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HomeMy WebLinkAbout05/21/1991, 3 - ESTABLISHMENT OF INDUSTRIAL USERS PERMIT FEES FOR THOSE INDUSTRIAL USERS DISCHARGING TO THE CITY'S WASTEWATER SYSTEM. Ill�lylll�IIIIInIIII�=Ilullll MEETING DATE: '°I II _Ilul C�Ty of san Lws oBispo May 21 1991. COUNCIL AGENDA REPORT ITEM NUMBER: FROM: William T. Hetland . , Prepared By: John E. Moss Utilities Director Wastewater Division Manag SUBJECT: Establishment of Industrial Users Permit Fees for Tho e Industrial Users Discharging to the City's Wastewater System. CAO RECOMMENDATION: By motion, adopt a resolution setting Industrial Users Permit Fees for discharge to the City's Wastewater System which includes the following: 1. Significant and Categorical Users Annual Permit Fees . . . . . . . . . . . . . . . . . . . . $ 680.00 2. Class 1 Users Annual Permit Fees . . . . . . $ 210.00 3. Class 2 Users Annual Permit Fees . . . . . . $ 64 .00 4. Monthly Compliance Monitoring, sampling and Follow-up Inspections for Noncompliance/Violations to be billed at the hourly rates established in the Public Works Department "Labor and Equipment Rates" document. 5. Annual permit fees to become effective and due July 1, 1991 with the proportionate amount included with the City's bi-monthly utility billing. REPORT IN BRIEF In 1982 the City established a federally mandated pretreatment program for monitoring and control of industrial users discharging waste to the City's wastewater collection and treatment systems. Based on Council direction, staff has developed a system of industrial user permit fees designed to recover only that portion of the program costs directly related to industrial user monitoring and inspection. This fee program is based on the average inspection time required per class of industry, the minimum number of monitoring events (inspections and sampling) required to insure industry compliance with Local, State and Federal regulations, and 35% of the program cost being directly related to inspection and monitoring activities. . The proposed fees are detailed above in the recommendation. 3 - I ���n���N►I�IIIII�IIINII�I11 city of sa►n Luis oBispo am-MM i-42 COUNCIL AGENDA REPORT Industrial User Permit Fees 2 Meeting of May 7, ' 1991 The pretreatment program is currently being funded through the sewer fund. Estimated annual cost of the program, including direct and indirect costs, is $136, 000. Council direction is to fund only that portion of the program related to industrial user inspection activities through a system of user fees. The inspection portion of the program has been determined to account for 35% of the total program time and cost ($47,556) . Council has previously approved an upgrade of the pretreatment program contingent upon establishment of industrial user fees. The previously approved program upgrade is essential in meeting State and Federal requirements for the program as well as insuring maximum potential for reclamation of wastewater effluent and sludge (see page A-25 of Appendix A. 1989-91 Financial Plan Supplement) . The costs associated with the program upgrade have been included in the proposed fee structure. The proposed fee program would result in an increase in revenue of approximately $47,500. Staff has presented the revised fee program to those industrial users responding to the earlier proposed program in a letter mailed April 10, 1991. Only one telephone response was received. This response was from Higuera Autobody and they felt the revised fee program was reasonable. A comparison of the proposed fee program with that of other cities shows these fees to be in the low mid-range of other city's industrial user permit fees. The proposed fee program does not affect the retail/commercial and non-industrial businesses within the City. The alternative to establishing the proposed fee program would be to continue to fund the entire program through the sewer fund. This would continue to place the burden for funding the program on the non-industrial users in the City and would not provide a funding mechanism for the required program upgrade. DISCUSSION: BACKGROUND In 1982 the City established a Pretreatment Program for monitoring and control of industrial users discharging waste to the City's wastewater collection and treatment system. The City's Pretreatment Program is a federally mandated program under the provisions of the Clean Water Act and is currently being regulated by the Environmental Protection Agency (EPA) and the California Regional Water Quality Control Board (RWQCB) . The City is required under Federal regulation (40 CFR 403.8 (f.) (3) ] to provide adequate resources (funding and personnel) to carry out the requirements of the program as identified in 40 CFR 403 . 