality. High turbidity, eutrophication, odors, floating trash, and other visible contamination can
discourage boaters from using a waterway. However, storm water controls may offer benefits to
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                                                                                    5-5
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                              5.0 Qualitative Assessment of Benefits
    boaters by reducing contamination entering impaired waters and increasing water clarity, thereby
    opening up new areas to boating and enhancing the experience for existing users.
                             ":"	-1'1''  ;:'	'     '   ' ' ";::i1 '"'•'" •'•"•'	""••'  •  """i':;'' ;":""'' '•    ;"'"''" " "::;;:;;;  •
    Enhanced Opportunities for Swimming
:'	,.,;, • .•;, "~	'. jlr  " '";    .'.,: ' „=  '  '	:.'.'	';:„ il:,_ ';	",';	 	,,;::.;;„",;,.:;,„."	.";. ;;;;:	';	  ,; I    ,:;;,,;' . • , '.,,  :':.'  : ":"v'„ ,i:i". ':;
    Because swim^                     contact with water, swimmers may have concerns about
    water contamination and its relation to aesthetic preferences and potential health risks.
    Turbidity, algae blooms, odors, floating trash, and other visible contamination, as well as posted
    health hazard warnings, can discourage swimmers from using a water body.  In 1993,180
   MlUpn^^^nicans, visited ocean and bay beaches (Weber, 1995).  The Natural Resources
    Defense? Council (flRDC, 19^97) reported 2,596 beach closures (1,054 of which were in
    California) or advisory days due to sources such as overflowing sewers and storm drains (each
   day that a beach was closed was counted as a separate day). In addition, it should be noted that
   many coastal states do not monitor beaches or monitor only portions of their coastline (NRDC,
    1997), s° many more beach closings and advisory days may have been necessary.
ilT'i"- , .'.'  ""Sis,*1!	PI  ''; "•"	!:	k*  •!%•  '"! : "tyfii*'.l	''"'? ,i! , '", ,:!l!l|,;i,";   m       	           !
  :«,, -i	•" 	Hi,', 	,!i.ii  ; ifi • • •   	i.a,	1, ,'«•••; ,-, 	ill!!!1,,, "M'1 »' ; • •<:" ;.-i ii	; a	ivf',,	      |    ill            I I        I      I
   Additionally, local health departments restricted recreation at 342 individual sites at least once
   during 1995 and 1996.  Storm water controls may offer benefits to swimmers by making waters
 -'-stuiable for .swimming where currently it is not desirable or safe.

   Enhanced Opportunities for Noncontact Recreation

   Activities such as picnicking, jogging, biking, photography, and camping do not necessitate
   direct contact with water; however, water quality affects the ability to enjoy these activities when
   m close proximity to water.  High turbidity, eutrpphication, odors, floating trash, and other
   visible contamination can discourage recreational activity near a water body. However, storm
   water controls may offer benefits by reducing contamination and allowing impaired waters to be
   used as focal points for recreational activities where they are not currently in demand for such
   use. These improvements also may enhance the experiences for current users.

   Enhanced Nonconsumptive Wildlife Uses

   Wildlife viewing activities can be affected by unpaired water quality through the reduced
   quantity and variety of species living in or near water bodies. An estimated 76.1 million people
   participated in nonconsumptive wildlife use in 1991, with 54.7 million observing wildlife and
   19.1 million observing waterfowl and shprebirds (US EPA, 1994). Storm water controls that
   result m greater numbers or diversity of viewable wildlife species will produce benefits
   measurable by increased trips and greater amounts of wildlife seen per trip.
   ',:'•,'..;   :;	;:,.;m;';,."..,    „;.;•"•,;.''	„..	,"/,: ,; v:   ,  v v'"Ji",';;i;v •	;;..j,:'':".:"  - '••: ~   • "•  : ;~"-
  ReducedFlopd Damage
     •• '    ::  ::	:'::  '"' '; 	     	           •       |                  •• ;  	

  Storm water runoff controls may mitigate flood damages by providing additional storage
  capacity, diversion,of runoff;^and reduced isedmen^on^mjflgp4wajsrs. The benefits from
  fe'duced flows and sedimentation can be measured by the reduced damage from flood flows and
  the reduced amounts of sediment deposited by flood waters requiring cleanup.
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                            5.0 Qualitative Assessment of Benefits
  Drinking Water Benefits

  Storm water was identified as a major source of impairment in 3% of surveyed rivers and streams
  and 6% of surveyed lakes, reservoirs, and ponds (US EPA, 1998a). Numerous municipal,
  industrial, and agricultural users treat the surface waters of streams, rivers, and lakes prior to
  their use for drinking water, manufacturing, or power generation. Pollutants from storm water
  runoff, such as solids, toxics (including pesticides), and bacteria, may impose additional costs for
  treatment or even render the water unusable, thereby forcing the use of an alternative source.
  Standards for drinking water, manufacturing, and power generation vary considerably, but
  reducing runoff may-result in avoided treatment and savings for municipalities, commercial
  facilities, and farmers.

  Polluted water also can cause damage to household pipes and appliances. Lowering contaminant
  levels can reduce this damage.  Benefits for drinking water can be measured by the avoided
  additional treatment to compensate for contributions of storm water runoff to water sources, but
  also may be considered benefits under the federal drinking water program.

  Water Storage Benefits

  Storm water was identified as a major source of impairment in 6% of impaired lakes ponds and
  reservoirs surveyed (US EPA, 1998a). The heavy load of solids deposited by storm water runoff
  can lead to rapid sedimentation of reservoirs and other receiving water bodies, meaning a loss of
 needed water storage capacity, which must either be replaced (if possible) or the existing
 reservoirs must be dredged.  The benefits of storm water controls, in particular the construction
 site runoff measure, can be measured by reduced storage replacement or reservoir dredging and
 reduced costs of cleaning out storm sewers.

 Navigational Benefits

 Storm water sediment loads also are delivered to and deposited in harbors and rivers critical to
 navigation and  commerce. Where the waters are used for navigation, solids must be dredged and
 disposed of to maintain the utility of the waterway. In 1995,251 million cubic yards of material
 were dredged from navigational waterways (US ACE,  1996). An estimated 5% of this can be
 attributed to roads and construction sites, representing  12.6 million cubic yards of material (Clark
 et al., 1985).  Benefits of storm water runoff controls can be measured by avoided dredging and
 disposal  costs.

Reduced Illness from Consuming Contaminated Seafood

Storm water controls may reduce the presence of pathogens in seafood caught by commercial or
recreational anglers. Bean et al. (1996) identified 679 cases of shellfish-vectored disease
between  1988 and 1992. Rippey (1994) estimated that illnesses were under reported by a factor
of 20 or more, leading to an annual estimate of 2,700 cases of illness each year.  Benefits from
decreased levels of pathogens may include lower incidences of illnesses due to raw or partially
cooked seafood.
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                            5.0 Qualitative Assessment of Benefits
  Reduced Illness from Swimming in Contaminated Waters
                                                                                     ..'"I,, f;
   Swimmers may accrue similar benefits, especially when storm water runoff contains high levels
   of bacteria, or parasites. Epidemiological studies demonstrate that swimmers who immerse their
   heads in waters with high densities of bacterial indicators bear a greater risk of contracting
   gastrointestinal or respiratory illnesses than those who do not immerse their heads (Haile et al.,
   1996). Benefits of decreased pathogen levels may include a reduction of such bacteria-related
   illnesses.	
                                                                  i                     !
   Enhanced Aesthetic Value

   When storm water affects the appearance or quality of a water body, the desirability of working,
   living, traveling, or owning property near that water body is similarly affected. A reduction in
   storm wafer pollution and excessive flows resulting in the unproved quality of a water body,
   such as more diverse or plentiful vegetation or wildlife, or overall better water quality, will result
   in benefits as these waters recover and become more desirable locations near which people want
   to live, work, travel, or own property.
  Other Ecosystem Improvements

  Increased peak flows resulting from urbanization (e.gl, from increased impervious surfaces) can
  cause catastrophic damage in receiving streams and stream valleys, including streambank or
  streambed erosion, vegetation damage, inundation and flooding, and sediment deposition.
  Forested areas, wetlands, estuaries, and shorelines can become submerged under water or
  Sediment can be deposited by storm flows. Impacts include loss of land, ecosystem and habitat
  damage, and high downstream sediment loads. Benefits from reduced flows can be measured by
  the reduced need for streambank, streambed, vegetation, or near stream and shore maintenance.
  Other benefits can be measured by the reduced need to remove sediment from downstream
  reaches or to repair ecosystem or property damage resulting from high sediment loads.

  5.2  Construction Site Controls
  The Phase II rule requires that construction sites between one and five acres in size control storm
  "Water" to prevent the runoff of sediment and pollutants into nearby water Bodies. Typical
- "methods of controlling runoff include BMPs such as the minimization of site disturbance or
  vegetation removal and silt fencing. EPA expects the implementation of such programs to result
  in reduced pollutant loadings and flows entering small streams with subsequent benefits hi the
  form of improved water quality and habitat of receiving waters.
i	i	

  5.2.1  Model of Construction Site BMP Effectiveness
  To estimate the effectiveness of the erosion and sediment control practices for which costs were
  estimated in Chapter 4 for the 27 model, construction sites, EPA and the US ACE modeled the
  "^effectiveness"of the practices m reducing soil loss from those model sites using the Revised
  Universal Soil Loss Equation (RUSLE) (US ACE, 1998).  Although RUSLE is limited to the
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                           5.0 Qualitative Assessment of Benefits
 development of average annual sediment loss, the model provides insight into how construction
 practices can impact soil loss from a site and how these impacts can vary regionally across the
 United States.  Specifically, disturbances to the soil can result in sediment loss increases ranging
 from 140% to 2,210% depending on the climatic region. The results show varying effectiveness
 of BMPs and may be useful for site planning.  For example, silt fencing alone may not be
 sufficient for sandy soils. Alternatively, some combinations of BMPs may overcompensate and
 thus fewer controls may be needed.

 Offsite transport of soil lost during construction was modeled for one location using Agricultural
 Nonpoint Source Pollution Model (AGNPS), an empirically based, single event watershed
 runoff, erosion, and pollution transport model (US ACE, 1998). Although the RUSLE model is
 considered more credible for calculating soil loss, the AGNPS model provides insight into how
 material is transported within a watershed.  The model was used to determine sediment
 movement through three  generalized watershed sizes under varying degrees of construction.  The
 results showed that soil type, watershed size, and construction site location with respect to the
 outlet of a watershed are important determinants in the transport of soil through a channel to a
 downstream portion of the watershed.

 For all watershed, slope, and construction densities tested, approximately half of the eroded soil
 from upland portions of a watershed with silt or clay soil was yielded to a downstream portion of
 the watershed (US ACE,  1998). However, for sandy watersheds, only a small portion of eroded
 soil was deposited downstream. Upland construction sites had far less impact than those located
 near watershed outlets. And, the model showed that construction in smaller watersheds results in
 a larger percentage increase in sediment yield from the watershed—up to a 70% increase hi yield
 for 30 acres of construction in a 99-acre watershed compared to a  12% increase in yield for 30
 acres of construction hi a 639-acre watershed.

 5.2.2  Anticipated Benefits of Construction Site Controls

 Implementation of construction site BMPs is expected to improve the water quality and physical
 condition of both small streams and larger water bodies. Runoff from construction sites may be
 particularly damaging to small streams because of the streams' typically small flow volume and
 channel size, thus lessening the ability to accommodate high flows and large sediment loads.

 Siltafion has been identified as the leading pollutant or process affecting rivers and streams hi the
 nation (US EPA, 1998a).  Although agriculture produces the largest sediment load, construction
 results hi the most concentrated form of erosion and the rate of erosion from construction sites
 may exceed that of agricultural land by ten to twenty times (Water Environment Federation,
 1992).

 During storms, construction sites may be the source of sediment-laden runoff, which can
 overwhelm a small stream channel's capacity, resulting in streambed scour, streambank erosion,
 stream "blow out," and destruction of near-stream vegetative cover.  As the flow velocity
 decreases, sediment from construction site runoff settles out, blanketing the streambed, burying
macroinvertebrates, and eliminating the natural stream substrate. Streams that are  overwhelmed
by runoff can become wider and, consequently, exhibit shallower base flow, lose the natural
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                                       Final Report
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                                                                                         Or;,*
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ir
Jiiiil
'  '
                                         5.0  Qualitative Assessment of Benefits
             riffle-run morphology, lose to erosion vegetative cover that shades the stream and mitigates
             iemperalure swings, and lose their habitat value for aquatic species.  The recurrence of high
             storm water flows maintains these degraded conditions, ultimately resulting in water quality and
             J        || '111 'WlIF  "| ..... Ill," Eilllli "lliiMlllllH'illJfi'l.iii,1' !!„'! ...... Ui'V ".in1,," J|  I"*"!1 V'lufl , Ull'i" i JUr .......... I .....   ............ i:,r. \, .................... V  ..... .......................... • ...... , .......................... A ..... ........... ' >.i, ...... „ ......................... wr ...... • •• ....... ,«, .......... * ............ a>, - ............ ..... :i
             habitat degradation. The prevention of sediment and flow runoff from construction sites will
                     this degradation.
              Although small streams are frequently the first water body with which storm water conies into
              Contact, tEese streams subsequently drain into larger streams, rivers, ponds, lakes, -wetlands,
              fyays,estuaries, or oceans, thus, stream reaches affected by construction activities often extend
              well Downstream o|the construction site. For example, between 3.6 and 3.5 miles of stream
              below construction sites in the Patuxent River watershed were observed to be impaired by
           "Ls&d&ngntinputs (Klein, 1979). It is near these downstream water bodies that a large share of the
              population lives or participates hi water-dependent recreation. When small stream habitat and
          ^'^jWatar^qiiality degrades, the downstream systems also are affected, suffering poorer water quality
           ^mSi]^j5gstceani habitat for aquatic-dependent species. When^ small stream habitat and water
              quality improves, downstream water bodies also will realize water quality and habitat
              Jl^rbvements, resulting hi benefits for the population living nearby or using the resource for
                                      ow.
        i in
           w^edunentad|on can adversely affect fisheries by reducing the possibilities for reproduction and
             survival offish, leading to lower yields or the elimination of a species. Excessive sediment loads
           :«i lij .Can bury fish eggs and stream substrates favorable for fish reproduction.  Additionally, excessive
           '. |j fitow^ mayjwash eggs downstream.
           ' j'r'fjj '"fl'i ........ !i,|;n '" :*;: "^ */ V5  l! 1,l!i!! ,  ' l!'11!:1!111 ',:,,„', V"'  :„':!,"' ::' ! • •  ,«: „;;"   *:"'' • 1|,,,''i" !", S , f1' /.J111^  IJJ; :::!!!" f/1',; ,! -ii*!"! " ..... !l"" '" : "•"'|i;,'"" ' > « ,•                 i  i
           ...... ' ..... ''"EnitancefO^poirtunities for 'Recreational Fishing  ......... .........................

             Construction site runoff may increase turbidity hi receiving waters and blanket streambeds with
           " !™ iSed^ente^^vering e|gs or fayorable substrates for egg laying. This, in turn, leads to aciult
           ^  ^
             I'iiiii,,, v,   , ....... ''SU"! „ 'lu,,1!! ''iiinu ........ iifijiiiiiiiiiiin I'1 in, . , , <',,,|.,,i  ,,,,n, •! ..... inn .......  liiii;: ..... "   „ ......... < .......... < ..... ..... 'le fish, or the elimination of a specific species from receiving
             waters. Through water quality improvements, the number, size, and quality offish may improve,
             thereby opening up new areas to fishing and enhancing the experience for existing users.
            	3-10
                                                   FinalReport
                                                            '"I,, ::,"!	iik; ' Hi1:, "I1 '.if! '  ,i HI1
                                                                                             October 1999
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                          5.0 Qualitative Assessment of Benefits
Enhanced Opportunities for Hunting

Construction site runoff may decrease the habitat quality for waterfowl species through the
burying of food sources, inundation of habitat, or damage to nesting areas, resulting in reduced
numbers, reduced breeding, or the elimination of a specific species using receiving waters.
Through water quality improvements, the number and quality of waterfowl may improve,
thereby opening up new areas to hunting and enhancing the experience for existing users.

Enhanced Opportunities for Boating

Although boating does not necessitate human contact with the water, boaters are sensitive to
water quality. Sediment runoff from construction sites results in turbidity, which may discourage
boaters from using a waterway. However, storm water controls may offer benefits by reducing
sediment loads entering impaired waters and increasing water clarity, thereby opening up new
areas to boating and enhancing the experience for existing users.

Enhanced Opportunities for Swimming

Turbidity hi surface waters may reduce the safety of waters for swimming. For example,
swimmers may be unable to judge the depth of cloudy waters or to see vegetation that may
interfere with swimming. Storm water controls offer benefits to swimmers by making waters
suitable for swimming where it currently is not desirable or safe.

Enhanced Opportunities for Noncontact Recreation

Activities such as picnicking, jogging, biking, photography, and camping do not necessitate
contact with the water; however, water quality affects the ability to enjoy these activities in close
proximity to water bodies.  High turbidity may discourage recreational activity adjacent to water
bodies. However, storm water controls may offer benefits by encouraging impaired waters to be
used as focal points for recreational activities where they are not currently in demand for such
use and by enhancing the experiences for current users.

Enhanced Nonconsumptive Wildlife Uses

Wildlife viewing activities are affected by impaired water quality through the reduced quantity
and variety of species living in or near water bodies. Construction site storm water controls that
result hi lower turbidity and sedimentation will make food and breeding habitats more accessible;
thus, greater numbers or diversity of viewable wildlife species will be available. Benefits are
measurable by increased trips and greater amounts of wildlife seen per trip.

Reduced Flood Damage

Storm water runoff controls may mitigate flood damages by providing additional storage
capacity, diversion of runoff, and reduced sedimentation from flood waters. The benefits from
reduced flows and sedimentation can be measured by the reduced damage from flood flows and
the reduced amounts of sediment deposited by flood waters requiring cleanup.
October 1999
Final Report
5-11
                                                                                        10
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                                           5.0  Qualitative Assessment of Benefits
I'll	it1
                 Water Storage Benefits

                 The heavy load of solids deposited by storm water runoff can lead to rapid sedimentation of
                 reservoirs and other receiving water bodies, meaning a loss of needed water storage capacity,
                 which must either be replaced, if this option exists, or the existing reservoirs must be dredged.
                 The benefits of storm water controls can be measured by reduced storage replacement, or
                 reservoir dredging and reduced costs of cleaning out storm sewers.
                                                                               i                     i
                 Navigational Benefits

                 Storm water sediment loads also are delivered to and deposited in harbors and rivers critical to
                 navigation and commerce. Where the waters are used for navigation, solids must be dredged and
                 disposed of to maintain the utility of the waterway. In 1995,251-million cubic yards of material
                 were dredged from navigational waterways (US ACE, 1996). An estimated 5% of this can be
                 attributed to roads and construction sites, representing 12.6-million cubic yards of material
                 (Clarjc et al-j1985).  Benefits of construction site runoff controls can be measured by avoided
                 dredging and disposal costs.
                                                                               I
                Enhanced Aesthetic Value
                                                                               I
                When storm water affects the appearance or quality of water bodies, the desirability of working,
                living, traveling, or owning property near that water body is similarly affected. A reduction in
                storm water sediment loads and excessive flows resulting in the improved quality of a water
                body, such as increased water clarity or more diverse or plentiful vegetation or wildlife, will
                result in benefits when impaired waters recover and become more desirable locations near which
                people want to live, work, travel, or own property.

                Other Ecosystem Improvements

                Increased peak flows resulting from urbanization (e.g., from increased impervious surfaces) can
               - cause catastrophic damage in receiving streams and stream valleys such as streambank or
                streambed erosion, vegetation damage, inundation and flooding, and sediment deposition.
                Forested areas, wetlands, estuaries, and shorelines can become submerged or sediment can be
                deposited by storm flows.  Impacts include loss of land, ecosystem and habitat damage, and high
                downstream sediment loads. Benefits from reduced flows can be measured by the reduced need
                for streambank, streambed, vegetation, or near stream and shore maintenance.  Other benefits can
                be measured by the reduced need to remove sediment from downstream reaches or to repair
                ecosystem or property damage resulting from high sediment loads.

                5.3  Conclusions
                       [the^six.municipal^minimum measures; that comprise the municipal storm
   watif pfogram as well as the construction site runoff program. Both programs are expected to
   control the impacts of storm water runoff and result in benefits to the nation's waters. Benefits
         : unproved recreation, such as fishing, swimming, or boating; reduced flood damages;
    1,	:
             ~-:'-5-12
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                                                      Final Report
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                                                                 .•.;..'iT';
                                                                         " fit;",)"
                                                                          '•
                                                                               October 1999
                                                                                                        *,r.y\
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                             5.0  Qualitative Assessment of Benefits
 reduced drinking water and water storage requirements; reduced illness and health risks;
 enhanced aesthetic value; and finally, improved ecosystem health. Chapter 6 contains the
 discussion of the quantification and valuation of benefits.
October 1999
                                        Final Report
5-13
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                                                ....... .    >•   :,     i, .....  *
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               6.0 QUANTITATIVE ASSESSMENT OF BENEFITS
  This chapter reports estimates of the potential value of quantifiable benefits of the Phase II rule.
  It begins with an overview of the economic concepts and analytical issues associated with
  defining benefit categories and developing quantified and monetized benefits estimates. This
  framework for the benefits analysis is in Section 6.1.

  EPA estimated benefits using two separate approaches.1  The first approach utilized the National
  Water Pollution Control Assessment Model (NWPCAM) to model reductions hi pollution
  loadings due to the municipal minimum measures and soil erosion control provisions of the
  Phase II rule.  The changes in loadings are translated into changes in water quality in a model
  that estimates water quality for more than 600,000 river reaches in the United States.  Section 6.2
  briefly describes the modeling approach and benefit valuation method. This method transferred
  willingness-to-pay estimates (WTP) from a national study of the value of water quality
  improvements (Mitchell and Carson, 1986) to derive benefits.

  EPA's second approach, which is described in Section 6.3, has separate estimates of the benefits
  for the municipal minimum measures and the soil erosion control provisions and also provides
  estimates for some marine benefits.  The benefit analysis for the municipal minimum measures
 provision used national water quality assessment data reported under Section 305(b) of the Clean
 Water Act to estimate both the impact of urban storm water runoff on national water quality and
 the subsequent benefits of efforts under the Phase II rale to mitigate this source of water quality
 impairment. The valuation step of the analysis incorporated estimates from Carson and Mitchell
 (1993) of household WTP to improve national water quality.  EPA also used a benefits transfer
 analysis to estimate potential human health and recreation benefits associated with marine water
 impacts.  For the soil erosion control provision, EPA estimated the share of national construction
 activity affected by the rule to apportion a household WTP value reported hi Paterson et al.
 (1995) for soil erosion control policies.

 Section 6.4 describes the key limitations and uncertainties in the benefits estimated using either
 approach and provides sensitivity analyses for selected  sources of uncertainty. Section 6.5
 presents a comparison of benefits estimated using the two approaches.
1 In the economic analysis for the proposed rule, EPA used a "top down" approach to estimate economic benefits.
That is, EPA estimated the potential total economic benefits of all wet weather programs and then allocated the
benefits to individual programs using best professional judgement. The use of best professional judgement
introduced uncertainty into the benefits estimates. In addition, the top down approach differed from the "bottom
up" approach used to estimate the cost of the proposed storm water rule, which developed unit costs per
municipality and construction start that were multiplied by the estimate of affected municipalities and starts.
Therefore, for this analysis, EPA developed two bottom up approaches for estimating benefits from the rule.
October 1999
                                        Final Report
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                                         6.0 Quantitative Assessment of Benefits
               6.1    Framework for Estimating Benefits
               Economic benefits refer to the dollar value associated with all outcomes of the rule that lead to
               higher social welfare and reflect estimated changes in consumer and producer surplus. These
               surplus values reflect the degree of well-being enjoyed by people given different levels of goods
               or services and prices, and are widely accepted concepts of applied welfare economics (see, for
               example, Freeman, 1993). An important component and potential limitation of this conceptual
               foundation	isJhStenefftjv^                                                        	
               valued by humans. Some analysts, however, argue that ecological benefits accrue and are
               separate from the values placed by humans on the protection and enhancement of habitat and
               living species  But because there would be no way to assign a value to such benefits for
               consideration in a benefit-cost analysis, ecological values are considered to be included within
               the traditional use and nonuse (passive use) benefits discussed below.
               	:   	" 	'	'   	j	;	
               6.1.1  Definition of Benefit Categories

               To move from the qualitative assessment of benefits presented in Chapter 5 to quantitative
               estimates of value, EPA first categorized the potential outcomes as they relate to different uses of
               the affected water resources, using, as a starting point, a list of categories developed for the
               analysis of the Caufornia Toxics Rule'(US EPA, 1998).'	Categorizing benefits in this manner
               ""helpsi" ensure '"that 'all Benefits are identified arid double counting is avoided. The potential benefit
               categories associated with water quality improvements are shown in Exhibit 6-1.

               Use Benefits
•ill:, ""I'-
 ll!1!1, i •	
 ISC	llrl'-l
               Use benefits include all of the current direct and indirect ways that people expect to make
               physical use of the resource (Mitchell and Carson, 1989). Direct use benefits are those that result
               from enhanced recreational water activities such as swimming or boating, or from reduced
               gxposufe to contaminants (e.g., the avoided illness cases reported in Appendix C).  Diversionary
            I:;;.; ^b^nefitsare afea.djrect use benefits .and include.avoided _wat^ storage replacement wste and
            ^"/^jg^^^^'^gj^"''indirect use"benefits are mose that resulFfrom water quality
               improvements that enhance other, nearby activities. For example, improvements in water quality
               rnay sustain waterfowl habitat, enhancing bird watching. A wide range of direct and indirect use
               benefits are expected to result from the Phase II rule.
    '  ""IS  -il'iiiii!  I'll i
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                                                  	ii. "!.-'„!	.(,!	i,
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                                                      Final Report
                                                                                              October 1999

                                                                                                         ~-s
                                                                                               '	"	-	i"!	'
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                            6.0  Quantitative Assessment of Benefits
                    Exhibit 6-1. Potential Benefits of Water Quality Improvements
In-Stream Use " ~
» t ,y+ i
'*' -> C '' \}fjr
- . "3- ' 1
. . „*, ,. ''
Near-Stream Use
^ •*-•"=
f k •» J "* t
I ~< *> * * 1 «• _
- "I .» M ^
i i i-
1 ' r ' r ' * - «
Diversionary Use -
, "•'" ^ "<,"•„ t! -
•<* - i '<• „ > j.-1 •.""', -
' " t " U "
, • vv i,\,
- u
Aesthetic Use
^Passive Use
«-,_,*• ' ~
*s ^ * !•
3 ' "% ^ J V
",^ ^ ' "^
• Commercial fisheries, shell fisheries, and aquaculture; navigation
Recreation (e.g., fishing, hunting, boating, swimming)
• Subsistence fishing
Human health risk reductions
Water-enhanced noncontact recreation (e.g., picnicking, photography, jogging,
biking, camping)
Nonconsumptive use (e.g., wildlife viewing, hiking near water)
Flood control (reduced property loss and risk to health and safety)
• Industry/commercial (process and cooling waters)
Agriculture/irrigation
Municipal drinking water (treatment cost savings, water storage dredging and
construction savings, and human health risk reductions)
Residing, working, traveling, and owning property near water, etc.
Existence (satisfaction gained from knowing the resources exist and knowing others
enjoy the resources; ecologic value, including reduced mortality and morbidity,
improved reproductive success, increased diversity of aquatic and piscivorous
wildlife, improved habitat for threatened and endangered species, and improved
integrity of aquatic and aquatic-dependent ecosystems)
Bequest (intergenerational equity)
  Note: Previous analyses have included option value as a potential benefit of environmental improvement. For
  this analysis, EPA adopted Freeman's (1993) conclusion that option value does not exist as a separate benefit
  category.

 Nontise (Passive Use) Benefits

 Nonvise or passive use benefits include the values humans place on the resource apart from their
 desire to use the resource. Storm water runoff can negatively impact aquatic and wildlife
 species, as well as the ecosystems in which they live and reproduce.  Control of harmful
 quantities of runoff and loadings can result hi ecological benefits, including reduced mortality
 and morbidity of aquatic and other wildlife; improved reproductive success of aquatic and other
 wildlife; increased diversity of aquatic and other wildlife; improved conditions for successful
 recovery of threatened and endangered species; and otherwise unproved health of aquatic and
 aquatic-dependent ecosystems. Passive use values may stem from a sense of stewardship for an
 aquatic resource or from knowledge that others do and can use a resource (vicarious
 consumption). These values also may arise from the desire to preserve the resource for future
 generations (bequest value) or from a philanthropic sense of environmental responsibility.

 6.1.2  How Benefits Arise from Water Qualify Improvements

 Freeman (1993) describes three functional relationships that link a particular regulatory action to
 beneficial outcomes: the relationship between resource quality and pollution control; the
relationship between resource quality and human use of the resource; and the relationship
between economic value and human use of the resource (Exhibit 6-2). Thus, estimating the
potential benefits of implementing storm water controls involves the use of applied economic
theory, but also requires involving a range of other types of information on the biological and
October 1999
                                       Final Report
6-3
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„-!	 "»: i	i"
no „; >  ::
                                         6.0 Quantitative Assessment of Benefits
                ecological links between aquatic and other wildlife and their environments. Exhibit 6-2 depicts
                the stages involved in determining the benefits associated with environmental improvements.
                Although developing mfbrmation to shed light on all stages of this process can be challenging,
                Freeman notes that it is particularly difficult to determine the link between resource quality and
                human use of the resource (Stage 2 in Exhibit 6-2). This difficulty arises because only in rare
                calif is the level of resource use a simple function of a single water-quality indicator such as
               ,,^^^.^^^ (Freeman, i993)  Instead, some uses (e.g., commercial fisheries, recreation)
                depend, "in complex ways, on the whole range of physical, chemical, and biological water-quality
                indicators (Freeman, 1993).                                       .

                For example, Freeman notes that species distributions offish, algae, zooplankton, and bacteria
                may be affected by changes in physical and chemical parameters of water quality, and not
                necessarily in the same manner, such that even providing a descriptive characterization at this
                stage is a formidable task. In addition, defining which water quality parameters are most
                important in influencing uses of a water body (such as fishing or swimming) requires extensive
                research (Freeman, 1993). Freeman notes that the development of predictive models for these
                parameters is a major research priority.
                                 " ""     "                '      '  '         1      '       .....        "
                        i III
                Despite the many difficulties associated with determining Stage 2 in Exhibit 6-2, there is a well-
                developed theory of economic value for use at Stage 3 of a benefits analysis where monetary
                value is placed on things such as improved recreational opportunities, increases in fish
                production, or the availability of a particular fish species (Freeman, 1 993). However, even at this
                stage, difficulties arise.  For example, the travel cost method is often used to value site specific
                recreation and is sometimes a preferred approach because it relies on observed behavior to
                determine value.  The method uses travel costs to a recreation site as surrogate prices. With
                information on travel costs and the frequency of an individual's use of a site, demand functions
                can be developed and consumer surplus estimated. However," the travel cost method has
                shortcomings when attempting to value changes in the quality characteristics of a resource. For
                exampiejas Bockstael et ah (1989) discuss, the method only includes sites that are visited,   .
                excluding sites that indeed may have desirable quality characteristics that are not necessarily
                more e||ensive. The wide array of services and quality characteristics among sites in
                conjunction with population centers also makes it difficult to discern which aspects of
                environmental quality are being valued.  As a result, determinhig use value can be difficult
                despite the availability of data based on observed behavior.
Another example of potential difficulties at Stage 3 is related to estimating nonuse or passive use
values. Total resource value is thought to consist of personal use value, including existence and
bequest values (Stevens et al., 1991). Indeed, Stevens et al. (1991) note that preliminary
evidence suggests that existence value may be the most important component of value.
Contingent valuation (CV) is the only technique capable of measuring existence values and this
technique has been ruled as an appropriate and acceptable means of estimating nonuse values in a
damage claim (US Court of Appeals, 1989).  A National Oceanic Atmosphere Administration
            	:	"  6-4
                                       Final Report
                                                                                             October 1999
run I-"i	" i: it" •    I,1,! 	i  •• "

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                            ill
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                            6.0  Quantitative Assessment of Benefits
       Exhibit 6-2. The Production of Benefits from Improved Ambient Water Quality
                                REDUCTION OF DISCHARGES
                                  Biochemical Oxygen Demand
                                  Suspended Solids
                                  Floating Solids
                                  Heat
                                  Toxics
                                  Miscellaneous chemicals
                                  Radioisotopes
          CHANGES IN PHYSICAL AND
          CHEMICAL INDICATORS OF
              WATER QUALITY
           Dissolved oxygen
           Temperature
           Turbidity
           Odor
           Nutrients
           Other chemicals
           PH
                                         Stage 1
                        CHANGES IN BIOLOGICAL
                     INDICATORS OF WATER QUALITY
                             Fish populations
                                 Algae
                              Zooplankton
                                Bacteria
           Stage 2
CHANGES IN HUMAN USES OF
      WATER BODIES

  Water supply:  residential
      industrial, irrigation, etc.
  Fisheries
  Recreation
  Aesthetics
          Stages
  VALUES OF HUMAN USES

  Measured in monetary unite
  Source: Freeman (1993).  Reproduced with permission.
October 1999
          Final Report
                                                                                          6-5
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                            6,0 Quantitative Assessment of Benefits
'|i'i,:!','|l ,,,' '< juli 	, i!'HI|||||||ii|i Jlllllllllllllllili  ,'i||||i|F , "f II,,, n	ill" ,1,, Illlllllll I,'", "i'(II nli	, p r, ill, f'l '" I",!!	IT 'flil'l'i1111 ,1 h,, i,,l" i'l'l' T , ,' in," ., ,llll!lllllllINIllllll|i|ii 'illllll' lilliil, ' lAlll <»,; I,, iK IWi i illl'lll	II, I /	M'II '  ,«,! HI'1 Ililli'i' „ if ' j :'|il,,l,<  	i.	'"*!,.!' v. "II!-:!,1	;, nil •ill!'1. ," -,:  i<:"  •	lf!M •'• »"	Bit ,!:,!]: "lUl'Iii	:,,!,':'III! if <,'•'' •«,»  ' :	III'!'"!" 'Jli'ili'JI	'Ill
111   'j!".i	 I'lllllllliiA" I'lJ'iillli* . 	 r  > , m,, :;;,„ Uii" I "i ,il",;l '~i :,";, '"I '"Ju "' 'flii1;,,,., |: i ;,l „	 , „!/, i'f Ill „ II ,i" i, '"L11",, 111, ', ., , .ijil,,1'  rinillll
  For this analysis, EPA simulated  baseline water quality impairment and improved water quality
  for the phase II municipal minimum measures and construction site controls using the National
  Water Pollution Control Assessment Model (NWPCAM). Documentation for this analysis is
ii n ivJih	iM ', iiiiiiiiiiiiiiiiiiiiiiiiiniiiii'"!'!	i,ii	lariiiiii,1 M'li'LiJiii'j	mil1",,, niiirwiii	'iM!*':;/™!'!	iiiiii:  ii|ii rii ',„ •> 'iin '<  n x >,   *	 •	 '	,	r	
         1 in. Appendix E.
 N^WPCAM estimates water quality parameter values and the associated level of use support for
 tljg £3.2,000 miles of rivers and streams in the EPA's Reach File Version 1 (RFl), which covers a
 fraction of the 3,600,000 river and stream miles in the continental United States.2 The water
 quality parameters in the NWPCAM are biological oxygen demand (BOD5), total suspended
 solids (TSS), dissolved oxygen (DO), and fecal coliforms (FC). NWPCAM incorporates
 geographical and hydrological information as it produces estimates of the water quality
 parameters, which are converted to use support designations based on the standards for FC,
 BOD, DO, and TSS shown in Exhibit 6-3. The model computes the designation for each river
 and stream segment of one mile or less by:

                ling the values for each water quality parameter based on loadings and river
 •      Comparing these values to the reference conditions for meeting each of the use categories
                      1	'""	'   "  '""	'	'	""	'	'	'	r	       '	  '	
 •      Assigning the use to the entire segment.

 The model classifies a stream or river segment based on an exceedance of any of the four criteria
 presented in ExJubif "6-3" For example, if the segment meets the FC, BODS, and TSS criteria for
 swimming, but it meets the DO only for game fishing, then me segment is classified as
 supporting game fishing. If any of the boating criteria are exceeded, then the segment is
 classified to indicate no recreational use support.
          Ill III in         I      ""   MII •!' 'ii1,,, •   "i,,;	K ," JTJT     	     	   	                	
                                                                                     Ii „ 'Mi.j WIJi	  .Hik'i,,,
 2This model was used for the Exequtive Orde;r op "Infrastructure'' mat was reyiewed by Office of Management and
 Budget (OMB). EPA also used an older version of this model as documented in the appendix of the Economic
 Analysis for the Proposed Phase II rule submitted for OMB review.
6-6
                                         Final Report
October 1999
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                            6.0  Quantitative Assessment of Benefits
                           Exhibit 6-3. NWPCAM Water Quality Ladder
   Source: Bondelid et al., 1999.
Beneficial Use
Drinking
Swimming
Game Fishing
Boating
Fecal
; Coliforms
(MPN/lOOmL)
0
200
1000
2000'
Dissolved
Oxygen
(mg/L) /(% sat.)
7.0/90
6.5/83
5.0/64
3.5/45
5-day
BOD
(mg/L)
0
1.5
3.0
4.0
Total
Suspended
Solids (mg/L)
5
10
50
100
  To estimate the impact of the soil erosion control provision on water quality, the construction
  start modeling component of the model estimates loadings reductions by simulating the effects of
  various BMPs (e.g., seed and mulch of the model, and sediment traps) using the Revised
  Universal Soil Loss Equation (RUSLE). The analysis is based on a U.S. Army Corps of
  Engineers (1998) report on BMPs for small construction sites and is described in more detail in
  Appendix E. Note, however, that the NWPCAM does not address potential impacts of post-
  construction controls.

  The construction part of the NWPCAM contains a "small streams" submodel that adds 34 500
  miles of small streams to the original NWPCAM/RF1 framework. This "small streams"  '
  submodel is included in the model to address the fact that many construction starts are not
  located next to the larger streams contained in the overall NWPCAM/RF1 river framework  but
  they are located near smaller streams. With the addition of the small streams, the submodel
  routes the loadings from construction sites to  the overall RF1 framework. The model treats the
  community with construction sites as a point source.  For each community with construction
 sites, the submodel assumes one small stream to transport loadings to the nearest RF1 stream
 The submodel decays the loadings using the same assumptions that the rest of NWPCAM uses
 Date for flow in the small streams is based on a hydrologic analysis that relates distance from '
 RF1 to drainage area and  then uses an RF1 flow analysis to estimate mean summer flow as a
 function of the drainage area. For this initial work on small streams, the model includes a
 straight-line distance from the construction sites to RF1 (i.e., stream sinuosity is not taken into
 account).

 6.2.1  Potential Fresh Water Quality Improvements

 Using the NWPCAM, EPA simulated baseline water quality and improved water quality caused
 by the anticipated loading reductions from municipal point sources and construction sites
 affected by the Phase II rule. These water quality changes are estimated for a river reach that is
 located immediately below a discharge source.
October 1999
                                      Final Report
                                                                                   6-7
                                                                                      •A ••
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                                        6.0 Quantitative Assessment of Benefits
             Baseline Simulation Conditions

             EPA used NWPCAM to estimate baseline water quality conditions nationwide using the
             following assumptions to estimate baseline loadings from various point and nonpoint sources
             including urban and rural sources:

             •       All combined sewer overflows (CSOs) are controlled by detention basins and the
                    assumed runoff capture rate is 85%, whichis based on"NEEDS" Survey assumptions
.i,,'!1"!' "„,'"iililli,  •   	•"''   * ,    'I!' .'I'llii,:   	I1'!',!! I  ' ''" • 'I1!!,:,,1:11, ' '  '! "" '"'I	jjlil 1 „:    || I III II      ",   "'if:1          I III       III           ' ,, ,,  II    I
             •       Detention basin controls are at each of the 1,723 individual NWPCAM Phase I urban
                    sites and the assumed runoff capture rate is 85%

             •       Construction start BMPs are in place in areas with existuig State programs

             •       Construction start BMPs are in place at sites greater than five acres.

             A statistical groundtruthuig of the model to storage and retrieval ambient water quality data
             indicates that the NWPCAM produces a reliable baseline estimate that can be considered a
             reasonable, predictor of the actual use support for the 1990s.

             Phase IIScenario Conditions
	l,i, • 'iHBIi	    Ill    II (I     I    III           I       '	i:,,  ,  *i	i  \  ,,  „•'-    \         11  I  n      |(|i       Hi          1	 I i   liiiill  'Jl
             The Phase II conditions include the baseline conditions and are assumed to further impose the
             foUqwing:

             •       Detention basin controls at each of the 5,038 individual NWPCAM Phase II urban sites
if:  ,1,   '   IBM,:  ,;-n   in i, »>'»"•, i, f	in 'i;	/i,	i	<: i	;i	      ', mm	 ii1', :"i	HI	iimi, -i it  '  	•,	•,	•	 »  ,,  n,	 	,-	 	,	,,		,,•	
   :  .    •• ™r>(_•'! -	;	i» with an assumed runoff capture rate of 85%
!'  ' miini ' .i1 i   llnl't'l ,  nl'  "i ilnll'i!' i 111.1"!  .» Ii II •"  Hi	III!  ' , ,'! 'V	 ' '  i f". i 	  I! ', . '  , " ii" I"'!,,,, 'ii.1' n| , If ll'lPni1 "I	liTI'liiii,1 i"lu'ill'II'- "'S', „ "i .1. "Vr 'lihriiUlirr "IV1 < ''Vi.'1'™ ,	ii" ',/' " , , 	I	IlilT, ' !'' i,i " , » ' ,11   '< '*,* '  i( .ilinlliJlJ "11" I'M •'• I
             *       Construction start BMPs are in place at sites between 1 and 5 acres.3'4

            NWPCAM rgquires an engineering surrogate for treatment of specific pollutants contained hi
             discharges, whereas the Phase II program includes both structural and nonstructural controls.
             Therefore, the model uses detention basins as a proxy to represent the impact of the municipal
            program. Based on surveys of existing literature on removal of pollutants from detention basins,
            EPA assumed controls on the urban runoff loadings would remove 33% of BODS, 60% of TSS,
            and 70% of FC. These .removal rates can^be considered conservativemedian values; as noted
            below in Section 6.3, EPA believes that the actual implementation of the Phase II minimum
            JThe Phase n municipalities identified in the model are 5,038, instead of 5,040 used for the cost analysis and the
            second benefit analysis approach, because matching for two of the municipalities could not be made in the
            population data bases used for the model.
            
