United States
Environmental Protection
Agency
Office of Water
Program Operations (WH-547)
Washington. D C 20460
December. 1978
Water
SEPA
Report to Congress
Industrial Cost Recovery
Volume III —
Exhibits
Coopers & Lybrand
1800 M Street, N.W.
Washington, D.C. 20036
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THIS PAGE INTENTIONALLY BLANK
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V - EXHIBITS
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LIST OF EXHIBITS
V—i—i Scope of Work, Contract 68_O1_L 8o1
V—1—2 Grantee Survey Questionnaires
V-1—3 Industrial Survey Questionnaires
V 1 L! Nine Questions from Congressional Record, 12/15/77
V—1—5 ICR Advisory Group Membership
V—1—6 ICR Alternatives
V—1—7 Initial Grantee Survey FQrm
V—1—8 Initial Industry Survey Form
V-1—9 Industrial Cost Recovery Regional Meetings — Summary of
Public Comments
V—l—iO Summary of Comments on Draft Report
V-i—il Summary of POTW Cost
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v—i—i
SCOPE OF WORK
Industrial Cost Recovery Study
EPA Contract 68—Oi—’ 8oi
Objective
The primary objective of this study is to examine —— with
full public participation —— the efficiency of, and need for,
the industrial.cost recovery provisions of the Federal Water
Pollution Control Act. This objective shall be met through
work divided into three phases:
• Develop study methodology.
• Compile needed information.
Data analysis and report preparation.
Phase I — Development of Study Methodology
The contractor shall develop a detailed study methodology,
which shall include the following tasks:
• Conduct a preliminary literature survey,
including
— EPA economic impact assessments,
— EPA’s “Cost to Industries data bases,
— Potentially a plicab1e programs, and
— availability of relevant software packages.
• Design preliminary analytic approaches to
examine the issues that shall be addressed in
this study, including
— policy analysis,
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v-i-i
— economic impact analysis,
— benefit/cost analysis,
- sensitivity analysis, and
— sample computations.
• Define basic data requirements, including
— EPA and grantee data available to address
issues that must be examined,
— data that must be obtained from industries
and other sources, and
— secondary data requirements.
• Establish documentation plan, including
— design of survey form
— development of file structure and index, and
— provision for hearing transaction, written
communications and telephone calls.
Establish a public participation plan including
— preparation of information materials,
— communication with relevant “publics”,
— communication with industries and their trade
associations,
— schedule of public meetings, and
— schedule of hearings.
Establishment of the .public participation and education
program shall be given early attention.
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Phase II — Compile Needed Information
The contractor shall develop an information base that will
permit analysis of at least the following issues:
Combined and incremental impacts of user charges
and ICR costs on five industries and on
industries in thirty selected urban and non—
urban communities.
Cost of ICR to industry
— by indus1 ry group,
— by geographic locations (state/regional
levels),
— urban vs. rural,
— as function of prevailing level of
unemployment,
— incremental cost of collecting ICR over that
required for user chargers,
— old city versus new, and
— P. L. 92—500 projects versus P. L. 8 —66O.
• Cost of ICR monitoring and enforcement.
• Benefits to industry from ICR “interest free”
loans.
ICR costs as percentage of total expenses to
industry.
• Comparison of industrial sewerage cost in POTW’
vs direct discharge.
Impact of ICR on selected national industrial
growth patterns.
• Level of business closures caused by ICR.
Impact of ICR on selected inter—industry
competition.
* Publicly Owned Treatment Work
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• Impacts of ICR exemptions, including impacts
related to
• — levels of flow,
— revenues forgone, and
— costs of grantee administration.
• Impact of ICR on
- employment
— export/import balance,
— local tax base,
- water conservation by industry,
— small business, and
— economics of scale,
• Encouragement of cost—effective solutions to
water pollution by ICR.
• Alternative methods of excluding solutions to
water pollution by ICR.
• Extent of ICR cost disparities within Standard
Metropolitan Statistical Areas, or within 50
miles of such areas.
Relative costs of ICR for treatment plants
operating at secondary level of treatment and
plants operating at advanced levels of
treatment.
Alternative methods of achieving ICR parity
where disparities exist.
Local government impacts of ICR:
— revenues produced
— incremental costs
— other issues
• Dry industry exclusion.
Seasonal flowissue.
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• . Alternative bases for inclusion in ICR
(i.e., other than SIC code).
• . Critical review of Appendix A of ICR
guidelines.
• . Analysis of grant payments for system
development.
The contractor shall structure its study methodology to
address, in part, the nine questions posed by Congressman Roberts
during debate on the ICR study amendment (page H12921 of the
Congressional Record, December 15).
The data to satisfy the issues shall be obtained primarily
through extensive survey of not less than 200 approved ICR
systems, a survey of at least 20 communities with potential ICR
problems and between 5 and 8 industries affected by ICR. Not
less than 10 case studies shall be made of communities that hold
high potential of providing valuable insights into the most
significant issues examined. Such studies shall include data
from:
interviews with grantees,
interviews with industries,
• interviews with citizen groups, and
• interviews with public “decision—makers”
The field survey effort, which shall not require 0MB
clearance, shall proceed through the following steps:
• Design data instruments, including
— questionnaire for grantees, and
— questionnaire for industries.
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• Develop interviewer guide that will
— maintain data comparability, and
— ensure ease of data reduction and computer
storage.
• Prepare survey p1-an to
— ensure optimum use of field staff time,
— make optimum use of travel budget, and
— provide data in sequence needed.
Orient field staff by
— providing a field staff package of relevant
materials, and
— conducting a one—day briefing session.
• Conduct pretest of data collecting methodology in
one EPA region, including
— about 20 on—site visits to grantees, and
— telephone interviews with both ICR and non—ICR
cities.
• Modify data instruments, guidance, etc., to
reflect experience gained from pre—test.
Conduct survey of remaining EPA regions,
including
— a minimum of 5 on-site visits to grantees, per
region,
— contact with at least 10 non—ICR cities in
each region, and
— contact by visit or telephone a sample of
industries to be selected by criteria approved
by Project OfCicer.
• Summarize results and reduce data for the
analytic phase of the study.
In addition to data obtained through the field survey, the
Contractor shall make use of other data sources, where
appropriate,, including;
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• EPA industrial economic impact assessments.
• EPA’s UC/ICR study (underway).
• Industry pollution control qio dels.
• Census of Manufacburers.
• Dun and Bradstreet’s DM1 files
• Trade association studies and surveys
The Project officer shall specify which data and operations to
be performed shallbe automated. The resulting data base shall
be given to EPA upon completion of the study.
The contractor shall prepare materials for, and participate
in, public review meetings to be in Washington on or about June
1, and August 1.
Phase III — Data Analysis and Report Preparation
The preliminary analytic approaches developed in Phase I shall
be revised in light of insights developed during the data
collection phase. A sample analytical run shall then be
performed, including statistical tests, sample computation and
the computation of cross elasticities. These shall be reviewed
from a number of viewpoints, not limited to the following:
Sensitivity analysis.
• Analysis of strengths and weaknesses.
Definition of limits of applicability.
Responsiveness to objectives of the study.
The review may result in the deletion of some analyses,
addition of o.thers, augmentation of input data, revision of
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output formats, etc: The Project Officer must approve any
adjustments.
After adjustments have been made, preliminary detailed
analysis shall be conducted using the automated data base
(ADB). The Project Officer shall approve any adjustments.
The contractor shall prepare material for, and participate in,
a public review meeting to be held in Washington on or about
September 1, 1978.
The contractor shall prepare materials necessary to suppport
public hearings, including 100 copies of the first draft final
report, report summaries, visual aids and handouts.
Ten public hearings will then be held. The Contractor shall
attend and participate in each of these hearings.
a. —
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V-1-2
Revised 7/18/78
U. S. ENVIRONMENTAL PROTECTION AGENCY
L ISLATIVE STUDY OF INDUSTRIAL ST RE( VERY
Grantee Thfor’mat ion Form
I. GENERAL DESCRIP1IOpj
A. Identifying Data :
&isiness,
Industry
or Public
State Group Ni ther
(01)’ C&L Reference N nnber: 1.Z4 . • • I I I
(02) Nanie ofGrantee : • . . . . . . • • • . , . . • . • .
(Street/Box #)
03A) Mailing Address , , • , , , . , . , . . . , , , , , . , . ,
038) Mailing Address _ j 11 , , , , , , , , , , , , , , , •
(OIIA) City: j , , , • , , • , , , (0 4B) State: , (05) ZIP Code , • ,
(06) EPA Region (07)’ SMSA • , , , ,
B. Reference Data :
Survey Form Prepared By: _____________________ (C&L Consultant)
On Date: __________________
Encoded On Date:’
By: __________
Grantee Contacts:
Name: ____________________________________ Telephone: (_) ___________
Title: ________________________________________ Date Interviewed:
Name: ____________________________________ Telephone: () ___________
Title: ______________________________________ Date Interviewed:
Name; ____________________________________ Telephone: (___) ___________
Title: ____________________________________ Date Interviewed:
‘To be entered by C&L.
1/15
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C. Brief Description of the Grantee’s Treatment Works:
(08) Age of Sewerage System: :
01 Old (No P.L. 92—500 Funds)
02 = New (Includes/Anticipates 92—500 Funds)
Design Capacity:
(09) Flow , , , MGD (10) SOD I , : lbs.!
day
(11) SS , , , , lbs.! (12) CODI, , , , , lbs./ (l2A) Other , , , , lbs./
day day day
Peak Capacity: Percentage of Design Capacity Presently Used:
(13) Flow ,,UI,:MGD (13A) FlowjL :%
(1k) Treatment Level Prior to EPA Grant _____
(15) Treatment Level Which Will Result From EPA Grant _____
01 Primary O k = Advanced Secondary
02 Advanced Primary 05 Tertiary (AWT)
03 Secondary 06 Other
(16) Treatment Process _____
01. Primary Only
02. Activated Sludge (Including Nitrif’ication)
03. Trickling Filter
Ok. Lagoons/Ponds
05. Chemical (with Primary)
06. Biological Treatment with Chemical Coagulation
10. Chemical for Phosphorus Removal (AWT)
11. Biological Nitrogen Removal (AWT)
12. Physical—Chemical Nitrogen Removal (AWT)
13. Carbon Absorption — (AWT)
1k. Filtration (AWT)
15. Blo Disc
16. ABF
17. Oxidation Ditch
18. Other/Combination — Coement Below
2/15
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Retail: Estimated Number of Customers Served Directly I . 1 (1,0003) (17)
Wholesale: Estimated Number of Customers Served Indirectly , , (l,000a) (18)
Total EPA Grants:
awarded to date
anticipated
Local Share of Capital Costs:
spent to date
anticipated
Other Non Local Sources of Funds:
state — spent and anticipated
county - spent and anticipated
other — spent and anticipated
Total Estisated Cost of Upgrading/ cpanding
Treatment and Collection System — all sources
Method of Funding Local & are of
01 G.O. Bonds
02 Revenue Bonds
03 Special Assessment
$1 ,
_L I I I II I I
Capital Costs: , (27)
= Pay As You Go
05 Other/ Coinbinat ion
(Explain:
(19)
(20)
(21)
(22)
(26)
Other Coninenta:
(1, 0000s)
$,
3,
I
I I I
I I
I
t,
I
3,
I I I
I I I
I
.....
$1
$1-.
V
I I —
(23)
(2i )
(25)
3/15
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II. CX)MBINED AND INC RE2IENTAL IMPACFS USER
CHARGES AND INDUSTRIAL COST RECOVERY CHARGES
ON ALL INDUSTRIES IN GRANTEE’S SERVICE AREA
Total treatment system revenues last twelve months before UC/ICR systems were Implemented.
(Dollars in l,000s)
Sewer Use Fees
Hook—up Charges
Tap—in Fees
Inspection Fees
Assessments
Tax Levies
Other
Total
(Yr/Mo)
PeriodCoverecl
Residential
$,
,
I I
I
lilt
$ 1
I I ii ii I
5I
I
4111111
5,
I 1 11 1 1
$,
liii Ill
— (Yr/Mo)
—t ‘ ‘ (52)
II ,,,
Non—Residential
Total
Total treatment system revenues most recent
first year of implementation.
(Yr/Mo) — (Yr/Mo)
Period Covered , — I . , : (53)
twelve—month period or estimeted revenues for
$1
I
5’
I I
liii
‘
I,,, ,,,
5’
ill,,, I
5’
till,,,
5,
1111111
5’
‘I , ’ , ’,
$,
(Dollars in l,000s)
Non—Residential
,
1
P___j_ j • i
5,
111111.
SI
‘ ‘I ,,,,
‘I I
P1 I I I I I I
s:
SI
I
II
I i
II
5,
I
Ii
I I I I
5,
lIlt,tl
SI
‘I,, ’ , ’
5’
tIll,,
I
5,
‘‘‘Ill,
St
I I lilil
5’
I I
5’
II
II
t
II
I
I
$,
I liii, ,
1111111
5’
till,,,
(28)
(31)
(34)
(37)
( ‘ Ia)
(43)
(46)
(49)
(29) $1
t _ I I I I I I
(32) 5 ’
‘‘‘I’ ’’
(35) $,
_ I _ I I I I I I
(38) s’
III, , , ,
(141) $‘
I I I II I I
(44) $1
1111111
(47) $,
I I I •l I I
(50) $,
I _ I 11111
(30) 5 ’
jill III
(33) 5 ’
I 111111
(36) 5 ’
I I I _l_ I I I
(39) St
II , , , , ,
(‘42) 5’
_ t IIIlIt
(45) 5 ’
‘ ‘‘III ’
(48) 5 ’
‘ ‘I, , ,,
(51) 5 ’
‘I’ll,,
R Ql,I nf4 1
Total
User Charge Fees
Hook—up Charges
Tap—in Fees
Inspection Fees
Assessments
Tax Levies
ICR Charges
Other
Total
(54) ______________
(57) _____________
(60) ______________
(63) ______________
(66) _____________
(69) ____________
(72) ______________
,.T ’ &i I
p1 i i t , I I
‘I I I I I t I I
(55) ______________
(58) ______________
(61) ______________
(64) _______________
(67) -
(7O) 5 ’
‘ ‘III ,,
(73) 5 ’
Il I I Iii
(76) 4 ’
‘‘II, ,,
C79) 5 ’
lIlt III
(56)
(59)
(62)
(65)
(68)
(71)
(71 4)
(77)
(80)
4/15
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III. UC/ICR RATE DATA
Grantee’ a Annual Wastewater Treatment and Collection Costs
Type
of
Expense
1’
0 M& R
U ’
U’
Period Prior to Impimnentat ion
Of EPA—Acceptable UC/ICR
System FY or CY
Period With Implementation
Of EPA—Acceptable UC/ICH
System CT FY
Annual
Average
Revenue Industrial
Annual
•
Revenue
Average
Industrial
Cost $ X 1,000
Method Rate
Cost $ X
1000
Method
Rate Per
‘
.y_I i
‘
• t I
8l)
‘ ‘ 82 ‘ ‘
1. • • i
Per ‘ ‘
J_L.
‘8 ’
‘. J
(8’i)
• ‘
V••i
‘
•, ,
j
‘ ‘ ‘86
‘
‘.
‘ ‘
a a a. I %
1000 Gallon
of Flow
1 Usage 1 = 1,000
Proportional Gallons
To Flow
1 = User
Q arge
, (88)
Poun of
S.S.
2 Usage 2 CCF
Declining
Block
2 Usage Q arge
With Industrial
Surcharge
. • (89)
Poun of
BOD
3 Fixed 3 = Year
Q arge
Year
11 Ad 1 l:$l,0 00
Valorem Assessed
Value
3 = Other
‘ , (90)
t’ouria of
00D
: . , ,: (91)
Fbund of Other
Or
5:Other
Specify:
‘ . (92)
LOOO Gallon
average per
industry
•Aasused deci l
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DEBF
SERVICE
a.
U’
Period Prior to UC/ICR
Period With UC/ICR
Annual
Cost $ X
1,000
Revenue
Method
Average
Industrial
Rate
Annual
Cost $ X
1000
Revenue
Method
Average
Industrial
Rate Per
et
j . , i
i
. ii
(n
‘‘J..
‘ ‘ (oL
‘.7
‘ ‘
Vs I I • I
Per ‘ ‘
.L..J
%7J1
(°6)
‘
Vu ii s
‘
. ii
‘°
.7I
‘ ‘
‘ .7
1
J I I I
1000 Gallon
ofFlow
1 = Usage
Proportional
To Flow
1 = 1,000
gallons
•
1 = User
tharge
, , , (100)
Poun of
S.S.
,
2 Usage
i clining
Block
3=Fixed
Qiarge
Year
2 CCF
3=Year
2 Usage C arge
With Industrial
Surcharge
3=Ad
Valorea
• (101)
Poun of
BOD
,.,,(l02)
Pound of
WD
.
= Ad
Valorem
$1,000
Assessed
Value
Special
Assessment
.
, • : (103)
Pound of Other
Or
5 = Special
Assignment
5 Custciners
5 = Other
‘ , . , (lOle)
I ,oo8 Gallon
average per
industry
6 = Other (Or
Conibination)
6 Other
Specify
• ‘ (105)
1,00 Other
Specify
‘Asatmied decinal
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-J
U’
OTHER
cosT
Period Prior to UC/ICR
Period With UC/ICR
Average
Annual Revenue Industrial
Cost $ X 1,000 Method Rate
$: ,,,., (lo6) j_j(1o7) $:,.,. (1o8)
Per ‘ ‘ (109)
-i--’-
1 Usage 1 1,000
Proportional gallons
To Flow
2 Usage 2 = CCF
Declining
Block
3 Fixed 3 Year
tharge
Year
Ad 11 $1,000
Va lorexn Assessed
Value
5 Special 5 = Cust iers
Assignment
6 Other (Or 6 = Other
Ccxnbination) Specify
Average
Annual Revenue Industrial
Cost * X 1000 Method Rate Per
$:,.. ,. c1lo) IL( 111 )
boo Gallon
of Flow
1 = User , , : (113)
tharge Pound of
S.S.
2 = Usage tharge , , , : (ll )
With Industrial of
Surcharge
3 Ad , (115)
Valorem Pound of
WD
Special ‘ . . : (116)
Assesseent fooD
Average
5 Other - ‘ : (117)
1,000 Gallon
average per
industry
(118)
1,000 Other
Specify
Describe Other Cost
Describe Other Cost
•Ass”ned decimal
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I - .
U I
Total ICR Repayment Period
_____ Years (125)
‘Ca
Period Prior to uciica
Period With
UC/ICR
Average
Annual
Revenue
Industrial
Annual
Revenue
Cost $ X 1,000
Method
Rate
Cost $ X
1000
Method
Industrial
Rate Per
N/A
N/A
N/A
N/A
.
jj (119)
‘ , :
boo Gallon
of Flow
(120)
1 Actual
Usage
, •
Pound of
(121)
,
s.s.
2 = Actual Plus
Reserved
Usage
• , ,
Poun of
BOD
(122)
3 Lump
&im
.
• , , :
Pound of
00D
(123)
4 Other (Or
Cc nbinaticn)
• •
Poun of
Other
Specify
(124)
•Assumed decimal
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IV. ADMINISTRATIVE AND PSDNITORIP )STS OF ICR
What are the annual costs of ICR to bill, collect, and manage investments? Identify
specific cost conponenta and levels of activity, including the start—up costs associated
with designing and linplmnenting ICR systmim (Identity EPA ‘ant funding and local share
of systea design efforts to include costs such as public hearings and consultant charges.)
Which annual administrative (billing, collecting, investing, etc.) costs would be
eliminated if there wore no requirement for ICR.
Administrative Costs
(in Whole Dollars)
— Start—Up Costs
EPA Grant
Other External
— Ongoing Operating
Costs (Annual)
— Eliminatable Costs
(If ICR wore eliminated
but UC maintained)
tbnitoring and Enforcement
Costs
— Prior to UC/ICR
— With UC/ICR
— Eliminatable Costs
(It ICR were eliminated
but UC maintained)
9/15
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V. EFFECTS OF ICR ON LOCAL INDUSTRY
Did any industry in the grantee’s service ares, due to the costs of ICR:
• Close j.j (1142) 1 yes 2 no
• Reduce Production jj• (143)
• Decide Not to t’bve Into the Grantee’s Area jj (1414)
• Relocate To a Different Service Area jj (145)
• Cut back on Expansion jj• (146)
If the answer to any of the above questions is yes, include additional information
on the type of industry, size, nucber of jobs lost, level of productionlost, if
applicable, the area the industry chose for relocation, amount tax revenue and other
revenue lost to the grantee or other governmental units.
4 Nucber Tax Moved To:
Primary Digit of Jobs Production Revenue
— Industry Activity SIC - Lost Lost Lost ($1000) City State
1
2
3
14
5
6
.z_
8
-
9
.0
10/15
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V I. IMPACT OF ALTEi .NATIVE ICR INDUSTRIAL EX IFrI0t
This question addresses several topics, as fo1low :
• Impact of the current definition of industry
• Impact of excluding all sanitary waste from ICR
• Impact of eliminating industries based on varying levels of flow from 5,000 to
100,000 GPD.
• Impact of eliminating industries based on varying dollar aia unts of ICR charges
from $10 to $500.
Two schedules will be produced to answer this queestion. The first schedule will include
a list of all. current industries C and the definition used) with flows, loadings, and
estlssted billings. The second schedule will list all users discharging onre than 5,000
GPD and whether discharge is sanitary or process waste, with estimated loadings for
process waste discharges.
Present Number of ICR Customers , , , : (l’ 7)
Number of ICR Customers if New Definition Applied . . (1Z48)
Table of Large WaLer Users
Name
Primary Activity
sic
Annual
(in
Discharge
Gallons)
ICR Bill
Estimated / Actual
11/15
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VII. IMPACrS (F ICR ON SEASONAL USERS
Are there any seasona ]. flow industrial users discharging to the P01W?
• the seasonal users
• flows and strengths
• days of operation
• method of charging ICR
If yes, cowplete the following table:
Describe method of charging ICR to Seasonal Users
a. -
_____ (l 9)
01 yes
02 no
Seasonal
1 1ow
Length ln
As%ofTotal.
User Name
Primary Activity
Flow
BOD
SS
Working
Days
Annual Flow
12/15
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VIII. IMPACT OF ICR ON WATER Q)MSERVATION
To answer this question, contact those in the group of’ 10 largest users lthat the grantee
identities as having reduced consumption. Interview these users to determine it ICR had
any impact on water oonslsnption. Other factors that any have led to a reduction are
increased potable water costs, UC increases, or drought conditions.
Has there been any ICR—attributable reduction in water cynsumption? f : (150)
01 = yes
02 no
If yes, complete the following table:
User Name
Primary Activity
SIC
Annual
Previous
Flow
Annual
J cent
Flow
ICR
Bill
Water
Sewer
13/15
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IX. IMPACT OF ICR ON EXX)NOMIES OF SCALE
IXJRIM] DESIGN AND COt TRUCTION
During plant design or construction, did any industries include in the 201 Plan not
participate in the publically_owned treatment works? _____ (151) 01 yes 02 no
If yes, are their loadings greater than 10% of P01W capacity? j (152) 01 — yes 02 = no
If yes, is the industry still in business in the PON’s service area? : (153) 01 = yea 02 no
If yes, is the industry’s waste coinpatable with the P01W? _____ (151) 01 = yes 02
If yes, complete the following table:
Additional Comments:
Impact on User—Charge for P01W Customers:
14/15
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)Z. EVALUATION OF APP 4DDC A TO MCD—45
FEDERAL GUIDELINES — INDUSTRIAL ( ST
REQ)VERY GUIDELINES , TITLED M DFZCRIP—
TICN OF INDUSTRIAL (X)ST RE( )VERY S!ST I”
What problems did the grantee experience in completing Appendix A?
What rcomsendatjona i u1d the grantee make as an alternative to Appendix A?
15/15
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Revised 7/18/78
I. z rrim c DATA
U. S. D(VIRCNMENTAL PROTECTION AG 1CY
L ISLATIVE STUDY OF INDUSTRLAL CX)ST RE VERY
Industrial. User Swvey
V-1-3
Although C&L will not dis-
close individual company
data in the report, any
data submitted is subject to
disclosure with the Freedom
of Information Act if so
requested.
& sir.ess,
Industry
or Public
State Group Nissber
(01)’ C&L. Reference Nu ber: ‘ 3. 141 I
I I I I I I I I I I
(02)’ Survey Class: ‘ ‘ 01 Visit 02 = Telephone 03 Other
III
(03) C00pany Name:
1111 111111 I I I I I I 1111 I I I I I I I liii
(014) Plant or Division: • , • , • , , , ,
I I I I I I I I I I I I I
(05) Street Address
I I I I I I I I I I I I I I i i • • • • . , , • , , •
(06) Street Address
• I I I I I I I I I • • p • • , • • • • • , • •
(07) City: ‘ ‘ (08) State: ‘ ‘ (09) ZIP Code ___________
I I I I I I I I I I I I I I
I I I
1 _ I
(10)’ EPA Region ‘ ‘ (11)’ SI6A ‘ ‘ (12) Plant SIC _________
I I I
I I I I I I I I I
Name or Th . b1ic1y Owned Treatment Works (POT.4) Used:
(13)’ PON Identifier ____________
I I I II I I
Ccxupariy Contact Name: _____
Title: ______
one N ber: (_)
C&L Interviewer: __________
Interview Date: ___________
F2lcoded by:’ _____________
‘To be entered by C&L..
COOPERS & LYBRAND
teOC H STREET. H.W.
WASHINGTON. D.C. 20038
Date:
1/7
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II. CHARACTERISTIC DATA ABOUT PLANT
Be tore
Adoption
of UC/ICR
Syst
Sabsaquent
to Adoption
of UC/ICR
Syst
Teaz’
(1 l) ‘
I I I I I
(15)
II I I I
I
0 of Beployees at Location
(16) ‘ ‘
• I I I II I I I
(17)
p • p • •
Level of Production
($ Value of Shi aents
FOB Plant, After Sales
(18A)$’ ‘
I, 1111111
(18B)$
111 11111
Discounts)(and units -
See Tranmeittal Letter)
(18C) ‘
I P I I I P I I I
(18D)
I I I I I I I I
Total of All Utility
Expenses (Excluding
Sewege)
(19) 5’ ‘
I I P P P P I P
(20) 5’
P P P P P
Annual Municipal tharges For Wastewater Treatment (1 ,000s)
0&M Costs (User O arges)
(21) 5’ • • , ‘
• P I I I P
(22) $‘
I I P I I P I I I
Capital Recovery (ICR)
N/A
(23) 5’
I I P P I I It I
Local Debt Service
(2 14) $I ‘
I I I I P I I I I
(25) $1 I
I I I I I I P P I
Ad Valorem Taxes Applicabi’
to Wastewater Treatment
(26) 8’ ‘
, I P lIP IPI
(27) $‘
P PlI P
Other Sewer Q arges
(Describe below)
‘
(28) 8’ ‘ ‘ ‘ ‘ ‘ ‘ •
(29)5’
p , , , , , ,
Total Muncipal Sewage
Costs
(30) 8’ ‘
I P P IIIIP
(31) 5’
PIllI PP
Coim nts:
2/7
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III. D4PACT OF UC/ICE
1. (A) Are your sewer charges expected to increase drseatically in the
near future?
jj (32) 1—yes 2=no 3:d ’t%a%ow
(8) It yes, in what year _____? I scribe in your owe words what
the new charges will be and the reasons lbr this increase.
(It possible, abow capital charges and grant repayment charges
separately fl operation and • aaintanance charges.)
2. (A) As a result of increased weste ter treatment costs, has this
plant:
a. Reduced the quantity of products shipped or shifted pro..
duction to other plants?
i_i. (33) 1—yea 2:no
b. It yes, in what year? : • : (3 )
c. Q rtailed expansion plans? jj (35) 1 yes 2 no
d. It yes, in what year? , , [ (36)
a. It yes to either a or c, above, why? j•j (37)
1 = lack of m .micipal treatnent capacity
2 lack of self—treatment capacity
3 increased municipal sewerage costs
increased aelf-treatieent coats
• 5 = Siç iticantly lower wastewater treatment costs experienced
by cospeting or subsidiary plants in the sane general
geographical area
6 = Other, explain ___________________________________
Cc nts: _____________________________
3/7
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3. (A) Is there a reasonable probability that this plant will be closed?
j_j (38) 1—yes 2:no 3 don’t iou
(B) Ifyes,in atyear? Lu (39)
(C) If yes, Will at ter treatment costs be a s1. iitioant factor?
Li. (‘10) 1-yes 2Rrm 3sdcn’t ow
‘1. In-pin_nt s,diticat ion costa (not pretreatment ar self-treatment):
(A) at do you estimete the capital investment or replaomeent value
of these in—plant andifications to be?
‘ ‘ ‘I ,’. ,’
(B) at percent reoduct ions i re achieved?
Flow (112)
DOD 1% (‘13)
: :% (‘$4)
TSS j 1 J% (‘45)
Other : . S (146)
If other, specify: _________________________________________
(c) ascribe in your awn words the in-plant andificat ions, including
changes in processing equipeent, med. at this plant during the
period of time (ron 1973 to the present primerily to achieve flow,
DOD or TSS reductions:
4/7
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5. (A) Is co sideri’g havir g th .s pant di e a e fr the
mun:c aj svst arid having the plant operate Its won self—
treatit ent system?
j j (47) 1—yes 2:no 3dcrn’tI ow
(8) It yes, is it due to: jj (48)
1 incre.a.s ts 1cipa1 se .age tha.’-ges
2 = increased pre-treati ent costs
3 = co bir)atjon of the above
4 other, explain:
PJ ZTREATh T COSTS
1. at do you estimate your pretreatmant cost to be?
(A) capital cost . . (49)
(B) arLrJa.l op ration and r a1r’tenance (includ ’ g labor,
e1ectric ty, che:n.icals, s1 ige disposal, ]and taxes,
mo 1toring arid reporting requlrelDent .s) . . . ‘ . :
(C) a1 depreciation , . (51)
C rn ent s:
V Si -iPDa JT s’s
1. In your o n words, des . ribe your seIf—treatr nt syst i or attach a dia ras of it.
1 / 7
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2. ‘—at s tbI t ‘ i’. C ’3t C! thL t2 1t !rt. , 1- , 1u 1r€
l trid p.i -5, i C3 ç’i SI E 3tO 5, ?pr r.klE 3, t&r k2, etc.?
c1. ie all th—plalt r .difiC It1Ofl p t. zt c.- 9ts - s y d1 C 55ed.
,_,_ _I _i
3. D 1 ! In y r o h:J t9s lf—tr at! lt ‘ -S’s :d.
14• (A) Is tr .ag neit C i :1ng d 5 ntthUth !e1f—treatrn ?.1t arid having the
tr !a .Ed t’ .’ a C - .1 ste -3tef tr . .nt fac1 tyi
Jj 53) 1—i’ S 2:rio 3=ao ’t C’ SJ
(B) It yes, ex iath: -—
5. ?iat s t e Est.. 3.e 1r?’ i c’!t O eir— ’ n t s £v t. iL? bclu5e
i1 r— ’.a fl pe:-z.at c s:s
(A) C : .:r _‘t ‘—:‘ (:r’ ‘t.:-,
eect - tV, c—- . id
ta S, arid an: re:’ th rj rltS) .. , ; (5L )
(B) ( 5 )
-------
(C) Other, specify • . , , (56)
CD) Ibtal • (57)
CE) O nts: __________________________________________________________
6. at is your self— treatment now capacity? , , , , , , GPD (58)
VI. OPINION QUESTIO?
1. (A) you believe that you have lost business to substitute goods (that is, not
to oo petitors produc .ng sJ.a.ilar goods, but producers .nufacturing substitute
prodocts) because of price increases caused to increased stewater treat nt
costs?
jj (59) 1—yes 2:no 3 don’t ow
(B) If yes, what is the estinated av is t of business lost?
, (60)or, :%ofproduction (61)
(C) If yes, to what industry have you loot business?
2. T you believe that you have becciiie less cczipetitive with foreigh goods because
of increased wastewater treatsent costs?
jj• (62) 1—yes 2 no 3:don’tknov
3. 1 ve the UC/ICR regulations been explained adequately for you? , (63)
l:yes 2=no
7/7
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V—i—k
Congressman Roberts’ Questions
(Congressional Record, 12/15/77)
INDUSTRIAL COST RECOVERY
It has long been the intent of Congress to encourage partici-
pation in publicly owned treatment works by industry. The
conferees are most concerned over the impact the industrial cost
recovery provision of existing law may have on industry partici-
pation in these public systems. Accordingly, the Industrial Cost
Recovery Study, section 75, has been incorporated in the confer-
ence report, and EPA is encouraged to submit the results of the
study as soon as possible so that Congress can take action on any
recommendations that are forthcoming.
It is expected that the administrator will consult with all
interested groups in conducting this study and that the study
will address at least the following questions:
First. Whether the Industrial Cost Recovery program (ICR)
discriminates against particular industries or industrial plants
in different locations, and do small town businesses pay more
than their urban counterparts? What is the combined impact on
such industries of’ the user charge and ICR requirements?
Second. Whether the ICR program and resultant user charges
cause some communities to charge much higher costs for wastewater
treatment than other communities in the same geographical area?
(Some communities have indicated that disparities in ICR and user
charges affect employment opportunities.) Whether a mechanism
should be provided whereby a community may lower its user and ICR
charges to a level that is competitive with other communities in
order to restore parity?
Third. Whether the ICR program drives industries out of
municipal systems, the extent and the community impact?
Fourth. Whether industries tying into municipal systems pay
more or less for pollution control than direct discharges?
Fifth. Whether the ICR program encourages conservation, the
extent and the economic or environmental impact?
Sixth. Whether the ICR program encourages cost effective
solutions to water pollution problems?
Seventh. How much Févenue will this program produce for
local, State and Federal governments, and to what use will or
should these revenues be put?
Eighth. Determination of the administrative cost of the
program, additional billing cost imposed, costs associated with
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the monitoring of industrial effluent for the purpose of calcul-
ating the ICR charges, ancillary benefits associated with the
monitoring of industrial effluent, procedures necessary to take
account of changes in the number of industries discharging into
municipal plants, and the impacts of seasonal or other changes in
the characteristics and quantity of effluents discharged by indi-
vidual industries?
Ninth. Whether small industrLes should be exempted from
ICR? How should small be defined? Is there a reasonable floor
that can be establishecI- for ICR based upon percentage flow?
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V-1—5
Environmental Groups
ADVISORY GROUP
INDUSTRIAL CDST RECOVERY STUDY
Mr. Robert Axeirad
Izaak Walton League
1800 N. Kent Street
528—1818
Mr. Jim Banks
Natural Resources Defense Council
917 15th Street, N. W.
Washington, D, C. 20005
737—5000
Mr. Richard Stroud
Sport and Fishing Institute
608 13th Street, N. W.
Washington, D. C. 20005
737—0668
Mr. Blake Early-Vicki Leonard
Environmental Action
1 346 Connecticut Ave., N. W.
Washington, D. C. 20036
833—18145
Ms. Rhea Cohen
Sierra Club
330 Pennsylvania Ave., S.E.
Washington, D. C.
547—1 1414
Mr. George Coling
Urban Environment
1302 18th Street,
Washington, D. C.
466—6040
Industrial Groups
Mr. Peter Sullivan
Wildlife Federation
1412 16th Street, N. W.
797—6800
Mr. Clem Rastatter—Marissa Roch
Conservation Foundation
1717 Mass. Ave., N. W.
Washington, D. C. 20036
797-J4 300
Mr. Rafe Pomerance
Friends of the Earth
620 C Street, S. E
Washington, D. C. 20003
5143—4312
Mr. Brent Blackwelder
S Environmental Policy Center
317 Pennsylvania Ave., S. E.
Washington, D. C. 20003
547—6500
Mr. Larry Silverman
Clean Water Action Project
13141 0. Street, N. W., Suite 200
Washington, D. C. 20005
638—1196
Mr. Jeff Conley
National Environmental Dev. Assoc.
#3 National Press Building
Washington, D. C. 200145
638—1200
Ms. Susan Boolukus—Mr. Richard Frank
American Frozen Food Institute
1700 Old Meadow Road, Suite ‘T(DO
McLean, Virginia 22101
821—0770
Mr. Jack Cooper—Mr. Steve Rosen
National Food Processors Assoc.
1133 20th Street, N. W.
Washington, D. C. 20036
331—6968
Conference
N. W.
20036
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Industrial Groups (Con’t )
Mr. Austin Rhoais
Milk Industry Foundation
and Ice Cream Product Assn.
910 17th Street, N. W., Suite 1100
Washington, D. C. 20006
652_z LI2o
Mr. Bill Roenigk
National Broiler Council
1155 15th Street, N. W.
Washington, D. C. 20005
296—2622
Mr. Don Gerrish—Mr. Perry Fischer
American Baking association
2020 K Street, N. W.
Washington, D. C. 200 6
296—5800
Government and Miscellaneous Groups
Mr. Drew Davis
National Soft Drink Association
1101 16th Street, N. W.
