Permitting Requirement Costs
for Drinking Water Treatment Cost Models

Contract # EP-B16C-0001

Draft

October 2020

Prepared for:
Rajiv Khera
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, D.C. 20460

Submitted by:
Abt Associates
6130 Executive Dr.
Rockville, MD 20852

Table of Contents

1.	Introduction	1
2.	Background	3
2.1	The Regulated Industry	3
2.2	Economic Analysis of Regulatory Actions	4
2.2.1	Social and Private Costs	4
2.2.2	Estimating Permit Costs	5
3.	Permit Cost Data	9
3.1	Building Permits	9
3.2	Environmental Regulation Costs	15
3.2.1	Permits for Wastewater Discharge	15
3.2.2	Permits for Storm Water Discharge	18
3.2.3	Permits for Air Pollution	20
3.2.4	Permits for Waste Disposal	22
3.2.5	Storage Tanks	25
3.2.6	National Environmental Policy Act Compliance Requirements	25
4.	Summary and Discussion	27
5.	References	29
Appendix A. Permit Cost Information from States and Local Jurisdictions	32

Table of Exhibits

Exhibit 1. Community Water Systems by Population Served and Primary Water Source	3
Exhibit 2. Building Size and Cost Estimates from the WBS GAC Model	11
Exhibit 3. Example of Building Permit Costs for GAC Processes	11
Exhibit 4. Example Building Permit Fee Schedule  -  Value Based	12
Exhibit 5. Comparison of Average Permit Costs and UBC-Based Costs	13
Exhibit 6. Ratio of Total of Building Permit and Related Costs to Building Permit Costs	14
Exhibit 7. NPDES Permit Application Fee by Discharge Flow (2020$)	17
Exhibit 8. Storm Water Soil and Erosion Control Permit Application Fee	19
Exhibit 9. Cost Estimates to Meet Risk Management Plan and Program Requirements	22
Exhibit 10. Small Entity Annual Fee Maxima by Type of Small Entity and Fee Threshold	24
Exhibit 11. Burden Estimates and Costs for NEPA Compliance	26
Exhibit 12. Summary of Updated Permit Costs for WBS Models	27
Exhibit 13. Sources of Uncertainty in the Analysis	28

Abbreviations and Acronyms

AEA	Atomic Energy Act
BMP	best management practice
CAA	Clean Air Act
CEQ	Council on Environmental Quality
CWA	Clean Water Act
CWS	community water system
ECHO	Enforcement and Compliance History Online
EPA	U.S. Environmental Protection Agency
EPCRA	Emergency Planning and Community Right-to-Know Act
ESA	Endangered Species Act
GAC	granular activated carbon
gpd	gallons per day
HAP	hazardous air pollutant
ICC	International Code Council
ICR	Information Collection Request
LLRW	low-level radioactive waste
mgd	million gallons per day
NEPA	National Environmental Policy Act
NESHAP	national emissions standards for hazardous air pollutant
NOI	notice of intent
NORM	naturally occurring radioactive material
NPDES	National Pollution Discharge Elimination System
NRC	Nuclear Regulatory Commission
O&M	operating and maintenance
OCA	offsite consequence analysis
POTW	publicly owned treatment works
PRA	Paperwork Reduction Act
PWS	public water system
RCRA	Resource Conservation and Recovery Act
RMP	risk management plan
UBC	Uniform Building Code
WBS	work breakdown structure

Introduction
The Safe Drinking Water Act Amendments of 1996 and numerous other statutes and executive orders require the U.S. Environmental Protection Agency (EPA, or the Agency) to estimate regulatory compliance costs as part of its rulemaking process. EPA uses these estimates in social benefit-cost analyses, as well as various distributional analyses (such as those required by the Regulatory Flexibility Act and the Small Business Regulatory Enforcement Fairness Act), to inform its decision making. Thus, improvements in the accuracy of compliance cost estimates enhance the Agency's policymaking capabilities.
EPA developed engineering cost models that have a work breakdown structure (WBS) to generate system-level treatment cost estimates. The WBS models estimate process requirements at the component level and corresponding unit costs. EPA pursued the WBS approach to derive system-level costs to address recommendations regarding its methods for estimating drinking water compliance costs (USEPA, 1996). Among these recommendations was one to incorporate indirect compliance costs such as the costs of meeting environmental permitting requirements and the costs of complying with local building codes and design requirements. EPA developed permit-related costs in 2013 (SAIC, 2013). This report updates and revises those costs based on current information.
In general, a permit is an authorization, license, or equivalent control document that is used to regulate an activity. Drinking water regulations can result in drinking water systems adding new treatment trains, for which various permits may be required under other existing regulatory authorities.
Incorporating permit costs in the WBS models requires analysis of several issues in addition to estimating permit costs. These considerations are:
the distinction between social and private costs and how it affects the type of permit costs included in an analysis
the potential to double count social benefits and costs of permit-related provisions that are properly considered elsewhere (e.g., EPA does not include the benefits of conforming to building codes in its drinking water rule benefits analyses)
incorporating the cost of building permits and other construction-related requirements (e.g., best management practices for construction site runoff) as line items in the WBS models may double count these costs if they are implicitly included elsewhere in the models such as in building construction costs.
This report addresses these issues and provides estimates of the costs for various permits that may be needed by drinking water systems. Specifically, Section 2 provides background information and discusses relevant economic analysis concepts. Section 3 presents information on permit costs and applicability. Section 4 provides summary arguments regarding permit applicability and cost, a sample of permit cost estimates by technology and design flow category, and a discussion of the limitations and uncertainties in the estimates.
Background
This section begins by providing background information on the types of public drinking water systems potentially affected by new regulations, and EPA's approach for evaluating cost impacts to these systems. Following this is a discussion of relevant economic analysis concepts. This discussion includes the conceptual background for two of the key issues described in the previous section: the distinction between social and private costs, and the potential to double count social benefits and costs of permit-related provisions that are properly considered in other regulations. This section also addresses specific Blue Ribbon Panel comments regarding permit-related costs that are included in other WBS line items.
The Regulated Industry
There are more than 148,000 public drinking water systems (PWS) in the United States (USEPA, 2020b). A PWS is a publicly or privately owned entity that regularly supplies drinking water to 25 or more people or 15 or more service connections. More than 50,000 of these systems are community water systems (CWS), which serve the same customers year-round. The service populations range from 25 people to several million people. Exhibit 1 shows the number of CWS by population size category and primary water source.
Exhibit 1. Community Water Systems by Population Served and Primary Water Source
Population Served
Primarily Ground Water
Primarily Surface Water
Water Source Unknown
Total
<=100
                                                                         11,179
                                                                          1,011
                                                                             13
                                                                         12,203
101-500
                                                                         13,276
                                                                          2,160
                                                                             11
                                                                         15,447
501-1,000
                                                                          4,211
                                                                          1,183
                                                                              3
                                                                          5,397
1,001-3,300
                                                                          5,555
                                                                          2,481
                                                                              0
                                                                          8,036
3,301-10,000
                                                                          2,794
                                                                          2,243
                                                                              1
                                                                          5,038
10,001-50,000
                                                                          1,345
                                                                          2,004
                                                                              0
                                                                          3,349
50,000-100,000
                                                                            161
                                                                            407
                                                                              0
                                                                            568
>100,000
                                                                             74
                                                                            367
                                                                              0
                                                                            441
Total
                                                                         38,595
                                                                         11,856
                                                                             28
                                                                         50,479
Source: USEPA, 2020b.
EPA drinking water standards vary across system subsets of this industry because of variations in exposure across system types and contaminants. For example, surface water treatment rules that regulate exposure to biological contaminants apply to surface water systems of all types, while the 2001 Final Rule for arsenic applied to both surface and ground water systems that were in the CWS and non-transient non-community system categories.
EPA's national cost analysis approach accommodates this variability in regulatory impacts because it combines system-level cost estimates with a compliance forecast of how many systems will incur compliance costs. The system-level costs for treatment vary by technology and incorporate capital costs for equipment, construction, and engineering, as well as operating and maintenance (O&M) costs. System size, or population served, is also an important determinant of costs because systems that treat large flows will incur higher capital and operating costs than systems treating smaller flows. The WBS models provide system-level costs using a flexible framework in which costs vary by technology and system size.
Economic Analysis of Regulatory Actions
When EPA promulgates a regulation affecting drinking water systems, such as a rule establishing the maximum contaminant level of a contaminant, it evaluates the incremental benefits and costs of the rule and the potential impacts on household water costs. The two types of analysis answer different policy questions. The benefit-cost analysis addresses the question of whether a regulation is efficient such that the gainers could compensate the losers such that everyone is at least as well off as before the policy. In contrast, the economic impact analysis evaluates the distributional effects on various subpopulations affected by the policy  -  who gains and who loses, and by how much.
The types of costs EPA includes in these two analyses are different. For the benefit-cost analysis, EPA estimates social cost, which it compares with social benefit to evaluate the net change in social welfare. For its economic impact or distributional analyses, EPA calculates private costs. This section addresses the distinction between these two types of cost estimates and its implications for including permit costs in the WBS models, which EPA plans to use in cost analyses for future drinking water regulations.
Social and Private Costs
As described in EPA's (2010) Guidelines for Preparing Economic Analyses, total social cost is the sum of the opportunity costs incurred by society as a result of a new regulation. Opportunity costs are the value of the goods and services foregone by society when resources are used to comply with and implement a regulation. For example, if a regulation requires a system to install new filter basins, the social costs include the opportunity costs of the labor and materials needed to design, build, and operate the basins because these resources are not available for other uses.
These "real-resource" compliance costs are the principal component of total social costs. They come from purchasing, installing, and operating new pollution control equipment, or otherwise altering production processes to comply with regulatory requirements. Other types of social cost include government regulatory costs such as monitoring, administrative, and enforcement costs (USEPA, 2010).
EPA also estimates the private cost of compliance to drinking water suppliers as input into economic impact analysis of the effects of a policy on an industry as a whole, or on individual households (USEPA, 2010). Private costs are the out-of-pocket cost of compliance incurred by drinking water utilities. Because utilities pass these costs on to households as drinking water fees, private costs are also the basis for evaluating household impacts of new rules.
As noted above, social and private costs can differ. The private or out-of-pocket costs for new treatment equipment or additional operator labor will most likely equal the social or opportunity costs. In other instances, however, an out-of-pocket expense may not be a social cost because the expense does not represent a real resource allocation that has an opportunity cost. An example is a transfer payment such as a tax. A tax transfers money from one entity to another, but it does not represent an opportunity cost of real resources such as the labor and equipment used to build a treatment facility. Although transfer payments are an out-of-pocket expense and, therefore, are included in private costs, they are excluded from social cost analysis. Conversely, there are social costs that do not have corresponding out-of-pocket expenses and, therefore, are not included in private cost estimates. In particular, costs associated with the environmental impacts caused by new waste streams will not be captured in an estimate of incremental out-of-pocket expenses unless there are waste disposal fees.
In summary, the costs in EPA's WBS models will need to represent both types of costs. Because EPA assumes that out-of-pocket expenditures equal real-resource compliance costs for most items in the WBS models (e.g., equipment, chemicals, labor, and materials), the resulting cost estimates can be used to represent both social and private costs. Exceptions include transfer payments and most likely permit costs. Social costs should exclude transfer payments such as sales taxes on equipment, but private costs will include such transfers as well as tax consequences of expenditures. Social costs should also exclude permit costs that are attributable -- along with their social benefits -- to other regulations, while private costs include the out-of-pocket expenses of such permits.
Estimating Permit Costs
Incorporating permit costs in the WBS models is a challenge because many permit requirements are site-specific. Consequently, they are difficult to characterize in models that provide average system-level costs for a national cost analysis. There is, for example, wide variation in site characteristics that affect the potential for environmental impacts, which affects the need for public agency review and approval.
Nevertheless, there are some relatively predictable permit requirements that are more amenable to valuation in the WBS models. First, most new facilities must obtain a building permit and related mechanical permits, regardless of location. Second, environmental permit requirements can be anticipated although they will vary by technology and system size, and may differ by location when states adopt requirements in addition to federal standards.
In a benefit-cost analysis, social and private permit costs can differ for two reasons. First, accounting for social permit costs in the WBS treatment cost models raises a double-counting concern because permit costs (and associated benefits) are properly attributable to the federal, state, or local rules that establish the permit requirements. For example, federal and state requirements under the National Pollution Discharge Elimination System (NPDES) regulate discharges to surface waters of the United States, and the discharger compliance costs and water quality benefits of implementing NPDES permits are attributable to the federal and state rule-making efforts that established the requirements. If EPA considers it appropriate to include permit costs in social costs, then benefits attributed to having permit requirements must also be included in the corresponding social benefit analysis. These benefits may include various use-related benefits of health, safety, and environmental quality improvements as well as nonuse benefits.
Second, permit fees may not equal the social cost of permit administration (e.g., time spent by employees of a public entity to review permit applications, make a determination regarding permit applicability and conditions, and notify the permittee), even when social costs are relevant. State and local permit authorities may charge application fees that do not reflect the real resource cost of reviewing and approving the permit. For example, in states that do not charge application fees for environmental permits, the out-of-pocket expense for environmental permits will understate the social cost of permit approval.
The private costs to drinking water systems of acquiring building and environmental permits comprise the out-of-pocket expenses of preparing the permit application and supporting documentation. Additional out-of-pocket expenses can include permit application fees charged by the administering agency and hourly fees for review or inspection services. Fees for building permits are set at the local level, e.g., the county or municipality that has jurisdiction over the treatment train location. Fees for environmental permits are generally set by states, although some states have regional oversight agencies that assess environmental permit fees.
In contrast, the social costs of acquiring permits are the opportunity costs of preparing, reviewing, and approving the permit applications. This includes the opportunity costs to the permittee of preparing the application form and supporting documentation, which will be similar to the private costs. It also includes the opportunity costs for the public agency that administers the permit to have employees spend time reviewing the documents, making a determination regarding permit applicability and conditions, and notifying the permittee; however, as discussed above, the out-of-pocket expense for the permit application may not match the agency's opportunity costs.
Following permit approval, the permittee will implement the permit conditions through upfront capital investments or operating expenditures. Both of these costs are already captured in WBS, which includes waste treatment equipment costs among capital costs and O&M labor and material costs for facility maintenance and waste handling. Thus, the permit cost line item in the WBS model reflects only the value of the resources including labor time needed to prepare and process various permit forms (based on private costs), and avoids double-counting permit compliance costs.
Estimates of costs for some types of permits can be found in regulatory analysis documents. Permit applications that implement federal environmental regulations constitute data collections, which are subject to the 1995 Paperwork Reduction Act (PRA). Under the PRA, an agency must have an Information Collection Request (ICR) approved by the Office of Management and Budget. Required inputs to the approval process include estimates of the potential "burden" on respondents to the collection. These burden estimates include the time required to generate, maintain, and disclose information sought by a federal agency. Thus, ICR burden estimates represent both the social and private costs associated with federally-required permits.
Unfortunately, cost estimates for permits that are required by state and local jurisdictions are not as readily available. They cannot be derived from federal ICR documents, and regulatory cost analyses are rare at the state and local level. Therefore, alternative sources of cost data need to be considered. EPA reviewed engineering cost estimating manuals and contacted professionals in the field to obtain information on state and local permit costs. These sources provide little information on permit costs and the general consensus among experts contacted is that permit costs are site-specific and are not readily estimated using rule-of-thumb approaches. Consequently, EPA sought site-specific information on permit requirements and costs. For example, the most common requirement is a building permit and accompanying mechanical, electric, plumbing, and fire safety permits. Many jurisdictions post building permit cost information on the internet.
Other permit requirements can vary within a state or local area and, therefore, require specific location information. A national average of such permit costs is not feasible and, therefore, introduces uncertainty into EPA's cost estimates. It is important to note, however, that EPA's national cost analysis methods and the WBS models address some of these state and local permit costs in ways not reflected in the permit cost line item. For example, the Blue Ribbon Panel identified local ordinances in California prohibiting cross-media transfers of pollutants as a potential impediment to systems preferring aeration as a low-cost treatment option in complying with the proposed radon rule in lieu of the higher cost treatment alternative (i.e., granular activated carbon) (USEPA, 1996). EPA can best address technology restrictions such as this one in the compliance forecast that it develops for each rule. This forecast characterizes the likelihood of selecting alternative technologies, and can reflect restrictions in local regulations by having a lower probability assigned to the affected technology.
Another example of permit-related impacts noted by the Blue Ribbon Panel is that local building codes and design standards can add significant cost to facility construction (USEPA, 1996). The Blue Ribbon Panel suggested that many communities have established strict standards and aesthetic requirements for the construction of public buildings so that they may blend into the surrounding environment. A member suggested that although these aesthetic and additional design costs should not be attributed directly to EPA regulations, they are real costs that the systems will incur to get community approval for project funding (USEPA, 1996). For building and environmental permit costs, a social cost analysis should reflect that the cost of complying with these requirements are properly attributed (along with their benefits) to the local design standards. For private cost analysis, the WBS models provide a wide range of building construction options that are adequate to evaluate the range of building costs from low (e.g., corrugated steel exterior and light duty interior) to high (architecturally detailed structure with a stone exterior). Thus, the cost ranges generated by the WBS models for policy analyses will address these types of concerns.

