In order to establish the cost of a future stormwater program, it is necessary to determine the Level of Service (LOS) currently provided balanced with what level is desired. The current LOS in Bristol is considered minimal and not adequate, and is largely reactionary and dependent on the amount of funding that can be secured in any one year and occasional voter-approved special bond referenda. The table below outlines a future stormwater program based on an increase in the annual appropriations derived from the new funding source to allow more than a minimal LOS to be provided. A larger budget for infrastructure and flood protection will allow the Town to improve long-range planning for capital improvement projects without having to compete against other Town initiatives for funding.
Future Stormwater Program Costs
Anticipated Phase II MS4 Permit Costs
RIDEM has been awaiting the issuance of a revised permit by Region One EPA before issuing a new permit (last updated in 2008). EPA has recently issued a new MS4 General Permit to some 260 municipalities in Massachusetts which also serves as a useful guide to the likely requirements that will be contained in RIDEM’s new permit. Based on a summary provided by EPA and Massachusetts Department of Environmental Protection, the following are some of the highlights:
Six Minimum Measures
· MS4 operators must provide a minimum of two messages to four specific audiences (residents, businesses, developers, industries) during the permit term for outreach.
· Stormwater management plans and reports must be shared with the public.
· More specific actions to address illicit discharge detection and elimination, but 10-year time frame allowed.
· Construction site control requirements expanded (Bristol may already comply with most).
· Post construction controls enhanced (Bristol may already comply with most).
· Added requirements for DPW Operation and Maintenance as well as Pollution Prevention Plans.
Water Quality Based Requirements
· More prescriptive actions required to address impaired waters including those without a completed TMDL.
Surely, if Rhode Island adopted these requirements, costs will increase. To determine actual costs under a Rhode Island permit, more analysis will be required once a Rhode Island specific permit is drafted by RIDEM taking into account the response to the range of impairments anticipated in Bristol and other MS4s.