Washington, D. C. 20036
833—2L 5o
Mrs. Robbie Savage—Mr. Louis Gi
National Assoc. of Manufacturer
1776 F Street, N. W.
Washington, D. C. 20006
331—3908
Mr. Jeffery H. Teitel
American Paper Institute
1619 Massachusetts Ave., N. W.
Washington, D. C.20006
332—1050
Mr. Ron Linton
Association of Metropolitan Sewage
Agencies
1015 18th Street, N. W., Suite 200
Washington, D. C. 20036
659—9161
Ms. Mary Reardon
National Association of Counties
1735 New York Ave ., N. W.
Washington, D. C. 20006
785—9577
Mr. Mike Pawlukiewicz
National Association of Regional
Councils
1700 K Street, N. W.
Washington, D. C. 20006
296—5253
Ms. Barbara Bassuener—
Mr. Robert Perry
Water Pollution Control Federa
2626 Pennsylvania Ave., N. W.
Washington, D. C. 20037
337—2500
Mr. Richard Mounts
League of Cities
1620 I Street, N. W.
Washington, D. C. 20006
293—7580
Mr. George Bartlett
American Public Works Assoc.
1776 Massachusetts Ave., N. W.
Washington, D. C. 20036
833—1168
a..
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October 10, 1978
EXHIBIT V—1—6
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
INDWTRIAL COST RECOVERY STUDY
PRELIMINARY COMPILATION OF POSSIBLE STUDY ALTERNATIVES
NOTE: This is a preliminary listing, prepared for discussion purposes only. It should not be construed as a final or comprehensive
list of possible alternatives. Coopers & Lybrand neither endorses nor rejects any of these alternatives at this time.
ADVANTAGES
— Eliminate complaints fran grantees
that ICR is not cost effective and
difficult to monitor and administer.
— Eliminate complaints from industry
that ICR is “double taxation” and adds
an unfair economic burden.
— Eliminate inconsistency in ICR charges.
DISADVANTAGES
— Without some control over the design
parameters allocated to industry,
abolishing ICR may encourage grantees
to plan and construct treatment works
that are larger than necessary.
— Eliminate ICR revenues returned to
the Federal Government.
2. Base grant funding for eligible
project costs (including industrial
capacity) on a sliding scale, fund-
ing current needs at 75% and re-
ducing the federal share of total
project costs and grantees plan treat-
ment works larger than current needs
indicate. ICR would be based on
the current regulations.
— Encourage more front end planning,
reducing the amount of excess capacity
design and constructed.
— Encourage industry participation in
planning and identifying treatment
works needs.
— May not be cost effective when
design treatment works for large,
rapidly growing areas.
— Will increase the total local share
of costs for grantees building trear—
ment works larger than currently
required.
3. Base grant funding for eligible
project costs on a sliding scale, as
in the previous alternative, funding
current domestic needs at 75% and re-
ducing the federal share of total
project costs as grantees plan treat-
ment works larger than current needs
indicate. This alternative differs
greatly fran #2 because eligible project
costs would include current needs
for domestic and commercial wastewater.
There would be no funding for industrial
capacity. ICR would be eliminated because
there would be no federal grant allocable
to industry.
— Eliminate grantee complaints that
ICR is not effective and difficult
to monitor.
— Eliminate complaints from industry
about “double taxation” and the
added costs of ICR.
— Eliminate costs associated with
iinplmeenting and monitoring ICR
for both grantees and EPA.
— Encourage better facility planning
— Increase local share of project
costs. These added costs may be
passed through to industrial users
and would exceed ICR costs because
there would be no Federal funding
for industrial capacity.
ALTE .JATIV E
1. Abolish ICR
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Page 2
ALTERNATIVE
14• Q arge ICR on treatment works
only, eliminating ICR charges for
interceptor sei rs.
5. Base industry’s share of the
federal grant on an incremental cost
basis rather than a proportional
cost basis, as is now the case.
6. Allow the costs of constructing
industries portion of the treatment
works to be granted eligible based
on grantee’s option. If industry’s
share is elected’ to be grant eligible,
industry would be required to pay
ICR. If the grantee used alternative
sources of’ funding for the industrial
share there would be no ICR requirement.
Grant eligibility could be either
proportional or incremental.
7. Establish a uniform ICR rate,
on a:
—National basis
—Regional basis
—State basis
—Sl EA basis
The rate could be modified based
upon a urn. form adjustment for treatment
level, treatment types, level of’ discharge
from the R)Th .
ADVANTAGES
— Reduce administrative work grantees
must often perform to identify and
allocate costs to industrial users
of’ specific interceptors, especially
on large segmented projects.
- Allow industry to receive the
benefits of. economies of scale
using an incremental cost basis.
- Allow grantees to make ICR a local
option, depending on alternate sources
of funding for the industrial portion
of the treatment works.
- Encourage industry participation in
planning and needs identification.
— Reduce inconsistencies of ICR
rates, depending upon level of
uniformity adopted.
DISADVANTAGES
— Reduce ICR revenues returend to
the Federal Government.
- May be difficult to determine
the incremental costs of construction
industry’s share of the treatment
works.
— I dustry may still complain of
“double taxation” and unfair economic
burdens based on geographic location.
8. Establish “circuit breaker”
ICR exemptions based on:
—Extraordinary circumstances
—Local economic conditions
—Industry group
—Geographic area
—Level of pollutant discharge
—Dollar level of ICR payments
— Reduce the number of industries
required to pay ICR.
— Allow flexibility based on
special circumstances.
— May be difficult to develop and
administer.
— Will result in inconsistent
ICR charges based on special
circumstances.
— May be difficult to develop and
administer uniform rates.
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Page 3
ALTERNATIVE
ADVANTAGES
DISADVANTAGES
9. Allow a tax credit for ICR
payment.
— Eliminate industry ccxnplaints
concerning “double taxation.”
— May be difficult to administer.
— Reduce revenue to the Federal
Government.
10. Allow tax credits for pretreat-
ment costs to include both capital
and maintenance costs.
- Encourage industry to pre—treat
wastes.
— May be difficult to administer
— Reduce revenue to the Federal
Government.
11. Return to the requirements of
P. L. 9’ —66O, abolishing ICR.
12. Abolish ICR and require that
local share of project costs be re-
covered through proportionate user
diarge.
— Eliminate ccmplaints of inequitable
charges of industries discharging to
ION’s funded under different programs.
— Reduce administrative burden on
grantees.
— Achieve equity in method of establish-
ing rates, if thoroughly and consistently
rionito red.
— Reduce revenue to the Federal Govern—
‘sent.
— Reduce grantees flexibility in
designing rates.
— Increase grantees administration of
User Charges.
— Increase costs to large users where
grantee currently uses a silding scale
rate.
— May require major ohangçs in bond
covenants where grantees fund the local
share through revenue or general obligation
bonds.
13. Add an interest component to
current ICE requirements.
— Increase industry participation
in facility planning by increasing
potential costs to industry.
— Eliminate the subsidy or “interest
free loan” component associated with
fLn ding industrial capacity.
— May encourage industry to seek other
alternatives to discharging to a
PON, possibly increasing both capital
and 0 & M costs for those users
remaining in the system.
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Page 4
ALTERNATIVE
14. Extend the ICR noratorium.
15. Maintain ICR in its current form.
16. Require letter of caumiteEnt (as
contract) fran industrial users of
POTW’s i ten P0Th is sized.
ADVANTAGES
— Postpones the date for making a
final decision on ICR.
— Requires no administrative or
regulatory changes
— Encourages nere precise planning.
DISADVANTAGES
- Postpones the date of making a final
decision on ICR.
— Eliminates none of the problems currently
ascribed in ICR by grantees and industry.
- Canmits industry for a longer term
contract than nest businesses are
willing to camait themselves.
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EXHIBIT V—1-7
U.S. ENVIRONMENTAL PROTECTION AGENCY
LEGISLATIVE STUDY OF INDUSTRIAL COST RECOVERY
Ref. # 1 4
Page No. 1 of
Engagement 0 11 255O_I 6 6O
Grantee Information Form
I. GENERAL DESCRIPTION
Name of Grantee
Street Address
State _________________ Zip Code ________ EPA Region ___________
SMSA ___________ Old System _____________ New System
Prepared by __________________ Data Input Form Prepared
by ________________ on
Grantee contacts:
Name _____________ Tel. No. Date Interviewed
Name _____________ Tel. No. Date Interviewed
Name _____________ Tel. No. Date Interviewed
Brief description of the grantees treatment works
Design Capacity: Flow MCD BOD _______lbs SS _______lbs
Treatment Level ______________
Treatment Pxocess ______________
Total Costs of upgrading or expanding treatment works
Total EPA grant funds ______________
Other Sources of Funds _____________
Local share of costs _____________
Method of funding local share _____________
Other Comments:
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Page No. 2 of
II. COMBINED AND INCREMENTAL IMPACTS OF USER
CHARGES AND INDUSTRIAL COST RECOVERY CHARGES
ON ALL INDUSTRIES IN GRANTEE’S SERVICE AREA
Total treatment plant revenues last twelve months before UC/ICR
systems were- implemented.
Period covered
Residential Non—Residential Total
Sewer Use Fees
Hook—up charges
Tap in fees
Inspection fees
Assessments
Tax Levies
Other
Total _______________
Total treatment plant revenue for most recent twelve—month period
or estimated revenues for first year of implementation.
Residential Non—Residential Total
User charge fees
Hook—up charges
Tap in fees
Inspection fees
Assessments
Tax Levies
ICR Charges —.
Other
Total
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Page No. 3 of
III. UC/ICR RATE DATA
Rates Prior to adopting UC/ICH Systems
Effective Date ___________
Describe in detail grantee’s billing system prior to DC/ICR.
Include information on the rates and methods of collecting revenue
to pay local debt service, OH&R, other costs, and billing units.
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Page No. 14 of
Current or Proposed UC/ICR rates.
Effective date _____________
Describe in detail the grantee’s UC/ICR revenue systems.
Include data on:
Debt service charges
User charges for
• . Flow
SOD
Suspended Solids
Surcharges
ICR Rates for
Flow
BOD
Suspended Solids
• Other Charges
• ICR cost recovery period _______years.
Include detailed budgets, and cost allocations to support the rates
developed.
a. -
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Page No. 5 of
IV. ADMINISTRATIVE AND MONITORING COSTS OF ICR
What are the costs of ICR to bill, collect, and manage investments?
Identify specific cost components and levels of activity, including
the start—up costs associated with designing and implementing ICR
systems (Identity EPA grant funding and local share of system design
efforts to include costs such as public hearings and consultant
charges).
.Which administrative (billing, collecting, investing, etc.) costs
would be eliminated if there were no requirement for ICR.
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Page No. 6 of
Administrative and Monitoring Costs Continued
What were the grantee’s monitoring and enforcement costs prior to
t iC/ICR? Identify specific cost components and levels of activity.
What are the grantee’s current or estimated monitoring and enforce-
ment costs for UC/ICR systems? Identify specific costs components
and level of’ activity.
Keeping in mind that monitoring and enforcement are required for User
Charge Systems also, what specific monitoring and enforcement costs
would be eliminated if there were no requirement for ICR?
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Page No. 7 of
V. EFFECTS OF ICR ON LOCAL INDUSTRY
Did any industry, in the grantee’s service area, due to the costs
of ICR:
• Close
• Reduce production
Decide not to move into the grantee’s service area
• Relocate to a different service area
If the answer to any of the above questions is yes, include additional
information on the type of industry, size, number of jobs lost, level
of production-lost, if applicable, the area the industry chose for
relocation, amount tax revenue and other revenue lost to the grantee
or other governmental units.
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Page No. 8 of
VI. Impact of Alternative ICR Industrial Exemptions
This question addresses several topics, as follows:
Impact of the current definition of industry
Impact of excluding all sanitary waste from ICR
Impact of eliminating industries based on varying levels
of flow from 5,000 to 100,000 GPD.
Impact of eliminating industries based on varying dollar
amounts of ICR charges from $10 to $500.
Two schedules will be roduced to answer this question. The first
schedule il1 include a list of all current industries (and the
definition used) with flows, loadings, and estimated billings. The
second schedule will list all users discharging more than 5,000 GPD
and whether discharge is sanitary or process waste, with estimated
loadings for process waste discharges.
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Page No. 9 of
VII. IMPACTS OF ICR ON SEASONAL USERS
Are there any seasonal flow industrial users discharging to the POTW?
If the answer is yes 1 identify:
the seasonal users
flows arid strengths
days of operation
method of charging ICR
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Page No. 10 of
VIII. IMPACT OF ICR ON WATER CONSERVATION
To answer this question, contact those in the group of 10 largest
users that the grantee identifies as having reduced consumption.
Interview these users to determine if ICR had any impact on water
consumption. Other factors that may have led to a reduction are
increased potable water costs, UC increases, or drought conditions.
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Page No. 11 of
IX. IMPACT OF ICR ON ECONOMIES OF SCALE
DURING DESIGN AND CONSTRUCTION
During plant design or construction, did any industries choose not to
participate in the publicly—owned treatment works? If’ the answer is
yes, identify:
• specific industries
• estimated riows
• any cost increases due to lost economies of scale.
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Page No. 12 of
X. EVALUATION OF APPENDIX A TO MCD— l5
FEDERAL GUIDELINES — INDUSTRIAL COST
RECOVERY GUIDELINES , TITLED “DESCRIPTION OF
INDUSTRIAL COST RECOVERY SYSTEM”
What problems did the grantee experience in completing
Appendix A?
What recommendations would the grantee make as an alternative
to Appendix A?
a. -
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EXHIBIT V—1—8
U.S. ENVIRONMENTAL PROTECTION AGENCY
LEGISLATIVE STUDY OF INDUSTRIAL COST RECOVERY
Ref. # ill
Page No. 1 of
Engagement # 114 2550 146 —60
Industrial User Form
On site visit Telephone survey
Industry _______________________ SIC Code _________________________
Contact Name _________________ Date Interviewed _______________
State _________________________ EPA Region _____________________
SMSA _________________________ Business Size __________________
POTW Name ____________________ POTW Number ____________________
Prepared by __________________ Data Input Form prepared
by ________________ on ________
Combined and Incremental Impact of UC/ICR
From the grantee’s billing records establish the total charges for
the individual industry for the twelve—month period prior to adopting
to UC/ICR, to include:
• amounts billed for O&M, debt service, other charges
• billing units (flows and loadings)
• periods billed
• time period covered.
For the last twelve months of billing UC/ICR (projected first year
charges if system not implemented) total charges for the industry by
the elements described above. Confirm these charges with industry.
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Page No. 2 of
From industry interviews determine the units of industrial activity
for the two periods billed.
From industry, determine common expense statistics for the two
periods billed.
Are there any similar industries within the SMSA or 50 miles that are
.payin significantly different ICR rates?
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Page No. 3 of
General comments from Industry concerning the impact of ICR.
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V-l-9
Industrial Cost Recovery Regional Meetings
Summary of Public Comments
-------
Industrial Cost Recovery Public Meetir
Region I
John MeCormack Post Office Building
Boston, MA
10 AM October 22k, 1978
EPA - Lester Sutton, I, Water Programs Division Director
— John Gall, I. UC/ICH Speoi list and EPA Washington
C&L — I. Mikul Townsley—
Myron Olstein
91 Attendees:
George D. Gallagher
Metro. Dist. Corn.
Boston, MA
Michael S. Karison
Arthur Young & Co.
Boston, MA
Paul D. Weisman
LEA
Boston, MA
Robert Burke
D EQ E
Boston, MA
Robert F. Dunning
Anderson—Nicholson
& Co. Inc.
Boston, MA
Paul Walker
Hollingsworth U Vose Co.
E. Walpole, MA
Richard S. Hersey
MAPC
Boston, MA
Paul Taurasj
DPWPC
Boston, MA
John O’Brien
Mass. DW. of
Control
Boston, MA
John J. Ostrosky
Metcalf & Eddy Engineers
Boston, MA
James C. Dakin
Town of Westwood
Westwood, MA
Stanley Linda
DWPC
Boston, MA
L. Blank
Metro. Dist. Corn.
Boston, MA
Wesley Ehrenzeller
D PW
Attleboro, MA
William J. Collins
Atlantic Gelatin Co.
Woburn, MA
Mimi Feller
Staff of’ Senator Chaffee of RI
Margaret Heckler
Congresswoman, Mass.
10th District
Makram H. Meggli
D.P.W.
Woonsocket, RI
Duane E. Sheeler
Acusknet Co.
New Bedford, MA
Kenneth Gillum
Goodyear Tire & Rubber Co.
New Bedford, MA
Karl Spilhaus
Northern Textile Assoc.
Boston, MA
Philip Murray
New Bedford Area C of’ C
New Bedfore, MA
Hedley Patterson
D PW
Woonsocket, RI
Canton Viveiros
Mayor
Fall River, MA
Water Pollution
-------
George t. Darmody
Industrial Agent
Fall River, MA
John E. Walker
Greater Portland Regional
C of C
Portald, ME
Martin R. Haley
Sewer Commission
Templeton, MA
Anna M. Richard
Town of Templeton
Baidwinville, MA
Patrick Harrington
United Merchants
Fall River, MA
Ralph Guerriero
Swan Finishing C.
Fall River, MA
David L. Philips
South Essex Sewage Dist.
Salem, MA
B. Goodwin
Sanitary Engineer
Portland, ME
Jack Truner
D. P.W.
New Bedford, MA
Adolph 1. Schmidt
Greater Woonsocket C of C
Woonsocket, RI
Anna Nestmann
League of Women Voters
Providence, RI
Ann R. Wire
Hollingsworth & Vose
E. Walpole, MA
Willilarn T. Garriepy
Smithfield RI Sewer Auth
Esmond, RI
Alvin t. Gravely
Metro Dist Corn
Boston, MA
John Brady
Whitmore & Howard Inc
Wellesley, MA
Jack Konovan
Whitmore & Howard Inc
Wellesley, MA
James Brayden
Chief Eng Mech Div
Beverly, MA
Mark Casella
Mass Div. of Water Pollution
Control
Boston, MA
Lay D. Patel
C.E. Maguire
New Britain, CT
Michael Long
Mas Div. of Water Pollution
Control
Boston, MA
E. M. Lape
G.E. Co.
Lynn, MA
D. S. Yeaple
G.E. Co.
Lynn, MA
Bill McAloon
Taunton md. Dev. Corn.
Taunton, MA
Charles E. Volkmann
Taunton Area Chamber William
of Commerce
Taunton, MA
Allan Morgenroth
Boston, MA
Vasanti Patel
Sanitary Engineer
Boston, MA
D. Olken
Dyecroftsrnen Inc.
Taunton, MA
Stephen H. Geribo
SEA Consultant Inc.
Boston, MA
Amperex Electric Corporation
Seatersville, RI
Michael A. Hyde
Atlantic Gelatin
Woburn, MA
Daniel Calnen
Wastewater Treatment Plant
New Bedford, MA
Richard A. Chiodini
Riely Assoc.
Providence, RI
Walter Hundley
C. E. Maguire Inc
Providence, RI
Anthony J. Zuena
Cullinan Engineering Co. Inc
Auburn, MA
-------
William Torpey
Greater Fall River Area C of C
Fall River, MA
Arthur Levesque
Upper Blackstone WPAD
Millburg, MA
Edward L. Callo
Upper Blackstone WPAD
Millburg, MA
Emil W. Holland
Upper Blackstone WPAD-
Millburg, MA
Ronald a. Breton
Env. Tech.
Manchester, NH
Thomas E. Wesolowski
Env. Tech.
Manchester, NH
Roland J. Desrosiers
City
Attleboro, MA
David Butterfield
City
Attleboro, MA
Kenneth Bundy
Reed & Barton
Taunton, MA
Donald G. Wood
Metro. Dist. Corn.
Boston, MA
Cheryl A. Breeri
Merrimack Valley Plan. Corn.
Haverhill, MA
Laura Montgomery—Tanner
Camp, Dresser & McKee
Boston, MA
Christopher Woodcrock
Camp, Dresser & McKee
Boston, MA
Julian Hatch
The Gorton Group
Gloucester, MA
Pearce Kiazer
Pricipal Sanitary Engineer
Providence, RI
Paul M. Colson
Associated Industries of Mass.
Boston, MA
Wayne T. Grandin
Metro. Dist. Corn.
Boston, MA
Douglas Funkhouser
Urban Systems Research & Eng
Cambridge, MA
Lionel H. Corriveau
Providence Pile Fabircs Corp
Fall River, MA
Gulab G. Hira
The Gillette Co.
Boston, MA
Alfred Prokop
Revere Suger Refinery
Charleston, MA
ronald Herder
Aluminum Processing Corp
Fall River, MA
Stephen W. Buckley
City
Fall River, MA
Steffan Aletti
American Towelry
Mfgr. Magazine
Providence, RI
R. C. Frederiksen
Providence Journal
Providence, RI
Dr. Richard Burns
EPA Region I
Boston, MA
John Christie
Reporter
Boston, MA
Frederick A. Rubin
New Bedford Area C of C
New Bedford, MA
Arthur Corey
City
Lowell, MA
Ed Gillisse
Acushnet Co
New Bedford, MA
Stephen E. Poole
Whitman & Howard
Wellesley, MA
Ben Fehan
SEA Consultants Inc
Boston, MA
Marie Holman
EPA Region I
Boston, MA
Inc.
-------
Complete presentation of
• Purpose of study
• Project scope and methodology
• Findings and conclusions
Statement of the Honorable Margaret Heckler, Congresswoman of the
Massachusetts 10th Congressional District.
Abolish ICR
Statement of Mimi Feller of Senator Chaffee of Rhode Island,
staff.
Asked for ideas from attendees.
Discussion of alternatives
Ottus Statements Presented.
Canton M. Viveiros, Mayor
City of Fall River, Mass.
Abolish ICR or, if not possible, allow ICR payments as
credits to taxes
George T. Darmody, Exec. Director
Fall River Industr ia1 Development Commission
Abolish ICR
Patrici H. Harrington, Bristol Co., Commissioner
on behalf of United Merchants of Fall River
Abolish ICR
John E. Walker, Director of Research & Development
Chamber of Commerce, Greater Portland, Maine
Abolish ICR
Makram E. Migalli, Director
Public Works, City of Woonsocket, R. I.
Abolish ICR
Hedley Patterson, Division Engineer
City of Woonsocket, R. I.
Abolish ICE
David L. PhilLips, Executive Director
South Essex Sewerage District
SIC, 25000 GPD definition of industry should also apply
to the equitable cost recovery requirements of PL 8 —66o
William Torpy, President
Greater Fall River Chamber of Commerce
Abolish ICR
Philip Murray, on behalf of The
Industrial Wastewater Survey Comm. , New Bedford
Abolish ICR
Ralph Guerriero, Co—Chairman
Fall River Textile Processors Waste Water Treatment Committee
Abolish ICR
Martin Hadley, Chairman
Sewer Commission, Town of Templeton
Town is depend. e.nt upon local share of ICR collegtions.
Town and industry have an acceptable agreement.
William Goodwin, City Engineer
City of Portland, Maine
Abolish ICR, or if not possible, go to national ICR rate
for all (840600, 92—500 and 95—217) grantees
-------
Kenneth Bundy
Plant Engineer, Reed & Barton Co.
Abolish ICR
Ms. Mimi Feller for Staff
of Senator Chaffee of Rhode Island
Explained considerations affecting Congressional actions
on ICR
Duane Wheeler, Vice President
Acushnet Company
Abolish ICR
Karl Spilhaus
Northern Textile Association
Abolish ICR
Kenneth Gillum, Mgr. of Engineering
Goodyear Tire & Rubber Company
Abolish ICR
10 AM October 25, 1978
6 Attendees
Three from 10/25 and three new
Abbreviated, informal discussions held of
• Purpose of study
• Project scope and methodology
• Findings, conclusions and possible alternatives.
No statements made by attendees.
-------
The Honorable Edward P. Boland
2111 Rayburn Building
Washington, D.C. 20515
Dear Representative Boland
IOWN OF M1’I..k:TON
TEMPLETON. MASSACHUSETTS BALDWiuVk:Et AeS Ot&’8
July 27, 1978 Teiep .-.e 939-t%801
fl ACG HMM ——
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I JAS --
— Pr. u — ( - L .1S
7
r i GDS
( J 1LA _ _
[ J EAB ( ‘(iJI iMS — .
O .JDE I _ E3Ki PG —
O cr - — 1 F L..S
Rei Industrial Cost ecovery Legislatjve Sudy
Some months ago, we had several conversatjo arid some correspond-
ence regarding the Industrial Cost Recovery oratorjum. The Town
of Templeton was chosen to fill out a questicn.naire in connection
with the ICR study; !r. Paul Flax of Coopers & Lybrand ca ine to our
office on the 2 th for this purpose.
We are very concerned tecause in our opinion the questiorL,ajre is
designed to discover the impact of the ICR payzen-ts on industry,
arid does not contain direct questior.s that woUld demonstrate the
economic impact on rural communities, such as ours, and as required
on page H12703, Sec jon 75, of the Congressjor.aj Record. AlSO,
most of the questjcns do not apply to our particular case,
In our case, Baldwjr.vjlle Products, a subsidiary of Ervirig Paper,
is the major polluter of the Otter River arid their effluent will
account for 95%+ of the wastewater treatment facility capacity;
the tcwn’s share is therefore approximately 5 . It was very advan-
tageous for the mill to have the town join them in the construction
of this facility. A considerable amount of rncr.ey was saved by the
mill because of this joint effort.
The townspeople voted on a joint effort because usage of the ICR
funds made the cost reasonable to the people. Using ICR funds, the
betterment charge is in the area of 2700. and without ICR furids it
would be apProxi ate1y $2,700. In our small town, with low average
yearly wages, the residents could not possibly pay a $2,700. better-
mer. -t charge, nor a greatly increased tax rate. The onomjc hardship
that would be created if ICR funds were withdrawn from the Town of
Templeton would be inestimable.
We believe that our si uation is some hat unique and are most con-
cerned that the above facts, of vital importance to our citizens,
will not be properly considered in a omputeriiad study.
-------
POWI% 0?. T IPLKTON.
The Honorable Edward P. Bo]and page
July 27, 1978
This Boa.rd is thereforerequeeting that you put this letter on
file for reference when Congress acts on the moratorium.Provjejo
should and must be made to allow towns and cities in our position.
to use ICR funds according to CFR rules and regu1at.tort in effect
when our plans forusage were determined. Any other congressional
action will put our community in deep financial trouble.
It i not clear to us whetheronly ICR funds to be returned to the
EPA by industry is under consideration for change and no change is
even contemplated or will be made for the town/city share. Perhaps
we are unduly alarmed.
Please let us hear from you.
Very truly yours,
BOARD OF SELECTMEN
Albert . Strott, Jr.
Acting Chairman
amr
cc, Mr. John P. Rhett
Deputy A e’t Adm for Water Program Operations (WH.5216)
USEPA
Washington, D.C. 2OZ 6O
The Honorable Edward M. Kennedy
2 0O A John F. Kennedy Federal. Building
Boston, MA 02203
The Honorable Edward W. Brooke
2003 F John P. Kennedy Federal Building
Boston, MA 02203
Coopers & Lybrand
1800 M. Street N.W,
Washington, D.C. 20036
PK/ PI
vFmI
Sewer Commission
Town of Templeton
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BOARD OF SELECTMEN BOARD OF HEALTH
TOWN OF TEMPLETON
( ( TEMPLETON, MASSACHUSETTS BALDW E Z p436
- F ovember 2. 1978 Telephone 939-8&
Mr. John Gall
U.S. Environmental Protection Agency
J.F. Kennedy Federal uilding
Boston, Massachusetts 02203
Dear Mr. Gall:
We are enclosing typewritten copy of statement given by Martin
Haley, Chairman of the Sewer Commission, at the EI’.A public meet-
ing of October 24, 1978, fdr the congressional record; meeting
concerned ICR payback. -
Regarding congressional action on ICR payback, our concern is
that being in the rather unique situation of joining the mill
in construction of the wastewater treatment plant, with the
mill responsible for 95.5% of the effluent, and being a small
town, we could get lost in the overall national study, and provi-
sions would not be made to protect the residents of the Town of
Templeton.
Bearing in mi•nd the following:
1. The townspeople voted funds for construction of the treat-
ment plant because the mill, as part of their contract witr.
the town, agreed to ICR payback.
2. It would be most inappropriate for Congress to take any
artion that could jeopardize our contract with the mill,
and we do not believe that they would do so if they were
acquainted with the facts.
3. The mill benefits greatly by having a 30-year loan, interest
free, because of town bonding of $935,000. Also, no payback
is required from the mill on their share of the State grant.
4. If ICR payback re to be discontinued, the mill would ex-
perience all the benefits, and the town and townspeople a1.
the disadvantages in cost. This would be most inequitable.
Our present arrangement is equitable to both parties.
therefore, we are requesting that the EPA bring out the facts of
our case and recommend continued I cR payback, at least the town’s
share, for the Town of Templeton when its recommendations are render-
ed to the congressional committee.
-------
BOARD OF SELECTMEN
BOARD o HEALTH
TOWN OF TEMPLETON
TEMPLETON, MASSACHUSETTS ‘ •
MJ .tj
Statement given by Martin : a1ey, Chairman, Sewer Commission, ro•M
of Templeton, Massachusetts, at EFA public meeting on 2 ,
1978, McCormac ]ç Post iffjce and Courthouse, Room 208, osto .
Massachusetts.
Whil l.jLc 1CR study will n; doubt provide the EPA ar ci re s
with necessary answers, we do not feel that it provides or : - :-
deratjon of the situatior existir g in the Town of Te e r..
have a letter on file wit? the USEPA stating our case a - :--
permission I shall read t paragraphs from that letter, as ; ;
“In our case, Baldwjnvj].le ?roducts, a subsidiary of :vi g r,
is the major polluter of t-.e Ctter River and their ef _ e .t
account for 95% of the wastewa -ter treatment facility :3;a’ . ;
the town’s share is theref:re approximately . It as ‘er a . -
tageous for the mill to have the town join t em in the
of this facility. A consi:erable amount of money was sa-ied e
mill because of this join: effort.
The townspeople voted on a joint effort because usage -r. ::.
funds made the cost reasor. ble to the people. Using fur.:, ,
betterment charge is in t?e area of $700. and without ::i fu-:s - :
would be approximately . 2,O0, In our small town, i - : c
yearly wages , the residentz could not possiblj pay a :e-
ment charge , nor a greatly increased tax rate. The ec: o ic ar:s .::
that would be created if I’R funds were withdrawn froi re ‘:wr :f
Templeton would be inestj .sb1e.”
T ‘P ” ’ r Pr rrr1eton i a rural area with a t’opulatic-
l0-i of nom are elderly persons on fixed incomes.
If a change is made in ICR payback regulations, it is i pera .ve th
a grandfather clause protect the towns and townspeople who h .Te
entered into an agreement dth industry such as Tempie:cn haf io..e.
An agreement entered into, in good faith by all parties, cve
ago, should not be nullified to the great detriment of ur tc’v .nd
citizens. We cannot give enough emphasis on the need : prot c’vr2
or cities in our situation, We must be allowed to use the toy:’! B ere
of ICR paybac]c as planned when the tpwn joined the miii ef crts
to stop pollution to the Ctt.er River. Should the Federal gov rr.m er
deem it a necessary economic measure to discontinue cdlle:tir - tz-e
federal share of ICR funds, fine, but we wish to go on record as tei
in favor of Alternative #17 - the tpwn retaining its share of rr
-------
2—
Mr. Johfl Gall
US EPA
November 2, 1978
Regarding alternative #lL , we do ‘not see any particular advantage
ii postponing a decision by extending the ICR moratoriurn This actic
create a climate of uncertainty beneficial to noone.
The Town of Templeton is in favor of alternative #15, maintaining
ICR in its current form, or alternative #17 whereby industry would
not be required to payback the Federal portion of ICR funds, but
would br required to payback the city or town share, with the possi-
bility of giving a city or town the option of collecting their
share of ICR or exempting industry from payback.
Very truly yours,
BOARD OF SELECTME ;
Dana G. Putnam
Chairman
ainr
cc8 Sewer Commission
FK/MPI/VF
Mr. John T. Rhett
Deputy Ass’t Adm. for Water Program Operatio a (WF 5Li.6)
USEPA
Washington, D.C. 20 4.6O
The Honorable Edward M. Kennedy
2 0O A. J.F. Kennedy Federal Bui1dir g
kioston, MA 02203
The Honorable Edward W. Brooke
2003 F. John F. Kennedy Federal Building
Boston, MA 02203
The Honorable Edward P. Boland
2111 Rayburn Building
Washington, D.C. 20515
Coopers & Lybrand
1800 M Street NW
Washington, DC 20036
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WAtCR SUFPI.Y T LCPHON(
SEW RAGE 27.7 150
THE METROPOLITAN DISTRICT
555MAINSTREET.p.O. DOX600
3—ATG/mlh HARTFORD. CT 06101
November 3, 1978
File: HFP Task l2C Hartford
U.S. Environmental Protection Agency
New England Regional Office
2203 John F. Kennedy Federal Building
Boston, Massachusetts, 02203
Attn: Mr. John Gall
Gentlemen:
We propose by this letter to go on record as being in favor
of the abolishment of 1CR.
Assessment of our system shows it to be too complex and the
types of combined industrial and con crcial businesses to be so diversified
to allow such a program as 1CR (current form) to be cost effective or
actual benefits determined.
The estimated costs to us as Grantee, beyond progressive
Government monetary participation, would soon become prohibitive for
adequate and consistent monitoring, administrative processes and litiga-
tions.
I is also believed that due to the extent of the “Paper Costs”,
at the Federal and local levels, there would be no actual “Recovery.”
IIowc. ver, should 1CR sustain, it is suggested that application
of 1CR in its current form be revised. An alternative to the current form
‘ :eu1d be the th1rr duction of an “Imposition Clause” and the establishment
of State-wide “1CR Imposition Rates” for application or non-application by
the Grantee with promulgation at the state level. The application of “1CR
Imposition Rates” only to the extent of assessed and determined benefits
would sustain equity, allow for some control over the design parameter of
industry and would provide a better avenue for determining the constant
cost effectiveness of “Applied 1CR.”
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-2—
The current form of 1CR (considered to be “Blanket 1CR” as
opposed to “Applied 1CR ”) removes from the Grantee and the State their
rights to determine and/or alter the economic impact to be felt, on a
much wider scope. (i.e. Loss of jobs from industry that has shut—down,
increased unemployment payment and added local and State cost for other
public assist programs. In addition, the probable increase in self-
treatment by industry would result in loss of “up-front” revenues to
the grantee with subsequent reduction in cash flow.)
Respectfully,
— , •. ,, 7
c—,4vz.
Lawrence A. Fagan, Jr., P.E.
Deputy Manager of Engineering and
Planning
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CITY OF NEW BEDFORD. MASSACHUSETTS
EXECUTIVE DEPARTMENT
OFFICE OF THE MAYOR
P. 0 BOX A 2089
999•2931
October 26, 1978
Mr. Stuart C. Peterson, Chief
U.S.E.P.A.—Nunicipal Facilities Branch
J.F. Kennedy Federal Building
Boston, Mass. 02203
Dear Mr. Peterson:
As you are aware,
Wastewater Surve
major industries
projected charges
has been supplied
the City working together with the Industrial
Committee (comprised of New Bedford’s 31
has compiled statistics relative to UCICR
in New Bedford. Copies of this information
to EPA and Coopers & Lybrand.
The obvious detrir iental impact that these projected charges
will have on local industry coupled with the imminent industrial
pretreatment requirements will certainly eliminate the recent
success of industrial expansion in the City.
Therefore, because of the many reasons cited by the Committee
in their presentations to you we could not endorze any alterna-
tive to ICR other than total and complete abolition.
Should you have any questions or require additional information,
please do not hesitate to contact us.
JOHN A MARKEY
MAYOR
Very truly yours,
Fred Rubin
/dh
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WILLIAM 3. TORPEY
PRES IDENT
v
ChamLer of
A yea
C omme r’ce
Mr. John Gall, UC/ICR Specialist
U.S. Environmental Protection Agency
J.F.K. Building
One Government Center
Boston, Massachusetts 02203
Dear Mr. Gall:
October 25, 1978
Enclosed is a copy of my testimony delivered yesterday at the
I.C.R. hearing in the McCormack Post Office Building, which
outlines the position of the Greater Fall River Chamber of Commerce.
Will you kindly see to it that the
official record of the hearing.
testimony is made a part of the
Many thanks and
meeting.
WJT:dJ.
End.. (1)
congratulations on the excellent conduct of that
Very truly yours,
P0 BOX 1811 • 101 ROCK ST
4cI ,c lig
William 3. Torpey
President
FALL RIVER, MA 02722
aIf
(617(6168226
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10/24/78
BOSTON
EPA/PUB. REARING
MR. TORPEY : My name is William 3. lbrpey. I am president of the Greater Fall
River Area Chamber of Cosm arce.
I want to thank the conmtittee for this opportunity to represent
the nearly 1,000-Chamber members of our business and professional organization,
in presenting a brief, but very positive position on the matter of total elimination
of the cost recovery portion of the 1977 Clean Water Act.
As you well must realize ly now, the City of Fall River has an
outstanding history of service to this country/as a world famous cotton manufacturing
community. The peak of this industrial achievement came a lifetime ago at the turn
of the Twentieth Century and suffered a steadily declining economy until financial
and social disaster struck during the depression era of the Thirties.
For the past 40-yelrs, the people of Fall River have struggled to
overcome many problems , not the least of which/included restoring its own dignity
and pride, self—confidence and identity.
This WAR against “apathy and self-condemnation” has been waged with
a mixture of success and failure/by every segment of our Fall River leadership...
political, church, indjstrial managci enL, and IrThor until L Jht N M /i UA ..
those efforts are being rewarded.