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                           6.0  Quantitative Assessment of Benefits
 measures will result in an overall program effectiveness of approximately 80%. Pollutant
 loadings sources in the model include 37,005 municipal and industrial point sources, 742 CSO
 loadings on 505 reaches, urban and nonpoint source loading estimates at 42,479 individual
 places, rural loadings (primarily from agriculture), and construction starts. The summary of the
 regulated universe and the assumptions are presented in Exhibit 6-4.
                 Exhibit 6-4. NWPCAM Summary of Key Model Assumptions for the
                             Storm Water Phase II Benefits Analysis

Number of Construction Starts
Number of Acres of Construction
Starts (Estimated from Input
Dataset of Numbers of Starts)
Construction Site Parameters
Construction Site BMPs
Combined Sewer Overflows
(CSOs)
CSO Runoff Control
Urban Runoff Sources
Note: Population adjustments made
to reflect 1998 values and
populations served by CSOs.
Urban Runoff Controls

Current State Programs: 100,316
Phase I: 184,520
Current Programs: 207,869
Phase I: 1,845,204
7% Slope, Medium Soils
1 . Between 0 and 4 Acres:
Silt Fence, Seed & Mulch, and
Stone Check Dams
2. Greater than 4 Acres:
Seed and Mulch, Stone Check
Dams, and Sediment Traps
742 CSOs on 505 Reaches
Detention basin-level of control for
CSOs, capturing 85% of the runoff,
with 33% removal of BODS, 60%
removal of TSS, and 70% removal
ofFC.
Phase I: 1,723 Places, 72.4 million
people
Not Phase I or II: 35,718 Places
with 81.7 million people
Capture 85% of the runoff, with
33% removal of BODS, 60%
removal of TSS, and 70% removal
ofFC.
'i^g^M^f^i/j-'ff^^i^^^
ilfiWitliiPtiase-JI-Implem'entationgj--
V?* - »'"• V'.-^'X;'.r,,>. iVv ,*• & -$,•*' •*>. -^'fr "n&zrg^'-tySHlg&f
Phase 11: 120,047
Phase II "R" Waivers: 13,057
0-1 Acres (unregulated): 91,332
Phase I: "289,819
Phase II Waivers: 33,517
0-1 Acres (unregulated): 45,491
7% Slope, Medium Soils
1. Between 0 and 4 Acres:
Silt Fence, Seed & Mulch, and
Stone Check Dams
2. Greater Than 4 Acres:
Seed and Mulch, Stone Check
Dams, and Sediment Traps


Phase II: 5,038 Places, 78.5
million people
Capture 85% of the runoff, with
33% removal of BODS, 60%
removal of TSS, and 70% removal
ofFC.
October 1999
Final Report
                                                                                      6-9
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             i  II
             I	' !'
                                   ill ' 1||M| f IT'lii;'! "''ill liti,!1' •' I' "!l'l liililllllli1! " 3W'!' 'iiiiii .III ...... .."I!1""1 „ ill!1,!!! jilliiPMilSlil1!' .'liflliVlill
                                                        i, III! till '' ii1" 'Hi. 'ii "W "'
                                                                                  I	\	i	ili'ri'J
                                                                            •'•I	n • "n ill1.1
                                                                            ;';	D
                                          6.0  Quantitative Assessment of Benefits
                The number£^m^(Bs"projected by i^PCAM to meet "me designateil uses as defined in the
                Resources for the Future water quality ladder under the baseline and the Phase II conditions are
                summarized in Exhibit 6-5. Miles are reported for swimming, game fishing, boating, and no
                support. The exhibit also shows the net change miles for each use category. For example, the
                net change oF'an Additional "4",54"8' miles that meet fishing and 'fioamig" water quality standards
                accounts for improvements in miles that were previously classified as boatable or no support
                minus the miles that were previously classified as fishing and boating that improved to
                swimmable.
Because the model uses water quality parameters rather than designated uses to determine
impairment levels, the implied number of impaired miles is approximately twice as large as the
impaired miles reported in.the 305(b) data (US EPA, 1998a). According to impairment data
summarized in Exfiib'it3^4, apprb'^omately 3"6%"bftn"e(j^S'^OS surveyed river and stream miles
in the nation are classified as unpaired based on their respective designated uses.  Thus, 249,800
miles are impaired. In contrast, in NWPCAM any river stretch that does not meet swimmable
water quality standards will be considered impaired. Consequently, the model estimates that
approximately 447,600 miles are impaired. This will tend to generate a larger benefit estimate
than the approach hi Section 6.3, which is based on 305(b) data.
                                        i    ;•'J?I '«H!".',I;" "'; Jl'i{  &»!-,„' |jL'v:., ,..• i	:"	W;J",
             Exhibit 6-5. Summary of Miles Meeting Designated Uses Under Baseline and
                                Scenario Phase II Conditions
    .i fit iUilii;' '	K
	 ;.;., . ' • •_ - v "1 ft** f A;'*
i "; i; S ' f ,!• l i vf - i i "" t,r ,
,Usc Support
Swimming, Fishing, and Boating
Fishing and Boating
Boating
No Support
Total Miles
• . Baseline Miles
(mid-i990s) "
219,547
418,190
480,515
186,589
667,104
Phase n Miles
223,674
422,738
483,451
183,653
667,104
Change in Miles *,
(Phase H— Baseline) '"-:
4,127
4,548
2,936
-2,936
n/a
                       Potential Yalue of Improved Fresh Waters

                EPA monetized the changes in designated uses of stream reaches using Carson and Mitchell's
                (1993) estimates of household WTP for incremental water quality improvements. EPA
                determined the number of households in the proximity of an affected stream reached by
                overlaying the modeled water quality results with population data from the 1990 Census of
                Populated Places and Minor Civil Divisions, updated to 1998 population levels.  EPA then
                developed economic benefits based on these household estimates and estimates of household
                WTP.	"	"	'	
               , r.	  ;„;	•	;	  -	  •.•;„•  „•	 •:	 •,.     ,:  .. , ••	;	;;	:„•	:	  ' ,-  ,;;:;;:,;	••:. j	:   •  •  .,; ,  :	 -„; •.:,.-„.;•:
                Carson and Mitchell (1993) estimated the magnitude of WTP for incremental improvements hi
                fresh water quality on the basis of their 1983 national survey. In the survey, respondents were
                asked to value three minunum levels of fresh water quality:
i
                6-10
                                       Final Report
October 1999

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                            6.0 Quantitative Assessment of Benefits
 •      Beatable: the value to keep the nation's waters from falling below boatable water quality

 •      Fishable: the value to raise the minimum standard from boatable to fishable

 •      Swimmable: the value to raise the minimum standard from fishable to swimmable.

 Carson and Mitchell (1993) reminded respondents of several reasons for valuing fresh water
 quality:

 •      Using fresh water for boating, fishing, and swimming

 •      Using areas near fresh water for picnicking, bird watching, and staying in a vacation
        cottage

 •      Getting satisfaction from knowing that other people use fresh water resources

 •      Knowing that the nation's water is cleaner.

 In addition, respondents were provided with the following information regarding baseline water
 quality:

 •       The (then current) minimum level of water quality is boatable

 •       Most of the nation's's fresh water bodies are fishable

 •       About 70% to 80% of fresh water bodies are swimmable.

 Respondents used a payment card displaying a wide range of payment amounts to indicate their
 household WTP. Carson and Mitchell corrected their WTP estimates for biases inherent in the
 response rate and adjusted them for inflation using the Consumer Price Index (CPI). The authors
 also discussed appropriate adjustments to their estimates based on changes in the regression
 variables that determined a household's WTP for water quality improvements:  real income  and
 attitudes toward pollution control.  Carson and Mitchell noted that the University of Chicago's
 National Opinion Research Center's General Social Survey suggests an approximate 30%
 increase in the number of respondents who think that there should be more spending on pollution
 control; other survey organizations report similar or larger changes in attitudes. To update WTP
 estimates to 1998 levels, EPA made similar adjustments to the WTP amounts to account for
 inflation growth in real per capita income, inflation, and a 30% increase in attitudes toward
 polhition control.5  The adjusted bids are shown in Exhibit 6-6.
5 The adjustment for inflation is based on the change in the CPI from 1983 to 1998 (a 64% increase) as reported by the Bureau of
Labor Statistics (U.S. Department of Labor, 1998). Note, however, that there is currently a debate regarding the accuracy of the
CPI. Recent analysis indicates it may overstate inflation by about 1%. To adjust for changes in income and attitude, EPA
adjusted the mean explanatory variables for income and attitude in the WTP function (Carson and Mitchell, 1993) by 28%,
which is the change in personal disposable income (U.S. Department of Commerce, 1998b), and 30% respectively to recalculate
WTP for the category of boatable to fishable. These changes to the explanatory variables resulted in a 38% increase in the
calculated WTP. Consequently, EPA applied an adjustment factor of 1.38 to all WTP values.
October 1999
                                         Final Report
6-11
   \ •
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                                                                                                             	S!i	
                                            6.0 Quantitative Assessment of Benefits
ft:!: I 3!'
i	IE: '
111 !'[ ! • I
                    Exhibit 6-6. Mean Annual Household WTP Amounts for Different Levels of National Water Quality
Water Qualify Level
Nonboatable to boatable
Beatable to fishable
Fishable to swimmable
WTP1, , . ,',„,
,(1983 dollars)
$93
$70
$78
Adjusted Corrected Bid2
(1998 dollars)
$210
$158
$177
                                                                                     .1
Note: N=564
1 Source: Carson and Mitchell (1993), annual household values adjusted for unit and item bias.
2 Adjusted bid: bid as adjusted by Carson and Mitchell x adjustment for inflation x adjustment for changes in
income and attitude = ($93) x (1.64) x (1.38).
                                                                     i
These WTP estimates are applied to value improvements hi local and nonlocal waters separately
because the survey results indicated that changes in statewide water quality are more important
than changes in water quality elsewhere. In then- survey, Mitchell and Carson asked respondents
to apportion '^h'""of their "stated WTP va|ues betweeniVcTEuevrngth^'water quality goals in their
         • and acKeviig those goals in the nation as a whole. On average, respondents allocated
            •j.'^!^^-jo acjgeving in-state water quality goals and the remainder to the nation as a
whole. Mitchell and Carson (1986) argue that for valuing local (substate) water quality changes
g^fy Qf ^g' tvTP value is a reasonable upper bound for the local multiplier; the remaining 33%
Of 1he value is applicable to nonlocal water quality changes.
If:. ,
To apply the Mitchell-Carson values to changes in local water quality where only a subset of the
waters is affected, Mitchell and Carson (1986) describe three "multipliers." The first is a
percent-local multiplier, which defines the percentage of the stated WTP amount that is applied
specifically to water quality improvements in the local area in question. The second is an
impairment multiplier, w£|cn describes how WTP changes in relation to the fraction of local
water quality impairment that is addressed by the rule. The third is a population multiplier,
which is simply the size of the population benefitting from the local improvement in water
quality.
  • "  .ii!|"Liii.i l"'Ji, , n|   f x '- . ....... : :;,,», 'V si' i   •"•••i1':    i '•:, • -'""i*"1  „ '" ..... "• n. . 1 '  ,,  .," ..»   .'".''", <' •  •„'<*      \  in
  ...... ,   flni'.li   ''IIP'   I I1  ....... 1,'1 ...... ''„ ,i  ;, 'liii,    "!'n ll1   il ' '",!!,,ii ,- i5l i1 1 ....... 11'" "ii  "  <     ' I ' '•'' ' 'ilf"!!!| ',i iiilH  . ', '' i I i,,1 1 . ,1  hi , '., ,«' < i1 iB» I111   '  .<
For this analysis, EPA defined the locality as urban sites and associated populations linked into
the NWPCAM framework.  In this analysis, "local" waters are defined as reaches that are located
near each of the population locations. The definition of "local" depends on whether an area is
classified as a Census populated place or minor civil division. For populated places, EPA  drew a
circle witE an equivalent area to the place', 'centered' on the place latitude/longitude coordinates
given by the U.S. Census Bureau and considered any reaches that fell in whole or hi part within
mat circle "local" to that place. For minor civil divisions, the closest reach is considered to be
the "local" water. EPA estimated "local" benefits based on use support changes hi reaches that
are "local" to each population location. The benefits depend on the portion of the local and the
national unpaired waters improved as a result of the Phase II soil and erosion controls for
" 111,11' |,| .ji'l i, ...... t ,| ..... |i|l! , 'mill ...... •* ,„ ............       ................ •*• ,      ......................... ...........................  ...................... ......... ......... ....... [[[   .............. I ,, ,   .................   .....................  .................................
construction sites and the municipal pollution prevention measures.
...... [••• ...... ' :• ..... |; ..... > . ..... • . " ..... S ..... ii i.fii ..... 1= ....... *'• : •   •' it'!'' '>i, i> ':' i ' liHi '? ''"' • lid" ('* •••  :¥!:!'! ..... ; i" '.• ..... if!'!?1 ; 'i S~ . "• ....... MSA ...... ;« >. :: > • • •  .' '• if'* : '•* „ • ..... '  "i: :; 5 "- ' , '" i • ..... .......... •''"" ?=!'  ••>'• W ..... I "f
., .......  ';  ",.; ..... iniil!))  I.iiSiiiil ' 'i. ............ . ; ijli,!-*"! f. ...... , "i ...... .....  , • .....  ''Sir,  , '• ,r.|b  n,""/ ......... ..Milk.'*.. 1"*^,:, ,' h > i .: ....... :i|i!I ...... Ii!"!1   H,  i i" ............ ,  'it 'It ,,;',« I1" "!' I MI!
Using this methodology, the EPA estimated benefits of the Phase II rule to be $1 .63 billion per
year. This estimate does not include potential benefits of post-construction- controls.  A summary
of the local and nonlocal benefits are presented hi Exhibit 6—7.
              ;!'ij"|"' iil-ii. I	 ,:. ,;	'" "! ..iaii , .alillt
                                                                                                     , '!'.	;,	;,f,,;	IT	iillfr' ,-!( V;	'  I
                                                          Final Report
                                                           '  I:  1
                       f ."ii.-f ...... iiiitsi '  :- , ":",  • ,,, .i 'I;:,
                       ii':; ..... .i ......... i ..... < i ........ a.,, ...... iKiuj :! !;i;:<;ni[j] ........... ;jN;>
                                                                                  ;	 II' ]• '•	it,',;.
                                                                 , ......... tixiiiu     • , -..I'm iiiiit i 1 •»!: ii ..... :.4 •• • ..... "'- • ~ -' •• •
                                                                                  October 1999
                                                                                  .• r-  'ti:-;*"11!	:	i >*/:.
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                           6.0 Quantitative Assessment of Benefits
      Exhibit 6-7. Local and Nonlocal Benefits of Phase II Controls Estimated Using the NWPCAM1
, 1 ' , *" > b t.
- "/ *"* s*\.,<- I '
*.*">? ~" ^T 'I »- „! ^ ^T^ ~
Use Support
Swimming, Fishing, and Boating
Fishing and Boating
Boating
Total
,- H
Local Benefits
(SmOtion/yr)" " f
306.2
395.1
700.1
1,401.4
X*NpnlocaI Benefits2 * *",
" .,: '' (SmilUon/yr) ' *
60.6
51.9
114.6
227.1
Total Benefits
(Smillion/yr)
366.8
447.0
814.7
1,628.5
 1 Does not include potential benefits of post-construction controls.
 2 To estimate nonlocal WTP per household, the 33% of willingness is multiplied by the fraction of previously
 impaired national waters (in each use category) that attain the beneficial use as a result of the Phase II rule. To
 estimate the aggregate nonlocal benefits, nonlocal WTP is multiplied with the total number of households in the
 United States.

 While the numbers of miles that the model estimates will change their use support seem small,
 the benefits estimates are quite significant. This is because urban runoff and, to a large extent,
 construction activity occurs where people actually reside and, consequently, the water quality
 changes mostly occur close to those population centers. NWPCAM indicates that the changes in
 pollution loads have the most effect immediately downstream of the pollution changes.  This is
 because rivers "treat" the wastes (using similar processes that occur in a wastewater treatment
 plant) as they move downstream. As a result, the aggregate benefit is large because there are
 large numbers of households in these population centers that benefit from improved water
 quality. If water quality improves in reaches that are away from the population centers, their
 economic value is comparatively less. The model captures this economic phenomenon.
 Moreover, the model fully incorporates the construction, starts modeling (including the "small
 streams") and an improved population database for the estimation of benefits.

 6.2.3  NWPCAM Sensitivity Analysis

 EPA investigated the impact of alternative assumptions for the NWPCAM approach.
 Specifically, EPA investigated the impact of different levels of control,  such as 60% or 80%
 pollutant removals from municipal sources.  EPA estimates that controls hi the 60% to 80%
 range will increase economic benefits by $200 million to $300 million per year, respectively,
 compared to the original $1.63 billion estimate.

 As another sensitivity analysis, EPA assumed that the construction  starts sediment loadings were
 25% higher or lower than originally assumed. The resulting local economic benefits estimates
 show a change of only plus or minus 5%.

 6.3    National Water Quality Assessment Approach

EPA also estimated benefits using national water quality impairment data in the 305(b) report
(US EPA, 1998a). EPA used the Carson and Mitchell WTP estimates discussed hi Section 6.2 to
October 1999
Final Report
                                                                                     6-13
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                          6.0  Quantitative Assessment of Benefits
value the removal of designated use impairment in streams, rivers, and lakes attributed to the
Phase EL urban sources, which was discussed in Chapter 3. For estimating benefits of the
sedimentation and erosion control (SEC) requirements of the rule, EPA used estimates of the
value of the SEC program in North Carolina. The derivation of benefits is discussed in the
following subsections.

6.3.1  Potential Benefits of Municipal Measures

As described in previous chapters, Phase II municipalities contribute loadings of nutrients,
metals, oil and grease, and litter that result hi impairment of the nation's rivers and streams,
lakes, reservoirs, Great Lakes, estuaries, and oceans. The benefits of implementation of the
Phase n municipal minimum measures to remove impairment depend on a number of factors,
including the number, intensity, and duration of wet weather events; the success of the municipal
programs; the site-specific water quality and physical conditions; the current and potential uses
of fgg ^^^ waters; and me existence of nearby "substitute" sites of unimpaired waters.
Because all these factors will vary substantially from municipality to municipality, data and
information are not available with which to develop estimates of benefits measure by measure
and water body by water body.

Previously, EPA developed a method for estimating the potential benefits of the storm water
program using national-level data that can be adapted to shed light on the benefits of the Phase II
rule. As part of an effort to quantify the value of United States' waters impaired by storm water
discharges, EPA applied Carson and Mitchell's (1993) estimates of the WTP for incremental
water quality improvements to estimates of waters impaired by storm water discharges as
reported by states hi their  305(b) reports.
i<"' IPrhi/LHi^  II	:•¥•' "' '»' "'l|"l|lfl I'i» I,!1'1 '!!!!S|   ''                                                                  I
¥0 Sevelpp estimates of the potential value of waters impaired by Phase II municipal sources,
EPA useS thej proportion of impairment estimated for just these communities as developed in
Chapter 3. That is, the potential Phase II benefits are assumed to equal the WTP for the different
water quality levels multiplied by the water quality impairment associated with Phase II
municipalities (see Exhibit 3-9, Urban Runoff/Storm Sewers column) and multiplied by the
relevant nuln^er of households (WTP x % unpaired x # households).  Although households in
Phase n communities will most directly benefit from improved local water quality, the WTP
values from Carson and Mitchell (1993) are applied to all households in the United States
because these WTP values represent the benefits—including nonuse benefits—that will accrue to
all households as a result of the water quality improvements of the Phase II rule. The 1998
population (270 million) was divided by the number of persons per household in 1997 (2.62) to
arrive at an estimate of 103 million households.

To apply the WTP values, EPA assumed that aquatic life support and fish consumption
categories hi the 305(b) data are similar to the fishable level that respondents were asked to value
in Carson and Mitchell's study. Likewise, EPA assumed that primary contact (swimming) is
similar to the swimmable  level and that secondary contact (boating) is similar to the beatable
level. However, these matches are not exact, as measurement and reporting standards for 305(b)
reports differ from state to state.
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Final Report
October 1999
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                          6.0  Quantitative Assessment of Benefits
Using the equation described above, the WTP to bring water quality in lakes to the swimmable
level is: ($177 adjusted WTP) x (0.56% impairment) x (103 million households) = $102.2
million.6 The Carson and Mitchell estimates apply to all fresh water lakes and rivers. As shown
in Exhibit 3-8, lakes are the most impaired by urban runoff/storm sewers, followed closely by
Great Lakes, and then rivers. It is not clear, however, how the Carson and Mitchell values would
be apportioned among rivers, lakes, and Great Lakes because the physical units reported in the
305(b) (river miles, lake acres, and Great Lakes shoreline miles) cannot be aggregated. In light
of this problem, EPA developed a benefits range by applying the WTP values to the categories
separately and assuming that the higher resulting value for lakes represents the high end of the
range (i.e., assuming that lake impairment is more indicative of national fresh water impairment)
and that the lower resulting value for impaired rivers represents the low end of a value range for
all fresh waters (i.e., assuming that river impairment is more indicative of national fresh water
impairment).

The designated uses given hi the 305(b) data list two categories that can be interpreted as
"fishable water quality:" aquatic life support and fish consumption.  Calculating the WTP for
each category and aggregating every category is likely to lead to double counting. Therefore,
EPA used the sum across every category to determine an upper bound on both the low and high
WTP estimates.  To determine a lower bound on the low and high WTP estimates, EPA included
only the aquatic life support category, the larger impairment impact, eliminating the fish
consumption category.  The resulting benefit estimates are presented in Exhibit 6-8.  These
results differ from the NWPCAM results, hi part, because  they exclude the soil erosion control
impacts, which are valued separately.  Furthermore, the changes in impairment levels based on
the 305(b) data are substantially lower than the baseline impairment levels simulated using the
NWPCAM.  As noted earlier, the 305(b) data only identify impairments to designated uses,
whereas the NWPCAM classifies as impaired any river reach that does not meet swimmable
standards.
             Exhibit 6-8. Potential Annual WTP Estimates for Fresh Water Impaired by
                           Phase n Municipal Sources (1998 dollars)
i * _B * i"
^ £ 1 •**.-."
' Designated Use
Adjusted!
:• Household
WTP
Impairment from
Urban Runoff/
Storm Sewers
- /,'•"« '^'4'*
Aggregate WTP1^
(millions)
Low Estimate
(Based on Impairment Data for Rivers)
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating, etc.
Subtotal (upper bound)2
Subtotal (lower bound)3
$158
$158
$177
$210


0.36%
0.19%
0.24%
0.22%


$58.7
$31.2
$42.7
$48.7
$181.5
$150.3
'Equation result is not exact due to rounding of factors.
October 1999
Final Report
6-15
   • ' •?
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 .11 I'll 'H'TIIPIP'ili, Illf
                                                6.0 Quantitative Assessment of Benefits
        <	mi.   i :i
                                  Exhibit 6-8. Potential Annual WTP Estimates for Fresh Water Impaired by
                                                 Phase II Municipal Sources (1998 dollars)
I; fit 1	Ill	i:|	 !"'
                 i;:"!"11!'
I
II ill"1: ' :"jii'i!::l< I* H, i
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              oil
  ?» '"f"'!p . Si-i"	'"i
  fif i!*; I,,'"'";
                 l ..... i
Designated Use
Adjusted
Household "
WTP
Impairment from
Urban Hunoff/
Storm Sewers
Aggregate WTP*
(millions)
High Estimate
(Based on Impairment Data for Lakes)
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating, etc.
Subtotal (upper bound)2
Subtotal (lower bound)3
$158
$158
$177
$210


0.70%
0.79%
0.56%
0.56%


$113.7
$128.3
$102.2
$121.8
$466.0
$337.6
                    Source: US EPA, 1998a.
                    "Based on 103 million households (US Bureau of the Census, 1998a). Results subject to rounding.
                    'Totals may not add due to rounding. Includes all designated uses.
                    3Totals may not add due to rounding. Excludes fish consumption values.

                   Although the results provided hi Exhibit 6-8 indicate the potential value of impaired waters, the
                   extent to which impairment will be eliminated by the municipal minimum measures is not clear.
                   The estimates are presented in Exhibit 6-9 for a range of potential effectiveness of municipal
                   programs excluding post-construction control measures.
                        Exhibit 6-9. Potential Annual Benefits of Improving Fresh Water Impaired by Phase II Municipal
                                  	Sources to Support Their Designated	Uses (Minions'of"l998' dollars)	
 11 11    i
; ' " Municipal Program Effectiveness1 ''_""'
60%
80%2
100%
Low Estimate (based on impairment data for rivers)3
$90J2-$108.9
$120.2-$145i "
$150.3-$181.5
High Estimate (based on impairment data for lakes)3
$202.6-$279.6 '
$270.1-$372.8 T
$337.6-$466.0
 111''""'''1	:i.	i	Ml
 ii! .! I'1' I11'"" "Ii Ml'
                    1 Figures subject to rounding.
                    2 EPA expects that municipal programs will strive to achieye at least an 80% effectiveness.
                    3 Adjusted for program effectiveness (e.g., for rivers: $150.3 x 80% = $120.2;  $181.5 x 80% = $145.2).

                  63.2   Potential Benefits of Avoided Water Quality Impairments
                                       '•"!: .].'," MNi,"11'! ...... TIH, .!,'
                                                                    i,,!1! ......... B'n lill-fj'1 ...... 'K I1;1}" ..... ...... 1,'^ j'l.'Wlo ..... 'i'
                   The fresh water benefit analysis in Section 6.3.1 does not include prospective benefits that are
               ::.-.. -;.L§xpected to accrue from municipal measures to address post-construction runoff control.  This is
                   because the benefit analysis is based on current water quality impairment levels in the 305(b)
                   report. Post-construction runoff control measures will mitigate future impairment to water
       'ill	 .••	' •!	-I
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                   6-26
                                                             Final Report
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-------
                           6.0  Quantitative Assessment of Benefits
 bodies by controlling contaminated storm water runoff from sites that are developed or
 redeveloped in the future. Without this provision, national water quality impairment would
 increase relative to the impairment levels currently reported in the 305(b). This section describes
 the approach developed by EPA to estimate potential benefits of avoiding future water quality
 impairment.

 New development and redevelopment activities can increase the types and amounts of pollutants
 that enter waterways in storm water runoff by increasing the amount of impervious surface and
 the presence of contaminants. Storm water quality sampling results from EPA's Nationwide
 Urban Runoff Program show that development activities increase contaminant concentrations in
 runoff. Exhibit 6-10 compares mean concentrations of pollutants in runoff from residential and
 commercial areas with runoff from nonurbanized areas.  Runoff concentrations of a wide variety
 of contaminants from land converted to residential and commercial use are fairly comparable, but
 both are substantially greater than runoff concentrations from nonurbanized land. Subsequent
 studies have shown that annual pollutant loadings from residential, commercial, and industrial
 areas can be one to three orders of magnitude greater than loadings from areas with low levels of
 impervious surface such as parks, and the concentrations of some pollutants in urban runoff are
 comparable to untreated domestic wastewater (US EPA, 1998a).

            Exhibit 6-10. Mean Contaminant Concentrations in Storm Water Runoff from
                              Developed and Nonurbanized Areas
, -> J-j Pollutant (units)
BOD (mg/1)
COD (mg/1)
TSS (mg/1)
Total lead (ug/1)
Total Copper (ug/1)
Total Zinc (ug/1)
Total Kjeldahl Nitrogen (ug/1)
Nitrate + Nitrite (ug/1)
Total Phosphorus (ug/1)
Soluble Phosphorus (ug/1)
- Residential Use, '^
10
73
101
144
33
135
1900
736
383
143
,„ Commercial Use ^ ~
9.3
57
69
104
29
226
1179
572
201
80
Nonurban Use f
—
40
70.
30
—
195
965
543
121
26
 Source: US EPA (1983) as cited in US EPA (1998a).


Under the post-construction runoff control provision, developments in the urbanized areas of
Phase II communities that disturb between one and ten acres may implement structural and
nonstructural BMPs to minimize the impact of development on storm water runoff. These BMPs
are designed to remove pollutants from storm water through settling or filtration. Studies of the
types of BMPs included in the cost analysis in Chapter 4 demonstrate their effectiveness in
reducing the pollutant loadings in runoff. Exhibit 6-11 summarizes some of the potential
loadings reductions.
October 1999
                                       Final Report
6-17
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                                           6.0 Quantitative Assessment of Benefits
             (Mill
                                                                       i\	i Sift;,)': ;:>)«!»•, |ii!«'...f!it.'t>; if ;ii^~'
                        II ill II  I III  I i     i  II   il |H I      i |l 11  II I l 11     I  'V'S	
                      Exhibit 6-11. Effectiveness of BMPs in Removing Contaminants from Storm Water Runoff
,

:, i •: ^
BMP
Detention
Pond
Infiltration
trench/basin
Sand Filter
Swale
Median Removal (Percent of Loading without BMP)


TSS
7

99

87
81


TDS
ND

ND

16
ND
BOD/
COD/
TOC
-1

90

66
67

Total
N.
5

60-70

44
ND

Total
P
10

65-75

44
ND


FC
ND

98

51
-58


Cd „
54

95-99

ND
42

•
Cu
26

95-99

34
51

f
Pb
43

95-99

71
67
,

Zn
26

95-99

80
71
                  Source: USEPA (1998b)
                  Note: ND = insufficient data
                 EPA assumes that future new development and redevelopment activities in urbanized areas of
                 Phase n communities will lead to further impairment of fresh water resources.  To characterize
                 the potential degree of the additional impairment attributed to urban runoff impairment sources
                 that the rule addresses, EPA assumed that baseline impairment would increase at roughly the
                 same,ra|g as,development. EPA calculated area disturbed to approximate the rate of
                 development by dividing the annual development acreage implied in the cost analysis by an
                 estimate of the total urbanized area in Phase II communities. The development acreage was
                 calculateil ^1^ Product of the number of construction starts in each size category by the
                 midpoint acreage of that category. This generated a total disturbed area estimate of roughly
                 40,000 acres for the multi-family residential, commercial, and institutional construction starts.
                 An additional 7,000 acres were added to this total to account for single family residential.
                 construction^starts. These starts are excluded from the cost analysis because EPA determined
                 that the flexibility of the rule would enable developers to satisfy the goals of this provision
                 without incumng significant additional costs. However, due to the use of nonstructural practices
                 such" as imp1 roved site design mat minimize impervious areas, mey are part of the baseline
                 developmentagainst which benefits are estimated.
                                                        ; ::,;::;:;""	,  ;;; i	„:",;:„!; ,;,"•;:	L." ,  '.	."  ,,,",;i;" L:;™
                 Thus, the total disturbed area potentially affected by the rule is 47,000 acres, which accounts for
                 about 0.17% of the 27.3 million acres of urbanized area in Phase II communities. Although a
                 larger percentage of land in Phase II urbanized areas is disturbed on an annual basis, some of the
                 disturbance should not further impair water quality because it falls under an equivalent runoff
                 control program (e.g., industrial developments, developments that disturb more than 10 acres,
                 and development in coastal counties that are covered by an equivalent CZARA program), and
                 some of the disturbance'that may further impair water quality is not affected by the rule (e.g.,
                 construction starts that disturb less than one acre). EPA also assumed that all of the construction
                 starts in the cost analysis would cause future water quality impairments j regardless of whether
                 they are new development or redevelopment starts.
                Assuming that the incremental impairment of new development and redevelopment activities is
                roughly proportional to the amount of land disturbed, EPA multiplied the 0.17% by the urban
                6-18
Final Report
October 1999
llllB      	I
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                           6.0 Quantitative Assessment of Benefits
 runoff/storm sewer impairment attributed to Phase II communities, shown in Exhibit 3-10.
 Exhibit 6-12 summarizes the resulting incremental impairment estimates, which EPA then
 multiplied by the adjusted household WTP values used hi the fresh water analysis in Section
 6.2.1 to obtain benefit estimates. These estimates range from a low of almost $308,000 to a high
 of over $950,000 per year for a single year of construction starts. Because the rule affects new
 construction starts  each year, EPA assumes that it mitigates the potential water quality
 impairments from an additional 47,000 disturbed acres each year.

        Exhibit 6-12. Potential Annual WTP Estimates for Fresh Water Impaired by One Year of
                    New Development and Redevelopment Activities (1998 dollars)
--*£-'> f >-'""'
*• S" -1 ,_ /'- HU
-teL -' ?*""C5t ,-i^
' , t Y" -^ ''.-^s. . " >t
-' v- _ ^Si' Ot:>' v! , < '>•
'i fa. ~-i.-\i'_- * „" * *
!-• , ; 11 ( -"•-j-'.ft
- , Designated "Use ~
"" *~ t, **
Adjusted
Household ,
WTP
V !>. *•*•* 1- "*
^, I
~~y
Impairment from
Urban Runoff/ "_
— A ~
Storm Sewers
Incremental T
i _ i-r '*
Impairment from
New Development
and Redevelopment
,'f Activities ,""'"""
^ ^
^j
Aggregate
- WTPJ"
( >f s i
(millions)
*--~\Y:~\^ >ff~t V "'- Low Estimate " f -"* - ;> , J ^ fj "*' *? *V^
"-4 :V/C""1 -^- (Based on Impairment Data for Rivers) . -" ^^-^^-T ^«'r^, .'
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating, etc.
Subtotal (upper bound)2
Capitalized stream4
Subtotal (lower bound)3
Capitalized stream4
$158
$158
$177
$210


0.36%
0.19%
0.24%
0.22%


0.0007%
0.0004%
0.0005%
0.0005%


$0.12
$0.06
$0.09
$0.10
$0.37
$2.62
$0.31
$2.17
-, -- -r - High Estimate " " *" ' -\ "j, J-E'^'-f -^ "j*^,{
^ J '"^r- t_ - 	 ^ •* ^ ~ j ~ ~ "°- f ** *? ^ 4* p T BS>~ ^ ""
5 - (Based on Impairment Data for Lakes) 1-"] t"t /*
Aquatic Life Support
Fish Consumption
Primary Contact — Swimming
Secondary Contact — Boating, etc.
Subtotal (upper bound)2
Capitalized stream4
Subtotal (lower bound)3
Capitalized stream4
$158
$158
$177
$210


0.70%
0.79%
0.56%
0.56%


0.0014%
0.0016%
0.0012%
0.0012%


$0.23
$0.26
$0.21
$0.25
$0.96
$6.74
$0.69
$4.88
 1 Based on 103 million households (US Bureau of the Census, 1998a). Results subject to rounding.
 2 Totals may not add due to rounding. Includes all designated uses.
 3 Totals may not add due to rounding. Excludes fish consumption values.
 4 Annual benefits were capitalized over a 10-year period assuming a 7% discount rate.
October 1999
Final Report
                                                                                       6-19
-------
                                                                             If:I1*,'I ' IllfJ1",!,']": 'I,:1,	,ii
                                                                                                      i|,,;,,, 1 WHIP, 1 ,,,liir:» !:„
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                                          6.0  Quantitative Assessment of Benefits
                     ill '	m
                                     ,	:."j,	i"1;
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                                                                '•' * '.:)'
  !:,	liilli'li!!:1

  , i n; jiiiiidii1'
 Because these are annual WTP estimates to avoid incremental impairments to water quality, they
 accirue each subsequent year that O&M expenditures; are incurred to maintain the effectiveness of
'"I,,1,'!1";! Jii'i1' i "S 'lUlilll'WIIIlllllliill1 '  illililill!! ! iJlttlt!	r  Wr	T"	,	 	,	 ,„„	 • li	 •,!*	ii - , • r	 < i<»,<:r:i	,.	«, :c»nstruction runoff control provision. Assuming municipal
                program effectiveness ranges from 60% to 100%, Exhibit 6-13 summarizes the range of annual
                future benefits.
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                                                                                  ,"»;	it! »'.i!!,
             :"::::' 6—20
                                        Final Report
                                                                                    October 1999
-------
                           6.0 Quantitative Assessment of Benefits
        Exhibit 6-13. Potential Annual Benefits of Avoiding Future Fresh Water Impairments from
              New Development and Redevelopment Activities in Phase II Urbanized Areas
                                   (Millions of 1998 dollars)
- K - & l - * t Municipi


jl Program Effectiveness * ., „„. „
" - _ •- ft* s t- j j- if. a,
"X ;v:80%2" I »T,:£L
100%
Low Estimate (based on impairment data for rivers)3
$1.3-$1.6
"•, s.v:$i.Jmi> :*.".*„ ^
$2.2-$2.6
High Estimate (based on impairment data for lakes)3
$2.9-$4.0
:^:^^9^j4^l^
$4.9-$6.7
  1 Figures subject to rounding.
  2 EPA expects that municipal programs will strive to achieve at least an 80% effectiveness.
  3 Adjusted for program effectiveness (e.g., for rivers: $2.2 * 80% = $1.7; $2.6 x 80% = $2.1).

 6.3.3   Potential Value of Improved Marine Waters

 The Phase II rule will affect marine waters as well as fresh waters. Consequently, EPA
 anticipates additional benefits as a result of improvements to marine waters.  These benefits are
 not reflected in the analyses above because the WTP estimates from the Carson and Mitchell
 study only capture fresh water benefits.

 Benefits to Commercial Fisheries

 Commercial marine fisheries are a significant part of the nation's economy. In 1997, the value of
 the commercial finfish catch was $581 million and the value of the commercial shellfish catch
 was $1.04 billion (National Marine Fisheries Service,  1997). However, as noted in Chapter 2,
 the pollutants found in storm water such as pathogens and silt can adversely affect the
 productivity and viability of fisheries populations. Although several studies document the
.adverse effects of pollution on fish and shellfish, there are limitations to estimating marine
 commercial fishing benefits. To develop a defensible, "bottom-up" economic valuation
 approach EPA would need to quantify three links: how changes in urban runoff affect marine
 water quality, how changes in marine water quality affect fishery productivity, and how changes
 in fishery productivity affect the commercial catch and resulting producer and consumer surplus
 measures. Although there is limited information for the  first and third links (e.g., the 305(b)
 water quality impairment data and total commercial catch values and estimates of surplus
 measures), there is little quantitative information regarding the second link. EPA is aware of
 proposed research efforts to develop such links between  water quality variables and fishery
 characteristics, but research hi not complete at this tune.  Thus, national level estimates are not
 feasible.

 Despite these noted difficulties and the lack of national level data, EPA did attempt to
 characterize the impacts of storm water runoff on commercial fisheries for areas of the country
 where fisheries are a significant part of the economy: Puget Sound, Gavelston Bay, and the Gulf
 of Mexico. While fisheries experts and state officials were able to confirm-that pathogens have
 indeed adversely affected or caused the closing of various fisheries, they were unable to identify
October 1999
                                       Final Report
6-21
-------

	 II 	

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                                         6.0 Quantitative Assessment of Benefits
                                                                                                 ' >ii	I'M! '"ill Kil. i:,
                the source of contamination.  Furthermore, those contacted were unaware of any completed
                comprehensive studies on the economic impacts of pollution on commercial fishing, including
                pollution associated with storm water runoff.

                The baseline value of commercial fishing can be characterized using the available national level
               /catch' datatescribjd^above.	Because, tire fnational value of finfish and shellfish catches are,high",	
                even a small contribution to enhancing these values (e.g., through the reopening of shellfish
                beds) is potentially large.  For instance, if controlling runoff from Phase II communities led to a
                relatively small 1% increase in the value of the shellfish catch, the corresponding market value
                                      ion.
                Benefitsfrom Enhanced Marine Recreational Fishing

                The 1996 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation reveals that
                9.4 million anglers participated in saltwater fishing in 1996 (US Department of the Interior,
                199JT). In addition, a review of the literature by Freeman (1993) suggests that one year's access
               ''W                                    be aVhigE	as	$120	to"$r,206" (1998 dollars).	If '9.4	
                ijj^jjQjj-^gj^-pj^j^pgjg in saltwater fishing, the potential value of marine recreational fishing
                is $ 1.1 billion to $ 11.3 billion per year. However, poor water quality may affect fishery
                populations and may negatively affect participation and the enjoyment associated with fishing
               ""tripsiTlSjI^lemeritation of the Phase II rule may increase the value of fishing experiences
                and lead to increased participation.
HRI! '' ' "III!1!',
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   ,,;There are, however, limitations associated with estimating the; benefits to marine recreational
    fishing that are similar to those associated with commercial marine fishing. For instance,
    although travel cost models may provide information about how changes in catch rate affect
    fecfeltional angling values, EPA lacks quantitative data regarding how loadings reductions are
    likely to affect fish populations and catch rates. In addition, as noted by Freeman (1993), benefit
    estimatesaregigg^^ to transfer becauseestimates vary ^^giy^^^ mg cna^acteristics of
    individuals, species offish studied, number of species included in the study, andEstimation
    techniciues. For these reasons, EPA did not estimate national benefits of recreational fishery
7=:' ".^pro'Venlente"	Because marine 'recreafionaT fishing is a gjgjify valued activity, even a slight
    improvement could yield large benefits. For example, if controlling runoff from Phase II
    communities led to a relatively small 1% increase hi recreational fishing, the corresponding
    potential value would be between $11 million to $113 million per year.

    Benefits from Enhanced Marine Recreational Swimming
	                    , ni,    	   	,    ,    ,                     j      	    ,,  	
    There is little question that marine recreational swimming is an activity enjoyed by many people.
liiiii i ^ EP'A estimates that A^enclns participated in approximately 1.3 billion nonppol swimming days
'T	;in"l§3fj	^^cw^^oynSa^c^S^^^^'^^^.	='""	L	'"oati	'	^""^	'	'	
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           i995c) estimates "mat approximately ?4.6% of swimming trips were to the ocean. Multiplying
          -theje,figures yields almost 580 million swimming trips to oceans per year. To approximate the
       iiis^^numtrer^f people swimming at ocean beaches potentially impacted by the Phase II rule, gp^
       jsswggg^^di that the total number of swimming trips is ^^1,^2 among Phase I and Phase II
           beaches in the same way that the coastal population is ^[ggg^eg between phase I and Phase II
           communities. Approximately 32.0 million people reside in Phase II communities that are located
                6-22
                                                 Final Report
                                                                                October 1999
                                                            	I	
-------
                           6.0 Quantitative Assessment of Benefits
  in coastal counties and approximately 111.7 million US residents live in coastal counties. Thus,
  about 28.7% of the coastal population lives in Phase II communities, and the number of
  swimming trips allocated to Phase II communities is about 166 million trips, which is equivalent
  to approximately five trips per person per year for the coastal residents.

  This approach may tend to overestimate the number of swimming trips to beaches in Phase II
  communities because it does not allocate trips to beaches that are located outside Phase I and
  Phase II communities, e.g., at national parks. On the other hand, however, this approach may
  tend to underestimate the number of swimming trips to beaches in Phase II communities because
  it assumes that a large share of trips  occur in Phase I coastal communities (e.g., Baltimore and
  the Bronx) although many people hi those communities may travel to beaches in smaller coastal
  communities to swim. In the absence of better national visitation data for Phase II beaches, EPA
  assumes that these potential sources  of bias offset one another.

 Unfortunately, fecal colifonn concentration and other pollutants such as oil, grease, and litter,
 may degrade beach quality and thus inhibit people's enjoyment and participation in outdoor
 swimming. Degradation of beach waters can also result in beach closures that prohibit
 swimming, resulting in welfare losses. EPA anticipates that the Phase II rule will reduce these
 losses.              -

 To evaluate the potential benefits of reducing beach closures hi Phase II communities, EPA used
 information on beach use and closures from beaches in 159 Phase II communities hi the EPA
 Beach Watch program.  This program only includes data for beaches that monitor and report
 water  quality and beach closures. There are 428 beaches in the dataset that are in Phase II
 communities; the number of beaches hi Phase II communities that do not monitor or report is
 unknown.  The data include daily visitation estimates and the reported number of closings for
 each beach in 1997, both categorized by weekday, weekend, holiday, peak and nonpeak season.
 EPA multiplied these visitation rates by the number of daily beach closings per beach and then
 summed over all the Phase  II beaches hi the dataset to produce a total of 86,100 lost beach days
 caused by beach closures. This estimate is subject to some limitations. It is important to note
 that several beaches hi the dataset did not report visitation statistics and EPA estimated that zero
 visits were lost at these beaches, thereby understating lost beach days. Another limitation is that
 these beaches reported storm water as a significant source of pollution, but elevated bacteria
 levels  were ultimately the reason for the closures.  Some of the elevated bacteria levels may have
 sources other than storm water, so the estimate may overstate lost beach days.