3 � � �,►�i�i►�Illll�lllf � 11 city of San a..Ais osispo MIN COUNCIL AGENDA REPORT Industrial User Permit Fees 3 Meeting of May 7, 1991 The objectives of the Pretreatment Program, as defined under 40 CFR 403.2, are to monitor and control industrial discharges to Publicly Owned Treatment Works (POTWs) to: (a) Prevent the introduction of pollutants into POTWs which will interfere with the operation of the �POTW, including interference with its use or disposal of municipal sludge; (b) Prevent the introduction of pollutants into POTWs which will pass through the treatment works or otherwise be incompatible with such works; and (c) Improve opportunities to recycle and reclaim municipal and industrial wastewaters and .sludges. Staff had originally developed a system of Industrial Users Permit Fees which would fully cover the cost of the City's Pretreatment Program. This recommendation was brought to' Council on February 5, 1991. Council denied staff's recommendation to fund the entire program through a system of permit fees and directed staff to return with a fee program which reflected only the inspection portion of the program directly attributable to the industrial users. Current Fundinc Since 1982 the City has funded it's Pretreatment Program through the Sewer Fund. The sewer fund is an enterprise fund consisting of rates and fees sufficient to fully cover the direct and indirect costs of the wastewater programs. Initially the Pretreatment Program was included as part of the Wastewater Treatment Program and was operated out of the Wastewater Treatment Budget. In the 1989-91 Financial Plan and Approved 1989-90 Budget, the Pretreatment Program was separated from Wastewater Treatment and its own budget identified and established (Pg. D-31, 1989-91 Financial Plan and Approved 1989- 90 Budget) . This was done to more accurately identify the required resources of the Pretreatment Program and provide a basis for establishing Industrial Users Fees. The need to establish Industrial User Fees was identified in the 1989-91 Financial Plan (Supporting Documentation pg. C-19 (a) ] . Proposed Fundinct The City currently has 328 total permitted industries made up of significant and federal categorical industries such as metal plating shops and printed circuit board manufacturers, class 1 industries such as service stations, dry cleaners and photo finishing shops, and class 2 industries which are primarily restaurants. The classification applied to individual industries ��IN@�N►��IIIIp�P° �11 CTCy Of San ItAIS OBISPO malbmm COUNCIL AGENDA REPORT Industrial User Permit Fees . 4 Meeting of May 7, - 1991 is primarily based on their potential to cause interference or pass-through. Those types of industries under the federal categorical industry classification have been identified by the EPA and are governed not only by local discharge limits, but by federal categorical pretreatment standards as well. Based on Council direction, staff has developed a system of Industrial User Permit Fees based on the cost of inspection related activities directly attributable to the industrial users. Inspection related activities are determined by the amount and type of monitoring and inspection required to insure industry compliance with Federal, State and Local discharge limits. The amount of required monitoring is governed by the classification of the industry and its potential to interfere with the operation of the POTW. Because of their potential to interfere with the POTW, significant and federal categorical industries require a minimum monitoring frequency of 4 times per year, class 1 industries - 2 times per year, and class 2 industries - 1 time per year. In order to provide equitable distribution of the fees, staff has developed a fee program which incorporates not only the frequency of inspection per class of user, but also the average time spent performing the inspection and related activities per class of user. From this, staff has determined that approximately 35% of the program operation can be directly attributed to industrial user inspection related activities. Therefore, as. per Council direction, this fee program is based on a cost recovery of only 35% of the total program cost. In order to standardize the time factor in determining the appropriate permit fees, staff developed a Minimum Inspection Time (MIT) equivalent factor. One (1) MIT is equal to the average time