The detcitunat ion of Fail Ri.vcr citizens to “work together” for bettor
neighborhoods. . . for a bett r city . . . ha h ppen . A now multi-million dollar High
School.. .Goverr. nt Center. . . and Bicentennial Watcrf ont Park. A flurry of new
construction by the banking institutions, housing for the elderly and co” rcial and
industrial firms.
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—2—
The birth of a new industry called TOURISM...previously unknown
14—years ago...has flourished and grown withthe development of the Battleship
Massachusetts, the Marine Museum, the Destroyer Joseph P. icennedy, Subc arine
Lionfish and the nationwide P-T Boat Association. These have meant nearly
200,000-visitors each year to Fall River and some 4-to-S-million dollars of NEW
MONEY, pumped intO our economy each y. ar.
We have seen the groundbre king for a new revitalizeil Central
- Business District; an On-going water filtration plant and water main relining
project; and so many re POSITIVE. . . .PRCGRESSIVE. . . . happenings for Fall River.
Fall Riv’ r cannot afford a STEP BAc WARtJS. Fall River’s people
WILL NOT sit-back and w. tch it happen.
Without the specific details already prebented to yC U and much u re
testi ny from the manufacturers yet to be heard from.. . . the unqualified position
of the chamber of. Conunerce is to totally reject the irr osition of the ICR proposals
by the federal governnent. With a current 6.8% unemployment factor in Fall River..
..affecting some 3,556-people out-of—work. ...such unfounded charges against our
major • mp1oyei5 . ii ii di .aster f1 OLL uconr :ny.
O:i Ai just 21, 197fl, reprc’ ntatiVC of I:I’Tt, ar’.d the consulting firm of
Coopers & Lybrand, heard the textile in(lustry lea. er of Fall River, their union
leadarship, eupportingindustry officials, city, state and fe ]cral representatives
headed by Congress man Mar rct Hec);ler, clearly dcscribecl the/affects of enforcing
I.C.R. Loss of jobs and payroll income... .poss blo plant closIngs... .cannot be the
Federal governments “goal”. Every possible effort to adhere to anti—pollution
standards have and will continue to be met by our industrius.. . .and these have been
themselves very expensive, to say the least.
-------
—3—
Gentlemen: As the spokesman for the Fall River Chan ber of Co nercs—
—I urge you to consider the total abolition of the ICR portion of the law. As
Mrs. Heckler so forcefully stated thts morning, ICR will not improve the clarity
of our waterways-——but it will have a devastatthg effect on the econontic future
of our city.
Again, we urge you to recommend adoption of Alternative #1 the
deletion of ICR in any form--—and subsequently-—-that EPA will recommend TOTAL
abolition of such recovery payments by the Congress.
Thank you.
-------
I.
‘&Q
State of Vermont
AGENCY OF ENViRONMENTAL CONSERVATION
—. -
Montpelier, Vermont 05602
DIVISION OF ENVIRONMENTAL ENGINEERING
Depautment of Fuch and G3me
Departmnnt of Forests, Parks, and Recreation
Department of Wat.’r Ri’sources
Ev vir’,nmpuut.uI Oo,iuuj fl + h 9 ’
Division of Euvironuuuental Fnguneering c o er
Divition of E. nv ii non ci tal Protect ion
Natural flesourcet Con eivntuon Council
Mr. John Gall
WC/ICP Coordinator
f uriic pa1 Facilities Branch
U.S. Envitonrnei Lal Protection Agency
Region I
John F. Kennedy Federal Building
Boston, MA 02203
RE: ICR Evaluation
Dear fir. Gall:
I am writing to offer coniiient concerning the Industrial Cost Recovery
System study now being conducted by EPA under mandate of the Clean
Water Act of 1977. This office would like to express complete opposition to the
concept and implementation of the ICR system for the following reasons.
1. An industry is as much a part of a coninunity as a homeowner, shop owner, drug
store, school, church, etc. and therefore should be treated no differently with
respect to receiving’ the benefits of federal construction grants.
2. The ICR system operates to encourage industries to construct separate
treatment facilities instead of joining with municipalities to build a single
treatment p’ant. In our opinion numerous smaller treatment plants are more costly
to build and operate than fewer, larger plants. Further they are less reliable,
partlcuhtrly t dicn rrlvately cMncd because the function of controlling effluent
q’a.’lfty ic Ici ’rI: “ i-il t the r.. nufacture of goods anti private operators are
f equctit Iv ‘n bottom of the pay scale, change jobs Iliore frequently and require
a greater program effort to train nd survei 1.
3. I\dimiinistratjon of the ICR system imposes an unnecessary burden on small
municipal governments which are forced to keep separate accounts suitable for
federal audit.
4. The existence of an ICR system does not contribute toward the stated
goals of the Water Pollution Co ro1 Act by causing or accelerating the abate-
ment of pollution or in any way restore water uses or water quality.
-------
Mr. John Gall - EPA
October 23, 1978
Page 2
5. The money repaid by an industry must be used in part to defray the cost
of future pollution abatement work and such amounts used are to be deducted from
the federal grant awarded at that time. The municipality gains no benefit from
these funds, but must maintain an accounting of them. A small town may never
again undertake a project qualifying for construction grants under PL 92-500
particularly recognizing the current trend of restricting eligibility.
6. Development and submissi n of ICR systems or commitment to do so add one
more administrative step to final design and construction projects, already over
burdened with red tape.
7. fleletion of I CR requirements from the program ,ii help cimplify planning
requirements, reduce planning and administrative costs, encourage reguo a1ized
sewerage systems and lift unnecessary and continuing administrative burdens from
small municipalities.
I trust the above summarizes our view of the ICR system. I would be
happy to elaborate on these points if you wish.
Sincerely,
Re nald A. LaRosa, P.E.
Di Fector, Envi ronmental Engineering
RAL/WCB/sec
cc: Elbert G. Moulton, Commissioner
Economic Deve1o ment Department
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4
FJ 9...
itg af Jn11 it’er, øad u eft
SEWER COMMISSION
ONE GOVERNMENT CENTER
Room 308
October 21 1978
Coopers a Lybrand
1800 11. Street N.LJ.
Washington, D.C. 20036
Attention: Mr. Edward J. Donahue, III
Reference: ICR Advisory Group
Study Alternatives
Dear Fir. Donahue:
This communication is in reference to our telephone communi-
cation of October 14 1978 concerning the above referenced
subject.
The alternatives presented were obviously well thought out
and encompass a broad spectrum of ideas. Obviously., each alter-
native has it distinct advantages and disadvantages. However,
we must not forget the reason why such a study was initiated!
As a result of some very persuasive industrialists in this
country especially the textile industrialists of the Northeast
Congress was convinced that the ICR requirements of Public Law
92—500 must be reconsidered.
Many aspects of the ICR requirements such as equity,
water conservation, etc. were questioned and the time had
come to thoroughly examine the effectiveness and need of such
a program.
Equity of the systerm would be my main concern. Whatever
approach is taken it must be one which is fair to industries
so that their financial burden is not heightened.
Industries coni laints of “double taxation” must be eliminated.
Industries can not afford to have a drain on cash for a non-
productive basis.
Although somewhat overlooked, an aspect of ICR which may be
as equally important is the administrative burden placed on the
grantee who must implement and monitor such a program.
-------
it of JuU Rther, Iu actiu ett
SEWER COMMISSION
ONE GO VERNMENT CENTER
Room 308
Why burden the grantee with an administrative task for a
program which has proven to be unsuccessful and not cost
effective?
Along these same lines let us not forget that the so—
called economic benefit to a grantee through ICR is not
so beneficial. The grantees share of ICR remains constant
for 30 years the cost of administering and monitoring such
a program will continually rise. Considering the rising
rate of inflation and subsequent rise in labor wages, any
economic benefit would certainly develop into a economic
debit.
Also, it appears obvious that the intent of Congress re-
garding ICR has not been fulfilled. The revenues being re-
turned to the Federal Government through ICR fall far below
those projected in 9?2. Surely. I would not be too far
a miss in assuming that the administrative costs incurred
by the Federal Government in implementing and maintaining
such a program far exceed the amounts recovered via ICR
payments. This is further strengthened by the fact that
there are only a few municipalities throughout the country
who have implemented an ICR program.
Another aspect to consider is the detrimental effect ICR
will have combined with pretreatment costs and user charges.
The combination of such factors could encourage industries
to self treat. This would result in proportional increases
in user charge costs and in debt service costs for the re-
maining P01W customers.
We see only one viable solution and that is to eliminate
ICR. By eliminating ICR we address the intent of Congress
with respect to the Moratorium Study; i.e. failing Federal
program, unfair economic burden to industries, administrative
headache to the grantee, so—called economic benefit to the
grantee, .
The effectsof ICR are far reaching. We are not only concerned
about the loss of jobs and industry, but also the detrimental
effect on the tax base? People out of work only crea futher
subsidies through unemployment, social security, ect. Cities
Towns, and States can not afford ICR.
-------
-4
itg of U Riber, B 3 4ZZ .CI1U e1I
SEWER COMMISSION
ONE GOVERNMENT CENTER
Room 308
Therefore, we strongly urge that your recommendation to the
EPA be to abolish ICR and at the same time request that the EPA
recommend to the Congress of the United States that the IC R
aspect of the Clean Water Act be abolished.
In closing we would like to point out: it appears that far
more than the majority, including officials of the EPA, favor
the elimination of ICR, thus, the Congress of the United States
must be convinced. Your recommendation to the EPA must be
abolishment of ICR and that recommendation must be made in as
strong and positive terms as possible.
Thank you.
Very truly yours,
Stephen I d. Buckley
Supervising Sanitary Engineer
Fall River, Sewer Commission
SWB/cn
cc: John Gall, EPA
Joseph S. Rego , Sewer Registrar—Fall River
\. 1.j ,‘i L
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OF NEW BEDFORD
CITY
MASSACHUSETTS
DEPT. OF PUBLIC WORKS
WASTEWATER DIVISION
Mr. Mike Townsley
Coopers & Lybrand
1800 M St. NW
Washington, D.C. 20036
Dear Mr. Townsley:
The City of New Bedford wishes to thank Coopers & Lybrand for
this opportunity, to participate in this study which will affect
the industry in our City to a great extent one way or another.
On August 21, 1978 your Mr. Ed Donahue provided us with the oppor-
tunity to point out some of the major concerns of the City and its
industries personally. However, we would like to again point out
some of our concerns that the reimposition of ICR will have on
local industry.
One industrial concern is that several of our larger industries
are subsidiaries of conglomerates based elsewhere. Reimposition
of ICR requirements and the associated pretreatment requirements
will probably result n a decision to phase out local operations
which are located in old structures to probable more modern counter-
part facilities in the South and West. Again indirectly penalizing
the older nOrtheast. This would be added on to the user charge
requirement which is also in the immediate future. Currently all
O & M system costs are on the Ad Valorem tax system.
We are also enclosing for your information a copy of our consultant’s
(Camp Dresser & McKee, Inc.) estimated ICR chart for six upcoming
major wastewater projects (Mass. FY 78 priority list - $23.2 million).
We have been meeting with local industry to show them what costs
could be if ICR is not done away with.
In the near future we will also be forwarding an ICR chart showing
projected costs to the 31 major local industries.
Again thank you for letting us participate in this study, the outcome
of which will be very important to the City of New Bedford.
Should you require any additional information do not hesitate
to contact me. The services of our local Industrial Wastewater
Committee can also be made available if necessary.
Very truly yours,
d 7 c tup e f
‘ncl
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•THE WOONSOCKET CALL
ITHE EVENING CALL PUBLISHING COMPANV
WOONSOCKET, RHODE ISLAND
tet t .a
NANCY E. HuC soN
5ECRITARV.TRIASUNC. September 15, 1978
Mr. Paul M. Flax
Coopers & Lybrand
1800 M Street N.W.
Washington, D. C. 20038
Dear Mr. Flax:
Enclosed is the answer of The Woonsocket Call to the questionnaire about the new sewerage
treatment plant. Unfortunately, the lines are not straight with the paper and we had a
great deal of trouble trying to get things in the right place.
You can see from the answers to the questionnaire that the effect on The Call would not
be direct. Our combined user and capital recovery charges would probably be about $1,250
per year over what we are now paying in utility costs. That is not going to drive us out
of business in and of itself. It is just another bit of fuel added to the fires of infla-
tion.
The effect indirectly on us, however, could be dramatic if it results in the closing,
moving or in non—expansion of existing industries and restricts introduction of new
industry into the area. This particular section of the northeast has had one economic
blow after another. We have tried to pull ourselves up by our boot straps and just when
it seems we are making some headway, something like this comes along. It certainly does
not help to decrease unemployment or move the economy of an already depressed area.
If we lose people or industry it means both our advertising and circulation will decrease,
since our costs will not decrease accordingly. We would be forced to raise advertising
and/or circulation rates,thereby losing more advertising and circulation, etc. It’s a
vicious spiral.
In essence, then, we are not affected directly to any great extent by the imposition of
these charges. The indirect effect, especially as we are fighting for our lives as most
other independent newspapers are also doing, could mean a sale or a closure of the paper
if the impact on the area as a whole were to be of drastic porportions.
Sincerely,
The Evening Call Publishing Company
, (• ( e ’ ’
(Mis ) Nancy E’ Hudson
Treasurer
neh/ lml
enc.
-------
October 6, 1970
I.
( ,‘ ..‘ .i ‘
‘‘‘s T’’c r. 1 i: ) !i_ce TllcIq..
L i )I ,%,,1_ofl , . (. 2O 3lO
r rr Ss r1at;or Pe1].
‘stt-r r 5 t t n ii L r -
fj r t i. ’rti rr,p.munjcatinn wtt . r 1 iunb r rf o’ir
, ç 4 r i I c’ — 1 . : ;u - -‘n ’ ,- ; • 1
J I 1 1 2 r. v’: l i;n: )0T I I- 1; r j 1.
r’ • ‘ C’t• .‘r ’ -.{ , ..
•( ! -‘flrn .: ‘ 1r.I— C ‘ ic’ (‘ e —
‘‘-i ‘e ic’o rh ov’ r ’,1 i: ia h’ r f r l—l. ‘7i1 1 oiil
‘ f 1- &n .tt 1.1. r by very fc-w in - 1 n :t ri , o . er
thc ].on r’m the economic effect will touch ever ’-
onn’r 11v r.
-2 h ’ t 1, on tc 1 ‘ th 1: CU 1 C)I c’crbflc,1 j C! tre 3
‘ IC hU .‘r1u1d h—vre to d c ’ C’ • ii r e-iPr •
1 1. ‘:h n the £cc 1ora1 qoverniuc’nt ± ‘3pcncliuc
rarbn , r) ievc 1op johq, to uvw orf un’ r ;i.ov’ 1 ‘rr’r!zc r i
arv at ti” ‘n tho Furrounr’i ,cr citjeF nr t ni
1c r cr with thc City of ‘o’iru o-f ’:’t ov 4 c ir . In
- : ‘ ‘ct - t” i ’’ t ecnrc ir gro ’t)i ‘i ir,4 ri.. j
h ,1S is , th rcrt c!Larr1l ‘ jni 1.d c .it 4 o ‘ . - ‘ ‘ uri :‘:r -
T r ]o’ of cir. ‘j’.’h or Cn’? 1 un’ r ’ j. h ! t3 cerL ’in—
li jnrr fv. aU. r,f oUr. tctait fli . rr ’Lce
rI st1 ie s. 11 is ‘1 ‘: ‘lotrv’ to t-rc thc iridivj. uaL
cit t ’?r 1 --hor’ owners who, if Ccicc• with a thrini -.
ing tnx bafle will have to pick UT) a l rgur portion
of th taxes in order to maini,ai.n the ser ric s
presently provide! by the citie9 and towns.
-------
!-Tonorahle Claiborne r1e’ . PG1].
ctobpr (, 197
Page 2
We therefore, urc e you t o a,rii t us in furthering
our oconomic c ro ’th by repealincj the Industrial
C03t flecovery charge,
Sincerely,
1 lames TT Rilyak
President
T1TT / 1i
‘c: Paul M Flax
-------
Octobar 6, 1f 78
:“ t . C Ecc
I I . (‘!.
I I trr i r t’ (i ficc2 i3ldq.
¶! tsh1nrrIc,r,, n.c. 20!].O
Dear 3enator Chafee:
TT I ‘ hr [ nc :te’rz :‘ t”r ‘ our ; of
‘Triflhli ( t1t)T tIth a UIPbOL of
ibJu9trial e nb’3r! • Our cB rjruc ui i c;n 1 1a’.’i 1.c ac!
fl 3 to C’”2 !h ’ t)if h”2o t4. ‘ ‘ f i iiujt ;:
(- :iç. s y “i r e i.ri.:I 1 },. ‘v-’ -‘ t• Lin;
C:L’t.)(,t ) T.j( t ‘‘j! ‘ i-’ rti’ r ‘ Y •; F. (‘rJ’(’ I-
c ; rv rc?r1 tt’ 1- tJ’r- fPr.c.t wi]]. onlv
0 I l folt m i by very frw irLdustr as, but. over
the ]o cr run the economic effee t will touc , ev ’rv—
or ’ i 1i.v ’- n.
“ ,. i. ; i 4 :c “ th tt. 1,. r tv:..1 of c rr r.-,: ij c s Lr 5J ,
•: O tiI ‘iou] 1 h ’c tc’ c 1o Ct LI :1 c itc
t. a tirne wbni, the fec eral qo1, rr ent ir en’ inq
€o revelo lobs, to supDort unemp] oy l ‘or:ets
r&’ L t rnr ho’ the c’irrounr jpc iti aiiO teMn
a]r,nq ith the City of Noonsor.’ : tI V i 1 i :i
a ‘; ict. to prOmote econo t ar’v’t t
h tsi , L e ICR charae wou.1.c L ‘ppc .nr t.. h. : c ’uitLc r-
pro’iuccive.
The lr)F33 o one job or one hunr or1 lobs is certain-
lv aoivzg to tax all of ou retnil nn 1 service
itdustrier. it ii also going to tax the individual
citizens ai4.Jior ie owners who, if faced with a shrink-
ing tax base will have to pick up a larger portion
of the taxes in order to maintain the services
presently nrovided by the cities and towns.
-------
[ F 1
J7
1ToLlor b1o .John It. Chafee
( ctober 6, 1978
Paqe 2
We therefore, urqe you to assi9t us in furthering
our economic qrowth by repealinq the Indu3trjal
Cost Recovery charge.
;ince eiy,
James H. Bilyak
President
11 3/c1eb
cc: Paul U. P1a :
-------
October 6, 1978
U’m r ‘1’ ‘ ‘ ; ‘t .1. St. ( e ain
• “r tat.t r
Lr 2’.3C p vbi:rr Jiou’e Offic’3lldg.
/ tiit’- ”. ,C. 2fl.S’
Dc ar C ng’r’ 3-3 13n ‘t. ‘n’ruitn:
t t r i.c beiiicr .‘rittcn ter hcurs% o
1 r ,4 I.’,r’ ‘7ith J’iI ) 1’ •) OU1
inr1 i itiia1. r o iv- r . C nr r ACil J ,C V nvc ) “ id
r r ’ 1 jr.ip- 4)- . ’ .Y rlflC3 j ‘ 4 .- -l 1 ” . j ‘ 1 ll 3 ‘ 1
- , rr j. ” ,‘ •‘ r’ •‘i 1 I —‘ ‘ ‘J i tr’ r
1 ro,fl1 r el ‘ir- r’ i ‘t . ?t ‘‘‘) “. •.( .c ar ”
D) ,ave 4.1 ,. O rq r oereJ that th f ct will iy
) ..? f. lt iriL ia11y by very w ind trie , but over
l,p 1r r ri r’m the cono, t1o of fnct “ii 1 t’,u h c v r’p—
f Yl i ” •1•
I rs ‘. ‘ ;ç’ 1 :1 PJ : t lOC ?‘• C- ‘ 1 C -
- } ‘‘—; n • w:.ui 1 h vr ‘ri ci ‘‘ r’ n • r I r, -e .
\\ // I tiir whr%vl tho 5rk r;i1. rrvoimi .’c rit i i
1 V / nonoy to dovolop johE , to qupr ort 1t1c .T I1o:.re u r -er i
/ ns1 at- a tine when tito urrotu” I , ‘ q r ‘; ‘ f;
al rinrv th the City of WoOfl och ‘ we oi rcJ
a ‘ t o pror,oto economic c.ro -t’ ‘ ‘• I
J b lsi3, the ICR charge would app or i- ci cc’inL r-
productive.
Tho lo of ic b or ono hundred jobs i rt tin-
lv e’o!rig tQ tax all oE our retail and sorvice
in 1iistri . it i also goinq to tax the individual
citizens nd home owners who, if faced with a shrink-
ing tax base will have to pick up a larger portion,’
of the ta ;es in order to maintain thc mrvice3
presenti” provided by the cities and towns.
-------
Iloriorahici Fr rn anc] J ‘ . 1Pi ifl
N tohr r 6, 197R
Page 2
We therefore, urge you to assist us in furthering
our ec’onoi ic growth by repea1in the Industrial
Cc3t Pecovery charge.
inceri ly,
James 7!. )3ilyak
President
J)Tt /deh
cc: Pan]. M. Flax
©
r )
-------
A. W. MeKerina
Paul E. Peters
Mattew Foster
Robert Caddell
William H. Wechter
N. Gilbert
H. HUNTER
G. William Calascione
Paul R. Paquin
Bergen County Utilities Authority
EPA, Region II
Grumman Aerospace Corp.
Dvirka & Bartilucci
American Cyanamid Corp.
Sopa & Detergent Association
Warner-Lambert Company
EPA, Region II
Parsons, Brinckerhoff, Quade &
Douglas
Wiendiel Engineers, P.C.
American Bakers Association
Country of Nassau, DPW
Westchester County, Dept. of
Environmental Facilities
Greeley & Hansen
Lobsenz—Stevens, Inc. (for CTL)
EPA, Regionli
Polilo Dairy Products Corp.
Hydroscience Incorporated
Industrial Cost Recovery Public Meeting
Region II
Biltmore Hotel
New York, NY
10 AM October 18, 1978
EPA — Kenneth Stroller, II, UC/ICJ Specialist
John Gall, EPA Washington
C&L - J. Mikul Townsley
Myron A. Olstein
24 Attendees:
Edward J. Brouillard II
Margarey Davis
Robert Wheeler
Joseph H. Greeley
James A. Hulme
Richard Sedlak
F. James Wound
William McCabe
Douglas Tozzoli
-------
Irwin Norwick N.Y.C. EPA Dept. of Water
Resources
Martin Rivlin N.Y.C. EPA, Dept. of Water
Resources
Joseph T. McGough N.Y.C. EPA, First Deputy
Commissioner of Envir. Protection
Douglas H. Starr TIiomas J. Lipton, Inc.
Maw Wong N.Y.C. Staff of Congressman
John M. Murphy
William Lauer Clinton Bogert Associates
Complete presentations of
Purpose of study
Project scope of methodology
Findings, conclusions and possible alternatives
Statements presented by
John 1. MeGrough, First Deputy
Commissioner, Department of
Environmental Protection, City of New York
Eliminate ICR
Honorable John M. Murphy, Congressman
from New York — as ready by
John Gall, US EPA
Eliminate ICR
a. -
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COUNTY OF ERIE
IDWAPO V E( AN COUNtY EXLCUTIVf
DEPARTMENT OF ENVIRONMENT NO PLANNING
DIVISION OF 5EW RAGC MANAGEMENT
ROOM 1475
Joan E. Loring, Cannissioner
October 17, 1978
Mr. Ken Stoller
U.S. Environmantal Protection Piqency
26 Federal Plaza
New York, New York 10007
RE: Industrial Cost Recvvery (ICR)
Public etings
October 18, 20, 24 and 25
Dear Mr. Stoller:
Enclosed is a docurrent prepared for a public hearing which was held
in Buffalo on Septanber 6, 1978. 1thile this docunent was prepared to state
our feelings regarding all aspects of PL 92-500 and tbe Clean Water Act of
1977, it reflects on a few points concerning ICR and industrial costs in
general.
I would direct your attention to points Nos. 2, 3 and 4 which
specifically deal with, industrial cost probl s.
Since we will not be attending, we ask that this letter and the
enclosure be made part of the record. Your cooperation in this matter will
be greatly appreciated.
Very, truly yours,
f L( L 4
Charles J. 4ss P . E.
ASSISTA1 T DEPt LOcI+IISSIctUIER
GJ7Vdn
cc: J. Loring
Enc.
File # 1150
(RUE COUNTY OFFCEDUULOING SAFRANRIJNSFREET BUFFALO NY I42O P•UONF IIAB4B A3 1
-------
C ENTS FOR STM: ASS MI3LY SUDccc ?4m’ MEETING
SE EMBER 6, 1978, STAlE OFFI BUILDING, 65 couRr sL ’r
The followinq ccir reritc r oreseflt Erie County Governmant’ s vie points
about projected sewer costs and solutions to alleviate the tax burdens while
still maintaining acceptable water quality:
1. Residential Sewer Pates — Wnj.le the Comiu.ctee is seeking projections
of resTdential sewer rates within the next few years, Erie County
Sewer District #2- is the only operational treatmant plant funded
under 92—500 within Erie Councy. Therefore, we can present actual
cost figures for providing service. iile most of the eitphasis
has been placed on the increasec cost for treath nt, one cannot forget
the substantial cost for providing lateral sewer service to the newly
sewered areas. Older catmunities, such as, cities and villages,
who built their sewers in past years, will not experience these
lateral costs. However, in District #2, the lateral sewer charge
alone .is a high as $160. per year.for a single family hate. Lateral
sewer charges can be substantially higher for industries, con n rcial
units, and other non-residential users.
A number of items have caused sewer service to rise dramatically
since the inception of the projects or the beginning of Public Law
92-500. These include: ever increasing State and Federal mandates,
inflation, the energy crisis, increases in borrowinq rates, construc-
tion costs, plus the expensive cost of actually operating these
facilities.
At the sams tiir ., the costs were ncreas1ng, we had a corresponding
decrease in revenues because of the reduction in 0 & M aid from 33 1/3%
to 25% and because of a curtailmant in bw.ldirig due to a slow down
in growth.
By the vei:y nature of these facilities, they cons T d much more energy,
use substantially greater amounts of chemicals which were never required
with the older systems, and the m power costs have gone up dramatically.
Manpower costs have increased (1) because of the extra work reciuired;
and (2) due to the fact that these facilities are so sophisticated
they now must be manned twenty-four (24) hours per day versus eight
(8) hours per day, five (5) days per week under the older systems.
An explicit example of how the ,e costs have increase can be shown on
the following table for Erie County Sewer District #2:
- Continued -
-------
—2—
ERIE COUI.I’Y SEWER DISTI IC # 2
CQMP/\RISO sI OF COSTS
1970 vs. 1976
1970 1978
Personnel Services 109,890 545,080
3,600 50,825
Materials & Supplies 8,000 10,400
Chemicals 7,500 90,000
Power 13,000 190,000
Telephone 600. 12,000
Other Expenses 32,020 81,800
Debt Service 330,887 1;357,980
‘IOTAL 505,497 2,288,085
Est.imated Population 9,600 19,000
Per Capita Cost $52.66 $120.43
hi1e this table is explicit in showing District #2 • s increases
in cost for the new facilities with respect to personnel, ‘er
and debt service, it is sonawhat misleading because the District is not
yet fully operational. In addition, there are a ni.nther of require-
nxrnts in 92-500 for which District #2 is not in full carpliance. These
recpiiremants, such as, I/ rerroval, sewer rehabiLitation, and sludge
disposal, would add even further costs. These additional items are
not included in the above cobts and represent future major expenditures
for the Sewer District. In addition, in 1978, the District is only
providing service to about 70% of the District, phosphate rerraval
costs wc-re not included in the 1978 budget, and about one third of the
punp stations are not as yet fully operational.
This tab1 typlifies errors in the basic 208 docurrent. The 208 report
identified a r er capita cost of $51.00. This is about equal to the
oer capita cost in 1970 for District #2 prior to the new facilities
being constructed or operational. Our exact 1978 costs are $120.43 per
person with the expectation that these costs could be substantially
higher in the future depending upon State and Federal mandates and the
availability of 0 & M funds. In the 203 Study, the per capita cost of
$33.00 of the Southtcwns Treacment Plant is only for the treathcnt plant
interceptors and does not include any of the cost for sewer rchabilitation,
exist:ing debt service or lateral se r maintenance which can be significant.
The new treath nt facilities wh ch are presently undor construction
axe really miniature chemical processing plants since the technology
was rrodified frcm rc-ex.isting chemical industr .a1 technology. Consequent-
ly, it is just not feasible to take existing personn il, in nost instances,
and expect them to efficiently operate and maintain the new facilities.
In tne past, personnel were hired with minimal anounts of education,
som tines, with not even a high school education. Now, in addition to
the operator’ S overall understanc-lir.g of the treatirent , rrost
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—3—
plants need em!, encj n rs and biologists. Since there has been
a rapid growth in the construction of those idcilities nat.ionwide,
the demand for qualified Iersonnel has far exceeded the supply.
Unfortunately, and probably nore importantly, thile construction was
proqressing, there was no concurrent program to train personnel.
This gross lack of qualified personnel can only lead to inefficient
operation arid rraintenance which, in urn, will lead to uneconomical
or costly operations. Cons uent1y, this will only add to the bill
for sewage treathent.
2. Industrial Sewer C arqcs — The majQr charges that can be experienced
by industry are pretreatn’erkt costs, industrial cost recovery charges,
and user charges.
Presently, industry is required to install best avaiLthle technology
to pretreat their wastes prior tc discharge into a municipal system.
There has been a relaxinc attitude on the part of E . P .A. to rards pre-
treatment requirements; how vcr, in order to take advancage of them,
it is a vexy ctmiberscme process. do not have a good handle on
industrial co3ts for pretreatnent since they are unique to each
p rticu].ar industry and basically unavailable to us. Ho ever, the
feedback we have from industry is that they are very expensive. The
E.P.A. is presently considering less stringent rcquirein nts for
industries discharging conventional pollutants which will not harm,
or can be satisfactorily handled by the local P.O.T.W. This policy
should be expanded to include even non-conventional poll itants where,
they can be shown not to interfere either the treatlTent process or
the ability of a municipality to meet their discharge requirements.
The requirement for Indusr.rial Cost Recovery charges is presently
under review by E.P.A. with a report due to Congress by the end
of the year. Industrial Cost Recovery charges can only add to the
burden bur industries must pay. These charges do nothing to improve
the quality of the environment. They would shift the cost of sewage
treatment from private res der.ces to industries; however, this will
result in three (3) major thsadvanta jes: (1) Industries will merely
pass these costs back tc the people through their product; (2)
ndus tries can be put on an economic disadvantage because sewage
treatrrent construction and operation is much nxre expensive for a new
sewer district discharging to the Great Lakes versus a municipalit•’
which is discharging to a coastal waterway. (This is e: cdial1y true
if the municipality discharging into the Ocean can receive a marine
variance);
and (3) since industry must pay their proportionate share of the
Federal cost of the project, indu trics closer to the tcea nt works
would end up paying less in sewer construction cost versus industries
which are located sane distance from the treath ent plantS thus,
causing an economic disparity even within a sewer district.
In the case of District #2, we have one industry whose I.C.R. charge
would be $9.50 per daily case of product versus a second similar
industry whose charge would be $25.00 per daily case of product.
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—4 —
An additional item of concern is the athwustratjve cost to initiate,
rronitor arid administrate an I .C.R. program.
Usor charges to industries require that the industry r ’ for the
additional degree of treatrr nt that is reciuireci to treat their wastes.
Wnule this would appear to be a very economical arrangerrent, one
has to seriously question its eff.ectiveness since it would entail a
seoarate system of accounts for the municipality and would entail a
large degree of data collection, interpretation and cost caipilations.
I Aost industries do not discharge their difficult waste to be treated
on a continuous basis. If they did, determining an equitable user
charge would be much easier. Unfortunately, they may discharge this
waste over a very short period of tima. ien this is compared to the
total flow to the sewage treath ent plant over an entire year, the cost
of keeping the records might exceed the actual revenues received.
Again, as beforè,any surcharges put upon industry would actually be
charged back to the consur Ler througn the price of the product. Also,
as before, since the municipalities tributary to the Great Lakes must
pay for operation and maintenance of expensive tertiary treatm nt
facilities versus other areas of the State or even the County,
industries in stern New York would be put at an economic disadvantage
because of this requiremant.
3. U.S. - C nac1ian Water Qu.iilty Agrec r nt - Since this Agreen-ent will
impose even more strict effluent limitations, it will only cause more
disparity between the sewer costs that oar industries must pay versus
other parts of the State or Coui .ry. It can only add to the amount
that industry and the local taxpayer alike must pay.
It is a cai n and most fundam nta1 engineering principle “that it is
cheap to remove the first 90 of a pollutant; however, as you ren ove
rrcreand more, and approach 100%, the costs go up astronomically.
Similarly, the cost to remove phosphorous to go from 6 rrg/l to 1 mg/i
will be relatively cheap compared to the cost. to go from 1 mg/i to
0.5 mg/l. Consequently, one has to question the cost effectiveness
or the cost benefit bj removing this additional half part per million.
This is especially true when one considers the facts: (1) that the
imijority of phosphorous is frc nonpoint sources, (2) only trcath nt
plants with an average daily flow of greater than one mrjd must remove
phosphorous,anci (3)that there is still a lot of skepticism as to the
benefits of removing phosphorous or or that matter, to what
concentrations the phosphorous must be removed. Consequently, we
feel the money will be better spent through rc1 ving the phosphorous
at nonpoint sources, guch as, rurdi runoff, and requiring all treat-
m2nt plants not just trea nt plants over 1 m jd to remove phosphorous,
if phosphorous removal is determined to be cost effective. The most
irrportant question, however, is the real need to remove pnosphorous
at all.
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Region V of the iv1ror.r ntal Protection Agency issued a proposition
paper that stated only 26% of the sources of phosphorous flc ing into
the Creat Lakes is fran Sewage Trcatmsnt (59 fran agricultural
runoff, 15% from atirospheric sources, 9 fran dethrgents and 17% from
human waste and garbage); therefore, even if phosphates are either
banned from detergents or removed through efficient treati ent plant
operation, it will still be necessary to treat phosphorous contributed
from other sources. Lc iering the limit to 0.5 mg/i will essentially
be ineffective, but very expensive.
4. Equitable Distribut.ion of Costs
a) Industries - Industries should be allo’ .ed to discharge to
municipalities without any surcnarges in costs. Any restriction
on in& stries should be based on treatabi.l ty problems, i.e.,
if industrje5’ discharge causes any problems with the collection,
transmission or treath-eiu of the wastes, then they should be
required to pretreat prior to thscharcjing into a municipal system
If the industrial waste contribution would orechide a municIpality
from n eting its discharge parmit, likewise, industry should be
required to pretreat. In making such a change, a would be
encouraging industrial developniant within e.xisting sewered areas.
If such encouragement is not made, industry may relocate outside
existing sewered areas wnich would force more of the cost to be
paid on existing resideiitial users. In addition, substantial
cost savings would e realized through olI. tunation of the cumbersare
industrial cost recovery and ucer charge svsteir.s. Industrial ‘ .m tor—
ing and cataloging would still be required to insure compliance
with the Sewer Use Ordinances and for protection of the public
faca .litjes.
b) £ unicipal discharges hou1d be based on water quality criteria,
not an arbitrary standard.
A minimum standard should be establisned for every mun,,icipality
throughout the Country whether it be preliminary, primary,
secondary, or tertiary wastawater treatn nt. Once this minimum
standard has been established, then each municipality should pay the
cost for construction, operation and maintenance of facilities to
mae t tius minimum standard. For exarl)le, if it i s detennincd that
primary treatment is the minimum standard, then each n unicipality
should pay for the primary portions of the treatment facilities
themselves with the normal expected amount of 87 % aid.
If any rnunicipa-lity is required, because of water quality criteria,
or otherwise, to improve upon this mininmmi scandard of primary
treabrent, then either the Ctatc or the Federal Government should
fund 100% of the costs to construct, operate and maintain these
facilities above the minimLo1 standards. The main rationale here
is that in mast cases, a rrrunicipality does not receive
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—0—
benefit of its own pollution control expenditures, but, rather,
the benefits are received by its downstream neigh bors whidh may
be in another portion of the State, or for that matter, another
State. In the case of the Great Lakes Basin, the benefit can
be received partially by another country.
Since there is insufficient data to justify building tertiary
treath’ent facilities, and there are insufficient personnel to
run these facilittes if they are built, consideration should
be given to building and operating facilities which rr et this
minirn standard, or water quality requ1rem nts. bile this
is taking place, it will give us time to evaluate t.he need for
tertiary trea rent and the cost benefits of tertiary treathent.
5. Operator Training - Programs should be started immadiately to train
personnel in the constl:-uction, operation and maintenance of these new
and soplusticated treatirent fecilities.
There are nonies available for training; however, this Ironey seldom,
if ever, is seen at a local level.. When it is used, it is used in
downstate New York. It is very difficult for local municipalities
to afford to send an employee for t o to three weeks at a tiim for
training. Therefore, they have initiated a program to s tart training
at our local Erie Ccninun.ity Collega. Financial assistance to the
College with respect to this program uld be a big asset.
6. Sludqe Dispo- al - The ultimate disposal of the chemical and biolog±cal -
s1uc ges produced at the new facilities needs to be further investigated.