 To value these lost beach days, EPA reviewed two meta-analyses, Walsh et al. (1-990) and
 Freeman (1993) to obtain a mean benefit measure of $30.00 per person per visit for a beach day.7
 The literature included in the meta-analyses mostly used the travel cost method to estimate the
 consumer surplus per person per day. The majority of these studies accounted for the effects of
 substitution between different beach sites with the use of dummy variables. However, some of
 the work included hi the Walsh et al.(1990) meta-analysis that used the contingent valuation
7 EPA used the mean of the aggregate value for swimming from the Walsh et al. (1990) and the value from the Leeworthy and
Wiley (1991) study included in the Freeman (1993) analysis.The Leeworthy and Wiley estimates of $19.41 are in 1988 dollars
and the Walsh et al. estimates of $22.97 are in 1987 dollars. To derive a mean benefit measure, bom estimates were adjusted to
1998 dollars using the CPI.
October 1999
                                       Final Report
6-23
-------
                'It	II'" Ml.',"' '	fill!""
(ill	ii it i
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                                          6.0 Quantitative Assessment of Benefits
                method did not explicitly account for substitute sites, thus potentially biasing the estimate
                upward.

                Using the $30.00 per person per day estimate of consumer surplus for a beach visit and the
                86,100  lost beach days yields approximately $2.6 million in lost swimming benefits. This
                estimate is expected to be a subset of marine recreational swimming benefits because it does not
                account for the increased participation of those who are not currently swimming, but would do so
                after an improvement in water quality. That is, this value only represents the benefits existing
                users have at current water quality levels and does not account for the increased potential
                ^enjoyment of new and existing swimmers for a water quality improvement. Thus $2.6 million
                can be taken as a lower bound to lost marine swimming benefits.

                The extent to which the Phase II rule will reduce the: incidence of beach closures is uncertain.
                Exhibit 6-14 reports an effectiveness range for municipal programs that is  similar to ranges
                reported earlier.

                                Exhibit 6-14. Potential Annual Benefits of Reducing the Number of
                                 11                                           i                     ii
                                 Beach Closures in Phase n Communities (Millions of 1998 dollars)
              •n HI i in i in   n in ii iiii n mil  n n n i in n  in  iiiii  i ii   i    n    n n      i   ii in  v                   '
. „- ,^
Municipal Program Effectiveness ,-••,,, =. 3 , IS:.,K
60%
$1.6
80%2
$2.1
, «»% V. ^
$2.6
                 1 Adjusted for program effectiveness (e.g., $2.6* 80% = $2.1). Figures subject to rounding.
                 2 EPA expects that municipal programs will strive to achieve at least an 80% effectiveness.
                                          in i i
                Benefits of Reduced Health Risks from Swimming

                One of the anticipated benefits of the Phase II rule is a reduction hi human health risks caused by
               , swimming in contaminated waters.  Although the Carson and Mitchell survey asked respondents
                io state a value for swimmable water quality, EPA does not believe that waters identified as
                swimmable according to federal standards are completely free of potential health risks. Indeed,
                EPA estimated that 19 out of 1,000 persons swimming in ocean and bays just meeting the
                acceptable standard of 35 enterococcus bacteria per 100 milliliter of water will become ill (EPA,
                |9 86J.  In addition, the health risks associated with swimming in contaminated marine waters are
                            '''         because the Carson and Mitchell study includes only fresh waters.
ili'lllilB,! ' l,!:>	•11' ji
SiHV]:"
             ;| ;Toirestoate.^ benefits of reduced health risks associated with swimming in marine waters,
ill,,,! j;;fjl;i l!"iii:J'l|'l:,j;l| ^^'e»^pblate'd"£ealt;h'impacts from an epidemiological study of swimmers at Santa Monica
            ^i'Say, gQjjg^^g ^y jiajig et ^j (19"$^ fo a national level.  This section briefly summarizes the
                benefit analysis, which is discussed in further detail in Appendix C.
             ""  '' '   	 '"'	''' "	'"''If	'	""	
                                                                             .',!,,,
                The Santa Monica Bay study of 13,278 swimmers found swimmers within 100 yards of storm
                disins, experienced increased incidences of gastrointestinal and respiratory diseases, and that
      	~ (	illness rates .wereoftenMgjiest among Apse who swam in the immediate vicinity of the storm
W1]'1^— I:--  :.4'"~;' drain' (Haite et'al., 1996)1 The increased incidence of illness was associated with swirnming in
	 , , ,
,1	III!	 111!1!	iiiii .{.!?$:'i'1
                6-24
        	"W
 Final Report
	"::';" •;  ." ":"•'•"-• "'•'••"I'1	;
ki.'Msi	tSJ;	ii1	Nyir:,;;	i	i	&&«?,	•	fc:;^iiwi
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                          6.0 Quantitative Assessment of Benefits
 areas where monitoring results showed high densities of bacterial indicators. The study
 identified illicit connections to storm sewer drains as possible sources of contamination.

 EPA developed a method for extrapolating the results of the Santa Monica Bay study that did not
 require water quality monitoring data, which is often not available for beaches in Phase II
 communities. The Santa Monica Bay study reported "attributable numbers," which characterized
 the additional number of illnesses occurring among the people who swam near the storm sewer
 drains compared to baseline illness incidences among swimmers who were more than 400 feet
 away from a storm drain. These attributable numbers provide a means for estimating the number
 of incremental illnesses at total coliform (TC) concentrations above or below a 1000 cfu/100 ml
 cutpoint EPA verified that concentrations above and below the cutpoint were possible at storm
 sewer drains (see Appendix C). Then, using exposure information from the Santa Monica Bay
 study, EPA estimated that of the 166 million swimming trips to beaches in Phase II communities,
 11.6 million trips may bring swimmers within the vicinity of a storm sewer outfall (see Appendix
 C).

 EPA multiplied the attributable numbers by the exposure range to obtain estimated incremental
 illnesses. For highly credible gastroenteritis two (HCGI2), defined as a person having vomiting
 and fever, the additional cases range from 35,795 for low contamination to 118,501 for high
 contamination.  For significant respiratory disease (SRD), defined as a person having fever and
 nasal congestion or fever, sore throat and cough with sputum, the increased cases range from 0
 for low contamination to 119,199 for high contamination. Other health effects included fever,
 chills, nasuea, vomitting, diarrhea, cough, cough with phlem, runny nose, sore throat, and highly
 credible gastroenteritis one (HCGI1),  defined as a person having vomiting, diarrhea and fever or
 stomach pain and fever. These various conditions are expected to increase by 249,340 cases, for
 high contamination exposures.  However, EPA only applied economic values to two of the health
 effects, significant respiratory disease (SRD) and highly credible gastroenteritis 2 (HCGI 2),
 because of the unknown overlap between other health effect categories and a lack of valuation
 information for many of the health effects.

 If the Santa Monica Bay study results are indicative of national swimming activity, avoided
 health impacts among children may make up a disproportionate share of the potential health
 benefits. Among the study sample, children appeared more likely than adults to swim near storm
 sewer drains in the study; children made up 48% of the study sample, but they accounted for
 62% of the subsample that swam within one yard of a drain.

 Since SRD and HCGI 2 are the only health effects accounted for, the consquent health benefits
 are underestimated. For the SRD cases, EPA used WTP values reported in EPA (1997d) to avoid
 upper respiratory symptoms, which was $19 per case in 1990 dollars. The symptoms associated
 with this illness are head/sinus congestion, cough, and eye irritation (US EPA, 1997d), which are
 similar to the symptoms for the SRD category. This value potentially underestimates losses
 associated with SRD cases because it does not include the value of any foregone work or leisure
 activities. The Santa Monica Bay study did not collect such information. EPA assumed that the
 combination of symptoms was severe enough to constitute one mild restricted activity day per
 case, which is valued at $38 per day (US EPA, 1997d). EPA escalated both of these values to
 1998 dollars using the CPI. The adjustment factor is 1.24, which equals 163.0 (annual average
October 1999
Final Report
                                                                                  6-25
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                                           6.0  Quantitative Assessment of Benefits
                 CPI for 1998) divided by130.7 (annual average; CPI for 1990).  The resulting values are $24 per
                 case for upper respiratory symptoms and $47 per day for a mild restricted activity day.
                          niiiiiiiiii  i in i in i    inn i   Jim, *                                        i ii'niiii '•• ' i         ii    n n n
                           	;	            	                                       	                n
                 For the HCGI 2 cases, EPA used cost of illness (COI) values estimated by Mauskopf and French
                 (1991) for related gastrointestinal illnesses, g^hibh 5115 summarizes the illnesses and
                 symptoms valued by Mauskopf and French, average illness durations, and COI estimates based
             	on medical	aji^orkloss estimates.,. EPA	did not atlgmpt to adjust the COI values to WTP
                 Values, which are generally higher because they account for nonpecuniary costs such as pain and
                 suffering. The COI in Mauskopf and French were estimated on a per case basis.  The symptoms
                 for moderate salmonellosis better match the HCGI2 symptoms (vomiting and fever). The
                 potential duration for HCGI 2 cases, however, is more comparable to the three-day duration of
                 mild salmonellosis: one to 10 days for viral infections and four to six days for e. coli infections
                 (CeateTfor•g-s^^''^on^0|^n^hpre^gn^^	f(J9S ^d 1994)!	Consequenlly,1 EPA used 1he"$l97
                 per-case cost ($1990) for a mild case of salmonellosis to value the benefits of avoided HCGI two
                 cases; escalated for inflation, the COI value per case is $244 ($1998).
                                 Exhibit 6-15. Cost of Illness Estimates for Gastrointestinal Illnesses
	III"!!'!	l"i'  i'iiili  I	
1 "' " "illness
Symptoms
* !
Length
f ". f, , * f ,
Treatment
"; Total COI1. ,
($1990)
($1998)
Mauskopf and French (1991)
Botulism-mild
Salmonellosis-
mild
Salmonellosis-
moderate
malaise, weakness, fatigue
nausea/vomiting, diarrhea,
abdominal pain, anorexia,
weakness
same as mild plus fever,
headache, dehydration/
prostration
5 days
3 days
7 days
antitoxin
oral fluids,
antispasmodics
oral fluids,
antispasmodics
$470
$197
$622
$583
$244
$771
till"!1
III
    Source: Mauskopf and French (1991).
    'Original 1990 values escalated to 1998 values using the CPI for all items. The adjustment factor of 1.24 equals
    163.0 (annual average CPI for 1998) divided by 130.7 (annual average CPI for 1990).

   Exhibit 6-16 summarizes estimated health benefits associated with the Phase II rule. For each
   symptom category, EPA multiplied the number of cases estimated for the two exposure
   assumptions and the two TC concentration.levels by the appropriate per case value. The annual
   benefit estimate for the low contamination assumption is $8.7 million. EPA believes this
   underestimates the potential low range of health benefits because the attributable number for
   SRD below the 1000 cfu/100 ml cutpoint is zero.  A method based on a dose-response function
   would most likely generate a positive value for the low range of SRD  cases.  The benefit estimate
   for the high contamination assumption is over $37 million per year. This estimate most likely
   overstates annual j^gg^ £-or these particular health effects because it assumes that
   concentrations at all storm sewer drains exceeds 1000 cfu/100 ml at all limes swimmers are
,   nearby, which is not likely. Exhibit 6-^17 summarizes benefits after adjusting these values for the
   range of municipal program effectiveness assumptions.

' iiiiriiH's1' iii ,'iiirii,: , in i i1 '
HI! :!!!B;;!iii!::"|y|ir ;["fl 	 i/i
	 llii',,11
6-26
m\n 	 ii1 	 i 	 j 	 in 	 i 	 iiii 	 i 	 iiiii 	 hni 	 "i 	 'n< 	

1 .,. S ': :'i,,| "n't ' i '', i 11,111 ' ' ,."!!„, '. 	 PI1- „ !";j||l|iil»ll!, J| JNII''' Inlniii1.1'1,;,1
	 	 1 	 	 	 i 	 mi1 1 ' i^^^^^^ 	 isJK 	 tu, 	 i, 	 IBJIII 	 „,, 	 gam 	 imms^
-------
                             6.0  Quantitative Assessment of Benefits
            Exhibit 6-16. Summary of Potential Marine Health Benefits by Symptom, Exposure
                       Assumption, and Total Coliform Concentration at Outfall
Symptom
HCGI2
SRD
Total
WTPorCOI
Value1 ;;
$244 per case
$24 per case
$47 per day

^ 	 * 5 *
Low Contamination
, (TC<1000cfu/100ml)
$8,733,980
$0
$8,733,980
High Contamination ^ t ~,rj
(TO1000 cfu/lOOmi)' ^ *
$28,914,244
$8,463,129 .
$37,377,373
  1COI value for HCGI is the per day value for a mild case of salmonellosis from Mauskopf and French (1991),
   adjusted from 1990 to 1998 dollars. The WTP value for a case of SRD is the sum of the upper respiratory
   symptom value and the mild restricted activity day value from EPA (1997b), adjusted from 1990-1998
   dollars. In both instances, the adjustment factor is 1.24, which equals 163.0 (annual average CPI for 1998)
   divided by 130.7 (annual average CPI for 1990).
    Exhibit 6-17. Potential Annual Benefits of Avoided Health Impacts from Swimming in Contaminated
                   Marine Waters in Phase II Communities (Millions of 1998 dollars)
v:. , ...*--„ Municipal Program Effectiveness1 ^ - V'Ji-- ill
•" «*.W~r, '.:-
$5.2-$22.4
8Q%2 ?
$7.0-$29.9 " 1 „-.•;,
*. " 100045:^
$8.7-$37.4
  1 Adjusted for program effectiveness (e.g., $8.7 x 80% = $7.0). Figures subject to rounding.
  2 EPA expects that municipal programs will strive to achieve at least an 80% effectiveness.

 6.3.4   Potential Benefits of Construction Site Controls

 The national benefits of construction site storm water runoff controls will also depend on a
 number of factors, including the number, intensity, and duration of wet weather events; the
 effectiveness of the selected construction site BMPs; the site-specific water quality and physical
 conditions of receiving waters; the current and potential uses of receiving waters; and the
 existence of nearby "substitute" sites of unimpaired waters. Again, because these factors will
 vary substantially from site to site, data are not available with which to develop estimates of
 benefits for each site.

Nonetheless, a survey of North Carolina residents (Paterson et al., 1993) indicates that
households are willing to pay for erosion and sediment controls similar to those contained in the
Phase II program. This study provides one way to develop national level benefits estimates of
the rule and, therefore, EPA chose to use benefit transfer methodology to apply the study results.
Paterson et al's. (1993) study is applicable to the construction component of the Phase II rule not
only because North Carolina's program requires similar controls, but also because the median
income of North Carolina residents is just below the median income for the United States. The
similarity of the median incomes indicates that the WTP estimates developed by Paterson et al.
October 1999
                                         Final Report
6-27
-------
                                            6.0 Quantitative Assessment of Benefits
      Ml

             I Ml
                 I   I      I   III          I II   I             "V'>«lj; 1"MT ifflj ''•':*!' 'H'Y.fT1 ..... 5 " Tf ; '. .»*. ''!"' ...... 1 1 '•• ••',. •',. i* .I."' 'flWJW1 '» ::: •*-. " '• ' 't't'! lililljl '.
                  (1993) may reflect the WTP of residents elsewhere in the United States. Furthermore, two other
                  surveys conducted at approximately the same time — one in Maryland and one in
                  Wisconsin — obtained comparable WTP estimates to improve water quality.
Value of North Carolina Storm Water Program
  I ....... I ............ Ill             I          ......... I I I
                                                                                                      ' iSil'llP '

                 In North Carolina, any activity disturbing one or more acres is regulated by an erosion and
                 sediment control program. In 1990, Paterson et al. (1993) conducted a CV survey of North
                 Carolina residents in urban areas to determine their WTP for the program.  For the survey
                 sample, the authors randomly selected urban residents from one of three geographic regions in
                 the state: Asheyille (Mountain region), Durham (Piedmont region), and Wilmington (Coastal
                 Plain region). These regions also represented a range of soil erosion conditions.
  ill      n       in     n   n mi in,'i  "	' " Aiiii:1',,,,!, ,,'''* ,,i,'."iiiiii!i;, "UN1" 'niiB'M,,,,1!!,.' i U",;1; if	i '•,• n •• i",.,!,:  „,;;;, /tiiii1"." i i, -^'Owr  >, ''..i"'!;:! mid	'",'!; in1 «' iiifWi'fiiiiiiLiT J' ,. iffv , /. ir B^^	"	I'.in iiKKViPiip i!i;» a?1 I>:,i
                 First, the survey explained the problems associated with sedimentation and the procedures
                 commonly used to control soil erosion and prevent sedimentation. The "harmful or costly
                 effects" from sedimentation described to respondents were (Malcom et al., 1990):

                 •      Killing fish and other water life, reducing catches for fishermen

                 •      Reducing the dep& of streams, rivers, and lakes, increasing the possibility of flooding,
                        and requiring expenditures for either flood control or the removal of sediment from the
                        bottom by "dredging"

                 •      Filling reservoirs with dirt, reducing the amount of water in the reservoir and requiring
                        additional expenditures either to remove the sediment from the bottom of the reservoir or
                        to build more reservoirs

                 •      Causing rivers, streams, and lakes to appear muddy and less attractive to hikers and
                        swimmers ^	_	,	,	,     ,	;i	;ii	,	.„.,,,	,i:   t 	::	„, i
                              , I,, l  IM ,ii;r "< ,nii|i ', ,, . ,,,,i 1», ,, • ' •  „ Hi', . n" ,1! ' : ' i J	„ :!,,      ',  ' ,i|	',	 I	Hip r I11< fill ,i I! Jll,,, WI   < ,lil'i,i,i< j||l|llll,	I	j,	 llnFI'l , ,  I'iU'.iL ' .„,' Jin ,:, „ „,  " ' ,' " n Mllllll*  i
                 •      Filling channels used for recreational boating and commercial fishing, requiring removal
                        of sediment by  dredging.

                 Procedures available to developers for controlling sedimentation that were outlined and
                 illustrated for respondents were (Malcom et al., 1990):

                 •      Rapid completion of construction so that land is disturbed for short periods of tune
                         , i              '                           ,                 i          „      ! '
                 •      Construction of sediment trapping devices, including ponds and ditches, so that sediment
                        is kept on the property, and does not wash into a nearby river, stream, or lake

                 •       Construction  of silt fences or check dams to catch or slow down sediment runoff before it
  	/~     ••;_'   / "	reacnes a nearby water body	
  I I" ,	"" ! 	    • 1"	 'I	'"'"  . !	"•  '»	Jl' "'!'• '  • .TI 'I'1.	 ,1',  "'i'  ;"   i' '" 'i '	'„ 	•''Hi J i	'""	'1 ' '•' ,',	 '  ",i,'n	!'•"• N'Hl1' '" 	M	 ' ' ' v li II": i'I I,	 I . . '.in ' i, 	!i||,j|;"   ' .
  i;,'1!!,!:1! ; "iiiiiiJ	•:»„ '  • i  l,:,1.",!! ."Hii	j,•;;"!•' ,;, flLi liiliiilliiyili11  fllililf'Fii!1!:! ''"'II...N.S'"".'..»  Idif;+ri^ ' ,''	"ii" '"I* i'l,"."i '.s,*'"*!	Wi''t , ' "A'\",''
:	,.	;	i" '„(,;,;_  ','-,,  j",,,,	jf '"":„, "jjii	fie ,of sto^-lined or paved channels to •


  i:: :• \' ^	|;'   !N • "*•''	"""	" """'!l!'" |o(!d|ng iand tree protection to preserve the natural ground cover.
                6-28
                                       Final Report
October 1999
                                                                                                       111	i
-------
                           6.0  Quantitative Assessment of Benefits
 Respondents were asked to assume that no funding sources for administration of the program
 existed, and that the public would pay for all administration, monitoring, and enforcement costs.
 Respondents were then asked about their recreational activities and to state their willingness to
 contribute to a special fund to administer, monitor, and enforce sediment control measures.
 Finally, respondents were asked about household characteristics and their opinions on
 environmental quality.

 It is important to note that Paterson et al. conducted their survey in 1990, based on the state of
 contingent valuation (CV) science in the late 1980's; CV survey methods and analytical
 techniques have developed considerably since then. In particular, the survey predated
 publication of proposed recommendations developed by the NOAA Panel on Contingent
 Valuation (58 FR 4601).  Nevertheless, the survey was reviewed and pretested prior to
 implementation (Lindsey, Paterson, and Luger, 1995) and the research team followed the
 recommendations in Mitchell and Carson (1989) to the extent possible (R. Paterson, personal
 communication, January, 1999). The authors also obtained technical advice from Dale
 Whittington, who is well recognized in the fields of water resource economics and nonmarket
 valuation.

 Although the response rate to the mail survey was only 41%, this response rate is similar to
 response rates for other mail surveys that obtain WTP values for policy development. For
 example, a 1987 CV study for Mono Lake, California had a 44% response rate (J. Loomis,
 personal communication, January, 1999), and the recreation demand study for the Columbia
 River System Operation Review Environmental Impact Statement (Cameron et al., 1999) had a
 raw response rate of 36%.

 Discussion of Survey Results

 Paterson et al.'s (1993) analysis of the survey results indicated a mean of $20 per year (in  1990
 dollars). This estimate is a simple statistic calculated from the open-ended valuation question
 that followed the dichotomous choice question. EPA adjusted the mean WTP value to $25 to
 account for inflation from 1990 to 1998.8

 The good that the authors asked respondents to value was a program that would administer,
 monitor, and enforce requirements that developers control erosion from construction sites. It is
 likely that the average household WTP responses reflect values for avoiding the sedimentation
 damages caused by construction site erosion because the survey discussed these types of
 damages (especially impacts on water-based recreational activities) and included photos showing
 examples of eroded construction sites with descriptions of adverse watershed impacts.
 Furthermore, 56% of the respondents  reported participating in water-based recreational activities
 and would be more likely be familiar with water quality impacts on these activities than people
 who do not engage in such recreation  activities (Lindsey, Paterson, and Luger, 1995).

 The respondents provided only their WTP for a state program that would help protect water
 quality (respondents were told that developers would pay for their own erosion control
 measures). Therefore, they may have provided lower bound estimates of then* WTP to prevent
'Based on the change in the CPI from 1990 to 1998 (1.25%) as reported in the Economic Report of the President (Office of the
President, 1998). Note again that currently there is a debate regarding the accuracy of the CPI.
October 1999
Final Report
                                                                                    6-29
-------
                                           6.0 Quantitative Assessment of Benefits
             ~	|  ^KgllsWcSon^slte sedimentation damages in urban runoff either Because they internalized
             S ^eyeiopimenTpnce	m"creases or because'fliey'engageH	E'free r ~3:~ ~	^-11" ---	
                                                                       ivior.
                                                                     	i	
      	"i	i	ii	>':;:
lljljJlljjijj.ljjjIT'lljjij.llijjljjIjjjP1 ' |i!|j,j|;	|jjj|l »j|l;« | I!
iliir'k iuSiL1!'!" \,i'i'!li,ii:iiiil "''ii'iii
       hi.!!'I  i  If IllU'l'"
fit i! ,,;¥' :, "'ii'1
 ,!  i !»W, "' I Ill'l
   ::The survey did not provide specific quantitative information about how water quality would be
   i*a|fkctelby the program9. This potentially raises the question of whether the respondents are
    valuing a well-defined environmental good or whether their WTP really reflects a willingness to
    support envkonmental quality in general. It is useful to note, however, that a coincident water
!f™qiMty studyobtaiiied higher WTP estimates for a specific good: reduced nutrient loadings in
    urban runoff for the Chesapeake Bay.  Lindsey (1992) obtained WTP estimates for a new
    government program to reduce nutrient loadings to the Chesapeake Bay from urban storm water
    runoff. Annual WTP for a 4% reduction in loadings was $42 and the WTP for a 1% reduction
    was $24 (Lindsey, Paterson, and Luger, 1995). This study demonstrates scope effects (i.e., WTP
    varies with the level of provision and, thus, provides evidence it represents values for an
    environmental good rather than a "warm glow") and elicits WTP for a similar type of water
    quality impact (i.e., a small change in the effect of urban runoff on water quality). Consequently,
    it provides support for the contention that the WTP values in the North Carolina study represent
    benefits: of'Improved v«afer ^^1^10  jt further suggests that the WTP values obtained in the
    North Carolinastudy are not particular to North Carolina residents.

    Benefit Transfer of Survey Results
II I    11    !
    Although North Carolina's erosion and sediment control program is similar to the construction
    site controls of the Phase II rule, the program covers all activities disturbing one or more acres
    whereas the Phase II rule covers construction sites between one and five acres in size. Other
=~1:*s:S^w0^1^e.jQy^d1i^sipn program^'m place that are similar to Phase II  (including CZARA
    States with primary enforcement). Therefore, to transfer Paterson et al.'s results to estimate the
    gSientialbenefits of the Phase II rule, EPA calculated the percentage of Phase II construction
    starjs that are not covered by a state program or CZARA.

    Nonurban households were not surveyed by Paterson et al. (1993) and EPA has no information
    off the WTP of these households. However, it is likely that these households also value soil and
   'S1!'" iCiiiUH	': " tililK^^^ ' lliilHlllJ	I'll, WliliE' IlllWil	IV WW II	I"	>	V '	fiilj	liflj	'	,«!"	(• 	'"	1 	B'J" * •	:	J	9TJU*	 i	W'WJrvp!	"• 	
    er&gon control programs.  One variable that may indicate potential differences in WTP is
    income. However, the per capita incomes of the urban residents surveyed by Paterson et al.
    r|I|c| ||| rapge of incomes throughout the State.  Thus, EPA does not believe that the value to
   ^^^"j^^^g^^j^r^g significantly different from that of nonurban residents. Therefore, EPA
    estimated the'aggregate WTP for all households.
             illil'i
             !	ili	
            1 ll'iiJt

             ili1!!!!!!!::1.
                                                      . .1.1.
                 If construction site erosion rates are higher for North Carolina than for other areas of the country,
                 the WTP values to prevent erosion from migrating off-site may be greater in North Carolina as
                 well. However, it is likely that erosion rates differ within Norm Carolina, so there is no one
                 figure to use for comparison. Likewise, storm water erosion rates elsewhere differ across a
                 *EPA is similarly unable to quantify water quality impacts of me Phase II rule Because damage functions are not
                 available to estimate how the soil erosion controls might avoid future impacts on water quality. Consequently, the good
                 in the'survey inore closely approximates the provisions of the rule than any household benefits measure that could
                 derived from the Carson and Mitchell (1993) water quality study.

                 "Lindsey, Paterson, and Luger (1995) note that North Carolina State officials used the results of the Paterson et al.
                 (1993) benefit-cost analysis in educational workshops in New England to assist states considering similar construction
                 erosion control programs.
                 6-30
                                            Final Report
                                                                                                 October 1999
                                                                                                           \ o * f
                                                                                                           \ £ -!
-------
                          6.0 Quantitative Assessment of Benefits
 variety of geological and climatological dimensions.  The CV study developers were sensitive to
 this issue and developed a stratified sampling plan to include respondents from three major
 geological regions of the state: the coast (sandy soils), the Piedmont (clay soils), and the
 mountains (Paterson et al., 1993 and R. Paterson, personal communication, January, 1999).
 Consequently, the aggregate values represent WTP across respondents who are familiar with a
 variety of soil types. Therefore, EPA did not adjust WTP for households to account for
 differences in watersheds.

 As shown in Exhibit 6-18, EPA multiplied the percentage of Phase II construction starts by the
 number of households and by the $25 WTP value.  For example, in Virginia, 21.6% of
 construction starts in 1994 were on sites of between one and five acres and were not regulated to
 control storm water runoff under a state program or CZARA. Also, in 1997, there were
 approximately 2,522,096 urban households in Virginia.11 To estimate the number of households
 using the WTP estimate of $25, the calculation is:

    ($25 adjusted WTP) x (2,522,096 households) x (21.6% Phase II starts) = $13.59 million.

 EPA considers the resulting benefit estimate a high estimate because using the percentage of
 construction starts potentially overstates the contribution of the Phase II starts to overall soil
 erosion caused by construction activities.  As a lower bound, EPA used shares based on site  •
 perimeter, which was chosen as a proxy for the share of eroded soils that would migrate offsite
 from different sizes of sites during construction. To estimate the share for each state, EPA
 estimated aggregate site perimeter length assuming square sites and taking the acreage midpoints
 for site size for all of the Phase II starts and for all starts.  Exhibit 6—19 reports the site-specific
 assumptions used to calculate the perimeter shares.  Exhibit 6-18 reports the resulting
 percentages, which are lower than the percentages calculated on a start basis.

   Exhibit 6-18. Potential Annual WTP for the Phase II Soil and Erosion Control Program (1998 dollars)
£ "* i."
*- v _ •*• .^
* 3"f
"State *"*
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
DC
Delaware
Florida
Georgia
Hawaii
Idaho
*;, i. \ ^
Phase n Share
of Starts
40.5%
11.7%
34.3%
41.1%
36.3%
39.7%
0.0%
0.0%
0.0%
0.0%
18.0%
36.0%
41.0%
Phase II Share
Jof Perimeter
32.7%
9.5%
25.9%
32.9%
27.8%
32.1%
0.0%
0.0%
0.0%
0.0%
11.4%
27.3%
32.9%
1998 ^
Households
1,617,661
228,206
1,705,980
944,876
12,085,506
1,457,919
1,224,666
274,000
198,114
5,488,369
2,803,836 '
444,420
453,270
? - r ~* " ? *f » "VrJ ~ 1 « ^ , A'Vf,*
„*£- Benefits ($ millions) '% T
»•_ t «- ,- Zi.,~,i.f, ^
Low Estimate
13.21
0.54
11.06
7.76
83.99
11.68
0.00
0.00
0.00
0.00
8.02
3.03
3.73
r., z&'.*
-High Estimate
16.38
0.67
14.63
9.72
109.67
14.49
0.00
0.00
0.00
0.00
12.59
4.00
4.65
"Estimates of households per state are based on the most recent estimate of population by state from 1997.
October 1999
Final Report
                                                                                     6-31
-------
                                                                                                                             i
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                                                    6.0 Quantitative Assessment of Benefits
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        •!.' .  'it,"
         liu   .•
                       Exhibit 6-18. Potential Annual WTP for the Phase n Soil and Erosion Control Program (1998 dollars)
' '
• State
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Mevada
ttew Hampshire
STew Jersey
^Jew Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Ihode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Phase H Share
of Starts
40.1%
41.7%
42.2%
41.8%
40.6%
40.8%
43.3%
0.0%
7.7%
0.0%
43.7%
42.1%
40.3%
42.7%
39.8%
33.7%
19.1% .
0.0%
40.2%
40.0%
0.0%
43.1%
40.2%
41.1%
40.7%
0.0%
0.0%
0.0%
44.1%
40.1%
38.2%
39.8%
43.5%
21.6%
38.3%
30.8%
28.7%
Phase n Share
of Perimeter
32.0%
34.0%
34.4%
34.1%
32.7%
33.0%
35.9%
0.0%
6.1%
0.0%
36.5%
. 34.5%
32.3%
34.8%
31.5%
25.3%
12.3%
0.0%
32.6%
31.6%
0.0%
35.6%
32.1%
33.4%
32.6%
0.0%
0.0%
0.0%
36.7%
32.3%
29.9%
32.0%
36.1%
17.3%
30.0%
22.3%
20.4%
1998
Households
4,455,374
2,196,295
1,068,323
971,850
1,463,717
1,629,876
465,188
1,907,973
2,291,206
3,660,634
1,754,887
1,022,660
2,023,243
329,142
620,551
628,018
439,217
3,016,048
647,847
6,792,969
2,780,967
240,031
4,189,637
1,242,356
1,214,789
4,501,746
369,824
1,408,307
276,394
2,010,561
7,280,651
771,216
220,591
2,522,096
2,101,259
680,070
1,936,209
" ^
Benefits ($ millions)
Low Estimate
35.68
18.66
9.19
8.28
11.98
13.44
4.17
0.00
3.48
0.00
16.03
8.81
16.32
2.86
4.89
3.97
1.35
0.00
5.28
53.65
0.00
2.14
33.65
10.36
9.91
0.00
0.00
0.00
2.54
16.24
54.49
6.16
1.99
10.91
15.76
3.80
9.86
High Estimate
44.64
22.90
11.27
10.16
14.86
16.64
5.04
0.00
4.41
0.00
19.18
10.78
20.39
3.51
6.17
5.29
2.10
0.00
6.51
67.93
0.00
2.59
42.11
12.78
12.36
0.00
0.00
0.00
3.05
20.16
69.51
7.68
2.40
13.64
20.14
5.24
13.89
                                                                                            	i|i'!"'ii''!i' Huii'ir	annpii	iii'.ii
                   6-32
                                                                   Final Report
October 1999
-------
                            6.0  Quantitative Assessment of Benefits
    Exhibit 6-18. Potential Annual WTP for the Phase n Soil and Erosion Control Program (1998 dollars)
State
Wyoming
Total
4 - f »t-
f « a f " , „" -1
Phase nShare*'
L of Starts^
42.8%
24.8%
?
X # £
*• " v J* &^s £•
Phase H Share
of Perimeter
35.3%
19.5%
^ ' 1998, s " \
Households
179,679
100,238,225
Benefits ($ millions)
Low Estimate
1.59
540.45
t * > , *„ -.•> -,
High Estimate
1.92
686.02
                     Exhibit 6-19. Assumptions Used to Derive Perimeter Shares
Site Size Category 'f *> * , y/_^
0 to 0.5 acres
0.5 to 1 acre
1 to 2 acre
2 to 3 acre
3 to 4 acre
4 to 5 acre
5 to 10 acre
More than 10 acres
^ * -Average Site'SLze s <.
0.25 acre
0.75 acre
1.5 acre
2.5 acre
3.5 acre
4.5 acre
7.5 acres
14 acre'
5 » -%i » »j«" A -»-«
Site Perimeter^- i / J
417
723
1,022
1,320
1,562
1,771
2,286
3,124
   The midpoint for the open-ended size category was estimated using the housing density implied by the sample
  data shown in Appendix B-2.

 EPA then summed the lower and upper bound results across all states.  The results indicate that
 WTP for the erosion and sediment controls of the Phase II rule may range from $540.5 million to
 $686.0 million per year (Exhibit 6-18).

 Small Stream Benefits

 The WTP estimates derived above reflect the potential benefits of erosion and sediment control
 programs that protect all lakes, rivers, and streams. Because construction can be especially
 harmful to small stream habitat, EPA is interested in the benefits that may be attributable to
 improvements in small stream ecology. Information on the different proportions of waters in the
 United States may provide a rough approximation of, and may not fully capture, how these
 benefits may be attributable to small streams versus larger water bodies. However, such an
 exercise is complicated because lakes are measured in acres or square miles and rivers and
 streams are measured in miles. Therefore, EPA converted stream miles to square miles using the
 average width and depth of each stream order. Based on inventory data reported in state 305(b)
 reports and the distribution of streams by stream order (Keup, 1985), approximately 20% of all
 water bodies in the United States are rivers or streams and 10% of rivers and streams are
 classified as first order streams. First order streams are non branching and form the headwaters
 of riverine  systems. Approximately 2% of all water bodies are first order streams,  suggesting
that $10.8 to $13.7 million of the total annual benefits from erosion and sediment controls may
reflect a desire to protect small streams  (2% x $540.5 million and 2% x $686.0 million,
respectively).
October 1999
                                       Final Report
6-33
-------
                                           6.0 Quantitative Assessment of Benefits
i •
i 11111
63.5  Summary of Benefits
                                                          '    •     i
A summary of the potential benefits from implementing the Phase II municipal measures and
erosion and sediment controls for construction sites |s: presented in Exhibit 6-20.  Total benefits
from municipal measures and construction site controls are expected to be $671.5 million to $1.1
billion per year (assuming 80% effectiveness of municipal programs), including benefits of
approximately $10.8 to $13.7 million per year associated with small stream improvements. The
largest portion of benefits are associated with erosion and sediment  controls for construction
sites.
                                  \;	         	|    	      '""I;"!!;.;
As shown in the exhibit, some categories of benefits are not included in the WTP estimates from
the research use3.  In particular; values for improving marine water  quality (those related to
comme|^aJj5sMng and shell fishing and recreation, e.g. fishing) are not mcluded  in the potential
benefits of the municipal minimum measures (excluding soil erosion construction sites controls).
                               Exhibit 6-20. Potential Annual Benefits of the Phase II Storm Water Rule
                                                    (Millions of 1998 dollars)
             ill
             nil 11
111 1
in 11
             •Ill
             Illl H
'/ 	 	 '. . - , ;;j ~ ^Benefit Category
Annual WTP "':"•'-*
Municipal Minimum Measures1
Fresh Water Use and Passive Use2
Marine Recreational Swimming
Human Health (Marine Waters)
Other Marine Use and Passive Use
$121.9-5378.2
$2.1
$7.0 -$29.9
+
Erosion and Sediment Controls for Construction Sites
Fresh Water and Marine Use and Passive Use3
$540.5 -$686.0
Total Phase II Program
Total Use and Passive Use (Fresh Water and Marine)
>$671.5->$1,096.2
 + m positive benefits expected "but normonetized
 JBased on 80% effectiveness of municipal programs.
 Potential annual benefits of improving fresh water impairment (Exhibit 6-9) plus potential annual benefits of
 avoiding future fresh water impairment (Exhibit 6^13)
 3Based on research by Paterson et al. (1993). Although the survey's description of the benefits of reducing soil
 erosion from construction sites included reduced dredging, avoided flooding, and water storage capacity benefits,
 these benefit categories may not be fully incorporated in the WTP values. Small streams may account for over
 2% of total benefits.
                6.3.6  Sensitivity Analysis
                As with the cost analysis, the analysis of benefits is subject to uncertainty.  EPA conducted a
                sensitivity analysis to evaluate the impact of key assumptions on the final benefit estimates.
                EPA? in its efforts to establish a baseline for water quality impairment attributable to Phase II
                sources^ may have overestimated the extent to which the 305(b) rnipairment data characterizes
                unassessed waters. Since" 305(t>) 3ata is gathered and reported by mdividual states, the method
                for deciding which waters to assess will vary from state to state. If some states choose to
                6-34
                                        Final Report
October 1999
-------
                          6.0 Quantitative Assessment of Benefits
 monitor only those waters that are likely to be impaired instead of a random sample of waters,
 then the reported percentage of impaired waters will not be characteristic of the unassessed
 waters.  To determine the sensitivity of benefit estimates to the assumption that waters
 represented by the 305(b) data characterizes all waters, EPA estimated benefits assuming that
 only 50% of the unassessed waters are similarly impaired. As Exhibit 6-21 shows, this
 assumption reduces overall benefits by 8% to 12%.


                           Exhibit 6-21. Results of Sensitivity Analysis
i * *" ~ ** "* * ^ - "- t
^ * , s >*•*., "Assumption1 ^ I ? x\
> - <..' ^^~nvv--«;^ -, '- ,
Original estimates
Impairment for 305(b) assessed waters applied to 50% of
unassessed waters
Percentage change from original estimates
J , - - -, ^ «. _, -• H.
Estimated Total National Benefits -
» (1998 dollars) *.,*-",,*
S671.5-$l,096.2
S619.2-S964.5
-8% to -12%
  1 EPA expects that the municipal program will achieve at least an 80% effectiveness.

 6.4    Limitations and Uncertainties Associated with the Benefits Analyses

 EPA's benefit analysis used two different approaches to estimate potential benefits .of the Phase
 II rule. The first approach used the NWPCAM to simulate the effect of the Phase II municipal
 minimum measures and soil erosion control provisions on water quality at the local level.
 Benefits, including benefits accruing to local and nonlocal populations, were estimated to be $1.6
 billion per year based on a benefits transfer of WTP values from Carson and Mitchell (1993).
 The second approach estimated benefits for the municipal minimum measures and the soil
 erosion control provisions separately. The municipal minimum measures benefit analysis was
 primarily based on national water quality assessment data in the 305(b) report and Carson and
 Mitchell's (1993) WTP values for changes in national fresh water quality, although some marine
 benefits were also estimated. The soil erosion control benefit analysis was based on construction
 start activity and a WTP value for a similar program in North Carolina. Total benefits for the
 second approach are estimated to range from $671.5 million to $1,096.2 million per year.

 Key limitations and uncertainties associated with the above estimates are summarized by
 analytical approach in Exhibit 6-22. Among the most important of these limitations is the
 inability to monetize some categories of benefits, which may underestimate potential benefits.
 There is also uncertainty associated with the applicability of the WTP values used' to estimate
 benefits of the rule, and with many details of the modeling approach. Some assumptions made to
 address uncertainty may tend over estimate benefits and others may tend to under estimate
 benefits.  The net effect is unknown.
October 1999
Final Report
                                                                                    6-35
-------
                                         6.0  Quantitative Assessment of Benefits
                             Exhibit 6-22. Key Limitations and Uncertainties in the Benefits Analysis
ii:	it
il
1] *,
Factor
Impact on
Benefits
Estimates
i « « it / » ,
Comments
National Water Pollution Control Assessment Model Benefits Analysis
The estimates of potential benefits do not include
benefits from improvements to marine waters.
The WTP estimates were assigned to "local" waters
on the basis of changes to local water quality rather
than statewide water quality.
The small stream analysis may have overstated
improvements to small streams.
The estimated number of Phase II construction sites
used in the model is 8% higher than the number used
in the rest of the economic analysis.