Permit Cost Data
The Blue Ribbon Panel (USEPA, 1996) cited the costs of complying with local building codes and design requirements, local permitting requirements, and environmental permits as specific types of compliance costs that should be addressed in EPA's cost analyses. Section 3.1 provides a discussion of local building codes and design requirements and resulting cost estimates. Section 3.2 addresses environmental permitting costs. The approach to estimating costs will reflect private costs or out-of-pocket costs to the drinking water utility, which can include the cost to prepare permit applications and application fees. As discussed in the previous section, accounting for social permit costs in the WBS treatment cost models raises a double-counting concern because permit costs (and associated benefits) are properly attributable to the federal, state, or local rules that establish the permit requirements, not drinking water regulations that result in building construction.
Systems that add a new treatment train to comply with a revised drinking water standard need to submit treatment plans to the primacy agency (either an approved State or EPA) for review and approval. This process can be tied to operating permit revisions and, therefore, may seem to be a permit requirement to be included in the private permit costs developed for the WBS models. The design review process, however, constitutes an information collection that is regulated under the PRA. As a practical matter, the costs of this activity should be derived independently from other compliance costs to simplify ICR reporting requirements for the new drinking water regulation. Therefore, these costs generally would not be included in the aggregate costs generated by the WBS models and are excluded from this report.
Building Permits
Systems installing a new treatment process to comply with new or revised drinking water standards will most likely build a new structure to house the process. They may also build auxiliary structures to store chemicals (e.g., for chlorine, which must be stored in a separate building). New buildings generally require building permits and inspections to ensure the structures meet local building code requirements. Even if a new treatment train can be added within an existing structure, local jurisdictions may require a construction-related permits.
Building codes are generally adopted and enforced at the State and local level, although building codes for industrial and commercial facilities must incorporate federal safety requirements promulgated under the Occupational Safety and Health Act, which address building features such as means of egress, ventilation, sanitation, and fire protection (29 CFR Part 1910, Subparts E, G, J, and L, respectively). Consequently, the private costs of acquiring and complying with building permits will vary from place to place. The costs include those to prepare and submit the application and accompanying plans as well as one or more fees charged for the permit, plan reviews, and inspections.
In the WBS models, the cost associated with compiling and submitting the permit application is captured in other WBS line items such as the architectural fees that are part of the unit cost for building structures and the engineering fees that are rolled up into a single multiplier on equipment costs. Therefore, these costs cannot be included in private cost estimates for permits without double-counting costs. A further implication is that regardless of whether cost outputs represent social or private costs, they include permitting costs that are embedded in other cost factors.
The Blue Ribbon Panel also raised a concern that local design requirements such as aesthetic requirements for buildings that blend into the surrounding environment increase construction costs (USEPA, 1996). As noted above, EPA has developed cost ranges that incorporate optional building exteriors, along with other factors that may make a treatment facility more or less expensive than average, as part of its overall effort to incorporate above-average-cost and below-average-cost facilities in its policy analyses. These "high-cost" and "low-cost" systems can be used in EPA's simulation-based SafeWater CBX model to generate national cost estimate ranges. Thus, EPA can address the costs of complying with potential site-specific aesthetic requirements without increasing the permit cost estimate.
In its original permit cost analysis in 2004, EPA evaluated the private costs or permit fees by collecting building permit cost information for several jurisdictions that post their fees on the Internet (SAIC, 2013). EPA began with a random sample of 30 locations drawn from the population of community water systems in the Safe Drinking Water Information System. Of these, EPA obtained building permit fee schedules for 20 locations  -  14 jurisdictions via website and 6 via interviews. EPA contacted three additional agencies that did not respond to a request for building permit cost information. To comply with limitations on federal data collection under the PRA, EPA did not make any additional contacts to acquire building permit fee schedules for the remaining seven locations. In 2013, EPA updated their evaluation of permit fees. EPA obtained updated building permit fee information for 19 of the 20 jurisdictions (SAIC, 2013). Updated permit fee information for one jurisdiction, Lake Charles, Louisiana was not available. Therefore, EPA used the original 2004 permit fee data for that jurisdiction. In 2020, Abt obtained updated permit cost schedules for 18 of the 20 jurisdictions. The building permit fee schedules for the sample locations are in Appendix A (see Exhibit A-1).
The sample locations generally adopted a value-based fee schedule, although a few have an area-based fee schedule. We derived permit costs using building size and cost estimates generated by one of the WBS engineering cost models. Exhibit 2 provides WBS model outputs from the granular activated carbon (GAC) model for building size and value for eight system size categories in EPA's flow paradigm using the design flows below:
25 to 100 people served [0.03 million gallons per day (mgd)]
101 to 500 people served (0.124 mgd)
501 to 1,000 people served (0.305 mgd)
1,001 to 3,300 people served (0.74 mgd)
3,301 to 10,000 people served (2.152 mgd)
10,001 to 50,000 people served (7.365 mgd)
50,001 to 100,000 people served (22.614 mgd)
greater than 100,000 people served (75.072 mgd).
Exhibit 2. Building Size and Cost Estimates from the WBS GAC Model
by System Design Flow in mgd (2018$)
WBS Output
0.03
0.124
0.305
0.74
2.152
7.365
22.614
75.07
Building 1 (sf)
                                      50
                                      210
                                      330
                                      590
                                     2,990
                                     6,590
                                    12,350
                                    32,400
Building 2 (sf)[a]
                                      NA
                                      NA
                                      NA
                                      NA
                                      NA
                                      NA
                                     2,140
                                     3,740
Building 1 cost ($)
                                     2,374
                                     9,972
                                    15,670
                                    62,076
                                    268,224
                                    547,010
                                    963,782
                                   2,299,884
Building 2 cost ($)[a]
                                      NA
                                      NA
                                      NA
                                      NA
                                      NA
                                      NA
                                    198,386
                                    328,209
GAC = granular activated carbon, mgd  -  million gallons per day; sf = square feet, NA = not applicable.
The 0.03 to 0.74 mgd systems are designed as pressurized contactor systems; the 2.152 to 75.07 mgd systems are designed as gravity contactor systems. We used the GAC WBS model version available April 6, 2020 with standard inputs and mid-cost assumptions.
a. The smaller system size categories have one structure, but the two largest size categories have two structures.
Exhibit 3 shows the permit cost estimates by location based on the building information in Exhibit 2. The estimates vary substantially across locations. For example, costs for the smallest size category range from $40 to more than $2,600, and costs for the largest size category range from almost $1,800 to more than $46,000. The final rows show average costs ranging from approximately $260 to $11,200. Removing the outlier cost of $2,666 from the four smallest size categories lowers the average cost for those sizes by more than $100.
Exhibit 3. Example of Building Permit Costs for GAC Processes
by Jurisdiction and System Design Flow in mgd (2018 dollars)
Jurisdiction
0.03
0.124
0.305
0.74
2.152
7.365
22.61
75.07
Tampa, FL
                                     2,666
                                     2,666
                                     2,666
                                     2,666
                                     2,846
                                     3,494
                                     4,395
                                     6,460
Westfield, IN
                                      610
                                      642
                                      666
                                      718
                                     1,198
                                     1,918
                                     3,498
                                     7,828
Sealy, TX
                                      35
                                      70
                                      100
                                      312
                                      967
                                     1,756
                                     2,986
                                     5,918
Lake Charles, LA
                                      30
                                      55
                                      84
                                      248
                                      763
                                     1,284
                                     2,514
                                     5,446
City of Bloomington, IL
                                      49
                                      104
                                      132
                                      343
                                     1,011
                                     1,866
                                     3,650
                                     7,250
Spotsylvania County, VA
                                      150
                                      150
                                      150
                                      150
                                      389
                                      857
                                     1,884
                                     4,698
Charlotte, NC
                                      60
                                      145
                                      218
                                      704
                                     1,758
                                     3,167
                                     6,273
                                     9,746
West Columbia, SC
                                      25
                                      30
                                      48
                                      189
                                      638
                                     1,148
                                     1,763
                                     3,229
Port Allen, LA
                                      40
                                      40
                                      48
                                      189
                                      638
                                     1,172
                                     2,095
                                     4,294
Rice County, MN
                                      83
                                      181
                                      265
                                      735
                                     1,940
                                     3,462
                                     6,383
                                    10,740
Clark County (Brush Prairie), WA
                                      244
                                      250
                                      444
                                     1,023
                                     2,333
                                     3,959
                                     7,034
                                    12,735
Bay City, MI
                                      133
                                      294
                                      432
                                     1,157
                                     3,085
                                     5,548
                                    10,468
                                    18,938
Jefferson (Ashtabula County), OH
                                      152
                                      159
                                      165
                                      177
                                      285
                                      447
                                      802
                                     1,776
Middletown Borough, PA
                                      264
                                      325
                                      385
                                      729
                                     2,377
                                     4,759
                                     9,829
                                    22,327
Amery, WI
                                      150
                                      150
                                      150
                                      378
                                     1,614
                                     3,288
                                     6,315
                                    13,645
Dunnellon, FL
                                      120
                                      175
                                      280
                                     1,103
                                     4,708
                                     9,590
                                    20,353
                                    46,008
Hollister, MO
                                      40
                                      61
                                      86
                                      284
                                     1,149
                                     2,321
                                     4,904
                                    11,061
Chadron, NE
                                      75
                                      163
                                      238
                                      656
                                     1,733
                                     3,128
                                     6,203
                                     9,492
Sonora, CA
                                      83
                                      181
                                      265
                                      735
                                     1,940
                                     3,462
                                     6,383
                                    11,555
Average (all values)
                                      264
                                      307
                                      359
                                      658
                                     1,651
                                     2,980
                                     5,670
                                    11,218
Average (modified)[a]
                                     130*
                                     176*
                                     231*
                                     546*
                                     1,651
                                     2,980
                                     5,670
