Draft Financial Capability Assessment Guidance for the Nutrient General Permit

Submitted By

12 Results

Search Type

Sort:

Sort Results By

Comment From: Alderwood Water & Wastewater D... (Josiah Hartom)

8/14/24 @ 5:30 PM

Attachments:

Download

Comment From: Bob (Bob Danson)

8/14/24 @ 4:57 PM

Olympic View Water & Sewer District's Concerns Regarding the Department of Ecology's Financial Capability Assessment Guidance

Olympic View Water & Sewer District has significant concerns regarding the Department of Ecology's Draft Financial Capabili...↓ty Assessment (FCA) Guidance. As a sewer utility, we believe that the guidance, as it currently stands, does not fully capture the complexity of financial challenges faced by utilities like ours. The narrow focus on present conditions, without a broader consideration of ongoing operational costs and future capital needs, could lead to decisions that do not adequately account for the long-term financial sustainability of our operations.

We are particularly concerned about the reliance on income level as a primary indicator of a community's ability to shoulder additional financial burdens. While income is undoubtedly an important factor, it alone does not provide a complete picture of a community's financial capacity. In today's economic environment, even middle-income households are finding it increasingly difficult to manage basic living expenses. Therefore, using income level as the main criterion for determining financial capability risks overlooking the real financial pressures faced by many of our ratepayers, leading to decisions that could impose unsustainable cost burdens on our community.

As a utility that relies on treatment facilities managed by external entities, we are also concerned about the potential disconnect between those making financial decisions and the realities faced by our ratepayers. Our community could be subjected to significant cost increases determined by an agency that lacks a deep understanding of our specific system and future needs. This separation could result in financial assessments that do not accurately reflect the unique circumstances of our service area, potentially leading to unjust and disproportionate financial burdens.

To better serve our community, we believe it is crucial that the financial assessment process takes into account a wider range of factors beyond income level. This includes considering the overall economic pressures on households, the specific financial challenges faced by different segments of the population, the unique challenges of individual utilities, and the long-term sustainability of proposed financial burdens. Such a comprehensive approach would provide a more accurate reflection of our community's ability to absorb additional costs and would help ensure that decisions are made with a full understanding of their potential impact.

Furthermore, the stringent nutrient removal requirements, such as the mandate to achieve a Total Inorganic Nitrogen (TIN) limit of 3 mg/L under the Puget Sound Nutrient General Permit, present additional challenges. These requirements do not consider the varying capabilities of different treatment facilities, or the potential environmental trade-offs involved in achieving such aggressive standards. The significant capital and operational costs associated with meeting these requirements could place an undue financial burden on our community, especially considering that a substantial portion of our wastewater treatment is managed by a facility over which we have limited control.

In conclusion, we strongly urge the Department of Ecology to adopt a more flexible and comprehensive approach to the financial capability assessment process. This approach should consider a broader range of economic factors and should be tailored to reflect the specific circumstances and needs of different communities. By doing so, we can ensure that the Nutrient Permit requirements are both environmentally effective and financially manageable for all communities, including those served by Olympic View Water & Sewer District.

Best Regards,

Bob Danson, General Manager

No attachments

Comment From: City of Tacoma Environmental S... (Teresa Peterson)

8/14/24 @ 4:50 PM

Please find attached the City of Tacoma Environmental Services comments.

Attachments:

Download

Comment From: City of Bremerton (William Davis)

8/14/24 @ 4:13 PM

The City of Bremerton supports Ecology's efforts to assess the financial impacts of the Puget Sound Nutrient General Permit and to provide guidelines for the analysis. The City believes that the financial assessment should reflect the potential finan...↓cial impacts on our most vulnerable community members through direct measures that consider all of the City's compliance obligations, as well as our need to maintain infrastructure assets to sustain the expected level of service into the future. For these reasons, the City has reviewed Ecology's Draft Financial Capability Assessment (FCA) Guidance document and is providing comments here with the intent to improve Ecology's approach to the assessment.

1) Attainable Implementation Schedules: There appears to be a disconnect between Ecology's Draft FCA Guidance and Puget Sound Nutrient General Permit (PSNGP) with respect to schedule and the establishment of economically feasible implementation timelines.

The Draft FCA guidance states: "We also emphasize that results, for purpose of the Nutrient Permit, are not intended for schedule negotiation." (Ecology 2024, p. 15).

Ecology's approach seems to contradict the clear direction in the Puget Sound Nutrient General Permit (PSNGP) that explicitly calls for the AKART analysis to address an attainable implementation schedule:
"Section S6.C. AKART ANALYIS Subpart f. Attainable implementation schedule that includes funding, design and construction of infrastructure improvement capable of achieving and maintaining AKART." (Ecology 2021)

2) Affordability and Insensitivity of Ecology's FCA Spreadsheet Tool: A test application of Ecology's spreadsheet FCA tool using realistic entries for baseline capital improvement plans without nutrient removal and representative upgrades for nutrient removal at significantly greater cost reveals a surprising lack of sensitivity to the magnitude of project costs. This baseline scenario received a ranking of "Low Impact" in the final FCA matrix assessment. In a sensitivity analysis, the project costs needed to be increased to extraordinarily high levels to even trigger a shift from "Low Impact" to a "Medium Impact" assessment in the FCA matrix. It is concerning that doubling the annual debt service and O&M expenses would result in only a "Medium Impact" since it would likely double rates. This is a particular concern considering the demographics of Bremerton since our median household income is only 75% of the state as a whole, and our poverty rate is 40% higher than the state as a whole (reference US Census data at https://www.census.gov/quickfacts/fact/table/bremertoncitywashington/IPE120222#IPE120222, and https://data.census.gov/profile/Washington?g=040XX00US53#income-and-poverty). This suggests that the formulation of Ecology's FCA tool may not be sensitive enough to reflect the severity of the financial impact of a doubling of costs.

No attachments

Comment From: King County Wastewater Treatme... (Jacque Klug)

8/14/24 @ 3:57 PM

Attachments:

Download

Comment From: King County Wastewater Treatme... (Jacque Klug)

8/14/24 @ 3:50 PM

Attachments:

Download

Comment From: Bob Jacobs

8/14/24 @ 3:17 PM

It is unclear to me how this process works.

If a community is not reasonably able to pay its fair share of the investment needed to protect Puget Sound, then what happens?

If more wealthy communities have their requirements increased to make up t...↓

No attachments

Comment From: King County Wastewater Treatme... (Jacque Klug)

8/14/24 @ 2:59 PM

Attachments:

Download

Comment From: City of Everett Public Works (Jeff Marrs)

8/14/24 @ 2:31 PM

Attachments:

Download

Comment From: Association of Washington Citi... (Carl Schroeder)

8/08/24 @ 2:04 PM

Please clarify that use of Ecology's spreadsheet tool is recommended but not required under the PSGNP.

Ecology's guidance and spreadsheet tool relies on EPA's Alternative 1 yet Alternative 2 provides a more accurate financial picture, year-over-yea...↓

No attachments

Comment From: Laurie Pierce

8/05/24 @ 7:25 AM

Attachments:

Download

Comment From: Bryce Figdore

7/08/24 @ 12:06 PM

Can the comment period be extended to August 9th or later to allow sufficient time for attending and digesting information presented at the July 24th workshop. The current schedule does not allow much time for attending the workshop and careful consi...↓

No attachments