+
+
+
Uses of marine waters (e.g., commercial fishing
and shellfishing, recreational fishing, and
swimming) are highly valued. The model does
not include marine water, nor do the WTP values
reflect household benefits associated with
improved marine water quality.
Survey respondents assigned two thirds of their
total valuation for water quality improvements to
improvements in in-state-waters. By assigning •
this share to improvements in local waters, the
analysis may have overstated WTP for these
improvements.
Because small streams were modeled only as
conduits from construction sites to RF1 waters,
both the baseline level of pollution and the extent
of improvement due to Phase II controls may
lave been overstated.
This may slightly overstate the benefit estimate
relative to the cost estimate.
National Water Quality Assessment Benefits Analysis
The estimates of potential benefits from the
municipal minimum measures do not include some
categories of potential benefits from improvements
to marine waters.
The estimates of potential benefits from erosion and
sediment controls for construction sites may not fully
capture the value of the flood control, water storage,
and reduced dredging benefits.
The WTP values for the soil erosion control
provision may overstate household WTP.
Carson and Mitchell's survey mentioned limited
examples of passive use benefits for fresh waters,
therefore it is not clear whether their results fully
reflect these values.
Estimates of the potential benefits from the
-

+
+/-
+/-
Uses of marine waters (e.g., commercial fishing
and shellfishing, and recreational fishing) are
highly valued. Individuals also likely hold
passive use values for marine waters. However,
the extent to which marine waters will be
improved by the Phase II rule is unknown.
Paterson et al. (1993) suggest that existence value
motivated survey respondents' WTP. Thus, their
results may not fully capture the total program
value.
Paterson et al. (1993) had a 44% response rate to
their mail survey; those not responding may have
seen less concerned about construction site run-
off than those who did respond.
EPA did, however, adjust for changes in attitudes
towards spending for pollution control.
Vlunicipal programs may be more or less
                                                       Final Report
                                                 •V,'	P'Mll	 '  III"  •' /Ml
                                                                                         October 1999
                                                                                            'ill '  I'M 1.
                                                                                                   )-.'
-------
                          6.0 Quantitative Assessment of Benefits
Paterson et al.'s survey was conducted prior to
recommendations developed by the NOAA Panel on
Contingent Valuation.
Survey respondents in Paterson et al.'s study were
not informed of the full costs of the state program.
Nationally, WTP for erosion and sediment controls
may differ from that of North Carolina households.
WTP of nonurban households may also differ from
that of urban households.
Overall Impact on Benefits Estimates for either
analysis '
+/-
+/-
+/-
+/-
Paterson et al. (1993) followed methods,
recommendations, and technical advice as
published and provided by experts in the fields of
water resource economics and nonmarket
valuation.
Additional information regarding total program
costs may have influenced WTP.
EPA examined income data (a factor likely
influencing WTP) and found that the median
incomes for the urban areas surveyed by Paterson
et al. are representative of the range of incomes
across NC counties. EPA also found that the
median income of NC ranks 31 among all states
and, therefore, concluded that no adjustment for
income differences was necessary.
There is not sufficient information to assess the
direction of potential bias in the analysis of
benefits.
 - = understates benefits
 +/— = unclear impact on benefits

6.5    Conclusion

The two approaches to estimating the potential benefits of the rule generate a wide range of
benefits, although both approaches show that the benefits are likely to exceed costs.  The
NWPCAM approach obtains a higher overall benefit estimate. In part, this is because the river
reach modeling approach generates a higher estimate of water quality improvements because
impairment is based on water quality parameters rather than designated use. The water quality
improvements that could be obtained using the national assessment data from the 305(b) report
are constrained by designated use (e.g., improving water quality to a swimmable level will not
generate incremental benefits if the designated used is fishing). The WTP values are based on
improving national water quality regardless of designated use, however, and the NWPCAM
approach is not affected by this constraint.  The NWPCAM valuation approach, however, tends
to  increase the estimate of benefits associated with any particular change in water quality.
Consequently, part of the difference between the estimates may be caused by the benefits transfer
method used.
October 1999
Final Report
6-37
-------
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                                                                                                                                                                                                                                              "I"'	'   !'    ',"	I.  «':"'!'	I	B.  iii!	  :S'i!
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                 7.0  COMPARISON OF BENEFITS AND COSTS

  This chapter provides a comparison of the monetized annual benefits and costs of the Phase II
  storm water rule.

  7.1   Total Annual Monetized Benefits

  To estimate the benefits of the rule, EPA used two different approaches: (1) water quality
  modeling approach and (2) water quality assessment approach. Because the approaches use
  different methodologies, the benefits estimates are presented separately for comparison in this
  chapter.

 National Water Quality Model

 EPA monetized benefits of water quality improvements associated with the Phase II rule in the
 designated uses of stream and rivers in the United States using a national  water quality model.
 The National Water Pollution Control Assessment Model (NWPCAM) estimates the aggregate
 annual benefits of the Phase II rule to be $1.63 billion.  This estimate, however, does not include
 estuarine and marine water benefits because the NWPCAM cannot estimate them at this point in
 time.

 National Water Quality Assessment

 EPA developed a partial monetary estimate of expected benefits of both the minimum municipal
 measures and the construction components of the rule. As reported in Exhibit 6-20,.the sum of
 these benefits ranges from $671.5 million to $ 1.1 billion annually.  However, as noted above and
 in Chapter 6, this benefit range is not comprehensive because it omits several benefit categories
 which are difficult to monetize. For example, some of the benefits associated with water quality
 improvements in marine waters, although potentially significant, are not included. Furthermore,
 other benefits may be underestimated.  The benefits  associated with construction site controls,
 for example, may be underestimated because all beneficial aspects of construction site controls
 may not have been fully valued.' In particular benefits associated with post-construction runoff
 are not included in the total benefits to be consistent with the cost analysis.

 EPA expects that the benefits associated with implementation of the minimum municipal
 measures (excluding erosion and sediment controls for construction sites) will begin accruing
 approximately three years following implementation of the rule. This three year time period
 provides time for such measures as public outreach and education to become effective and the
 benefits realized. With regard to erosion and sediment controls for construction sites, EPA
 expects benefits to accrue immediately following implementation of the rule because the
 construction site controls will be immediately effective abating sediment and providing benefits.

 7.2    Total Annual Monetized Costs

As described in Chapter 4, EPA estimated the annual aggregate municipal  and construction
compliance costs and Federal and State administrative costs for the proposed regulation to range
from $847.6  to $981.3 million. EPA expects that costs will decrease over time because certain

October 1999                 '           Final Report      ~                            7_/
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                                           7.0  Comparison of Benefits and Costs
•it
(in in
      •ill
                municipal activities should be completed during the first permit cycle. These include
                development of construction ordinances and BMPs for new developments, development of
                Ordinances prohibiting discharges other than storm :wateFmtd'rae MS4s, assessment of the
                maintenance, schedules.^^^,^0^.waitgrjnfi^tructure, and the assessment of illicit
                connections to the MS4s. However, because EPA preferred to present one cost figure, the costs
                for these items were not eliminated for subsequent permit cycles.
                7.3    Comparison of Benefits and Costs
!i:iiiiiiiiiii,inii'i i i Hi!,;fill
   f LI,?1	fill	!, ill"	i	i
    Exhibit 7-1 provides an annual comparison of benefits and costs for a representative year in
    whichiiMthg.rule js implemented, one in which benefits from the minimum measures and
    construcSon controls are accruing.  Because there is not an initial out lay of capital costs with
    benefits accruing in the future (i.e., benefits and costs are almost immediately at a steady state), it
    is not necessary to discount costs in order to account for a tune differential. In addition, EPA did
•I   III! II 111 III   I III III   IIIUIII          •                                                         '   '. '
    not vary the factors that comprise the benefits and costs to  account for market changes over time.
    Therefore, the benefits and costs presented in Exhibit 7-1 reflect a constant and steady stream of
    annual benefits and costs.  This method of comparing benefits and costs, described hi EPA's
    Guidelines for Performing Regulatory Impact Analysis"(1991),|'Appendix C, compares streams "of"
    benefits and costs to examine net benefits in each year. This is deemed equivalent to first
    discounting the costs and benefit streams to obtain their present values and then comparing them.

    The two approaches to estimating the potential benefits of the rule generate a wide range of
    benefits. The water quality model approach obtains a higher overall benefit estimate event
    though it includes only a portion of freshwater benefits (i.e., lakes are included), and it excludes
    all marine benefits. Bom approaches show that benefits could exceed $1 billion while costs
   .would[likely be less than $1 billion. In addition, costs are expected to decrease over time
f»= j1 because certain components are likely to be implemented in the first permit cycle only. This
S,;;'ltRSreases the likelihood that actual benefits would indeed be significantly greater than the
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-------
                               7.0 Comparison of Benefits and Costs
          Exhibit 7-1. Comparison of Annual Benefits to Costs for tbe Phase II Storm Water Rule
  National Water Quality Model
  Total Annual Benefits
                                      $1,628.5
  National Water Quality Assessment
  Municipal Minimum Measures
  Controls for Construction Sites0
  Total Annual Benefits
                                   $131.0-$410.2
                                   $540.5-$686.0
                                  $671.5-$1,096.2
 Municipal Minimum Measures
 Controls for Construction Sites3
 Federal/State Administrative Costs
 Total Annual Costs
                                       $297.3
                                   $545.0-$678.7
                                        $5.3
                                   $847.6 -$981.3
  'National level benefits are not inclusive of all categories of benefits that can be expected to result from the
   regulation.
  2Detail may not add to total due to independent rounding.
  3 Controls evaluated include both erosion and sediment and post-construction controls.
October 1999
Final Report
7-3
-------
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                8.0 REVISED SMALL ENTITY ASSESSMENT

 This chapter updates EPA's analysis and statements with respect to three federal directives:
 Executive Order 12886 (Regulatory Planning and Review), including the Regulatory Flexibility
 Act (RFA) of 1980, as amended by the Small Business Regulatory Enforcement Fairness Act
 (SBREFA) of 1996; Executive Order 12898 (Federal Actions to Address Environmental Justice
 in Minority Populations and Low-Income Populations; and the Unfunded Mandates Reform Act
 (UMRA) of 1995. In particular, because the cost hi Chapter 4 has been revised, EPA revised the
 analysis presented hi the initial SBREFA screening analysis, which was included hi the EA for
 the proposed rule. Section 8.1 presents the results of the revised screening analysis. EPA will
 certify the final Phase II Storm Water Rule. A justification for certifying the rule is provided in
 the Preamble.  Environmental justice issues are addressed in Section 8.2, and UMRA issues are
 addressed in Section 8.3.

 8.1    Revised SBREFA Analysis of Impacts on Small Entities

 In accordance with §402(p) of the Clean Water Act (CWA), the US Environmental Protection
 Agency (EPA) is finalizing a Phase II Storm Water rule. This rule is subject to the requirements
 of the Regulatory Flexibility Act of 1980 as amended by the Small Business Regulatory
 Enforcement Fairness Act of 1996. The analysis of the potential cost implications for small
 entities presented hi the EA for the proposed rule supported the determination that the rule was
 not expected to have a significant impact on a substantial number of small entities.  In response
 to comments, EPA revised its cost analysis for the soil erosion control provision of the rule.
 EPA also revised the per household cost estimate for the municipal minimum measures
 provision. EPA subsequently revised its original SBREFA screening analyses to determine the
 effect of the cost changes.

 The RFA was enacted to increase agency awareness of the impacts of regulations (and their
 alternatives) on small entities, to allow for public comments on regulations that affect small
 entities, and to encourage agency use of flexibility in regulating small entities (US EPA, 1992).
 SBREFA amended the RFA to strengthen its analytical and procedural requirements. Under the
 RFA as amended, agencies are required to prepare a final regulatory flexibility analysis (FRFA)
 unless the agency certifies that the final rule will not have a significant economic impact on a
 substantial number of small entities. EPA is including the following revisions to the original
 economic impact analysis for small entities hi this EA, as further support for the decision to
 certify the final rule.

 The original economic analysis of potential impacts on small entities was prepared following
EPA's Interim Guidance for Implementing the Small Business Regulatory Enforcement Fairness
Act and Related Provisions of the Regulatory Flexibility Act (US  EPA, 1997a) and, where
appropriate, EPA Guidelines for Implementing the Regulatory Flexibility Act (US EPA,  1992).
This section presents mainly those portions of the analysis that have been updated.
October 1999
Final Report
                                                                                   8-1
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•Ill
                                             8.0 Revised SBREFA Analysis
  8.1.1  Background
1 mi i 1   n 11   ii nil  inn n
  Storm water runoff from lands modified by human activities can harm surface water resources in
  two ways: (1) By changing natural hydrblogic patterns (e.g., increasing peak flow levels), and
  (2) by elevating pollution concentrations and loadings. The National 1996 §305(b) Report found
  ftat pollution fern nonpomt sources such as runoff from agHciiltoal ani urban sources,
  corisffuction sites, land disposal oTwaste,"and resource 'extraidion' wasthe leading cause of
  unpaired waters (see also the Preamble to the rule).  In addition, the Nationwide Urban Runoff
  Program found that the concentration of total suspended solids in runoff from residential and
  commercial "sites' was239"mg/L ascompared to 20 nig/L in effluent from treatment plants
  providing secondary freatment (see Preamble).  Evidence also suggests that illicit discharges and
  intensive construction activities can create severe water quality problems. As described more
  completely in the Preamble to the proposed rule, storm water runoff continues to harm the
  nation's waters. The purpose of the proposed regulation is to identify storm watef sources that
  need to t>«egula;te3 to "protect" water~quis3iity and to regulate these sources through a
  comprehensive program.
       nun  iiiii in ill i   in i linn n   n in   i in  in      i   n  n          in mi n   nn i  i   i  i    inn i l| 11 ni|iin      n i i In         n  i
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• I IIIII  I III III IlllililliliS	,	•	 . IM.™.!.,, J-ij.-.. 	i, 	•		-	 ii	•*.,..	..,  	
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llil ' • • I	IllilllhiIIIII	llnilllllllillllC''^'''''!..!!!!!^!!!!'!,,!!'	,jii	•	«iiij|]	i'i-	•	" ii	,	i	g	 •;	B	;	•' 	'	 •  • 	• 1i". 	«	
  discharged through discrete conveyances such as municipal separate storm sewer systems, which
  are subject to the NPDES program.  Under §402(p) of the CWA, EPA is required to implement a
  comprehensive approach for addressing storm water discharges. In the statute, Congress
  specified that this program should be developed and implemented in two phases. The first phase
  addresses storm water discharges that:
                i
  •  were subject to a NPDES permit before February 4,1987
  •  are associated with industrial activity
  •  are from a municipal separate storm sewer system serving a population of 250,000 or
     more    '         	  .     	"	"'	
  •  are from a municipal separate storm sewer system serving a population of 100,000 or
     more but fewer than 250,000
  •  are determined to be contributing to a violation of a water quality standard or to be a
     significant contributor of pollutants.
                          i   inn  in   i  nn    IN      i   n   n n   n i i   n i  n| n i  i    i             i n i
  The rule implements Phase II by instituting regulations for other storm water discharges. In
  accordance with §402(p)(6), this rule establishes a comprehensive program to regulate
  designated sources, and specifies that this program will be implemented as part  of the NPDES
  permitting program. At a minimum, this program is required to establish priorities, requirements
  for state storm water management programs, and expeditious deadlines.
               8-2
                                         Final Report
October 1999
-------
                              8.0 Revised SBREFA Analysis
 The Phase II rule will regulate:

 •      all construction sites disturbing between one and five acres of land
 •      urbanized places and counties not included hi Phase I (see the Preamble for
        additional details on the rule requirements).

 8.1.2   Small Entities Affected by Rule

 EPA used the definitions of small businesses, municipalities, and not-for-profit organizations
 established by the Small Business Administration (SBA) and the RFA. The SBA defines small
 businesses based on Standard Industrial Classification (SIC) and size standards expressed either
 in number of employees or annual receipts in millions of dollars (13 CFR §121.20).  To evaluate
 the economic impact on small entities involved hi the construction activity affected by the rule,
 EPA'looked at the number of building contractors considered to be small businesses.  For this
 SIC (SIC 15), the size standard is up to $17.0 million hi annual revenues. In the EA for the
 proposed rule, EPA reported results from a database of businesses (Dun and Bradstreet, 1997)
 that was used to identify small building contractors.  This estimate is believed to still be a
 reasonably accurate estimate of the number of construction businesses that may be affected by
 either the soil erosion provision or the post-construction control provision of the final rule.

 The RFA defines small governmental jurisdictions and organizations (US EPA, 1992). A small
 government is the government of a city, county, town, school district, or special district with a
 population of fewer than 50,000. A small organization is any not-for-profit enterprise that is
 independently owned and operated, and is not dominant in its field. To evaluate the potential
 economic impact on small municipalities, EPA looked at the unufbanized places, urbanized
 places, and urbanized counties with populations of fewer than 50,000 based on the 1990 Census.
 EPA did not identify any not for profit organizations that would be affected by the rule.  The
 original SBREF A estimate of small municipalities included incorporated places located outside
 of an urbanized area, and incorporated places and counties located either fully or partially within
 an urbanized area. EPA has since revised this estimate to include the minor civil divisions (i.e.,
 unincorporated towns and townships), and municipios located fully or partially  within an
 urbanized area, and to exclude the incorporated places located outside of an urbanized area since
 they are not automatically covered by the rule.  The number of small businesses and the revised
 number of municipalities affected by the rule is shown in Exhibit 8-1.
October 1999
                                      Final Report
8-3
-------
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       	I1*
                    8.13  Compliance Requirements

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                    This section describes the projected reporting, recordkeeping, and other compliance requirements
                    (and compliance costs) of the proposed rule, including the estimated classes of small entities
                    subject to the requirements and the type of skills necessary for the preparation of reports or
                    reco!ds:  Tllissection dso Provides initial screening analysis of the potential impact of these
                    requirements, and analysis of environmental justice issues. The reporting, recordkeeping, and
                    other (i°FP!Jan^S£S$*SP£^ *£ described in Section,8? 1,1,  Section 8.1.5 presents the'
                    screening analysis of the potential economic impacts on the regulated small entities.  Section
                    8.1.6 contains further financial analysis on home buyers who might be impacted.

                                                            ''	  '   " '  	  	   "'"!,	;	;	  \	 | 	f  	      '  ,	I	 i"° " !' •	
                     Exhibit 8-1. Businesses and Municipalities Potentially Affected by the Phase H Storm Water Regulations
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' Business or Municipality
Construction
Incorporated Places, Counties, and MCDs
Municipios (Puerto Rico)
Total Municipalities
Total Number
of Firms
189,4532
5,040
39
5,079
Number of
Small Entities1
187,6103
4,425
30
4,455

                     I™311 munisipalities defined as municipalities with populations of fewer than 50,000; small businesses in SIC 15
              jjjj^^denned as bjginess.s.wjjh	annual,, revenues of $17 million or Jess.
                 »;-5^umbe^ o£fi8psft]KjfiflR firms in SIC 15 with sales > $0 identified in Dun & Bradstreet's FACTS database Firms in
                s'-!:'..*^*8 mQi equivalent soil erosion control programs (CT, DC, DE, MD, MI, NC, NJ, PA, PR, and SC) were removed
              =:,Ju,S««n the original estimate. Because additional states with equivalent programs were subsequently identified (FL GA
                    NH> y>WV' ?°d W1)' t11'5 estimate potentially overstates the number of construction firms affected by that provision
                	^Slwto?™liteini^^^MSP^^BlSS.(MJ?E, FL, MD, PA, RI, and SC) have equivalent programs for the
                    P^00"^™^011 nuioff control provision.  Consequently, this estimate includes some businesses that will not be
                    wscted by that provision and excludes some businesses that will be affected.
                   .               1 construction firms in SIC 15 identified in Dun and Bradstreet (1997). Note that there is no way to
                ™;' 'ijjs^nguish which firms are involved in remodeling only.
                    Scarce: US EPA, 1997.
'ii	iiii.fi1--
                                                     other compliance requirements of the proposed rule are
                               ,!? Exnilt §^?a^ichalso presents EPA's estimates of the cost of compliance for
                              SSKWP^iti63 and[construction contractors.  EPA's analysis of costs did not
                            £22?iderthe costs for small municipalities and construction sites; however, EPA
                fj	«£™~	=£	S2M9.SSS	SJit!6? tob e less	tjiaftfor,	all,e,ntitiess	Therefore, Exhibit 8-2 reports
                  the avejage cost for construction sites and municipalities.  These estimates serve as an upper
                !i n130^! °8	KSJ?!      	        small,enti|iess	The bulk of the costs for municipalities are reported
                  on a per capita basis, with additional fixed administrative costs reported on a per entity basis.
                  Building contractor cost estimates are reported on a per site basis.
                                                              Final Report
                                                                                                        October 1999
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                               8.0 Revised SBREFA Analysis
 Reporting Requirements

 Regulated municipalities will be required to submit annual reports to the NPDES permitting
 authority for their first permit term (a permit term is five years). For subsequent permit terms,
 regulated  entities must submit reports in the second and fourth years unless the permitting
 authority requires more frequent reports. The report must include the following elements:

        The status of compliance with permit conditions, including the status of identified
        Best Management Practices (BMPs) and measurable goals for each of the
        minimum control measures

        Results of information collected and analyzed, including monitoring data, if any,
        during the reporting period

 •       A summary of the storm water activities the regulated entity plans to undertake in
        the next reporting cycle

        A change in any identified measurable  goals that apply to the program elements.


 EPA estimates that the skill level needed for reporting is a high school education or related work
 experience. However, in accordance with §122.22(a)(3), reports must be signed by either a
 principal executive officer or ranking elected official (US EPA, 1997b).

 Building contractors will be required to submit a notice of intent (NOI) to the NPDES permitting
 authority, and to notify the municipality of planned construction activities. EPA estimates that
 the skill level needed for this task is a high school education or related work experience
 (US EPA,  1997b).
October 1999
                                       Final Report
8-5
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                                                   8.0 Revised SBREFA Analysis
iii in	
        i in
              ii in
               Exhibit 8-2. Summary of Compliance Requirements and Estimated Costs of the Phase II Storm Water
              	l	i	Rule for Small Municipalities and Building Con tractors (1998 dollars)	
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                                   Small Municipalities
                   Per household costs (mean)1                   $8.93

                   The per household costs include the cost for: public
                   education and outreach, public involvement, illicit
                   connection and discharge detection and elimination,
                   construction site sediment and erosion control
                   program, post-construction storm water management
                   in new development and redevelopment, pollution
                   prevention/good housekeeping of municipal
                   operations
              Fixed Municipal Administrative costs2

              Submittal of application                         $161
              Record keeping                                 $75
              Reporting                                   $1,289
              Total fixed costs                            $1,525

                                                                            Building Contractors"
                                                                        Administrative costs per site

                                                                  Submittal of NOI                  $126.50
                                                                  Notification of municipalities         $ 17.10
                                                                  Average SWPPP3                  $772.25
                                                                  Retention of records                 $4.51
                                                                  Notice of termination (NOT)        $17.10
                                                                  Total administrative costs        $937.46
                                                         Soil erosion control costs per site4

                                                         Size Category
                                                         1 acre site                        $1,206
                                                         3 acres site                        $4,598
                                                         5 acres site                        $8,709
              'The per household costs do not include municipal administrative costs, which are factored on a per
             : glnjgjjgaliry basis here. So hpusehoM costs are $0.23 less than as reported in Chapter 4.
              Mnnual costs per municipality based on estimated costs over a live year period. For reporting, costs are
             j!j:;j)as,gg! SaJhenumber of reports over 30 years (an average of three reports in each permit term).
              3Stprm water pollution prevention plan.
              Per acre costs are average costs from model simulations across three slope assumptions (3%, 7%, and 12%)
              and three soil credibility assumptions (low, medium, and high).
                 Recordkeeping Requirements
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line proposed rule requires regulated entities to keep" records required by the NPDES permit for
• "i'liil, fjjj	'»i	unit •"'',, will	.i1. 	ii" •	I'L	i« ""i.	"	m  	 ""i'lL.	•	 '»," 	''hiiir- 	nil	'	„	,	,„" ',i	'ii. 	 ' ^,'^iffl ,,i!iii,i,	i	i	,	iiii|i|iiiii:',i	i	.'I'm1 	„„	•	i»	i	nr.m,,,	-	„	,,,,•	•	•	riir.niin	•",' 	»•.•,•	 niu,	 >,	n.'ii 'niii	 ,i,,
• iat	least three ^ears after me permit term. The entities are required to submit their records to the
NPEXJES permitting authority only when specifically asked to do  so. The records, including the
storm water management program, must be made available to the public at reasonable times
during regular business hours.  EPA estimates iihat the skill level needed lor recordkeeping is a
high school education or related work experience (US EPA, 1997b). Building contractors will be
required to retain records of their NOIs, their storm water pollution prevention plans, and then-
notices of termination.
                 Other Requirements
                 The costs shown in Exhibit 8-2 not associated with reporting and recordkeeping requirements
                 reflect the othercompliance requirements of the proposed rule. Under the proposal, NPDES
                 permit holders must develop, implement, and enforce a storm water management program
                 designed to reduce pollutants to the maximum extent practicable (MEP) and protect water
                 8-6
                                                        Final Report
                                                                                         October 1999
-------
                               8.0 Revised SBREFA Analysis
 quality. As part of this program, permit holders are required to identify and submit to their
 NPDES permitting authority (in either the NOI or the permit application) the best management
 practices (BMPs) to be implemented and the measurable goals for each storm water minimum
 control measure. Permit holders must also identify the person or persons responsible for
 implementing or coordinating the storm water program, and identify the years in which they plan
 to start and complete the following measures (Draft Proposed  Rule, February  13,1997):

 •     Public education and outreach. Permit holders must implement a public
        education program to distribute educational materials to the community or
        conduct equivalent outreach activities about the impacts of storm water discharges
        on water bodies, and the steps to reduce storm water pollution.

 •     Public involvement and participation. Permit holders must comply with state
       and local public notice requirements.

 •     Illicit discharge and elimination.  Permit holders must:

       — Demonstrate awareness of their system, using maps or other existing documents,
           develop a storm sewer system map (or equivalent) showing the location of major
           pipes, outfalls, and topography. If data already exist, show areas of concentrated
           activities likely to be sources of storm water pollution.

       — Effectively prohibit (to the extent allowable under state law through ordinance,
           order, or similar means) illicit discharges into then- storm sewer systems, and
           implement appropriate enforcement procedures and actions.

       — Implement a plan to detect and address illicit discharges to their systems.

       — Take actions designed to inform public employees,  businesses, and the general
          public of hazards associated with illegal discharges  and improper disposal of-
          waste.

       Construction site storm water discharge control. Permit holders must develop,
       implement, and  enforce a program for construction sites that discharge into their
       separate storm sewer system. They must use an ordinance or other regulatory
       mechanism that controls erosion and sediment to the greatest extent practicable
       and allowable under state law. The program must control other waste at
       construction sites, such as discarded building materials, concrete truck washout,
       and sanitary waste. The program must include, at a minimum, requirements for
       construction site owners or operators to implement appropriate BMPs, provisions
       for ^reconstruction review and approval of site management plans, procedures for
       receiving and ensuring proper consideration of information submitted by the
       public, regular inspections during construction, and penalties to ensure
       compliance.
October 1999
                                      Final Report
8-7
-------
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           Post-cpnstruction storm water management in new development and
        ^.J^^r^jjpiwewZ'Permit holders must develop and implement programs to control
           storm water discharges into their separate storm sewer system from development
         — aBd redevelopment projects using site-appropriate and cost-effective structural
           alp 'mmsrmciural BMPs.  The programs must ensure that permit holders minimize
           water quality impacts.
                                                                    I
           Pollution prevention and good housekeeping. Permit holders must develop and
  <	 „,!«,< , -"'ill! "'I'M1	!ii'\Hii!iiiii||iiiiiiiiiiiiii!''i!iiiii\iiiiiiiiiiiiiiiiiiii»iiiii!iiiiiiiii!!!,,i	 S;,	  	 ^  _
          IB-implement a cost-effective operation and maintenance program with the goal of
l;:" ""^l^^'^ii'SKmg	^d'reducmgjollutant runoff from municipal operations. If training
          !^'^^|Q^^»^^^^. Jipigajffie^R&ES' ^ftraffie^or "ftan other bf|aiuzations	
           j^hosejmateriais are approved by the local government, the programs must include
           local government employee training to prevent and reduce storm water pollution
           fJQpa government operations.

     •     Permit holders must comply with other applicable NPDES permit requirements
           and standard conditions established in the individual or general permit.

     •     "Evaluation and assessment. Permit holders must evaluate program compliance
           arid effectiveness of identified BMPs and measurable goals.

     8.1.4  Revised Analysis of Potential Economic Impact
  111 ill in in  nun  nil i iiiin||iiiiniii niiiiiin i n i in nil inn

     The initial SBKEFA screening analysis concluded that the rule would not have a significant
     impact on a substantial number of small entities. Since then, the economic analysis for the rule
     has revised the municipal and buildlBg construction costs. To determine whether the revised cost
     analysis for the final rule alters this finding, EPA revised the initial screening analysis to
     incorporate updated costs to municipalities and building  contractors.

     Municipalities

     EPA guidelines recommend a "revenue test" to evaluate  the potential severity of economic
     impact on small municipalities.  This test calculates total compliance cost as a percentage of total
     revenues, EPA used the same method to approximate municipality revenues in the revised
     analysis that was reported in the EA for the proposed rule.  EPA approximated municipality
     revenues using population estimates and per capita revenue estimates from the  1992 Census of
     Governments.  No attempt was made to escalate revenue to 19WdoUars',"so"revenues are most
     likely underestimated. For each small municipality, EPA estimated total costs by first
     multiplying the number of households in the municipality with the per household costs shown hi
     Exhibit, 8i-2," and then'aHdlng' the $1,525 fixed administrative cost. Total costs were then divided
     by municipal revenue to estimate the number of municipalities that had percentages greater than
     1% and greater than 3%. EPA conducted mis test for several per-household municipality costs in
     Exhibit 4-3 of Chapter 4.
             •i
                8-8
                                            Final Report
                                                                                            October 1999
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                                8.0  Revised SBREFA Analysis
 The results of the revenue test and sensitivity analysis are reported in Exhibit 8-3.  The results
 demonstrate that even if the assumption were made that per household costs for Phase II
 communities were equal to the 75th percentile of household costs in the Phase I sample, less than
 20% of small governments affected by the rule will incur costs greater than 1%. Therefore, with
 respect to the mean per capita costs incurred by small municipalities, the rule can be considered
 not to have a significant impact on a substantial number of small municipalities.

                         Exhibit 8-3.  Revenue Test for Small Municipalities
* ff. *&f*f *• f «•>«
^ii'Xv * ^
Per Household Cost1
Median: $3.96
Mean: $8.93
75th percentile: $10.17
Per Municipality
Administrative
Costs
$1525
$1525
$1525
Small jMunicipalities
with Costs Greater than
1% of Revenue (%)~ <<•„
118(2.65%)
481 (10.80%)
628 (14.10%)
Small Municipalities with
'Coste Greater than 3%,of }
„ ^Revenue (%)
25 (0.56%)
31 (0.70%)
32 (0.72%)
  'The per household costs have been adjusted from those reporte'd in Chapter 4 to remove the $0.23 per household
  in administrative costs because those costs are assumed to be the same for each municipality. The administrative
  costs, which were used to generate the $0.23 per household cost, were included in the revenue test as lump sum
  costs for each municipality.

 Small Building Contractors

 US EPA (1997) guidelines recommend a "sales test" to evaluate the potential severity of
 economic impact of compliance costs on small businesses. This test calculates annualized
 compliance cost as a percentage of total sales. Because such a test was not feasible, the initial
 SBREFA screening analysis approximated the sales test by estimating compliance costs for three
 sizes of construction sites and then comparing those costs with a representative sale price for
 three building categories. The site size categories are one, three, and five acres and they
 represent the amount of disturbed land on the development site. The three building categories
 are: single-family homes, multi-family residences, commercial. Industrial building sites were
 not considered because they fall into the multi-sector general permit category.  Institutional
 buildings were also not considered, as they are not typically built to be sold in the real estate
 market. These sales tests assume that all the compliance costs are incurred by the building
 contractor. However, as explained below, it is unlikely that the compliance costs — even if they
 exceeded 1% or 3% of sales for many construction businesses — would have a significant effect
 on these businesses because costs will be passed on to the eventual purchaser of the property.

 Compliance costs were assessed on a construction development or start basis, and a construction
 start could include one or several buildings (particularly for single-family homes).  So to
 compare the compliance costs with sales costs, an estimate of buildings per site size had to be
 made.  EPA developed these estimates based upon construction data collected from 14 local
jurisdictions from around the country. A detailed description of how these estimates were
 derived can be found in Appendix B-2. Ratios of buildings to construction starts are not based
 on a random national sample, so the mean number of buildings per construction start for the
 states affected by Phase II may vary from these ratios.
October 1999
                                        Final Report
8-9
-------
                                                                                                          	I	
IIP111
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                                                  8.0 Revised SBREFA Analysis
                       in  Hi i liliili ill
                                                                           *!1*	IE-	,	;ii"«
                                                                                              ,H!l|i|i|,|,"';i;,,," |! i-lyl'r,, ; ,,! '•|,,||!l	M.i,iWi-4!OKr-lV\
                  For single-family homes EPA divided the revised compliance costs per construction start by the
                  appropriate ^0]£eiS_^o_s£te ratj0 for eacj1 of ^ three sjzes of construction sites. Exhibit 8-4
                  reports the median compliance costs per construction start (see Exhibit 8-2), and the estimated
                  per home costsj based on the estimated number of homes per start. The average  compliance cost
                  per home ranges from approximately $460 to $650.
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 As a proxy for the sales test, EPA divided the revised per home costs by the 1998 median and
 mean home sales prices, which are $151,000 and $181,300, respectively (US Bureau of the
 Census, 1999). Exhibit 8-5 reports the revised per home costs as a percent of median and mean
 home prices!  These per(;eil|^ges ^gg g.om 0.22% to 0.43% and they are lower than values
 reported in tie initial SSHSFA screening analysis, whlc£ ranged from 0.29% to 0.87%. These
 results suggest that under these assumptions, the compliance costs will not exceed 1% of sales
 for a construction business that builds and sells typical single-family homes.
 Ill 111 111 in I i   ill 111 , Iiflillll .iJHtf'*; 'JiSiSi,	'liiflf't	'if1,1:	Jiii,:"'!"!!!''!!';,,:,1"1!1"""1,, sIKJty.lilf''."*''.1 " '<•'• ' ]"Sfl-}',,:Yi'fSH	UflQIHPv "IT,,,/, "' '"'W'l ' 'l"'""!'"' ','f ",  " Siif j"!, f '	^'llillii Ji/ifi1!,1 "I;1
            "	i"	"	i	''	""'"	""	,i'"i i, I,'M,	^		i	i	|,	i	,' 	
 Implicit in this sales test is the assumption that the party that receives the revenue from selling
 the newly built homes for the construction start, is also the party who incurs the  cost for
 compHancewim Phase fi; all parties subcontracted to perform work on building the houses do
 not incur compliance cost and payment for their work is considered part: of the developer's
 building costs. This is in keeping with the definition for "value of construction work done" in
 the 1992 United States Census of Construction Industries (US Bureau of the Census, 1996).
                             Exhibit 8-4. Construction Start and Per-Home Compliance Costs toy Site Size
                                                                                                            i Jdiill!!/',!	'!,    I
1
1 Site Size ,
(disturbed area)
1 Acre
3 Acres
5 Acres
Average Compliance
Costs per Construction
Sfart
$2,143
$5,535
$9,646
Number of
Homes per '
Site *.
5.3
8.5
20.1
Compliance
Costs per
^Home
$404
$651
$480

           4	liili,'
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                       Exhibit 8-5. Per-Home Compliance Costs as a Percent of Median and Mean Home Sale Price
                               it,1!,,f >:.iiiiiiir,'ammmMiii::	:• a'tfiiBfiit'.,!i;ii!iLii-,:;	.iiiiL.!,''!:1 ,f-,,„	i:,"ir':1!-!',,:!.	.iiiiii! •	
                   1 Acre
                   3 Acres
                   5 Acres
                             Percent of Median
                            '. Home-Sale'Price>:"
                            - •  "-($151,000) ••;7;
                                  0.27%
                                  0.43%
                                  0.32%
                                                                   •'Percent-b'f/Mean;
                                                                        0.22%
                                                                        0.36%
                                                                        0.26%
                 The jjjjgai ggj^jgp^ screeimig analysis noted that the cost to sales ratio was expected to be
                 higher for single family housing than for the multi-family residential or commercial
              P^>|'^eyi^[o^ients-	Therefore, if was not considered necessary to also conduct screening analyses for
                 those types of developments.
    	tliJ!
  in;1:!"'Vl ! ',!„'' 'ililiUlh,
                              i:;,iii"',i':,im,'' ,,iiii:; i''«,;:m
                                           Final Report
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                                                                             iiij1	

                                                                                       October 1999
                                                                                         ii    iiiii i iwr ~
-------
                                8.0 Revised SBREFA Analysis
 In response to comments that the post-construction runoff control measure may have a
 significant economic impact on builders, EPA has considered the possible associated costs for
 multi-family residential or commercial developments. The post-construction runoff control
 measure does not directly apply to construction operations, however municipalities may choose
 to regulate construction developers in response to this requirement. In order to inform the public
 EPA conducted similar analysis to determine the potential economic impact of the combined
 incremental soil and erosion and post-construction runoff control costs on these developments.

 There is some uncertainty surrounding the eventual impact of the post-construction runoff
 control costs.  To begin, EPA is not directly requiring small entities to adopt specific control
 measures, instead EPA is requiring MS4s to develop storm water management programs that
 address post-construction runoff controls for new developments.  This approach allows for much
 more flexibility in how localities and developers can address post construction runoff. Secondly,
 the post construction runoff control costs shown in Exhibit 8-6 are high end estimates. Many
 post-construction runoff controls can be incorporated directly into the site design for a new
 development, which often results in much lower control costs. In fact there is evidence that
 property values can actually be enhanced when controls are designed to increase the aesthetic
 value of the sites landscaping (Schueler,  1997).

                  Exhibit 8-6. Best Management Practice Costs per Construction Site
                                               ,              y
                                            Structural BMP construction costs per site
                                                        ^  V  4  4 «- <^ff^-  «, *^  &.
                                                           «  -
                                                             '
                                                   Impervious Surface Area2
                                   Site Size
                                  35%
                                                                                  85%
         1 acre
         3 acres
         5 acres
$1,206
$4,598
$8,709
 1 acre
3 acres
5 acres
7 acres
 $1,716
 $3,788
 $6,636
$10,479
 $3,157
 $7,625
 $9,319
$18,020
 $5,938
$10,037
$11,626
$40,919
  1 Post construction runoff control costs are the total control costs detailed in Appendix B-4, minus the capitalized
  operation and maintenance costs. Only the construction costs of the post construction controls were relevant to
  this analysis because the operation and maintenance costs will most likely not be borne by construction
  companies. Appendix B-4 provides a complete discussion of the post construction runoff control cost analysis.
  2 It is assumed mat 35% imperviousness is associated with mulit-family residential, and 85% with commercial.
  The 65% imperviousness is representative of multi-family with high imperviousness, commercial with low
  imperviousness, and sites with a combination of the two building types.  These impervious levels are based on a
  review of local government reports on average imperviousness by land-use (See Appendix B-4).

To conduct an analysis for multi-family residential developments, EPA performed a sales test,
similar to the one for single-family homes, for condominiums and apartments. The first step was
to determine the average number of multi-family units per start, for each site size category using
the construction start data collected from the fourteen jurisdictions mentioned previously.
Unfortunately, some of the data for multi-family developments did not report the number of units
to be built on the site.  However, because these were multi-family developments it could be
assumed that at least two units were  built on each site.  So, when the number of units was not
October 1999
                                        Final Report
                                                                      8-11
-------
                                                8.0 Revised SBREFA Analysis
                 included in the data, EPA assumed there would be two units built on the site. From this data
                 EPA was able to determine an estimate of the number of units per acre for each site size
                 category. This estimate is should be considered a lower bound estimate, since it is very likely
                 that the starts that did nqt report the number of units were building more than just two. The
                 estimated units per acre were then multiplied by_ the: acres for each site size to get the estimated
                 number of units per start, gj^jj^ g_y' snows me estimated number of units per acre and per start.
                            Exhibit 8-7. Estimated Number of Multi-Family Residencies per Start by Site Size
                i	
       UV	¥	I  ISliJI
  U	mi	"i	IS Iffiir	IK'
Site Size" (disturbed area) ,
1 Acre
3 Acres
5 Acres
7 Acres
Estimated Number of Units / Acre
9.7
18.0
6.6
7.2
Estimated Number of Units /Start
10
54
33
50
                  S:Tie lare value for the number of MFR unite for toe three-acre site size is the result of two outliers in toe
ESi!1!11';
illlij	iV	 l!,,1!! HI	ill
	El!	iisl
            For the second step, EPA used sale prices for both a condominium and a rental apartment to
        III! r|e|)reseH"^e grice of a muM-femiry residential unit.  The initial sale price for an apartment,
        t  ::.:.547}Q()(), was the estimated mean price of an apartment unit based upon the 1993 Property
        " ^* Owners, S ||ana|ers Survey	gJS Bureau of Census,' 199 J). The sale price used for a"
;;;'::, ;::;:: ,;;;;;;;:;; „ fionloinifflum, f 1 19^700, is the median sale price for a condominium reported hi the 1997 Survey
            of Market Absorption (US Bureau of Census, 1998).  Both sale prices were adjusted to 1998
          '""Collars using a 4.6% annual inflation rate based on the average sale price of a single-family home
            .|,™-^ j^,-- ^^,j ™^ ~g g^g^ of Census, 1999).  These sale prices were multiplied by the
"'" •	" '•: ""  """" "'estiinatejl number of units per start to determine the ^estimated sales per site size for both
           londo^
                      'I'iSifKl!'!^ ''JftsJ'" "' '  l|11 • "ll "            i    i mi mi  i i         1  i   i  i        i  i  i  i  i
                      I	show^theies^ting sales per site, along with the ratio of compliance cost to sales for
               i site size. These percentages range from 6.17% to 0.91 % and they are based on a very
               ijijl < ,{||]|^ IIIIIII	Kill llimiH	K,	:.-	•"	  °	-i-	5	:	 I... l ,	.- :	'	:.<	•. /	M.	J	: •, 		i.		 •	 J .,	
               jeWktiye estimate of fienumber units per site. These results suggest that under these
            assumptions, the compliance costs will not exceed 1% of sales for a construction business that
            builds  and sells a typical apartment or condominium development.
               '"',.!, 'i  	p'"!i::!i i
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                                                                                                   ',1ml!	ii, vi,1 ,| Mini	
                8-12
                                                   Final Report
                                                                                     October 1999
-------
                               8.0 Revised SBREFA Analysis
         Exhibit 8-8. Estimated Multi-Family Residential Sales and Compliance Costs by Site Size
'Site Size \t
(disturbed _
area)
1 Acre
3 Acres
5 Acres
7 Acres
» % ~ t f
Compliance
\JCpsS ^
, per Site1 -
$4,579
$11,242
$17,623
$14,249
Estimated
* Number of {
Units per
Site
10
54
33
50
1998 Median Price "
— Condominium ($125,209)
"Estimated
'Sales per site
$1,252,090
$6,761,286
$4,131,897
$6,260,450
Compl. Cost
as % of Sales
0.37%
0.17%
0.43%
0.23%
1998 Mean Apartment Price ..
- ^l($58,496)
Estimated
Sales per site
$584,960
$3,158,784
$1,930,368
$2,924,800
Compl. Cost as
%s of Sales"-
0.78%
0.36%
0.91%
0.49%
   * iiv i.wiui wijupucuivv VITOL xvi ui& i, j, oiiu j-auic sues uiuiuucb uic sun crusiuiis cuiuroi cosis anu ulc pOST-
  construction runoff control costs, while total compliance costs for the 7-acre sites include only post-construction runoff
  control costs (See Exhibit 8-6).

 The analysis for commercial developments differed slightly from those conducted for single-
 family and multi-family developments. To estimate the sales price of commercial buildings,
 EPA multiplied the 1998 mean price for a square foot of commercial office space, which is
 $145sq/ft (FDIC, 1999) by estimates of building size. To estimate the amount of office space per
 site, EPA used a floor area ratio (FAR) to estimate the amount of impervious surface devoted to
 floor area for a typical site. For commercial  sites, typical floor area ratios will range from 0.25 to
 0.5 (see Appendix B-2).  Floor area is assumed to be a reasonable estimate of office space, even
 though it does not account for non-office area, since the most conservative FAR value was used.
 Also since the sale price of a commercial office site can be assumed to be based primarily on the
 amount of available office space, developers have an incentive to mirumize the amount of non-
 office  space within a building.