spent on inspection and related activities for the lowest class (2) of user. Staff then determined the total number of program MIT equivalents per year and divided this into the program cost to achieve a $/MIT figure. This $/MIT figure is multiplied by the MIT equivalents and number of required inspections for each class of user to determine the appropriate permit fee. By basing the permit fees on the minimum number of monitoring events required per year and the time equivalents required for monitoring each class of user, the rates will most accurately reflect the demands placed .on the Pretreatment Program by each industrial user classification. A detailed breakdown of the derivation of the Permit Fees is provided 'in Table 1. 01►11IIIII1IIP01°9�U�U city of san L.4Is osispo Al COUNCIL AGENDA REPORT Industrial User Permit Fees 5 Meeting of May 7, 1991 TABLE 1 1991-92 Pretreatment Program Budget. . . . . . . . . $108,700 Inspection = 35% of program total . . . . . . . . . . $ 38,045 Overhead = 25% additional . . S 9 .511 TOTAL INSPECTION RELATEDCOST . . . . . . . . . . . . $ 47,556 Minimum Inspection Time (1.5 hrs) = 1 MIT MIT Equivalents for User Classifications Class 2 - 1.5 hrs/inspection = 1 MIT Class 1 - 2.5 hrs/inspection = 1.66 MIT Sig/Cat - 4 hrs/inspection = 2. 66 MIT Total Program MIT's = # in class. * MIT * insp./yr. Class 2 = 164 * 1 * 1 = 164 Class 1 = 160 * 1.66 * 2 = 531 Sia/Cat = 4 * 2.66 * 4 = 43 TOTAL PROGRAM MIT's /yr. = 738 Program Cost / MIT = $47,556 / 738 = $64. 00 / MIT Annual Permit Fee = # Insp. /yr. * MIT * $/MIT Class 2 = 1 * 1 * 64 = $ 64.00/yr. ($ 64. 00) Class 1 = 2 * 1.66 * 64 = $212 .00/yr. ($210.00) Sig/Cat = 4 * 2.66 * 64 = $681. 00/yr. ($680.00) In determining the MIT equivalents for each class of industry, staff first identified all inspection related activities that must be performed with each inspection. Based on past experience in performing these activities, an average inspection time was established. The average inspection time per class of industry and inspection related activities are identified in Table 2. 3 .� �►��►�� ��IIIlI��p��u����llll city Of San WI s OBISPO i COUNCIL AGENDA REPORT Industrial User Permit Fees 6 ,.Meeting of May 7, 1991 Table 2 Class 2 Users - (average inspection time = 1.5 hrs) Inspection related activities: File review. Travel time. Introduction. Inspection of grease trap. Issuance of receipt to manager. Review and update of file after inspection. Database update. Refile. Class 1 Users - (average inspection time = 2.5 hrs) Inspection related activities: File review. Report preparation. Travel time. Introduction. Inspection of facility. Inspection of receipts, manifests and permits. Complete report. Report review. File review and update. Database update. Refile. Significant/Categorical Users -(average inspection time = 4 hrs) Inspection related activities: File review. (previous inspections and required documents) Permit review. Discharge concentration data review. Report preparation. Travel time. Introduction. Inspection of facility. Inspection of waste and materials storage. Inspection of receipts, manifests and permits with mgr. Complete report. Report review. File review and update. Database update. Refile. �u i�i��Illll�flpaN►ui���N city of san L.AS oBispo COUNCIL AGENDA REPORT Industrial User Permit Fees 7 Meeting of May 7, 1991 In addition, staff is recommending establishing a system of fees for monthly compliance monitoring and sampling, and follow-up monitoring and inspection resulting from industry non-compliance. These fees will be based on the hourly rate established in the Public Works Department Labor and Equipment Rates document dated January 1990. The current labor rate for the Industrial Waste Inspector is $35.65 per hour. These fees will be billed through use of the Public Works Billing Statement. Assessment of additional inspection fees resulting from non-compliance will provide additional incentive for compliance as well as insure equitable distribution of program costs to those industrial users - placing the most demand on the program resources. Comparison With other Cities Staff has investigated the industrial user fee programs for other cities and has found them to be greatly variable. Fees were found to range from $25.00 per permit for all industries regardless of classification, to $3, 000 for significant and categorical industries. There was also some indication that industrial users fees were often an indication of local policy towards industrial growth. That is, low fees to encourage industrial growth and high fees to