The E.P.A. should set up a program to handle and fund the ultimate
disposal of solid waste in a safe manner. They must becomn an active
partner in seeking workable solutions to sludge disposal and use of
public, including Federal, lands for sludge disposal, should be
aggressively pr ted.
7. Administrative Pad Tape - The E.P.A. and D.E.C. are presently involved
in too many nonpollution related items in administering Public Law
92-500. The E.P.A. should leave the specific details of building a
project such as, bidding, specifying products, etc. to the local
municipalities. While there are obvious adv&ntarjcs in the present
system, it is causing too rranytirr delays getting E.P.A. approval
and building the projects.
It is very cumberso irnpiem ft the intentions of the Federal Water
Pollution Control Act because there are a1x: ut 40 allied statutes and
executive orders which have an impact on the construction grant program.
These other 40 programs end to bog a construction program down and
add costly delays and expensive criteria to an already expensive program.
In addition, there are State and local requirern2nLs which must be
addressed. All of these requirenents should be consolidated and reduced
to have one effective program. The State should cut back on their
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—7—
provisions requiring stringent erflucnt standurds to the cdoral or
E.P.A. 1ev ls. Municipalities who have already cormu.tt€d. themselves
to achieving these levels should be reimbursed in construction costs
and 0 & .M costs 100 percent.
8. Sar.Itary Sewer Overflows — The idea that all sanitaiv sewer overflows
should be eliminated shthld be. discouraged. A certain arTount of
saiutary overflows are cost effective without endangering the
environmant or public health. The cost effectiveness of trying to
reduce all overflows does not exist. -
9. New Changes to the Act, E ecutiva Orders, Etc . — New administrative
rea’uirerrents, or even technical requirent nts shoul not be imposed
retroactively.
10. Credit to Municipalities Who Have Shown Initiative - Corrrnunities who
took the initiative initially and went all out to build the new
waste treatment projects should not be penalized by doinq so. Too
often, we have fought to get changes in the kiw because of problems
we had with initiating our programs. Unfortunately, the laws were
changed after the fact to the betterment of municipalities who drag
their feet but to our detrirnant. not only lost because of a lack
of eligibility, but also, because we were the forerunners who spent the
time and rroney to fight for changes in regulations Cr the laws.
11. Iteji s Tnel qiblc for Grant Assisbance - A nurber of items, which are
presently ineliq ie for aid, add significantly to projects which are
necessary for nc-w facilities construct .on and really considered an
integral part of the construction program. These it . ins would include
interest during construction, land acquisition costs, garages and
maintenance centers, and certain ineligible pieces of noving equip ent.
12. Availability of Funds — The dollars currently available for water
pollution abateirent are nowhere r.ear the staggering amounts needed to
complete the objective of pure waters. Therefore, reconsideration
should be given to supporting Ofliy the cost effective phases of a
project. Those co t nunities who already are in the process of corplet-
ing their ultimate facilities should be reimbursed for any antunts
spent over and abeve the cost effective solution. Recognition of the
cost benefit factor is basic to continue progress in c e tning our
waterways and maintaining public support for the Wastewater Construction
program.
13. rinancial Impacts - An inportant aspect of any program is whether or
not it could be afforded. E.P.A. defines the project as expensive if
oparataon and rriaint’ enance cost plus dtht retircn’el)t cost are between
1.5 and 2% of the local median incc . W a are presently approaching
3% of the average family incc*i - in District #2, with the expansive
programs of ultimate sludge disposal, sewer rehabilitation and full
operation yet to be cc p1eted. Anticipated cost, exclusive of sludge
disposal, is approximately $350. per dwelling unit.
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—8—
14. Present E.P.A. Policy Shiffts — While E.P.A. is presently
considering a] rnati.veg which will reduce capital investnents and
0 & M costs, nDst of Erie County’s carmunities are already ccjtimitted
to the fore expensive projects. In addition, they are overenphasizing
such items (like on-site disposal) to a point where it is misleading
people which can work to the detriirent of a comnunity or Ccmnunities.
A case in point is the Town of Amherst which built its regional
plant per mandates df the New York State Dapartinent of Environnental
Conservation large enough to service j.he Town of Clarence and part
of the Town of Newstead. Now, with the revised criteria of E.P.A.,
Clarence arid Newstead are looking at on-site managenent system
alternatives. If these towns are allowed to proceed, then Amherst
will have built a plant which is extrerrely oversized for its own
individual needs. If, in fact, they are allowed to proceed, then
municipalities like Amherst should be reimbursed the costs to build
the treal ient facility bigger than their own needs.
There is a breaic even point with on—site systems; whereby, it is
cheaper to consolidate plant s and use areawide manageirent
(by Mr. Cos tell). While the pendulum was swung too much this way in
the past, it now appears to be swinging too much toward the other
direction, towards on-site disposal.
15. State q:x ration & Maintenance Aid - StaLe Operation and Maintenance
Aid is one of the few items of relief which our local municipalities
can receive from high sewer costs. allstically, it only represents
about 5 - 10% of the total sewer charges to the individual taxpayer.
But when you are talking about an annual sewer tax bill of $350. it
rreans a reduction of $35. cer horre per year. Obviously, to be of any
c,jreat benefit, the actual amount of aid would have to be substantially
increased. (While the State is paying 25% aid, this aid is oniy for
eligible items on the sewage treatmant plant. It doos not cover
lateral sewer maintenance, interc .ptor sewer maintenance or administra-
tive cost of a sewage treatnent plant.) The Federal Governmant should
provide 0 & M Aid to con nsate municipalities for adthtional 0 & N
costs which would put them in a disparity with other states in the
Nation. L ikewise, the State should suppleirtant the 0 & M costs to the
extent that the State requi eirants would exceed the Federal require-
Irents for discharge.
Besides financial benefit, the State 0 & M Program has helped to improve
sewage treatment, had a beneficial affect on maintaining and upgrading
operational status of municipal wastewator treatin nt plants, and has
been a useful administrative tool to improve all aspects of sewer service.
A rrore detailed justification is contained in the D. E . C. prepared
document. (Technical Paper No. 44). A copy of wiuch is attached.
16. Implementation of Advanced WasLe Trcatim nt — P.dvanced waste treathent
projects should not be implemented unless a sufficient amount of
menitoring arid nodeling has been done.
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—9—
17. Staff]nq at the D.E.C. L vcl — The State should have rrorc personnel to
carry out their review of waste treatm nt projects. Locally, nore
staff will ce reqw.red, and both the new staff and the c
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W he u y
ALFRED B. DEL BELLO
County Executive
WILLIAM G. BORGHARD, P E
Commissioner
Department of Environmental Facilities October 3C), 1970
Mr. Kenneth Sto].ler
New York-Nov. Jersey Construction Grants
United States Environmental Protc tion Agency
2G Fc cral I’].a a
N w Yoric, New Yoth 10007
flea EPA Industrial Cost iecovery Study
Clean Water Act of 1977
At the public meeting of October 1(3, 1970 in New York City
relative to the above noted study, it was indicated that written
statenents may be submitted as p&rt of tho official record through
November 6, 1970. This letter will constitute cox uttent from the
County of Westclioster.
of particular note at the meeting was the lack of comment
from industry. While the consultants have obtained input from
industry in prepapation of data, such input is limited and has been
largely from selected industries. Realistic projections of actual
U3OV charges and I.C.R. charges to industries in the New York area
generally are not available to industry. This fact, very likely,
account3 for the lack of comment from the industrial community.
It ic ur od, on behalf of octie er County’s industries,
in line with the philosophy behind the public participation require-
ments of the Federal Water Pollution Control Act, that a further
moratorium on cost recovery payments } j industrial users beyond July
1979 he enactd to allow meaningful participation by those 1 nose
effected. /) / /
— z 7
William 0. Borghár( , p, j .
Comtniesioner
cc: Coopers Lybrand
Alfred a. Del Bello
t. ’estcheetor Cou. ity Association Inc.
532 County Office Building • White Plains, New York 10601 • 914 682-2613
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MIAMI—I)ADE WATEF AND SEWER AUTHORIUY
P o F3OX 330316
MIAMI, FLORIDA 33133
October 30, 1973
United States i&nvtrogz .ntM1 rrotoctioti Age icy
E ton IV
421. Peachtree Street, N, .
Atlanta Georgia 30309
Attmntioas ft. Joha C. bLts, M 4 eL.truoa
Cent 3..,men;
Our Authority representatives attended the E.P.A. public sstio
o Industrial Cost ecovery (ICfl) in Atlanta, (50r€ia on October 26,
l97 . They have reported fully on the presentations and statesents
eads and have inforsed as of the opportunity to pr.aest additional
•tat snts fot the public record prior to govesber , l97 .
£ tborou h dteceasioa of the pointi raisd at the public meetiag
lead. us to conclude that the alterosUve i ivolving Ibolitian of XCI
La by far the c oet desirable approach. Our reasons are described below.
b cotirinue to feel very u i ly that the XCI provision of
P.L. ?2-50Q is t spscLally onerous and financially eoimt.rproductiv.
Lu an ares such as Dada County, florida where industrial vaetevater
Tepr•senta auth a small proportion (less than 4 percent) of th. total
waatav*tar treated. Thu. proposed chsr .e viii certainly tend to
diecoura e t atcpaiieion of our industrial base, which La viewed as
e ocial1y i tVortant to the dtveraificettou of the local, econcay.
W i concur with the study findings and various public atate ents
that the ICa revenue returned to the Federal Cov.rsn.nt will be . ieh
lees tt’ n ori’LnalLy project 4 ‘in.t tharc t’ors is i iuc 1 i lev s o s nec ative
ftictor In co isiJar1n; abolition o ICR. In fnct we feel that the cost
c ( local Liti atLoit, which seat certsitty will he incurred because
of the pro r ’s cospio tty, h , riot been adi quace]y considered.
In addition to tocal ftandtn factors, controls do exist at beth
State end Federal levels, to dtacou e rantaes froa eonotructin
liir izer traarsent works 2han oocc ar’y if IC is abolished.
-------
United States Environmental Prot•ction Agency
October 30 1978
Page Two
One very inportant factor, discussed at the hearing, involved
the yet unknown effect of the new I .P.A , pretreatsent regulations,
At the very least, vs (eel the present ICR cioratoriui to June 30,
1979 should be extended until these regulations hav, been in place a
sufficient length of time to evaluate their .ff.ct on the overall ICR
problem.
Finally, should 1.P.A/. JeaLd. to r.eo mend continmamee of the !CR
program in eons form, we feel it rhould be limited totally to treatment
plants, with rates established on an overall national level and with
. eaptious for areas whose total industrial usage is lees than 25Z of
trsat uont plant capacity.
Thank you for the information provided and the opportunity to
prsa6nt this etate&ieat for the public record.
Very truly yours,
Garrett Sloan
Director
CS/CAL/bc
cc: The I onorab1.e Stephen P. Clark
Mayor, Hetropolitan Dad. County
Dade County Courthouse, Second floor
tliani, Florida 33130
1r. Lester Freeman, Ezecutiva Vies President
Cre atc r Mizrii Cbay,ber of Cornmerce
I2GQ l3iacsyns Soulevard
Miaui, Florida 33132
Mr. John Lurt.baus
United States tvironaontal Protection Agency
Region IV
421 Peachtree Street, L K.
Atlanta, Georgia 30309
1r. George A. F iug, Special Assistant to the Director
Miami—Dade Water nd Sewer Anthority
P. 0. Box 330316
Kia t, Florida 33133
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Uiitced Statee E3vironmental Protection Agency
October 30, 1978
Page Three
ces Mr. Myron Oldstein k-
Coopers and Lybrand,
Certified Public Accountant.
1900 ( Street, L V.
Washington, U. C. 10036
Mr. Merritt ft. Sti.rheia, County Nanager
Dade County Courthouse
Room No. 911
Wta i, Florida 33130
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___ 215P EST NOV 78
ICS LPMMTU CSP
2 1b412552 TD 1 T LITTLE FERRY NJ 74 11- 142F EST
PMS COOPER. AND LYBRAND ATTN MYRON OLSTEIN, DLR
M S N3’ Tr(4E T
4ASHLN TON DC 2 36
ICR Sr(OULD bE ABOLISHED (C&L ALT 1)
I- ICR NOT COST EFFECTIVE. DUE TO INFLATION ( PERCENT)
FOR BCUA:
A- NET ADMINISrRATIvE COST EXCE.3 OF IC t EVE UES Ar*RO MATELY
B- NET SUM OF “r ECONSTRUCTION” FUND EQUIVALENT TO IN 1978
DOLLARS 1: SIGNIFIcANr COMPARED TO 34.3 1ILLION DOLLAR 3RANT.
U- EPA RETAINED AD. UNISTRATLVE CONTROL OF 3RANrs THE EFO E CONCERN
OF EXCESSIVE DESI3N CAPACITY FOR INDUSTRIAL USERS Nor JUSTIFIED.
DETAILS AVAILAdLE ON REQUEST
SF.1201 (R5-69)
J 3 COStELLO. EXECUTIVE DIRECTOR
NN N N
WAF13 (1343)(4-04 714E312)PD 11/08/lb 1342
SF.1201 (R549)
-------
Industrial Cost Recovery Public Meeting
Region III
Benjamin Franklin Hotel
Philadelphia, PA
10 AM October 20, 1978
EPA — Greene Jones, III, Water Pr,ograms
Division Director
Thomas Maker, III UC/ICR specialist
John Gall, EPA Washington
Thomas J. Moran, EPA Washington
C&L — J. Mikul Townsley
Myron A. Olstein
45 Attendees:
H. P. Green Guy A. Aydlett
Wyeth Laboratories Hampton Roads Sanitation
District
Paul Hess Jack Cooper
Hershey Foods Corporation National Food Processors
Hershey, PA 17033 Association
Washington, D. C.
Howard J. Lobb L. C. Gilde
Black & Veaths Consulting New Castle Country
Engineers Delaware
Kansas City, MO
H. J. Amici J. B. Asilania
Penna Power & Light Co New Castle County
Delaware
John E. O’Brien John V. Dougherty
Matlack, Inc. Gannett, Fuming, Corddy &
Carpenter, Inc
Harrisburg, PA
Thomas L. Goodwin John T. Kane
W. Va. Dept. of Natural The Chester Engineers
Resources
V. J. Gordon, Jr. Jim Canterbury
Roy F. Weston, Inc. W. Va. Dept. of Natural
Resources
J. G. Weidman D. S. Patterson
Betz Lahs Prior Coated Metals
Trevose, PA
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Thomas Kulesze D. G. Clarke
Phila. Water Dept. Rohm & Haas Co.
Fred Grant Paul J. Sierackj
EPA — Region III Phila. Water Dept.
R. P. Schiwall Bruce Kraeuter
A.W. Martin Assoc. Water Resources Agency for
•New Castle County
George a. Golia - M. D. Hopkins
Betz—Converse—Murdoch PA State or United States
Breuers
William Moore Joseph W. LaCerra
Rohm U Haas & Co. C. Schmidts & Son
Philadelphia
Bob Reed Tom Heley
EPA — Finance Phila Water
Paul H. Grandolfo Bill Hoffman
EPA — Audit EPA — Finance
Jospeh Saiwen John H. Williams
Crown Paper Board Western Electric
Allentown, PA
J. Robert Gallegher William A. LaFrankie
D.V.R.P.C. Pet Incorporated
Phila, PA Allentown, PA
William C. Goe Lzer Robert A. Schway
Landis Sewage Authority Landis Sewage Authority
Vineland, NJ Vineland, NJ
Arthur S. Vanek Gardner Cox
F. & M. Schaefer Brewing Co. Perferdel Corp
Allentown, PA Eriv. Improvement Committee
Phila, PA
V. H. Hathaway C. D. Yoh
Jaca Corp State of Maryland
Ft. Washington
Richard Snide Don Wchtz
Lehigh Valley Dairy City of Allentown
Allentown, PA
Blake C. Marks Michael D. Verra
Butz, Hudders & Tailman City of Camden
Allentown, PA New Jersey
-------
Charles Bodo
Coopers & Lybrand
Complete presentations of
• Purpose of study
• Project scope and methodology
• Findings, conclusions and possible alternatives
Statements presented by
Representative for th Honorable Anmgelo J. Errichetti,
Mayor of the City of Camden, NJ
Present restrictive DC and ICR requirements adversely
affect Camden’s ability to compete with other
communities.
Jack Cooper National Food Processors Association
Abolish ICR or, if not possible, charge tiC and ICR on
only incremental industrial costs.
L. C. Gilde, Campbe1 Soup Company
Abolish ICR and provide for greater flexibility in
developing user charges.
Howard Lobb, Black & Veatch Consulting Engineers,
for the city and County of Baltimore, Maryland
Abolish ICR
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ENVIRONMENTAL
ENGINEERS & PLANNEPS
945 Fourth Avenue
Coreopolie Pa 15108
Phone 412/771-4320 — —
Phone. 412/202-1035
October 30, 1978
Coopers & Lybrand
1800 M Street, NW
Washington, D. C. 20036
Attention: Mr. Myron Olstein
Gentlemen:
These comments are directed toward the ICR problem as presented
in the public meeting attended by the writer in Philadelphia on
October 20, 1978, and specifically in response to the handout
at that meeting entitled “Preliminary Compilation of Possible
Study Alternatives” and the discussions regarding that document.
The first alternative would abolish ICR which we as consultants
to many sewerage agencies feel is the only practical solution
to the many problems encountered with the ICR concept. The
advantages listed for this alternative do not fully describe
the situation. Small sewerage agencies are ill-equipped and
staffed to perform the accounting tasks required by ICR and
will be required to add staff in a non—productive area which
will increase overall costs to the users of the system, all
of which does nothing to clean up the waters of the country.
In the case of large sewerage agencies, the ICR concept poses
additional costly problems of administration due to the diver-
sity and location of many “industries” in a metropolitan area.
The disadvantages listed for this alternative are largely
untrue. ICR provides no control over the design parameters
of a treatment works. Sizing is controlled by other sections
of the law (cost effectiveness, reserve capacity, pretreatment).
The Federal government will receive no net revenues from the
ICR concept when the corporate tax situation is considered,
since the Federal government would receive only 50% of any
ICR payment, but the industry could deduct as an expense 100%
of the payment and it can fairly be assumed that such industries
will be in the 50% tax bracket. The net effect to the Federal
government is, therefore, zero.
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Coopers & Lybrand
October 30, 1978
Page Two
In the discussions of this alternative, several allusions to
the societal effects desired by Congress were made but were
not quantified. While we are not sociologists, we find it
hard to believe that anyone, including Congress, would con-
ceive of society without including industry as an integral
part thereof and, as such, the ICR concept is counter-
productive to society in general. The whole idea of ICR
seems incongruous when it is considered that through other
agencies the Federal government is spending billions of
dollars to encourage industry and to create jobs.
These comments have been directed toward the first alternative
considered by Coopers & Lybrand because it is the only plausible
alternative to those who will be saddled with the implementation
of ICR if that concept is retained as a part of the clean streams
program.
Very truly yours,
THE CHESTER ENGINEERS
JTK/skw
cc: AMSA
K. R. Harrington
Thomas Maher
ne
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QIoflntWnri 2z11tI 1 Of
HAMPTON ROADS SANITATION DISTRICT’. .
COMMISSION MCM R
BOX 5000 5. DUANE HOLLOwAy
MAURICE A PCR ON. , - , t - ‘ C I IAIRMAN .4 ’ . u’--.
A5$T OEM NOR 4 I. , , .
• DIR. OF CNG•NCCRIMU - VIROINIA BEACH,VIROINIA 23455 WILUAM T.
ANNA MARIE OOTTOMS • •• I • L VICE CHAIR. AN
.1 •.. • .
- ., I . J. CLYDE M5NRI
JAME S P. BORBERO. P C - ‘ • - ‘I
DIR Or COMSYNUCTIOM • - • -. • ROBERT t . IICIOC , N. 0 .
• EUGENE II. OOF IGON - • . October’ 27, 1978 S - WILLIAM A.COXaJR¼P. Li
j DIR. OF TREATMENT . ‘ . • CARpI.YN II. CO PMAP4
‘POBCRT H PORTER, JR 1 t• . - . ‘ S - ‘
DIR Ør FINANCE 4 ADMINISTRATION ., S , , ,• ‘ 5. WALLACE STIC rEN
. 5 ,, r
DONNIC P. WHEELER F ‘ ‘ ‘ •. , - CH SLCYH McGINNI5
DIR OF WATER QUALITY • ‘ ‘, • S
1 I ‘ I I. S 1’ ‘ • 1 —
1: Mr. Thomas Maber • , - •;; ‘ •.,, • •• ‘ I, . , . I
‘ , Enviroumentaj Protection Agenoy.:’ ..; ‘ ‘ “ • ‘ I
‘ : ‘ . RegionTtI— Sixth .-Wa1nut Streetu- :‘- . y” . . •:-
Philadelphia, PA 19108 ,‘ •. •. ‘ . .
I • . —
. 5 I .. •,1 ’, .,
Dear Mr. Malior: ‘ ••- ‘ . S S •
As a result of HRSD’s representation at the ICR public rneeting . ”
on October 20, 1978, the following statement is Dreseflted: , . •
S • ‘S ,• • S S S S
‘I S • .
The’Hampton Roads Sanitation District, havinghad one of ,the .’ .
first approved ICR systems in the country and having’ remitted money
to EPA representing two ‘years of ICR billing, has had a great deal of ‘
experience with ICR. The Industrial Cost Recovery program has not -
fulfilled any purpose foi’ which itwas Intended. Preliminary findings
of the Coopers & Lybrand study support this statement. It Is apparent
that any system of recovering grant costs from an industrial user ot..a
Publicly Owned Treatment Works is neither cost effective, nor adinin—
istratively practical. • - . ‘ :
The Hampton Roads Sanitation District is an active member pf the’.’
Association of Metropolitan Sewerage Agencies fAMSA) and fully concura.
with their recant statement’ calling.for abolition of.Induetria]!.çoat. r.
Recovery. - ,: 1 . - — •:• •‘. : ‘- .•‘ • 5, • ‘- • : ‘-
S • •, ••_ • , - . S., -. - . - - • S V. ‘ .S 41,
“ • IS ‘ ‘-5 5 5 •‘ - .‘ _ç’ • ‘l 4 .
• I am sure that ,Con ,g eas,’ ..j.intpntions ’. concerninthe-baaiO JQ*floep.t
of Industrial Cost Recovery were good, however, our law makers must loo...
at the practicality, reasonableness, and effectiveness of this “monster”
which they have created. It Is hoped that the findings in the Coopers:
& Lybrand study will be presented to Congress by EPA supporting dlscofl—
tinuation of the ICR program. .•
‘3.-
Thank you for this opportunity to comment and participate in tha,
ICR review process. ‘• ‘ ‘ - •- : •.
Sincerely,
• James R. Borberg
General Managor
tim /
cc: Myron Olstein, Coopera& Lybrand ”
AMSA, Wash., D.C. ‘ •
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CITY OF SOUTH BOSTON
•SOUTH BOSTON. VIRGINIA 24592
OFFICE OF
CITY MANAGER
August 24, 1978
Mike Townsley
Coo pers & Lybrand
1800 M Street, N. W.
Washington, D. C. 20036
Dear Sir:
We are returning herewith the response to your request for
information concerning the legislative study of Industrial Cost
Recovery.
Where data is not precise we have given you the best possible
estimate.
The secondary sewage treatment plant was, for all intent and
purposes, completed approximately one year ago. However, to date
the plant is still not performing to design criteria. There are
several problems, n stly failure of substituted mechanical equip-
ment, to function properly.
Thoug1 Council has adopted the I. C. R. System, and it is our
intent to bill the industries as of June 30, 1978, this has yet to
be done.
Those of us in small communities raise objection to the required
contribution by industries who are “substantial users” of the system.
A substantial user in South Boston (such as Daystrom Furniture)
would not be required to contribute anything if they were located in
a large metropolitan area where their consumption, for example,
might be of l , as opposed to 10 or 20’s in a small community. It
is a deterrent to having industry locate in a community.
Though we cannot prove that an industrial prospect did not
locate here as a result of the I. C. R. system I can attest that it
was a consideration and this community was not selected.
Some of the data is rough but hope it will be of some benefit.
Sincerely,
ty Manager
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Industrial Cost Recovery Public Meeting
Region IV
Civic Center
Atlanta, Georgia
10 AM
EPA -
Margaret Davis
Robert Wheeler
Joseph R. Greeley
James A. Hulme
Richard Sedlak
F. James Wound
William McCabe
Douglas Tozzoli
A. W. McKenna
Paul E. Peters
Mathew Foster
Robert Caddell
William H. Wechter
N. Gilbert
Bergen County Utilities
Authority
EPA, Region II
Grumman Aerospace Corp.
Dvirka & Bartilucci
American Cyanamid Corp.
Soap & Detergent Association
Warner—Lambert Company
EPA, Region II
Parsons, Brinckerhoff,
Douglas
Wiendiel Engineers, P. C.
American Bakers Association
County of Nassau, DPW
Westchester County, Dept. of
Environmental Facilities
Greeley & Hansen
Lobsenz—Stevensens, Inc.
(for CTL)
EPA Region II
October 26, 1978
Kirk Lucius, IV, Deputy Director of Water Division
John Hurlebaus, IV, UC/ICR Specialist
John Gall, EPA Washington
C&L - J. Mikul Townsley
Myron A. Olstein
7 Attendees:
Edward J. Brouillard II
Quade &
M. Hunter
-------
G. William Calascione Pollio Dairy Products Corp.
Paul R. Paquin Hydroscierice Incorporated
Irwin Novj k N.Y.C. EPA, Dept. of Water
Resources
Martin Rivlin N.Y.C. EPA, Dept. of Water
Resources
Joseph T. McGrough N.Y.C. EPA, First Deputy
Commissioner of Envir. Protection
Douglas H. Starr Thomas J. Lipton, Inc.
Mae Wong N.Y.C. Staff of Congressman
John M. Murphy
William Lauer Clinton Bogert Associates
Complete presentations of
• Purpose of study
Project scope and methodology
• Findings, conclusions and possible alternatives
Statements presented by
Joseph T. McGrough, First Deputy Commissioner,
Department of Environmental Protection, City of New York
Eliminate ICR
Honorable John M. Murphy, Congressman
from New York. — as read by John Gall, US EPA
Eliminate ICR
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HARRY £ INGRAM. MANAGER
COBB COUNTY
WATER AND POLLUTION CONTROL SYSTEM
1772 County Farm Road
MARIETTA, GEORGIA 30060
427-8481
November 3, 1978
Mr. John C. White
Regional Administrator
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 303O
Re: Environmental Protection Agency
Industrial Cost Recovery Guidelines
Dear Mr. White:
We appreciate the opportunity to comment on the development and implemen-
tation of guidelines which have as significant an impact as the Industrial Cost
Recovery guidelines. The intent of these regulations was encouraging initially.
However, changes in related regulations and guidelines require careful consid-
eration of those for ICR.
The original intent of PL 92—500 was to eliminate the discharge of pol-
lutants to this country’s waters. To achieve this goal, our government pledged
the expenditure qf vast sums of money to subsidize the construction of necessary
treatment facilities. This money in turn came from the industrial and individ-
ual taxpayers who were to ultimately use these facilities. The initial thrust
of the ICR requirement was industrial repayment of tax monies allocable to the
treatment of such industrial waste to the extent attributable to the federal
share of the cost of construction. Herein lies the major fallacy of the law.
EPA, six years after the passage of FL 92—500, has not been able to arrive at
a practical and impartial method in which to measure the economic effect of
waste loads from what is considered like industries, let alone dissimilar
industries discharging to the same POTW. Because the effect of the waste loads
cannot he accurately measured against the capital cost, the ICR cannot be
equitably proportioned between industries.
In conjunction with the ICR requirement, EPA has also implemented two other
sets of regulations. The first is the linear rate schedule scale and the second
is pretreatment requirements. Originally, pretreatment by industries was not
implemented in cases where the treatment costs related to high concentrations
of industrial chemicals were recovered through Industrial Cost Recovery. This
allowed some option on the part of the industry. The present policies reflect
EPA enforcing pr treatment consistent with best available treatment economically
achievable. The,r’esult will be that industries are going to remove pollutant
loads originally assbciated:wi.th Industrial Cost Recovery. The net effect is that
ICR will not api l9s.origina ] I$oncejved. This change in concept combined with
implementation a id’ headaches results in ICR being a most impractical
proposition. ‘
-------
Pir. John C. White
November 3, 1978
Page Two
The rate schedule is another factor affecting the treatment of industrial
wastes. In the future, the EPA rates which don’t reflect economy of scale will
encourage new industries tq locate where economy of scale for wastewater treat-
ment can be achieved. The implementation will discourage the connection of
industrial facUlties to POTW. In the future, industries with wastewater easily
(renteqj will locate out of the POT T . Likewise, industries which have wastes
difficult to tr(’ - L will connect to P0Th hoping the combined treatment schemes
can r’movc or dilute the effects of trace pollutants hich cannot be readily
removed iiLh economical treatment schemes.
A key factor ignored by most EPA personnel is the enforcement of these
ICR regulations. In many instances, industrial wastewaters are discharged insidE
one political boundary and are treated in a second boundary. The enforcement
of ICR under these circumstances will generate turmoil in the best situations.
The long term effect of the inconsistencies mentioned above will ultimately
place detrimental economic burdens on local governments and private taxpayers.
Also, the origi.nal objectives have been greatly diluted by pretreatment rate
structure and reserved capacity reauirements. The net effect is that 1CR will
not serve a purposeful function and should be abolished.
Sincerely,
Manager
tiLl I L.im ‘t . Floyd
Supervising Engineer
W lF: Lb
cc: Ernest (4. Barrett, Chairman, Cobb County Hoard of Commissioners
a-
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MIAMI DADE WATER AND SEWER AUTHORITY
P. 0 BOX 330316 Main Offuc.
3575 S LaJeun. Road
MIAMI. FLORIDA 33133 Telephon. 665 7471.
October 30, 1978
United States Environmental Protection Agency
Region IV
421 Peachtree Street, N. E.
Atlanta, Georgia 30309
Attention: Mr. John C. White, Administrator
Gentlemen:
Our Authority representatives attended the E.P.A. public meeting
on Industrial Cost Recovery (ICR) in Atlanta, Georgia on October 26,
l978 . They have reported fully on the presentations and statements
made and have informed me of the opportunity to present additional
statements for the public record prior to November 6, 1978.
A thorough discussion of the points raised at the public meeting
leads us to conclude that the alternative involving abolition of ICR
is by far the most desirable approach. Our reasons are described below.
We continue to feel very strongly that the ICR provision of
P.L. 92—500 is especially onerous and financially counterproductive
in an area such as Dade County, Florida where industrial wastewater
represents such a small proportion (less than 4 percent) of the total
wastewater treated. These proposed charges will certainly tend to
discourage the expansion of our industrial base, which is viewed as
especially important to the diversification of the local economy.
We concur with the study findings and various public statements
that the ICR revenue returned to the Federal Government will be much
less than originally projected and therefore is much less of a negative
factor in considering abolition of ICR. In fact we feel that the cost
of local litigation, which most certainly will be incurred because
of the program’s complexity, has not been adequately considered.
In addition to local funding factors, controls do exist at both
State and Federal levels, to discourage grantees from constructing
larger treatment works than necessary if ICR is abolished.
a. -
-------
United States Environnieiital Protection Agency
October 30, 1978
Page Two
One very important factor, discussed at the hearing, involved
the yet unknown effect of the new E. P.A. pretreatment regulations.
At the very least, we feel the present ICR moratorium to June 30,
1979 should be extended trntil these regulations have been in place a
sufficient length of time to evaluate their effect on the overall ICR
problem.
Finally, should E.P.A. decide to recommend cont [ nuauce of the ICR
program in some form, we feel it should be limited totally to treatment
plants, with rates established on an overall national luvel and with
exemptions for areas whose total industrial usage is less than 25% of
treatment plant cdpacity.
Thank you for the information provided and the opportunity to
present this statement for the public record.
Very truly yours,
4 / • --- -
d’arrett Sloan
Director
CS / GAK/ bc
cc: The Honorable Stephen P. Clark
Mayor, etropolitan Dade County
Dade County Courthouse, Second Floor
Miami, Florida 33130
Mr. Lester Freeman, Executive Vice President
Greater Miami Chamber of Commerce
1200 Biscayne Boulevard
Miami, Florida 33132
Mr. John Hurlebaus
United States Environmental Protection Agency
Region IV
421 Peachtree Street, N. E.
Atlanta, Georgia 30309
Mr. George A. King Special Assistant to the Director
Miami—Dade Water and Sewer Authority
P. 0. Box 330316
Miami, Florida 33133
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7
615637455 TDBN KNOXVILt.E TN 108 11-01 043SP EST
PMS DIRECTOR REGION 4 ENVIRONMENTAL PROTECTION AGENCY, DIR
345 COURTLAND ST
ATLANTA GA 3O3O
ALL POSSIBLE STUDY ALTERNATIVES INCLUDED IN UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY INDUSTRIAL COSTS RECOVERY STUDY
THOROUGHLY REVIEWED AND ANALYZED. IT IS THE RECOMMENDATION OF
GREATER ‘(NOXVILLE CHAMBER OF COMMERCE UPON ADVICE OF ITS
ENVIRONMENTAL QUALITY TASK FORCE THAT ALTERNATIVE NO. I BEING THE
COMPLETE ABOLISHMENT OF INDUSTRIAL COST RECOVERY BE SELECTED AS
RECOMMENDED ALTERNATIVE BY COOPERS AND LYBRAND AND EPA. SHOULD THIS
ACTION NOT BE TAKEN RECOMMEND ALTENATIVE NO. 14 BE SELECTED TO
EXTEND CURRENT ICR MORATORIUM. INDUSTRY HAS BORNE BURDEN OF RECOVERY
sF.I2oIcr . RTIONS OF CAPITAL COSTS OF TREATMENT PLANTS LONG ENOUGH. URGE YOUR
SERIOUS CONSIDERATION OF THIS REQUEST TO END DOUBLE TAXATION OF
INDUSTRY.
SINCERELY,
I O JOHNSON, PRESIDENT
NNNN
AAC2RG(I644)(4—O53703E305)PD 11/01/78 1638
ICS IPrIBNGZ CSP
sF.I,GI (Rio,)
-------
A. NUSt NbAUM
MAYOR
orrict or
MAYOR
J W FORR Srt
CITY MANACIR
U. S. Environmental Protection Agency
via
Region IV Public Hearing of October 26, 1978
RE: Industrial Cost Recovery System
Gentlemen
The City of Meridian, after six years of diligent effort under Public Law
92—500, is on the brink of launching its construction program of wastewater
treatment facilities. We are deeply concerned with the implications that
the proposed Industrial Cost Recovery System will bring to our city of about
50,000 people.
We wish to take this opportunity to express our objection to the ICR System
for the following reasons:
1. Administration of the ICR System will be a tremendous burden, and vexing
to say the least. In our small town (but the second largest in Mississippi),
we have about 400 commercial and industrial users who would probably become
entrapped in the system. We can visualize a separate division of our water
ard sewer department just to administer the program.
2. At what flow value would a user be exempt from the ICR System? There are
certain fixed administrative costs, such as sampling, analyzing, billing, col-
lecting and record keeping which are independent of the flow quantity of the
user. In our opinion, administrative costs would exceed the present ten per-
cent (10%) of the total charges which municipalities would be allowed to retain.
3. Due to the strict effluerrt limitations placed upon our community, the ICR
charges would be higher here than in some of our neighboring communities where
CITY COUNCIL
N R. ANO(RS
BILLY FORT
OR. NOB RT KORNEGAY
BROGAN PRICE
JIM SPEED
COLJNCIL.MANAGER GOVERNMENT
MERIDIAN, Miss.
October 25, 1978
-------
Page Two
U. S. Environmental Protection Agency
October 25, 1978
lesser (secondary) discharges are permitt ed. This differential in charges
would place our community in.an unfair position in trying to attract new
industry, or keep the industry which we have for that matter.
4. We also believe that such a system will tend to drive Industry out of
municipal systems, even to rural areas at a location where the industry, as
a separate discharger, could utilize secondary treatment.
We respectfully request that you seriously consider these arguments in forming
your opinion.
Yours very truly,
I. A. Rosenbaum
Mayor
IAR/gy
-------
ALl —\ v M_ 4 DEr IArJ , ir’4c.
VALDESE. NORTH C AROLINA 28690 704 874-2191
October 12, 1978
Mr. John C. White
Environmental Protection Agency
Civic Center - Room 201
Piedmont Avenue
Atlanta, C,eorqia 30308
Re: EPA Public Meeting on Industrial Cost Recovery
Dear Mr. White:
I have your announcement about the upcoming EPA meetinq in Atlanta on
October 26, 1978 and have these comments that represent a consensus of
our President and Officer group here at Alba-Waldensian.
Although we are strongly civic minded and believe in paying our way,
we are non the less in the textile industry and with inflation, foreign
imports, regulations and all the other adversities of modern business,
hard pressed to meet our responsibility to our employees, stockholders,
and the public in qeneral.
We. believe that the cost of proper waste treatment should be spread
more broadly to all facets of American society.
Specifically, Valdese’s water and, waste treatment utilities have in the
past been amortized on a self-supporting basis, so that to a degree
Alba-Waldensian will have to pay twice for facilities now in use. Also,
due to our quantity of facility usaqe, we have had to declare future
needs of waste treatment that we may or may not use.