 To calculate the square footage of floor area for each site category the FAR value of 0.25 was
 first multiplied by the estimated impervious surface coverage value of 65% (see Appendix B-2),
 then by the number of square feet per acre, and then by the number of acres hi each site size
 category. Finally, to determine the sale price for a start hi each site size category the mean price
 of a square foot of office by the square footage of floor area in each category.
     0.25(FAR)*65%(imp.surf.)*43,560(sq/ft)*site size*$145= Estimated Sale Price of Start
Exhibit 8-9 reports both the estimated sale price of office space per site, and the ratio of
compliance cost to sales price. These percentages range from 0.38% to 0.47%, and this suggests
that based upon current assumptions, the compliance costs will not exceed 1% of sales.
Therefore, it is assumed that a construction business that builds and sells a typical commercial
office development will not incur compliance costs greater than 1% of sales.
October 1999
                                       Final Report
8-13
-------

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                                                                              SS
                                                   8.   Revised SBREFA Analysis
                                                                                                             '•, i11';,1 '";il,ii
                                                                                                            nn Jllllllliiilllllli'i'iiliilllliilllllllill I '"i'l|i
-------
                                8.0  Revised SBREFA Analysis
  the percentage of homes sold that were newly built was 21.6% (Chicago Title Corporation
  1999). Of newly built homes only 12% are estimated to be in developments affected by Phase II
  Storm Water Rule (see Appendix B-3).  So only 2.6% of all homes sold are likely to incur the
  cost increase.

  8.2    Environmental Justice

  Executive Order 12898 established a presidential policy for incorporating environmental justice
  into.Federal agency missions by directing agencies to identify and address, as appropriate
  disproportionately high and adverse human health or environmental effects of its programs
  policies, and activities on minority populations and low-income populations. For example 'to
  assist in identifying the need for ensuring protection of populations who principally rely on fish
  or wildlife for subsistence, the EO directs agencies, whenever practicable and appropriate, to
  collect, maintain, and analyze information on the consumption patterns of those populations and
  to communicate to the public the risks of those consumption patterns.

  As described in the above sections, the Phase II proposed rule addresses construction sites and
  municipal storm water sewer systems that have not been covered under Phase I. In addition, the
  CZARA addresses nonpoint sources (e.g., storm water runoff) located in the coastal zone
  Finally, smaller communities outside of the coastal zone that may not be covered by either the
  Phase I or Phase II rules can be addressed by nonpoint source programs under the CWA
  Therefore, with the promulgation of the Phase II rule, EPA's regulation of storm water runoff
  should be fairly comprehensive.

 Environmental justice concerns for the regulation of storm water discharges may lie in the level
 of control resulting from the different regulations. In comparison to the Phase I rule the Phase II
 rule has fewer requirements and offers substantial flexibility in meeting those requirements
 particularly for small entities. (The Phase II rule addresses smaller municipalities and
 construction sites compared to Phase I, and a subset of these are defined as small entities by the
 Small Business Administration as noted in Section 8.1.) Thus, to the extent that fewer
 requirements and more flexibility results in less pollutant reduction, Phase II may result in
 disproportionate environmental impacts on small communities.  However, small communities
 may not be disproportionately minority or low income.

 Evaluation of the impact of the proposed Phase II rule on minority and low income populations
 would require information on the location of these populations with respect to waters receiving
 discharges regulated under the rule. This would most likely prove difficult because:

       Upstream water quality may affect downstream populations (such that the location
       of the affected municipalities and construction sites alone is not sufficient)

       The same water body may be affected by discharges regulated under both Phase I
      and Phase II (because different size communities can be located along the
      waterbody and its tributaries).
October.
                                      Final Report
                                                                                   8-15
-------
                                                                          .......... ;n ...... P liIllRI, JlliliJiifflilii'yji1' ..... HIM
                                                   8.0  Revi
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                  requurements
                  and tribal governments as well as the private sector. Under section 202(a)(l)n of UMRA, EPA
            ^  iiMi ^^^j^ ^^raT[y p^parel'awniten statement!, including a cost-benefit analysis, for proposed and
                 ,	, ____a3cms	g^'zjjj-j^g—'—1pe3etal	'mandate'ffiat"may	result In the	-^^^^.2""^	j§tete~	
llUfwrt'cIV ' W i MiUKnugau	B	B	,	•	SB	 ,               .<   j               .   .,     .   .     ,   „  ,.	s	-\_	'»	•	'	
I                  local, and tribal governments, in the aggregate or by the private sector  of annual costs in excess
 |5Jj;^jj	;:,	'^:'^ "^i^OlOS^SE*11-1  -^-s a §eneral matter, a federal mandate includes Federal Regulations that
                  Etfm'pBsii fcrararceable duties on State, local, and tribal governments, or on the private sector
 [•—'"	:i	^"	'	i;"" -	r"	!;"pggg^	1"555)"	"gj^jjg^g	~^__^~ 1a^g0iis'^equijre""Qgjce	of^if^lgement"and Budget ^^^
I      "'"ii'fli1 '*i!1i 'i WifldEI Se preparation	of a Regulatory Impact Assessment that compares the costs and benefits of
                   the action.
                 "  i	         	:•	'M	ii;i	        	i	g	&	LiiHKiii^^	!	•«	mm^^.^^	•	iffm	^f-5i*a
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                            ; anticigated to
                            ''	'	Si"	B""ie	^mep^od^'ana^ze?!	1^^-^^ ^ Economic An^ysis(EAJ addresses:''
                          Section 202(a)(l) — authoring legislation (see EA Chapter 1 and the Preamble to
 I
   S'laiif; i iriiit
                                           — a qualitative and quantitative assessment of the anticipated
            '-'" '•'''"	'"'	'	il"il"ii'!l"!!l'i'	'''-"(Ssfi	an3""benefits of the regulation (see EA chapters 4 througjbt 7 and
                        '	iccompahying appendices)
I                  •      |eptij>n: 20,2(a)(3)(A) — accurate estimates of future compliance costs (as
  	'	: :i' '"':::ii	''  "''	
 I IIIK il.',;,!: •:  * JH
                          Section 202(a)(3)(B) — disproportionate effects on particular segments of the
                          private sector (see this chapter)
                          Section 202(a)(3)(B) — disproportionate effects on local communities (see this
                          chapter)

                          Section 205(a) — least burdensome option or explanation required (see the
                          Preamble to the rule)
                 llll'i'-ifllll1),11!": W, '  ll||l I IIIIIII  II      III 111     .        '                  I    II  II I       1       I       -          Ii
                      'The $100 million in annual costs is the same threshold that identifies a "significant regulatory action" in Executive
                 ::''6rderl2866.	'	
               	'"	8-16
                                                             Final Report
                                                                              October 1999

                                                                                         "!	":' :;	Hn ',.''	i"".;,:! ,. I .nil!,:i'S'.iJCi.'^.'+Hp,;	Itm':!:''':!!    I
                                                                                         Iliali^^^feiijy	
-------
                                8.0 Revised SBREFA Analysis
   Pursuant to UMRA section 203, before an agency establishes any regulatory requirements that
   may significantly or uniquely affect small governments, including Tribal governments it must
   have developed a small governments agency plan. The plan must provide for notifying
   potentially affected small governments, enabling officials of affected small governments to have
   meaningful and timely input in the development of regulatory proposals with significant Federal
   intergovernmental mandates, and informing, educating, an advising small governments on
   compliance with the regulatory requirements. The Preamble to the final rule summarizes the
   extent of EPA's consultation with stakeholders including industry, environmental groups, states
   local, and Tribal governments.  The Preamble and comment-response document contain '
  responses to their comments collected during the public comment period for the proposed and
  subsequent Notices of Data Availability (UMRA sections 202(a)(5) and 204).

  Pursuant to section 205(a)(l)-(2), EPA has selected the "least costly, most cost-effective or least
  burdensome alternative" consistent with the requirements of the CWA for reasons discussed in
  the Preamble to this rule. A cost comparison in the EA for the proposed rule showed that high
  costs for alternative options (except the no action option) all exceeded $3.0 billion per year
  which is substantially greater than the $803 million cost estimate provided in Chapter 4.  Under
  the CWA §402(p)(6), EPA is required to design a regulatory program to control contaminated
  discharges associated with storm water runoff. This rule addresses contaminated storm water
  discharges from sources that were not included in the Phase I rule: small municipal separate
  storm sewer systems and construction activities at small construction sites (sites disturbing
  greater than or equal to one acre and less than five acres).
October
                                       Final Report
                                                                                    8-17
-------
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                                  9.0 NO EXPOSURE

  The storm water Phase II rule includes a no exposure exclusion for Phase I regulated industrial
  facilities that have the potential to reduce the total compliance costs. "No exposure" means all
  industrial materials or activities are protected by a storm resistant shelter so that the materials are
  not exposed to rain, snow, snowmelt, or runoff. This chapter estimates the number of Phase I
  industrial facilities that may be able to qualify for the no exposure exclusion and the net cost
  savings that will result. Section 9.1 provides background and an explanation of the Phase II
  rule's no exposure exclusion provision.  Section 9.2 discusses the methodology and estimates the
  cost savings from the no exposure provision for facilities currently regulated under Phase I.
  Section 9.3 estimates the compliance costs associated with the no exposure provision. Section
  9.4 summarizes the findings, Section 9.5 identifies state and federal costs and Section 9.6
  identifies data limitations and assumptions used to estimate the net cost savings of the no
  exposure provision.

  9.1    Background

 In the 1990 storm water regulations, EPA identified eleven categories of industrial activities in
 the definition of "storm water discharge associated with industrial activity"(40 CFR
  §122.26(b)(14)(I)-(xi)). See Exhibit 9-1 for a description of each category. All operators of
 industrial facilities with activities  identified in these categories are required to obtain an NPDES
 storm water permit to discharge, except those facilities that are included in the "light industry"
 category (xi). These facilities were exempt from the requirement to obtain an NPDES permit if
 their industrial materials and/or activities were not "exposed" to storm water (see 40 CFR
 §122.26(b)(14) [introductory text]). The Agency had reasoned that most of the activity at these
 types of facilities takes place indoors and that emissions from stacks, use of unhoused
 manufacturing equipment, outside material storage or disposal, and generation of large amounts
 of dust or particles would be atypical (55 FR 48008, November 16,1990).

 In 1992, the Ninth Circuit court remanded to EPA for further rulemaking, the portion of the
 definition of "storm water discharge associated with industrial activity" that excluded the light
 industry in category (xi) when industrial materials and/or activities were not exposed to storm
 water. See NRDC v. EPA, 966 F.2d 1292,1305 (9th Cir. 1992). The Ninth Circuit determined
 that the exemption was arbitrary and capricious for two reasons. First, the court found that EPA
 had not established a record to support its assumption that light industry that was not exposed to
 storm water was not "associated with industrial activity," particularly when other types of
 industry not exposed to storm water remained "associated with industrial activity." Second, the
 court concluded that the exemption impermissibly "altered the statutory scheme" for permitting
 because the exemption relied on the unverified judgement of the light industrial facility operator
 to determine non-applicability of the permit application requirements.  In other words, the court
 was critical that the operator would determine for itself that there was no exposure and then
 simply not apply for a permit without any further action.  Without a basis for ensuring the
 effective operation of the permitting scheme—either that facilities would self-report actual
 exposure or that EPA would be required to inspect and monitor such facilities—the court vacated
 and remanded the rule to EPA for further rulemaking. The Phase II rule responds to that remand.
October 1999
                                       Final Report
9-1
-------
                                                      9.0 No Exposure
 l|i i lllllli In il .....
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                  Under the Phase II rule, the Agency responds to both of the bases for the court's remand.  In
                  response to the first basis, the exemption from permitting based on uno exposure" now applies to
                  all hidgtrial categories listed in the definition of "storm water discharge associated with
                  industrial activity," except construction (category (x)) and industrial facilities individually
                  designated by the NPDES permitting authority. This assures that discharges from different types
                u'li'^ffldu^gial facilities are equally regulated based on their propensity to be contaminated.  In
                  response to the second basis for the court's remand, the permitting exclusion is "conditional."
I          , £,,
                  The operator responsible for a point source discharge from a "no exposure" industrial source
                iiii '''iJlBrjIIiriHIIllll'', A .......................... • ..... ................ \\\mm\ ................. ,' 'ft, ........... ' ..... ill ....................... ......................... ,il "i, ..... ', ....... ............ .if .......... , ............... u ........................................... ,:i ......... , ..... , ............... .................... • hi,!,;," ihi,,', ..... "" ................................ ....... .............. „„ ...... , ..................... mi, ............ i" ........ ...... , ......................... , .................... ,,' .............................. uPua§e I program that can claim a condition of no exposure, except discharges from construction
                  and[from individually designated sources.
I     	E it!
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                    prder to obtain the no exposure exclusion, the discharger of an otherwise regulated facility
jf^ri"'  ":r "v:" * iiii^!1]ip^l^E?nit a written no exposure certification that incorporates the Yes/No questions of
                  §l22.26(g)(4) of the Phase II rule to the NPDES permitting authority once every five years (see
                     |'§ jgp Exposure Certification Form in Appendix D-l). Based on recommendations of the
                     3A	Committeej	the	certification requires only a minimal amount of ffiprmation from'the	
               	.""Facility. Mlw ex£osure certificatipns must be signed in accordance with the signatory
                  requirements of"40 CFR § 122.22. The no exposure certification is non-transferable. In the event
                  that the facility operator changes, the new discharger must submit a new no exposure
                  certification.  The NPDES permitting authority is expected to maintain a simple database to
                ^'record Jflie information included in the no exposure certifications and track the facilities.
              ||.T;fi,,^dition to the written certification, the facility must allow the NPDES permitting authority or
                 operator of a municipal separate storm sewer system (where there is a storm water.discharge to
                ^•tfte municipal system) to inspect the facility and to make such inspection reports publicly
                 available upon request. Also, upon request and where applicable, the facility must submit a copy
                 of the no exposure certification to the operator of a municipal separate storm sewer system.
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                           ''Iffll.'^	ifoy1"?;'"1' "I'"1'1 Illlii1"-111*"'!1'	|fc," V'^.t.Vj^!';'•' ""I.' ?v', ':'"|! • :!"|' ••&$'''. |!|?'i	""":" "if1'
                               
-------
                                             9.0 No Exposure
      Exhibit 9-1. Industrial Facilities That Must Submit Applications for Storm Water Permits (Phase I)
    40 CFR 122.26(b)(14)
        :   Subpart
                                   Description"
             (0
  Facilities subject to storm water effluent limitations guidelines, new source
  performance standards, or toxic pollutant effluent standards under 40 CFR,
  Subchapter N [except facilities which are exempt under category (xi)].
             (ii)
 Facilities classified as:
 SIC 24 (except 2434)	Lumber and Wood Products
 SIC 26 (except 265 and 267)	Paper and Allied Products
 SIC28 (except 283 and 285)	Chemicals and Allied Products
 SIC 29 	Petroleum and Coal Products
 SIC 311  	Leather Tanning and Finishing
 SIC 32 (except 323)	Stone, Clay and Glass Products
 SIC 33 	Primary Metal Industries
 SIC 3441  	Fabricated Structural Metal
 SIC 373  	Ship and Boat Building and Repairing
            (iii)
 Facilities classified as SIC 10 through 14, including active or inactive mining
 operations and oil and gas exploration, production, processing, or treatment
 operations, or transmission facilities that discharge storm water contaminated by
 contact with, or that has come into contact with, any overburden, raw material,
 intermediate products, finished products, byproducts, or waste products located on
 the site of such operations.
 SIC 10  	MetalMining
 SIC 11  	Anthracite Mining
 SIC 12  	CoalMining
 SIC 13  	Oil and Gas Extraction
 SIC 14  	Nonmetallic Minerals, except Fuels
            (iv)
 Hazardous waste treatment, storage, or disposal facilities, including those that are
 operating under interim status or a permit under subtitle C of RCRA
            (v)
 Landfills, land application sites, and open dumps that receive or have received any
 industrial wastes (waste that is received from any of the facilities described under this
 subsection) including those that are subject to regulation under subtitle D of RCRA
            (vi)
Facilities involved hi the recycling of materials, including metal scrap yards, battery
reclaimers, salvage yards, and automobile junkyards, including but limited to those
classified as Standard Industrial Classification 5015 and 5093
           (vii)
Steam electric power generating facilities, including coal handling sites
           (viii)
Transportation facilities which have vehicle maintenance shops, equipment cleaning
operations, or airport de-icing operations. Only those portions of the facility that are
either involved in vehicle maintenance (including vehicle rehabilitation, mechanical
repairs, painting, fueling, and lubrication), equipment cleaning operations, or airport
de-icing operations, or which are otherwise listed in another category are included:
SIC 40  	Railroad Transportation
SIC 41  	Local and Suburban Transit
SIC 42 (except 4221-45)	Motor Freight and Warehousing
SIC43  	US Postal Service
SIC 44  	Water Transportation
SIC 45  	Transportation by Ah-  •
SIC 5171  	Petroleum Bulk Stations and Terminals
October 1999
                                               Final Report
                                                                           9-3
-------
                                                               9.0 No Exposure
       ••	WE'! ,  |:;|ii,lll|1
      •	1	it!!  .Ui'liiL i,i' liilF''>'«
       "')'til "1,1 liiJ ''!• .'.Hi' '
                            -Exhibit !MU Industrial Facilities That Must Submit Applications
                                     lor Storm Water Permits (Phase I) (Continued)
                                                                             IE''"1;;••'.. iiiiin	tiquwvw;	.fin	aili	:«>!'"*': i'li'it c'ati: i'":is ijiiliL ii'iist*	i..1: |
                            i ill i   in I in  ill in
 liiililililllF i'illilililil!1!.1 •illilnlllii. •(" ; .1 llllliil <::
               : iliili
•IH 1!i; ill:' iiullr j 111:;:!!' ' ir'E1'' •
     fWiii	•>	c.r-.
i           	a "'9,	
11 llll'i'SflJ'T'llillllllllllllllllllliO" HI".!!!'!!!!!!1, iii!1""*!!"  I'llBUI" i
           IN	W	I'
I       	{Mi: ,/T'ii lljli	I
          it/
I     	'(!	iiliLif:!'11.; Illiilr
                             Subpart
                               CDC)
                               (xi)
                                                                    Description
                                  Treatment works treating domestic sewage or any other sewage sludge or wastewater
                                  treatment device or system, used in the storage treatment, recycling, and reclamation
                                  of municipal or domestic sewage, including land dedicated to the disposal of sewage
                                  sludge that are located within the confines of the facility, with a design flow of 1.0
                                  MOD or more, or required to have  an approved pretreatment program under 40 CFR
                                  part 403. Not included are farm lands, domestic gardens or lands used for sludge
                                  management where sludge is beneficially reused and which are not physically
                                  located in the confines of the facility, or areas that are in compliance with section
                                  405 of the CWA.
                                  Construction activity including clearing, grading and excavation activities except:
                                  operations that result in the disturbance of less than five acres of total land area
                                  which are not part of a larger common plan of development or sale
                                  Facilities under the following SICs [which are not otherwise included in categories
                                  (iiXx)]> including only storm water discharges where material handling equipment
                                  or activities, raw materials, intermediate products, final products, waste materials,
                                  byproducts, or industrial machinery are exposed to storm water.

                                  SIC 20  	-"	Food and Kindred Products
                                  SIC 21	 Tobacco Products
                                  SIC 22  	Textile Mill Products
                                  SIC 23	Apparel and Other Textile Products
                                  SIC2434	WoodKitchenCabinets
                                  SIC 25	Furniture and Fixtures
                                  SIC 265 	i	Paperboard Containers and Boxes
                                  SIC 267 	Converted Paper and Paper Board Products
                                                                   (except containers and boxes)
                                  SIC 27  	Printing and Publishing
                                  SIC283 	Drugs
                                  SIC 285 	Paints, Varnishes, Lacquer, Enamels
                                  SIC 30  	Rubber and Miscellaneous Plastics Products
                                  SIC 31 (except 311)	Leather and Leather Products
                                  SIC 323 	Products of Purchased Glass
                                  SIC 34 (except 3441)	Fabricated Metal Products
                                  SIC 35  	Industrial Machinery and Equipment, except
                                  Electrical
                                  SIC 36  	Electronic and other Electric Equipment
                                  SIC 37 (except 373)	Transportation Equipment
                                  SIC 38  	Instruments and Related Products
                                  SIC 39  	Miscellaneous Manufacturing Industries
                                  SIC 4221  	Farm Products Warehousing and Storage
                                  SIC 4222  	Refrigerated Warehousing and Storage
                                  SIC 4225  	General Warehousing and Storage
 frwiiiim  >
                    Scarce: Federal Register, Vol. 55, No.  222, p. 48065, November 16,1990.
                                                i;1!	"•.•'WMJ	^'tii	sJM'fli*.':;4(*i	••.?•;$*	;:	;
                                                                                              JWi.ifv
.:  ;::	9-4
                                                                   Final Report
   <:!4' „' IS'1,!?1 ."i llil  . , 'Y	I""1  illlllllllli I	Ii
 I itiiiia^^^^^^^^^^^^^^                          1^     ill 11	iliili ill	1 ii ii ii iiiiiii	in i ill in i	i iiiii'iiiiiiiii iii'i i I'll - j .lUUjMiuiaiLLiiiiaiaLJJii!
October 1999

  in i nn ii i 111 inn inlllli i mi nn  >•  ^ '
 i m  nn i   n mini inn     i
-------
                                     9.0 No Exposure
  9.2   No Exposure Cost Savings

  In order to estimate the potential cost savings that may result from adoption of the no exposure
  provision it is necessary to estimate the number of currently regulated Phase I industrial facilities
  that may be eligible for the exclusion and to estimate the avoided costs. EPA's approach for
  estimating no exposure cost savings involved:

  •      Identifying the total number of establishments in the United States that have a narrative
        description or a SIC code identified in §122.26(b)(14)(I)-(ix) and (xi).

  •      Estimating the total number of establishments 'that are currently required to have a storm
        water permit.

  •      Determining the percentage, and number, of facilities for each industrial category in
        §122.26(b)(14) that have industrial activities or materials exposed to storm water.

  •      Allocating the industrial facilities in the 10 industrial categories to the 30 sectors in the
        modified multi-sector general permit for storm water discharges.

 •      Developing minimum and maximum unit compliance costs for all facilities covered by
        the multi-sector general permit (includes costs for visual monitoring, analytical
        monitoring, development and implementation of a storm water pollution prevention plan,
        submitting an NOI, notifying the local municipality, and recordkeeping).

 •      Applying the unit compliance costs for each sector to the number of facilities that may
        potentially qualify for the no exposure exclusion.

 •      Developing cost estimates for completion of the no exposure certification form.

 •      Estimating the increase hi compliance costs for category xi facilities which currently do
        nothing if they have no exposure but will be  required to certify no exposure after
        promulgation'of the no exposure provision.

 •      Obtaining net compliance cost savings for the no exposure provision by subtracting
        compliance cost increases from avoided costs.

 This section addresses only facilities that are currently regulated under the Phase I industrial
 program, including those category (xi) facilities that have industrial equipment or materials
 exposed to storm water and did not qualify for the original no exposure exemption. The
 following sections  discuss each of the steps mentioned above.
October 1999
                                       Final Report
9-5
-------
	II	
lllllllhllllllllliiNlliHi.iiiil'lil.lli: ... '1IIFI
            lit;", ninnniiiinin	nn,:117!,,!;,,,iini,,,»
                          II::!!!11]!!1!11 ,.	Hill! J'ni!,' ""Mil! 	 I1'1 .'Mil

                                            ™:,::,::. •:  :'"	'.:,	:;	"i' -, •£:. 9.0 No Exposure
                                                                                       !•!', .ii'QliilllJ'1.:,, V"1 liliilJi'ill iiii
                                                                                                                          !'!!'•i:iiviiiini!iniiliii«i:iiiiii!;!iiiii|iii|i!i;ii
     iiii'i1 '	.liLJIIIll1!:!1!	Illi! III! ,::'"! ,
   I	su'.nEllin: •' ill' i Jllllti'i 	U"
                   9.2.1   Number of Facilities Eligible for the No Exposure Provision
                                                                                                          11	."in,,	;i|ii|'  "ii:|i'i,!i,
•ill
   mm	••i  : <' * 'iisis:1.;;,!	i; nifto	& 'film. til r;i, t >:?	;:ii	it ui,sm	SA	er ..... oTflcilities or ..... inclustnaT acEvitie's "mat have ..... me ..... pbtenHal'to m eet me definition of storm
                        ^^      ..... liil'llllllllll'''' ..... Illllllltlllil!! ..... IIIUIIIIIIW^    ..... 11/1,11*1::' V^^         ..... , ........ ................ •, ....... i- ........... •• I ............................. <1 ...... II ......... ........................... "••> ................. • .................... i ......................... « ....................... ,,_, vri% >-» /-  ... .   .   t   '' '
                         '                  an industrial activity.1  There are approximately 587,099 facilities in the
                                  that meet the narrative description or have a SIC code identified in
                                            '     .....       ™ ~"  .........  ™             '             '
   'Milly 	iiUIl,
   	t!1!'', "Jilt:
           "ii	!>
            'I'llllljir
  IIIT11 III I'lllUI1' , II'1 'II.'"' ,
lljll	"	'"I"
                hi Hi'n1 Hi.'1', T	i jniiiiinnnniig''iii|iiiiiTi'ii'n«nnnnnnnnnir '''iii,	nil" /hase I industrial
.fIStaWishments thatmeetthe_	definjtionofa	§torm_ water disch^rge_	associated with an industrial
  activity within their stated These estimates assume that every facility in categories I-ix with a
.__..„   9|sch^S6 i10^ reqliire a storm water permit, and only those facilities in category xi
IP11", iijit'lli1"11!"1!'!1!!!!!!!1! ,:!lil!lllllllll!lll|i||i:!i: ^i'lllPllllllllliri'iiliiNlNi'iiiii1" Fs'iiiiJi'iii:	wwii' •« • ""ifiiiin ..1111111111111, wiiiKi i	a11	•»	'	""'"t	'	1|"11"	"•	'	•	¥li	»	si.	"nir-iy	-	«-»	-sr	'"«i	a"j""	^	;	;'• "1 	^	/»
*JS^ta exposure and discharge will require a permit.  Exhibit 9-2 indicates the potential number of
SJj&cili^S^tSin''these states that are defined by categories (I) through (ix) and (xi) hi
  §122.26(b)(14), the number of facilities estimated by the state storm water representative to have
  a Sis'cE^e"meetmg~tfie definition of a "storm water discnafg"e associated with an industrial
  actrvity,"and the percentage of all facilities that have a discharge meeting the definition of "storm
  water discharge associated with an industrial activity."


                                                                                                                , IK' , /.uiMiiF, SihlnillH"",!!1'! 	Illi!1!"""*" V W!i I
  ni: i ii	mi;: ' iFi'i  ^ 	•	Kiini1"!	-i	' "  » ."ii!!i!!,,u,,,
  :,ii;i;: '.'J'I.IHJ	lim.  |] t,,:","	', P		irih^^*	
                                        i, 	IIP: A'1.'. I1' '"t«:,!!!" a'vfl i', 	IP'ri1 :•  i,1'!.	•',	lilpil,'
                                       " ill1" fi I:.!,,'	 .a-trlllliirillF     ' ",,	i" ,''!!	Ill
                                                                              i jil!1 "Wi ..... ..... P iiniRft'l . • ...... !l,,,.,,i,',,ll,
                                                                                               ..i,1!. r:"'» 'T yl!|: ...... fl
                                                                                                                 ',, ;;;',„ JVn.fift™ SS.A
                                                                                                                 II ,',, :,'', Ifi!1""!,"!1:.,!!,!,	Ilill^Nfll^^ ,:
        I'1*1"  "• 'ft ' ' I
                               'lillnfPllllllBl'  "I'1 "U" 	 " „ ,
                                             P rnniiii,!'	llllii'inilillpi'iilii .PI ;ii
                                                                                  „ .ii'iiMi'w ii";	iii1'.  	i,!!''!;"!,1!!!'!!1!	It i i.ihiNSn.'y.'iipiiii,1	;, .t	':,:	 ,,;iiiii., "• i •• i*.,1*  •	",'3, i j.,.
               illi,
   I.. '""i: mill!1 <'!., II	Hi  , if' „;' ,  aiij •: TI Tiililil f S .I'llllll] ,,,lll! I'l'T llHI f''".., K' 1111.. 'SI":" t'' ill!11111' Hii1!' JlBilliii"1, P 111 I' ]''i:''"ilillSI! 1" T T,.:!i," '",	 'K«S HK, .,il,	'.II i:'	
                                                                         ^ro'^:-;,,/, rT-J^Ti
    D;	li'i-lii"!':	!;'  ii  llilKfi	Iii''' ,j
   llliM.llilll' 'i''1, 'liliilil'"lllil'  "  ,'  lllllli'' I1'1 'ullllli'in^
•I	BM;'JW   "3

                               i   • ' »f*s.(ii p«(/4  ii i  li f «    M : ifld'i; ii^           ^^         i. iiKiri:;.::!:! /" „	liKl-'r';: n,':" '• ^ >i: .i'li'iis i;;;:::  i  >.
                               ent of Commerce, Census Bureau. 1996. County Business Patterns: United States; Edison Electric Institute,
                                	15^' p-^,-.—^^^^.^ Hazardous Waste Report: Based on 1995 Data; and US EPA, 1995.
                   Municipal Solid Waste Fact Book. This number does not include: abandoned and inactive landfills, mine sites, and oil and gas
                   sites; vehicle maintenance activities at rail yards and the US Postal Service; and wastewater treatment facilities with a design
                   flow of Imillion gallons per day (MOD) or greater.
                      • i Inn n in i n nil nun nil i n n  mini i  in in in inn nil i ill n  n mil   i  inn i  n  inn  nil       i  in  iininnninn  inn  i in n nn linn i n  MM i  i  i         inn  i    i  nil i nil n nn n mini  inn n
                                                                                               II                          "
                    - The NPDES authorized States contacted are: Arkansas, Illinois, Michigan, New York, South Carolina, Tennessee, Virginia,
                   and West Virginia. Other states were contacted but the information was not available, therefore, they were not requested to
                   provide this information to EPA.
                             i  I   i                                                             II 	
                    9-6
                                                                  Final Report
                                                                                                               October 1999
                                                                                                                              '. n •
                                                                                                                              i
-------
                                            9.0 No Exposure
     Exhibit 9-2.  Total Facilities and Estimated Number of Regulated Industrial Facilities in Selected States
State
Arkansas
Illinois
Michigan
New York
South Carolina
Tennessee
Virginia
West Virginia
TOTAL
Total
Number of Facilities1
5,282
22,135
18,648
31,732
5,936
9,688
8,775
3,319
105,515
Estimated Number
of
Regulated Facilities2
2,500
11,000
6,000
10,000
4,500
5,780
3,200
3,000
- 45,980
; Percentage3
47%
50%
32%
32%
76%
60%
36%
90%
Weighted Average = 44%
                                              ,       .   .                      ^.     ,.\.   l  .
 source of information includes: for facilities identified with SIC codes US Department of Commerce, Census
 Bureau, 1996. County Business Patterns for 1994; for steam electric facilities Edison Electric Institute, 1995; for
 hazardous waste facilities US EPA, 1997. Preliminary Biennial RCRA Hazardous Waste Report: Based on 1995
 Data; and for landfills US EPA, 1995. Municipal Solid Waste Fact Book. Note: This number does not include:
 abandoned and inactive mine sites, landfills, and oil and gas wells; vehicle maintenance activities at rail yards and
 US Postal Service centers; and wastewater treatment facilities with a design flow of 1 MOD or greater.
 2Total number of facilities in the second column that meet the definition of "storm water discharge associated with
 industrial activity" in 40 CFR § 122.26(b)(14), because they discharge to waters of the United States, therefore, must
 obtain a NPDES storm water permit. Source: Personal communication with State Storm Water representatives on
 April 23, 1997.
 3The percentage of the total number of facilities in the second column that meet the definition of "storm water
 discharge associated with industrial activity" and must obtain an NPDES storm water permit.

 The percentage of facilities that meet the definition of storm water discharge associated with
 industrial activity ranged from a high of 90% to a low of 32% in the states contacted.  The
 weighted average is  approximately 44% for (I-ix) categories. EPA estimates the number of
 category (xi) light industrial facilities that meet the definition of "storm water discharge with
 industrial activity" to be approximately 8%.4 These figures, 44% and 8%, were used in the
 analysis.
  EPA determined the number of NOIs submitted to the NOI tracking center for facilities meeting the definition of "storm water
discharge with industrial activity" for facilities characterized as category xi facilities.  In the non-NPDES authorized states the
owners/operators of 3,701 light industrial establishments submitted NOIs to the tracking center. The Dun and Bradstreet's
FACTS database estimates that there are 65,091 light industrial establishments in the non-NPDES authorized states. The number
of NOIs compared to the total number of establishments is approximately 6%. EPA also estimates that nationwide the rate of
compliance for storm water permits is approximately two-thirds. Therefore, when taking into consideration noncompliance,
EPA estimates the percentage of light industrial establishments that require storm water permits to be approximately 8% of the
total number of establishments.
October 1999
                                              Final Report
9-7
-------
                                                                                                     on>".	LI"	ill1, nun' TTlinn
                            ....... "OHIil  • • v HV iSW V. <:i
                                                     / ' i ........ ?: ' i 1; :«' ...... .'• 'ft ..... : .....
                                                                                                  1!'!1 nil- Mviwtt lilDiOT^  -!llliilC •	' ,<*'"ili .1,;,; wi	sj	tew         •ill ttfdfini t",, I'liii'i '!::i !* s;n imjEtito^    	iiiiBiii'iirii1! 'ill I
                                   facilities conducts different activities and follows different
                   materials use and storage practices, the level of exposure of these activities and materials will
                   varjr Exhibit 9-3 provides an estimate of the number of facilities with and without exposure for
                  "^j^i^^^Ji^e^o^^jSibit 9-3 mdicates that approximately 76,438 of the 152,677
                   facilities, M the United States that meet the regulatory definition of "storm water discharge
                   associated with industrial activity" have exposure and, therefore, must obtain a Phase I storm
                   permit Exhibit 9-3 also indicates that approximately 76,239 facilities that meet the regulatory
                   definition of "storm water discharge associated with industrial activity" may have no exposure
                   conditions at their site and will be eligible to take advantage of the no exposure provision.
       nilpi linni": ihinvi In i1'
  If'Hflt' 'MM;  i'
liw^^^^^^^^^^^
       IP  ,": '!
       ii!:;"1 • '	h1.:
                  " 933,  Industrial Compliance Cost Savings

                   ^       facilities currently regulated under the Phase I storm water program are required to
                   obtain permit coverage.  Under the permit, they are required to develop and implement a storm
                  t^Sel pollution prevention plan and conduct visual and analytical monitoring of their storm water
                    '           The no exposure provision provides a potential cost saving to those facilities that can
                              a condition of no exposure exists at their facility because they will no longer be
                              "^	—	annual"cost savings	for"ari"jj	
                          was estimated to | be eqiiivalent to the iannual|	comDliance cost for an mdustnal
meeting the conditions of the multi-sector general permit.  EPA estimates that very few industrial
facilities have applied and received an individual storm water permit and, therefore, estimated the
CoWsavings based on the compliance costs for the multi-sector general permit.5
       illllll  iillll  IliiilII Hi    i  I  i Id     II    ill    i  iii i   11   i'i l    I'll (ill i  i
       Water Pollution Prevention Plan Costs
 iLlllllllllilil	IIIH	iMillhiil'lllIli'il
I          iiliilLnlili	
Ifft'WrinM	'	'""«	Si
I       	ii:jiii/:,<	A;"
 111	I	
             [™ ^.HSgh and low cost estimates for development of the multi-sector general permit storm water
           , ,;!j jp^^^^^g^g^ pi^	were pOTihed' oh	SeptemBer 29j' 1995 (60 FR 51108);	The cost	
                  estimates have been gj|iate^ to  1998 dollars using the Consumer Price Index and are shown in
                  Exhibits 9-4 and 9—5. Exhibit 9-4 presents the estimated per facility start up, annual, and total
                               industrial compliance costs for development, implementation, and maintenance of
                    e storm water pofluSonlvevention plan,  gj^blt: 9-5 indicates 'the 'additional costs that
                    Illilllllllllllllllllllllllllllllllllllli I'lllllllllllllllinillliivi!, I'linillP'''!!!^!	n	r-	i,	,	,	„ „„	n	
                  Emergency Planning and Community Right-to-Know (EPCRA) facilities would incur.6
              • i in     i p  'jifim	iiiiii^       " "El	ini::1:!!!	iiiy1:!'1;'' ;;:'i ^ ;mi	niitiTig, :„> ii ,n	f!	;> iu, '"•;• v:< > if	ii,	iiriaw^     'jiiin • "> Mniiakiiiil'1')'. '^ • iiii'f-i	i':1"1' 'iiiiiiii: iiiiiii'li ^ 'K'ln IB! in	iiiliaiiB^^^   "itpii	i": 'iif I
                  The multi-sector general permit requires permittees to conduct a number of activities during the
              "'" """""l" 'start-up	^ea5-sll0'f|{Je —g^j permj| m"a{ aj-g not required hi years four and five of the first permit
                  and all years hi subsequent permits. Activities such as plan preparation and start-up costs are not
                  imposed hi years four and five,  and subsequent terms, because the annual pollution prevention
                  activities are intended to maintain or modify the storm water pollution prevention plan as
                                                                                           11      	
                                  i                                                    i
 I  '  11 ii    ii ii pi  iVft"f mulSiSF^tS"i ^en^,,Se,S!,,^^,,<:h.ose,H,a^ ,!h,e ?55£'5":"^!KJ>.^1"S5^?A-^9£S.22J Els?, ,0,^ 1^"i5?u!Pl *e, !>as,e:!!n,e, iH!E^!
 I' I1 ' 11 ii Illilli  fill Illllll I permit for industrial facilities* The" mififi-s'e'ctor^enen'r^^                                       es^llsEnents'	
                  that were ggf previously included in the multi-sector general permit

                  TThe multi-sector general permit has additional conditions for EPCRA facilities.  For this reason, Exhibit 9-5 indicates the
                  compliance costs only applicable to EPCRA facilities, however, these costs are in addition to those indicated in Exhibit 9-4.
                  9-8
                                                           Final Report
                                                                                   October 1999
-------
                                              9.0  No Exposure
                       Exhibit 9-3. Estimated Number of Regulated Industrial Facilities
                                          With and Without Exposure
Phase I
Industrial Category
(i) Effluent Guidelines
(ii) Manufacturing
(iii) Mining5
(iv) Hazardous Waste
Treatment and
Storage
(i) Landfills5
(vi) Automobile and
Scrap Recyclers
(vii) Steam Electric
(viii) Vehicle Maintenance6
(ix) Wastewater
Treatment Facilities
(xi) Light Industrial7
TOTAL
Total
.Number of
Facilities in
the US1
NA4
78,757
27,166
1,787
3,581
16,171
993
165,182
NA4
293,462
587,099
Number of
Facilities
Requiring a
Permit2
NA4
34,653
11,953
786
1,576
7,115
437
72,680
NA4
23,477
152,677
Percent of
Facilities
with
Exposure 3
NA4
50%
100%
30%
100%
100%
50%
20%
90%
100%

Number of
FacUities
witb
Exposure
NA4
17,327
11,953
236
1,576
7,115
218
14,536
' NA4
23,477
76,438
Percent of
Facilities
with No
Exposure 3
NA4
50%
0%
70%
0%
0%
50%
80%
10%
0%

Number ol
Facilities
with No
Exposure .
NA4
17,327
0
550
0
0
21B
58,144
NA4
0
76,239
  'US Department of Commerce, Census Bureau. 1996. County Business Patterns: United States; Edison Electric Institute,
  1995; US EPA, 1997. Preliminary Biennial RCRA Hazardous Waste Report: Based on 1995 Data; and US EPA, 1995.
  Municipal Solid Waste Fact Book. This number does not include: abandoned and inactive landfills, mine sites, and oil and
  gas sites; vehicle maintenance activities at rail yards and the US Postal Service; and wastewater treatment facilities with a
,  design flow of 1 million gallons per day (MOD) or greater.
  2 Based on 44% of total number of facilities in US. The 44% is an average obtained  from Exhibit 9-2.
  3The percentage estimates are based on best professional judgement of EPA Phase I storm water staff—Bill Swietlik, US EPA,
  Office of Water Permits Division.
  4NA = Not Available.
  5The exact number of abandoned and inactive mine sites, oil and gas sites, and landfills is unknown.
  6The exact number of vehicle maintenance activities will be greater than the number indicated because information is not
  available for the number of rail yards and US Postal Service facilities that conduct vehicle maintenance activities. Also, the
  number of manufacturing facilities that have co-located vehicle maintenance activities in unknown. Likewise, the number of
  Federal, State, and local government facilities conducting vehicle maintenance is unknown.
  'Based on data received by the NOI Tracking center, EPA determined that NOIs for light industrial facilities represented 6% of
  the total number of light industrial facilities in the non-NPDES authorized States. EPA estimates that the compliance rate for
  the storm water program is 60%. When taking into consideration the compliance rate, EPA estimates that  8% of all light
  industrial establishments require Phase I storm water permits.


 necessary.  The cost savings for an existing industrial facility are only the annual  costs, but cost
 savings for facilities that become operational after promulgation of the Phase II rule will include
 both start-up and annual costs. This analysis, however, does not attempt to  estimate the cost
 savings for new facilities.
 October 1999
Final Report
                                                                                                         9-9
-------
                                                   9,0 No Exposure
                                                                                                                !.";*,:	BP
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ual Costs
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      9-10
Final Report
October 1999
-------
                                         9.0 No Exposure
                   Exhibit 9-6. Estimated Annual Cost Savings per Facility (1998 dollars)
   'Based on annual costs in Exhibit 9-4.
   2 Based on annual costs in Exhibit 9-4 plus annual costs in Exhibit 9-5
   {i.e.: ($650 +512,043 = $12,693) and ($21,136+512,043 = $33,179) }
   3Based on first time costs divided by 5 years plus annual costs in Exhibit 9-4-
   {i.e.: (1863/5) + 650 = 1,023 and (139,067/5) + 21,136 = 48,949}
   "Based on first time costs divided by 5 years plus annual costs in Exhibit 9-5 and figure from above
   {i.e.: (63,642/5) + 12,043 +1,023 = 25,794 and (63,642/5) +12,043 + 48,949 = 73,720}
  The percent of facilities that required to meet EPCRA requirements is unknown; this analysis
  assumes that 25% of facilities qualifying for the no exposure exemption must meet EPCRA
  requirements. Based on this assumption of 25% EPCRA and 75% non-EPCRA, a weighted
  average using annual costs information from Exhibit 9-4 and Exhibit 9-5 determined the low
  and high range of estimated cost savings.7
                  Exhibit 9-7. Adjusted Annual Cost Savings per Facility (1998 dollars)
 Monitoring Costs

 The lack of required monitoring will result in a second cost savings for industrial facilities that
 qualify for the no exposure exclusion. The multi-sector general permit includes both visual and
 analytical monitoring requirements. The visual monitoring requirements must be conducted each
 quarter year by all facilities.  Analytical monitoring must be conducted during years two and four
 of the multi-sector general permit.  EPA estimates that it will take 30 minutes to collect and .
 visually inspect a storm water sample and to log the observation.  EPA also estimates that it will
 take 30 minutes to collect, via a grab sample, and package each storm water sample for shipment
 to an outside laboratory for analysis. The average hourly wage for private sector employees
 (including overhead and administrative costs) is estimated to be $44.35, in  1998 dollars.8
 Therefore, the average cost to collect and package, or visually inspect and record, a storm water
 sample is estimated to be $22.17, in 1998 dollars. The multi-sector general permit includes
 analytical monitoring of storm water samples for many of the industrial sectors and subsectors.

 7For the low estimate, 25% (650 + 12,043) + 75% (650) = 3,661.
 For the high estimate, 25% (21,136 + 12,043) + 75% (21,136) = 24,147.