discourage industrial growth. The fees being recommended at this time fall in the low-mid range of those surveyed. Citizen Participation In order to evaluate industry response to the proposed fees, letters were mailed to those industrial users who responded to the previously proposed fee program which was presented to Council on February 5, 1991. The letters identified the basis of the proposed fee program, the proposed fees, and requested their response. Only one telephone response was received from this mailing. The response was received from Higuera Autobody and they felt the revised fee program was reasonable. A separate mailing has also been completed notifying all currently permitted industrial users of the public hearing and presenting the proposed fees and the basis of the program. Although staff received only one comment on the first mailing, Council may anticipate some additional response at the public hearing. A copy of the letters mailed are attached. Staff had met with the Chamber of Commerce to discuss the previously proposed fee program. At that time, the Chamber understood the need for the pretreatment program and felt the basis of the previously proposed fees was reasonable, however, were reluctant to either support or oppose the fee program. 3 - 7 „H�►����IIIII�p� u� �N city of san Luis oBl spo NMI COUNCIL AGENDA REPORT Industrial User Permit Fees 8 Meeting of May 7, 1991 CONCURRENCES The City Finance department has reviewed the recommended fee program and concurs with the recommendations herein. In addition, staff has discussed the basis of the proposed fee program with the State Water Resources Control Board and they concur with the fees being based on inspection frequency. FISCAL IMPACT The recommended fee program will result in an increase in revenue of approximately $47,500 to the sewer fund. This increase in revenue reflects the cost of operation of the inspection portion of the City's Pretreatment Program. It is recommended that the fees be reviewed and adjusted annually if necessary to reflect any increase or decrease in cost of the inspection program. ALTERNATIVES 1. Take no action and continue to fund the Pretreatment Program through the current system of sewer rates. This option does not place the cost of that portion of the program directly attributable to industrial users on those users and places an additional burden on the non-industrial users. The demands on the pretreatment program will continue to grow and as such, so will the cost for operation of the program. On June 12, 1990 Council approved an upgrade of the Pretreatment Program contingent upon establishment of industrial user permit fees. Previously established goals for the program will not be achieved if the permit fees are not established. This will result in the City not achieving compliance with the requirements for the pretreatment program as set by the State and Federal regulatory agencies and may result in not achieving compliance with the wastewater discharge requirements as a result of inadequate pretreatment program enforcement. This alternative is not recommended. RECOMMENDATION By motion, adopt a resolution setting Industrial Users Permit Fees for discharge to the City's Wastewater System which includes the following: 1. Significant and Categorical Users Annual Permit Fees . . . . . . . . . . . . . . . . . . .$ 680. 00 2. Class 1 Users Annual Permit Fees . . . . . $ 210. 00 . 3'8 �►►►► IIIUIIIIIIIIIPI��u�I���h city of san L,Ais o$1spo = COUNCIL ^GENOA REPORT . Industrial User Permit Fees 9 Meeting of May 7, 1991 3. Class 2 Users Annual Permit Fees . . . . .$ 64.00 4. Monthly Compliance Monitoring, Sampling and Follow-up Inspections for Noncompliance/Violations to be billed at the hourly rates established in the Public Woks Department "Labor and Equipment Rates" document. 5. Annual permit fees to become effective and due July 1, 1991 with the proportionate amount included with the City's bi-monthly utility billing. Attachments: Resolution Letters to Industrial Users RESOLUTION NO. (1991 Series) ESTABLISHMENT OF PERMIT FEES FOR INDUSTRIAL USERS OF THE CITY WASTEWATER COLLECTION AND TREATMENT SYSTEMS WHEREAS, the Environmental Protection Agency (EPA) and the State of California, Regional Water Quality Control Board (RWQCB) require the City to establish and operate an Industrial Pretreatment Program to control and monitor industrial discharge to the City's wastewater treatment systems, and WHEREAS, the City has established a pretreatment program that complies with the State and Federal requirements as defined in Part 