AgdaPkt 2002-09-23 - Laserfiche WebLink

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September 17, 2002 Mr. Arthur Baggett, Chair State Water Resources Control Board 1101 'T' Street Sacramento, CA 95814 Re: Proposed Revisions to the State Water Resources Board's Annual Fee Schedule Dear Chairman Baggett, On behalf of the twenty one municipalities which comprise the San Mateo Countywide Stormwater Pollution Prevention Program (STOPPP), thank you for the opportunity to comment on the proposed revisions to the State Water Resources Control Board's Annual Fee Schedule. STOPPP has been in existence since 1993 and we are mid term of our second five year NPDES Permit. A stormwater fee collected on the County property tax bill funds our Program. Our NPDES budget was adopted in May 2002, our fees were adopted July 2002 to support the Program and we are beyond the deadline to change the fees for this fiscal year, even if we had the legal ability to do so. Under the proposed Revisions, the impact on STOPPP would be an increase from the current $10,000 to a proposed $143,500, a $133,500 increase. This represents approximately 10% of our NPDES Budget. Since we cannot increase our revenue, we must consider reducing our effort to comply with our current Permit requirements. We feel the impact statewide of the proposed revisions will have a negative impact on the very program you are promoting. The State Water Quality Task Force sent you a letter dated September 16, 2002, that represents our views on this subject, so I will not repeat them in detail and I commend that letter to you for careful consideration. in brief, our issues are as follows: · . Legal/Policy Issues Adequate time has not been given for a proper review of the proposal The State Board has not provided adequate findings to support the new fees. Municipalities have completed their budget approval process for this fiscal year. We question the legal authority to establish new fees on co-Permittees. AB3000 makes no mention of fees to co-Permittees. We do not oppose a reasonable increase in fees to the Stormwater Programs. We do oppose the establishment of new fees on co-Permittees without a thorough review of the impacts of such a proposal.