If the moratorium declared on industrial cost recovery is rescinded,
waste treatment facilities should be amortized on the longest possible
life of the facilit,y.
.Finally, we think that protecting the environment is a responsibility
of all United States citizens, therefore corporate citizens should not
SALES OFFICE EMPIRE STATE BUILDING NEW YORK N V 10001
/ OIJNS 314-7915
-------
Mr. John C. White
October 12, 1978
Page Two
have to pay 100% of our capital waste treatment cost. Providinci jobs
is a responsibility of all citizens and should be supported accordingly.
Y ours sincerely,
ALBA-WALDENS IAN, INC.
Philip H (arrou
Senior Vice President
PHG:lc
CC: Mr. Richard E. Whitley
Town Manager
Valdese, North Carolina
Honorable James T. Broyhill
House of Representatives
Rayburn House Office Building
Washington, D.C. 20515
-------
Valdese Manufacturing Company
TEL. 704 874-2156 VALDESE, NORTH CARoLINA 28600
October 23, 1978
SPECIAL DELIVERY
U.S. Environmental Protectian Agency
Region 4
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Gentlemen:
The following are comments in connection with the Region 4 EPA public
meeting to be held on October 26, 1978, in Room 201, Civic Center, Atlanta,
Georgia.
Some time ago, as part of the requirements of Section 75 of the Clean
Water Act of 1977 (P.L. 95-217) Valdese Manufacturing Company, Valdese,
North Carolina, signed a more or less open-end contract to purchase a stated
amount of daily water consumption from the Town of Valdese, North Carolina.
The proposed construction was the eastern outfall in the Hoyle Creek ex-
pansion of the Town of Valdese.
Va].dese Manufacturing Company is a textile yarn manufacturing company with
a large yarn dyeing facility. It is essential that we have proper filtra-
tion and sufficient volume of water to carry out the manufacturing purposes
of our company. We employ approximately 400 people within the Town Limits
of Valdese, North Carolina, and our annual volume of sales is in excess of
$20 million.
The requirements under Section 75 of the Clean Water Act of 1977 requiring
users of water filtering facilities under the Industrial Cost Recovery
(ICR) program to sign open-end contracts is certainly inconsistent with
general business practices. To be required to sign a binding contract to
pay an unspecified amount for filtration plant construction at some date
in the future is, in my opinion, economically dangerous. We would pledge
to pay all cost overruns, inflation and general changes in construction
cost without having any idea what the ultimate cost of such a project would
be. There is also a question in our minds as to who would own the facility
if ever completed and who ‘buld have jurisdiction over the amount of water
filtering capacity that would be owned by our company. We have questions
as to the tax treatment of such proposed expenditures. In total, I find
the whole program most unbusinesslike and possibly inequitable to new
businesses coming into the town and county and to the residents of the
Town of Valdese. .1 do not believe that this is the intent of the act.
PACKAGE DYERS OF ALL TEXTILE YARNS
&eeah, , .)1 ilf(,, ‘ l J,J
COMBED
MANUFACFUREUS OF CorroN YAI S
CARDED
-------
I
U.S. Environmental Protection Agency
Page2
October 23, 1978
The uncertainties for Valdese Manufacturing Company of financing as
attempted undet the Clean Water Act of 1977 is certainly questionable
since a slight miscalculation by us, as to our future water usage, could
result in a serious economic problem for our company. Also, our competi-
tors in neighboring cities who have already funded the cost of their wate
consumption under regular procedures would certainly be at a tremendous
competitive advantage with a dyehouse whose water cost would be det ermined
by the ultimate cost of this open-end contract. At present, the U.S.
textile industry is at a serious disadvantage with imports from the
eastern countries of the world. To add additional costs as would occur
under the Clean Water Act of 1977 would only result in a further dis-
advantage in world trade to the domestic textile market.
In the past, supplies of water for the purposes described in the precedin,a
paragraph have been provided out of current taxes and the industries con-
suming the major portion of the water paid the major portion of taxes as
a result of their large asset base and also paid for the gallons of water
consumed. This appears to be the only fair and equitable manner in which
a facility of t iis type can be financed along with funds granted by state
and federal agencies.
Yours very truly,
VALDESE MANUFACTURING COMPANY
PCR/gb
CC: Mr. Richard Whitley
Mr. Ed Pascal
-------
County
556 North McDonough Street / Decatur. Georgia 30030/ 404 371 2881 Board of Commissioner,
Walter B Ru ,sell Jr . Chairman
- William A William;• District 1
October 26, 1978 Liane Levetan, District 2
Robert E L.anuer Distqict 3
James M Patterson. District 4
Brince H Manning, Ill, At Large
Manuel J Maloof At Large
Mr. John White
Regional Administrator
Environmental Protection Agency
3 i5 Courtland Street, N. E.
Atlanta, Georgia 30308
RE: DeKalb County’s Statement
Opposing Industrial Cost
Recovery (ICR) - Public
Hearing of October 26, 1978
Dear Mr. White:
Attached is DeKaib County’s official statement opposing any form
of Industrial Cost Recovery. This statement was compiled in 1977 and
our position has not changed.
The ICR concept in any form or extent results in an additional and
unwarranted tax on industry which will be passed on to the consumers and
taxpayers of DeK.alb County and throughout the nation. This type of tax
is highly inflationary and will become a model of Federal government
bureaucracy and inefficiency.
In these t’imes of great concern by our taxpayers about the need for
cutting taxes, I think the members of Congress and EPA should be aware of
the consequences of such programs as ICR.
Not only is ICR an inflationary tax, but it would create inequities
in sewerage rates between adjoining counties. This would interfere with
the competitiveness of plant location and would also influence the move-
ment of existing plants. This unwarranted interference with the affairs
of local government is intolerable.
We also oppose ICR because it makes the EPA construction grant pro-
gram a loan program, requiring the payback of so—called grant funds back
to the Federal Treasury. This is highly inefficient and I do not think
this should be the Intent of the EPA construction grant program. If it
is called a grant program, then that is what it should be.
Your cooperation in t1 fs matter will be greatly appreciated.
Sincerely,
Walter B. Russell, Jr.
Chairman, Board of Commissioners
WBRJ r/cp
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.
1• 1 1
I • •‘
I: “i •.
• :: ! —
‘r ’ 1u i . Ij 1 (
!f J 1 !
CHARLES L DAVIS
Commissioner f Finance
W ROY SMITH, Director
Bureau of Management Systems
October 26, 1978
(,i I
,..\ 1 1. ‘\ J
MAYNARIJ JACKSON. MAYOR
DEPARTMENT OF FINANCE
601 CITY HALL.
ATLANTA, GEORGIA 30303
404/658-6480
ROBERT H JONES. Director
Bureau of Financial AnalysIs
and AudIting
DORIS H WILLIAMS. Director
Bureau of Treasury. Licensing
and Employee Benefits
RONNIE L. PATTERSON. Director
Bureau of AccountIng and
Budget Administration
Mr. John C. White, Administrator
Region IV, Environment Protection Agency
142] Peachtree Street N.E.
Atlanta, Georgia 30309
Dear Mr. White:
SUBJECT: Position Paper
on I.C.R.
The City of Atlanta is pr’oceding with it’s plans to develop and implement
an I.C.R. System in accordance with Public Law 92—500 and the grant
conditions upon which we have accepted E.P.A. grants. The Mayor and the
City of Atlanta’s Department of Finance have however expressed opposition
to the I.C.R. provisions of PL 92—500.
Submitted herewith are documents which set forth our opposition.
1. A position paper prepared by the City of Atlanta’s Department of
Finance and the DeKaib County Water and Sewer Department for
presentation to the Municipal Finance Officers Association
International Conference on Public Finance held in April, 1977.
This was adopted by the Municipal Finance Officer Association.
2. A copy of a resolution prepared by the City of Atlanta Mayor’s
Office for presentation to the LI. S. Conference of Mayors.
We hope that this data will be of value in your I.C.R. study.
‘Sincerely,
CIL4, kd (•
Charles L. Davis
Commissioner of Finance
CLD :H13/rbc
Enc] osures
cc: Jim Ih’ghsmith
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Proposed Resolution no. 32
Water Pol1u jon Control and Mayor 1aynard Jackson
Industrial Cost Recovery Atlanta
1) WHEREAS, all cities are required to abide by the Federa]
Water Pollution Control Act Amendment of 1972, Public Law 92—500
for the adequate control of water pollution; and
2) WHEREAS, Section 204(b) (1) of this Act requires local
governments to make provisions for industrial cost recovery/user
charge systems for the purpose of defraying cost of construction
of treatment systems by charging industries based on their in-
dustrial wastes: and
3) WHEREAS, many cities throughout the country have not im-
plemented industrial cost recovery systems because of financial
hardships and in dequate regulations; and
4) WHEREAS, the implementation of industrial cost recovery
systems requires sophisticated accounting systems, pollution
detection systems and means of enforcement; and
5) WHEREAS, Section 204(b) (1) and (2) infringes upon the rights
and responsibilities of local governments independently to set-
rates, assessments and charges for waste treatment services; and
6) WHEREAS, undue complications will, develop because of over-
laps in service areas over political boundaries; and
7) WHEREAS, stringent methods of coordinat!on will be c1iff i.cu1t
to institute among participants to avoid duplication of effort, as
well as gaps. in the data base; and
8) WHEREAS, all cities must achieve maximum water pollution control
as effeciently, economically, and quickly as possible to assure the
he lth and welfare of their residents;
9) NOW, THEREFORE, BE IT RESOLVED that the U.S. Conference of
Mayors seeks relief from Congress and the Carter Administration be-
cause of the tremendous difficulties involved in the implemenLatjon
of the industrial cost recovery systems within the Federal Water
Pollution Control Act Amendment of 1972, Public Law 92—500, a i
amended.
P’rojected Cost: Not computable.
— 39 —
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POSITION PAPER
INDUSTRIAL COST RECOVERY
The City of Atlanta and DeKaib County oppose Section 204 (b) (I) (B) of
the Federal Water Pollution Control Act Amendments of 1972 (PL 92-500) for
the following reasons and recommends that it be rescinded in its entirety.
I. The stated intent of Section’ 204 (b) (I) (B) is that “industrial users
of the treatment works make payments for that portion of the cost of
construction of such treatment works (as determined by the administrator)
which is allocable to the treatment of such industrial wastes” since
it is deemed to be inapproprLate “to subsidize industrial users from
funds provided by taxpayers at large.”
Industries pay taxes as well as private citizens. Thus to charge
industrial users for plant construction while not charging private
users is to discriminate against industrial users. This is particularly
true in the City of Atlanta and DeKalb County where an industrial sur-
charge is already imposed on industrial strength waste. Given that such
a charge as that imposed by the Industrial Cost Recovery requirements
was equitable, it would still in most cases be passed along to the
private citizen in the form of higher prices for the commodities pro-
duced by the affected industries. Thus instead of the private citizen
paying only taxes for plant construction costs, he is now faced with
numerous possible additional costs. These include higher prices for
the commodities produced by industries who must now pay the Industrial
Cost Recovery Charge. Also included is the high cost of the Federal,
State and local bureauracy needed to admLnister and police such an
unwieldy system. The admini.strative and operational costs of the
local government which must implement and operate the ICR System
must also ultimately be paid by the local citizen. There is also the
risk of the affected industry relocating elsewhere or of new industry
locating ela.where with the resulting effect this has on the tax base.
The positive effect of Industrial Cost Recovery on the private citizen
would appear to be non-existent since in no case will his costs be
reduced (there is no mention of reduced taxes for the private citizen)
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and ICR would seem to have no effect on the amount of strength of
effluent discharged. The math effect of ICR would seem to be a
distribution of tax funds from the wastewater facilities to other
federal programs at the expense of industry which must pay Industrial
Cost Recovery charges and the private citizens which must pay increased
costs for products.
II. The excessive cost of iiztplementation versus the questionable benefits
to be der’tved make Industrial Cost Recovery uneconomical from a cost-
benefit standpoint. This applies to the local) state and federal
levels, particularly to the local level. A local government is
faced initially with the cost of instituting a Industrial Cost Recovery
System which is quite costly (from $50,000 to $200,000) given many
industrial users, cross jurisdictional problems, many waste-water
treatment facilities and a large number of grants. Following the
implementation of an Industrial Cost Recovery System is the ongoing
annual costs of monitoring, enforcement, maintaining the necessary
accounting systems, auditing, and bill collecting. On the state and
federal level is the cost of administering and policing the vast
system which would seen to require considerable review, auditing, and
regulation. The legal costs of implementing and enforcing such a
system also needs to be considered, from the standpoint of disputes
between the federal and state governments and the local governments;
disputes between local governments when a wastewater plant covers
more than one jurisdiction; and disputes between the local governments
and industries within that jurisdiction.
III. The implementation and operation of an Industrial Cost Recovery System
would be an adininistt-ative and accounting nightmare at all levels of
government. The detail required to make implementation equitable
among all of the industries involved, the ongoing accounting structure
necessary, the annual monitoring required, and the policing required by
all leve _of government to inusre compliance would be both excessive
and costlr. Since “each new grant requires a separate consideration
of Industrial Cost Recovery,” and grants are generally received for
individual plants and lines, it is conceivable that there could be five
—2—
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to ten separate accounting systems and rate structures for Industrial
Cost Recovery, the administration of which would be both cumbersome
and costly, particularly if several other jurisdictions are involved.
IV. The legal, accounting and administrative problems imposed by a number
local governments being involved in a single grant are astronomical.
The governments involved, in the Three River Project I or example
include Atla ta, DeKalb County, Fulton County and Forest Park with
Atlanta the grant recipient and all of the jurisdiction providing
a portion of the local share. The politics involved in such an
understaking makes getting contracts executed a difficult and slow
process. To impose the additional burden of implementing an Industrial
Cost Recovery Systen to cover all of these jurisdictions might make
such a process impossible. There would seem to be only two alter-
natives as far as the City of Atlanta is concerned since it has no
jurisdiction over the industries in these other jurisdictions. Either
each government must set up its own Industrial Cost Recovery System,
including monitoring and billing and turn the federal portion over
to the City of Atlanta; or the other governments contract with
the City of Atlanta to provide this service for them with their portion
less the cost of providing said service to be refunded to them. What
recourse, if any, the City of Atlanta would have if the other juris-
dictions refused to enter into such a contract or to collect such
information on their own also presents problems.
V. Industrial Cost Recovery could prohibit or impede industrial growth in
the City of Atlanta, DeKalb County, amd the entire metropolitan area.
The larger municipaiLties in Atlanta, especially, are being required
to make significant improvements to their sewer systems, the cost of
which are considerable and a large portion of which may have to be
borne by industry under the Industrial Cost Recovery requirements.
This will surely have an effect in discouraging new industry from
settling in the area and in accelerating the trend of established
industry moving out of the area. Atlanta, which is s member of the
Association of Metropolitan Sewerage Agencies concurs with the reso-
-lutiom adopted by A?(M on April 14, 1976 which states in part;
—3—
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“Industrial Cost Recovery charges to industry may encourage some
industrial users to leave publicly owned systems, thereby compli-
cating nationwide attainment of the water quality goals called for
in PL 92-500,” and “The added costs passed on to industry might also
encourage some businesses to relocate in communities where waste
treatment works are built without assistance from P1. 92-500 programs.”
The implication of the ‘above to the affected local government is manifold.
First, its tax base is reduce. Second, it may be left with considerable
excess capacity in its treatments plants, a high portion of the cost
of which is fixed. Third, the jobs provided by that industry may be
lost to the community. The burden on the private citizen remaining
in the area is thus increased. While the ability of industry to avoid
jaying Industrial Cost Recovery charges by moving from one municipality
to another is short run, this provides little solace to the municipality
thus affected by this unfair advantage created by ICR requirements.
IV. The Industrial Cost Recovery requirement is a prime example of the
Federal government’s interference in local financial affairs.
P1. 92-500 should be implemented with Federal grant participation only,
but the ICR requirement makes it a combination loan and grant program
because 507. of the ICR funds collected must be returned to the Federal
government. It should be left up to the local governments to determine
what their rate structures should be based on all cost factors required
for operation, maintenance, replacement, and capital improvements. The
natural competitiveness between communities and the political structure
would tend to set rate structures which would be fair and equitable to
all citizens and industry based on costs and the industry’s contri-
bution to the community. If citizens or industries are unhappy with
the rate structures, they can work through the political and judicial
process to correct any inequities.
VII. If the ICR requirement is not rescinded at this time, then it will die
a slow and painful death several years from now as the insurmountable
problems of implementation and government red tap are encountered. The
time to act is now to avoid untold millions of wasted taxpayer dollars
required to implement and administer ICR and to avoid the inflationary
pressures and loss of tax base for many local governments.
-4-
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VIII. While the question of rescinding Section 204 (b) (1) (5) of FL 92-500
is being discussed, the City of Atlanta and DeKaIb County propose that
moratorium be placed on the intplementation of ICR and that a detailed
study of its impact on local governments, industries, and the Federal
bureaucracy be made, if a moratorium is not declared, we request
that the impact study, be made anyway, with sufficient local govern-
ment input and participation and that the ICR System requirement be
greatly simplified in its operation and administration, perhaps making
it a simplified part of the user charge system. Also, if Section 204
(b) (I) (B) is not rescinded, we request that the Federal portion of
the grant repayment provision of the ICR requirement be rescinded, with
all of the ICR funds retained by the local governments.
IX. The City of Atlanta and DeKalb County propose that the attached reso-
lution be considered and adopted by the 71st Annual Municipal Finance
Officers Association International Conference on Public Finance. Also,
that this resolution be brought to the attention of the highest levels
of the Federal, State and local governments, industry and commerce.
JE/MR/sm
4/15/77
—5-
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STATEMENT ON INDUSTRIAL COST RECOVERY
BY
THE LOUISVILLE AND JEFFERSON COUNTY (KENTUCKY) METROPOLITAN SEWER DISTRICT (MSD)
FOR
EPA REGION IV PUBLIC MEETING OF OCTOBER 26, 1978
The intent of Congress with ‘espect to the Industrial Cost Recovery (ICR) plan
has been argued by experts. Whatever the arguments, we know that for six years
we have not been able to produce a fair and equitable set of procedures for ICR
because the law itself is neither fair nor equitable.
Congress should not demand that only one class of customer, industry, reimburse
the federal government for 201 grant money spent on their behalf when other
custQmers are not asked to do the same. The money comes from all federal tax-
payers, including industry.
If industry is required to pay the ICR charges, the estimated $2 billion cost
will be passed on by industry to the consumers with an additional profit markup.
The federal government should display its concern for inflation by not imposing
the ICR on American consumers.
Under PL95-217, an industrial user with a flow equivalent to 25,000 gallons or
less per day of sanitary waste (residential equivalent of BOD and SS) is exempt
from ICR. If this were 25,000 gallons or less per day of volume, the exemption
would be acceptable. However, as written, this is what happens when applied to
MSD customers.
MSD has approximately 1,800 current industrial customers subject to ICR under the
old definitions. We believe only 10% of these would be charged ICR under the
PL95-217 exemption. However, since volume alone is not the sole criteria, all
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-2-
industrial customers are suspect. Therefore, all 1,800 industrial customers must
be monitored and sampled annually to determine loadings that would be used for
the residential equivalent test. Billings would be calculated, using unit ICR
costs for volume, BOD, and suspended solids, for all 1,800 industrial customers
to determine which industries exceed the exempt.bill calculated for a 25,000
gallon per day customer using residential loadings. Bills would then be issued
for all industrial customers exceeding the exempt billing.
MSD would incur the cost of calculating 1,800 bills but would actually bill only
180. Some of the cust’ mers billed would be indystrial customers discharging
wastewater far cleaner than the average residential discharge bu.t who would be
penalized because of their volume.
We understand that Coopers & Lybrand, in its report to EPA, has concluded that
the average cost of the ICR program per grantee will be slightly less than
$20,000 per year. MSD can assure you that its cost will be at least ten tinies
this amount unless the program is simplified.
MSD has corwnenced a twenty-year expansion program to implement the 201 plan for
Jefferson County, Kentucky. Each year MSD will be entering into new 201 grants
and completing old 201 grants for various phases of the project. Based on past
experience, MSD predicts that for each grant it will take years for EPA to make
a final audit and determine the final grant amount. Since the grantee is re-
quired to begin billing ICR when the facilities are placed in operation, the
billings must be issued subj.ect to adjustments.
MSD will constantly be adjusting prior billings because of the cumulative effects
of adjustments to the ICR charges due to EPA interim audits, EPA final audits,
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—3—
resolution of grantee/EPA disputes regarding grant eligibility of costs, and
changes in customer loadings. For these reasons, it will not only be costly to
maintain the annual ICR program, but it will be impossible to produce accurate
annual billings.
To date, MSD has determined only the method it will use in calculating the ICR
unit costs of volume, BOD, and suspended solids. The uncertainties and the
continual series of regulatory revisions have precluded MSD’s development of a
complete ICR program. To have incurred the cost of attempting to complete the
development of an ICR program, while knowing changes in the regulations and
the law were being considered, would have been irresponsible. Therefore, due
to factors beyond our control, it appears MSD will not meet the July 1, 1979
deadline, and construction of facilities needed for a healthier environment
will again be delayed because of federal requirements.
MSD recomends the elimination of ICR provisions fron the Federal Water Pollution
Control Act of 1972 (PL92—500) and the Clean Water Act of 1977 (P195—217) .
Unless or until the ICR requirements of the law are eliminated, MSD urges EPA
to develop regulations for the program that:
1. Define an industrial user based on categories A, B, D, E, and
I of the SIC Code.
2. Exempt industrial users who:
a. Discharge 25,000 gallons or less of wastewater per day; or
b. Discharcje in excess of 25,000 gallons of wastewater per
day with BOD aM suspended solids loadings equal to or less
than the grantee’s average residential user.
3. Allow each ICR bill to be reduced by a credit for 25,000 gallons of
wastewater per day using the grantee’s average residential loadings
for BOD and suspended solids.
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‘ ,__,,j•
( ‘i
\V GWINNETT COUNTY WATER POLLUTION CONTROL DEPARTMENT
POLICY POSITION OF GWNNETT COUNTY, GEORGIA
ON INDUSTRIAL COST RECOVERY
Gwinnett County, GeQrgia supports the abolishment of the Federal Industrial
Cost Recovery System since we feel in our situation it is practically im-
possible to equitably charge each “industrial user” as defined in the Clean
Water Act of 1977. At the presenL time here is only one facility funded
federally under P.L. 92-500 (Beaver Ruin AWTF and its associated inter-
ceptors) in Gwinnett County. Within the Beaver Ruin Basin there are now
only two users that qualify for industrial cost recovery. The total ICR
obligation from these two user’s ai, ounts to approximately $3000 a year.
Under P.L. 92-500 Gwinnett County’s only legal obligation is to charge these
two users which happen to be located in the Beaver Ruin Basin and forget
about the other “industrial users” that discharge into other County facilities.
This would be very simple for us to administer, but would it be equitable?
We feel that it is unequitable to penalize the two affected users simply
because they are located in a certain area of the County. Also by charging
just the industries located in the Beaver Ruin Basin, we give industries an
incentive to congregate in an area that is not affected by ICR. We feel that
this is a potentially serious problem
Federal regulations governing ICR systems permit the grantee to calculate
unit ICR costs on a countywide basis in lieu of unit ICR costs for each basin
within the grantee service area. Thus, the law permits the grantee to charge
all “industrial users” in the County the same ICR rate regardless whether the
industry discharges waste into a federally financed facility or not. This
SUITE 7 / 1300 PLAZA DRIVE / LAWRENCEVILLE GEORGIA 30245/404—962-14/1
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eliminates the problem of industries congregating in certain areas of the
County, but is it equitable?
Since the Beaver Ruin project is at present time the ouly P.L. 92-500
federally financed project in the County 1 the Unit ICR Costs calculated for
that basin will be used if a count ’wide CR system is implemented. Gwinnett
County is only required by law to return 50% of the ICR payment from industries
located in federally funded basin. No percentage of the revenue collected from
industries outside the Beaver Ruin Basin is required to be returned to the
U. S. Treasury. Therefore, Gwinnett County could receive large revenues
from the countywide ICR system from industrial users which in most instances
do not benefit from Federal monies. We feel that this is likely to cause
serious legal problems, preventing the implementation of a countywide ICR
system in this context.
The situation in Gwinnett County is complicated further by the fact that the
wastewater generated in North Fork-Peachtree Creek Basin is transported thru
DeKaib County in a federally funded interceptor, but is eventually treated
at the R. M. Clayton facility in the City of Atlanta. DeKaib County plans
to implement a countywide ICR system in which the Unit ICR costs for each
basin of the County will be the same. For this reason, even though the waste—
water is treated in the City of Atlanta, which at the present time does not
have any P.L. 92—500 funded facilities, DeKaib intends to bill Gwirinett
County for transport as well as treatment of this wastewater.
This, in our opinion, is not equitable. Since DeKaib only transports the
flow from Gwinnett, we feel we should only be accessed an ICR bill based on
flow alone. However, this would cause problems in the implementation of the
countywide ICR system, each “industrial user” is charged based upon the
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strength and quantity of their waste discharged without regard to their
location within the County. Therefore, those “industrial users” in DeKaib
that discharge into the R. M. Clayton Interceptor will pay an ICR payment
based on the capital cost of both the treatment and transport of wastewater.
To those industries, i is evident that charging Gwinnett County only for
flow is inequitable.
It appears that an ICR system free of inequities is virtually impossible.
For this reason, we reiterate our plea for the abolishment of the Industrial
Cost Recovery System.
. 7 if.
- -,‘I (. /• ,.,
•,t.. ,/.. ‘ ••. (- :‘. :. -
David V&n Landingham,yP.E.
Director
10/26/78
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of Tampa
Tampa, Florida
DEPARTMENT QF SANITARY SEWERS
SUITE 205 33602
120 N FLORIDA AVENUE
10 August 1978
Mr. Alan Brown
Coopers & Lybrand
1800 M Street N.W.
Washington, D.C. 20036
Re: EPA Legislative Study of Industrial
Cost Redovery
Dear Mr. Brown:
As requested by your representative during a meeting
last week, we have compiled information concerning our
industrial cost recovery. My- personal feeling is that
the ICR was ill-conceived and will not prove to be a
beneficial program for either EPA, the City’s involved,
or particularly the industries.
I am enclosing also a letter that I addressed to AMSA
on the same subject and would appreciate it if you would
convey my thoughts to EPA if an opportunity arises.
Yours very truly,
DEPARTMENT OF SANITARY SEWERS
J. W. Silliman, P.E., Director
HFC : JWS : j d
Enclosures
a-
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of Tampa
Tampa, F/ .;Ja
AR rMENT O SANITARY SEWERS
(E20 5 - 33602
I N. FLORIDA AVENUE July 28, 1978
Mr. Ron Linton
AMSA Executive Director
Suite 200, 1015 18th St., N.W.
Washington, D.C. 20036
Dear Ron:
Recently we forwarded the brief data you requested n
your GB 78-19 of June 19, 1978.
I would like to expand on our general attitude t:owards
the EPA Industrial Cost Recovery Program, - in a nutshell,
we would like to scrap the entire program.
There are several reasons that lead us to recommend
that the Industrial Cost Recovery Program be scrapped in
its entirety, as indicated below.
Double Taxation
All segments of our total economy (private, commercial,
industrial, agricultural, etc.) contribute taxes from which
Federal Grant support programs are funded. Hence, all segments
pay towards the construction of treatment plant works. Re-
quiring an arbitrarily defined segment of our total economic
activity to pay again for their federal grant portion of con-
structing treatment works is nothing more than discriminatory
double taxation, which cannot be justified from any ethical
or equity standard.
Additional Cost to the Public
Any enterprise required to participate in the Industrial
Cost Recovery (pay-back) program will merely pass the costs
on to the consumer (immediate or ultimate), which inevitably
becomes the average citizen; so this winds up being an addi-
tional cost to individuals, not business or industry.
-
Creation of Arbitrary Unfair Competition
Any definition of “Industrial User” will include the
“ins” and exclude the “outs”. For example, using the proposed
1 1 /’ ’i
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Mr. Ron Linton - 2 - July 28, 1978
25,000 gpct definition, an indust ia1 or commercial complex
discharging 26,000 gpd would be saddled with an industrial
cost recovery pay-back whereas a similar industrial or
commercial complex discharging 24,000 gpd would be exempt.
This obviously is neither equitable nor fair, - it just
doesn’t make sense. No matter what definition is used,
there will always be an inequitable split between the “ins”
and “outs”.
Costs to Administer
Any industrial cost recovery (pay-back) program will
require a continuing lacal effort, with a separate fiscal
accounting system. Since EPA is a 507. recipient, we can
anticipate EPA audits, and also intervenirg state audits.
To compound the foregoing, it is safe to say that the EPA
ground rules will be changed from time to time, with accompany-
ing interpretations and judgements, all of which will further
complicate and cloud any local effort to maintain an industrial
cost recovery program. Local costs to implement and administer
such a system would not be insignificant, -— and the bureaucratic
rebuttal that such costs should be passed on to the industrial
users fails to recognize that such costs wind up in the lap of
the average citizen.
Sacrifice of Local Revenue
Some will say, “How can your City recommend that the in-
dustrial cost recovery (pay-back) program be scrapped since
your City would receive half of the funds?”. Well, for Tampa,
assuming that 107. of the wastewater flow would originate from
industrial users, and also assuming a $100 million federal
grant support ($133 million program), the pay-back would be
107. of $100 million divided by 30, or $333,000 per year for
30 years. Half of this would go to EPA. and the remaining
ha1f wou1d be kept by Tampa, - this annual Tampa portion of
$167,000 is roughly equivalent to slightly over $2.00 per
presently connected cu&ttmer per year. Tampa can stand this
loss of revenue if we can be spared the nonproductive time,
effort, and expense of an ICR program.
Inflation
I wonder what the level uniform annual industrial cost
recovery (pay-back) amounts will be worth in the years to come?1
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Hr. Ron Linton
— 3 — July 28, 1978
Sinnrnary -
The industrial cost recovery (pay-back) program initially
established by Congress and implemented by EPA appears, upon
examination, to be an inequitable, unfair, highly controversial.
and nonproductive exercise, and results in an additional cost
to the average citizen ( not to industry). Hence, every legitimate
effort should beinade to scrap it.
Yours very truly,
. ARThENT OF SANIT ARY SEWERS
J. W. S i ian, P.E.
Director
JWS:eg
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Industrial Cost Recovery Public Meeting
Region V
Radisson Chicago Hotel
Chicago, Illinois
11 AM October 16, 1978
Meeting delayed for one hour to permit additional attendees
to arrive.
EPA — Ted Horn, V, UC/IGR Specialist
John Gall — EPA Washington
C&L — J. Mikul Townsley
Myron A. Olstein
13 Attendees:
Gary Greenway Leonard Weeg
Donohue &Assoc, Inc Enviro—Services, Inc.
Sheboygan, Wis. 975 N Main St.
Rockford, IL
David Jaechke William Mondschein
MSDGC R&D Dept MSDGC Engrg. (Grants)
Joseph Benigni Gary MoFarlane
Container Corp of Amer. The Larsen Co.
Green Bay, Wisconsin
Tom J. Bingam Carol Johnson
Sanitary Dist. of Rockford San. Dist of Rkfd
R. W. Erik J. Hetride
San. Dist. of RKFD Dean Woods Company
Rockford, IL
George Hisle George Rippil
Detroit Water & Sewage Dept. Detroit Water & Sewage Dept.
David Alexander
GM
Complete presentations of’
• Purpose of study
• Project scope and methodology
Findings, conclusiQns and possible alternatives
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Statement presented by
Carol Johnson, on behalf of Sanitary
District of Rockford, IL
ICR should be based on only those incremental costs to
construct an atypical process required to treat
industrial wastes.
Leonard Weez, on behalf of
Enviro—Services, Inc.
Oposed ICR -
10 AM October 17, 1978
No attendees by 11 AM.
a...
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RICHARDSON
BROTH ERS CO
- -
FURNITURE MANUFACTURERS
POST OFFICE BOX 157
SHEBOYGAN FALLS, WIS 53085
TELEPHONE 414-467-4631
October 27, 1978
Myron Olstein
Coopers & Lybrand
800 M. St. NW.
Washington, D.C. 20036
SUBJECT: Industrial Coat Recovery - Wastewater Treatment Operation.
Genitemen:
We respectfully request that the following information be added
to the record of the recent hearing held on Industrial Cost Recovery.
In addition we would register our concern for the limited notice that
was given for this hearing. We would ask that a much wider range of
notice including extensive use of mass media be used for a hearing
of this nature.
We contend that the Industrial Cost Recovery program as ad-
vocated is not a fair, equitable, and workable measure. It will be
exceedingly difficult and expensive to administer. It appears the
plan will entail engineering and accounting determinations of proper
charges and distributions. This is spending even more money to
collect the revenues. -
The period of payment time for industry, up to 30 years, may
well not be compatible with the book life of the facilities. This
provides dangerous potential for compounding costs and creating
confusion at a later point in time. In addition the criteria of
apportioning costs according to what is a “fair” share for industry
leaves far too much latitude as to what the “fair share” is.
Rebating part of the funds collected to the municipalities to be
spent in any way they desire has placed an unfair burden on sewage
costs. At the very least these funds should be required to be used in
the community’s waste water programs, preferably operation &
maintenance, if indeed they should be collected at all.
Please note that the doubt of the work ability of this program is
widely shared as witne ed by the present moratorium on it.
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We submit that I.C.R. should be reviewed as a basic concept
as opposed other formulas for distributing cost burdens fairly and
equitably. A series of well publicized hearings could go far to
gathering varied and well founded information on ways to approach
this question.
cc. Ted Horn
E.P.A.
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• DIVISION OF WATER CITY OF LORAIN, OHIO
• DIVISION OF WATER UTILITIES DEPARTMENT
POLLUTION CONTROL
1106 FIRST STREET LORAIN, OHIO 44052 PHONE (216) 245-1000
PHILIP 0 MAIORANA
DIRECTOR OF UTILITIES
ELla JACOBOZZI
DIRECTOR OF
PUBLIC SERVICE
August 31, 1978
Mr. Paul Flax
Coopers & Lybrand
1800 M Street N.W.
Washington, D.C. 20036
Subject: City of Lorain
ICR
Dear Mr. Flax:
Please be advised that we are enclosing the- forms that you mailed to us
and we have completed them as much as possible as to what we feel could
be accomplished by this office.
Also be advised that the City of Lorain has commenced to become involved
in ICR and has not been in complete fulfillment of the ICR program, how-
ever we do hope to accomplish this soon.
At this time we would like to make several comments in regard to our
feelings of ICR:
1. It is the opinion of the City of Lorain that certain branches
of the Federal government have already set up certain categories for
certain individuals and now we have another branch of the Federal govern-
ment, the EPA, differentiated from other government branches specifically
in that the Federal government set up a special category—-senior citizens.
Many governmental agencies are regarding this as a special group only to
be ignored by EPA.
2. As you will note the City of Lorain has established one flat
rate on sewers based on flow plus a surcharge on any excess industrial
flow. We believe that this is an equitable way to go. We note that the
ICR disagrees with thj.s.. Under our one flat rate based on flow everyone
is equitable. This also includes Capital Improvement, Operation, and
Maintenance. Tinder this system it would appear to us that the ICR would
be reverse discrimination since in this one flat rate industry is already
charged for Capital Improvements. It is included in the rate structure;
therefore, when they are made to pay again, it would appear that they
would be paj’ing double.
II
JOSEPH J ZAHOREC
MAYOR
-------
Mr. Paul Flax
Coopers & Lybrand
August 3l, 1978
Page 2
3. The City of Lorain is planning and proposing to split the system
in two, with several industrial giants included. These industrial giants
are now in one sewage p1 nt. If the City of Lorain splits and goes into
two systems, one of the industries would be forced to go into another
system. How can the Federal government charge one and not the other?
Again, if you will return to the flat rate item which includes Operations
and Maintenance and Capital Improvements based on flow again would prevail
here and is the most equitable and fairest way to go.
The City of Lorain budget is a complete budget breaking down Operation
and Maintenance, b reaking down Capital Improvements, etc. However, for
the EPA to demand certain breakdowns, we feel is an infringement on the
rights of local government autonomy.
At this time, since your firm is making a study of the ICR, we would
appreciate if you would take our views under consideration and give them
your fullest attention.
If there are any further questions or further discussions in which you
would need our assistance, please feel free to call on us.
Very truly yours,
THE CITY OF LORAIN, OHIO
Philip Q. Maiorana
Director of Utilities
PQM:mvs
Enclosures: Completed Forms
Copy of 1977 Budget
Copies (2) of Surcharge Computation
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11 1 1t’A
i—i eu Z 1._i. ..) . ‘‘i ‘ii I I J I I i’i.’ Company
• r,;
ru hjvqli f’ iiiv.yIvanua I52 O
I cI(’ Ii( rI(’ 112 237 5757
September 22, 1978
Mr. E dward J. Donahue III
Coopers & Lybrand
1800 M Street N.W.
Washington, D.C. 20036
Dear Mr. Donahue:
Your September 19 letter asks for permission to cite the closing of our
Bowl ing Green, Ohio Factory in your final report on the Industrial Cost
Recovery study. We have no objection to your use of the information which
we sent you, as It is all public information. Please keep in mind, however,
that there were factors other than wastewater costs which contributed to the
closing, as noted In the company news release.