 'This figure is based on the average hourly compensation for all employees in the manufacturing sector (SIC codes 20 through
39) and uicludes 50% for overhead, 67% for fringe, and 15% for inflation. The source of the number of employees is US
October 1999
                                         Final Report
9-11
-------
                                                             9.0 No Exposure
                                 p                                                          I |           i               in
                    Exhibit D-2—1 in Appendix D provides estimated unit costs for the parameters identified in the
                    monitoring section of the multi-sector general permit. Exhibit D-2-2 indicates the monitoring
                    requirements and estimated costs for each subsector in the multi-sector general permit. Since the
                            of outfalls willvary from site to site, it has been assumed that each industrial facility will
 lillF111 r"!",!' : Jljllt1?"'1 !' illiiiiii' JIIIIIU W11'1!'1,*!!	iiiiiin	Si	• ''ill	'	I1,	"'"Mi.	'	INUI	15,	', r	j^	.„ • ,• **,	.MM	'	'""• "i"	 jii	;	jf«™ y -
           	,	,,	j,	jjojlected	during the life of the five year permit is 32.

                   Notice of Intent Costs
              i iiii i in i   in iiii   ii ill   nnii i ii i  i 11 in                    n  in  n     i   i mi i
                   The operators of Phase I industrial facilities are required to submit a notice of intent (NOI) under
                   aNPDES general permit to obtain coverage of storm water discharges associated with industrial
                   activity!	In	1992 j' 'EPA "g^-j^gg 'g-~^ |^-^e—g——^---—j^™	~^Q| ^^
                   apprbximateiy $1633, in1998 Hollars.10 Since the submittal of the NOI is a one-tune expense,
                   an annual cost can be estimated by dividing the one-time cost by the life of the permit, which is
                   typically five years. Therefore, the annual cost is estimated to be approximately $3.25, in 1998
                   dollars.
            II i  III III 11 III I   I III  IIII I  IIII   III III   I    II  I  III III            II  III II
                   Costs for Notification of Municipalities

                   Under the modified multi-sector general permit, operators of industrial facilities that discharge
                   into a local municipal separate storm sewer system (MS4) are required to notify the MS4
                   operator (typically a m^cfpafity) that they are applying for a NPDES storm water permit. In
                   1992, EPA estimated the cost of municipal notification at approximately $16.25, in!998
                   dollars,1^ Notifying the local municipality is a one-time expense an annual cost can be estimated
                   by dividing the one-time cost by the life of a five-year permit. The annual cost is estimated to be
                                         in 1998 Hollars.
                                                                            i            "    i   '         '        „      ,  ,
                                         !!" ! 	!!!!l '1!1"!' !l'":1	'"	'	'' '  '"'  T "	    	'""   ' '  i'S .""".!.'..!'.' ':	!  ..'"'' •  	 l|  ''       :'!'!' 	"'.i.i	  '«	!!!'",'"":	 ' !SHS= '"I!!"",:11:1',
            ; ,;>!	'- ^f-JRecgrdkeeping Costs
 lit, ifitff\:::	 m	IT.; '	Hi	i ia:mBWi! ": iwTja; JP <	IK •iri':. !><)::!	i xa i . i	r IK, '>'': art'i ,;	> •:>;;,i	i	si!';: s	'<;,.it ;• •,» tit :i jitir:' isniH	ibs.:*:!:: •'. 'r;,,. • is*?; :v :". •££ 'i,;;:	\:,TS ':i5Sif,ss
                                                                              '   '  '' " I   '  L I I       i                 ii  '"'''   N   :
      i	i	•*	:,	nine oTjerator	oflin industrial	fac"i'l'iry""is""re'quu:e'3"to j^et-ajn alfc&ta)' plans',"reports, 'and' inspections
                                      : jpiermif for three years from the date of permit expiration.  It is estimated that
                                                                     ^ ^  ___•jj^jj^- j™ - gve ygar perm||5 or |9j5

 ,,:"™;I!;";;;;::';:'  '';; !^=l,iiliI9^§^(bi|ars	annually.12


 .ISHT'"^ * !* '!''. " "I" 'TI.?The number of samples collected during the life of the five year permit can be calculated by:
               ii	," JHiJiiiSi pfJM§]|R OF YEARS SAMPLES REQUIRED] x [NUIrfBER OF OUTFALLS] x [QUARTERS' IN A YEAR]
   IfHtr..}'!^ •! Si,]. '• fl|*^ (WBP '^B''!' iS;!;''',» i'l'l	$&. IS I; 1 • '';*'ll^^^^^^^^^^^^^^^^^^^^^^^^^    	ylrAl lllii'	i	s	if s	•	•	z	;	;	a j.	,	,v;	A	;;.;,'.-:,	.•; •?,	 A •-,	; s' •; w "< v <. ii •;	", t	.';;.»„; i	
j"!!!!=V':!::!^^^^^^^^^^^": !,!!!!='	',""' a'"S= SJ^c Cajmus Group, Incorporated. February 21,1992. Information Collection Request for the Revisions to the National
'"	'"' "m"p£Jj^miiSjschffge £j-mjnat-on §^stem: Storm Water Implementation." 'K^aiBdToFu"S"ESA*"C>fficeof Wastewatef	
                   Enforcement and Compliance.

I                  ' 'The Cadmus Group, Incorporated. February 21,1992. Information Collection Request for the Revisions to the National
I                  Pollutant Discharge Elimination System: Storm Water Implementation. Prepared for US EPA Office of Wastewater

I1 Jill i" Jllllll'lIWi!''' I'l1" • i llf .IfSftj!?.,6?^1111*^?^ *^^ ov'r- ^^,l'Ye"year multi-sector permit the industrial facility will spend five hours for recordkeeping
I \	!	i	""i	'•"'•	—• "~;l •:'	-"""• • activlties'at $43^,67" per" h'oiir. 'For tneserecord'iceeping activiS'es it will be necessary for the industrial facility" to purchase one
                   two- drawer vertical file cabinet for $208 and hanging folders for $25. The total cost over the five-year permit is approximately
 I III:!!' ,.rl<: 'qilllM^^^   Jillll'fi, IK i i iiR "Ulii'ili Sllll-liii I»H^^^^^        •' ii	.llllllill.'ill	l»]	IITW^^^^ t	''i II:!!! 1 i'" -.'. ^T111:!!!!!::}!!!	l.i:i	'"	ilillllilll!!'1. Ill" V 1 uiUSC!!' „	Ilitif ifllllW y-tOlfifi	Illil'v!1:1!1;	111! '''iljllhll1::!	!>4fi	't. S '	'llu iiltlM il:'	Ill «r i	illiliM	'ill!  . Ill	£ ::'.'	4;' I
                   p-72         ~              '•              Final Report                                 October 1999

             in. ,n ii iiiiiii jiii"!	in;	Hull in,; tiii, "i, i.: iiiiniiiiniiiiinijH iHiijiiiiiiiiini'	';;ms :n,i jiiiiiiiii jiiiiiinniaiiiiJiiinini iiijiiiiiiB:! •• .ami!! ^*:'WP sii.: uiiiiii!!1,, .< IIJIIH ' uiinii1 jiLininiiii.:1. iiiii'i'iiiKiiiiiiiiiui ;:„: j'i:' iiiiiiniiiH :i|ii!i'
-------
                                       9.0 No Exposure
  9.2.4   Total Industrial Cost Savings

  Exhibit D-2-3 in Appendix D indicates the estimated number of industrial facilities in each
  subsector (under the multi-sector general permit) that may qualify for the no exposure exemption
  and the cost savings associated with each subsector.  The per facility per subsector annual costs
  were summed over visual monitoring costs, analytical monitoring costs, submittal of NOI costs,
  municipality notification costs, recordkeeping costs and the respective low and high pollution
  prevention plan costs. This estimate is then multiplied by the number of facilities with no
  exposure in each subsector to obtain the annual low and high range cost savings for each
  subsector. It is estimated that a total of 76,239 facilities, currently regulated by the Phase I
  industrial storm water program, will qualify for the no exposure conditional exclusion.  This will
 result in an annual cost savings ranging from $318,825,521 to $1,865,642,987 in 1998 dollars.
 This range is extremely large due to the large annual cost range associated with storm water
 pollution prevention plans (per-facility annual costs range from $3,661 to $24,147), as shown hi
 Exhibit 9-7.

 9.3    No Exposure Certification Cost

 Under the Phase II rule, industrial facilities currently regulated and permitted under
 §122.26(b)(14)(I) through (ix), but have no exposure of activities or materials to storm water,
 will be eligible for the no exposure exclusion.  The operators of facilities that seek to obtain the
 no exposure exclusion must provide written certification to the NPDES permitting authority that
 no exposure conditions exist.  In addition, operators of facilities that meet the SIC code definition
 of § 122.26(b)(14)(xi), but are not currently covered by a permit because their industrial activities
 and materials are not exposed to storm water, will now need to certify that no exposure
 conditions exist at their industrial site. Therefore, to determine the net cost savings it is
 necessary to estimate the certification cost.

 Through an informal poll, it was estimated that it would take 45 minutes to complete EPA's no
 exposure certification form (see Appendix D-l).13   Similar to a permit application, the
 certification form must be re-submitted every five years.  The average hourly wage for private
 sector employees (including overhead and G&A) is estimated to be $44.35, in 1998 dollars.14
 Therefore, the average cost to complete the no  exposure certification form is estimated to be
 $33.26, in 1998 dollars.
$450, in 1997 dollars.

  An informal poll of professionals knowledgeable of the industrial activities conducted by storm water permittees and the storm
water program was conducted. The average time to complete EPA's no exposure certification form was 45 minutes.

  This figure is based on the average hourly compensation for all employees in the manufacturing sector (SIC codes 20 through
39) and includes 50% for overhead, 67% for fringe, and 15% for inflation. The source of the number of employees is US
Department of Commerce, Bureau of the Census. 1995. 1993 Annual Survey of Manufactures: Statistics for Industry Groups
and Industries, M93(AS>1. Table 2, page 1-8.
October 1999
                                         Final Report
9-13
-------
   i  iiiiii in iiiiiiiii iiiiiiiii  iiiiiii i  nil in  iiii i i in
                                 III II  II  iill	! If ii' : i' l „ I'lUliiif'' 31 :, -"' ill'1!,-'' 1' Uil» :,;1	;^ ,i: lilil'i1! >lliT' iiii<' t
                                     "ii U111,: U'	lii	II MUiil, II i,1 iiiiiii,, i'"	i	'»,1	i,  ''	I1:;;" ',i' ', Gill Jililr °i'«»
                                                                       I	Ill
                                                                                                                 I
                                                                                                                 •I I lllllllll
                                lllllllll    : lEWiilriiiil1'-1,: f. lilts -:.,'ill j, 'i11'1!."1: ",'ifli1	I"Q A XT/"»
                                     "":	ii: ii	ih j IB j",, ii, iii'i'iriiniiH iiiiiiiii ,„ i' I'll1 nil	i,;':, i vkiH 'I1111'l'i ail'' 7 . \J 1NU
 III
 111 11
 Hi	'I'M Ill
                                     ~: ~ ~	77! 777,7177 7,,"	', ', „	71	'.	11 „'.	I	ll	11	17"! 117117	„	1	11117111]111,11,'	1,7	'. 771171	,711	Ill	7771!,,	Ill
                   The number of currently permitted facilities in categories (I) throughL (ix) with no exposure is
                   estimated to be approximately 76,239.l5  The number of existing category (xi) industrial facilities
                   with no exposure that will now be required to submit a no exposu^e certification form to the
                   NPDES permitting authority is estimated to be approximately 105,646.!6 The summation of
                   these two figures results In 181,885 asmeJ total number of facilities that will complete the notice
               III1' III1 of certification.

                   The total cost to complete the no exposure certification form can be estimated by:
                                                                                         '  i'
 111111 	>l	li:i:ii ,i ii lit '' ill -:  .JillllJi	'(iiillll ili,!-!'!!'	Ml 1, iiliiiJlii,1,:1 ill	   i
                                   [LABOR COST] x pQj^gER OF FACILITIES] = TOTAL COST
              	;I:.:	;';	:„:;; ^	i;	;:::	:	i	;;;::: ~:	;	;	;	i	:	n	;,;	;;;;;	i;	ii;,;;	:::ii:;	;	;;::];',, ,;:„;	:	;.„	;;„;;: 	:;	,„,;:: :i;:;;,
                       •,-,	*,, i	•	,	„ I-., ',..•:,	,,	,;	•.	: •
           IK	»
                                                 : "=	"' "1^3126,'in1	i^ilfdo^^
                                                         wage of $44.35 for private sector employees in the
                                                         manufacturing sector to complete the no exposure
               II 111 11,1	11~ 11, II'"	\	'	1	\	II\	I	,1,1	"1[	"certification form in 45 minutes)., i

                   NUMBER OF FACILITIES =      $181,885 (Number of facilities from categories (I) through
               —v ;.•;.	:=-;-.,1=	,• -.;	=	*	|i==	=;., .••;	>—?!*'- j^~ ~f'^	',$$) &$• ,(xi) that have no exposure of their activities and
 	*	i	I-	,-	:•  ij^'il^ •;*£»"•;•»•»'.ii™	iflwll,l'?tL?:*mj£ Tut.;, < < "iiiiiii:1',	i";	JillK1 iiiliHlii „	<>l:ili;i ii:,«,!': IIKI''!!!;.!'!)!,! lijiT,!', iiyi liii,,'?: i ,,!iili:'. ill," ;,i: iji'b 	UJM :! 'iiiiiFH	iiiiifiiij.iTlIjK^^^^^ , • >',' 1 '", > Jin •:' :illiiiliiiiiilii

 iiEii'i	iiiieiM^^^^^^ >< JIT ••awUsing the above formula, the total cost to complete the no certification form is approximately
[' j[7	~71""1;	,7; 77;	j.3$,049,495. "By dividing the total cost by five (the term of the certification), the estimated annual
                                           j^gg^g^-;^^-^	$1^097899.	
                                                      [i:,1*:1!!	,:	l-ffjUW'siJ.'.'!	'.'"f '»•]!	1:»m^A'il^J1*MII'^;(,Wj;;;!	vi::: 'i-i
                                                                                                               •ill'irfS
I    	I:!:	"	lllllllll'. k;«^^^
                                      'fiB
                                                                                                                              I
I          ••••I,;:
lfEt"B(iDi| 	"
                                                           nlH'WIlT"1' ..Jli1' , 'llll'llliL'u/ili11,,!,' i;!,!1 	1',:"!	 Oriiili, '"
                                                                                   	  'illiv11 mnli M|II|"|, y	i,i,
                                                                                   .'llUllii, Ii	i'lllv	illi'iilhill",, "I'll, I	
                                                                                     ,l!|l|iliIK     	
                    AJWHUl^ „„.,	.	~~ _..^^sike exclusion is an annual net compliance cost savings ranging
            i,	Si	                	ftm	'	|,	,	••	,	'••	___	'•'	3	,	 	'	a	 r*	 ,  ,1         '1 "
                'ZlmmL^^]Uol5^2 to $1,864,433,088. Annual net compliance cost savings reflects the annual
                    cost savings for all facilities projected to qualify for the no exposure exemption less the
[                   estimated total^mi^l.costfor.all.&dlilies to complete the no exposure certification form.
              • f^ 9l5
                                  aiid ...... F gSiral ...... Costs
•"'TiJii1!1 r'nuiiiiiiiiiiiii;:" ^ininiiiii *! iin  niin	nifMi; • .i	rUiui
                                          n: yi*;,;, innnni	ii	i1;1
f^MMlB1'^	!"'• JP!^^!^?	$P	S^SS^'iS3;^^0111S P101^^3*6^ ti*e costs f°r federal and state NPDES permitting
l:-''•'"-•'•'	"'"'::  '  ""l '	'"•::;':'' l'*"1"	"'""'	"s	wlf liicreaser'	TEe NPDES permitting authorities will need to make a certification
                             	''	riS      	hi  II "ill i"  I   	'        HI      	I	II i'i (i ii II	I "	 11" illiliii iiillll	  Ill i
                    '?See Exhibit 9-3. The total includes industrial categories (I) through (ix) of 40 CFR § 122.26(b)(14).

               , iiiir'iir'wThe total number of light industrial facilities in the US is estimated to be 293,462 and the total number of light industrial
                    facilities regulated by the Phase I stbrni water regulation is estimated to be 23,477 from Exhibit 9-3. The exact number of light
                    mdSffiS fSIffies with a discharge to waters of the US is unknown. If it is assumed that 44% of all light industrial facilities
          ff,\"£ jfjt'&mc discharges to waters of the US (44% is equivalent to'the average developed in Exhibit 9-2) and 23,477 light facilities
 , rjij=;L-	yjf*£\	=*'-i?jequSre p"h'ase I industrial storm water permits because they meet the regulatory definition of § 122.26(b)(14)(xi) then the number
 1                   of category xi facilities that will need to certify no exposure conditions is approximately 105,646, that is, (293,462 x 0.44 -
-------
                                        9.0 No Exposure
 form available to the regulated community, and then record and review the no exposure
 certification forms submitted. However, since EPA has already included a certification form in
 the Phase II rule package, the cost for a NPDES permitting authority to develop a form was not
 included in this analysis.  The increased cost is based simply on significant number of industrial
 facilities that are expected to certify to no exposure.

 9.5.1   Total State Costs

 The NPDES-authorized states and territories will be responsible for implementing the no
 exposure provision. This will require the states to record and review the no exposure
 certification forms submitted by industrial facilities.  It is estimated that a total of 181,885
 industrial facilities have no exposure and will submit a no exposure certification form.
 Multiplying the ratio of NPDES-authorized states and territories (44) to the total NPDES
 jurisdictions (53) by 181,885 results in a total of 150,999 facilities possibly seeking the no
 exposure exclusion in NPDES-authorized states and territories. Exhibit 9-8 presents the cost to
 implement the no exposure provision in NPDES-authorized states and territories.  The annual
 cost is expected to be approximately $811,000.
         Exhibit 9-8. State Costs to Implement the Industrial No Exposure Provision (1998 dollars)
  Number of Establishments Certifying No Exposure1
  150,999
  State Cost to Process Each Certification Form2
                                                                      $26.87
  Total State Costs (Over 5 years)3
$4,057,343
  Total State Costs (Annual)4
 $811,469
  'The estimated number of industrial facilities (categories (I) through (ix) and (ix)) eligible forme no exposure
  exclusion was calculated by multiplying the ratio of NPDES-authorized States (44) to total NPDES jurisdictions
  (53) by 181,885, which is the estimated number of facilities eligible for the no exposure exclusion.
  2The average hourly wage for State employees was determined by the US Dept. of Labor Employment Cost
  Indexes and Levels 1975-1995; Bulletin 2466, Oct.1995. The hourly wage includes overhead expenditures and is
  in 1998 dollars.
  3Total state costs are reported over five years in this row. Five years represents the life of the certification. In
  subsequent permit cycles the costs to process the certification forms may increase because additional facilities
  will constructed (which are not included in this analysis) and other facilities will change their existing practices
  to make themselves eligible for the no exposure exclusion.
  "The annual cost was derived by dividing the Total State Costs by five. Similar to a permit, the certification form
  has a five-year term.
October 1999
                                          Final Report
                      9-15
-------
 ill
           •dinjiK'j	I'lilihW   W»!'' .'IB -'"Si	•:
           •x?	
                                             II;HI'iiii,!ii'jl"j .i,:  '	>\i,!.	n1
                                                           !f':l;S9,Oi,NpiExposure
                                                                                                                          !::'"!i	    I
                           Total Federal Costs
1IH                        J:ill&f:iBKM't!M!<:£'.W	Ill
    •|!,iill|.|;:'!'	Iilll '	I	Ill'	!":,tar, UK.:'! 'fl.!!!!*! i..t 't -, illli:» iit • ' ;•	r	Hnivt :' '.'*!	I	|i" «' .''(Kill' "I"..;: 'i ill'!1!:!!!1!*"*.!	l!li|ilrill liliilF.. 'ittKiaLi^Hft ,r .'M&R.tf'WiFfl	!l .III!1'!"'" ''itllli!!:.
               :::::;::;-, EPA will be responsible for implementing the no exposure provision in the nine non NPDES-
~L—	::;::: ~;;;: ~':.aj|Q»nzed statesjnd territories.	As	the	NPDES permitting authority in these nine areas, EPA
™'!"™:'~ ™"~_" '"!;^j[][ |^ve to record and review the no exposure certification forms submitted by industrial
           'l^'i                                                        industrial facilities have no exposure and will
                    submit a no exposure certification form.  Multiplying the ratio of non-authorized states and
                    territories (9) to the total NPDES jurisdictions (53) by 181,885 results in a total of 30,886
                    facilities, possibly seeking the no exposure exclusion hi non-authorized states and territories.
                   Jliijiibit 9-9 presents lie cost for EPA to implement the no exposure provision in non-authorized
'™ ;;*••; ^:;:»'	">:.';;"~™fsSies andterritbries'i "The annual cost is'expecteS to be approximately $175,000.
Ill li	I	lit lifl: . '';!;; S III!"!,! % • 5	If i; i	W il I III II  llllillil." WWfWM, 1 • i-iS	'" '.IWi,:,: 11 i	W'&CiWftfivV	'.	'	i <":	,	»	'.'"!«£''!	J ;- „'	«	'i si1"""	  ,.,	
                                                                                                              i'l .'.iSi;; W (*••')•*)	liillllllil ill'
                            Exhibit 9-9. Federal Costs to Implement the Industrial No Exposure Provision (1998 dollars)
ill , 111 1 1, ( > i i T i i 11, «»rt 1
i i j ' i 1 » i, ' »•»*",**,*
• i i i i « i . r, , 4 i T ,«",*•*-.
1 l 	 ii r i in i * • *
Number of Establishments Certifying No Exposure1
EPA Cost to Process Each Certification Form2
Total EPA Costs (Over 5 years)3
Total EPA Costs (Annual)4
Estimate
30,886
$28.37
$876,236
$175,247
	  'The estimated number of industrial facilities (categories (I)" tiuwi^                                                      I
'•"-'—"	::	I———11' .i—'- -" aSculat^^y n^^piyiing thTi^i(T67non NH>^r^                                              181,885,
IIIIJI'1' iljiniJI11', r | I,,]!!, fillllli	;|||	i!lhi,n|| '• in"ni1' ",'L ''' ''!>•!''I1' "iiiilPIBi.il ...'liHill'IIIIIHIIIIIIIII	\f „ 	iiiif , ::,i,	£1	inra	 »		 	 ,	,i" , ' t	" i',,	 	^ 	MI ,i>,ii,	 	H 	,	'  ,	' 111,  ii,«.  II111 I 111
 »l!;jf.:	,.*
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                    9.6 :	Data Limitations
                                                          IJil'.. ,|. '" " "'flu,''"^ I1.'1!,,:::1"!..!1:111!; ;»
\
                   There are a number of data limitations that hindered the no exposure provision analysis in this
                   chapter. These limitations include:

                fr
                               ...... IK   ......... i,
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                                                                                                                       \W- JlE-1'! .....
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                 i ........ .. ........... ~ ...... •• reliable data could not be collected.
            /.<"!i!!	Ill
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                     yKTHBiiH! ipiiii'iiiiiiiiaiii1 ...... ', ruiiiLM^inM^  ..... in,, .imii111:!1 '.iiiiiiiKiiiiiiini'n:' rpi*1; .ihViiii."!"!'!!!! "'" ' » t n » ....... |i,",n f. ......... :.< ''i,"< ...... ...n1 if • ..... "ii-1 'iiiiiiiioii1'1 ni1 "an • "«\,"m iiiJn ...... in.,} «:„ .iiniii > v.'ii >i» ..... :'!'i>,:,^, . ............................................ ^ ................................ ............... rs?
                            on both public and private lands.
                   ?  By estimating the universe of regulated facilities with data from County Business Patterns
                  "~ ; ::::'"Shereij§iii1|ie,, potential to under estimate the number of facilities, and industrial activities,
                      igjJIjQafeJijL por example, some facilities may need to meet permit requirements for more than
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                                                                , fmalJReport

                                                                 , :• „ /iii II ........ ! ..... Ililiil .:• &iiii:l, :

                                                                                                              October 1999
                                                                                                                '""  i:,:"":":"""!":, """"i: 9.'
                                                                                      ^
                                                                                                   ':ji:l;.iiJ!> "iiii,	;:ibi|.||iii!,ii. iiijijii: :•!	riii ivEiB:: iifiilii i iiiiiiiriii.:.!1:!;. "iliij I
-------
                                      9,0 No Exposure
    may have to meet permit conditions for newsprint manufacturing, vehicle maintenance,
    railroads, steam electric generation, and on-site landfills. The method used to estimate the
    number of establishments would 6nly count this as one facility in this analysis, but in reality
    this facility would have five different permit conditions reflecting each of the above industrial
    activities.

    By relying on the County Business Patterns there is the potential to over estimate the number
    of industrial establishments is some SIC codes and under estimate in others. The County
    Business Patterns records locations where commercial transactions occur not where the
    industrial activity occurs.  For example, the County Business Patterns indicates that there are
    over 100 facilities identified by SIC code 45 occurring in the District of Columbia. SIC code
    45 represents transportation by air, but in reality, the District of Columbia does not have a
    single commercial airport within its jurisdiction. Similarly, the County Business Patterns do
    not report data for the thousands of active oil and gas exploration, production, processing, or
    transmission sites. These two help indicate the difficulty in estimating the number of facilities
    regulated under the Phase I program.

    The potential number of industrial facilities requiring storm water permits may be overstated
    because there was no attempt to eliminate industrial facilities that may discharge storm water
    to combined sewers. Storm water discharges to combined sewers are exempt from storm
    water permitting requirements. The exact number of industrial facilities with storm water
    discharges to combined sewer systems is unknown.
October 1999
                                       Final Report
9-17
-------
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-------
                                10.0 REFERENCES

 Barret, M. E., J.F. Malina, and RJ. Charbeneau. 1996. Effects of Highway Construction and
        Operation on Water Quality and Quantity in an Ephemeral Stream in the Austin, Texas,
        Area.  Center for Transportation Research, The University of Texas at Austin. Report
        No.: FHWA/TX-96/1943-3.

 Barret, M.E., R.D. Zuber, E.R. Collins, J.F. Malina, RJ. Charbeneau, and G.H. Ward. 1993. A
        Review and Evaluation of Literature Pertaining to the Quantity and Control of Pollution
        From Highway Runoff and Construction. Center for Transportation Research, University
        of Texas at Austin. Report No.: 1943-1 TX-94+1943-1.

 Barringer, T.H., R.G. Reiser, and C.V. Price. 1994. Potential Effects of Development of Flow
        Characteristics of Two New Jersey Streams. Water Resources Bulletin. 30(2).

 Bander, J.W.  1993. Assessing Extension Program Impact: Case Study of a Water Quality
       Program. Journal of Natural Resources and Life Science Education. 22(2): 13 8-144.

 Bean, N.H., J.S. Goulding, C. Lao, and FJ. Angelo. 1996. Surveillance for Foodborne-disease
       Outbreaks: United States, 1988-1992. Morbidity and Mortality Weekly Report. 45(55-5).

 Bockstael, N.E., K.E. McConnell, and LE. Strand.  1989. Measuring the Benefits of
       Improvements in Water Quality, The Chesapeake Bay. Marine Resource Economics.
       6:1-18.

 Bondelid, T., AH,  G., and Van Houtven G.  The National Water  Pollution Assessment Model,
       Benefit Assessment of Storm Water Phase II Program, June 1999.

 Bondelid, T. et al. "Progress in Water Quality: A National Evaluation of Wastewater
       Infrastructure Investment, Water Quality and Economic Benefits of the Clean Water
       Act", Proceedings of WEFTEC 97, Chicago, Illinois.

 Brown, W. and D. Caraco.  1997. Controlling Stormwater Runoff Discharges from Small
       Construction Sites: A National Review. Prepared by Center for Watershed Protection for
       the U.S .EPA Office of Wastewater Management. Silver Spring, MD.

 Cameron, T.A., W.D. Shaw, and S. Ragland. 1999.  "Nonresponse Bias in Mail Survey data:
       Salience vs. Endogenous Survey Complexity." In Valuing Recreation and the
       Environment: Revealed Preference Methods in Theory and Practice. Herriges, J.A., and
       C.L. Kling (eds).  Massachusetts: Edward Elgar.
October 1999
                                      Final Report
10-1
-------
                 Carson, R.f /and' RTOSte^".'  i^~i^^w^"^m.'^i^c: The Public's Willingness to

                         Pay for Beatable',Rshablejand SwiffimaB le^j^ Water. Water Resources Research.
              |i|i  1  (ill	I111
                                   m iiijip'.!'!!, 'ii'ii'1 "wi ...... J'iii is: 'nil1 a: F < ..... 3 • iniii1:;  "': .1 '; i !l :;,> , •liii ' ..... ihiFSiiriiii ' /iivfi
                                                                                   :x r "is*, 1 1 mi ....... , s~ : i >>! • ifrt
                  Center for Disease Control and Prevention. 1994.  Morbidity and Mortality Weekly Report.
                         43(5).
       iiiiiiiiiii
        in i
                 Center for Disease Conliol and Prevention. 1998.  National Center for Infectious Diseases,
               III I  111 III II  I II I Pl IIIIII III;I 1IIIB                  'tii''1 IfVTWlSPlK'W^fWIr'.HW1!1 'Vt'<^S'lf'ift'':'t'^mWifJ> ik1"!!"'1:')	"!i| I jllif!"':,; 'Uii;:', "flRi.'IWi S!"	III.''!!!!!'1 :"'.'!!!'!.
                        Division of Vkal and Ricketsial Diseases.

                        http://www.cdc.gov/ncidod/dvrd/gastro.htm
                                                                                                            Cilll	HI!!,.'1
                                                                                       " t	
in 11
                 Center for Watershed Protection. 1998. Cost and Benefits of Storm Water BMPs. Final Report.

                        Prepared for Parsons Engineering Science.
                  Center for Watershed Protection. 1997.  Controlling Stortnwater Runoff Discharges from Small

                         Construction Sites: A National Review. Silver Spring, MD.
in ini MI i  ii IP
iii	iv
                 ChesapeakeSay"p"rogramlLiving' "Resources Subcommittee.  1991. Habitat Requirements for the
             • fijli 'I, '',,„ j1' i'"''Jlliiilli'JIIillll'jili'inijii!!'r {KiiiiiiBiiiinnnii1 i iiiinnnini1, n i "iiBt' it amiiiiii1"1" ninL1'wiiiiiiiuiiir1 ? UHIF	if»»:< '• \	<„ n' n1"1; >, *:i\	\«j	< VXK »•' 'iiiiiiiiiniiii1 wi"». • & »•»» ••  	  »	  - -	rkgroup and the Chesapeake Research Consortium, Inc.
       nil*	IE;	 . iiiiiiiiiEj11
                                         on!11959" Chicago Title Corporation's 23rd Annual Survey of Recent

                                      . hr^:/^vww.ctt.com/hbs/defauh.htm[05/13/99]
                                 i'J:	andE.	Smith.	1995/TheTahoe Landscape: A BMP Education Program.

                                                   Conservation. 5(3):272-274.
                                                                           ..... El ..... lift    ..... i ..... ii, Iiiiii ...... ^i£Kf.M ....... iiiiii ........ ii,:;, ...... 'i'' ..... '^;:ii>iii-^1vl^  .......
	     	ii: il'1" - Jl	I	i	Illllil	Iiiiii 'Bi'flli	!' JIIIIH ,: iiiillil! 'fXsmf	Kill.: I :,';: SI i. L»iJiif Ii	"'i: ',, i'l':" iiiiii!,ill	I	&	i! •  WlI	'iillli:1'':;, ill illiiill	iiiil^^^^^^^^^^^ ' fill	iiiliiiJlliilJlli' &i	!.	'<	iini II l'< ii	:;:'	(!«',	'illiiiilliil	iii', >
'itilKlf^A^Iiil	Kity of Olympia. 1994. Impervious Surface Reduction Study. Olympia, Washington.
                      	:	;	;	:	:"!	'	:|	     '  *
                        	'	'	''	;:	r;	";	r	:	:'	:	'	:'   ;	:	
                        E.H., J.A. Haverkamp, and W. Chapman.  1985. Eroding Soils: The Off-Farm Impacts.
 I ..... :ii::ii,| ...... ii-jsi! ..... pi ..... i; ,-;:«
 ,£"':•;! : ..... " ,;; ;;: ";'•' ' " ;~ ; ;:; ' :: : -';~"fle" C^nservation'F oundation, Washington, D.C.
 ii'Mii!' j:i:!iliiiiiil; ..... ii 1 1 Ji' ...... ti  III'!' ' , if ''!>^^^ r "' 'i ilK fflillB ,1 ..... lit i'" : ........ '!«:: ...... "i1 ,..<;. / i::::::icliii!i ..... >< HI ....... ^mism: .aif, ..... i, • i' ; ni> . 'i ........  ..... <' "'  i
          ijiiii " '< iii'iK	.fii'.);,
                  Code: pfjFederal j^^                     122-26-us Government Printing Office,

                                     ,	DIG.	
                                ,^-jfl^jj^ D^ stoffel, and B. Miller.  1979. Sediment and Nutrient Yield From
                                                   ^^^^^.^^^--^-—^.^^^.^ g:3Q4_308.
      ...... i!' IIHIB "i1; 'i»i ''iiiuiiii' 'aj.;,; '1;,., tjiiiii* itiiiiiii'iii "fiii;1 • ,i ..... !,-f LV
                                                   ;• ..... •'' i;"|:;,, !'"!: "if t1 ' ff •!,  •, \ a;" ;; : j ;'i ! .iji'ji a ,:!!:ij|iiiii,;i ft "_, ill1!-!!' "H.'i"
                                                                                      i iiiiiiiiiii1 ' ' nil i n>. ..... 11. r' ''"'i"'!!!!!, ....... ii. :, ,. ..... ' .'.''i ...... i ..... ii'
                                                            Final Report
                                                                                                      October 1999

-------
                                      10.0 References
  Delaware Department of Natural Resources and Environmental Control and the Brandywine
         Conservancy. 1997. Conservation Design for Storm-water Management,

  Dunne T.R. and L.B. Leopold. 1978. Water in Environmental Planning. W.H. Freeman and
         Company.

  Engineering News Record. 1999. Building Cost Index History (1915-1999).
         http://www.enr.com/cost/costbci.asp

  Ewing R. and R. Hodder. 1998, Best Development Practices: A Primer for Smart Growth.
         Smart Growth Network.

  Federal Register 63. No. 31. February 17,1998, Reissuance of NPDES\General Permits for
        Storm Water Activities.

  FDIC. 1999. Survey of Real Estate Trends, Division of Research and Statistics. Washington, DC.
        January, 1999. p.4.

  Field, R. and R.E. Pitt.  1990. Urban Storm-Induced Discharge Impacts. Water Environment and
        Technology. 3(6): 47-49.

 Freeman, A.M.  1993. The Measurement of Environmental and Resource Values: Theory and
        Methods. Washington D.C.: Resources for the Future.

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                                                                 ••• ^Jt ......... ' ii ........ '-" ..... • ..... ..... > ........... ................... ' ...... *. '' ..... ' * ' .......... « ..... '" ...... • ':» ..... ........... :
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                                                "
                                                                                   :!::. .i1 "si < "'' i »ii i'Pi< '   M i w ;i < ,• • ft • i ......... n J1"1 "J ' " niiii1,; , • tat ''it • : i i riL'r., in <„, H . :,ii"i

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                                                                                             [October 27, 1 999]
                                                                                                  ...... i; 11* ,:
                    	:	Ji:;^^^       	i
                 	;	liB     .ilJIli	!ili^^            	liii	il''i^'iW^^        	s:,;irW  	!:	i	v^,	t\
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                                                                                       T ;V i"1!"'!!!"',*1 ' "("!'! ,: 'I' i'!1': ' ':!>•:: ..... ii"!'!!1'' ..... ..... ' ' :":,S!I i ..... , ' " '
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                  JO-JO
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                                                             Final Report
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  Whittington, D., G. Cassidy, D. Amaral, E. McClelland, H. Wang, and C. Poulos. 1994. The
        Economic Value of Improving the Environmental Quality ofGalveston Bay. Prepared for
        the Galveston Bay National Estuary Program. GBNEP-3 8.

  Williams, G.P.  1978. Bank-full Discharge of Rivers. Water Resources Research. 14(6).

 Wolman G.W. and A.P. Schick. 1967. Effects of Construction on Fluvial Sediment, Urban, and
        Suburban Areas of Maryland. Water Resources Research. 3(2):451-464.

 Yorke, T.H. and W.J. Herb. 1978. Effects of Urbanization on Streamflow and Sediment
        Transport in The Rock Creek andAnacostia River Basins, Montgomery County,
        Maryland, 1962-74. U.S. Geological Survey Professional Paper 1003, Washington D.C.
October 1999
                                      Final Report
10-11
-------
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-------
              Appendix A

Literature Related to the Potential Impacts
       of Storm Water Discharges
-------
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-------
                                              Appendix A
            Exhibit A-l. Literature Related to the Potential Impacts of Storm Water Discharges
      Study
               Description
                  Results
  Jones et al.
  (1997)
 Macroinvertebrate and fish communities
 were used to assess the ability of urban
 BMPs to mitigate Storm water impacts in a
 suburban watershed.  A total of eight
 practices were assessed including wet ponds,
 dry ponds, a retrofitted culvert, and a
 riparian park.  The study area is Neabsco
 Creek in Prince William County, VA.,
 located in a rapid growing suburban
jurisdiction in the Washington D.C., metro
 area.  The area has undergone substantial
 development in the past 20 years and has
 been accompanied by the use of BMPs to
 control Storm water impacts. The reference
 site is Quantico Creek, also in Prince
 William County, whose watershed is
 occupied by a unit of the National Park
 System and the Quantico Marine Base. The
watershed is almost entirely forested.
 Alterations in the stream macroinvertebrate
 community in the suburban Neabsco
 watershed were clear at all sampling stations
 even when EPA Rapid Bioassessment
 Protocol (RBP) index values were near
 reference levels. Taxa richness was
 consistently lower in the suburban streams
 particularly in the key indicator groups:
 stoneflies, mayflies, and non-hydropsychid
 caddisflies. In general, the data suggest that
 appropriately designed and properly sited
 BMPs can provide some mitigation of Storm
 water impacts on stream communities.
 However, no BMPs were able to restore the
 full complement of macroinvertebrate families
 found in the reference watershed. The
 resulting communities reflect a fundamental
 alteration in stream biotic diversity, structure,
 and function.
  Barret et al.
  (1996)
Examined the impact of highway
construction on Danz Creek, Travis County,
TX, an intermittent stream that flows in a
natural channel and through the construction
corridor.
A review of literature shows that, in general,
changes in water quality are the result of an
increase in suspended sediments discharged
from construction sites.  The higher suspended
solids levels result in reduced diversity and
density of fauna in the affected area.  Fourteen
samples from ten storms were collected at
each of two monitoring sites. The greatest
differences between upstream and
downstream concentrations are shown by
suspended solids, turbidity, iron, and zinc.
Although accumulation of sediment in the
creek occurred during this period, by the end
of the study period the creek below the
highway had returned to preconstruction
conditions. Even though the effects on Danz
Creek were temporary, there is concern
regarding the effects of construction on the
water quality in the Edwards Limestone
aquifer. The Danz Creek lies on the recharge
zone and therefore, higher concentrations of
suspended solids could be expected to enter
the aquifer during the period when runoff
from the construction site occurred.
October 1999
                            Final Report
                                                                                                   A-3
-------
                                                                  Appendix A
                                                                                                                         I	In ill	liiliii	Hill	
                               Exhibit A-l.  Literature Related to the Potential Impacts of Storm Water Discharges
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                         Study
                     Masterson and
                     Bannerman
                     (1994)
                    Barret etal.
                    (1993)
                                      Description
                      Study to determine the impacts of Storm
                      water runoff on five urban streams in
                      Milwaukee County, Wisconsin. The authors
                      analyzed storm sewer outfall, stream water
                      quality, bottom sediment, whole crayfish
                      tissue, semipermeable polymeric membrane
                      devices (SPMDs), benthic macroinvertebrate
                      surveys and habitat.
                      A review and evaluation of literature
                      pertaining to the quantity and control of
                      pollution from highway runoff and
                      construction.
                   Results
 Study results show that the urban streams are
 not meeting their biological potential and
 recreational classifications as designated by
 theWDNR. Levels of suspended solids,
 bacteria, heavy metals, oil and grease, and
 PAHs were detected in Storm water
 discharges and stream water that exceeded
 water quality criteria.  Urban streams
 exhibited a significantly lower diversity of
 fish species and a majority of the organisms
 are pollutant tolerant species offish and
 macroinvertebrates. Benthic
 macroinvertebrate bioassessment scores
 indicated moderate to severe impairment. The
 study also found a correlation between the
 extent of urban land use  and biological
 degradation and limited recreational uses.
 Three of the five streams studied have 100 %
 urban land use and were the most degraded.
 Two of the streams have approximately a 50
 % urban and non-urban land use and
 supported a healthier population of aquatic
 organisms.  The reference site supported  the
 most abundant and diverse fish and
 invertebrate community in accordance with its
 100 % non-urban location. Furthermore, high
 PAH and heavy metal concentrations (lead, in
 particular) were found in urban whole crayfish
 tissue samples. SPMD results confirmed that
 pollutants that tend to bioaccumulate
 (lipophilic pollutants such as lead, PAH,
 pesticides, zinc) are discharging  into the
 streams.
Highway construction may cause changes in
turbidity, suspended solids concentration, and
color of receiving waters. The extent and
persistence of the changes varies from site to
site. However, turbidity and suspended solids
concentrations are much greater after
construction begins. When construction
impacts on stream quality are detected, they
are usually transitory. Prevention of erosion
during construction is important to minimize
the effects on receiving waters. Vegetative
stabilization is the most effective method for
reducing construction impacts.
           	