403 of the Code of Federal Regulations(CFR) , and WHEREAS, CFR 403.8(f) (3) requires the City to have sufficient resources (funding and personnel) to carry out the requirements of the program, and WHEREAS, 13.08.250 of the City Municipal Code provides the legal authority to establish a system of charges and fees, and WHEREAS, the cost of the pretreatment program directly attributable to the industrial users shall be equitably distributed to the industrial users through a system of industrial user permit fees which reflect the actual demands placed on the program by each classification of industrial user. NOW, THEREFORE, BE IT RESOLVED, the City Council of the City of San.. Luis Obispo does hereby adopt the following schedule of Industrial User Permit Fees: 1. Significant and Categorical Users Annual Permit Fees . . . . . . . . . . . . . . . . . . . . $ 680.00 2. Class 1 Users Annual Permit Fees . . . . . . $ 210. 00 3. Class 2 Users Annual Permit Fees . . . . . . $ 64. 00 4. Monthly Compliance Monitoring, sampling and Follow-up Inspections for Noncompliance/Violations to be billed at the hourly rates established in the Public Works Department "Labor and Equipment Rates" document. 5. Annual permit fees to become effective and due July 1, 1991 with the proportionate amount included with the City's bi-monthly utility billing. Resolution No. (1991 Series) Upon motion of seconded by , and on the following roll call vote: AYES: NOES: ABSENT: the foregoing resolution was adopted this day of , 1991. Mayor Ron Dunin ATTEST: Pam Voges, City Clerk APPROVED: City dministrative Officer C' y to ne r City Finance Director City Utilities Director 3 - Il .,,,,�i.,:�1�I�II'iil!l� li�lll ill I II I illi Ililll .. _ Q-ty Of San WIS OBN `" LL 25 Prado Road • San Luis Obispo. CA 93401 April 10, 1991 SUBJECT: REVISED INDUSTRIAL USER PERMIT FEE PROGRAM Dear Industrial User: Thank you for responding to our request for input regarding the proposed Industrial User Permit Fee Program. As you may remember, the program was submitted to the San Luis Obispo City Council for approval on February 19, 1991. At that time, the program was intended to fully recover the cost for the City's Industrial Waste Pretreatment program. Numerous protests were filed and heard from the industrial community regarding the basis of the proposed fee program and the level of fees to be established. Council then rejected the proposed fee program and directed staff to return with a program which recovers only those program costs directly attributed to inspection and permitting of the industrial users. Staff has re- evaluated the proposed fee program and has developed a program which is based on the Council's direction. The propose fees for industrial user permits are as follows: Significant and Categorical Users . . . . . . $680.00/year Class 1 Users . . . . . . . . . . . . . . . . . . . . . . . . . . $210.00/year Class 2 Users . . . . . . . . . . . . . . . . . . . . . . . . . . $ 64. 00/year - Attached you will find Tables 1 and 2 for you information. Table 1 provides a breakdown of the derivation of the proposed fees. Table 2 identifies the inspection related activities, and estimated completion times, for each class of industrial user. These Tables are being provided to assist you in understanding the basis of the proposed fee program. Staff will be presenting this proposed fee program to Council for approval in May 1991 and is requesting that you review the 3-I Z III Fees letter April 10, 1991 Page 2 attached information and respond in writing with your comments by May 1, 1991. Please send your responses to: John E. Moss, Wastewater Division Manager Utilities Department 955 Morro Street San Luis Obispo, CA 93401 Your comments will be made available to Council and summarized in the staff report. If you have any questions regarding the proposed fee program you may contact Mr. David Hix, Industrial Waste Inspector @ 549- 7241, or myself @ 549-7220. This correspondence is being sent to only those industrial users commenting on the previously proposed fee program. However, all currently permitted industrial users will be notified of the time and place of the public hearing before the City Council to consider adoption of the proposed fee program. Again, thank you for your input on the previously proposed fee program. Your continued involvement is greatly appreciated. Sincerely; John E. Moss Wastewater Division Manager iufeeltr TABLE 1 1991-92 Pretreatment Program Budget. . . . . . . . . $108,700 Inspection = 35% of program total . . . . . . . . . . $ 38, 045 Overhead = 25% additional . . . . . . . . . ... . . . . . . . S 9,511 TOTAL INSPECTION RELATED COST . . . . . . . . . . . . $ 47,556 Minimum Inspection Time (1.5 hrs) = 1 MIT MIT Equivalents for User Classifications Class 2 - 1.5 hrs/inspection = 1 MIT Class 1 - 2.5 hrs/inspection = 1.66 MIT Sig/Cat - 4 hrs/inspection = 2.66 MIT Total Program MIT's = in class. * MIT * # insp. /yr. Class 2 = 164 * 1 * 1 = 164 Class 1 = 160 * 1.66 * 2 = 531 Sia/Cat = 4 * 2.66 * 4 = 43 TOTAL PROGRAM MIT's /yr. = 738 Program Cost / MIT = $47,556 / 738 = $64.00 / MIT Annual Permit Fee = Insp./yr. * MIT * $/MIT Class 2 = 1 * 1 * 64 = $ 64. 