                                    11,218
GAC = granular activated carbon.
a. Outlier value of $2,666 for Tampa, FL excluded from modified average values identified with asterisks.
Based on a comparison of permit cost estimates such as those in Exhibit 3 for multiple technologies, SAIC (2013) noted that permit costs equal less than 1% of process costs, which suggests that total capital costs are not very sensitive to building permit costs, on average. The impact, however, varied substantially across system sizes, making a single cost multiplier impractical. Furthermore, the step function method used by most locations to estimate permit costs presents a challenge for incorporating "average" permit costs in the WBS models (e.g., some locations use building value to determine permit fees, while others use building size, and the breakpoints for step functions differ across locations).
Based on the SAIC (2013) recommendation, the WBS models incorporated the value-based fee schedule shown in Exhibit 4, which is from the Uniform Building Code (UBC) (International Conference of Building Officials, 1997). The UBC provides `model' building code language for local governments to copy into their ordinances. Since publication of the UBC fee schedule in 1997, the International Conference of Building Officials has merged with two other building code organizations to establish the International Code Council (ICC). The ICC no longer has a fixed fee schedule like the one shown. Instead, it publishes average square-foot construction costs by building type. Then, the building value generates a permit cost based on a local permit multiplier calculated from local building department budgets and construction values (ICC, 2018).
Exhibit 4. Example Building Permit Fee Schedule  -  Value Based
Total Building Valuation
Fee
$1 to $500
$23.50
$501 to $2,000
$23.50 for the first $500 plus $3.05 for each additional $100, or fraction thereof, to and including $2,000
$2,001 to $25,000
$69.25 for the first $2,000 plus $14.00 for each additional $1,000, or fraction thereof, to and including $25,000
$25,001 to $50,000
$391.75 for the first $25,000 plus $10.10 for each additional $1,000, or fraction thereof, to and including $50,000
$50,001 to $100,000
$643.75 for the first $50,000 plus $7.00 for each additional $1,000, or fraction thereof, to and including $100,000
$100,001 to $500,000
$993.75 for the first $100,000 plus $5.60 for each additional $1,000, or fraction thereof, to and including $500,000
$500,001 to $1,000,000
$3,233.75 for the first $500,000 plus $4.75 for each additional $1,000, or fraction thereof, to and including $1,000,000
$1,000,001 and up
$5,608.75 for the first $1,000,000 plus $3.65 for each additional $1,000, or fraction thereof
Source: International Conference of Building Officials (1997).
SAIC (2013) recommended using the 1997 UBC schedule based on a comparison of the sample average with the fee schedule costs. Exhibit 5 shows the comparison from SAIC (2013) between the average costs based on the sample of local building permit fee schedules (first row) and the UBC-based costs in 2013 dollars (second row). The negative percentages in the third row show that the UBC-based costs were generally higher than the sample averages. Therefore SAIC (2013) concluded that using the 1997 UBC schedule would continue to provide conservative building permit cost estimates (i.e., tending to overstate costs).
Exhibit 5. Comparison of Average Permit Costs and UBC-Based Costs
by System Design Flow in mgd
Value
0.03
0.124
0.305
0.74
2.152
7.365
22.61
75.07
      2013 Comparison of Sample Averages and UBC Estimates (2013 dollars)
Sample Average[a]
                                     $298
                                     $625
                                     $796
                                     $944
                                    $1,550
                                    $2,541
                                    $4,685
                                    $9,676
UBC Estimate[a]
                                     $111
                                     $644
                                     $847
                                    $1,044
                                    $1,671
                                    $2,797
                                    $5,687
                                   $11,086
Percentage Difference
                                     168%
                                      -3%
                                      -6%
                                     -10%
                                      -7%
                                      -9%
                                     -18%
                                     -13%
      2020 Comparison of Sample Averages and UBC Estimates (2018 dollars)
Sample Average (all values)[b]
                                     $264
                                     $307
                                     $359
                                     $658
                                    $1,651
                                    $2,980
                                    $5,670
                                    $11,218
Sample Average (modified)[b]
                                     $130*
                                     $176*
                                     $231*
                                     $546*
                                    $1,651
                                    $2,980
                                    $5,670
                                    $11,218
UBC Estimate[c]
                                      $83
                                     $181
                                     $265
                                     $735
                                    $1,940
                                    $3,462
                                    $6,383
                                    $13,347
Percentage Difference
                                  57% to 218%
                                  -3% to 70%
                                  -13% to 35%
                                 -26% to -10%
                                     -15%
                                     -14%
                                     -11%
                                     -16%
a. Values reported in SAIC (2013)
b. Average of permit cost estimates in Exhibit 3. Modified average values with "*" exclude Tampa, FL, permit cost.
c. Permit costs were estimated using the cost schedule in Exhibit 4 and the building costs for GAC systems in Exhibit 2. Building costs are lower for design flows up to 0.305 mgd because the WBS models generate smaller footprints for more compact, skid-mounted designs, which also substantially reduces the $/ft[2] cost for buildings less than 500 ft[2], which have a metal shed option.
Exhibit 5 also provides a similar comparison between the UBC-based permit costs and the 2020 average costs based on sample permit fee schedules in Exhibit 3, both in 2018 dollars. The UBC estimates, which are based on the GAC building values in Exhibit 2 and the UBC schedule in Exhibit 4, continue to exceed the 2020 average permit fees for the four larger size categories. The UBC-based costs also exceed the modified average (i.e., excluding Tampa, FL fees) for three of the four smaller design flows. Therefore, we recommend continuing to use the 1997 UBC schedule in the WBS models. Doing so may underestimate building permit costs for the smallest size category, but may overestimate costs for the remaining size categories.
Building permit fees alone may not capture all building permit-related costs for a new structure. The sample locations have additional fees such as fees for inspections and fire safety permits. Some also charge a separate fee for plan review and site inspections. For example, Sealy, Texas has a building plan check fee equal to half the building permit fee in addition to fees for electrical, mechanical, and plumbing permits. Thus, the multiplier is greater than 1.5 for all design sizes. Therefore, the WBS models require a multiplier to convert the building permit cost output from the UBC equation into total building permit-related costs.
Based on our estimates of total building permit-related costs (see Appendix A, Exhibit A-2) and the permit only costs in Exhibit 3, we calculated the ratio of these total costs to building permit fees. Exhibit 6 shows the ratios for each jurisdiction and design flow. The final row in the table shows average ratios by design flow. These averages range from 2.6 to 1.5 across system size categories. Often these supplemental fees have fixed values or fixed minimum values. Consequently the ratio values are higher for smaller design flows. Because these costs reflect both private costs and social costs (e.g., for plan review time), we recommend adding the average multipliers to the building permit cost equation.
Exhibit 6. Ratio of Total of Building Permit and Related Costs to Building Permit Costs
by Jurisdiction and System Design Flow in mgd (2018 dollars)
Jurisdiction
0.03
0.124
0.305
0.74
2.152
7.365
22.61
75.07
Tampa, FL
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
Westfield, IN
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
Sealy, TX
                                      3.8
                                      2.7
                                      2.6
                                      1.8
                                      1.7
                                      1.6
                                      1.7
                                      1.7
Lake Charles, LA
                                      2.7
                                      1.9
                                      1.6
                                      1.4
                                      1.1
                                      1.2
                                      1.1
                                      1.1
City of Bloomington, IL
                                      7.3
                                      5.6
                                      5.7
                                      3.8
                                      3.1
                                      2.5
                                      2.3
                                      2.2
Spotsylvania County, VA
                                      5.4
                                      5.8
                                      7.2
                                      7.2
                                      4.4
                                      3.5
                                      2.8
                                      2.5
Charlotte, NC
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
West Columbia, SC
                                      4.0
                                      3.8
                                      2.8
                                      1.5
                                      1.4
                                      1.3
                                      1.4
                                      1.5
Port Allen, LA
                                      2.9
                                      3.0
                                      2.9
                                      1.5
                                      1.2
                                      1.1
                                      1.1
                                      1.1
Rice County, MN
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
                                      1.0
Clark County (Brush Prairie), WA
                                      2.5
                                      2.5
                                      2.6
                                      2.0
                                      1.9
                                      1.8
                                      1.8
                                      1.7
Bay City, MI
                                      2.4
                                      1.6
                                      1.4
                                      1.2
                                      0.4
                                      1.3
                                      1.3
                                      1.4
Jefferson (Ashtabula County), OH
                                      2.6
                                      2.6
                                      2.5
                                      2.5
                                      3.4
                                      3.1
                                      2.9
                                      2.7
Middletown Borough, PA
                                      1.1
                                      1.1
                                      1.2
                                      1.2
                                      1.5
                                      1.5
                                      1.6
                                      1.6
Amery, WI
                                      1.7
                                      1.7
                                      1.7
                                      1.3
                                      1.1
                                      1.1
                                      1.2
                                      1.1
Dunnellon, FL
                                      2.5
                                      2.0
                                      1.6
                                      1.2
                                      1.1
                                      1.0
                                      1.0
                                      1.0
Hollister, MO
                                      1.0
                                      1.2
                                      1.2
                                      1.2
                                      1.2
                                      1.2
                                      1.2
                                      1.2
Chadron, NE
                                      2.3
                                      1.6
                                      1.4
                                      1.2
                                      1.1
                                      1.0
                                      1.0
                                      1.0
Sonora, CA
                                      2.9
                                      2.2
                                      2.0
                                      1.8
                                      1.7
                                      1.7
                                      1.7
                                      1.7
Average ratio[a]
                                      2.6
                                      2.3
                                      2.2
                                      1.8
                                      1.6
                                      1.5
                                      1.5
                                      1.4
GAC = granular activated carbon.
a. Average of the ratios of the total of building permit plus related costs to corresponding building permit costs alone from Exhibit 3.
Environmental Regulation Costs
The Blue Ribbon Panel (USEPA, 1996) cited environmental regulations as an example of site-specific costs that EPA's WBS models should address. EPA identified several environmental regulations that potentially apply to the WBS treatment technologies based on likely waste streams or chemical use and federal requirements. The following sections provide overviews of environmental permit applicability to the WBS technologies as well as estimates of the private costs of obtaining permits.
Permits for Wastewater Discharge
Most treatment technologies result in some liquid effluent that must be discharged (e.g., due to backwash, cleaning, dewatering, or rejection of raw water); exceptions include chemical addition technologies. If residuals are not disposed on-site (e.g., in septic tanks), then discharge requirements apply.
The Clean Water Act (CWA) regulates direct and indirect wastewater and storm water discharges to waters of the United States. Direct wastewater discharges to surface waters are regulated under the NPDES, which is implemented by states and the federal government. Indirect discharge to publicly owned treatment works (POTWs) are regulated under industrial pretreatment programs, which establish limitations on the types and volumes of contaminants in industrial wastewater that can be discharged to a POTW. The industrial pretreatment programs are generally enforced either by states or municipal governments. In addition, the CWA regulates storm water discharges, which are addressed in the following section.