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-------
                                             Appendix A
            Exhibit A-l. Literature Related to the Potential Impacts of Storm Water Discharges
      Study
               Description
                  Results
  Lopes and
  Possum (1995)
The chemistry and toxicity of urban Storm
water, streamflow, and bed material in the
Phoenix, AZ area were characterized to
determine if urban Storm water could
degrade the quality of streams.  The
objectives were to characterize the chemistry
and acute toxicity of Storm water from'
drainage basins with urban and undeveloped
land use and of streamflow from the Salt
River; identify the phases of Storm water
(oil, grease, suspended solids, dissolved
trace metals, and dissolved organic
compounds) that are. causing the toxic effect;
and characterize the chemistry and acute
toxicity of bed material from drainage basins
with urban and undeveloped land use and
ephemeral streams that receive urban runoff.
First-flush samples from urban drainage
basins appeared to be more toxic than flow-
weighted composite samples, and Storm water
was more harmful to fathead minnows than to
water fleas.  The most toxic Storm water
samples were collected from the drainage
basins with residential and commercial land
use, and the toxicity probably was due to
surfactants and other constituents leached
from asphalt and resealant. Toxicity was
generally due to organic  constituents. In
urban drainage basins, bed-material samples
collected from areas where Storm water
accumulates appeared to be more toxic than
from areas where Storm water does not
accumulate.
  Campbell
  (1994)
Storm water treatment ponds in the Orlando,
FL area were studied to determine if fish that
live these ponds contained significant
concentrations of cadmium, nickel, copper,
lead, and zinc. The study examined fish
with different foraging strategies to
determine if such differences affect heavy
metal concentrations in the fish. The fish
studied included the redear sunfish, a bottom
feeder; largemouth bass, a predator at the top
of the fish food chain; and bluegill sunfish,
an omnivore. The Storm water ponds were
associated with shopping center, apartment
complex, and road construction projects'
Wading birds were observed feeding in all
selected storm water ponds. Natural lakes
and ponds that did not receive any road or
urban runoff were used as controls.
Significant concentrations of heavy metals
were observed in the fish living in Storm
water ponds, especially in the bottom-feeder,
the redear sunfish.  Redear sunfish collected
from Storm water ponds contained mean
cadmium, nickel, copper, lead, and zinc
concentrations that were significantly higher
than those from control sites. The effect on
wading birds and other wildlife that are
feeding on the fish  living in Storm water
ponds is unknown and was beyond the scope
of the study. The authors suggest that, due to
the results of the study, attracting wildlife to
these ponds be discouraged.
October 1999
                            Final Report
                                       A-5
-------
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-------
                                                Appendix A
  I	
              Exhibit A-l. Literature Related to the Potential Impacts of Storm Water Discharges
   	'Study
                Description
                   Results
   Gardner
   (1981)
 Studied the effect of turbidity on the feeding
 rates of bluegills in a laboratory setting.
  Found, under controlled circumstances, that
  turbidity significantly affected feeding rates.
  The experiment tested three levels of turbidity
  (60, 120, and 190 NTU) and found that
  feeding rates at the most turbid level declined
  by almost 50% as compared to the clearest
  level. The authors concluded that the
  reduction of feeding rates may occur in
  natural systems subject to periods of high
  concentrations of suspended sediments. The
  range of turbidity used in the study
  encompasses that found in North Carolina and
 may be typical of many southeastern US lakes
 and streams. In addition, turbidity in streams
 from watershed disturbed by construction or
 logging could exceed these levels.
   Field and Pitt
   (1990)
Two studies examined the effects of urban
runoff on aquatic organisms. One study
examined Coyote Creek in San Jose, CA, a
small stream only a few meters wide and
less than a meter deep that drains a
watershed of about 80,000 ha. Upstream
flows are quite clean and downstream urban
flows are highly variable and polluted.
Another study compared two streams in
Bellevue, WA, Kersey Creek an urban
stream, and Bear Creek, a rural stream.
 Both studies found significant impairment to
 aquatic life beneficial uses, but the possible
 causes were quite different. In Coyote Creek,
 impairment was attributed to major
 accumulation of toxic sediments. Kersey
 Creek suffered from increased flows, altered
 channel morphology and food availability,
 low DO concentrations, and various organic
 and metallic priority pollutants.  The studies
 reveal that the effects of storm-induced
 discharges on aquatic, receiving-water
 organisms and other beneficial water uses is
 site-specific.  Previous attempts to identify
 urban storm runoff problems using available
 data have not been conclusive because of
 differences in sampling procedures and the
 practice of pooling data from various sites.
 The long-term aquatic effects of urban runoff
 are probably more important than short-tenn
 effects associated with specific events.
 Further, long-term effects may only be
 expressed at great distances downstream from
discharge location,  or in accumulating areas
(such as lakes).
October 1999
                                              Final Report
                                                                                 A-7
-------
                                                                                   Appendix A
  i ii 11 nil n i iiii i   PI i i  iiiiiiii in
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                                        Exhibit A-l. Literature Related to the Potential Impacts of Storm Water Discharges
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            1   ! ...... i:i !i  jill' '
WE!	ilk	I!'	•fir'ftffii-;
                               Stndy
                           Steinman and
                           Mclntire
                           (1990)
                                                                  Description
                                              Describes the responses of periphyton
                                              communities to disturbances that change
                                              local environmental conditions and
                                              biological properties of the system in
                                              question. The disturbances examined in the
                                              paper are floods, desiccation, organic
                                              nutrient enrichment, and toxic pollutants'.
                                                                                                                 -'  '  *   Results
                                                                                                    A survey of the literature reveals that
                                                                                                    periphyton recovery patterns can be
                                                                                                    influenced strongly by site and disturbance
                                                                                                    type. For example, local environmental
                                                                                                    conditions, such as nutrient concentration,
                                                                                                    light level, grazing pressure, substrate size and
                                                                                                    composition, propagule abundance and
                                                                                                    source, sediment load, and stream order,
                                                                                                    grade, and channel geomorphology all can
                                                                                                    affect the recovery rates of periphyton.  In
                                                                                                    addition, periphyton communities appear to
                                                                                                    take longer to recover from exposure to toxic
                                                                                                    metals than other disturbance types, perhaps
                                                                                                    because these metal remain in the system a
                                                                                                    relatively long time.  Periphyton communities
                                                                                                    are crucial to stream ecosystem recovery
                                                                                                    because they serve as an important food
                                                                                                    resource for many invertebrates.  Hence, if
                                                                                                    periphyton recovery is slow following a
                                                                                                    disturbance, other biological  components in
                                                                                                    streams also may be slow to recover.
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-------
                     Appendix B

         Data and Methods Associated with the
Municipal, Construction, arid Post-Construction Programs
   Appendix B-l    Narrative Explanations of Evaluated
                   Costs and Municipal Cost Data

   Appendix B-2    Revised Construction Start Methodology

   Appendix B-3    Model Construction Site Plans

   Appendix B-4    Post-Construction Runoff Control Analysis

   Appendix B-5    Federal and State Administrative Costs
-------

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-------
               Appendix B-l

Municipal Cost Questions and Results from the
   NAFSMA Storm Water Phase II Survey
-------
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            Exhibit B-la
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-------
                                                         Appendix B
                                  National Association of Hood and Stormwater Management Agencies
                                  1299 PcnmjrlvaD.:.AveNW. Eighth Floor West uWashbglon. DC 20004 
-------
      II 111

                                                                                              Appendix B
                                                                    "industrial" "'facilities,  such  as vehicle maintenance operations, transportation facilities
                                                                                        , light rail, commuter van pools, etc).?  Y  N
                                                    *   If no. do you have an estimate of the cost to prepare such information? $_
                                                    *   Do you have a program to detect and address illicit discharges, including illegal dumping, to your
                                                  	,	- storm water system?  Y  N

                                                  ::",*   If y65' wt»t >s the approximate annual cost of this program? S
                                                                                                                        >n activities involvi
                      !!!!!!!!!!!»^^^^  „'	 lav.fiiiW 4.      Do vou have an erosion/sediment control program for construction activities involving one or more acres?
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                     V^	=!*!	'"'"*!!	^'i1'1!1	s^*1'1 I'SSiF^^ g'p you regulate or impose sediment control requirements on construction activities, management of
                                                        construction waste (including human) and debris at construction sites? Y  N
                                                          j=____^^,,,_^,__,,__^.^^^i^ otner regulatory mechanismjhai requires the control of erosion and sediment to
                                                 I  the maximum extent practicable and allowable under State orTriballaw. The program must control other waste at the
                                                       nfuctlon site that may adversely impact water quality, such as discarded building materials, concrete truck washout and
                                                       Cy'iISE	TKeprograninaisl include, at a minimum, requirements for construction site owners or operators to implement
                        !,;^^
                                                      •eipt and consideration of information submitted by the public, regular inspections during construction, and penalties to insure
                                                n	cornpttance.^ ,   i         i            ,        	                      .
                                                        If yes, what is the approximate annual cost of this program? S_
',:;—;: ..... "™ :^;:::,— ;, , ;,::: ...... —- •:— •; ..... :: ..... ; ::—;:;::; ..... — 5.
                               "
,     .....      ,   , , ,  ......                   .....    .      Do you have a program to permanently address storm water runoff from new development and
jiiiliraiiir     :ii|: ii ..... x liiiiii • '-ii ........ "                   'redevelopment projects that result in land disturbance of one or more acres?  Y  N
**' ;" 'liliiSi1 '•' .ii 55! . . " ii,"!!-, illllllS^^^^^^^^^^^^^^^  !'!' -I ..... ~A~.R 1 .ii!^   :f: SSSfffJate": " S!K)I op ^j— jjj-j^— ^ggjjj.1,, pjj,, to implement site-appropriate and cost-effective structural and non-s
.......... " ............. .......... ................. ! .............. ............. • ................................. ........ ' " ..... '• ' ................. ........ ............. !'!"!"! ...............  ................. ' ..... ' ' 'nS/BSn&S&ff&fl&lu-eitBMP's). and ensure adeauate lone-term operation and maintenance of such BMP 's. Tht
                                                   management practices \omr a, and ensure adequate long-term operation and maintenance of such BMP's. The program must
 iiK^^^^^^^                                                                                                                        Examples of non-structural BMP's include
                     :	i"1	':-;	: " •—•'' "	• i	;	-"""'	i	" 'foSSamS'^^^aesthat result In protection of natural resources and prevention of runoff, such as growth limits, protection of
                                                   wetlands and riparian areas, minimizing impervious areas, maintaining open space, and minimizing disturbance of soils and
                                                   yeieuBiSi: Examples of structural BMP's include detention ponds, filtration practices such as grassed swales and sand fillers.
                                                   and infiltration practices such as porous pavement.
                                                   " *   If yes, what is the approximate annual cost of this program? $_
                                                    Do you have a program to prevent or reduce pollutant runoff from municipal operations?   Y   N

                                                   	''fioi™'llucXfpi5gminSisFRcS&Ti&
                                                   '-government operations, such as park and open space maintenance, fleet maintenance, transportationfaciliiies, planning, building
                                                    oversight, and storm water system maintenance.
                                                        If yes, what is'the approximate annuarcbit of this program? $_
                                                    Are"youi aware "that 'by August 7.2001 municipalities less than 100.000 population thai own or operate an
                                                   1 "industrial facility are required to submit a NPDES permit application for storm water
           •il/'llli'11  'IP Jill .ill! 'i
                                                    discharges? Y N
                                                    Note:  Municipalities less than 100,000 were exempted by a provision in 1STEA in 1991 from having to prnr.it facilities they own
                                                    or operate with "storm water discharges associated with industrial activity" except for airports, power plants, and uncontrolled
                                                   i jg^jjjjy{andfills. Regulations effective August 7,1995 extended this exemption for six years. "Industrial" facilities that a small
                                                   |:: "imoiicipaiity might own or operate that are exempted until 8/7/2001 include:  vehicle maintenance shops, asphalt and concrete
                                                   i • "Kuejji plants, sand and gravel mines, municipal solid waste landfills or transfer stations, hazardous waste landfills and land-
                                                   ,,, 'g^l^jv^sites, hazardous-waste recycling facilities, municipal wastewater treatment plants over I MCD, and municipal
                                                    coniiruct'umsites::_(including new rood projects) over 5 acres.

                                                   „ y	^re\ouawue"tfiat if "You own" oYbperatean airport, power plant, or uncontrolled sanitary landfill, you
                                                               equired to submit a storm water permit apllication by October 1, 1994? Y  N
                                                    Note: Uncontrolled sanitary landfills are active or closed landfills or open dumps that do not meet the runoff control requirements
                                                   for solid waste facilities defined inRCRA.

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                                                                                                                                                                               iKiSiiir;1111
                                                                                                                                                                                           I
-------
                                                         Appendix B
             8.



             9.

             10.
             11.
        What is  the  area served by your storm  water system,  measured  in  square miles?  	
        square miles

        *  What is the area of your jurisdiction, if different from above?	square miles

        What is the population of your jurisdiction?	

        Is there an adjoining or overlapping city or county that already has a stormwater program permitted by the
        State or EPA that may agree to:

               a)  operate a joint stormwater program for both your cities;
               b)  operate selected parts of the program jointly for both your cities;
               c)  provide you with assistance in developing and implementing your program:
               d)  talk to you about the program;
               e)  none of the above;
               f) don't know;

        What portions of the storm water sewer system in your jurisdiction do you currently regulate, maintain, and
        replace when obsolete? (Check all that apply)
             Portion of System

             Jurisdiction owned properties

             Jurisdiction maintained
             streets/roadways

             Adopted easements on
             private property

             All streams, ditches and
             storm drains that...
                                 Regulate
                                                      Maintain
                                                                              Replace
                           (check statement below that matches your defintion of storm drain)

	serve more than one property                     	have a drainage of	acres
	contain runoff from a public street or property      	other	
             12.
              A.
              B.
              C.
              D.
              E.
              F.
                    How are your current storm water system operations, maintenance, repair, rehabilitation, and replacement
                    activities funded? (Circle all letters that apply)
       Your city's/agency's general revenues
       A separate storm water system fee or tax
       A combined water utility fee or tax
       A dedicated street maintenance revenue
       A regional storm water management agency
       Other	
. percent
. percent
. percent
. percent
. percent
. percent
            13.     How do you expect to pay for this new program? (Circle all letters that apply)

             G.    Your city' s/agency:s general revenues
             H.    A separate storm water system fee or tax
             I.     A combined water utility fee or tax
             J.     A dedicated street maintenance revenue
             K.    A regional storm water management agency
             L.     Other	
                                                        . percent
                                                        . percent
                                                        . percent
                                                        . percent
                                                        . percent
                                                        . percent
                                                              -3-
October 1999
                                                       Final Report
                                                                                                           B-9
-------
                                                                                                Appendix B
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                             ' ..................... [ .................... • ......... 14. ............... How ....... do you ...... expect to  prepare ...... the ^required permit application when the time comes?

                                             A.   :   Existing staff
          ......      .....            ,,,           .................... ,              ,
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   S:S=	JS*	'i*	'V	fS	B-10
                                                    Final Report
October 1999
                                                                                                                                                                           :,•	~~	
                                          .      ,
-------
                                        Appendix B
 NAFSMA assigned an ID number to each city and county that responded to their survey. Of the
 121 respondents, 56 were able to provide cost information about their storm water programs.
 Exhibit B-lb presents the cost information reported by the 56 respondents.
                  Exhibit B-lb. NAFSMA Raw Data Used in the Economic Analysis
                                    Annual Costs Reported
* •***:?
1 A-,^
* ,V W
*EW£

1
2
4
5
6
8
11
13
14
15
20
22
25
27
28
31
33
35
36
37
40
41
44
46
47
50
52
55
56
58
60
63
64
65
V \ ' ^
Question 1*1,
Public Ed/
~ Outreach ~
-' *!$) ~






27,500
600

2,000
30,000



2,000

3,000

3,000





400
50,000
114,000

1,000
10,000
1,000
200



>, - «
"-Questions ^
- , BliciT 7"
' Discharges ^
v ~ <$> . r

5,000




50,000


2,000

5,000

100,000

100,000

30,000



35,000







6,000

10,000
5,000
75,000

v _B ^
Question 4
Erosion/Sed
Ctfntrof"
($)'f-f


40,000
30,000

5,000
35,000




5,000


4,000

10,000
20,000
40,000
1,040


5,000
10,000
500
7,000

75,000



15,000
2,000


A -^ %
•*
•>*Question*"5
'• 4
Development
* ($) - -


40,000
30,000

5,000
20,000

25,000


5,000
100,000
100,000
5,000

7,500
10,000
50,000

40,000
10,000
5,000
10,000
1,200
3,000

75,000


5,000
5,000

•

* < "•
«K " S-.
Question 6
^Muni T
- V .^M:
Runoff
""($)„" ""




2,000

15,000




2,500


2,000










7,000

500,000



5,000
3,500
10,000
300,000
? ~* <,
'A-w f^ •« ^
" » Questions* /
b. PopSilation^^ *
— -*^(S)

4,900
40,000
30,000
45,000
12,500
23,500
4,406
23,500
150,000
30,000
10,000
15,000
50,600
3,300
100,000
88,000
37,000
13,000
23,000
65,000
45,000
29,800
72,000
15,396
120,000
50,000
25,000
33,000
68,000
100,000
35,000
4,200
33,000
90,000
October 1999
                                       Final Report
B-ll
-------
                                                                                                                Appendix B
                                                                    Exhibit B-lb.  NAFSMA Raw Data Used in the Economic Analysis
                                                                                                        Annual Costs Reported
ill:: 	 i'i'ii/i'it 	 :-''•
iiiiiiiiii iiiiiiiiiii i n iiiiii 111 1 in
11 	 I'lHa^^^^^ 	 '.in, iiiiiib
••III1 "[' lli'l !' '''Illlli'lllf ''I1 i'!'1!' Ill '"'I liiii •••I' ' i "''I1
IIIIIIU 	 Jllii«^ "4 	 •til JB
ijinipiii'i'^^^^ '.'iiiMKii 	 iiiiiiiinii'iiiiin
•MiiflKjKflHTiittiii im^i
••111 ii'llii'iilllil'IM^ i| ' 'lllllllllllli! Jim
	 	

iHpi'iKfi''"'.!!'!!!1 'li' 'i Wl'l'liil
HilSil, 	 ill 1i^^
iBl]WKiUr'H*iJHH
iiii''!''"!'!!' U .Milii IP' '"iii i'1'1 1 i I liii

••i i1!,:! 	 I''! 	 mif'\'fi 	 ; iiiiiiiiii"!'
1I9 i"1'!!',,:!'1'" iiiilllii
	 ,»" 	 ' 	 ii' 	 'i' 	 	 ' 	 in 	 ' i" 	 ' 	

i, H| ' , !,, ' ,,,,„,, '"",i, 	 : , Ir '!,,',
i i i i i
t
I i "i ' '
.'I'lIDf
66
67
71
76
77
79
80
99
106
108
109
113
122
123
133
136
137
138
139
141
144
147
%Resp:
f t , -t
Question!
Public Ed/
Outreach
(S)



18,700
5,350



3,650


5,000

2,000
6,100
152,000




40

18%
Question 3 -
Illicit.
Discharges
($)



30,000



1,000
4,000

2,000
500


25,000
15,000






16%
Question 4
Erosion/Sed
Control
($)


1,000 .
45,000
1,000
75,000
9,000
15,000
7,000

10,000
2,000
3,000
25,000
5,000
15,000
30,000
5,000

35,000
10,000
8,000
29%
Question 5
Development
($)
30,000
150,000

15,000

75,000
9,000
18,000
1,000
30,000
50,000
2,500
8,000

5,000

50,000
5,000
90,000

10,000

30%
Question 6
Muni
Runoff
($)



500



1,000


5,000
500
1,000

10,000
50,000
30,000
1,000
200,000



16%

"Hi f ' "I; I11;;1|l'«i,'l™«;:;1 >\ • Sji '" , • "51 	 K. ") SI!1"™ 	 ' "" ' SWf! i' 	 iliiliiiiifiili 	 "IT! 	 I! 	 , ""I1!"!1!! ," 	 I! -'-Hli ' • .: III!! 	 :' l"l"!!'l Ilill'l!1!1!! 	 HKtfftl '! ' ' V; •! "'ll , ", 	 f. ill' ilij!",! • 	 '„ :lll. ''"II;1"1!"! ' 	 ii" II11!":1 1;,,"1!!;; ''i1 . "IE '. V 	 1, ;:';" i t1,,,1 : 1"!1!!1' •' 	 I'
- Question 9, r~
Population
80,000
118,000
5,200
167,854
27,300
78,000
19,000
16,000
14,000
65,000
99,000
17,500
26,000
43,000
105,000
250,000
84,105
1,000
43,000
85,000
100,000
12,000


iiiii'i«' 'll' ' 'ii',,ii 	 	 iiii" iiiiiiiiii 'ii'li-iiiiii iiiiiiiiii"1 '''ii'i'ili

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                                                    I'll |l' I'lhimilii'idl'li ' "if l|l|lii;l» 1: IIP11'  "" ''II '"'J'''!!!!!!1!	', SH IllillP I II  i, „, < 'II,, ,'i'  i 'I' i i' |l' i iillilnltp >l|i, '
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                                                                                                                                                                                                  H'''!:!' ..... tiiiM^^^^^        i
                                B—]2
Final Report
October 1999
-------
                                              Appendix B
                                              Exhibit B-lc.
                 Average and Percentile Costs for Five Phase II Minimum Control Measures
                                       (Per Household Costs, $1998)
^'VH>J
* " «?~ "-
* v^
*** *.
Mean Cost
Minimum
25%
50%
75%
95%
Maximum
*\ Public/ *
Education/
^Outreach -
$0.91
$0
$0.08
$0.37
$1.01
$3.04
$5.97
tf
Illicit
Discharges
$1.78
$0.03
$0.20
$0.75
$2.65
$5.61
$5.95
* f *.-p3f»
.Erosion/ _
Sediment
•**" t
Control"
$1.84
$0.09
$0.30
$1.08
$2.10
$7.92
$13.10
<~ jf
* 4 ~ -a- j f
"& «£* ff
Development '
$2.64
$0.07
$0.37
$1.24
$2.79
$10.68
$17.47
Municipal
j _ * ~, «.
Runoff1
$1.75
$0.01
$0.14
$0.52
$1.63
$9.08
$12.19
- Totals: All
Categories
$8.93
$0.19
$1.09
$3.96
$10.17
$36.34
$54.68
   Source: NAFSMA Phase II Survey Raw Data Report, 1998
   'These estimates removed the effect of one disproportionately huge "outlier" (almost 15 times the mean cost for
   all other municipalities and 4 times greater than the next highest per capita cost) in one municipality's
   (respondent number 52) estimate of its annual municipal runoff control costs.
October 1999
                                            Final Report
B-13
-------
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-------
        Appendix B—2




Construction Start Methodology
-------

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-------
                                        Appendix B
                                      Appendix B-2.
                              Construction Start Methodology

 This appendix describes the methodology used to estimate the number of construction sites
 potentially incurring incremental costs of the Phase II Storm Water rule. In determining the
 universe of construction starts, a correlation was made between the information obtained from
 the fourteen municipalities on construction starts per disturbed area and data obtained from the
 national building permits. The methodology consisted often steps. The appendix discusses each
 step in detail. Note that the exhibits referenced hi the text are presented at the end of the
 appendix.

 Step One. EPA obtained data files from the United States Bureau of the Census indicating the
 number of building permits issued by each building permit-issuing authority in the United States.
 Data files were obtained for the years 1980-1995. The Census Bureau stopped collecting
 nonresidential building permit information in 1995, which precluded the use of 1995 data in this
 analysis.

 The data files, covering 1980 to 1994, group the building permits into the following categories:

 •     Residential housekeeping buildings (single-family buildings, two-family buildings, three-
      and four-family buildings, and five or more family buildings, residential non-housekeeping
      buildings, nonresidential buildings)

      Residential non-housekeeping buildings (hotels, motels, tourist cabins, lodges, dormitories,
      rooming houses, and fraternity houses)

      Nonresidential buildings (amusement, social, and recreational buildings; churches and other
      religious buildings; industrial buildings; parking garages; service stations; hospitals; office,
      bank, and professional buildings; public works and utilities buildings; schools and other
      educational buildings; stores and customer services; jails and reformatories; and structures
      other than buildings, such as marinas, boat houses, dog pounds, boardwalks, and outdoor
      stadiums)

•     Additions, alterations, and conversions of nonresidential and non-housekeeping residential
      buildings (excluding "installation" permits issued to cover electrical, plumbing, heating,
      and air-conditioning)

•    Additions of residential garages and carports

•    Demolition and razing of buildings.

Step Two.  EPA summarized the data for building permits issued in 1994 in the 50 states, the
District of Columbia, the Virgin Islands, and Puerto Rico.

Step Three. EPA removed building permit categories with a 400 and 600 series designation.
The building permits issued for Category 400 include additions, alterations, and conversions to
October 1999
Final Report
                                                                                    B-17
-------
                                                        Appendix B
                 residential and nonresidential buildings, and additions of residential garages and carports. These
                 structures typically disturb less than 1A acre of land or involve internal renovations. Category
                 600 includes the demolition and razing of buildings, which may not disturb land. If land-
                 disturbing activities were to occur following demolition or razing, these activities should be
                 included in the storm water permit application for the new construction activity.
                                                      "          •         • .    * •'' I !••   .'•'.,
                 Step Four. EPA selected 1994 as the base year for developing construction cost estimates
             „	;	because	If	wasJEe year of most recent data on building permits issued in the United States. The
                 cost analysis, however, used 1998 as its base year and the number of construction starts was
                 escalated from 1994 to 1998 using an average annual growth rate of 1.3%, which reflects the
                     __ __     ^ permits during prior years.
          i iiiiiiiif11 jiiinngiiiiii	Hi; i
                 Step Five. EPA grouped building permits into similar types of buildings and activities. The
                 following equivalents were developed based on commonly used zoning code descriptions and the
  :	^j=^= -iijLjf i	Census Bureau's definition of building categories:
                                                                                                       	i	
,!!"

                 *     cafe 103,104, and 105 represent other "attached" homes (e.g., apartments, townhouses,
   '•'•••	-'- •"	:  •'• '"••	'	-•'	" '  condominiums);
                                                               11          I

             ::^^  codes 213,214,318,321, 322,324, 327, and 328 represent commercial establishments;

                 •     code 320 represents industrial or manufacturing facilities;

                 •     codes 319, 323,325, and 326 represent all institutional buildings (e.g., schools, hospitals,
                      churches, government buildings);

                 •     code 329 represents parks and recreational facilities.
                                                        I
                Step Six.  EPA converted building permits to storm water construction starts. A storm water
                construction start encompasses general construction activities occurring on a given site at a given
                time; it is independent of the number of building starts. For example, if a contractor builds 20
                single-family homes on a four-acre parcel of land, that contractor will require 20 separate
                todding permits.  The same development would be considered one storm water construction
             IIIIIIIIIIIIIII'IIIHIIIIIIIIIIII i llilnHP in iiiinniiiiignii ...        _	•	•	>ij
                start, assuming it is part of a common plan of development or sale. Municipalities do not
                ordinarily maintain construction records from a "storm water construction start" perspective.
                Therefore, to estimate the scope of this category, it is necessary to translate building permits into
                storm water construction starts.

                In the EA for the proposed rule, construction data collected from Prince Georges County,
                Maryland was used to translate building permits to storm water construction starts nationwide.
                For this EA, EPA has supplemented that data with data from thirteen other local government
               jurisdictions from around the country to develop new ratios to estimate the number of
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-------
                                       Appendix B
 Exhibit B-2—1 categorizes the construction type, the number of housing developments, the
 number of housing units constructed, and the number of commercial, industrial, institutional, and
 parks and recreational units constructed by size in acres. Exhibit B-2-1 also lists the number of
 units per development within the single family homes category. These data are required because
 the assumption that one building permit equals one storm water permit does not apply to single
 family homes. (The derived values based on this data are designated in the equation used in step
 seven below as SFD with the relevant subscript. For example, SFD,/3 equates to the average
 number of single-family homes built on developments disturbing between zero and Vz acre.)

 Step Seven.  EPA developed ratios to estimate the number of building permits issued by
 construction type (residential, commercial, industrial, etc.) for each size category. The size
 category is equivalent to the land area disturbed by an individual development. Exhibit B-2-2
 indicates the percentages used to estimate the type of construction by size category. For
 example, Exhibit B-2-2 gives a percentage value of 1.39% for Residential Detached home sites
 on construction sites that disturb between 0 and 1A acre.  This value was derived by dividing 252
 (the number of units built within this size category, shown in Exhibit B—2-1) by 18,134 (the total
 number of units built for all size categories of residential detached homes, also in Exhibit
 BT2-1), and multiplying the result by 100. Exhibit B-2-2 shows that approximately 86% of the
 building permits issued for single-family homes were constructed in developments disturbing
 more than five acres of land.

 The following example uses the methodology to convert the number of building permits into
 storm water permits, as outlined in Steps 6 and 7 for Alabama.

 Example:

 In 1994 the State of Alabama issued 14,459 single-family building permits, 558 multi-family
 building permits, 2,543 commercial building permits,  175 industrial building permits, 233
 institutional building permits, and 775 parks and recreation building permits. The following
 equation was used to convert these numbers to construction starts:
N4 = (SFB -SFm x SFP4) + (MFB x MFP4)
      (InstB x InstP4 ) + (P&RB x P&RP4)
                                             (CB x CP4) + (IndB xlndP4)
where

N4
SFB
SF,
  D4
SF
  P4
          Number of construction starts between four and five acres in State X
          Number of building permits reported by the Census Bureau in State X for the
          construction of single-family detached homes.
          Average number of single-family homes built on developments disturbing
          between four and five acres in the municipalities where data was collected (from
          Exhibit B-2-1).
          Percent of single-family development plans disturbing between four and five
          acres of land in the municipalities visited, as compared to the total number of
          single-family development plans reviewed in the municipalities visited (from
          Exhibit B-2-2, converted to a decimal, e.g., 4.87% = 0.0487).
October 1999
                                 Final Report
                                                                                   B-19
-------
                                                        Appendix B
  HiiiV^
                          =    Number of building permits reported by the Census Bureau in State X for
                                               dwellings.
|H     	-'MM mHt*® *	'! >*im	'' ••	iiiilii ~	J	&
'Kffjfss,t«A £& gas.* MFp4    =    Percent of multi-family dwelling plans disturbing between four and five acres of
                                Jand HLJ^^IpIffli&palities visited, as compared to the total number of multi-
.^s^,.=i[.; =;.,	:; sr^v.sj^iiis;!:^,'sE,^fjmilj;	dwelling plans reviewed in the municipalities^ visited (from Exhibit
           v^mm^'m
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                          =    Number of building permits reported by the Census Bureau in State X for
                         •;'';«                                ,.' J^'^'^ '"IZ"","'111 111	;«p,-,,n "111."'	', 111,1,. 11 11 I i 1 III i	ill 111,1,
                         p =	Percent	o^coinmerd^                   reviewed in the municipalities visited
              P^'JffiMii'lrtf-1	1M^^^^                      	a^five'a^rofla^as'comparedlo	the total	nu^g—

                	::	;;,„;	:	Exhibit B-2-2, converted to,, a decimal).             '
                JndB      —    Number of building permits reported by the Census Bureau in  State X for the
                ;:ii;i;':&=':::;::	^^"*^> '••	construction of industrial establishments.
                          =    Percent of mdustrial establishment plans reviewed in the municipalities visited
                         !tl	1—*	'""	"~J--"--•'"- -"'""-; Between	four "and "five acres	bflandV'as "compared to the total number
    	„	,	,,	,;j...,	„.	eif!!	t	W                 	Si^liMffiHt£knsr^Iiewed,^,!!!e."^Pl^!!!68,Y!5^ted.fei1
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    ll'/'ll Ji:' ^IjllJ^i'^"	=111 '""'"'Number' of building jpemiite' 're^r^biy'^e^ensias Bureau	in StateX'for' the
    : 1,!	iiiiil "|l!|!-; 1,!' titbits ml1^	lip: •'JS::, i iilonstraction of institutional establishments.
                Instp4    =     Percent of institutional construction plans reviewed in the municipalities visited
:=^^^^^      :,:::;.,::	::::::,,::;	i •. • ii: i: •==: ==..::::: •:.:: disturbhig between four and five acres of land, as compared to  the total number
                         ;:" ';;;;=/'' '•',o/.jinsti^Qn^ic^Hg^|rjucJjon plans reviewed hi the municipalities ^sited (from
in
i!;:i!ii!;^iir;i^!!!:B	:;	v-mt>a
                          =     Number of building permits reported by the Census Bureau in State X for the
r~ ;~£i:-~ f- •	;;••:;• -; -~	-:: ~^.'	::—:;::,:::,9onstruction °f parks and recreational facilities.
                 P&Kp4    =     Percent of park and recreational facility plans reviewed in the municipalities
          :"":"". ~	""".":;";	':;=^     	"ivisited disturbing between four and five acres of land, as compared to the total
         '*i'. .^."'.;..	!!l^."l™	"=~1'.	"Sufhber of plans for parks and recreational facilities reviewed hi the .
                                municipalities visited (from g^j,^ B_2—2'9 converted to a decimal).

i •;;•; *«_- -I; - •" - _";	:	~:: • ;t5s5ig' tKc	^lab'ama data gives the following resuhs:

iiiiiii	miml	;. "ii	•' ii,:'.'N4= (14,4507(884/44) x 0.0487) + (558 x 0.10843) + (2,543 x 0.0507) + (175 x 0.0515) +
                                           x 0.0722)

      	;;:;;:;:, ™	•;;:;	':'K»=35+61 + 129+9+14+56

      li.'i;;™ ii'Ili: , '"'I'' • Ik;!'1!, £V* '•
    jUiJIiil ,:w!inniK            n i in ill 11 i iili in   i   n  ii    i n i MI  i in i i   ii     in n|i      n   i|iiiinii|iniin

           ^^;:-:Ms value is reported in Exhibit B-2-3 in the Alabama row under Construction Starts four to
    ---::-••'"•;	; •;-'• ""five Acres as 304 starts.

                Step Eight. EPA collected and reviewed state erosion and sediment control regulations during

                                                              i between one and five acres (Phase II) that are


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      	iil	v	: tiiliii:	iili:i:;	^'t^ .n||plwtw:l^«^jililiiiffl	Mi,';i4li^i:ft1V:'^?j;/iS!st^':''l.	I	iiiawiS^	i«a(fi;'j'?wlM. HwM
	;|h,,!	a,:-iaiiS '\iilf t^f^'-XS^^MMiit^X	if%fflH(liiliitiil(irvt i,; J!fc''Si'•,;',''v'1 •$&' 'ii SHtSi.S'.'.SI.^S'	
     »;;l|K^^                     	'i1™^^                      	i:;l!J':;::^^                     i!!!!!¥         •!^:;«lllllll!ll::,ill'l:w:A	101^^   	i,1'1,!
-------
                                       Appendix B
 equivalent to EPA's final Phase II rule requirements.  In states that regulate construction starts
 that disturb between one and five acres, or a subset of that acreage range (Georgia, New
 Hampshire, West Virginia, and Wisconsin) those starts were eliminated from the analysis
 because they already have sediment and erosion control requirements similar to Phase II.  The
 following states have equivalent programs:
    Connecticut (all starts)
    Delaware (all starts)
    District of Columbia (all starts)
    Georgia (two- to five-acre starts)
    Maryland (all starts)
    Michigan (all starts)
    New Hampshire (two- to five-acre starts)
            New Jersey (all starts)
            North Carolina (all starts)
            Pennsylvania (all starts)
            Puerto Rico
            South Carolina (all starts)
            West Virginia (three- to five-acre starts)
            Wisconsin (three- to five-acre starts)
 Step Nine.  The Coastal Nonpoint Pollution Control Program directs municipalities hi the coastal
 zone to require erosion and sediment controls for construction starts disturbing less than 5 acres
 of land.  Coastal municipalities are required to have construction erosion and sediment control
 requirements in place before issuing Phase II permits. EPA's cost estimate includes only those
 states and counties that do not have enforceable policies and mechanisms for erosion and
 sediment controls at construction starts. EPA eliminated construction starts located in CZARA
 states and counties (as identified by EPA Coastal Nonpoint Finding Status. April 22,1998)
 where CZARA is, or is expected to be, used as the primary enforcement tool. As a result, all
 construction starts in the states of Florida, Rhode Island and the Virgin Islands as well as starts
 from CZARA counties in Alaska, Massachusetts, and Virginia were excluded.

 Exhibit B-2—3 indicates the number of storm water construction starts by state and size category
 after all equivalent programs have been removed.

 Step Ten. Finally, EPA chose to examine the Phase II construction universe, as presented in
 Exhibit B-2-3, by climatic zones. Climatic zones reflect regional variations in rainfall intensity
 and amount. This step involved estimating the percentage of land area within each state
 corresponding to a given climatic zone and then using these percentages to determine the number
 of starts within each zone.  The results are presented in Exhibit B-2-4. The total number of
 construction starts between one and five acres is  123,145. This estimate was reduced by 15% to
 account for waivers, resulting hi slightly more than 110,223 starts.  This is the number of Phase
 II construction starts that is used throughout the cost analysis. To determine that 21.1% of all
 starts may be regulated by Phase II, EPA divided the number of Phase II construction starts by
the total number of permits issued nationwide (110,000/522,000 = 21.1%).

Summary

This appendix identifies the methodology used to identify the number of construction starts
potentially incurring incremental costs of the Phase II Storm Water rule. The Phase II
construction universe comprises 110,000 construction sites ranging from one to five acres hi size.
October 1999
Final Report
                                                                                    B-21
-------
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                         5-22
Final Report
                                                                                                                                                         October 1999
-------
                                 Appendix E
              U
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October 1999
                                Final Report
                                                  B-23
-------
                                                                                                                                      •IS
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                                                                                    ^ii	ii^^
                                                    Exhibit B-2-3.  Construction Starts by State and Acreage with Starts  in States with
'

	
:^'±^;^:": -^ 'I;;";, S^

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.{ , j«; ,„ - ,|1 / f .,' i 	 _"„' '
Alabama
Alaska
Arizona
Arkansas
*•* t»*» •
California
Colorado
Connecticut
&C
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
^ouisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
few Mexico
New York


"forth Dakota
Ohio
Oklahoma
1-2 acres ?•'?
908
25
1,940
737

,669
1,153
0
0
0
0
2,684
563
688
3,005
2,603
1,109
963
908
1,023
871
0
393
0
2,433
732
1,494
242
889
1,068
474
0
403
4,847
o

229
2,619
706
:','. ':2-3ac"res::^,i
480
13
997
392

,368
623
0
0
0
0
0
282
363
1,565
1,349
575
502
483
530
443
0
197
0
1,254
383
785
127
451
549
0
0
215
2,443


119
1,375
367
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322 '
9
727
273

2,269
• 443
0
0
0
0
0
190
248
1,044
854
367
322
334
336
259
0
118
0
757
246
531
83
283
413
0
0
146
1,519


77
931
235
•. 4^5 acres ~
304
8
907
275

2,722
409
0
0
0
0
0
243
242
1,035
793
341
300
315
323
233
0
122
0
650
226
524
79
300
537
0
0
133
1,645


68
924
221
Total (1-5 acre sitesjil
2,014
56
4,570
1,678

15,028
2,628
0
0
0
0
2,684
1,279
1,541
6,649
5,598
2,392
2,087
2,040
2,213
1,806
0
829
0
5,094
1,587
3,334
531
1,923
2,567
474
0
898
10,453


493
5,849
1,529
                      	
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                                                                                                   October 1999
                                                                                                   '9S :''TSt!;yiSfiiff''9ii.:"''*^A;i
-------
                                          Appendix B
             Exhibit R-2-3. Construction Starts by State and Acreage with Starts in States with
                Equivalent Erosion and Sediment Control Programs Removed (continued)
t'..-~-isA--ff]^3iM^^^
o. * ,*- '-i!' '&-'-»'•>, *'+/!)*• -,l.^i-: •*%
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Total
('f^Zt&cfesjjj:
1,271
0
0
0
0
477
1,510
4,571
733
426
0
1,370
2,034
562
3,082
157
58,572
i!^.;aeres;' [
675
0
0
0
0
246
799
2,371
393
217
0
717
1,065
286
. 1,396
82
28,477
• •: 5^feacrJes»
470
0
0
0
0
149
541
1,601
279
129
. 0
459
745
0
0
52 '
. 17,764
'JlpRS'Sicre^ftf
458
0
0
0
0
132
511
1,715
266
115
0
412
802
0
0
46
18,332
l^^o^llli^cre^fte^; -:'•
2,874
0
0
0
0
1,004
3,362
10,259
1,671
888
0
2,957
4,646
848
4,478
337
123,145
 Exhibit B-2—4 further refines the analysis of construction starts by correlating the total
 construction starts of each state with the total amount of pollutant loading. By subdividing each
 state by climatic zones, a relationship can be formed between the pollutant loading of each state
 and construction starts.
                   Exhibit B-2-4. Estimate of the Numbers of Phase H Storm Water
                           Construction Starts by State and Climatic Zone
^jSfate'lls
Alabama
Alabama
Alabama
Alaska
Arizona
Arkansas
Arkansas
California
California
California
Colorado
K:'^6sSjimaptic^&e^atejg6ry •."
P
N
T
W,X,Y
D
N
P
A
C
D
D
•'- •\%-6f;SfiifeiantlLriaii^2?
25
72
3
100
100
40
60
12
40
48
8
^^ifrlsl^eirepp-
503
1,450
60
56
4,570
671
1,007
1,803
6,011
7,213
210
October 1999
                                         Final Report
B-25
-------
!
                                             r^-^.	Istimate of the NHmbers of Phase II Storm Water
                                        Construction Starts by State and Climatic Zone (continued)

	 	 ' 	
I 1 if, ^ 	 ' ,:i; ' UmM
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Iiiii!1! 	 4 	 lilM^^ ••""!» 	 IIIM^^^^
	 iiEi 	 iiiiir:: 	 li-iiiii , ;rHStartsl-r5. acres- ; -.'
1,524
710
184
0
0
0
0
0
268
1,959
456
1,279
539
185
817
6,649
4,423
1,176
2,392
1,690
396
1,856
184
1,527
686
1,806
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509
2,853
1,732
1,539
48
i












'—26, 	 , , 	 Final Report October 1999
	 • 	 IIIH'L • 	 	 '"; •' 	 	 l"j" 	 • 	 '""" 	 ':i11 •"• 	 :1 	 " 	 • " "•i-r •''• 	
	 '-' i 	 iH-'-liMll-' 	 IB 	 .:• 	 ' 	 : 	 « 	 1 "II 	 «' 	 	

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it»^.

-------
                                          Appendix B
                   Exhibit B-2-4. Estimate of the Numbers of Phase II Storm Water
                      Construction Starts by State and Climatic Zone (continued)
'? 'Stater y~
Missouri
Missouri
Missouri
Montana
Montana
Nebraska
Nebraska '
Nebraska
Nevada
^ew Hampshire
New Jersey
^ew Mexico
New Mexico
^Jew Mexico
New York
North Carolina
North Carolina
North Carolina
North Dakota
•forth Dakota
Ohio
Ohio
Ohio
Oklahoma
Oklahoma
Oklahoma
Oklahoma
Oregon
Oregon
Oregon
Oregon
Pennsylvania
Pennsylvania
•uerto Rico
Rhode Island
South Carolina
•V * ^Climatic Zone Category ' • -
M
N
P
E
G
•M
G
H
D
R
R
D
E
G
R
N
P
T
G
F
M
N
R
H
M
' N .
P
A
B
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E
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R
Z
R
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46
7
66
34
20
43
37
100
100
100
57
14
29
100
16
57
27
6
94
42
31
27
68
8
19
5
37
24
27
12
74
26
100
100
64
Starts 1-5 acres !
1,567
1,534
233
350
180
385
827
712
2,567
474
0
512
126
260
10,453
0
0
0
30
463
2,457
1,813
1,579
1,040
122
290
76
1,063
690
776
345
0
0
0
0
0
October 1999
Final Report
                                                                                          B-27
-------
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                                                                                           Appendix B
                                                                                                                                                                            "!	I	  	
                                                        Exhibit B-2-4.  Estimate of the Numbers of Phase II Storm Water

                                                            Construction Starts by State and Climatic Zone (continued)
1 1
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South Dakota
South Dakota
South Dakota
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Tennessee
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Texas
Texas
Texas
Utah
Utah
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Virginia
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Washington
Washington
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35
50
15
76
24
11
44
27
11
7
67
33
100
100
40
46
14
30
56
14
100
63
37
27
43
30
Total Starts— 1994
Estimate of Total Starts' — 1998
istimate of Total Starts Adjusted for Phase II Waiver Provision •
'. s Starts 1—5 acres y~K
0
351
502
151
2,555
807
1,128
4,514
2,770
1,128
718
1,120
552
888
0
1,183
1,360
414
1,394
2,602
650
848
2,821
1,657
91
145
101
123,145
129,675
110,223

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                                 SsPJS	1994\v5g	1.3%.	This growth rate is used to estimate 1998 construction starts from the 1994 baseline. However,

                         EPA recognizes the growth rate for construction starts fluctuates yearly and does not necessarily increase each year.
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-------
       Appendix B-3
Model Construction Site Plans
-------
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                                                                                                                                                                                            illiiiliM^^^^
-------
                                       Appendix B
  Drawing Assumptions

 Detailed drawings of the model sites (i.e., site plans) and the assumed BMPs that could be used
 under the Phase II rule are found in the following pages.  In developing the BMP mix for each
 model site, certain simplifying assumptions were needed. EPA assumed the following would
 apply to each site:

 •  The project area will remain completely denuded for six months.
 •  The site slopes uniformly from north to south.
 •  No  structures, swales, or other drainage features will impede the flow of storm water from the
    northern part of the site to the southern part.
 •  No  run-on will occur from surrounding areas.
 •  25' wide streets are located on the north and east sides of the site.
 •  A stream flows along the south side of the site.
 •  A 30' vegetated buffer is maintained between the site and the stream.
 • .  Sediment traps will be designed to a volume of 1,800 cubic feet/acre.
 •  All  BMPs will be properly installed and maintained.
 •  An existing 4' wide swale runs along the east side between the project site and the street.
    This assumption was made because erosion and sediment control plans typically need to
    control runoff to and from various existing drainage structures.  Although the site slopes
    north to  south, a designer should assume that a considerable amount of sediment will enter
    the swale due to the constantly changing drainage patterns of a construction site.
October 1999
Final Report
                                                                                    B-31
-------
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-------
               Appendix B-4
Post-Construction Runoff Control Cost Analysis
-------
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-------
                                       Appendix B
 Overview

 This appendix describes the methodology used to estimate BMP installation costs attributable to
 the Phase II Storm Water rule's post-construction municipal minimum measure.  Specifically,
 the costing exercise estimates the costs associated with constructing BMPs that attempt to
 maintain predevelopment runoff conditions on post-construction sites. The measure affects sites
 on which land disturbance is greater than or equal to one acre and that discharge into a regulated
 MS4. However, sites that disturb more than ten acres are not included in this analysis because
 the Construction General Permit already imposes post-development storm water control
 requirements on those sites (63FR 7858) .