00/yr. ($65.00) Class 1 = 2 * 1.66 * 64 = $212.00/yr. ($210.00) Sig/Cat = 4 * 2.66 * 64 = $681.00/yr. ($680. 00) Table 2 Class 2 Users - (average inspection time = 1.5 hrs) Inspection related activities: File review. Travel time. Introduction. Inspection of grease trap. Issuance of receipt to manager. Review and update of file after inspection. Database update. Refile. Class 1 Users - (average inspection time = 2.5 hrs) Inspection related activities: File review. Report preparation. Travel time. Introduction. Inspection of facility. Inspection of receipts, manifests and permits. Complete report. Report review. File review and update. Database update. Refile. Significant/Categorical Users -(average inspection time = 4 hrs) Inspection related activities: File review. (previous inspections and required documents) Permit review. Discharge concentration data review. Report preparation. Travel time. Introduction. Inspection of facility. Inspection of waste and materials storage. Inspection of receipts, manifests and permits with mgr. Complete report. Report review. File review and update. Database update. Refile. •I'7111;"III Yel ll,l 11 rr Irrl li 11 rl Ili •I ,r Ii ._ _ :Irl 1. i iiliIII I I ill I li rCl 11 ill Il it cit' of SM lus .0 - 25 Prado Road • San Luis Obispo. CA 93401 May 1, 1991 SUBJECT: REVISED INDUSTRIAL USER PERMIT FEE PROGRAM Dear Industrial User: A public hearing will be held by the City Council on May 21, 1991 at 7:00 pm, at the City Council chambers, 990 Palm Street, to consider adoption of a revised industrial user fee program. As you may remember, a fee program was previously submitted to the San Luis Obispo City Council for approval on February 19, 1991. At that time, the program was designed to fully recover the cost of the City's Industrial Waste Pretreatment program. The City's Industrial Waste Pretreatment program is required under federal mandate. It's function is to monitor and control industrial discharges to the City's wastewater collection and treatment systems. Numerous protests regarding the previously proposed fee program were filed and heard from the industrial community. The protests were largely based on the criteria used for development of the proposed fee program (full program cost recovery) and the level of fees to be established. Council rejected the proposed fee program and directed staff to return with a program which recovers only those program costs directly attributed to inspection and permitting of the industrial users. Staff has re- evaluated the proposed fee program and has developed a program which is based on Council's direction. The proposed fees for industrial user permits are as follows: Significant and Categorical Users . . . . . . $680. 00/year Class 1 Users . . . . . . . . . . . . . . . . . . . . . . . . . . $210. 00/year Class 2 Users . . . . . . . . . . . . . . . . . . . . . . . . . . $ 64.00/year 3- l� III Fee Letter May 1, 1991 Page 2 Attached you will find Tables 1 and 2 for your information. Table 1 provides a breakdown of the derivation of the proposed fees. Table 2 identifies the inspection related activities, and estimated completion times, for each class of industrial user. These Tables are being provided to assist you in understanding the basis of the proposed fee program. If you have any questions regarding the proposed fee program you may contact Mr. David Hix, Industrial Waste Inspector @ (805) 549-7241, or myself @ (805) 549-7220. Sincerely; John E. Moss Wastewater Division Manager iufeeltr.2 TABLE 1 1991-92 Pretreatment Program Budget. . . . . . . . . $108,700 Inspection = 35$ of program total . . . . . . . . . . $ 38,045 Overhead = 25% additional . . $ 9 ,511 TOTAL INSPECTION RELATEDCOST . . . . . . . . . . . . $ 47,556 Minimum Inspection Time (1. 5 hrs) = 1 MIT MIT. Equivalents for User Classifications Class 2 - 1.5 hrs/inspection = 1 MIT Class 1 - 2.5 hrs/inspection = 1. 