We have a hearsay report about an A&P facility in Bloomdale, Ohio, which is
now for sale. It was supposedly closed because of wastewater costs. You
may wish to Inquire about the situation.
DONALD G. KIRK
ENVIRONMENTAL ENGINEERING
1 ak
cc: Mr. Jack L. Cooper
National Food Processors Association
1133 Twentieth Street N.W.
Washington, D.C. 20036
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Industrial Cost Recovery Public Meeting
Region VI
Sheraton Dallas Hotel
Dallas, Texas
10 AM October 16, 1978
EPA — Ned Burleson, VI, Chief of •Municipal
Facilities Branch
Arvil Wilson, VI, UC/ICR Specialist
John Pal, EPA Washington
C&L — Alan D. Brown
Edward J. Donahue III
Walter J. Huelsman
20 Attendees:
James H. Suchma, Consulting Engineer, Bovay Engineers,
5009 Carolina St. Houston, Texas 7700k, various cities grantees
Marilyn A. Mathison, Environmental Specialist I,
1115 N. MacGregor, Houston, Tecas, City of Houston Water
Pollution Control
Alterto F. Gutierrex, P.E. , President, Gutierrex,
Smouse, Wilmut & Assoc. Inc., Environmental Engineers,
11171 Harry Hines Blvd., Suite 113, Dallas, Texas 75229
Pat Cook, Engineering Systems Specialist, P.O. Box 2231,
Irving, Texas 75060, representing Frito—Lay
Cary M. Verchow, Tech. Manager of Environmental Systems,
P.O. Box 2231, Irving, Texas 75061, representing Frito—Lay
Bill Cox, Sanitarian, Campbell Taggart Inc., Dallas,
Texas
Charles Hughes, Engineering Assistant, 1506 Commerce
Street, Dallas, Texas 75050, Dallas Power & Light Co.
John P. Johnson, Accountant, 1500 Manila, Dallas, Texas
75201, City of Dallas Water Utilities
Duane C. Haimberger, Civil Engineer — Community Planner,
1200 Main Tower Bldg., Dallas, Texas, Air Force Regional Civil
Engineer —-
Rick McCleery, Pollution Control Officer, 1901 Lakewood
Drive, Arlington, Texas 76016, representing City of Arlington,
Texas
-------
Robert Dill, Industrial Waste Control Manager, Dallas
Water Utilities, 3 AN City Hall, Dallas, Texas 75277,
representing City of Dallas
I.M. Rice, Director, Dallas Water Utilities, Room 14 AN,
City Hall, Dallas, Texas
Alice Grisham, Manager, Natural Resources, 1507 Pacific
Avenue, Dallas, Texas 75201, representing Dallas Chamber of
Commerce
James B. Miller, Assistant Director/Admin., Fort Worth
Water Department, P.O. Boc 870, Fort Worth, Texas 76101,
representing Fort Worth Water Department
T.M. Anderson, Industrial Waste Supervisor, P.O.
Box 870, Fort Worth, Texas 76101, representing Fort Worth Water
Department
Thomas Sanders, Engineer, 8700 Stexnrnons, Dallas, Texas
752147, representing URS/Forrest & Cotton, Inc.
Catherine Perrine, Water Director, League of Women
Voters of Texas, 7616 Royal Place, Dallas, Texas 75230
T.H. Gaertner, P. E., Engineer, 6220 Gaston, Suite 3014,
Dallas, Texas 752114, representing Boyle Engineering Corporation
Joseph C. Smith, Industrial Waste Section, Dallas City
Hall, Dallas Water Utilities
Dev Greeg, 5806 Birch Brook, Apt 205, Dallas, Texas
75206, SMU student representing SMU
Complete presentations of
• Purpose of study
• Project scope and methodology
Findings, conclusions and possible alternatives
Statement presented by
Dr. I. M. Rice, Director, Dallas Water Utilities
Eliminate ICR
10 AM October 17, 1978
those in attendance were present on 10/16/78. No
additional statements, questions or discussions.
-------
dry 0F SA xq
P C i BO qO e
SAN ANTONIo TEXAS 782O
October 30, 1978
Administrator, Water Division
Environmental Protection Agency, Region VI
International Building
1201 Elm
Dallas, Texas 75270
Dear Sir:
Pursuant to the October 16-17,1978, hearings conducted by Cooper and Lybrand
for the Environmental Protection Agency on the Industrial Cost Recovery
portion of P.L. 92-500, as amended, end’orsed is an official resolution
adopted by the City of San Antonio.
We wish to have the resolution included as part of your record on comments
concerning the. ICR provisions.
Sincerely,
fl, c
Frctk iL Kiolbassa, P.E.,
/ Director of Public Works
I ‘
-
F RK : e 1 d
Attachments
RECEIVED
NOV 03 1978
EPA 6AWM
REGION VI
AN EQUALOP ORTUNITY EMPLOYER’
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A RESOLUTION
No. 78—48—145
OPPOSING THE INDUSTRIAL COST RECOVERY PORTION
OF THE FEDERAL WATER POLLUTION CONTROL’ACT,
P.L. 92—500
WHEREAS, the Congress of the United States enacted the Federal
Water Pollution Control Act (P.L. 92—500) as amended by the Clean
Water Act of 1977 (P.L. 95—217), with the object&ve “to restore and
maintain the chemical 1 physical, and biological integrity of the
Nation’s waters; TM and
WHEREAS, the 201 Wastewater Facilities Advisory Committee, duly
appointed by the City Council, has unanimously recommended the City
Council oppose the Industrial Cost Recovery prov .sion of sai .d Act
as of little benefit to the citizens, an unreasonable burden on
industry bordering on double taxation and results in unreasonable
administrative burden in conflict with the policy stated in the Act
with little or no financial gain.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF SAN ANTONIO:
SECTION 1. That the City Council of the City of San Antonio
hereby agrees with the findings of the 201 Areawide Wastewater
Facilities Advisory Committee, and does hereby state its opposition
to the implementation of the Industrial Wastewater Cost Recovery
portion of the Acts described herein.
SECTION 2. That copies of this Resolution be sent to all of the
Texas Representatives and Senators of Congress and to the Environmental
Protection Agency.
PASSED AND ?2PRUVED THIS ‘ ‘ ‘ day of I ,1978
i\.. #-r4. A_,
__ MAYOR
H k t C lerk1
APPROVED AS TO FORM: . .!l ’7fl £‘ 4.J’ R i I f
)V 0 3 1978
EPA (‘A, M
REc lOt1 VI
STATE OF TE.
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The Coca-Cola Bottling Works, Inc.
6011 Lemrnon Avenue/P. 0. Box 2008
Dallas, Texas 75221
October 24, 1978
,t’ L
Mr. John T. Pal (WH-547.)
US-EPA
401 M. Street, 5. W.
Washington, D. C. 20460
Dear Mr. Pal:
Concerning the Environmental Protection Agency’s Industrial Cost
Recovery Program (ICR) that has been proposed to the City of Dallas,
Texas to be imposed on the industrial users of Dallas Water IJtil—,
ities Waste Disposal Systems, there are views and considerations
that are of importance to us since we are a major customer of the
City of Dallas.
Our industry does not emit toxic pollutants into the public sewage
system. We have been extremely cooperative with the Dallas Water
Utilities operations, and they have been very cooperative with us.
We have an excellent working relationship. We do not intend to
emit any pollutants into the waste disposal system that is. owned
by the citizens of Dallas, and have exercised every constraint in
our operations, to minimize our emmission whether it is biological
oxygen demand, total solids or whetever. We have been willing to
pay our waste disposal surcharges and charges, install meters to
monitor quantity of discharged liquids and have trained personnel
in the proper operation of equipment to reduce pollutants. We
have recently installed water meters in one of our operations to
provide guidelines for the Dallas Utilities management personnel
to monitor our water useage and liquid discharges. All of these
installations are extremely expensive and arc not profit making
contributors; however, we believe that this is our responsibility
as good citizens. We support the city of Dallas and the govern-
ment of our city one hundred percent.
Since we are already paying a user charge and surcharge to the
City of t)a31a9, arid since we have an excellent relationship that
ha t’i n e tal 1ish d for more than cventy—f ive years, It is our
opthicn that ny change in the already cstablithed approved system,
would make it lezs efficient , and would involve Federal regulatory
in iaattrrs that should be handled by local government. Our city
water department is well managed and does not need the help of Fed-
cral CPA regulatory in managing a function that has been success-
fully managed for years.
Since the City f Dallas received a “GRANT” with “STRINGS ATTACHED”
from the Federal EPA, you can be assured that our city will re-
imburse the Federal EPA for any expenditure for waste disposal
facilities. As a matter of fact, as taxpayers we have already
paid for those facilities.
Sincerely,
0. Dan Poole
Qirector of Quality Control
-------
r 1 COOPER AIRMOTIVE
I COOPIR I
INDUSTRIES
October 30, 1978
Coopers and Lybrand Inc.
Attention: Alan Brown
1800 M. Street N.W.
Washington, D.C. 20036
John T. Pai (WH-547)
U.S. E.P.A.
401 M. Street S.W.
Washington, D.C. 20460
Arvel Wilson
U.S. E.P.A. Region 6
Grants Office-Water Division
1201 Elm Street
Dallas, Texas 75201
Gentlemen:
We appreciate this opportunity to comment on the proposed
Industrial Cost Recovery (ICR) program proposed by the
Environmental Protection Agency. Cooper Airmotive, an
industrial user of the City of Dallas, Texas, POTW considers
the ICR program inappropriate and inequitable and we strongly
oppose its implementation.
To our knowledge, industrial users were not included in the
decision to request or determine the amount of the Federal
grants. Nor to our knowledge, were we informed of the
industrial repayment burden implicit in the grant.
It is our belief that public owned waste treatment facilities
are intended for the general benefit of the public in the area
that they serve and that industry is currently paying its fair
share through a user charge that is born by all users in pro-
portion to their use of the system. We understand that the
depreciation of capit,al facilities is currently being reclaimed
over the actual anticipated life of the facility thru these
user charges.
7555 LEMMON AVE • BOX 7086 ‘ DALLAS, TEXAS 75209 • 214 357-18 1 1
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October 30., 1978
Page 2
It is our opinion that the ICR proposal:
1. inequitably imposes sole responsibility for repayment
of waste treatment facility capital costs on one class
of customers, namely industrial users.
2. imposes double charging of industrial users by requiring
them to repay Federal funding that was in part generated
by those industries.
3. proposes to recover capital costs of waste treatment
facilities within an artifically short depreciation
life of 30 years compared to an actual facilities
life of up to 50 years.
4. is of questionable cost effectiveness based upon the
Dallas Water Utilities ICR administrative cost estimate
vs. anticipated ICR collections outlined in their
statement of October 16, 1978, at the EPA meeting
on Industrial Cost Recovery.
We urge that ICR be eliminated by the EPA.
Sincerely,
coo:
Engineer
PS
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FRITO-LAY, INC.
£NGINCE lNO OEFARTMCNT _______
October 30, 1978
Mr. John Pal -
Project Officer (WH-547)
U.S. Environmental Protection
Agency
401 M Street SW
Washington, D.C.
Dear Mr. Pal:
Frito-Lay,
option #1,
al ternati ye
Section 204
Inc. wishes to formally comment that Coopers and Lybrands’ -
Abolition of Industrial Cost Recovery, is the preferred
to the present ICR system as promulgated in Title II,
(b)(l) of the 1977 Clean Water Act.
Through allocation of Federal tax dollars as grants to municipalities,
the Federal Government utilizes corporate income taxes for industrial
cost recovery without the ICR system. To require industry to further
subsidize capital investments in Publicly Owned Treatment Works as
would be the case with ICR capital component, places an unfair
financial burden on industrial P01W users.
Industries presently contribute to the municipality’s shareof P01W
capital costs through ad valorem taxes and/or property taxes and
existing user charge systems. Implementation of ICR represents there-
fore a double recovery of costs from industry tantamount to double
taxation. Abolition of ICR would eliminate the double taxation.
Very truly yours,
FRITO-LAY, INC.
Patricia G. Cook
Engineering Systems Specialist
PGC/CMV/mj t
cc: Mr. Edward J. Donahue, III
Coopers and Lybrand
..10W
Technical Manager
Envi ronmental Systems
Mr. Arvel Wilson
U.S. Environmental Protection Agency
900 LOOP 12 • P. 0. BOX 22 * • IRVINO. TCXAB 7SO6 • 579-2222. ARCA COOC 214
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(lii LUJ
October 23, 1978
401 . Street
Iashin ton, I). C. 20400
As an industrial user of the Dallas P )T , Jonof; Blair oinpany
h’ s been intorested in anti has followed developments and
interpretations of the 13iwiron uenta1 Protection Agency’s Juiie 26,
fl73, policy announcement of the ICR program. Ve have dune so
by participating in IiPA’s Region 6 seninars and the City of
Dallas Water Utilities department meetings with industrial users.
Our study of the sul)Joct prompts this 1ott r; wherein, wo express
our objOCtio s to the ICR program and give our reasons fur doing
so.
1) The 1CR program a:; proposed would add a superfluous
and inequitablo addition to the wasto water rates now
being charged industrial users of the Dallas POTW. These
rates are based on excess strength (DOD and TSS) of waste
entering the sewage system prorated on water purchased.
The imposition of the ICR systems would be inequitable to
industrial users and it would be superfluous because the
Dallas rato system is now or uitab1e and is not as compli-
catod, difficult..to understand, and athainistcr as tiLe ICR
3yste m !t.
2) We believe tliat self monitoring by industrilLi users
would be very costly and almost impossible to achieve with
the testing and metering technology now available to us.
3) tic feel UPi ’ s pretreatment standards based on appli-
cation of the best available technology oconomically
achieva 1e is an excessively stringent program that does
not truly reflect the intent of the Clean Water Act of
l977 . This act shows congressional concern that national
-------
Qi)
John T. J’ai
J).lrve 2
)CtOI)0T 23-, 1978
;tandards reflect the actual pollutant reaoval capabilities
of municipal treatment plants.
4) The ICR system would amount to “double taxation” which
is an unfair economic burden.
Based on the above, we believe that ICR should be aboli5hed,
w1 ich is Alternative #1 listed by Coopers and Lybrand, Inc.,
consultant firift employed by I PA. The advantages of doing so
far outweigh, in our opinion, the disadvantages as outlined by,
the consultiii t firm.
Uc rospectEully r que5t that our OJ)inIon as outlined in this
letter 1)0 recorded as a public conuiient on the subject.
JflNL 5 I LAIR COMPANY
C. illdon Isom
Plant Engineer
C I 1 / 1) d
cc: Alan Rrown
Coopers and Lybrand Inc.
1800 M. Street N.W.
1’Iasliington, I). C. 20036
Arve]. Wilson
U.S. E.P.A. Region 6
Grants Office-Water Division
1201 Mm Street -
Dallas, Texas 75201
I. M. Rice (4A )
a1las Wntcr Utilitjos
City Uall
l5i O Harill:
Dallas, Texas 75277
-------
October23 1978
?lr. Arvel Wilson, Cirant5 Office
Ilater Division
Region VI
Environmental Protection Agency
First international bldg., 1201 Elm St.
D ,I1as, Texas 75271)
Lear l w. Wilson:
COMMENTS Oil INDUSTRIAL COST
RECOVERY PUBLIC MEETINI Ill DALLAS
ON OCTOBER 16, 1978
the Fort Worth Water Department has been concerned about the cost implications
to Industrial users and to the City resulting from implementing of the Industri-
al Cost Recovery requirements of current EPA Regulations. It would appear that
Industry Is being required to pay a share of the federal part icipatlon In public
treatment works costs thru payment of federal taxes and then being required to:
pay all or part of that shar. again thru payment of ICR charges. Moreover, it ‘
would appear that the City Is being required to undertake a costly and complicat-
ed effort to establish, collect and dispense those ICR charges for a return of,
a fraction uf the cost of that effort. Even after all this, it would appear
that the actual fiscal benefits to the federal government are going to be
minimal, according to the findings presented at the iubIic hearing on the ICR
program In Dallas on October 16. it is difficult to find a winner:
From the Fort Worth Water Department’s v1e point, the best of the 16 alternatives
presented at the October 16 hearing ii the first one, “AboHsh ICR”, but it Is
recognized that this Is probably not a politically viable ternatlve. Of those
remaining, it would appear that Alternate 12:
a. -
“Abolish ICR end require that local share of
project costs be recovered through proportion-
ate user charge”
Is the most reasonable and equitable.
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Pagefl2
October 23, 1978
• • - .;• __ -•-• .1 • —
Alternate 12 would imp!y ;ti t .à11-’fsdöraJ’ t.xp.ye(háth 1
individual, are sntltl.4 .l of cep.c lty:provlOd
funding and that :ths’iOà& e tre.tment ørks,
shared ,on..e-pr si) benef!tt1ng cus’
arica with thu ice provided, 11
thI tions to bensfi
limit since u,er, haV
suff ci n1 f I n.nc 1119 osti. frc the
Iñ int Is esse, tI.1Iy. thecurrsnt
Fort W
ri1} iti
2
• Thin
4.,
I
..; J. :Li’RobInson, Drectov f .: y %
Fort Worth ,W z ev ,Oepartnsnt.. • - ; :: •
, ‘ ;, 4 ,
JLR&ea - ‘ ‘
cc&’ Dr 1 1.M ’R1cs, Dallas Water Utilities
CoàpeI ’4LybrMd, Attn: 1r. Allen Brown,’
WashIn ton, D.C..:.
., : - ‘ ry Gb yn, Asslsttnt City, Manager • . ‘I
., “ Carl RIe i, Acting Director, North Central Texas Itinicipal
Drawer C, Wy1., Tss j5O98.
— . . • I . ._ • , . - I .
- ‘L . • -
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STAFF REPORT
Recently, the Oklahoma City Council enacted an ordinance allowing
surcharges to be placed on sewage b 1ls of certain types of industrial
users, most notably, foo d processors. Those surcharges were based on
qualities of their effluents and are scheduled to take effect in December,
1978. The surcharges were required by the United States Environmental
Protection Agency and could not be avoided due to the large amounts of
EPA grant monies received by Oklahoma City in the recent past.
The primary impacts deriving from imposition of the surcharges are
economic in nature, falling first on the industrial users, second on the
users’ labor force, and finally on large segments of the City and State
populations. For example, Wilson’s most recent annual sewerage bill was
about $40,000. That amount is reliably estimated to increase to about
$1.4 million in the first year of full surcharges. Other food processors
face similar situations. Food processors in general depend on sales vol-
ume rather than high profit margins to generate returns. A typical pro-
cessor may receive a net cash return of between .0 percent and 1.2 percent,
a return which will be completely removed by imposition of the sewerage
surcharge. Under these circumstances, it becomes logical to cut losses and
go out of business. The result will be loss of most of the Oklahoma City
food processing industry and considerable direct employment.
The jobs at risk number between 2,200 and 4,000 depending on the
precise categories inclu ded in the industries considered to be affected.
The direct loss in Oklahoma City also affects employment in other industries.
In Oklahoma, Canadian and Cleveland counties, the employment mulitplier is
estimated at from three to four from the food processing industry. This means
-------
that every one job in food processing generates three to four additional
jobs in other industries in the region. Even using the most conservative
figures, at least 6600 ( 2O0 x 3) jobs will be lost by losing the food
processors. Throughout the state an undeterminable number of additional
jobs will be lost over nd above those in the three county region of
Oklahoma City. Recognizing the adverse potential of the surcharges, the
City Council has pledged support to the affected industries as has the
Governor of the State of Oklahoma.
In June, 1978, Governor Boren released $5,000 of Department of
Economic and Community Affairs (DECA) funds, matched by a request for
release of $20,000 of Economomic Development Administration 304 monies,
to partiQlly fund an action study of the problem. An additional $75,00Q
may be applied for under EDA Title IX, a title which deals with adverse
economic impacts caused by actions of the Federal Government, in this case
by EPA regulations. This study is expected to provide a feasible least—
cost approacW to pretreatment for the affected industries, thus avoiding
surcharges althogether.
The time periods in which grant applications, studies, and impleme—
tation must start and be completed are very short. The preliminary Title IX
grant ($75,000 study) must be approved before September 30, 1978 to get into
this Federal fiscal year and the study be completed in the fall with a
Title IX implementation grant being written and submitted concurrently.
Both of the Title IX gr ts require an Advisory Task Force. Given the short
times available, implementation options should be considered at the outset
of the project. Several have been considered and are presented below in
increasing order of desirability.
(1) No action — Option appears to be the most simple but carries the
employment loss consequences described above. Acceptable on the
-------
basis of a philosophy of nonintervention, but would be inconsistent
with previous City actions with respect to the business community.
(2) Direct City operation/ownership of facilities -- This option results
in no change in the current situation. Since the City would own—
operate, the pretreatment facility surcharges would not be reduced
enough to matter a d the industries would have same incentive to shut
down anyway.
(3) City operation of industrially owned facilities —- This option is
feasible given that the affected industries could affort to build
pretreatment plants. Some mix of guaranteed loans, bonds and
stocks could probably be arranged, but staff feeling is that a
large capital subsidy will be required to force the cost curves to
an acceptable level. Such a subsidy will be forthcoming only to a
municipality or to a not-for-profit corporation.
(4) Not-for-profit LDC -- Two of the five existing Local Development
Companies (501 (c) (3)) are eligible to receive grant funds from
the EDA. Their limitations exist in two areas: (a) lack of manage-
ment experience in the area and, (b) probable inability to generate
matching funds. The latter difficulty could be overcome through a
variety of complex financial exchanges and leveraging efforts.
(5) Trust formation —- At present, formation of a trust to implement
study results seems the course least complex from the standpoints
of the City, EPA, EDA and matching financing. A trust is enough
divorced from the City (it need not be a City trust at all) that
EPA surcharges would not apply; trusts are eligible EDA applicants;
trusts can issue revenue bonds and receive other tax exempt financing.
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Industrial Cost R co ery Public Meeting
Region VII
Federal Building
Kansas City, MO
10 AM October 18, 1978
EPA - Earl Stevenson, VII Water Qivision Director
Tom Robertson, VII, UC/ICR Specialist
John Howard, VII, UC/ICR Specialist
John Pal, EPA Washington
C&L - Alan D. Brown
Edward J. Donahue III
51 Attendees:
Douglas, Dolinar, American Meter
James Martin, Van—Doren—Hazard—Stallings
Charles Plummer, Iowa Beef processors
Donald G. Kirk, Hinz, U.S.A.
Boyd C. Mills, City of Arnold, Missouri
L. Joe Sell, Western Electric
John C. Thompson, So. St. Joseph Industrial S.D.
Daryl Ripper, So. St. Joseph Industrial S.D.
Alan Shineman, City of Manhatan, Kansas
Jerry E. Petty, City of Manhattan, Kansas
Richard R. Miller, So. St. Joseph Industrial S.D.
Dale S. Duffala, Black & Veatch
John A. Metzler, Kansas Department of Health & Environment
E.W. Bartley, E.P.A.
Richard D. Kuntz, Missouri Department of Natural Resources
a -
Dave Wissing, Carnation Company, Pet Foods Division
W. C. Nielson, Wapsie Valley Cry., Inc.
John D. McEnru , Little Blue Valley S. District
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Richard Wuttke, Farmers Butter & Dairy Corporation
John Jursitis, Veenstra & Kimm
David R. Duffield, City of Springfield
Harry Criswell, City of’ Springfield
Stephen Yonker, Burns & McDonnell
Nate Beezley, N.E. Depa’i’tment of Environmental Control
R. E. Crawford, Wilson & Company
Arthur F. White, Peat, Marwick, Mitchell
Donald R. Boyd, ICC. Missouri Pollution Control
Jim S. Noel, K.C. Missouri Pollution Control
J. Willis Sneed, Wells Engineers, Inc.
William G. Stannard, Black Veatch
Earl R. Myers, St. Joseph Light and Power Company
Charles Dakin, Whitaker Cable Corporation
George Sallwasser, Homer & Shifrin
J. L. Stein, Anheuser & Busch, Inc.
Ralph Flournoy., EPA
Earle C. Jones, Methodist Medical Center
LA. Frederick, H.R. Green Company
George W. Milligan, City of Cedar Rapids
Mario G. Nuncio, EPA
Roy L. Jackson, City of Kansas City, Missouri
G. Carlos Knight, Water Pollution Control Department, Kansas
City, Kansas
Greg Rupert, MARC —-
Walter M. Johnson, City of Butler, Missouri
M. Clark Thompson, Larkin & Assoc.
Bernard A Rains, Metro. St. Louis Sewer
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C. F. Kovach, City of Kansas City, Kansas
Richard Ream, City of St. Joseph, Missouri
Cindy Bernard, City of St. Jospeh, Missouri
Richard L. Halda, TJ. Lipton, Inc.
James D. Resnick, City of Davenport, Iowa
Bruce Duffin, Corps of Engineers
Complete presentations of
Purpose of study
Project scope and methodology
Findings, conclusions and possible alternatives
Statements presented by
Donald G. Kirk, H. J. Heinz Company
and National Food Processors Association
Eliminate ICR — or, as a second choice, charge industry
for the incremental costs incurred to treat industrial
wastewater
Boyd Mills, City Administrator, Arnold, MO
Abolish ICR
Richard H. Miller, South St. Joseph, Missouri
Industrial Sewer District
Abolish ICR
George Saliwasser, Homer and Shifrin,
Consulting Engineers
Recommended circuit breaker — no ICR below specified
dollar amount because of grantee administration costs.
Bob Frederick, Howard R. Green Company,
Consulting Engineers, Cedar Rapids, Iowa
Abolish ICR. Second choice would be a national ICR
rate.
a-
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City c i Linr. o”i Coun yICdy OuiI hn L i coIn. Neb,. .lc Trl.phoiie i2I 475.5U HQ Pn G. BDD aI I.CiI ay
I / -
-
3-
t ) -
- } I
D’ P . .PC uIl’Ir !
- - . _
ovcbPr
.%!&% •‘‘ -‘‘ .
?r. Earl t”pbenson. Director
a er Division
frSirOrlJ?fltdl Protection çency
1735 altiri re
ns s City. isso ri 4lO3
Dz’ar r. St phenson: Re: c.o’v - ntS on In hStri rost Pcci ’crI
Study iy C 3!)ers >
The City f Lincoln h s rev ede4 the flcto er V), l97’ , draft f the Ind stri i
Cast ecover ’ Study preUninary corpilat on of pot sthle study terr ativeS -
coi sed by to3 erS & Lybrond. e have also reviewed the IC R c ues ions raised
by Co r s - n floberts dated [ cer er 15, 1977, and the su -1:. ry of findinOS.
Ccrrients on each part of the report are as fol1o s:
- Sr r f Fiadinis d t d O:tober l2
:e c0:• c jr bflth th c fl ?fltS rac e ur 1 der Su-Ta, cbf Fir4dinçs anti açree dth the
conclu on -tnot the co t to r ir,t3in and operate the ICR Syste is cuite c v.-
f ’iS ‘ i C.
- icc. : ;uestlons raised by C nn j o ’erts dct’ _ c. r 9?J .
The only cvr nt &nT this section is i (1r it ‘iuite nte St n t’ t under
qjcstiofl . 7 that the ar,unt of IC ’s revenue receivet ts c rs1 er blY less
th3r the orthir.3 1 jredicte i aroiant, therefore re sin t ’ e esticn - i IC 1
really 3rt ’ it?
rt ç - 1n L strial Cost c pyer _ t id;? Pre) le r -crr )a 0fl rssibJ ’
alt rn t.ire ,
Ccr ents on t ;s section are:
a) Co- i1ete e ree ent dth .lterr ti e ‘b. i, -: ich st .’ ‘at i5 C ’ .
do a re with all the advar ta es tated for f Itern3te \ . 1. t t dis ircc
with tie d sath nta°e that abolishiric’ 1C’ r y erco jraoe erantees to plan
and c nstr ct treatrent or).s that are 1ar er tha i neceS .org. uS 3 rt -
cular ct’ncern has airei 1y been ddresst d under the ct rreflt r’eou1at CflS In
the cons r ct 0n crantS ozra and a so tiv the revic of the State a ’eT CY
ani EPti which the consultant r t justify the size cf the tr atf. nt zi: s
proposed. Therefore, (Ph already has s-jilt in a veto ; icer o the izc of
the size of the treatr ent u r .s propt sed.
-------
- -
, ._Ic L.
o:
b) ternat es ‘os. 2, 3, 4, 5, &, 7, 8, 9. ‘ICi, fl, ‘ I or d 15, t 1d er e
n purpose other than to co. li(ate 8 1 Ir.cr ,Ras the frieqii ts’ ;r 1 d ad- -mis-
trat1v costs for any ty ie of ar lndustrj Cost Recovc•ry syst i. Therefore;
ce ou1d stron 1y rcom nd anain;t adootlon or con dtratio of the a ter-
nates b(e habe listed above.
c Mternate o. 11 Return ti) the requirer rpts of Pt. ‘.-E6C ab)IISP.fr,cc
ICJ ’ .. feel this paitlcular aiter at.c is basically acco i1she. ’j iy
acDptior. of Alternate . 1.
d) “Iternate ‘ o. 12 - Abolish ICR and require that local share of praject
costs be recovered through I’ roportionate User Ch r e. e agree one hundred
percent with this alteryiatjye a’ d concur dth the ad antaQe that equity
culd b achieved by estab li ;hiro a ro ortionate Jscr C rqe syst . e
sa ree t at t? re would t e a isac1vant oe n r thi:ing ye flc;ibiflty of
dcslcnina rates because t ser Cnerne systc ; ar the? Tr3 t e 1t blc r en
o a ;‘roportlonate basis ar.d the costs ou d not.
be s 1 nificant. Also, any changes in bond covenants w i1d pose rio cob ’ Ier.
e) Alternate o. 16 - P .e uire letUr of c it,r nt (os contract) fro ndu5trial
users of P r , ’s when Pt)fl size u1d be a definite dv ntape t the oianr 1 in;
of in order to reet their need; of their COrITJnItY an the associated
industrics.
he a ve serves as a su-rar,’ of cur c Tvents or the t rn tive; ro ose1 ir.
the Cc’ooers tvbrand report. If yoj have any estlo s or c1crific tirn ; on
cur CGrents, please c- ,ntact the Pub jc Utilities Uepart. ,nt.
èc r tr,ly,
I ) ; () ( -:
- ‘I’
Richard ,!• £rixsøn, irector
Depart,- nt of Public Utilities
—-
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Clarence ‘11 ghi, Mayor
S OCTOBER 9, 1978
HEBRON, NEBRASKA 68310
lana Henning. Clerk
Ouncil Mcniber
ININ I OII’ .II IFK
‘%IIII r . I 14 ,%t’SI
I_O J %Il’ t.
P,,LI Ifll% tM 11
ld)kIH)N ii cui
IIO I1 .(IIEI’IIR
U.S. Environmental Protection Agency
Office of Public Awareness
Region 7
1735 Baltimore
Kansas City, Mo. 6z 1O6
Dear Sirs:
In reply to your invitation to the public meeting on EPA
Industrial Cost Recovery, I would like to state that I feel
that industries should pay their fair share in the cost of
treatment of industrial waste.
Our city of 1700 population has a new treatment plant which
we neededinainly due to the industrial load of a cheese plant.
Their BOD load runs just as much, if not more, than the load
for the rest of the entire’city. This cheese plant is the
only industry in our city.
Therefore, I definitely feel, that it is’ the duty of the
chees plant and not the residents of the city to pay for the
cost recovery. ,.
The cost of running our treatment plant has jumped from
‘$10000 with our o].d ,’plant to’ $6 ,ooo for ou new plant.
Thank you for letting me express my opinion.
Sincerely,
(% /Z94
Clarence L. Wright, Mayor
City of Hebron
CLW/jmn
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OFFICE OF THE MAYOR
HESSTON. KANSAS 67062
October 4, 1978
Office of Public Awareness
Region 7
1735 Baltimore
Kansas City, Missouri 64108
Dear Sirs:
The City of Hesston, City Council Wishes to have its
opinion of Industrial Cost Recovery entered into the
record of your public meeting on October 18, 1978.
We believe that industry which locates or is located
inside the corporate limits of our City should be
exempt from the Cost Recovery program. These “inside”
industries that pay City taxes are already contributing
to the “Matching” share of the new sewer facilities and
will be charged their porportionate share for operation
and maintenance.
On the other hand, industries locating outside the taxing
jurisdiction of a recipient government should be subject
to a Cost.Recovery provision in proportion to their sewerage
treatment facility.
Sincerely,
Mi ton R. Miller
Mayor
MM/j k
a. -
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QUAKER
The Quaker Oats Ccnioany P0 Box 1848. Cedar R pi’l Ir,,da %24’ 1Vs 1 3 ? i1?1
October 31, 1978
Mr.. Alan Brown.
Coopers & Lybrand
1800 M Street, N.W.
Washington, D.C. 20036
Re: Cedar Rapids Waste Water Treatment Plant
Dear Mr. Brown:
We have reviewed a copy of the “Preliminary Compilation of
Possible Study Alternatives, Industrial Cost Recovery Study”
distributed at the EPA public hearing in Kansas City on
October 18, 1978.
As you probably know, a new 42 million gallon per day waste
water treatment facility is being built in Cedar Rapids. The
startup design flow for this plant is presently estimated at
338,000± gpd.
It is our recommendation that Alternative II be adopted. Two
disadvantages a-re listed for it: 1) Reduce revenue to the
Federal Government; 2) May encourage development of excess
capacity, lacking other controls. According to the ICR questions
raised by Congressman Robberts (Congressional Record - House,
December 15, 1977), the total ICR revenues will amount to only
25± ’ of that estimated in 1972. With regard to the second
disadvantage, it doesn’t seem as if industries subject to the
EPA payback have much to say on the size of a waste treatment
plant - this is a decision of the public owner.
—- Very truly yours,
timl?’
RBS:ck . Manager
I. - ..- ‘. - - —
Wdter PollutionControj Plant
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Industrial Cost Recover Public Meeting
Region VIII
Quality Inn
Denver, Colorado
10 AM October 19, 1978
EPA — Harvey Hormberg, VIII, Dirqctor, Office of Grants
Jerry Burke, VIII, UC/ICR Specialist
John Pal, EPA Washington
C&L — Allan D. Brown
Edward J. Donahue III
23 Attendees:
Dennis T. Cafaro, Mgr. , Wastewater Division,
811 E. Las Vegas, Colorado Springs, Colorado
William E. Korbitz, Manager Metro Denver Sewage
District, 6L 5O York Street, Denver, Colorado 80229
Moe Tabatabai, Chief, Operation Engr., Wastewater
Management Division
John P. Hurst, Environmental Engineer, 310 Capitol Life
Center, Denver, Colorado. Hdq. Engineers
J. Thomas Adams, Operations Consultant, McCall,
Ellingsori & Morrill, Inc., 1721 High Street
Richard 0. Davis, Mgr., Environmental Engrg. Department,
M&I, Inc., Consulting Engineers, Ik7O1 S. College Ave., Fort
Collins, Colorado
Tommy O’Brien, Sellands & Grigg, Inc., Engineer for
Sellands & Grigg, Lakewood Colorado 80215
Errol K. Stevens, Wastewater Management, 38 40—6 York,
Denver, Colorado
Robert J. Madden, Chief, Government Affairs, County and
City of Denver, Wastewater Management Division, 38Z 0 York Street,
Denver, Colorado 80205
Bob Kocarha, Operations Specialist, Camp, Dresser &
McKee, 1660 S. Albion St..., Denver, Colorado 80222
James F. Dunn, Sanitary Engineer, EPA.
Dallas K. Stephens, Assistant to Utilities Director,
Englewood Utilities Department, 3 OO S. East Street, Englewood,
Colorado 80110
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George D. Sellards, Sellard & Grigg, Inc., 87115 W. 14th
Avenue, Lakewood, Colorado
Robert Greaney, Project manager Del—Mont Consultants,
Inc., P.O. Box 1186, Montrose, Colorado 811101
Dick Johnson, Metro Denver Sewage Disposal District,
61150, York St., Denver, Colorado
Jonathan Downir g, Laboratory Director, City of Colorado
Springs, 18 S. Nevada Avenue, Colorado Springs, Colorado 809117
Robert L. Arnold, City of Westminster, 8777 W. 88th
Avenue
Dan Uhl, Sanitary Engineer, City of Rapid City, 22 Main
Street, Rapid City, So. Dakota, 57701
Paul E. Williamson, Senior Public Health Engineer,
Colorado State Health Department, WOC, 79 Julian St., Denver,
Colorado 80219
Frank Orthmeyer, Director Public Works, City of Grand
Forks, North Dakota
Richard Zajac, Administrative Assistant, Pueblo Public
Works Department, 211 “E” D Street, Pueblo, Colorado 810011
Bruce Smith, Administrative Assistant, Pueblo Public
Works, 211 “E” D Street, Pueblo, 81003
Fred A. Nagel, Assistant Director, Operations, Denver
Wastewater Management, 3 1 180—G York Street, Denver, Colorado 80205
Complete presentations of
• Purpose of study
• Project scope and methodology
• Findings, conclusions and possible altert)atives
Statement presented by
William E. Korbity, Manager,
Metor Denver Sewage District
Eliminate ICR
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Metropolitan boqve Sewag Disposal District t*o.1
-- :- - - ---- — - : --.-
DON F ALLM 1);Chauman
MAP.JOEL flCflENOAUM.Cha,,man No T om
ROOERTW H1TE Sccrctary 6450 YOFII< STREET
GIL( CRTc IAPIG,Troasuror _____ OFNVFR.COLORAOO 80229
WILUAMCKOflOITZ,P E.Manau’i TELEPHONE NUMBER 13031 289-5941
October ii, 1978
Mr. John Pai
Project Officer (WH—547)
U.s. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear 4r. Pai:
In addition to the statement which I presented at the October
19, 1978, public meeting on the Industrial Cost Recovery study,
I submit herewith comments which I respectfully request be
included in the public meeting comments to be considered by
the consulting engineer, EPA and Congress.