 In estimating incremental costs attributable to this measure, EPA estimated a per-site BMP cost
 for 12 model sites of varying size (one, three, five and seven acres) and imperviousness (35%,
 65% and 85%). This approach was based on the results of an EPA Office of Science and
 Technology study (Preliminary Data Summary of Urban Storm Water Best Management
 Practices, US EPA, Office of Science and Technology, December 1998b). EPA used the Office
 of Science and Technology study to develop a combination of BMPs for the model sites and
 calculate costs based on the amount of storm water runoff expected from sites of varying
 imperviousness. Based on considerations of site size constraints, total BMP costs and terrain
 variations, EPA calculated a weighted average BMP cost, including operation and maintenance
 costs, for each of the model sites.

 Two additional adjustments refined the per-site cost estimate for post-construction control. First,
 EPA included a cost reduction associated with nonstructural practices that it anticipates will be
 used to comply with this measure.  EPA identified per-site average cost reductions associated
 with redirection of rooftop runoff ("rooftop runoff credit"). Second, EPA anticipates ancillary
 cost savings because the new BMPs (structural and nonstructural) will also reduce peak storm
 water flows, allowing developers to save on construction costs when they build their sewer
 connections.  The potential cost savings, based on estimates of reduced per-site costs for storm
 water conveyances, were also subtracted from the initial per-site BMP cost.

 The adjusted per-site BMP cost was then multiplied by the total number of construction sites that
 are located in Phase II urbanized areas to obtain a national cost estimate.

 Detailled Description of the Cost Analysis

Phase II Post-Construction Universe

 EPA derived the number of construction starts affected by this measure by further refining the
 construction start analysis used to identify the number of starts that would be regulated under the
 Phase II construction program for sites nationwide.  As a result, this analysis started with the data
 set that is described in Appendix B—2, steps one through seven. Two additional steps, described
below, were performed to identify the post-construction universe.

 Step One. EPA used county-level Bureau of the Census construction data as the basis for
 identifying the universe of construction starts affected by the post-construction minimum
October 1999
Final Report
B-35
-------
                                                                            Appendix B
                      measure (construction starts that disturb between one and 1 0 acres of land and. occur in Phase II
                      urbanized areas).  EPA identified all counties that are located either entirely or partially inside
                      urbanized areas.  EPA eliminated all other nonurbanized counties from the construction start data
                 ^r^Sfet  For counties that are located partially inside an urbanized area, EPA assumed that
                ,. , .............. ,,, ............. cjjns j||||Qg ...... agtiYltyjs ..... evenly ^stributed^and^therefpre, ...... based its calculation of the number of .......... '
                     '                 starts on ratio of county^ land located in the urbaruzed area versus outside the
                 :iii«^^^^^	

                j££	§tepiTwoT  'EPA	removed"	cbrJBtfucS6ri"siiarts	that were	located Hcounties
                                              s under^CZARA m the 'foUowSig ..... sSesrilro
                                                                                      ......
                     ^ |ej|                                                           Ebt          suianzes
                 ^;^^§1^^2S ..... it§ll§ ..... Py acrea§e ca*egory m"at may be agec|e5 ^ the Phase !! rule.
                                                                                                                                , 'Maryland, ..............................
                                                                                                                                         '    ........................... ' ........... .........
                                          [[[ | [[[ ; [[[ ........... ; ................................. ; ......................................... ; .......... ....................... . ............................ ......... ;;| ........ ; ...... ' ..................................... „, ............................ ............... ........................ | ...........................

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-------
                                        Appendix B
           Exhibit B-4-1. Estimated Number of Construction Starts Potentially Affected by the
                        Phase II Post-Construction Runoff Control Provision
V ~ z * \
v Area" „-
Acreage
1 Acre
3 Acres
5 Acres
7 Acres
Totals
.1 i"*^' *>*, "f ^Construction Stal^; (1998) J "•"-*. ~*. „,* v , * %
-Multi-Family
Residential
(35%) ,
221
287
228
244
981
Multi-Family/' * ^
Commercial/ Institutional ^
2,942
2,451
822
818
7,033
Commercial
(85%)
2,505
1,939
523
384
5,351
Totals
5,668
4,677
1,573
1,445
13,364
 Per-Site Costs

 Step One. EPA developed a theoretical series of representative sites to which typical best
 management practices could be applied. The 12 model sites varied by site size (one, three, five
 and seven acres) and level of imperviousness (35%, 65% and 85%). Imperviousness levels for
 multi-family and commercial development were established based on a review of local
 government reports detailing average imperviousness by land use type (see Exhibit B-4-2). To
 account for ranges of imperviousness reported for multi-family (35%-65%) and commercial
 (65%-85%) development, EPA assigned half the starts to either impervious category. For
 example, of the 442 multi-family one-acre starts, 221 are counted in the 35% impervious
 category while the other 221 are counted in the 65% impervious category. All institutional starts
 are counted in the 65% impervious category, reflecting the reported impervious range of 50-80%.

                 Exhibit B-4-2. A Summary of Impervious Surface Percentages for
                            Commercial and Multi-Family Land Use
V5 M „ **"• „ * Reference » ™ rf „ Jfc-%, *L-"*' ..
~" i -*
^ % Impervious ^ "
- ^ "^ * fr -Commercial -" * ^* ^ ^* "
~~ ? ^ ^ «, v
US Soil Conservation Service. 1975. Technical Release 55. Urban
Hydrology for Small Watersheds
MWCOG. 1987. Controlling Urban Runoff: A Practical Manual for
Planing and Designing Urban BMPs
MWCOG. 1997. Anacostia Watershed Study— draft (survey of land
use and corresponding impervious surface levels in the District of
Columbia, Montgomery and Prince Georges counties)
Maryland Department of the Environment (Jim George and Greg
Lindsey). 1991. Financing Stormwater Controls in Carroll County: A
Preliminary Investigation
85
60-80 (light com)
80-100 (heavy com)
50-70(low density com)
70-80(medium density com)
80-90(med/high density com)
90-1 00(high density com)
82
October 1999
                                       Final Report
B-37
-------
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                                                              Appendix B
II	II  llilllll   I llilllll I llilllll
                                                                                                   I1111! I I I I II   II II III ||ll Iliilll I IIIIII llilllll II 111  I  |l
111 111 llllllllllllll 111 IIIIIIII llilllll I llilllll
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                                                                                                        IN  ii'ii	nil i	M i iii ii iiiiii in i in
               " ""  | ™f'm	"'['_	™|  |	ExhibftB^-4. A Summary of impervious Surface Percentages for
 	j	I	|	Commercial	and| Multi-Family Land Use
      	liliii't',
                    NVPDC.  1990. Evaluation of Regional BMPs in the Occoquan
                    Watershed
                                                                                               90-95
                                                                                     (suburban shopping center/cbd)
                               ,                        .
                  *~ : ....... T f", ........... ff 'f'T:;-.1'"1" ';;"•; S'lir.!-!;^*-"! f. -f-?~.'- ,'• A:%^Vl
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                                                                                                              " '  *: '- i
                                                                           •V-iv,v:^--*^":Vvt^^^f/^Si>^V:-'::;:;'--^."'r.'V-'.' '•• - ; ..'••
                                                                          m^&.A-^MX                      •'f-.i.-j » ,-• ?,; it1
                    MWCOG. 1997. Anacostia Watershed Study—draft (survey of land
                    use and corresponding impervious surface levels in the District of
                    Columbia, Montgomery and Prince Georges counties)
                                                                                  50-70 (schools, military installations,
                                                                                              churches)
                                                                                   70-80 (schools, colleges, churches)
                  : ,*. «i, ;»• fit fer !s;T;i!si-,%st, W& * t *• f f -# .•> :•*• |. i fi • t. • ^^^smssf^^^^
                  	:^;Sa$igfs:^^^^^
                    US Soil Conservation Service.  1975. Technical Release 55. Urban
                    Hydrology for Small Watersheds
                    MWCOG.  1987. Controlling Urban Runoff: A Practical Manual for
                    Planing and Designing Urban BMPs
                    Maryland Department of the Environment (Jim George and Greg
                    Lindsey). 1991. Financing Stormwater Controls in Carroll County: A
                    Preliminary Investigation
                    City of Olympia. 1994. Impervious Surface Reduction Study
                    MWCOG.  1997. Anacostia Watershed Study—draft (survey of land
                    use and corresponding impervious surface levels in the District of
                    Columbia, Montgomery and Prince Georges counties)
                                                                                          38 (lots < 1/8 acre)
                                                                                           65 (lots 1/4 acre)
                                                                                     35-60 (townhouse/garden apts)
                                                                                      40-68 (garden apts/condos)
                                                                                        42-56 (4-7 units/acre)
                                                                                  30-50(row houses/garden apts)
                                                                                  50-70(mid-rise apt/multi-unit)
                                                                                        70-80(high density res)
I
       qua, iiiiii	ifiift
                    NVPDC.  1990. Evaluation of Regional BMPs in the Occoquan
                    Watershed
                                                                                        35-75(6-30 DU/Acre)
                  For purposes of this analysis, EPA assumed that single family residential development would be
                  able to meet the post-construction runoff control program goal using storm water sensitive site
          L-^'TKS^i?- "ii161:6*?*6?, ,?^nl^e ^fftily residential construction starts were excluded from this analysis.
          : ....... ~~;^l ...... The ..... M^fi-Sector ...... General ..... Pejinit places post-development runoff requirements on industrial sites
                  that are similar to the Phase II requirements for the post-construction runoff control minimum
                                                                              ...... analysis ......
i ....... i, i
               ......... iii Step Two. EPA Wentified five £^ man^ement j^tices gMPs) that developers could use to
                                 idiP^ program requirements of the new developmentA'edevelopment minimum
....... , ............ ij;- ...... ! .......... ........ > ...... , ................... ........... i, ..... ...ii.mi
                          T  The following five BMPs selected for the analysis represent typical water quality
                        s: dry detention ponct, infiltration trench, infiltration basin, grass swales an3 sand" filter.
               §g!iEPA accounted for site constraints resulting from site size and impervious level when assigning
                  BMPs to the model sites, then developed an average per-site §MP cost This per-site cost was
 :J5n_2SI'™, ™:*™13djusted to account for potential cost reductions associated with the redirection of rooftop runoff.
                                                                                    |
                                                                                 iiiiilinn null in 1
               ;	S-3S
                                                             FinqlReport
             October 1999
-------
                                        Appendix B
 BMP Installation and Maintenance Costs.  Per-site costs were calculated based on estimates of
 water quality volume (WQv), which is the volume of water that a BMP is designed to treat.1
 Using Schueler's simple method, EPA determined water quality volume for the one-inch storm
 as follows (US EPA, 1998):

     WQv = (.05 + .91) A/12

     where:WQv = Water Quality Volume (Acre-Feet)
     Mmpervious Fraction in the Watershed
     A=Watershed Area (Acres)

 Exhibit B-4-3 summarizes the results of calculations determining water quality volume for each
 of the twelve model sites described above. Total volume, which includes both water quality
 volume and detention volume, is not used in this analysis because EPA assumed that site
 operators will account for detention volume where it is needed to correct for flooding hazards;
 the control of detention volume is not a feature of the Phase II Rule. Construction and
 maintenance costs depend on the size of the BMP, which depends on the water quality volume.

              Exhibit B-4-3. Water Quality Volume Calculations for Twelve Model Sites
Square Acreage(A) *
Percent Impervious Cover (I) *
Water Quality Volume (acre-feet)
(PXRvXA/12)
P=l" of rainfall
Rv = 0.05 + 0.9 (I)
A = Drainage Acreage
Square Acreage (A)
Percent Impervious Cover 0)
Water Quality Volume
(P)(Rv)(A/12)
P=l" of rainfall
Rv = 0.05 + 0.9 (I)
A = Drainage Area
1 Acre
„ '35 "-,
0.03

65
0.04

85,
0.07

5 Acres
' 35 '
0.13


65
0.18


85 ^
0.34


" ^ 1 *'"'' 3 ./jLcres \
35 „
0.08

^65^,,
0.12

" as^-r
0.20

/ J7 Acres'1"^ ajs.
35 v
0.18


, 65 ^
0.26


-'85*"'
0.48


EPA's cost analysis used the construction cost equations and the annual maintenance cost
assumptions in Preliminary Data Summary of Best Management Practice Cost Analysis (EPA,
1998), which reports the findings of OST's national review of capital costs attributable to BMP
design and construction. Exhibit B—4-4 summarizes construction cost equations and
maintenance costs for each of the five BMPs.
1 For example, a BMP may be designed to capture the first inch of runoff from the drainage area. Any volume of
rainfall over the first inch would bypass the BMP. Therefore, water quality volume for this BMP would be one
watershed inch.
October 1999
                                       Final Report
B-39
-------
• 	 , 	 i;i;;, 	 	 ,;; 	 ; 	 , 	 	 ,,, 	
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	 	 i 	 Ap'pendlx B

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             .JH                                                   ...... ICI ...... iilM^
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                                                 ...... iiiiiii; iin^^^                           .....
                                  Exhibit B-4-4. Descriptions of New Development and Redevelopment BMPs
IH^^^^^ 	 Wmeii
Iliilill, 	 -I 	 IlllH^ 	 O'iJV^
lllliD^ liiliii, •iiiiiil:*
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I'iillH^^ 	 B1 III' iT.!,!,'''''..!!!'''!'!! f
IRB
in i jiiiiiiiiiaiiiii/M iKilliiiiiinii Win
BMP
Detention Pond
Infiltration
Trench
Infiltration Basin
Swale

Sand Filter
Construction Cost
Equation
18.5 WQv0-70
l-3ac: 4,400
Sac: 10,400
7ac: 3.9 WQv + 2,900
1.3 WQv
(1 5%)*(%Impervious
area)*(.25$/sf)
4 WQv
Maintenance
Costs1
5%
12%

4%
5%

12%
Notes
Ponds are a reliable best
management practice.
Although infiltration trenches are
designed to last a long time, they
need to be inspected and rebuilt if
they become clogged.
Infiltration basins are not very
reliable, and tend to become
clogged.
Used for smaller development,
requires frequent maintenance in
order to function long-term.
Sand filters require frequent
maintenance in order to function
long-term.
Sources
a,b,c,d,e
d,e,f

g
d

a,e,g
                                                                                          in i| '  i  1 1111111 nil in in nip • iiii.'i
                                           ! IIRI'llll'lk ILflhl I 'B ' '"I: ,JMI iJ
                                                                        ''!!!1 Lllnllll :d	nlijllMllili.vqnlllllL1,,.!
                                                                                                 !!: inuii .: 'iiimiiiiiiriLLi, ; „,:,!! ..... " HP iii'"i inT
          ;;::i;::';':i=   Sand filter volume was estimated at 4^Qv, which is slightly high, to account for the relatively small drainage area.
                    Life •= Length of time without major modifications or reconstruction
                    111! I  III Illllllll 111 II llllllll||l|l IIIIIII 111  III 111  I  111 nil 111 111 II 11 III II II III II II   III I   II I    111 111  111 I  I I   111) II I   I   11 III I  II  111 II    III I     (
                    a « Brown and Schueler, 1997b
          ^^^^^^^^^^^
                             , 1987_,,,,,,	,r .;,	M	 ; ,, i;,'t         	r1,	 '., r,
                                   1,1997

iiff™™!!:":'!-!'™	i™^^^^^^            as % of construction costs on an annual basis
Nllinillllilil'ilhl'''"'!!,!,:!!!! : "iflllllliiJiii" .JiiIKi'	
:J&s S°,,l||| P,rcyjously» this costing analysis utilizes a theoretical set of representative sites to which
	''"^Typical b'est management practices are assigned  For each of these representative^ sites. Exhibit
         sKows; which jg'jj/fps were Use3 |o develop an average per-site cost. Some BMPs are more      I
   I1 III "I i 111 111	
                 in i H 11 in
                                                                                                                iiiii i iii iiiii   nil
         ;o	be	Jjsedjftiano&eis	for	^^^^zes^of sites	and	idj^CTe^ti^jreesof|imp£ryipusness.
    ie selection of gMps t0 ^5 for eapjj site was based on the following assumptions:
                                                                            i in i iiiiii 11 nun   ii ipi in i i| iiiii i mi
      To allow for variety in sites and to provide a range,  a selection of three BMPs was typically
      provided.
                                                                 I
                            I
      Engineers will use the most cost effective BMP provided site restrictions are not a factor.

      It is standard practice and feasible to select detention basins in the design of BMPs.
      Consequently, a detention basin was assigned to each of the model sites.
 I	iii • in	ill iiiii
'lilll'iilil	Hill I'I'll1 ill 1111
ill1 IIWI	liiilli
                                                                                                                II III Iliilllii
                  B-40
                                              Final Report
                                                                      October 1999
-------
                                       Appendix B
    Infiltration trenches are not cost effective on smaller sites with low impervious levels but
    may be on larger sites.

    In general, swales are used and effective on small sites with low impervious levels. Due to
    cost constraints, sand filters are typically used on larger sites.
                          Exhibit B-4-5. BMPs Used for Cost Analysis
-I £"*&*,<.
,- > < t '^^
• *N f %J^~S
• 'Site Sire v
* v y ^ -&
-> "(acres) t
1
3
5
7
^x - „ rt
* /j - > t
-»-"'/ *
% impervious
z ••»»,
35
65
85
35
65
85
35
65
85
35
65
85
Percent Selected for T|MPl>esign 1" "r*
Detention
Basin
40
30
40
40
33.3
33.3
40
50
30
40
45
66.6
Infiltration
Trench *"

30
40

33.3
33.3


30
10


Infiltration
V Basin
#>f
40
30

40
33.3
33.3
40
50
30
40
45

,-h '**%
Swale ^
20
10

20
-

20





Sand ,
Filter


20





10
10
10
33.3
Exhibit B-4-5 also shows the weights that were assigned to each BMP to obtain a weighted
average cost for each type of site.  Nonuniform weights were provided when one BMP was
believed to be less likely to be selected than the others. The sand filter and swale BMPs were
given less weight than the other possible options to account for site constraints or limited
effectiveness. The remaining weight was then distributed evenly among the other BMPs. For
example, on a five-acre site with 85% impervious surface, the cost of a sand filter exceeds the
combined average cost of the detention pond, infiltration trench, and infiltration basin. Because
an engineer would be more likely to select the most cost effective BMP or combination of BMPs,
and sand filters are used only when site constraints present no other option, EPA assigned a low
weight to the sand filter (10%) and equal weights to the remaining three BMPs (30% each). By
assigning nonuniform weights to the BMPs, the analysis more accurately reflects expected costs
under actual development conditions:

The BMP costs shown in Exhibit B—4-6 are capital costs associated with each BMP for each size
site and impervious cover. Exhibit B—4-6 does not report costs for BMPs that were not selected
for a model site because of limitations related to site size and imperviousness The average
October 1999
Final Report
                                                                                    B-41
-------
|M                  ..... f(K

                                                                                                                                                                 ',,: "!',- '-'ii'S-;," i
                                          ," ilUlllliP, IP ,:,|,|||II,R 'ih, 'illLiiilll	l.illlll, illiiiiiliii,,!! ^"lnl'lJilRiini	ii,llli,4,,,!l"ii	
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                                                    il»^^^	1MB	«^^
                          ,,,	,,,,.	|i|hted cost was obtained by_ using the weights in •Exhibit B-4^5.  The total cost is the sum of

                          "	the	average weighted	BMP	and operating and maintenance (O&M) costs.
                                              	T	
 ™fz:::;:^ :";,;;	"" ~ f lEhe,	Pj&jM,,, costs, shown	in the, ..exhibit	are,, present value, calculations of O&M costs over ten years

                            (i.e., two NPDES permit periods) assuming a 7% discount rate.  These capitalized O&M costs

I ''^miiii "'"„„,i p iii	vi iii,'|^^i^^^Jgi A£S3j^S|!^sis because they_ represent the social costs of maintaining^ the

                                        aggafiflie	§JteHS^ii.§$Sl.s,,la§^J^[..in,3Py year- If the BMPs were nol maintained,

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                                          Appendix B








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October 1999
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                                                                                         B-43
-------
                                                                                               Appendix B
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'Refer to Exhibit B-4-4
2Refer to Exhibit B-4-5
'Dollar costs provided in
                                                                       Final Report
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-------
                                       Appendix B
 Rooftop Runoff Credit. EPA anticipates that non-structural practices will be used whenever
 feasible to comply with this measure, because they are generally less costly to implement than
 structural measures.  One simple design practice, the redirection of rooftop runoff from
 impervious surfaces to grassy areas, can be used as a way to reduce the need for installation of
 structural BMPs. In EPA's cost analysis, per-site average cost reductions associated with
 redirection of rooftop runoff have been calculated and subtracted from BMP installation and
 maintenance costs.

 The steps used in calculating the rooftop runoff credit are as follows:

 Multi-family sites: The calculations are based on an average density for townhouses of 10
 townhouses (TH) per acre. It was assumed that the average square footage of the rooftop was
 SOOsq. For example, to calculate a reduced impervious area for three-acre 65% multi-family
 sites, the following steps are used:
 •   3 acre x lOTH/acre = 30TH
 •   30TH x 800 sq/TH = 24,000 sq = 0.55 acre (total rooftop area of townhouse)
 •   3 acre x 65% = 1.95 acre (total impervious area on site)
 •   1.95 acre-0.55 acre =1.4 acre
 •   1.4 acre/3 acre = 46% rounded to 50%

 Commercial/Institutional sites: Floor Area Ratio (FAR) was used to determine rooftop surface
 area.  FAR for commercial sites ranges from 0.25-0.5. For the one-three acre sites a FAR of
 0.25 was used, and for the five-seven acre sites, a FAR of 0.35 was used. It was also  assumed
 for these calculations, a single story building, and the discharge from the rooftops will be from
 multiple locations along the roof. For example, to calculate a reduced impervious area for three-
 acre 65% commercial sites, the following steps are used:
 •   3 acre x 65% = 1.95 acre (total impervious area on site)
 •   3 acre x 65% x 0.25 = 0.48 acre (area of rooftop on impervious surface)
    1.95 acre-0.48 acre =1.47 acre
 •   1.47 acre/3 acre = 49% rounded to 50% (revised impervious surface area)

 Results are presented in Exhibit B-4-7.
                Exhibit B-4-7. Cost Reductions from Redirection of Rooftop Runoff
 '^^^Mi^K\.^^^^^^^^^^^^^:S^£^^^^^

 1 Acre
 $266
                                                   $425
                                                  $0
 3 Acres
 $674
                                                  $1,643
                                                  $0
 5 Acres
$1,048
                                                  $3,058
$0
 7 Acres
$2,301
                                                 $12,097
$0
October 1999
             Final Report
                                                                                 B-45
-------
           tl^
                                           average'tota
                                               .......... I!;)]!!.:
                                                                          ie rooftoprunoff credit, Exhibit g^lg1
                                                                                             sites.	'	
                                                                                                      .........               I

                                                                                                                     .............
• 	 •• 	 - 	 ' 	 ' 	 	 	 " 	 	 "'


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~~^~~:~ 	 " 	 '.'.'.".£."'

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mf'M iJipiiiiiiiNiiiiiiiiiiF'1 liniihiiiiiiii' • i:?!, ' ''S'li'iiii lii iiiiiil iiiiifiiii' iiiiiiiiiiii " i
Average BMP Costs (1998 dollars)
Area
(Acreage)
1 Acre
3 Acres
5 Acres
7 Acres
35% Impervious
(Multi-Family Residential)
$2,277
$5,676
$8,760
$16,828
: 65% Impervious
(Multi-Family/Commercial /Institutional)
$4,867
$12,698
$15,353
$31,448
85% Impervious
(Commercial)
$10,486
$15,998
$19,377
$68,996
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                                                                                     :i !:i:Jii.i
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                                                                                 ,	1	
 'I	;	:|!=	_ An §5ci||ary 1®SH§!:, 2l ™ S??*~c9n?^ction rrao^PFov*s*on *s ^a* ^e new gMPs (structural
                                                                                               sewer system.
                               JT, developers may be able to save on construction costs when they build their sewer
                                                            ismbst'cfbselyafiglDeS'^mth^co'staialysis, which
smmm	t iin	mv ill	«connections.
^^rE= ,."';:	rii|^
                                                                                                     ; in the
                             is'reduce   e peak runoff hat must  e handled by conventional storm water
                                                                 	poteniiai"fo"f	g^ygj^gjg	to"reduce"'the"cbst	of
                  The analysis assumed that reductions in peak runoff volumes generate cost savings associated
                MBMi ...... i ............................. ! ....... " .............. ........................................... m ................................. m .......... • ....................... ....................... '. ........................... s ..... . ....... • ....... = ............ > ................... • ..... •• ................................... i™.— ............... • ......... s ..... ...... • ..... • .......... ........ s ..................................... 3 ............. ••" .................... ..... i ...... "T1" ..... 9- [[[ « ...................... 3 ............... • .......... «3" ............. TSt ............................................ ...................... '
               =;- =:Wim;using smaller diameter pipe compared to pipe sizes that might be required without the
                                      liisi ..... tEe "size ...... of pipe that would be requked to transport the wafer quality
                              1 JanaJwiSouT5ie ..... useTolPSie" ...... stonn' wato ..... BMP ...... was ...... 3eteimine3 ..... for each of the twelve
                          .    M        ..... £jM^^^^^^^    .....    .       „ ......           . .....     , ,    .  ................. ' ........... ' .............. ' ........ i ..... »' ...... !M|!||B .....   ,, ..... ....... 1| ...... l|i"|i;<:|" ...... ..... .............. " ............................
                      iel sites used in the cost analysis (i.e., four acreage sizes and three impervious surface
                                   ..... ~^ j ..... ancf third
                                                             " m Exhibit' B-4—9 show the water quality volumes
                  for the one-inch and five-inch storm events, respectively.
                 "	"1'	"'"	"	~	"'	
                         	1!	

                  The standard approach for calculating the size of pipe used in a storm water/sewer drainage
                         is to determine: the• peak discharge from a given property and then use the value in
                            equation to determine the pipe diameter.  In these calculations, a water quality volume
                                   a peak discharge using Claytor and Schueler's method (1996) (columns 4 and 5
                                    for the five-inch storm (water quality volume without a BMP) and the one-
                                itef quality volumeYetameffby^BMf^ IlieiC^aiinings equation was used to
              .,
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             **^*':-	Ho'rm	25^	tSeoinch	storm) and wii&buta'H^r7 measure	(five-mch storm).  The resulting
 ;=,;^==s:: '"-^r^^':	figduction in pipe diameter was assumed to represent the size by which the storm water/sewer
               ,,.. :.{djainagepipuig'could be reduced because of the implementation of the BMP (column 6 in
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                                                                                                     October 1999
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-------
                                          Appendix B




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                                         Final Report
                       B-47
-------
                                              	PI,	i,	m,	;	:	,	i	Appendix B
                                                                                         ' '"''''   ' ' '  '•    H '' l! J
           ii	Bii
                    The cost sayings were estimated by subtracting the unit cost of the pipe size required to transport
                   bfeg.fiXSSncj^gtojnj	volume	from the,	unit	cost	of the pipe size required to transport the five-inch        I
™                                                          	The	1999	Means	manual	was	used to	detennine	the	
 	rial ;icost per linear foot assuming the pipe was made of concrete (non-reinfp£cedpip£, extra
                                                     ~i cost-savings analysis used standard pipe sizes; Serefore, if
                                                                       i drop to the:
                                                        ), a zero <
            •w«S£«analysis did not assume any cost savings associated with construction or maintenance activities.

                   Because: costs are: measured in dollars per linear foot, EPA needed an estimate of approximate
                            length of storm water drain pipe adjacent to each" construction start. To calculate the
                                    A. assumed that the one-, three-, five- and seven-acre properties are square in
—•»:	~--~	::	:	:'" !;=^^       a53 tfiat the storm water drain runs along one side of the property.  Therefore, the total
. ^E:'™.~~":". r^j^".^^! of p|f>mg per property was determined by taking the square root of the acreage area and
  •^v^^^^^ggQy^g^ frOm acres to feet (column 8 in gjjjjjgj.
                il'uiliiiuiii!!"'
                                                                                  	I	I	'	,	Ill	:,'|l	>"«	'•
                                  #l| lijjijB
                               pfej.ggsjggyings per model site by multiplying three values: the cost savings per
                               the linear feet per site, and the number of sites. Column  9 in Exhibit B-4—9 shows
                                of construction starts used to estimate gi^p costs, and column 10 reports aggregate
                                                                       cost savings across all sites
     EH*	ii	,.;'
                        savings per type of model site. Total
                   $7.7 million.2
                   «	,	,	,	i3iip!*if;;!i^^	
                                                                       :	;•-;;	 —ir ;:";:,; ;_;-; -;;T -_---	;;_;-;;,

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                         ..      ll          ,             saiv!n,s
                       numSr o^cons^uctipsterts summarized in gg
                                                                                       o obtam total natona costs, ,
                                                                  §tijte  post-cnstouction nmoff icontrol cte are
    mflig-.jft ::,,,,, toW'SiStRfixffiate      78 raonperyear.
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         IE1-	illK
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                    g|f!"sS5Jgs. |f the rule encourages developers to implement design sirategies such as clustering, or if'Se rule
               ^=,^™ggg|ggex.k',,j.  .^ {jyjj^jjjg requirements such as street widths or parking lot sizes, the construction cost
               IliEii iiiil ..... i ................................. s [[[ = ......... =7 .............. i [[[ a .................. a [[[ *- ....................................... e [[[ '
               — :;; ........ savings are potentially large.
                                                                Final Report
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-------
                                        Appendix B
                  Exhibit B-4-10. Estimated Post-Construction Runoff Control Costs
"*:?
* ~ ~4 J ft
, > *„ i •>:-?
v*A *•*
„ Area
1 Acre
3 Acres
5 Acres
7 Acres
Total Cost
35% Impervious
(Multi-Family
' Residential)'
$503,163
$1,486,961
• $2,001,641
$3,863,272
$7,855,037
65% Impervious
(Multi-Family/
Commercial/
Institutional)
$14,318,035
$29,571,535
$11,835,630
$23,910,571
$79,635,771
•=•»(•
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-------
               Appendix B-5




Federal and State Cost Analysis and Assumptions
-------

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-------
                                       Appendix B
                                     Appendix B-5

                 Federal and State Cost Analysis and Assumptions

 Promulgation of the Phase II rule will expand the universe of municipalities and construction
 activities required to submit an application for a National Pollutant Discharge Elimination
 System (NPDES) storm water permit. The Phase II rule has the potential to increase the universe
 of municipalities by a total of 5,106 places/counties and to require permitting authorities to
 process permit applications from approximately 110,223 construction sites and 19,452 waivers
 each year. The annual cost to the Federal government is estimated to be approximately $457,000
 and 'the annual cost to State governments is estimated to be approximately $4,861,000.

 B.5.1 Federal Costs
 Once the Phase II rule is implemented, EPA will be required to operate the NPDES program in
 non-NPDES authorized states.3 Environmental Protection Agency (EPA) will be responsible for
 two Hypes of costs: start-up costs and annual costs.  The start-up costs include the incorporation
 of Clean Water Act 401 certification language into the general permit that EPA anticipates
 developing for small MS4s, the review and filing of non-NPDES-authorized States/Territories
 plans, development of storm water goals for these states and territories, and the designation of
 additional.  All the start-up costs associated with the administration of Phase II will occur once
 as the rule becomes implemented. Some of these start-up costs may also be incurred periodically
 as needed at the beginning of each new permit cycle. For example, the incorporation of 401
 certification language into the general permit language is likely to only need to be done once,
 while the designation of additional MS4s may occur occasionally at the beginning of each new
 permit cycle.

 When the Federal government is the permitting authority for the Phase II municipalities, EPA
 will be required to annually process the applications, review plans, issue NPDES storm water
 permits to the municipal applicants, and review and file any reports.  For construction sites
 disturbing between one and five acres of land in non-NPDES authorized States, EPA will be
 required to process the notices of intent (NOIs) to be covered by the construction general permit,
 the notices of termination (NOTs), and the waiver certification. For small MS4s, EPA will be
 required to process and review the NOI and report.  Exhibit B-5-1 provides the estimated start-
 up costs and Exhibit B-5-2 presents the annual costs to the Federal government.
3The non-NPDES authorized States and territories include Alaska, Arizona, District of Columbia, Idaho, Maine,
Massachusetts, New Hampshire, New Mexico, Puerto Rico. While Florida and Texas will not administer the storm
water portion of the NPDES program until the year 2000, they are counted as part of the NPDES authorized states
and territories since the Rule will take effect in 2003.

October 1999                             Final Report                '
-------
                                          '
                                                                    .          . ,  .        .       ....
                                                              ^	•»                       1!^^
                                 ..fSiill-'l1,!	lUC	1IR!	iilin^^^^^	,1(il!K^^^	tfHBg^WiligrnMnMffiitaViWW'I'i'.'iMlir"-'"
                                                                                            11	kih.	'	,r	,	,	,-•,,'!	,	,	.,::'., ssi	:',;:!,!	, :	,-
                                                                                                                                    ''lilliilliilliiiil'ililiJIf1!!!!,

!llllllllllilli;i::.;ii:i!llllil]l!Ji IliliiJlllik'1 JPIF Jn I!
                                            Exhibit B-5-1. Estimated Federal Start-Up Costs (1998 dollars)
It
i;"f 	 '!« jiiiiiiiiiiiliii^ii
l,;i;;; 	 JS1
'•;,? 	 ir , 	 ;; 	 
-, 	 , 	 	 ' 	 	 ,» ,;!!'••!• .' /',' i,f v-i •';•",. /"/•>••'*• "•• i1 •'•'••••,••.'•*"•
i 	 }•;!";, 	 Phase II Program Element ' •
Review and File Modified State Programs
Develop Storm Water Goals in
Non-Authorized States
Incorporate 401 Certification Language
Designation of Additional MS4s
TOTAL COSTS6 $46,879
Respondents
'• •:i$er,-: ' •
Year*
9
9
9
9

'. «Burden-:;"?
.Hours- jier:;.
Respondent2
12
100
5
66.6

'/'Hourly:-;-:
.vyLabor ;-''':
'ft'Cosis?''.'
$28.37
$28.37
$28.37
$28.37

Estimated
£'dort?; -.•='.
$3,064
$25,533
$1,277
$17,005

Annual Cost
Over Permit
Period5
$613
$5,107
$255
$3,401
$9,376
                        	••• i in niiiiiniiiii iiiiniiiii nil inn  i ii in 11 ii nil ii HI mill ii  11 in 11 ii   iii 11 ii in 1 111 ii i   i i in 11 in iii i iii i iii i in 111 nil iiiiiiiiniiiiiiiinnniiiini i in n nil nil in ill inn inn inn in in in iiliiiiinin i i nliiinn  iiiiinn iiiiini niniilnin  iiiiinn
                        jejtiuinberjjfRespondents, 9, represents the non-NDPES states and territories that EPA will operate the NPDES
                     i Hourly labor costs are based upon an average annual Federal employee salary of $39,338, divided by 2,080 labor
                     	'	'	'"	"	'	'	u	'"""'""	"	"	""'	verneac! costs (US office of Personnel Management, 199 8'J.
                                                   af the respondents per year, hours per respondent, and hourly -labor costs.
                                                                 3, estimated cost is divided by five years.
                      Numbers may not total due to rounding.

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                                               	I;,!' jut! I'liiillllli I, H'lnli'llNIItU
	,	.,	,	,,	,,	,.	,	„	„	d*uJub!tBr£r-2£	Estimated	Federal	Annual	Costs (1998 dollars)
Jliillll             ,i

f>» 	 ""* 	 N 	 f." 	 |i»" 	 '!'«> 	 	 ' il SBi'' ';l '' •1'"",; i- !i< *'-v:>l',V, ''" 'r'' 	 '', """'"• *|!
2TiM^ftT^tl:-rC->-'i/jIid"^'?i^^.77^;V'''
Phase n Program Activity
Construction Program
Waiver Cert Processing & Review
NOI Processing & Review
NOT Processing
Small MS4 Program
NOI Processing & Review
Report Processing & Review
Annual Total5
Respondents
Per Year1 '-''

1,607
9,104
9,104

357
357

^BurdenJEfonrs'?'
}^-. ..vs.iiiw*',,,:-,,^ -v\,V'*V.r,V':";i1r
per Respondent*

1
1
0.5

0.8
1.6

-•Hourlytliabor'::-'
.,,,,>,,.;,, .r;, . .-!, ~'.y-.. .--,-. -•
<;,;•' ;:-/.sGostr?;'*.:-'

$28.37
$28.37
$28.37

$28.37
$28.37

Estimated
"'^••'Cost4 ••"*•

$45,590
$258,280
$129,140

$8,102
$16,205
$457,318
                    1 The number qf respondents per year was based on the 1990 Bureau of Census data for small MS4s and 8.26% of

                    * Burden hours per respondent were estimated by EPA.
                    3 Hourly labor costs are based upon an average annual Federal employee salary of $39,338, divided by 2,080 labor
jSSSS^E.,'1.'"^!   hours per year and then increased 50% to represent overhead costs (US office of Personnel Management, 1998).
                    4 Estimated cost is the product of the respondents per year, hours per respondent, and hourly labor costs.
     i«^^^  	o	" i' - ':• "i	s Numbers may not total dueto rounding".	
!=^^^^^^^^^^       	'fT'!, B.5wK State Costs
           : ™-F'C:'States and, Territories that are authorized to operate the NPDES grogram will iexperience boft
           "^'1 """'s	an3'aiim3	costs.4  The start-up costs include ^e costs associated with revising
                                                '.       2escrige5g  40 CFR 123.62(5), the incorporation
                                                                                                   	iii'!1	
                                                                                  I/'PIIW1 'sniiiiw^	luniljj^^    	B	r*

                               44 States and Territories authorize  to operate the NPDES program.  No Native American Tribes
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-------
                                          Appendix B
 of Clean Water Act 401 certification language into the general permit, and designation of
 additional MS4s. The annual cost includes the State's responsibility as the permitting authority.
 For the Phase II municipal program, States will be required to will be required to annually
 process the applications, review plans, issue NPDES storm water permits to the municipal
 applicants, and review and file any reports. For construction sites disturbing between one and
 five acres of land, the States will be required to process the NOIs, NOTs, and waiver certification
 form. For small MS4s, States  will be required to process and review the NOI and report.
 Exhibit B-5-3 provides the estimated start-up costs and Exhibit B-5-4 presents the annual costs
 to the State government.
                     Exhibit B-5-3. Estimated State Start-up Costs (1998 dollars)
- - /PhaseH
- .Program Element
401 Certification
State Revision Procedures6
Designation of Additional
MS4s
Respondents
Per Year1
44 '
44
44

Burden Hours
per Respondent2
12
100
66.6

Hourly Labor
v. Costs'",
$26.87
$26.87
$26.87

TOTAL COSTS7
Estimated
-Cost! *
$14,187
$118,228
$78,739

$211,154
Annual Cost Over
.^Termit Period5
$2,837
$23,645
$15,748

$42,230
 1 The number of respondents represents the 44 NPDES-Authorized States and Territories.
 2 Burden hours per respondent were estimated by EPA.
 3 The hourly labor rate for NPDES Authorized States and Territories was based on the average hourly rate for state
 and municipal employees as determined by the US Department of Labor, Bureau of Labor Statistics, Employment
 Cost Indexes and Levels, 1975-1995, Bulletin 2466.
 4 Estimated cost is the product of the respondents per year, hours per respondent, and hourly labor costs.
 5 To determine annual costs over permit period, estimated cost is divided by five years.
 640CFR123.62(b).
 7 Numbers may not total due to rounding.
October 1999
Final Report
                                                                                         B-55
-------
                                                                                  Appendix B
               II III 11  liillll 111 III
                1   ill	
 II	(Mil	I	
  Ill111!	I	
         fi,
                  IP 111
                                                       Exhibit B-S-4. Estimated State Annual Costs (1998 dollars)
' ,-; - - h-^'i. ;-'t*
Phase n Program Element * "/
Respondents
PerYear1
'Burden Hoars
per Respondent2
Hourly Labor „ ,
Costs*:---- -
, 'Estimated,
Cost4
Construction Program
Waiver Cert. Processing & Review
NOI Processing & Review
NOT Processing
17,845
101,119
101,119
1
1
0.5
$26.87
$26.87
$26.87
$479,495
$2,717,068
$1,358,534
Small MS4 Program
NOI Processing & Review
Report Processing & Review
Annual Total5
4,749
4,749
0.8
1.6
$26.87
$26.87
$102,085
$204,169
$4,861,350
                             	I	"I	      	I	I	'"'         	I	
                          1 The number of respondents per year was based on the  1990 Bureau of Census data for small MS4s and 91.7% of
                          total starts that are inNPDES states and territories in E?chib|ts B-2-3 and B-2-4 for qonstruction.
                          2 Burden hours per respondent were estimated by EPA.
                          3 The hourly labor rate for NPDES Authorized States and Territories was based on fee average hourly rate for state
                          anSjnuiupipal employees as determined by^ the US Department of Labor, Bureau of Labor Statistics, Employment
                          Cost Indexes and Cevels,'	l573'-l555,"SinieSm2466.	"	
                          * JEslimated cost is the product of the respondents per year, hours per respondent, and hourly labor costs.
                  ,;~;r:™ Numbers may not total due to rounding.
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                                                                                                               iiiiilr'l	I1' TMW'V i	^''WlWlf l:":'|l|l;|11""' f VV  IPillilfiiiii1'1 "Iiiii	'!i
 liillll I ill 111
                         B-56
                         ii ii i in  IK
                                                                                                                                          October 1999
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          Appendix C




Supplemental Benefits Calculations
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