66 MI.T Sig/Cat - 4 hrs/inspection = 2 .66 MIT Total Program MIT's = # in class. * MIT * # insp./yr. Class 2 = 164 * 1 * 1 = 164 Class 1 = 160 * 1.66 * 2 = 531 Sia/Cat = 4 * 2.66 * 4 = 43 TOTAL PROGRAM MIT' s /yr. = 738 Program Cost / MIT = $47,556 / 738 = $64 . 00 / MIT Annual Permit Fee = # Insp. /yr. * MIT * $/MIT Class 2 = 1 * 1 * 64 = $ 64.00/yr. ($65.00) Class1 = 2 * 1.66 * 64 = $212 . 00/yr. ($210.00) Sig/Cat = 4 * 2.66 * 64 = $681. 00/yr. ($680.00) Table 2 Class 2 Users ­ (average inspection time = 1.5 hrs) Inspection related activities: File review. Travel time. Introduction. Inspection of grease trap. Issuance of receipt to manager. Review and update of file after inspection. Database update. Refile. Class 1 Users - (average inspection time = 2 .5 hrs) Inspection related activities: File review. Report preparation. Travel time. Introduction. Inspection of facility. Inspection of receipts, manifests and permits. Complete report. Report review. File review and update. Database update. Refile. Significant/Categorical Users -(average inspection time = 4 hrs) Inspection related activities: File review. (previous inspections and required documents) Permit review. Discharge concentration data review. Report preparation. Travel time. Introduction. Inspection of facility. Inspection of waste and materials storage. Inspection of receipts, manifests and permits with mgr. Complete report. Report review. File review and update. Database update. Refile. AUTO BODY. . . MEMNG AGENDA DATE S M #= May 10, 1991 City of San Luis Obispo, Subject:Revised Industrial User Permit Fee Program I am in receipt of your letter dated May 1 , 1991. The fees seem to be more in line on this revised letter than on the original.. As with all businesses I am currentlywatching all .of my expenses and costs. It would be wonderful if there was no cost at all, but- I realize that everyone needs- to pay their share. I feel comfortable with the new' amount . as being fair.. RECEIVED MAY 2 1 .1991 COF. TO: Thank .Your.. . ❑•j)awtxs Athan ❑ FYI CfTY CLERK a/ Q CMDUL . SAN LUIS OBISPO,CA i �LO ❑ FIN.DIR r_ Ci,0 ❑ F�CFI l� ATICWIJEY ElFW DIR /:.-LEK/01UG. ❑ POLICE CFL ❑ :-r�AT.TFniv1 ❑� DIIt ❑ ADFILE Lam( mru D'.R .. - sr— �'Cl e Cheri Medsker' = Office ManagerE P 'i Is r1' SIV F i .'{ I.v 31 HIG.UERA STREET • SAN LUIS OBISPO , CA 93401 • ( 805 ) 54. 3 - 9505 FAX ( 805 ). 543 - 1559 ilhETING AGENDA CALIFORNIA DATE Automotive Service Councils of California (Formerly Independent Garage Owners of California) ABC San Luis Obispo Unit 17 �^ ^• •49P.O. Box 3216 PROFESSIONALS.. San Luis Obispo, California 93403 AUTOMOTIVE SERVICE COPlFSTp: January 22, 1991 ❑ Action Fn ❑ CDD DIR O ❑ FIN.DR ACRO ❑ F�C� ATTORNEY ❑ FW DUL City of San Luis Obispo C4� LERK/ORIG. ❑ Po=C3-, Attention: John E. Moss MAI ' "`' ❑ MG'4TTEA-M 11,RECD� 955 Morro Street ^�2 1 1§91 o,CRTEADFU �" San Luis Obispo, CA 93401 O�,p �� Cil Dear Mr. Moss: S�ILlI1S 6l��CA This letter is in response to the propcEed industrial user fees for the San Luis Obispo' s water Pretreatment program. The members of the Automotive Service Councils of California, San Luis Obispo Chapter 17 (60 businesses county-wide, 2000 businesses statewide, over 10,000 businesses nationwide) strongly oppose the proposed fee structure. Our association' s goal is clean air and water, just as is yours. But we feel that it is unfair to charge us for treatment and inspections, without any criteria or proof showing who ' s doing the polluting. As we understand the fee structure, it is based on inspection costs, yet you don't plan to actually perform the inspections. This seems unfair. Due to stringent hazardous waste regulations, our industry is probably cleaner and contributes less to wastewater than most single dwellings or businesses. We feel that without specific testing, all dwellings and businesses should pay equally for this proposed treatment. The City should consider taking the lead, as in the no-smoking ordinance,in the regulation of motor oil, coolant, brake fluid, etc. sales. There is no regulation for the do-it-yourselfers, who may be disposingof their waste oils improperly and illegally. We propose that a substantial deposit be required with the sale of any oils, coolants, or related fluids, which would be re- turned when the customer brings in their waste oil. Any store not charging his deposit would be prohibited from selling these fluids. Please take our suggestions into consideration, and please contact us for further discussion or information. incerely, Jeff Spevack Per Mathiesen Continental Motor Works _ Mat's Brake and Alignment SC 17 Representatitve "? , -`-•:ASC State Board MAY � ��F1j i"1 t