Updated Cost Analysis For Compliance With Draft 2013 Industrial General Permit

Written By: Caltha LLP | Published On: 12th September 2013 | Category: Stormwater, Water | RSS Feed

The California State Water Board staff has released an updated analysis of the compliance costs for the proposed Industrial General Permit (2013 Final Draft IGP) This updates the prior analysis released in 2012.

To conduct the 2013 cost update facilities were categorized with corresponding assumed probabilities of Numeric Action Level (NAL) exceedances. The cost analysis was based on the assumptions that 70 % of all industrial facilities will remain in Baseline status (i.e., no exceedances) for the 5-year permit term of the 2013 Final Draft IGP, 20 % will have Level 1 NAL exceedances only, and an additional 10 % will have both Level 1 and Level 2 NAL exceedances. The State Board summarized their findings as follows:

  • The average cost per facility to comply with the existing 1997 IGP is estimated to be approximately $32,700 per year or $162,500 over a five year period.
  •  The 2013 Final Draft IGP will increase costs for a facility
    • without numeric action level (NAL) exceedances (Baseline or Level 0 status) by 13%
    • with NAL exceedances in one year (Level 1 status) by 17%, and
    • with exceedances in two years (Level 2 status) by 33%.
  • The additional costs for 70 % of facilities to comply with the 2013 Final Draft IGP, in addition to the current cost to comply with the existing 1997 IGP, will be approximately $4,500 more per year.

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