The main concern I have about the industrial cost recovery
requircmen s of the Federal Water Pollution Control Act is
the complete lack of benefits to the environment or the
American people front the industrial cost recovery system.
The lack of benefits of the industrial cost recovery system
together with a sizable cost, estimated at no less than
$400 million annually, make it obvious that such industrial
cost recovery provisions should be eliminated from the fed-
eral law. The question of benefits of industrial cost re-
covery requirements must be addressed in the ICR study.
The October 4, 1978, Preliminary Cornpi].ation of Possible
Aitern itJ vcs ic1en ifies eii.mination of industrial cost re-
covery revenues as a disadvantage to be realized from
termination of the ICR roquireincnts. If raising revenue
from certain inciuz tries is a goal of the ICR system, I
suggest that a siqnificantlv more efficient system would
be collcction of moneys through the internal ROVCflUC Ser-
vice on a productioir unit ba i s or some other system. If
one of the goals of inthmtrinl cost recovery is to raise
money, the present tax system would appear to ho much
more efficient for this purpose.
-------
2
Another concern expressed in the October 4, 1978, draft is
that elimination of industrial cost recovery will lead to
building oversized treatment works. The present rules for
201 facility planning are strict on residential and comrner—
cial wastewater flow projections, and it would seem that
relatively little additional work would be required to bring
about good estimates of industrial flow. It then would be
easy to require reserved capacity agreements from industry
where the proportion of industrial flows to other flows is
high. Inasmuch as 201 facility plans must include estimates
of industrial flows in any event, this would be a relatively
small additional burden. I do not believe that industrial
cost recovery would be a proper way to limit the size of
treatment works;
The ICR study information indicates that the costs for col-
lecting industrial cost recovery charges are extremely high,
probably not less than 40 percent of the amount of revenue
collected. I believe this cost of collection of revenues
is intolerable. In addition, the stated estimated costs of
$20,000 per grantee per year for industrial cost recovery
collection does not apply to agencies such as the Metro Den-
ver Sewage Disposal District. The Metro Denver District as
a regional agency has no direct contact with industries, but
would collect industrial cost recovery revenues through its
21 member municipalities. It is obvious that the costs of
monitoring, billing, accounting and general administration
would be double because information required of the member
municipalities must flow from industries to municipalities
and then to the Metro District. It is obvious that the ad—
ministrativ’e and monitoring costs by member municipalities,
the I’ietro Dishrict or similar regional agency as well as
federal government are completely unreasonable as compared
to the small amount of i.ndustrial cost recovery revenue
generated.
In the mz- tter of water conservation, there would appear to
be no relationship botw en industria]. cost recovery and
water conservut-ion. If one of the reasons for industrial
cost recovery is water conservation, I submLt that in many
areas of the country such as the metropolitan Denver area
where less than 10 percent of wast:ewdier flows come from
industry, the water conservation brought about by industrial
cost recovery would be virtually meaningless. I submit that
some reasonable water conservation program would be much
superior to any indtT itrial cost recovery provisions.
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3
In the matter of industries being connected to publicly owned
treatment works receiving an advantage over other industries,
I point to historical fact that over the years industries
have subsidized local government in the form of ad valorem
tax base and jobs to help the economy of local government.
It should be kept in mind that the economic advantage given
to local government by industries would far exceed any
economic advantage given to ipdustries connected to POTW’s
with or without industrial cost recovery.
In summary, Congress should realize that the industrial cost
recovery system is extremely costly with no benefits to so-
ciety or the environment. The requirements of the Federal
Water Pollution Control Act concerning user charges, pre-
treatment and toxic wastes, together with the 201 facility
plan requirements have significant impact on industries con-
nected to publicly owned treatment works. The industrial
cost recovery provisions add little or nothing to these re-
quirements. It is my suggestion that Congress eliminate all
industrial cost recovery requirements; require 201 facility
plans to justify any high industrial flows or reduce capacity
of treatment funded; and where necessary require ten year
connector agreements for reserved capacities between publicly
owned treatment works management and industries.
Thank you for the opportunity to provide these additional
comments to be considered in the industrial cost recovery
study report.
Yours very truly,
William E. Korbitz
Manager
cc: Alan Brown, Coopers & Lybrand
Ron Linton, AMSA
Chairman Don F. Allard
WEK/j
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DIRECTOR OF PUBLIC WORKS
October 20, 1978
Cooper & Lybrand
1600 M Street NW
Washington, DC 20036
Attention: E. Donahue A. Brown
Gentlemen:
Enclosed, please find my written statement to be entered into the
record of the regional public hearing on the Industrial Cost
Recovery Study which was held in Denver on October 19, 1978.
I feel the hearing was well worth the time ;ind effort and your
firm should be complemented on the way it presented the information.
Yours very truly,
( Frank B. OrClimey’ r
Director of Public Works
CITY OF GRAND FORKS
BOX ISIS
GRAND FORKS NORTH DAKOTA 51201
(701) 711.1151
FBO/ch
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My name is Frank B. Orthmeyer, Director of Public Works for the City of
Grand Forks, North Dakota, a city of 42,000 pooulatiori with two industries.
It is a privilege to have an opportunity to express my view on this
matter.
I have been in municipal engineering work for almost 30 years, and before
PL 92—500 was passed, industry did about anything they pleased when it
came to sewage treatment. Practically all industries were either heavily
subsidized by the cities or dumped partial or non—treated sewage into
the river streams. was impossible to get information from them and
impossible to get their cooperation on obtaining factual test information
for a wastewater plant design.
Since PL 92—500 industry has been put on notice that Uncle Sam means business
and if PL 92—500 has done nothing else, industry now sits down across the
table and puts their best effort into front—end planning so that better
engineered facilities are being planned and constructed. We are getting
engineered Industrial parameters to work with.
So before we kill the Industrial Cost Recovery lets look at the benefits:
1. Industry is encouraged to participate in front end planning.
2. Industry is getting a non interest loan for their share of the
treatment facility.
3. fndtistri;il Cost Recovery takes part of the decision of an industrial
subsidy out of the local politicians hands.
4. If the local cost is not compensated with the 10% non refundable,
lets raise the non refundable to 20%.
In’dustry has been picking away at PL 92—500 since its inception, and I think
a. -
the law especially in the Industrial Cost Recovery section needs more flexi-
bility, but let’s not lose what we’ve gained.
Thank yo . I,
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Industrial Cost Recovery Public Meeting
Region IX
United States Environmental Protection Agency
215 Fremont Street
San Francisco, California
10 AM October 23, 1978
EPA — Frank Covingtori — Director,’ IX Water Programs Dj j j 0
John Randolph — IX, UC/ICH Specialist
John Pai — EPA Washington
C&L — Alan D. Brown
Edward J. Donahue III
16 Attendees:
Jack Barron, 636 Van Ness Avenue, San Francisco, 914102,
California, representing City and County of San Francisco
Ed Barry, 9660 Ecology Lane, Sacramento, California
95827, representing WOD — Sacramento County
Robert D. Bottel, Drawer J, Stockton, California, 95201,
representing Tillie Lewis Foods
C. W. Caron, 555 Capital Mall, Sacramento, California,
985114, representing Peat, Marwick, Mitchell & Company.
John Damas, Sr. , P.O. Box 214055, Oakland, California,
94623, representing EB Mud, SD 1401
W.S. Hyde, 9660 Ecology Lane, Sacramento, California,
95827, representing County of Sacramento, Department of Public
Works.
Christopher W. Jens, 450 N. Wiget Lane, Walnut Creek,
California, 94598, representing John Carollo Engineer
Jocelyn Kempe, 575 Market Street, San Francisco,
California 94105, representing Chevron Chemical Company.
Barry M. Landa, P.O. Box 83145, Stockton, California,
95209, representing Del Monte Corporation
Joseph A. Maldari, One Post Street, San Francisco,
California, 94104, representing Foremost—McKesson, Inc.
L. J. Naua, 1 Post Street, San Francisco, California,
941014, representing Foremost Foods Company
-------
Norman A. Olson, 1950 Sixth Street, Berkeley,
California, 914710, representing National Food Processors
Association
Bob Parod, P.O. 3327, Modesto, California 95353,
representing Tn/Valley Grocers
Nicholas s. Patemon, P.O. Box 14557, Haywood, California
9514140, representing Hunt—Wesson Foods
Lloyd Sawchuk, 213O Adeline Street., Oakland,
California, 914623, representing East Bay MUD
H. E. Stone, P.O. Box 3575, San Francisco, California,
914119, representing Canners League California
Complete Coopers & Lybrand presentations made, including all ICR
alternatives
Statement by
William Hyde, Water Quality Division,
Dept. of Public Works, Sacramento
Abolish ICR
7 PM October 23, 1978
1 Addendee:
Eugene Boone, P.O. #3111, Zip Code 95353, representing
John Inglis Company
Complete Coopers & Lybrand Presentations on methodology and
findings. Much discussion on alternatives.
No official statement. Comments from attendee opposed ICR.
10 AM October 214, 1978
3 Attendees:
R. Lim, 3601 S. Santa Fe Avenue, Vernon, California
90058, representing Glass Containers Corporation
Donald P. Perrin, 20114, T Street, Sacramento,
California, 958114, repr entig JWR&B
-------
F. N. Verlancier, 1501 N Broadway, Waltnut Creek,
California 9L 596, representing Brown & Ca].dwell, Consulting
Engineers.
Informal discussion of study methodology, findings and
alternatives.
No official statements. Comments from one attendee opposed ICR.
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7 i r. CITY AND COUNTY OF SAN FRANCISCO
-. DEPARTMENT OF PUBLIC WORKS
BUREAU OF SANITARY - 636 VAN NESS AVENUE
ENGINEERING SAN FRANCISCO
INDUSTRIAL WASTE DIVISION October 31, 1978 CALIFORNIA 94102
Mr. John Pal (WH—547)
U.S. Environmental Protection Agency
401 “M” Street, S.W.
Washington, D.C. 20460
Dear Mr. Pai:
The following comments pertain to the preliminary Industrial
Cost Recovery (ICR) study results that were presented by EPA
Consultants, Coopers and Lybrand at a meeting held in San Francisco
on October 23, 1978. We concur with the preliminary study
alternate which would abolish the ICR Program. We agree with
the advantages listed as a partial list, and disagree with the.
list of disadvantages. Further advantages to abolishing the
ICR Program are as follows:
1. This action would encourage industry to utilize
the publicly owned treatment facilities (POTW)
for the removal of conventional pollutants.
2. Thi action would eliminate discrimination
against those industries which do not have
sufficient space to provide pretreatment of
facilities for the removal of conventional
pollutants. Such removal of conventional
pollutants may be desirable to the industry
in order to lower or eliminate ICR costs.
3. This action would encourage industries to remain
in the POTW service area and to pay its fair
share of the costs of operating and maintaining
the sewerage system. Therefore, the increased
cost burden, because of industrial relocations,
wbll not be placed on residential and commercial
users.
a-
The disadvantages of eliminating ICR expressed in the prelim-
inary compiliation — the loss of control over the design
capacity of POTW’s and — the loss of revenue to the Federal
Government are not valid for the following reasons:
-------
Mr. John Pai(WR—547)
October 3]., 1978
Page 2
1. ICR should not be the method used in an attempt
to control the capacity of a POTW. Any controls
on excess capacity of new construction should be
accomplished in the Federal and State review pro-
cess for grant eligibil’ity. The State of California,
for example, has developed such a method of reviewing
and regulating the grant fundable design capacity of
POTW’s.
2. The total lost revenue to the Federal Government
would amount to a maximum of $1 billion collected
over 30 years. This is an insignificant amount
compared with the Federal Budget.
In conclusion we believe that because there are many dis-
advantages to continuing the present ICR Program; the
ICR Program should be abolished.
Very truly yours,
/ Zl ’ a 2
,‘Jeffrey Lee
.1 / Acting Director
j 4i ’Department of Public Works
cc: Mr. John Raridoif
Water Division
215 Fremont Street
U.S. EPA, Region IX
San Francisco, CA 94105
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SAF STORES, INJCOR
425 Madison Street. Oakland, California 94660
Industrial Design and Construction Department October 30, 1978
Mr. John Pai — E1145 WH 547
United States Environmental Protection Agency
Municipal Wastewater Treatment Works
Construction Grants Program
401 M St. S.W.
Washington D.C. 20460
SUBJECT: Statement Concerning Industrial Cost Recovery,
Public Meeting, EPA Region 10, Seattle,
Washington, October 25, 1978
Gentlemen:
We believe that Industrial Cost Recovery (ICR) should be abolished.
Alternative 12 of the study appears to be a rational approach, but
with some precautions. This alternative provides that industry
would pay a proportionate share of the non-grant portion of the
capital cost rather than upon the grant portion. It further provides
that this share be recovered through user charges (UC). Unfortu-
nately, considerable inequity can result depending upon the method
of calculating UC. The following comments explain this position.
It should be cheaper to treat conventional pollutants on a large
scale at a publically owned treatment works (POTW) than on a small
scale at a number of industrial sites. This concept is widely
accepted and its cost—effectiveness is in the public interest.
However, our experience with UC has been a costly one in which
these charges exceed the cost of self treatment or at best equal
this cost. Addition of ICR to UC compounds the problem.
To justify a charge for capital cost requires a review of UC, since
there are frequently many inequities committed in its calculation.
For example: a grant-funded 10 mgd plant is currently operating
at less than 5 mgd. At least 75% of the O&M cost is directly
related to capital in stment and at the 10 mgd level. The company
is charged a proportionate share of O&M based upon a 10 rngd
investment.
-------
Mr. John Pai - E1145 WH 547 October 30, 1978
—2—
Another example of an excessive UC charge has resulted because the
POTW was not a cost-effective design. The POTW was built to
evaluate physical/chemical treatment. The resulting UC far exceeds
the cost of self-treatment. Rat1 er than enter the sewage treatment
field, the company has continued to pay the excessive charges.
To summarize our observations:
1. ICR is not justified.
2. Collection of a proportionate share of non grant
funding may be justified but should require
review o-f UC.
3. The total charges for sewage treatment of
conventional pollutants should be less for POTW’s
than for self-treatment.
Very truly yours,
SAFEWAY STORES, INCORPORATED
CL R.1Jo KQ
A. R. Van Kleeck
Sr. Environmental Engineer
INDUSTRIAL DESIGN AND
CONSTRUCTION DEPAWThIENT
ARV:pp
cc: C. P. Pond
B. Rosnor
R. J. Lindquist
R. A. George
R. H. Kaufman
D. E. Hennigh
for G. E. Ribary
J. D. Clark
H. 0. Davis -
G. B. Skinner
B. S. Thornton
cc: Alan D. Brown
Coopers & Lybrand
Washington, D.C.
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_________________________ ______I
i&97 flAY WU,v/(/PAL urlL/r Ql TRICT
October 30, 1978
Mr. John Pal (WH547)
Municipal Construction Division
U.S. Environmental Protection Agency
401 “M” Street, SW
Washington, I X. 20460
Subject: ICR Study Comments
Dear Mr. Pal:
It is our understanding that the legislative intent of ICR was to achieve
industrial equity, capacity control, and conservation. We have reviewed
the preliminary listing of possible study alternatives to ICR dated October
10, 1978, and recommend that ICR be abolished.
Based upon our knowledge of our interception, treatment and disposal system,
none of the remaining 15 alternatives would insure equity, capacity control
and conservation in our service area. In many instances the alternatives
would create greater inequities and increase ICR program development and
administration costs.
We believe that the following are examples of how ICR alternatives will
continue to fail to achieve the objective of “equalizing” costs or achieving
“equl ty”.
- Alternatives 2, 3, 5, & 6 require a knowledge of industrial contributions
which may not now exist at many POTW’s. Industry surveys will be required
under new pretreatment regulations for a limited number of municipalities.
Therefore, in many areas, industrial dischargers will not be identified
and even if identified under pretreatment rules, will probably be limited
to only those industries discharging toxic substances.
- Alternatives 6, 7, 8, 9, & 10 would establish ICR rates based upon
factors other than industrial capacity of the facilities constructed.
— Alternatives 2, 3, 5, 7, 8, 9, 10, 14, 15, & 16 would result in varying
increases for development and/or administration.
I ‘ . .I yiQ’J
— .V 4 1 • - I .I I .I I
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Mr. John Pal -2- October 30, 1978
- Alternatives 2, 3, & 5 would change the basis of grant funding of future -
facilities from that of previous and current projects.
The ICR study alternatives wil.l not result in capacity control and conservation.
Again, we recommend that ICR be abolished. Should you have any questions on
this matter, please contact Mr. Joseph Damas, Wastewater Control Supervisor,
at (415) 465-3700, extension 120.
Very truly yours,
‘M NAGER,
Water Pollution Control Department
EER:nc
cc: Coopers & Lybrand, Alan D. Brown
EPA, Region IX , John Randolph, Water Division
Assoc. of Metropolitan Sewerage Agencies
California Assoc. of Sewerage Agencies
a.-
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John Inglis Frozen Foods Company
Cabic JIFFCO , Modesto, CA, USA. — Phone 209.524.5521 — Teletype 510-761-4414
P o. Box 3111 — Modesto, California 95353
October 26, 1978
Hr. John T. l’.ii
liunicipal COnStrUCtIOn Division
lliilted St,,tc l r vironrnental Protection Agency ‘ ..
4 )l “I! ” SLrcet S. W ‘! ?
U’shington, 1. C. 20460 :
4
l)e,ir U i-. ii
Lct iiie tiI:r’ this opportunity of thanking you for putting on the
Presentlithi’ r the ICR program at the San Francisco hearing last
Uondny, Octobci- 23, 1978.
As t told ycui’ at the meeting, our company is deeply involved in
paying for h.ivit g waste treated by municipal sewage plants in eight
west coast ciliuc. Anything that would cause the already high cost
to go up cr’ ite ; re 1 problem for us.
1 undc’rstari.i that the moratorium on the ICR is scheduled to be
liItc(l on July 1 , 1979 which would expose us to possible penalties.
You Ii ive ig ;cst:cd sixteen alternatives to the ICR program. The only
one that scenic t’) me to be cost effective is Number I which calls
for the nbolisljmeut of the ICR. The second best possibility seems
to he your l’hinibc’r 12 which calls for the abolishment of the ICR
and rectuires that the locals share (12’f/,) the project cost to be
recovered tlu nu ;Ii users charges.
The PresHc’it, in his speech of last Tuesday, is asking everyone
to help him arr ’st the runaway inflation rites. If industry cost
recovery eliari .’F are assessed to food plants such as ours, we will be
forced to raise our prices in order to pass our costs along to the
(‘(iu’ Uincr. TI ‘ •;ocms to ric to be counter—productive to what the
l’rcsidcnt is tryi.iig to achieve to hold down prices to break the
-inflation spiril. Lastly; I would suggest that the EPA give strong
consideration to relaxing their approach to some of the environmental
proI)lcrlS such as purifying the water in order to assist in holding down
fitfialion. Our industry is not against the EPA program in any way but
we arc rryin . to make it practical and cost possible rather than
t(lOalistje.
I would 1i’ c’ these comments added to the comments you received from
industry g ’iieral ly on the ICR program.
Very truly yours,
John Inglis Frozen Foods Company
ru c’’ t’ Vicr ‘hi -
— — — I — _1 I_ I__i.. _.. — ._ . — ___._ — ——S — — ._. _I —
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Industrial Cost Recovery Public Meeting
Region X
Federal Building
Seattle, Washington
10 AM October 25, 1978
EPA — Bob Kussman, X, Wastewater Operations Branch
Christine Noah—Nichols, X, UC/ICR specialist
John Pal - EPA Washington
C&L - Alan D. Brown
Edward J. Donahue III
28 Attendees:
Bruce Brown, P-I
John J. Bohn, Nalley’s Fine Foods, 3303 S. 35th St.,
Tacoma, Washington 98411
Jerry Clarke, Safeway Milk Department
H.O. Davis, Safeway Stores, Inc.
James M. Davis, John, Fluke Mfg. Co., Inc.
William T. Dehn, CH2M Hill, 1500 — 114th St. S.E.,
Bellevue, Washington 98004
Howard Donelson, Boeing
Jim Ddwning, Ch2M Hill, 1500-114th Ave. S.W., Bellevue,
Washington 98004
Howard Edde, Howard Edde, Inc., Bellevue, Washington
Tony Harber, Brown & Caidwell
Douglas A. Hilderbrand, Municipality of Metropolitan
Seattle, 821 Second Avenue, Seattle, Washington 98104
George Hou k, Washington State Department of Ecology,
Olympia, Washington 98504
Travis Keller, Overall Laundry Services
A. R. Van Kleedi, Sr. Environmental Engr., Design &
construction Department, Saf’eway Stores, Inc., 425 Madison St.,
Oakland, California 94660
Gary Krahmer, Unified Sewage Agency, Hillsboro, Oregon
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Stanton LeSieur, Unified Sewage Agency, Hilisboro,
Oregon
Charles F. Liebert, Unified Sewage Agency, Hilisboro,
Oregon
Robert MoGuire, Agripac Inc., P.O. Box 5346, Salem,
Oregon 97304
Bob Meyers, Olympia Brewing Co., Box 9147, Olympia,
Washington 98507
Elwood W. Ott, Seattle Engr. Dept., Room 910 Municipal
Bldg., Seattle, Washington 98104 Tel. 206—625—2354
Larry L. Petersen, Metro, 1410 W. Harrison, Seattle,
Washington 98119
Mike Price, City of Tacoma Sewer Utility
Judy Riley, Metro
Bill Sohow, Magic Valley Foods, Inc., P.O. Box 1475,
Rupert, Idaho 83350
W. T. Sparke, Gordner Engineers, Inc., 3rd & Cherrt,
Seattle, Washington 93103
John d. Thomas, Metro Wastewater Management Commission,
P.S.B., 125 Eighth Ave., Euguene, Oregon 97401
Bill Wittom, Mayor Rupert, Idaho 83350
Gary C. Young, P.E., City Engineer, City of Twin Falls,
P.O. Box 1907, Twin Falls, Idaho 83301
Complete presentations of
Purpose of study
Project scope and methodology
Findings, conclusions and possible alternatives
Statements presented by:
Bill Schow, Magic Valley Foods Inc.
Opposed ICR. Supported #9 too - tax credit for ICR
Payments.
Bill Whittoin, Mayor, City of Rupert, ID
Need industry Th POTW - do not drive them to self—
treatment
Mike Price, Chief, Sewer Utility Div., Dept. of Public Works,
Tacoma, WA
Opposed to ICR. Supported #12 — recover local share
through proportionate user charges.
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John Bonn, Nalley’s Fine Foods, Tacoma, WA
Opposed to ICR. User Charge has quadrupled.
Robert Maguire, Agripac Inc. Salem, OR
Opposed to ICR. Supported #8 — circuit breaker.
George Houck, Dept. of Ecology, VA
Continue ICR, with administrative improvements
Gary Young, City Engineer, Twin Falls, Idaho
ICR has benefited the city.
Tony Harber, Consulting Engineer, Brown & Caldwel].
Believes industry can estimate future POTW usage.
W. T. Sparke, Gardner Engineers, Seattle, WA
Supported #12 — abolish ICR and recover local share
through proportionate user charges.
Written statements received from:
Unified Sewage Agency of Washintori County, Hillsboro, OR 97123
Opposed to ICR
Electro Scientjfjc Industries Inc., Portland, OR 97229
Opposed to ICR
Hally’s Foods, Hilisboro, OR 97123
Opposed to ICR
a. -
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OL I i k B E*INIG
POST OFFICE BOX 947. OLYMPIA. WASHINGTON 98507.206/754.5000
October 27,, 1978
Mr. Alan D. Brown
Coopers & Lybrand
1800 “M” Street, NW
Washington, D. C., 20036
Subject: ICR Review Study
Dear Mr. Brown:
After attending your public hearing for Region 10 in Seattle
on 25 October, I would like to offer some thoughts on ICR and your
current study.
First, picking alternatives from your list of sixteen, obvious-
ly No. 1 has the maximum positive impact on our financial health. Al-
ternate No. 11 is also viable. Alternate 12, while outwardly attractive,
would eliminate such practices as existed in Washington State whereby
15% of the local share was state funded without ICR. All other alternates
have varying degrees of negative impact; most, in fact, more severe than
the existing No. 15.
As food for thought, a couple of additional alternates might be
considered: -
1. Reduce ICR to 50% level with all monies to be retained in the local
Community under the existing ground rules.
Advantages : a. Softens impact on Lndustry by 50%.
b. Reduces effect of “double taxation”.
c. Keeps money in user’s local community.
d. Provides local funds for future replacements.
e. Maintains method of federal funding of
...ceplacement cost.
f. Encourages local POTW to treat industrial waste.
g. Reduces many of the problems currently ascribed
to I C R.
Disadvan.tages: a. Reduces cash flow to federal government.
BREWERS OF BEER A LIGHT REFRESHMENT BEVERAGE OF MILLIONS OF TEMPERATE PEOPLE
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Mr. Alan D. Brown -2- October 27, 1978
2. •CompLetely revise funding for waste water treatment plants. One meth-
od would be the establishment of a program similar to that used to pay
for the Interstate Highway System. Under such a plan, all users, be
they private, commercial or industrial, would pay into the federal trust
fund- based on usage. New plant construction would then be paid out
of the fund. Administration would be relatively simple because it could
be set up to be paid by POTW’s on incoming flows. POTW’s, In turn,
would pass the charges through to their customers. Customers sending
waste to a plant requiring special handling such as high BaD, suspend-
ed solids, or whatever, could be billed incremently for levels above
residential or community averages. The advantages are numerous:
a. It is relatively simple.
b. All users would pay based on usage
c. Charges would be uniform nationwide.
•d. Treatment plant unit cost per gallon treated would
not be a factor in funding. Thus, large users
of small planlswould not be penalized, nor would
- small cities, nor would cities in high labor cost areas.
e. It removes the program from the general fund and puts
the cost on users. If some “social value” is per-
ceived in the program, general fund monies could
be added thus reducing the user charge.
f. Large users requiring special facilities would pay the
direct cost of the extra or special facility.
g. There would be an increase in cash flow to the treasury.
This could perhaps be rebated in the form of a tax cut.
h. It would encourage large user conservation thru a
direct reduction in cost.
i. By making cost uniform and fair, it would encourage
large user connections to POTW’s.
Among general comments is that the use of the word ‘revenue’ in
“disadvantages” has a mildly negative connotation. What you are referring
tc• is a return of loaned funds to the federal government that were colLected
from primary tax sources. While it represents an economic gain or loss to
the government, it should not be considered as a source of revenue. it is
not a tax.
Finally, your summation seems to show a concern about industrial
participation in design plThses. This has not been a problem for our local
facility. We have been involved with all aspects of the concept and design
phases that impact on our firm. I would guess, however, that industrial
participation would tend to b inversely proportional to community size and
POTW size.
OLYMPIA BREWING COMPANY
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Mr. Alan D. Brown -3- October 27,, 1978
Obviously, there are numerous approaches to the problem. It Is at
least worthwhile that the shortcomings in the present approach are realized
and an attempt is being made to simplify the program and to lessen the bur-
den on one specific group of taxpayets.
o S very truly
t 7 Ltf V14
Robert I. Meyers (
Asst. Plant Engineer
RIM:rncc
cc: Mr. John Pai
M.S. WY547
U. S. Environmental Protection Agency
401 “M” Street, SW
WashingtonD. C., 20460
S -
OLYMPIA BREWING COMPANY
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overall
LAUNDRY
SERVICES
OCTOBER 27, 1978
IR S ALAN D. BROWN
COOPERS C LYI3RAND
1800 M. STREET N.W.
WASHINGTON, D.C. 20036
[ ‘EAR MR I3ROW? I:
Ar rilE ()LTO 13ER 25, 1978 PUBLIC MEETING HELD IN SEATTLE TO ACCEPT
LOl ?iENTS ON ThE ICR PROGRAM YOU INDICATED - THAT LETTERS REGARD INC, TRAT
PROGf AM COULD BE SENT TO YOU.
I AM A PARTNER IN AND P WJNER OF OVERALL LA’JIIPRY SI-PVICES. OIJP
I 1PM OPERAFFS A PLANE III TACOMA, WASH. AND OIJP HFAFX UARTERS Pt ANT IN
SIATTLE, WASH. WE EFIPI OY AUOIJT 250 PEOI’I F Nil) USE AROU 170,1)00 GAL LONS.
OF WATEP DAILY IN SEA1TLE AND h7,000 GALLONS PEP DAY IN TACOMA. WE
HAVE REEIJ MFETING wirii SEATTLE ME1RO OFFICIALS 1 - OP SEVEPAL YEARS ON
fliF WHOLE UI4 ,iE1T OF WAS1E WATER. TIlE FOCI OWING COtUCN S ARE BASED
ON t NSIDEPATJOFJS AT OUR SEATTLE PLANT ONLY. I CANNOT VIEW THE (1) ICR
PROGPt4’I SI- PERATE LV FROM THE (2 rRx;PAM TI IA I SF15 UP T I IF (I IAPr.FS WF PAY
:()p pTS(.HApGIr.I , , rMJR WASTE WATFP TO ThE Nr1P SEWIEP. SYSTF I, At 5 ) IN—
I lii Ffl IN 1 P Till NK I MG 1 S Ti IF APPARFI ir RV’ IJ I P VF .1FNT WE FA F TO P111 IN
SOME (3) PP.E—TREATMENr FQUIPMENT RI TREAT OI’I WASTE WATFP FOR THE FUTURE.
I I APPFAPS WE WI Li. bE OUT OF COMPL lANCE ON GP.FASE AND Oil AND POSSIRLY
Sfl?4F FIFAVY MFTALS.
THESE THPF . FALIORS TOGETHER REPRESFNT A TREI-IENDOIJS F INNJCIAL
(.OF T4ITMFNT FOR (IS AND CREATE A GREAT MANY DIFFICULT PROFiL EMS.
(Ip r 1 1 T’ V Pt ‘V’II IS III A S •Pl ; OF OLt’fP UIIILDI 1I;c (i I T TFTh
! ih ‘‘f _F _ il P I.’S TO INS1AI I. PPETRF-ATMENT i -E0I1I PMEMT WI II I IJVOLVF
s’ ‘i s 1. N I I i ’ i ’ ii 1.1)1 N’; FJI:NOvAT i Ii AND PP .OPAI3I_Y NICESS I r IF flI)P US I FIG WI IAT
- i ITt .r ‘“ji it ir I I si_I “ LAN( WE I IAVE AVA I LABI_E l( I 5 , CT’ IE I 1)5 I OF Ifi ’ID
N 1-AP u ’; I:; 4flOUT 7.50 PEP SQ. Fr). A (.(‘NSFRVATIVE ESTIMATE OF COSTS
TI) I-UP AN1 II-I TI LL THE EOUIPMENT IS $25i),IJOU. IiASEI) ON (0S15 L:APEPIENCED
t; r S I F-’ II 1.1-’ I NI ;L’Sl P I AI_ LAUNOR I i_ S N 1 OS5 TI IF: I I 01 JR ANI II IA( )I IPA r I Nr.
((‘Si S WOl Jil’ IF APPPOXIMATFI_Y SRO, 000.
WI LI JIRI NI I ? PA’v A1i lARGE flW H I( ,i I i N JGli I DI ‘ (J ‘Ar’Gf: (I- 1 75 .
( OP ‘JIIZ!7f1 rI Iflh1 /7 ). TillS IS IN ANNIT 1011 r OUR crw r UI I 1MG OF
i ; rj (Ø IIIF ‘At . ! P1 !J(’l)_ I IJAVF NO PFAI IDI A WHAT 1IIV f( P ( I ”\P( I ‘ I AY
‘/1: T l’ I IV Ai 5 (Ii ;T .10.
222 YALE AVENUE NORTH . SEATTLE, WASHINGTON 98109 . 682-6666
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PA(E 2
THE 501 L wi: PUT INTO OUR WAS1 EWATEP. is WASI ‘ED OU1 OF WOPK CLOTI I I M c,
WOPJ’J 1W THOUSANDS OF INDIVIDUALS EMPLOYED LW PUGET SOUJD RUS II IFSSES.
OUR IF&REASFD COSTS MUST BE PASSED ON TO r1IFSF BUSINESS. IF fliP. c:osis
BLC( ‘ I rE TOo Ill Gil TIlE SE BUS I NESSES H VE Ti IE OP r I 011 OF RCOU I R I I Y I I IE I P
EIIPLOY I S ro W A5ii TIfEI GAPNENTS Al HOPE, OP ALTEPNATIVELY 01 run INC
IN THEIR OWN CAPTIVE LAWDRY. THIS WOULD RCSULT IN TilE SANE TOTAL
LOADING OF C0IITN-IINANrS BEING PLACED ON THE T1ETRO TPEATIIEFJT PLNJTS,
WITHOUT ANY USER CHARGES OR ICR CHARGES BEING REQUIRED.
OUR (OMPANY UF’PERSTANDS ANT) AU EPTS TI-IF NATIONAL AND I OCAI COI41IT-.
?‘E Ni TO (.1_EANEP. WATER. FR01 1 OUR ANALYS IS ANI DI SCUSS I( I WI TI I ,1IIFPS IT
SEIJIS EVI DEN I I IOWEVEP TI IAT TIlE 14)ST EFF I I EN r AND L0x I (AL APPP ’AUI TO
u_FAN I Fi( UI’ 1011 rNl I £4ATED WASTE WATER I S TO I fl IT TI P.flt K;I I LA ’cF P1 JUL 1 ( —
AL.LY ()WrIF.D AND OPEPATEI) TREATMENT PLANTS,• IIIAT APE SOP1IJSTICAIErI r:r1our,II
10 IININ F THE ENTIPE CLFAN UP PPOCFSS.
1. iT WI LI_ COST US M RF TO TRY 10 TPF:AT WASTE WA1F P TI IA /i I r iflhJLD
METRO.
2. I r OUR COSTS GET TOO 1-IIG1 i our. ci is rot ii:rs I IAVI- Al TLPNA 1 IVF.S TI IAT
tlO( ii 0 PEST iii I N TI IF 5$! . TOTAL WAL I NC ON lEE TF’o, it’ Jt OMIt I C, FROM
I lUNDi. EF ’S OP LVEN THOUSANDS (‘F cnv;’ i-c N!1) W ’ it I L .1) Ti [ P1: FORE DE
UN(.OI’iTRULI.AULL.
I F WF Mi V,T PUT I H PP .Ei RI— Afl4FF! [ C’ ‘I Pt l. T ri iLN tIC 51 t( ’I ii_D I JOT
i irwv ro PAY i i i i CR u IARG 1 . m r n I ; To t i: TO GI I iJE “DOUBI_E
TAX’\ r i or i”.
I LOt f’F IAVE ii IE UACK(,POL’I if TO REALLY If ii If Ll_ IGENTI v ‘tILL (IDE WHETHER
I CR I S ‘ PPPOI ‘IA I(- (IR N’) I L UT ri i i : 1 ‘P03W iS IPEATED F( ‘p 4Y ( flI- P, NY AS WE
FAIL Il-IF FIJI IPF P4NGE OF WAS1E WATER RE( UIPE14EIJTS, ARE SF-VERE.
TI ’lV YOU FOR TIlE OPPOPILNITY 10 t”PkKF THE F PFMAPVS.
. (fl RI I V YUPS,
7/
iiv vis VL:EI_i r.
‘ If/ zr
a —
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EXHIBIT V—1-1O
SUMMARY OF PIJ IC CX 1MENTS RECEIVED BY C&L ON DRAFT REPORT
CCIMENTS ON EAQi RE(Y MMENDATION
1. Eliminate 2. EPA Pay 3. Debt Service . Trust Fund
Ccziimentor IC R for less Thrki User for Re—
capacity tharge construction
National Assn)of
Manufacturers’ Agree Disagree Disagree Disagree
National Food
Processors Assn. Agree Neutral Disagree Limit to POVd, Eliminate
Collectors and Interceptors
Anmrican Frozen Food
Institute Agree Disagree Disagree Disagree
AMSA Agree Disagree Most members Disagree (political
not supposed agree problems)
to address
growth control
City of Fall River,
Massachusetts Agree Not Practical Agree Disagree (not practical)
State of Ver nt Agree Disagree Should be Insufficient amount
optional Collected to be of value
Campbell Soup Co. Agree Disagree Disagree Disagree
Penjerdel Corp Agree Disagree Disagree Disagree
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NATIONAL ASSOCIATION OF MANUFACTURERS
RESOURCES & TECHNOLOGY DEPARTMENT
Energy
Environmental Affairs
Natural Resources -
Science & Technology
December 6, 1978
Mr. Edward J. Donahue III
Project Manager
Coopers & Lybrand
1800 M Street, N.W.
Washington, D.C. 20036
Dear Mr. Donahue:
The Wate’ Task Force of the NAM Environmental Quality Com-
mittee has reviewed a draft copy of the Summary Volume of the
Study’s Industrial Cost Recovery report.