As noted in Section 2, CWSs that use surface water already provide water treatment and, therefore, may already have a residuals stream. A large number of ground water systems, however, use disinfection only or disinfection with other chemical addition (e.g., fluoride), neither of which are likely to generate liquid effluent. Thus, new regulations can trigger new liquid effluent streams and new NPDES permits, even among systems that already provide treatment. For systems that already have an NPDES permit, a new treatment train that affects the quality or quantity of effluent can necessitate a revision to an existing permit.
Alternately, drinking water facilities that do not discharge directly to waters of the United States might discharge to a POTW. The CWA also regulates discharges to POTWs under the National Pretreatment Program. Under that program, regulated facilities must ensure that their effluent meets certain pretreatment standards. The goal of the pretreatment program is to protect municipal wastewater treatment plants from damage that may occur when hazardous, toxic, or other wastes are discharged into a sewer system, and to protect the quality of sludge generated by these plants. Facilities regulated by the National Pretreatment Program include dischargers in certain industries (not including drinking water treatment), and dischargers of more than 25,000 gallons per day (gpd). Thus, pretreatment requirements would apply to water treatment plants that discharge more than 25,000 gpd on average to a POTW.
The social benefits and costs of obtaining NPDES permits are attributable to the original permit regulations. Therefore, this section provides estimates of private costs of acquiring or revising NPDES permit coverage.
Private costs include the labor costs for completing and submitting permit applications and the processing fee charged by the permit agency. These costs generally vary by the type of permit sought and the waste flow volume. Permit processing fees for major dischargers (i.e., sources that discharge more than 1 mgd) are often higher than fees for minor dischargers, and fees for dischargers covered by general permits are lower still. EPA's Enforcement and Compliance History Online (ECHO) database includes 3,380 drinking water systems (USEPA, 2020a). Of these, only 30 (<1%) are classified as major dischargers; the remaining 3,350 are minor dischargers. Thus, assuming the WBS technologies do not result in widespread discharges in excess of 1 mgd, the relevant cost for most systems will be the cost to obtain either an individual permit for a minor discharger or coverage under a general permit.
We reviewed two types of cost data for NPDES permits. The first type was burden estimates from an ICR for the NPDES program and the second was a sample of state permit fees.
To apply for an individual discharge permit, a water treatment facility would complete NPDES Form 1 and Form 2D or equivalent forms. The permitting authority will review the documents and issue an individual permit. EPA's ICR for NPDES permit applications indicates facilities will require an average of 27.3 hours to complete and submit the application forms (USEPA, 2015a). The average hourly cost is $53.56 (2014 dollars) based on total compensation for management, professional, and related occupations. Total cost is $1,462. Escalated to 2020 dollars using the Employment Cost Index for the same occupations (BLS, 2020a), the cost is approximately $1,660 ($1,462 x 138.9 / 122.3). The individual permit cost will overstate the cost for submitting notice of intent (NOI) forms to obtain coverage under a general permit and may overstate costs for those seeking a revision to an existing permit. Conversely, it will understate cost in instances where permits issued to major dischargers undergo the added expense of public hearings.
Abt also collected data on fees that States charge applicants for new NPDES permits (and major modifications to existing permits). We obtained fee schedules for nine of the ten States with the most drinking water systems. The tenth State, Georgia, does not indicate fees for NPDES coverage for direct discharges. The collected data are in Appendix A (see Exhibit A-3). The State permit application fees range from $75 (minor discharger, general permit in Michigan) to $50,000 (dischargers with flows greater than 10 mgd in Illinois). Costs generally vary by flow and/or permit type.
Abt calculated average state permit costs for three wastewater flow ranges: less than 0.1 mgd, between 0.1 and 1.0 mgd, and above 1.0 mgd. Exhibit 7 shows the state permit fee estimates by flow category based on permit information in Appendix A. It also shows the average across states. The final row of Exhibit 7 adds these average application fees to the $1,660 facility cost to arrive at a total NPDES permit cost. When direct discharge is selected for liquid residuals, the WBS models select the appropriate NPDES permit cost from among these three values based on the calculated discharge flow rate.
Exhibit 7. NPDES Permit Application Fee by Discharge Flow (2020$)
State
Less Than 0.1 mgd
0.1 to 1.0 mgd
More than 1.0 mgd
California
                                     1,606
                                     1,606
                                     3,598
Florida
                                      500
                                      500
                                      500
Illinois
                                      500
                                     5,000
                                    15,000
Michigan
                                      400
                                      400
                                      750
North Carolina
                                      860
                                      860
                                     3,440
New York
                                      375
                                     1,125
                                     7,500
Pennsylvania
                                      500
                                      500
                                      500
Texas
                                      150
                                      150
                                      150
Washington
                                     1,141
                                     1,141
                                     1,141
Average
                                      670
                                     1,254
                                     3,620
Combined NPDES Permit Burden ($1,660) and Application Cost
                                    $2,300
                                    $2,900
                                    $5,300
Source: Estimates derived from state fee schedules shown in Exhibit A-3.
New rules can affect facilities that discharge to a POTW. Under the National Pretreatment Program, a drinking water facility discharging to a POTW that is required to have a pretreatment program would generally be classified as a non-categorical significant industrial user if the daily discharge exceeds 25,000 gallons. The ICR for the National Pretreatment Program (USEPA, 2015b) indicates that the average one-time baseline monitoring reporting and analysis burden associated with a new non-categorical significant industrial user is approximately 42.3 hours for sampling, reporting, and record keeping activities. The average hourly labor cost is $53.56 (2014 dollars) based on total compensation for all civilians in management, professional, and related occupations. The total cost is $2,266. Escalated to 2020 dollars using the Employment Cost Index for the same occupations (BLS, 2020a), the cost is approximately $2,600 ($2,266 x 138.9 / 122.3, rounded to the nearest $100).
Permits for Storm Water Discharge
Discharges of storm water from industrial and construction sites may require NPDES permit coverage. In general, however, industrial storm water permit requirements will not apply to drinking water facilities because they are not among the industrial categories specifically regulated under 40 CFR 122.26(b)(14)(i)-(xi). Water treatment facility construction sites may, however, be subject to soil and erosion control requirements if they disturb one or more acre.  In particular, construction sites for processes that require large amounts and/or treat large flows may require permit coverage. For example, construction sites for the largest size category (75.07 mgd) for most technologies exceed the 1-acre threshold, and some filtration technologies have site sizes that trigger the requirement for smaller flow size categories.
The private costs attributable to the Storm Water Rules include permit administrative costs and best management practice (BMP) implementation costs to minimize soil erosion during construction. These costs accrue only during building construction and, therefore, are capital costs in the context of the WBS models. The ICR for storm water discharges associated with construction activities (USEPA, 2015a) provides the following cost estimates (in 2014 dollars):
An average of 2 hours to prepare a NOI to obtain coverage under a Construction General Permit, submit it to the permitting authority, notify the local municipality that the site is operating under an NPDES general permit, retain records, submit a notification of termination to the permitting authority (1.5 hours for the NOI and 0.5 hours for the Notice of Termination)
22.7 hours (for < 5-acre site) and 36.4 hours (for >= 5-acre site) to develop a Storm Water Pollution Prevention Plan, which includes a description of site conditions, the controls used to reduce storm water transport of pollutants, and maintenance and inspection for the controls.
EPA assumed a wage rate of $40.76 for municipal employees and a private sector wage rate of $53.56, both in 2014 dollars (USEPA, 2015a). Abt escalated these values to 2020 dollars using corresponding Employment Cost Indices for state and local workers (BLS, 2020c) and private industry workers (BLS, 2020b). The wage rates are $47.02 and $60.49 in 2020 dollars, respectively. Based on the distribution of public and private water systems (49% private and mixed private/public and 51% public including local, state, federal, and tribal governments), we calculated a weighted average labor cost of $53.89. The aggregate costs to the permittee are $1,331 for 24.7 hours (sites of 1 to 5 acres) and $2,069 for 38.4 hours (sites greater than 5 acres).
Abt also collected data on fees charged by certain States for general permit coverage. Exhibit 8 provides fees for construction sites that are up to five acres and greater than five acres in size, by state based on information in Appendix A (Exhibit A-4). The fees range from $100 to $1,203 across states and site sizes. EPA added the average costs shown in Exhibit 8 to the facility costs to estimate administrative costs.
Exhibit 8. Storm Water Soil and Erosion Control Permit Application Fee
by Construction Site Size (2020 dollars)
State
Sites up to 5 Acres[a]
Sites Larger than 5 Acres[b]
California
                                     526*
                                     610*
Florida
                                      250
                                      400
Illinois
                                      250
                                      750
Michigan
                                      400
                                      400
North Carolina
                                      100
                                      100
New York
                                     330*
                                     550*
Pennsylvania
                                     800*
                                    1,000*
Texas
                                      100
                                      100
Washington
                                      740
                                     1,203
Average
                                      388
                                      568
Source: Estimates derived from state fee schedules shown in Exhibit A-4.
a. Values with asterisks include per-acre costs incorporated based on an average of 3 acres.
b. Values with asterisks include per-acre costs incorporated based on 5 acres.
Combining the permit application burden costs with the permit fees provides total costs that vary by site size. For sites of 1 to 5 acres, the total cost is $1,700. For sites greater than 5 acres, the total cost is $2,600 (rounded to the nearest $100).
Facilities would also incur costs to implement BMPs to comply with permit requirements. EPA believes that these costs are already accounted for in the WBS cost estimates. The WBS model includes sitework costs in its capital cost estimate. These costs are from RS Means (2013) and are intended to reflect industry-standard construction practices. Consequently, the sitework cost estimate will include the costs of BMPs to control storm water under the Phase II Storm Water Rule.
Aggregate costs for application preparation and fees vary by technology and system size because construction sites vary. Costs are incurred only for construction sites of one acre or more. The WBS models estimate site size and will apply the costs as appropriate.
Permits for Air Pollution
The Clean Air Act (CAA) regulates emissions of 187 hazardous air pollutants (HAPs), including pollutants that can be removed from water using air stripping technologies (e.g., multi-stage bubble aeration and packed tower aeration). These contaminants include several volatile organic compounds regulated in drinking water (e.g., benzene, tetrachloroethylene, trichloroethylene, and xylenes) (USEPA, 2005b). HAPs also include metal compounds (e.g., arsenic, beryllium, and cyanide compounds), although these are unlikely to be released as air pollutants from water treatment facilities. Facilities that are regulated under these provisions must meet technology-based national emissions standards for the HAPs (i.e., NESHAPs).
Generally, drinking water facilities are unlikely to be regulated as stationary sources of HAPs because the industry is not listed as a specifically regulated source, and because they will not emit HAPs in sufficient quantities to be considered a "major" source.
Certain drinking water treatment plants may be subject to the requirements of section 112(r) of the CAA, which requires owners or operators of facilities meeting certain criteria to have a risk management program and file a risk management plan (RMP). The regulations in 40 CFR 68 apply to stationary sources that have more than a threshold quantity of a regulated substance in a process. Drinking water treatment utilities are the owners or operators of facilities that can be considered a `stationary source.' The WBS models include the following regulated substances, shown with their threshold quantities (40 CFR 68.130):
2,500 pounds of chlorine
15,000 pounds of hydrochloric acid (at concentrations of 37% or greater).
The 2020 version of the WBS unit cost database (cl.xls) indicates that all of the hydrochloric acid prices are for products at a 36% concentration, which is below the 37% threshold. Therefore, the WBS designs would not trigger RMP costs for any chemical quantities. For the chlorine disinfection model, the 30-day storage quantity exceeds the 2,500 pounds threshold at an average flow of 2 mgd, given the default 5 mg/L dose for primary disinfection. The WBS model logic compares the 30-day storage requirement against the 2,500 pound threshold and includes an RMP cost when applicable.
The RMP cost is a function of compliance requirements, which vary across three program levels that distinguish lower (Program 1) from higher (Program 3) potential health risks. Chlorine and hydrochloric acid are listed as `highly hazardous chemicals, toxics and reactives under 29 CFR 1910.119, through which Occupational Safety and Health Administration (OSHA) regulates Process Safety Management procedures that protect worker health and safety in accidental chemical releases. Therefore, drinking water processes subject to RMP requirements are automatically subject to Program 3 requirements regardless of the secondary containment structures and buffer areas in the WBS models. Burden estimates for Program 3 requirements include:
understanding applicable requirements
conducting an offsite consequence analysis (OCA) of a worst-case and alternative release scenarios
developing a prevention program that addresses process hazards through controls, mitigation systems, and detection systems
preparing and submitting an RMP.
The RMP for a Program 3 process documents the results of the OCA, the prevention program, information for emergency response steps and coordination with the Local Emergency Planning Committee plan; and certification of the accuracy of the information submitted. RMP updates every five years will also include a five-year accident history, identifying each incident that caused specific on-site or offsite impacts from a release of a regulated substance held above its threshold in a covered process.
Exhibit 9 shows the reported costs (in 2017 dollars) for each activity by size of non-manufacturing entity (USEPA, 2019a). Costs comprise private sector labor costs. Abt escalated total costs from 2017 dollars to 2020 dollars using an Employment Cost Index for private sector employees in management, professional, and related occupations (BLS, 2020b). USEPA (2019a) does not provide an explanation of how source size is determined. Consequently, we do not know whether size should be based on service population or chemical quantities. The WBS cost database contains a single value for RMP-related costs. To combine both costs estimates into a single value, we calculated a simple mean of $3,200 for the WBS model.
Exhibit 9. Cost Estimates to Meet Risk Management Plan and Program Requirements
for New Sources
Non-Manufacturing Source Size
Rule Familiarization (and OCA)
Prevention Program and Documentation
RMP Preparation and Submission
Total (2017 dollars)
Total (2020 dollars)
Small/Medium
                                                                           $606
                                                                           $303
                                                                           $322
                                                                         $1,221
                                                                         $1,379
Large
                                                                         $2,088
                                                                         $1,619
                                                                           $771
                                                                         $4,478
                                                                         $5,057
Average (rounded to nearest $100)
                                                                         $3,200
Source: USEPA, 2019a. Values escalated from 2017 dollars to 2020 dollars using the Employment Cost Index for total compensation for private sector workers in management, professional, and related occupations, which had an average value of 129.625 in 2017 and a first quarter value of 137.9 in 2020 (BLS, 2020b).
Although no permit is issued, the cost of developing a risk management program and an RMP is a start-up cost associated with federal regulatory requirements that can be incorporated as a capital cost in the WBS models. The WBS cost estimate does not include costs for state review and approval because such approval is not required.
Permits for Waste Disposal
Water treatment plants generate solid waste in the form of spent filtration media, contaminants removed from raw water (e.g., heavy metals), compounds formed from the addition of chemicals during the purification process (e.g., as a result of adding coagulants such as aluminum sulfate), and materials used for cleaning membranes and other parts. Depending on the nature of the raw water and the treatment process, some of these wastes may be considered hazardous or radioactive waste. In addition, for facilities that apply dewatered sludge to land, such application is regulated under the CWA.
Some treatment technologies, when used to remove certain contaminants, may generate hazardous waste. For instance, filtration technologies may accumulate sludge that contains hazardous contaminants (e.g., heavy metals) present in raw water. Disposal of hazardous waste is regulated by Subtitle C of Resource Conservation and Recovery Act (RCRA). Regulated entities that generate hazardous waste are subject to reporting and record keeping requirements. These entities are also subject to RCRA permitting requirements, and classified as Treatment, Storage and Disposal Facilities, if they store waste onsite for more than 90 days after it is generated (for generators of more than 1,000 kilograms per month) or more than 180 days after it is generated (for generators of 100 to 1,000 kilograms per month) (40 CFR 262). EPA assumed that water treatment facilities would not store any hazardous waste onsite for the threshold periods and, therefore, only recurring record keeping and reporting burdens apply; there are no start-up expenditures to obtain a permit.
Some treatment technologies may generate radioactive waste. For example, filter or adsorptive media that remove groundwater contaminants may accumulate radioactive materials present in the raw water such as uranium (USEPA, 2005a). Treatment processes may also remove radioactive contaminants to meet drinking water standards for alpha emitters, beta and gamma emitters, radium-226, radium-228, and uranium. Doing so concentrates these contaminants in treatment process residuals.
The Atomic Energy Act (AEA) regulates the processing and utilization of three categories of nuclear materials: source, special, and byproduct. Source material generally refers to thorium or uranium with a uranium-235 content less than 0.71%. Special nuclear materials refers to plutonium and enriched uranium (e.g., uranium-233 isotope or uranium-235 > 0.71%). Byproducts are radioactive materials that are not source or special materials; they include materials that have become radioactive through exposure to nuclear materials, tailings or wastes from uranium or thorium extraction, sources of radium-226, and sources of naturally occurring radioactive material (NORM) that pose a public health threat similar to radium-226 and are "extracted or converted after extraction for use in a commercial, medical, or research activity" [AEA Sec 11 e(4)(B)]. Based on these definitions, treatment processes that remove uranium may be subject to source material requirements and processes that remove radium-226 and other radionuclides that pose similar health risks may be subject to the byproduct requirements.
Regulatory requirements include obtaining a license to use or transport nuclear materials and complying with oversight inspections. The U.S. Nuclear Regulatory Commission (NRC) implements the AEA in conjunction with 37 Agreement States. These agencies license and inspect the handling and disposal of source, special, and byproduct nuclear materials.
Licensing requirements vary by the nuclear material quantity. If treatment process residuals contain less than 0.05 percent source material by weight, then they are considered an "unimportant quantity" that is exempt from licensing. If the source material exceeds this threshold, but the total amount in possession any time does not exceed either 7 kilograms (kg) (15.4 pounds) at any one time or the total during a calendar year does not exceed 70 kg (154 pounds), then it is a "small quantity" that is subject to a general license [10 CFR 40.22 (a)(3)]. The general NRC license has no application requirements and, therefore, no application costs. Quantities that exceed these thresholds require a specific license issued by the NRC or an agreement state. Obtaining and maintaining a specific license is costly. For example, the NRC estimates the initial facility burden to complete application Form 313 is 40 hours (NRC, 2008). Using the NRC labor cost in 2013 of $297 per hour, the cost of the initial form is $10,920 (NRC, 2013); implementation costs impose additional burdens on licensed facilities.
The NRC (2011) notes that despite an estimate that up to 500 systems would need to remove uranium to comply with the uranium drinking water standard, only one system obtained a specific license for uranium removal. Reasons given for unexpectedly low specific licensing demand (or requests for enforcement discretion) included systems using alternative water sources, using treatment to remain below the exemption for unimportant quantities, operating within the constraints of the general license for small quantities of source material, and deferring treatment (NRC, 2011). The NRC (2011) concluded that "most CWSs are able to operate within the confines of the existing general license requirements." Therefore WBS models do not contain permitting costs associated NRC specific licenses because this cost is expected to be rare and will be dealt with on a case-by-case basis.
There are, however, annual NRC licensee fees for entities with general licenses. These fees are assessed because the NRC must recover approximately 90 percent of its annual budget through fees. In 2019, the NRC finalized a regulatory revision that reclassified community water systems from the 2.A (5) fee category to the 2.F category (other source material licenses) because systems do not recover or concentrate uranium for profit (NRC, 2019). The annual fee in 2019 and 2020 for category 2.F is $9,300 (NRC, 2019), which would be an O&M cost instead of an upfront permit cost. The NRC also provides reduced license fees for small entities. Exhibit 10 shows the small entity size thresholds and corresponding maximum fees. For the WBS model, when uranium quantities meet small quantities criteria, we recommend including licensee O&M expenses for of $900 to radioactive waste disposal costs systems serving fewer than 20,000 people. For systems serving 20,000 to 49,999 people, the annual fee is $4,500. For systems serving 50,000 or more people, the annual fee is $9,300.
Exhibit 10. Small Entity Annual Fee Maxima by Type of Small Entity and Fee Threshold
Small Entity Category
Maximum Fee of $900
Maximum Fee of $4,500
Business
                      < $485,000 annual gross receipts
                 $485,000 to $7 million annual gross receipts
Not-for-Profit
                      < $485,000 annual gross receipts
                 $485,000 to $7 million annual gross receipts
Government
                            < 20,000 population
                          20,000 to 49,999 population
Source: NRC, 2019. The NRC calculates fees on a biennial basis. Thus, these fees apply for 2019 and 2020.
Certain treatment technologies can generate sludge. Depending on the volume of sludge, concentration of solids, and other circumstances, facilities may discharge the sludge to a POTW (possibly after pretreatment such as settling), or they may dewater the sludge and land apply it. Land application of sludge by water treatment plants is regulated under RCRA, as implemented by 40 CFR 257. The pertinent regulations of 40 CFR 257 constrain application practices to decrease harmful effects to floodplains, endangered species, and surface and ground water supplies; minimize disease spreading and air pollution; and, regulate application on agricultural lands. However, there are no record keeping or reporting requirements except for entities that receive waste from other producers. Therefore, there are no start-up costs to comply with this requirement. Thus, the costs associated with hazardous waste are recurring O&M costs for disposal and reporting for onsite quantities and, therefore, are not associated with permits.
Storage Tanks
Many of the chemicals used by drinking water treatment facilities may be hazardous to human health. For example, aluminum sulfate, which is commonly used as a coagulant to aid filtration, is corrosive; lime (calcium hydroxide), which is used to soften hard water, is an irritant; and, chlorine gas, which is used as a disinfectant, is poisonous (Kawamura, 2000). For the WBS cost models, EPA assumes that all chemicals are stored in aboveground storage tanks with secondary containment structures and in enclosed buildings. Facilities are more likely to use aboveground tanks as opposed to underground tanks because both tank integrity and chemical volume are easier to monitor for aboveground tanks.
There are no federal regulations governing aboveground storage tanks, other than those containing petroleum. Thus, there are no permitting costs associated with chemical storage. Although the Emergency Planning and Community Right-to-Know Act (EPCRA) has reporting requirements for facilities that manufacture, process, or otherwise use certain hazardous chemicals above threshold quantities, there are no start-up costs associated with EPCRA planning and EPA includes labor costs that are intended to cover these requirements (e.g., submission of materials safety data sheets) in the O&M costs for the WBS models.
National Environmental Policy Act Compliance Requirements
New treatment facilities with a federal nexus (i.e., funded, authorized, permitted, or carried out by a federal agency) will need to comply with National Environmental Policy Act (NEPA) requirements. NEPA requires federal agencies to evaluate the environmental and related social and economic impacts of their actions. There are different levels of review that depend on the potential for environmental impacts. Possible levels of review and outcomes  -  in order of complexity  -  are a project review to identify a categorical exclusion, an environmental assessment and a finding of no significant impact, and an environmental impact statement.
For a NEPA review, the applicant planning an action such as a new treatment process will incur burden to prepare the materials that describe the potential for environmental impact. EPA (or another agency) will incur burden to review the materials and make a decision. USEPA (2019b) reported the applicant and EPA burden estimates shown in Exhibit 11. Total costs range from $7,068 for a categorical exclusion to $275,713 for a full environmental impact statement.
Exhibit 11. Burden Estimates and Costs for NEPA Compliance
NEPA Study
EPA Burden Hours
EPA Cost [a]
Applicant Burden Hours
Applicant Cost [b]
Total Cost (2018 dollars)
Total Cost (2020 dollars)[c]
Categorical Exclusion
                                      50
                                    $2,613
                                      50
                                    $4,179
                                    $6,792
                                    $7,068
Environmental Assessment
                                      120
                                    $6,271
                                      260
                                    $21,728
                                    $27,999
                                    $29,138
Environmental Impact Statement
                                      530
                                    $27,598
                                     2,840
                                   $237,339
                                   $264,937
                                   $275,713
Source: USEPA, 2019b
a. The labor cost assumption of $52.26 per hour (2018 dollars) is based on the GS 11, Step 9 wage rate of $32.66 and burden factor of 60%.
b. The labor cost assumption of $83.57 per hour (2018 dollars) is based on a wage rate of $58.44 for occupations among wastewater grant and permit recipients and burden factor of 43%.
c. Values escalated from 2018 dollars to 2020 dollars using the Employment Cost Index for Total compensation for All Civilian Workers  -  Management, professional and related occupations, which had an average value of 133.375 in 2018 and a first quarter value of 138.8 in 2020 (BLS, 2020a).
As noted above, only treatment projects with a federal nexus will incur costs for a federal NEPA review, although states may also have environmental review requirements. The number of systems requiring a NEPA review is not known. The only variable in the WBS models that would trigger a NEPA review is the surface water discharge option for liquid residuals. A surface water discharge would require a NPDES permit (or state equivalent), which necessitates an environmental assessment. Therefore, we recommend that the WBS models include a cost of $29,100 (rounded to the nearest $100) for all designs that include the surface water discharge design option.
There are no data indicating the share of water treatment trains that may incur any NEPA costs, or which type of review. A Council on Environmental Quality (CEQ) estimate that less than 1 percent of NEPA analyses result in an Economic Impact Analysis (GAO, 2014) indicates that the highest cost study is rare. The study provides no indication of how frequently construction projects require a NEPA analysis, however. There are some federal water systems, which would incur NEPA costs for new construction, but the national cost simulations do not identify when federal systems incur treatment costs.