The Task Force believes that Recommendation #i to eliminate
the Industrial Cost Recovery provisions of P.L. 92-500 has a
solid foundation from the standpoints of both factual basis and
logical conclusion. Both the assumptions on which Industrial
Cost Recovery was based and the manner in which it actually
operates, upon analysis justify the conclusion that it should be
eliminated.
On the other hand, Recommendations #2, 3, and 4 are in the
nature of speculative ideas without background in previous exper-
ience and without any basis for anticipating their impacts in
actual practice. We strongly urge that these recommendations
not be made by Coopers & Lybrand or by the U.S. Envirormtenta l Pro-
tection Agency. It has not been demonstrated that elimination
of ICR necessitates any other substitute measure.
Although the draft Executive Summary alludes to user charges,
(UC), the Task Force, does not believe that the subject is ade-
quately considered. At page 4, it is stated that “the combined
impact of UC/ICR can be very significant,” This statement is
made again at page 17.
At page 20, it is stated that “The combined impact of User
Char e (UC) and Industrial Cost Recovery (ICR) is greatest on
seasonal users for (.for CR1, on industries paying for AWT (for
UC and ICR) and in those cases where rates prior to UC/ICR were
low due to treatment levels or promotional (declining block rate
structures.”
1776 F Street N.W., Washington, D.C. 20006 • Phone (202) 331-3700
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Mr. Edward J. Donahue
December 6, 1978
Page 6
At page 24, it is stated that t1 the study data indicates that,
prior to adoption of UC/ICR systems, an average of 55% of grantee
waste water revenues caine from the residential sector, with 45%
coming from the non-residential sector. Subsequent to adoption
of UC/ICR systems, this ratio was’reversed.”
The Water Task Force believes that the rigid inflexible legis—
lative and regulatory requirements imposed in connection with user
charges have imposed substantial disparities and inequities through-
out the United States. EPA should explore this subject further and
make recommendations to the Congress for legislative changes that
would allow greater flexibility in user charge arrangements so long
as they were not clearly unsound.
We appreciate your consideration of our comments.
Sincerely,
Louis C. Gilde
Chairman -
Water Task Force
NAM Environmental Quality Committee
cc: John Pal, EPA
a
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I I ’F1 National Food Processors Association Agricultural and
I 11 3 3 rw ,t’ Street N W, Washiu nk n D C 2003b Environmental Aflair
TeI phon 202,331-5900 Edwin A Crosby. PhD.
Senior Vice President
202/331 -5967
Jack L Cooper
Director.
December 6, 1978 Env lronmentalAffairs
202/331.5968
Raymond F Altevogt, Ph D
Mr. Ed Donahue Assisfarit Director.
Coopers & Lybrand AgrlcuUuralAff air
1800 M Street, N. w. • 202/331-5969
Washington, D. C. 20036 -
Regarding: Comments on the November 22, 1978 Draft Final Report of the
Industrial Cost Recovery Study, Vol. 1 - Executive Summary
Dear Mr. Donahue:
Thank you for .providing us with a copy of the above report. As requested
at the November 28 Advisory Group Meeting, we are pleased to provide you with
our written comments on it.
I. General Comments
A. EPA and Coopers and Lybrancj
We commend the Agency staff and Coopers and Lybrand (C&L) personnel
for their open-mindedness and willingness to work with all interested parties in
the development of the report. The procedures followed were exemplary and
should be followed by the Agency in the development of all of its future reports
and regulations.
B. C&L Recommendations
1. We believe that the first recommendation is clearly supported by the
information collected by C&L and contained in the body of the report. However, we
believe that the other three recommendations are not supported by data and other
information obtained by C&L. Accordingly, we suggest that Recommendations 2,
3, and 4 be given less emphasis by not listing them as firm recommendations.
Rather, we suggest that if they are to be retained in the report they be listed in
an appendix as “Discussion Items for Congressional Consideration.”
Our suggestion is based on the fact that the focus of the study was not on how
Congress should establish parity, limit POTW capacity, force water conservation
practices on POTW users, aron how POTWs should be funded in the future. As
stated on page 1, Coopers & Lybrand was required to “examine the efficiency of,
and the need for the industrial cost recovery (ICR) provision of the Federal Water
Pollution Control Act. “ The study C&L conducted clearly assesses the efficiency
of and need for ICR. Thus, C&L has a sound factual basis for making a recornmenda-
tion on ICR. However, the C&L study did not address the issues to which
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Mr. Ed Donahue - .2 - December 6, 1978
Recommendations 2, 3, and 4 respond. Consequently, we do not believe that the
report contains sufficient documentation to support Recommendations 2, 3, and 4.
2. We do not support the inclusion of C&L Recommendation No. 3 in the
report, even as an item for Congressional discussion for we do not believe that
funding of the local share should be subject to Federal regulation. Additionally,
this requirement is not needed to force industrial users to conserve water. As
stated in the C&L answer to Congressman Roberts’ question No. 5, user charges
and water costs are sufficient to achieve this objective for industrial users. We
also believe that reduced water availability in many parts of the country plays a
significant role in forcing water conservation. We also point out that Recommenda-
tion No. 3 could create additional inequities. For example, industrial users could
be required to pay local debt service for sewers not used for transport of industrial
wastes from the plants to the POTW.
3. C&L Recommendation No. 4 has the potential of having a greater
economic impact on industrial users of POTWs than the current ICR program if the
amount of the charge is increased substantially. While the C&L proposal appears
reasonable, the possibility exists for different rates being set by Congress for
residential and industrial users. Hence, we strongly suggest that this Recommenda-
tion be included only as a possible Discussion Item for Congressional Consideration.
Based on our members’ experiences with local government, creation of
trust funds of this type frequently results in use of the collected fund for other
“temporary” purposes and when actually needed for the intended purpose may be
unavailable. Furthermore, trust funds of this nature should not be created without
clearly identifie4 purposes, total costs, and community endorsement of the project.
C&L Recommendation No. 4 should also be modified to state that the charge
should not be implemented until a treatment program has been developed and a
maximum value for the fund established. The amount collected should not exceed
a certain percentage of this maximum value.
Also, C&L Recommendation No. 4 should be modified so that an industrial
user would be required only to pay that part of the fund which would be used to
replace or build new POTWs and sewers which are used to treat and transport that
plant’s wastewaters. Sewers which serve only the residents of the area should not
be paid for by industry contributions to the fund. Existing industry also should not
be expected to pay for capacity or services which might be made available to
competitors.
C. Effect of combined UC, ICR, and local Debt Service on Industrial Users
should be stressed more heavily .
Throughou t the report, the total effect of POTW wastewater treatment costs
on industrial users should be stressed more heavily. The back-up data to the report
clearly shows that seasonal industrial users of POTWs are paying more for waste-
water treatment than self-treaters. This total cost effect should receive greater
emphasis in the report.
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Mr. Ed Donahue - 3 - December 6, 1978
D. Removal of ICR is only one way the high cost of seasonal industrial
use of POTWs can be ameliorated .
We suggest that C&L discuss in the final report other methods, in addition
to abolishment of ICR, for reducing the cost of industrial user of POTWs to restore
the Congressional intent of encouraging dischargers of conventional pollutants to
use POTWs. These other methods could include suggestions for modifying the
existing operation and maintenance requirement.
E. We believe that the major reason Congress included ICR in PL 92-500
is that it did not want to subsidize industrial use of POTWs .
We believe that the report should point out more clearly that industry has
been and would be paying its fair share without ICR, as implied in the second
underscored statement on page 24.
II. Specific Comments
A. Recommendations
1. We support recommendation No. 1; however, we believe that the
discussion of C&L’s findings on the need for and the efficiency of ICR could be
improved by expanding the comments on page 27.
2. We believe that if the other three items are to be included in the
report that they should be placed at the end in an appendix. Also, we believe
these other three recommendations should not be listed as recommendations, but
as “Discussion Items for Congressional Consideration.”
B. Page-by-Page Comments
1. We believe that the third paragraph of page 2 would be improved if
the word “partly” is added between the words “and” and “relied”. The sentence
would then read “For that reason, the study team examined the intent of ICR, and
partly relied upon simulation to identify how industry should act rather than relying
solely on the data available at present.”
2. On page 3 of the C&L report the statement is made that : “ICR has
not served to control design and construction of excessive future capacity in waste-
water treatment facilities.” We agree with this statement. Our members’ experienc
conclude that excess or uncQxnmitted capacLty for industrial user of POTWs has been
limited by the grant review process, rather than by ICR.
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Mr. Ed Donahue 4 - December 6, 1978
3. On page 5, we recommend that the following be added to the last
sentence of the first paragraph: “; however, there have been localized effects due
to the combined impact of ICR, user charges, and local debt service.”
4. In the third paragraph on page 5, we believe that the social and
economic objectives referred to should be specified. This paragraph should also
specify which of the economic objectivqs were met and which social objectives
remain to be fulfilled.
5. At the end of the first paragraph on page 6, we suggest that the
sixteen alternatives that were presented for public comment be repeated for the
reader’s benefit.
Also on page 6, Recommendations 2, 3, and 4 should be removed from this
section and placed in an appendix. We note that the language in Recommendation
No. 2 is not the same as the language contained in Recommendation No. 2 on page 27.
6. On page 10, paragraph 2, it is stated that “possible alternatives to
ICR as it is presently constituted were formulated and presented for public discus sioz
and comment .” While it is true that the alternatives were presented, no significant
discussion of the alternatives was presented. Also, in-depth studies of each of the
alternatives were not undertaken by Coopers & Lybrand. This was not part of the
contractual basis for the study.
7. For purposes of clarity, the three issues addressed beginning on
page 14 and ending near the bottom of page 16 should have individual headings such
as No. 4 Parity; No. 2. POTW Capacity; No. 3. Water Conservation; and one that
is not discussed, No. 4. Funding of Future POTW Construction, should be added.
8. In the underscored portion near the top of page 14, we question the
use of the word t someu and suggest that the proper word should be “most”. As
modified, this sentence would read: “The analysis indicates that for most medium
or large industrial plants having compatible wastes it is least expensive in the long
run to self-treat than to pay user charges and local debt service. “ At least this is
true for seasonal food processing plants.
9. In the second sentence of the second paragraph on page 14, we
suggest the addition of the word “partly” between the words “based” and “on”. The
sentence as revised would read, “This is based partly on several tax changes that
were enacted after the passage of P. L. 92-500;”
10. In the underscored portion at the bottom of page 14, we believe that
the word “few” is inaccurate with respect to seasonal food processing plants.
Fully 60% of our members’ plants utilize self-treatment systems. While in total,
-------
Mr. Ed Donahue - 5 December 6, 1978
it may be true that most industrial plants utilize publicly owned treatment plants
for wastewater treatment, if possible, we would like to see this section modified
to reflect the significant use of self treatment systems by the seasonal food
processing industry.
11. At the end of the last paragraph of section a., concluding on
page 16, we recommend that the followi 1 ng sentence be added: “However, the
impact on POTW treatment capacity will be less than proportionate to the reduction
in water usage because to a large extent the same quantity of pollutants will be
discharged but in a more concentrated form.
12. In the underscored sentence at the top of page 17, we recommend
that the words “average” and “alone” be inserted so that the sentence reads as
follows: “The average economic impact of ICR alone to date is not significant,
in most areas.”
13. We recommend that the following be added at the end of the last
paragraph on page 17: “; however, there have been localized impacts due to the
combined effects of ICR, user charges, and capital requirements.”
14. We do not agree with the finding stated in response to (A) of
Congressman Roberts’ second question on page 20. We know from our own
experiences and are confident that the data in the wastewater treatment question-
naire returned by members of our industry and provided to Coopers & Lybrand
clearly demonstrate that the cost to industrial users of publicly owned treatment
works with established ICR and user charge programs are much higher than in
other communities within the same geographical area. Possibly, the term
“geographical area” has been misinterpreted. In our view, a geographical area
should encornpas the conti uou area in which the same commodity is processed.
For tomatoes in California, for example, this would include the central and inter-
coastal valleys. For corn and green beans, this would include the eographica1
area in which these commodities are processed in the mid-west. This would
include significant parts of Wisconsin, Minnesota and Illinois. Certainly, the
geographical area utilized to arrive at the finding should be identified. If our
definition of geographical area is adopted, certainly there are examples in the
data we have provided to show that some communities do indeed charge much higher
costs for wastewater treatment than other communities in the area. Accordingly,
disparities in wastewater treatment costs could affect employment opportunities
and economic development.
15. With respect to C&L’s response to Congressman Roberts’ question
No. 3 (page 21), we sugges tJiat C&L make a projection of how many plants are
likely to disengage from POTWs if ICR is retained. This informatLon would be
useful to the Congress in its future deliberations of the ICR requirement.
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Mr. Ed Donahue - 6 - December 6, 1978
16. In response to Congressman Roberts’ fourth question on page 21,
we recommend that the finding be modified as follows: “It appears that medium
or large sized industrial plants using a POTW ee 1d often pay more (over time)
for wastewater treatment than do direct dischargers depending in some cases on
the tax structure of the self-treatment alternative.”
17. With respect to Congr ssrnan Roberts’ question No. 5, page 21,
we recommend that the findings be modified as follows: “ICR appears to have a
role in encouraging conservation of water, but as an insignicicant conservation
factor to date, particularly relative to user charges, water costs and water
availability .
18. The second underscored statement on page 24 and the accompanying
analysis of it demonstrates that industry has not been receiving a tfree ride” in
POTW plant wastewater treatment costs. This fact should be emphasized in
support of Recommendation No. 1 on page 27.
We appreciate this opportunity to comment on the Draft Final Report and
urge your careful consideration of our comments on it.
Sincerely,
Jack L. Cooper
cc: Industrial Cost Recovery Subcommittee
a -
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AMERICAN FROZEN FOOD INSTITUTE
1700 OLD MEADOW ROAD. SUITE 100 McLEAN, VA 22102 70’) UI.07’ O
December 5, 1978
Mr. Ed Donahue III
Coopers & Lybrand
1800 M Street, N. W.
Washington, D. C. 20036
Dear Mr. Donahue:
The American Frozen Food Institute (AFFI) is the national trade
association representing processors of frozen food. AFFI members
process more than 90 percent of the frozen fruits and vegetables and
80 percent of the prepared frozen foods marketed in the United States.
On behalf of its members, the American Frozen Food Institute
would like to make the following comments regarding the Coopers &
Lybrarid study of industrial cost recovery (ICR) as mandated in the
Clean Water Act of 1977. -
AFFI would like to commend both EPA and its contractor, Coopers
& Lybrand, for a job well done. The data collected on ICR payments,
wastewater treatment costs and the economic impact of these costs is
the most complete information gathered on these issues to date.
We specifically would like to take issue, however, with the fact
that the ICR report not only makes a recommendation to abolish ICR,
but includes three other unsolicited recommendations. The Congressional
intent of the study was simply to determine the efficiency of and need
for ICR payments by the industrial users of municipal treatment works.
The real questions to be addressec by the study were whether or not ICR
was a reasonable means of repaying the Federal share of municipal treat-
ment works construction and its actual impact on industrial users accord-
ing to Congress.
Recommendation number one addresses these questions and is supported
by the report’s data and analysis. AFFI agrees with the recommendation
that ICR be eliminated.
We agree, also, that the problems of capacity, flow and funding
need to be addressed, but believe that the Coopers & Lybrand study does
not contain data pertinent to the recommendations made regarding these
issues. Recommendations two, three and four are not based on the find-
ings of the study. None of these recommendations resulted from the data
collected by the contractor and do not fulfill the requirements of the
ICR study as mandated by Congress.
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Mr. Ed Donahue III
Page 2
December 5, 1978
We would suggest that the draft report be rewritten before submission
to EPA to- -remove recommendations two, three and four.
Sincerely,
Hugh W. Symons
Research & Technical Services
HWS : j m
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AMSA
ASSOCIATION OF METROPOLITAN SEWERAGE
SUITE 200, lO 5 18th ST., N.W., WASHINGTON, D. C. 20036
AGENCIES
(202) 659-9161
MEMBER ACENC1ES.
Nulcipality if Auderege, Al
City if Tassel, AZ
C ciii , Saaitatlss Districts if
Oliegu Cou.ty, CA
East Bay Nualcupsi Utility Distrust, CA
City if Lie Angeles, CA
Coaty $aaitatlss Dust rusts ii
Lee Angeles Ceuety, CA
Sasra.suts Regioul Cou.ty
Sasitatiss District. CA
Cuts of Sscra.e.ts, CA
City if Si. Duege, CA
City of Sal Freucisse, CA
Vestere Regusual Cousty Salltatiei
District, CA
City if Sal Jose, CA
Metrepelitau O liver Sewese 015usd
Distrust N . I, CO
Tie Netrspslitas District (Naitf Sri
Ceusty), CT
Nieai.Deis Water all Sewer
Authority, FL
Oraigi Ceesty Sewer asd Wits,
Dipartme.t, FL
City if Tamas. FL
City of Atleata, GA
City if Honolulu, HI
City if Boise ID
The Nstrepehtai SauitiIy Dis Iet
if Greater Cilcegs, IL
City of WicAita, U
Louisville cud JeDerses Cii
Metripulltas Sewer District,
City ef Baltl•eru MD
Wuklagtes (D.C.) Subuitas 5su taiy
Cummlssuos, ND
Metrepellia. Oisthst Co..isslss
(Bastes), NA
Ss.ti Eases Sewerage Distrust, NA
Cua.ty of Wayae, NI
Notrepelutan Waste Csutrei
Commuss,ss, St. Paul, MN
Weateru Liii Superuer Sasitaly
District, 0.11th, NIl
City if Kansas City, NO
Netrepelita. St. Linus Sewer
District. MO
City of Omaha, NB
Sergei Csuaty Utilities Autiuruty, Ni
Nililuses Cuuely Sewerale
Authority, NJ
Passaic Valley Sewerage
Cummlssuosera, Ni
Aliauy Csusty Sewer District, NY
Ceusty if Meurse, NY
0 50.0.5. County, NY
City if New Yort, NY
City if Greeaaiore, NC
City of Same, ON
Metrupelita. Sewer District of Greats,
Cuscinusti, ON
Clevelial Rsgleual Sewer District, ON
City if CelueDus, OH
City of Dsytsu, ON
City of Touts ON
City of Psrtiauid OR
Ualtsl Sewerage Authority of
Wasimgtse duty OR
Aiisgheay Csuety euItasy
Aetiority, PA
City of Pilledsipila, PA
City of Nesivilie, TN
City of Daiise, TX
El Paso Water Utilities, TX
City if Forth Worth, TX
Gulf Cuast Waste Duipsisi
Antisrlty, TX
Trielty River Astherity, TX
City if Hositsu, TX
Hempta. Roads Sa .itatles
District. VA
Neaiclpaiity if Metroselltia
Seattle, WA
City if Yuceuua, WA
City if Ciariestes, WV
Buses Bsy Metrepsiltas Slaitssy
District M l
Mutrepeiitu Sewerage District situ
Ceasty if NiiweeUe, WI
December 6, 1978
Mr. Edward J. Donahue, III
ICR Study Director
Coopers & Lybrand
1800 iiMii Street, N.W.
Washington, D.C. 20036
Dear Mr. Donahue:
The AMSA staff has reviewed your draft executive report and has
discussed the results of your ICR Steering Committee meeting
of November 28th. With the staff comments contained in this
letter we are submitting the responses of those members from
which we have comments at this point. Together these documents
are the preliminary response of the Association of Metropolitan
Sewerage Agencies.
Our members have advised us that they agree with your first
reconiliendation: eliminate ICR. Most of them have long believed
that the ICR would not effectively realize the primary
legislative intent behind the program, equalizing sewage
treatment costs for direct and indirect industrial dischargers.
Your study reveals that this is the case. In fact, your
finding that ICR requirements may make it economically more
sensible to pull out of a municipal system and self-treat
is a strong argument that the program has had exactly the
opposite effect.
We are particularly gratified to find that your work supports
our contention that the question of equity is not a major
problem at all. More attention should be devoted to this
point in your final summary. It deserves more than a
parenthetical reference on page 3.
On page 5 of your sumary you refer to hlsocialu objectives
as part of the original, overall legislative intent behind
ICR. We assume this is a reference to those passages in
P.L. 92-500 and the legislative history supporting It which
are concerned with the political question of using tax
dollars to fund a ilfree ridei for indirect industrial
di schargers.
-------
Mr. Edward J. Donahue, III
December 6, 1978
Page 2
The appearance of using public money to subsidize industries
served by grant-funded POTWs could be a touchy political
issue....if there was a factual basis for the contention.
We believe there is not.
Would it not be simpler to m rshal the evidence in your study
to show that appearances are deceiving on this question and
that, in reality, the public need not be worried about a mis-
use of federal funds in this way?
Allaying such fears with a cogent set of facts and conclusions
is a much more effective way of dealing with the problem than
is proposing “alternatives’ to ICR. Why substitute something
else for the program, when the basis for the program is unfounded?
After all, the so-called indirect dischargers pay federal and
local taxes on the same basis as non-industrial users. EPA’s
pretreatment program is designed to bring the wastes discharged
by industries in line with non-industrial flows. Once this
occurs, industries will be getting the same service as non-
industrial customers and the question of a “free ride” will be
irrelevant.
In as far as the other three recommendations are concerned,
we believe our members will object to including them in the
final report. They address an entirely different issue.
We find nothing in the legislative record of either P.L. 95-217
or P.L. 92-500 charging the study with the task of suggesting
alternatives to the ICR concept as a method of growth control .
To think of ICR as primarily or even secondarily a growth
control mechanism is to confuse Congressional intent. ICR
was not designed to accomplish this end.
The question of urban growth and excess capacity is, of course,
one of legitimate concern to EPA, but ICR feasibility studies
are the wrong forum in which to deal with it. It is our opinion
that the questions of parity and capacity can best be dealt with
under other provisions in the acts, existing regulations for the
201 grant program, and the 208 planning process.
We do not favor a final report to EPA that includes your last
three recommendations. To confuse the issues of growth control
with user equity will muddle the basic message of your work.
S. -
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Mr. Edward J. Donahue, III
December 6, 1978
Page 3
We hope that you will seriously consider a single recomendation
In favor of eliminating ICR, together with strong arguments
for this action, when you make your final report to EPA.
xc eDiretor
RML:bel
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QL it of aU iitier, g I 1 u U
fl
SEWER COMMISSION I O j ?PJ 4L
ONEGOVERNMENTCEPimH MC.D ( ‘-
Room 308
Pec..ber 5, 3976 -i• I-kt./- -•r
Coopers ft Lybrand
1500 II. Street N.V.
Vastsington, D.C. 2003h
Attentions Sir. Edward J. Donahue., III
Dear Sir. Donahue;
Naturally 1 we are pleased to see that the eli iriatior’ of
the Industrial Cast I ecovery CICR} Provisions of P.L. 9 —5 C
is an integral aspect of the Coopers K Lybrand report re—•
cossendetions to the U.S. Environmental Protection Agency
LEPA}.
Mowever, this recom endatiar, ir c1Lcate5 that the IC
provisions of the Federal !later Pollution Control ct had
economic and social objectives which are assuu d to b stJ ll
valid, and which should be set. Said econoxjc r d sociaL
objectives should be clearly defined. The validity of such
objectives say be determined only if they are sLated., defined
and understood.
Recommendation •2 the intent of which is to encourage
more precise planning of wastevater treatment facilities.
certainly appears to address this problem. However,
hav, certain reservations concernin9 this recwimenda iorz.
?irst, this recommendation, especially in Fall ivar-,
• Ilassachusstts., re—opens an extremely controversi 3. i5sue;
• i.e. reserved,ar if you like, non—reserved Capacity. S e
feel this is a very sensitive area to be adoressed and
should be left elan..
Also, the existing law requires major industrial usors
C IDZ of facility capacity) to contractually coait for the capacit
reserved far the user in question. However, to require each
and every industry to contractually co mit for their capacity
presents sass problems.
1.11$ — —
-------
it d il cc, t rix Lt
SEWER COMMISSION
ONE GOVERN7 . ENT CENTER
Room 308
A very real problem wou.ld be the abilit.y of any iridu tr’y
to make a commitment for ’ a 2t1 yaar period. C risith rir ‘tics
stability of today’s economyw it is diTicult for iiu 1.ri€
to formulate definite plans far torwrro . T?,LS is sp cially
true in the older urban cities of the ?*Qrtheclst.
Also., this appears ta create further i intstrathic
for the grantee. In Fall River’s case, cont” cting ..iith
vet process industries would prove to be an r tiv
headache. This would cost the eiier Corac issiot’ a st rt I
amount of time arid money, which could be batter iri urinc-
the successful completion of the s ewati r trt r . r LtLt1
The report indicates that ICFC ha not rved to contr ai
design and construction of exce sive future cap icft ; tn wa ta—
water treatment facilities. Over -JEsi rz of faciliti CTU t
be controlled in a camprehensiv r anner. rw pl ; thc
burden on the industrial user so1e! ’ , cJr s p ’ of
poor zoning and planning in the resid r.tijjL and cc rrc rci i
sectors as veil. Proper plarrnin to n3ur {2L - . nrni—
excessive design must errcarpass all s# ctars of a c rzur ity.
Recomsendation •3 is a very sound conc pt dei r - c
insure the adequate collection arid nroper rqductior, &
debt service created by the wastet ater treat nt r c .1it1 5.
This concept also separates coLlection of the c!ebt stErvic
from the burden of the locial pr oprrty tax r2vcnu .;rc dac s
not allow for manipulation of the coI.l’!ctad funds. Funri
spelled—out and collected for a specific purpo;e iilL tcnd
to serve this purpose.
It should be noted., that the c I1 ctIMr at t w d i
service can be easily acccr pIished vL. t i user h r ;c
syste. the City eventually adoots, bu c writ.L,,cy tt is
another story. The collected oney tiould hA to c it r ’.
for and administered on a seperate basis. Thus . . tP d- iri .jtr—
ative tasks associated with uastevater treat rt pr’ ijc.ctsi
greatly expanded.
Another drawback to the ac1o ,tion of thL rec t t
legislation is thejederal gov2rn ent no C?Jr- iri tv d
in the financing of the local hare of the r i ct. 1
financing of the local share of a proj ct 7ir,uH ctrG1.
by the grantee not the federal gavcrn nt- t i .
make good senseto account for the coll ictLr c f ti
service seperate frao local propert:y t r . ‘c i .-
- — v/fr V .’
-------
QI tg of U
SEWLR COMMISSION
ONE GOVERNMENT CENTER
Room 308
Categorically, the esta 1jshi, rtt of trust furr1
distrusted by the general pub1ic . Trust funds ha r
tendency to breed nanipulatioi, and ger c ralLy thea int, nt
of the fund is not eat.
Trust funds are against the lE w in many st not th
least of which is flassacftusetts. Xinci’ uc tauld not be
dealing with federal funds, f daral l could not ups d
in this case.
If leplemented, this recor nd tiar i ould just bc’ cr t—
ing another fore of ICR, except the ch rg ¶. ou1d r. cnl1 :cL’ d
fro. all users. However, as far as in1ust ’y ts. corc a( a
fore of double taxation would still exi t.
Realizing that we are dealing with th issue orrrir3ustni l
Cost Recovery, it seeps the report goes to gr t 2 trcgt tc
bla.. industry for poor planning and CCS V€? dc sicr. Also,
th. report recoeeendatlans favor nt inirr so e f .”r of IC
in an atteept to control desi’rn nd cn tr :ri Gr ce iv
capacity. Surely, the failure of th IC r ision F.L.
12-500 to satisfy the intent is not 50121y . r rJ. ct n or in—
du try. To atteept to resolve these probl - .in oi c l
fashion would be a istake. They must be r ss .d in a co r- —
hensive, all-encoepassing oanner.
Finally we have the following co r ents or the i ody of
the report:
1. There are a nui ber of refer’ rces r-ad to t i ract
of industry using publlcly—ow: d atcr t nt
systees. Industry c rtairtly ouLcc con .‘Jor’er. tr
be a segment of the public. I y rrj d q -nti. l
support necessary to t ’ sconor-ic J!- Jth pr•’
•ent of any city by providing joois, rvjce- ic
sobs to the public. They also paid :;t aL
of .oney in taxes for the support ar cL devil.o nt of
city services.
2. The figures relating to i8Z 0 r -i c tt - or
227 facilities surveyed is not th.Lt cu i c,.
Considerin!p that are dealir q with a 2
design period. if the average Lift of t i ‘ ilitic
was in the range of 5 — r, yr r or co ic szu’-
the design criteria is in oo r ic’ Ic d r ori-
strate adequat2 ori r 1 of ; , ::c,-
-------
Qtit of dL iti.t; 1 et
SEWER COMr I5SION
ONE GOVERN?. ENT CENTER
Roe,, 30$
Unless eore data is prestented an cu t _ ccz i ”
can not be far u1ated.
3. Page 4 of the report conc rnir IC s ci tcc! wit t
secondary and advanced wa t tr at nt y t i’ i
not that clear. This sec .ton ct’ t?i rt,r t- .huutd
be expanded to better € cpIain the inter; .
4. References to U.C. ICR tatal co t, 1i 1 cost,
etc. shouLd be pore clearLy ri rinzd so t t t i€y i r
understood as seperat ent tt s
I
Please advise, If you have any uestion or d sir any
additional Inforeatlon.
Very truly yours.
flephen . Duckley
upervisihg Sanitary Engineer
Fall River Sewer Cc ission
SVB cn
cc John Gall. EPA
Jaseph S. Rego Sever egis .rar
a. -
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State oZ Vermont
AGENCY OF E XVI1(O’.ML TAL CO>EtRVA11u
MtmIp. ;rr, V rmtmL o ;e oz
DIVISION OFF. RQ T (, K I FJRt?
J
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nJis. ..s & cwd
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v a i%a1 Pr 4 evtic’n A :y
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l%e; Is’1u tiia1 (X’ t v ’ y $ u. V
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t i’iculd 1ke to of1 r th€ ro1i ricii- hr 1 cc’-r i,t .-ith - -t tc t).
Z La’ x’ o n t1c n.’ pjv n &vI th d cft r rt tv u P2i itt .: to c
in the lbvI bQr 29 ) tt r Dr r 7 . Pt tEr . cc.r,cur .-i.th tr r z1y
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rv VCz7 pZVVl8iOfl5 Of $‘.L. 9? ’,o1). O tr 1enc j -kdR i
oonclude there lii i1tt] b v f1t 1ned frtv this t io f t a;t ..r4
tt*t it er itea an i’ pedb t both to i 1u. 1ir. r - L- .- r- -: - t.c•
uu11d1T pollution control 1 fl t1 iv to th u c &rui tic cir
proJecta ,ddth treat both ndu tri 1 a dz v tic w v - u ‘çLii
effbrt should t v -uc. UCii f t.x 1 e 1 .ntz “ Sc
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c i
* * * * CAMDEN. NEW JERSEY 08101 * * * *
December 5, 1978
Mr. John Pai
Municipal Construction Division
US EPA
H 547
401 M St., S.W.
Washington, D.C. 20460
Dear John:
This is to confirm our telephone conversation.
I wanted you to know that the draft Industria l. Cost
Recovery Study only reached my office after your
meeting in Washington. This late delivery of mail
may be a problem on some of the comments.
On this whole project, I have been pleased
with the cooperation extended by you and members
of Coopers & Lybrand in reviewing the development
of information and having the opportunity to openly
discuss matters as the project progressed.
From all the information I have reviewed that
is part of the material provided to you plus my
participation in meetings and and hearings, I agree
with your recommendation one - eliminate ICR pro-
visions of PL 92-500. The second most important
thing, I believe, to come out of all of the data
provided, is that there is a great disparity in
user charges from community to community and that
if Congress does not desire that disparity to con-
tinue, legislation is necessary to modify the
present regulations. It would appear that the
simplest means of reducing this disparity when a
community desires to do so, would be for Congress
to permit communities greater flexibility in de-
veloping user ch xges.
The major portion of the data supplied deals
with user charges, and therefore the final report
should discuss user charges in greater depth and
the fact that just elimination of ICR will not
eliminate disparity in total sewage charges nor
necessarily encourage joint treatment which were
the intent of Congress.
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Mr. John Pai Page 2
I urge that the final draft report have as its
key recommendation the elimination of Industrial Cost
Recovery as is already indicated and secondly, that
alterations be provided in the user charges to further
permit communities a reduction in disparity of costs.
The existing draft report places three recom-
mendations on Page 6 on a equal priority basis as
the first recommendation to eliminate ICR. I appre-
ciate that it should be the Contractor’s prerogative
and also EPA’s prerogative to make further recoumienda-
tions, however, such recommendations should not
receive the priority rating given in the draft’s final
report. Therefore, it would be most desirable to
discuss this type of matter in some other section of
the report.
Very truly yours,
L. C. Cilde
Director-Environmental Programs
LCG: bmn
cc - Mr. E. Donahue
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THE PENJERDEL CORPORATION
The fRI-STATE ASSOCIATION OF BUSINSSS. INDUSTRY & PROFESSIONS SERVING ThE DELAWARE VALLEY
OUR BUSINESS IS
THE DELAWARE VALLEY
Dec nber 5, 1978
Mr. Edward Donahue
Coopers & Lybrand
1800 N Street, N.W.
Washington, D.C. 20036
Dear Mr. Donahue:
I wish to offer oanrnents on the INDLETRIAL COST RECOVERY, DRAFT FTh L PEPO1 P,
EXECXYI’IVE SUMMARY, dated Nov inber 22nd, 1978, and prepared by Coopers &
Lybrand.
The vironnental Imprcwanent Ccmnittee (EIC) of the PE EI )EL Corporation
consists of men having environnental control responsibilities in sane 45
plants and corporate headquarters in the tn-state Delaware Valley Region.
(The PEMJE1 )EL Corporation itself has, with its sister organization the
Greater Philadelphia C iamber of Catinerce, sane 2,441 mEnbers thith are
industrial and a]iinercial installations in the Delaware Valley Region and
within Philadelphia.)
Concerning the referenced cecutive Suminazy (and the Oct. 20th public meeting
held at the Benjamin Franklin Hotel in Philadelphia, tith six EIC menbers
attended), I uld LiJce to offer the following catiments:
1. The EPA contractor, Coopers & Lybrand, is to be congratulated for
having developed an cceptionally well-thonght-out plan of study and
for having cecuted it in the short time allowed to than.
2. We agree, fran the infonnation at hand, that ICR is not doing at it
was originally intended to do, and will not acocauplish it.
3. We do not sense fran the cecutive Sununazy that all the data does, in
fact, point to the three recatsnendations 2, 3, and 4 made in the Suninazy
by Coopers & Lybrand and ich are, in effect, designated as “must”
itans (pp. 27—28).
a. -
Suite 1960 1617 John F. Kennedy Boulevard Philadelphia, Pennsylvania 19103 (215) 568-4040
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Decenber 5, 1978
Page2 --
4. Thus the final three recatinendations should be listed in the text
merely as other things that might be considered should there be a
desire on the part of congress to do sanething other than merely
cancel ICR.
5. Fran sentiments expressed at the Oct. 20th public hearing, uld
believe there should be nore attention paid to User Charges and the
necessity of having User Charges with greater local discretion and
flexibility. Central (EPA) establishnent of rigid and unifonn
systans of applying User Charges uld have severe restrictive
drawbacks for municipalities having their n planning thjectives
whith may differ widely fran the thjectives of other municipalities.
To impose any rigid or uniform pattern upon than uld rth than of
freedan of action and fr 1nn to plan.
Sincerely,yours,
Jay Wei 1man, Vice Chairman (WATER) SubCanmitte’
JW/&&n Envirorniental Improvanent Catmiittee
cc: John Pai, EPA
a. -
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EXHIBIT V—i—li
SUMMARY OF PO IW (X)STS
TREAIMENT LEVEL OF PON
(All Data are Averages) Secondary Advanced Tertiary
Design Flow (MGD) 514 59 55
BOD (lbs/day) 102,14149 1114,908 113,2814
SS (lbs/day) 120,021 130,6142 98,1400
% of design capacity used 68 75 73
Average Total Cost
($1,000) 67,950 72,769 89,614
Cost per {D ($1,000)
of design flow 1,241 1,287 1,628
Revenue Before ($1,000) 3,9714 5,1488 7,139
Revenue After ($1,000) 5,623 7,978 10,157
% increase (decrease) 142 146 142
O & M Before ($1,000) 2,3514 3,062 14,682
0 & M After ($1,000) 3,1499 5,104 6,652
% increase (decrease) 49 67 42
0 & M Cost per MGD
(Design) 614 90 714
0 & M Cost per MGD
(Actual Use) 94 132 102
Debt Before.($1,000) 1,101 1,551 1,912
Debt After ($1,000) 1,161 2,2014 2,386
% increase (decrease) 6 42 25
Debt Cost per MGD (Design) 21 39 27
Debt Cost per MGD (Actual
Use) 31 57 37
Other Costs Before ($1,000) 389 353 592
Other Costs After ($1,000) 488 358 599
% increase 26 1 1
Other Cost per MGD (Design) 9 6 7
Other Cost per MOD (Actual
Use) 13 9 9
Average Total Cost 5,1148 7,666 9,637
a. -
NOTE: This data is based on data supplied to Coopers & Lybrand by grantees.
Coopers & Lybrand has not audited the financial or statistical data
provided us, and has relied on the accuracy of the data provided to us
in mald.ng the calculations used to produce the statistics shown
above.. Since not all supplied all the requested data, the statistics
produced must be used with caution. (Based on grantees providing both
before and after responses).
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