Summary and Discussion
This section summarizes the permit cost estimates provided in Section 3 and provides a comparison between current permit costs in the WBS models and the updated costs (Exhibit 12). The update of radionuclide waste-related costs also resulted in annual fees to include in O&M costs.
Exhibit 12. Summary of Updated Permit Costs for WBS Models
Parameter
2013 Value (2013 dollars)
Updated Value (dollar year varies)
Building Permit
                              UBC (1997 version)
UBC (1997 version) plus multiplier (dollar year depends on building cost dollar year)
NPDES Permit
                                                                    <0.1 mgd
                                                                  0.1  -  1 mgd
                                                                     >1 mgd

                                    $2,600
                                    $3,200
                                    $5,500

                                $2,300 ($2020)
                                $2,900 ($2020)
                                $5,300 ($2020)
POTW Pretreatment
                                     None
                                $2,600 ($2020)
Stormwater Permit
                                                                   1 to 5 acres
                                                                    >5 acres

                                    $2,200
                                    $2,300

                                $1,700 ($2020)
                                $2,600 ($2020)
Risk Management Plan
                                    $1,700
                                $3,200 ($2020)
NEPA Review[a]
                                                                NPDES discharge

                                      NA

                                $29,100 ($2020)
Source: SAIC (2013)
a. The values from SAIC (2013) only reflect the cost of reviews under ESA. The recommended values include all activities for either a categorical exemption or an environmental assessment. The latter values also include a probability weight that reflects the share of systems that are publicly owned and, therefore, are more likely to have a federal nexus that triggers a NEPA review.  The NEPA costs in SAIC (2013) were $1,600 for designs where land acreage was less than 1 acre and $6,300 for designs where land acreage exceeded 1 acre. The WBS models only included NEPA costs under a high-cost scenario. The ad hoc basis for the acreage assumption and the high-cost application introduces uncertainty.
There are a number of limitations and uncertainties inherent in the method and data used to estimate permit costs. Exhibit 13 summarizes the sources of potential bias, and the potential impact on the cost estimates. In most instances, the direction of potential bias is unknown. By switching the NEPA costs from applying to all systems under high-cost designs to applying only when there is a known federal nexus for a surface water discharge, the direction of bias is potentially downward  -  i.e., tending to understate costs because there are other types of federal nexus that would trigger either an environmental assessment or at least a review to identify a categorical exclusion.
Exhibit 13. Sources of Uncertainty in the Analysis
Source
Potential Impact
Comment
Building permit cost based on UBC permit fee schedule
                                      +/-
Average permit costs in locations affected by a particular rule may be higher or lower than the UBC fee schedule and fee multiplier.
Environmental permit fees based on averages costs across selected states
                                      +/-
National average for a particular rule may be higher or lower depending on distribution of affected systems across states.
NEPA costs only included for known federal nexus of surface water discharge
                                       -
Linking NEPA costs to known federal nexus may underestimate cost for systems that have a nexus not related to a model input or parameter
Some ICR burden estimates represent averages across many types of industries
                                      +/-
Drinking water systems may have higher or lower permit application burdens than the averages used for ICR analysis.
+/- = impact of assumption on cost estimates is unknown.
= impact of assumption on cost estimates is to under estimate costs.

References
Bureau of Labor Statistics (BLS). 2020a. Employment Cost Index:  Total compensation for all civilian workers in management, professional, and related. Retrieved from https://data.bls.gov/PDQWeb/ci.
BLS. 2020b. Employment Cost Index:  Total compensation for private industry workers in management, professional, and related. Retrieved from https://data.bls.gov/PDQWeb/ci.
BLS. 2020c. Employment Cost Index:  Total compensation for state and local government workers in all industries and occupations. Retrieved from https://data.bls.gov/PDQWeb/ci.
Government Accountability Office (GAO). 2014. National Environmental Policy Act: Little Information Exists on NEPA Analyses. GAO-14-396. Retrieved from https://www.gao.gov/products/GAO-14-369.
International Conference of Building Officials. 1997. Uniform Building Code. Pasadena, CA: International Conference of Building Officials.
International Code Council (ICC). 2018. Building Valuation Data  -  February 2018. Retrieved from https://cdn-web.iccsafe.org/wp-content/uploads/BVD-0218.pdf.
Kawamura, S. 2000. Integrated Design and Operation of Water Treatment Facilities. New York: John Wiley & Sons.
Moran, M.J., W.W. Lapham, B.L. Rowe, and J.S. Zogorski. 2002. Occurrence and Status of Volatile Organic Compounds in Ground Water from Rural, Untreated, Self-Supplied Domestic Wells in the United States, 1986-99. U.S. Department of the Interior, U.S. Geological Survey. Water Resources Investigations Report 02-4085. Retrieved from http://sd.water.usgs.gov/nawqa/.
Nuclear Regulatory Commission (NRC). 2008. Justification for Change in An OMB Clearance Package Form 313 and 313a Series of Forms. Retrieved from < http://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=200805-3150-003>.
NRC. 2011. NRC Regulatory Issue Summary 2006-20, Rev. 1 Guidance for Receiving Enforcement Discretion When Concentrating Uranium at Community Water Systems. Retrieved from http://pbadupws.nrc.gov/docs/ML1120/ML112031215.pdf.
NRC. 2013. Final OMB Supporting Statement for Final Rule 10 CFR Parts 30, 40, 70, 170, and 171: Distribution of Source Material to Exempt Persons and to General Licensees and Revision of General License and Exemptions. Retrieved from http://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201307-3150-004.
NRC. 2019. Revisions of Fee Schedules; Fee Recovery for Fiscal Year 2019. 84 Federal Register 22331. May 17, 2019. EPA 816-R-05-004.
Rowe, B., S. Grady, J. S. Zogorski, B. Koch, and P. Tratnyek. 2001. Initial Findings: National Survey of MTBE, Other Ether Oxygenates, and Other VOCs in Community Drinking-Water Sources. U.S. Department of the Interior, U.S. Geological Survey. Retrieved from http://sd.water.usgs.gov/nawqa/.
RSMeans. 2013. Facilities Construction Cost Data 2014. 29th Annual Edition. Norwell, Massachusetts: Reed Construction Data LLC.
Science Applications International Corporation (SAIC). 2013. Permitting Requirement Costs for Drinking Water Treatment Cost Models. McLean, VA: SAIC.
U.S. Environmental Protection Agency (USEPA). 1996. Proceedings of the Blue Ribbon Panel on Safe Drinking Water Act Costing. Washington, D.C.: USEPA, Office of Ground Water and Drinking Water.
USEPA. 2005a. A Regulators' Guide to the Management of Radioactive Residuals from Drinking Water Treatment Technologies. Retrieved from https://www.epa.gov/radiation/regulators-guide-management-radioactive-residuals-drinking-water-treatment-technologies.
USEPA. 2005b. Initial List of Hazardous Air Pollutants with Modifications. Retrieved from https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications.
USEPA. 2009. 2006 Community Water System Survey, Volume II: Detailed Tables and Survey Methodology. EPA 815-R-09-002. Washington, D.C.: U.S. EPA, Office of Water.
USEPA. 2010. Guidelines for Preparing Economic Analyses. Washington, D.C.: USEPA, Office of the Administrator. Updated May 2014.
USEPA. 2015a. ICR Supporting Statement Information Collection Request for National Pollutant Discharge Elimination System (NPDES) Program (Renewal). Retrieved from https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201703-2040-001
OMB Control No. 2040-0004, EPA ICR No. 0229.21.
USEPA. 2015b. ICR Supporting Statement Information Collection Request: National Pretreatment Program. Retrieved from https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201512-2040-007.
USEPA. 2019a. Supporting Statement for EPA Information Request 1656.16  -  Risk Management Program Requirements and Petitions to Modify the List of Regulated Substances under Section 112(r) of the Clean Air Act (CAA) (Renewal). Retrieved from https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201908-2050-003.
USEPA. 2019b. Supporting Statement for Renewal of Information Collection Requirements under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. 40 CFR Part 6: Procedures for Implementing the National Environmental Policy Act and Assessing the Environmental Effects Abroad of EPA Actions. Retrieved from https://beta.regulations.gov/document/EPA-HQ-OA-2019-0296-0002.
USEPA. 2020a. ECHO Database. Retrieved from https://echo.epa.gov/facilities/facility-search?mediaSelected=all.
USEPA. 2020b. Safe Drinking Water Information System, Federal Reports. Retrieved from https://ofmpub.epa.gov/apex/sfdw/f?p=108:1:::NO:1::.

Appendix A. Permit Cost Information from States and Local Jurisdictions
This appendix contains permit fee information collected from State and local jurisdiction websites and from personal communication with local jurisdiction personnel. Exhibit A-1 provides building permit fee schedules for the jurisdictions included in Section 3.1.
Exhibit A-1. Building Permit Fee Schedules (2020$)
State (Jurisdiction)
Fee Schedule
Florida (Tampa)
Building Permit Fee: (based on building size and type)
For size up to 2,000 sf, $2,666; plus $18.00 for each additional 100 sf
For sizes from 2,001 to 10,000 sf, $4,080 plus $7.00 per each additional 100 sf
For sizes from 10,001 to 20,000 sf; $4,678 plus $11.00 per each additional 100 sf
For sizes from 20,001 to 40,000 sf; $6,635 plus $4.00 per each additional 100 sf
For sizes from 40,001 to 100,000 sf; $8,551.00 plus $2.00 per each additional 100 sf
For sizes from 100,001 to 200,000 sf; $9,920.00 plus $6.00 per each additional 100 sf
Indiana (Westfield)
Building Permit Fee: $800 plus $0.20 per sf
Texas (Sealy)
Building Permit Fee: (based on valuation)
$25 for valuation up to $1,000 (if inspection is required)
For valuation of $1,001 to $50,000, $25 for the first $1,000 plus $5 for each additional $1,000
For valuation of $50,001 to $100,000, $260 for the first $50,000 plus $4 for each additional $1,000
For valuation of $100,001 to $500,000, $460 for the first $100,000 plus $3 for each additional $1,000
For valuation over $500,001, $1,660 for the first $500,000 plus $2 for each additional $1,000
Building Plan Check Fee: 50% of the building permit fee (for commercial structures)
Electrical Permit Fee: $25 plus fees dependent on amperage and fixtures
Plumbing Permit Fee: $25 plus fees dependent on fixtures
Mechanical Permit Fee: $25, plus $10 for the first $1,000 of valuation, plus $2 for each additional $1,000 of valuation (based on HVAC valuation), plus inspection fees
Fire Alarm Systems Permit fee: $25 plus $50 for 1-10 devices
Louisiana
(Lake Charles)
Building Permit Fee: (based on valuation)
$25 for valuation up to $5,000 (if inspection is required)
For valuation of $5,001 to $15,000, $25 for the first $5,000 plus $4 for each additional $1,000
For valuation of $15,001 to $100,000, $65 for the first $15,000 plus $3.50 for each additional $1,000
For valuation of $100,001 to $500,000, $362.50 for the first $100,000 plus $2.25 for each additional $1,000
For valuation over $500,000, $362.50 for the first $500,000 plus $2 for each additional $1,000, plus technology fee of $25.00
Plan review fee (commercial construction)
For new construction <1,000 sq. ft. of building area or renovation work, <$100,000, $50
For new construction 1,000 sq. ft. up to 190,000 sq. ft. of building area or renovation work, $100,000 to $300,000, $100
For new construction greater that 10,000 sq. ft. to 50,000 sq. ft. or renovation work over $300,000 to $600,000, $200
For new construction over 50,000 sq. ft. or renovation work over $600,000, $300
Illinois (Bloomington)
Building Permit Fee: (based on valuation)
$32 for valuation up to $1,000
For valuation of $1,001 to $5,000, $32 for the first $1,000 plus $0.86 for each additional $100 (up to a maximum of $62)
For valuation of $5,001 to $10,000, $75 for the first $5,000 plus $0.58 for each additional $100 (up to a maximum of $89)
For valuation of $10,001 to $50,000, $104 for the first $10,000 plus $0.47 for each additional $100 (up to a maximum of $265)
For valuation of $50,001 to $100,000, $292 for the first $50,000 plus $0.39 for each additional $100 (up to a maximum of $445)
For valuation of $100,001 to $500,000, $487 for the first $100,000 plus $0.31 for each additional $100 (up to a maximum of $1,605)
For valuation of $500,001 to $1,000,000, $1,727 for the first $500,000 plus $0.29 for each additional $100 (up to a maximum of $2,995)
For valuation of $1,000,001 to $5,000,000, $3,177 for the first $1,000,000 plus $0.25 for each additional $100 (up to a maximum of $12,355)
For valuation of $5,000,001 to $10,000,000, $13,177 for the first $5,000,000 plus $0.22 for each additional $100 (up to a maximum of $22,605)
For valuation of $10,000,001 to $50,000,000, $24, 177 for the first $10,000,000 plus $0.17 for each additional $100 (up to a maximum of $86,605)
For valuation of $50,000,001 to $100,000,000, $92,177 for the first $50,000,000 plus $0.14 for each additional $100 (up to a maximum of $154,105)
For valuation over $100,000,000, $162,177 for the first $100,000,000 plus $0.10 for each additional $100
Plan review fee (commercial construction):
$20 for valuation up to $500
$30 for valuation of $500 to $1,000
For valuation of $1,001 to $20,000, $30  for the first $1,000 plus $2.40 for each additional $100
For valuation of $20,001 to $50,000, $496 for the first $20,000 plus $0.42 for each additional $100
For valuation of $50,001and over, $612 for the first $50,000 plus $0.24 for each additional $100
Electrical Permit Fee: (based on electrical valuation)
$30 for valuation up to $500
$50 for valuation of $500 to $1,000
For valuation of $1,001 to $10,000, $50 for the first $1,000 plus $1.75 for each additional $100
For valuation of $10,001 to $50,000, $207.50 for the first $10,000 plus $0.55 for each additional $100
For valuation over $50,000, $427.50 for the first $50,000 plus $0.35 for each additional $100
Mechanical Permit Fee: (based on HVAC valuation)
$20 for valuation up to $500
$30 for valuation of $500 to $1,000
For valuation of $1,001 to $20,000, $30 for the first $1,000 plus $2.40 for each additional $100
For valuation of $20,001 to $50,000, $486 for the first $20,000 plus $0.42 for each additional $100
For valuation over $50,000, $612 for the first $50,000 plus $0.24 for each additional $100
Plumbing Permit Fee: Based on fixtures, with minimum of $30
Virginia (Spotsylvania County)
Building Permit Fee: $0.13 per sf; $150 minimum
Plan Review Fee: $0.11 per sf; $150 minimum
Electrical Permit Fee: $1.15 per amp; $170 minimum
Mechanical Permit Fee: $0.05 per sf of gross building area or $170 minimum plus $30 per fire damper
Plumbing Permit Fee: $170 plus $30 per fixture
North Carolina (Charlotte/
Mecklenburg County)
Building Permit Fee:
For construction cost of $1 to $3,000, $59.70
For construction cost of $1 to $7,001, $79.61 minimum Fee-Commercial Projects requiring plan review
For construction cost of $3,001 to $50,000, $59.70 plus $12.19 per $1,000 or part over $3,000
For construction cost of $50,001 to $100,000, $632.57 plus $5.93 per $1,000 or part over $50,000
For construction cost of $100,001 to $150,000, $907.12 plus $5.93 per $1,000 or part over $100,000
For construction cost of $150,001 to $250,000; $1,203.52 plus $4.59 per $1,000 or part over $150,000
For construction cost of $250,001 to $1,000,000; $1,662.37 plus $5.05 per $1000 or part over $250,000
For construction cost of $1,000,001 to $10,000,000, $5,445.74 plus $2.64 per $1,000 or part over $1,000,000
For construction cost over $10,000,000, $29,214.74 plus $1.35 per $1,000 or part over $10,000,000
Plan Review Fee:
For small commercial projects  -  construction less than 1 denuded acre; $1,500
For large commercial projects  -  construction more than 1 denuded acre; $8,600 plus $250.00/denuded acre
South Carolina (West Columbia)
Building Permit Fee:
For construction value of $1 to $100,000, $3 per $1,000 or fraction thereof ($25 minimum)
For construction value of $100,001 to $500,000, $300 plus $2 for each additional $1,000 or fraction thereof above $100,001
For construction value over $500,000, $1,100 plus $1 for each additional $1,000 or fraction thereof above $500,000
Electrical Permit Fee:
For value of $1 to $3,999, $25
For value of $4000 to $50,000, $25 plus $4 per $1,000 or fraction thereof
For value of $50,000 to $100,000, $225 plus $3 per $1,000 over $50,000
For value of $100,000 to $150,000, $375 plus $2.50 per $1,000 over $100,000
For value of $150,000 to $200,000, $500 plus $2 per $1,000 over $150,000
For value of $200,000 and up, $600 plus $1 per $1,000 over $200,000
Mechanical Permit Fee: (based on HVAC valuation)
For value $0 to $1,000, $25
For value over $1,000, $25 plus $2 per $1,000 of additional value over $1,000
Plumbing Permit Fee:
$5 per fixture, $15 minimum
$20 per sewer hook-up
Louisiana
(Port Allen)
Building Permit Fee:
For construction values up to $100,000, $3.00  per $1,000 ($40 minimum)
For construction values from $100,001 to $500,000, $300 plus $2.00 per $1,000 over $100,000
For construction values greater than $500,000, $1,100.00 plus $1.50 per $1,000 over $500,000
Electrical Permit Fee:
service charge: $8 through 60 amps, $12 through 100 amps, $14 through 200 amps, $16 through 400 amps, $18 through 600 amps, $20 through 800 amps, $22 through 1000 amps, $24 through 1200 amps, $26 through 1400 amps, $30 through 1600 amps, $34 through 1800 amps, $38 through 2000 amps, $42 through 2400 amps, $46 through 2500 amps
Mechanical Permit Fee:
$20 plus 40.00 per ton for A/C from 0 to 4 tons
$20 plus 59.00 per ton for A/C from 5 to 10 tons
$20 plus 7.00 per ton for A/C greater than 10 tons
Plumbing Permit Fee:
$20 plus $6 for each additional fixture to 100, $5.00 for each additional fixture after 100
$25 for sewer connection
Minnesota
(Rice County)
Building Permit Fee:
For valuation up to $500, $23.00
For valuation of $501 to $2,000, $23.50 for the first $500 plus $3.05 for each additional $100 or fraction thereof
For valuation of $2,001 to $25,000, $69.25 for the first $2,000 plus $14.00 for each additional $1,000 or fraction thereof
For valuation of $25,001 to $50,000, $391.75 for the first $25,000 plus $10.10 for each additional $1,000 or fraction thereof
For valuation of $50,001 to $100,000, $643.75 for the first $50,000 plus $7.00 for each additional $1,000 or fraction thereof
For valuation of $100,001 to $500,000, $993.75 for the first $100,000 plus $5.60 for each additional $1,000 or fraction thereof
For valuation of $500,001 to $1,000,000, $3,233.75 for the first $500,000 plus $4.75 for each additional $1,000 or fraction thereof
For valuation of $1,000,001 and up, $5,608.75 for the first $1,000,000 plus $3.15 for each additional $1,000 or fraction thereof
Washington
(Clark County)
Building Permit Fee:
$94 for permit issuance
For valuation up to $5,000, $150.00
For valuation of $5,001 to $10,000, $250.00
For valuation of $10,001 to $25,000, $250.00 for the first $10,000 plus $16.67 for each additional $1,000
For valuation of $25,001 to $50,000, $500.00 for the first $25,000 plus $13.00 for each additional $1,000
For valuation of $50,001 to $100,000, $825.00 for the first $50,000 plus $8.00 for each additional $1,000
For valuation of $100,001 to $500,000, $1,225.00 for the first $100,000 plus $6.00 for each additional $1,000
For valuation of $500,001 to $1,000,000, $3,625.00 for the first $500,000 plus $5.00 for each additional $1,000
For valuation of $1,000,000.01 to 5,000,000, $6,125.00 for the first $1,000,000 plus $4.00 for each additional $1,000
For valuation of 5,000,000.01 and up, $22,125.00 for the first $5,000,000 plus $2.00 for each additional $1,000
Plan Review Fee: 65% of permit fee
Mechanical Permit Fee:
$94.00 for permit issuance
Fees ranging from $29 to $89 for various mechanical units and connections
Plumbing Permit Fee:
$94.00 for permit issuance
$192 for up to 5 plumbing fixtures; $35 for each additional fixture
Fees ranging from $35 to $178 for various units and connections
Michigan
(Bay City)
Building Permit Fee:
$35.00 for valuation up to $500
For valuation of $501 to $2,000, $35.00 for the first $500 plus $5.00 for each additional $100
For valuation of $2,001 to $25,000, $110.00 for the first $2,000 plus $23.00 for each additional $1,000
For valuation of $25,001 to $50,000, $639.00 for the first $25,000 plus $15.00 for each additional $1,000
For valuation of $50,001 to $100,000, $1,014.00 for the first $50,000 plus $11.00 for each additional $1,000
For valuation of $100,001 to $500,000, $1,564.00 for the first $100,000 plus $9.00 for each additional $1,000
For valuation of $500,001 to $$1,000,000, $5,164.00 for the first $500,000 plus $8.00 for each additional $1,000
For valuation over $1,000,001, $9,164.00 for the first $1,000,000 plus $6.00 for each additional $1,000
Plan Review Fee:
For valuation of $0 through $2,500,000.00 = $0.0015 of the Estimated Value ($60.00 Minimum)
For valuation of $2,500,000.00 through $5,000,000.00 = $3,750 Plus $0.0005 of the estimated value over $2,500,000.00
For valuation of over $5,000,000.00 = $5,000 Plus $0.0004 of the estimated value over $5,000,000.00
Electrical Permit Fee:
25% of Building Plan Review fee for each trade - $60 minimum.
Mechanical Permit Fee:
25% of Building Plan Review fee for each trade - $60 minimum.
Plumbing Permit Fee:
25% of Building Plan Review fee for each trade - $60 minimum.
Ohio (Ashtabula County)
Building Permit Fee: $150 plus $0.045 per sf
Plan Review Fee: $85 per hour
State fee on all commercial permits and plan reviews: 3% of permit and plan review cost
Electrical Permit Fee: $150 plus $0.025 per sf
Mechanical Permit Fee: $150 plus $0.045 per sf
Pennsylvania (Middletown Borough)
Building Permit Fee:
For construction cost up to $500, base fee of $15
For construction cost from $501 to $1000, base fee of $22.00
For construction cost from $1001 to $2000, base fee of $33
For construction cost from $2001 to $3000, base fee of $39
For construction cost from $3001 to $4000, base fee of $45
For construction cost from $4001 to $5000, base fee of $47
For construction cost from $5001 to $7000, base fee of $60
For construction cost from $7001 to $20000, base fee of $10 per $1000 or part thereof
For construction cost from $20,001 to $50000, base fee of $9 per $1000 or part thereof ($200 minimum)
For construction cost from $50,001 and over, base fee of $8 per $1000 or part thereof ($450 minimum)
Building Permit Fee augment to base fees:
For size up to 1,000 sf, $225
For sizes from 1,001 to 5,000 sf, $75 per 1000 sf or part thereof ($225 minimum)
For sizes above 5,000 sf, $35 per 1000 sf or part thereof ($375 minimum)
Electrical Permit Fee: (based on value of electrical work)
$7.50 for $0 to $500 of electrical work
For $501 and over, $2.00 per $100 or part thereof
Mechanical Permit Fee: (based on value of HVAC work)
$15 per $1,000 of heating work
$7.50 per ton for air conditioning
Plumbing Permit Fee: (based on value of plumbing work)
$7.50 for $0 to $500 of plumbing work
For $501 and over, $2.00 per $100 or part thereof
Wisconsin (Amery)[a]
Building Permit Fee:
For valuation up to $500,000, $6 per $1,000 or part thereof·
For valuation over $500,000, $3,000 plus $5 per additional $1,000 or part thereof over $500,000
Minimum permit fee of $150
Includes plan review and electrical, mechanical, and plumbing permit fees
Florida (Dunnellon)
Building Permit Fee: 1.75% of construction costs, with minimum of $120
Commercial Plan Review Fee: $75 for the first two hours; $35 for each additional hour
Administrative Fee for all permits: $50, unless permit costs less than $120
Missouri (Hollister)
Building Permit Fee (includes electrical, mechanical, and plumbing permit fees):
For valuation up to $5,000, $4.20 per $1,000 of valuation or part thereof; $40 minimum for commercial structures
For valuation over $5,000, $40 plus $4.20 per $1,000 of valuation or part thereof over $5,000
Plan Review Fee:
For valuation under $15,000, no fee
For valuation of $15,000 to $30,000, $30
For valuation over $30,000, $1 per $1,000 of valuation or part thereof
Nebraska (Chadron)
Building Permit Fee:
For valuation up to $500, $21
For valuation of $501 to $2,000, $21 for the first $500 plus $2.75 for each additional $100 or fraction thereof
For valuation of $2,001 to $25,000, $62.50 for the first $2,000 plus $12.50 for each additional $1,000 or fraction thereof
For valuation of $25,001 to $50,000, $350 for the first $25,000 plus $9.00 for each additional $1,000 or fraction thereof
For valuation of $50,001 to $100,000, $575 for the first $50,000 plus $6.25 for each additional $1,000 or fraction thereof
For valuation of $100,001 to $500,000, $888 for the first $100,000 plus $5.00 for each additional $1,000 or fraction thereof
For valuation of $500,001 to $1,000,000, $2,888 for the first $500,000 plus $5.00 for each additional $1,000 or fraction thereof
For valuation of $1,000,001 and up, $5,012 for the first $1,000,000 plus $2.75 for each additional $1,000 or fraction thereof
Sewer Connection/Tap Fee: $100
California (Sonora)
Building Permit Fee:
Same as 1997 Uniform Building Code
For valuation up to $500, $23.50
For valuation of $501 to $2,000, $23.50 for the first $500 plus $3.05 for each additional $100 or fraction thereof
For valuation of $2,001 to $25,000, $69.25 for the first $2,000 plus $14.00 for each additional $1,000 or fraction thereof
For valuation of $25,001 to $50,000, $391.75 for the first $25,000 plus $10.10 for each additional $1,000 or fraction thereof
For valuation of $50,001 to $100,000, $643.75 for the first $50,000 plus $7.00 for each additional $1,000 or fraction thereof
For valuation of $100,001 to $500,000, $993.75 for the first $100,000 plus $5.60 for each additional $1,000 or fraction thereof
For valuation of $500,001 to $1,000,000, $3,233.75 for the first $500,000 plus $4.75 for each additional $1,000 or fraction thereof
For valuation of $1,000,001 and up, $5,608.75 for the first $1,000,000 plus $3.65 for each additional $1,000 or fraction thereof
Plan Review Fee:
65% of Building Permit Fee
Issuance Fee:
$25.00
Electrical Permit Fee: (based on value of electrical work)
$22.00 for permit issuance
Mechanical Permit Fee: (based on value of HVAC work)
$23.50 for permit issuance
Furnace unit fees:
$14.80 for forced air type furnace including ducts up to 100,000 BTU
$18.20 for forced air type furnace including ducts over 100,000 BTU
A/C unit fees:
$14.70 for A/Cs up to 3 hp and 100,000 BTU
$21.15 for A/Cs from 3 hp to 15 hp and 100,000 BTU, up to 500,000 BTU
$37.25 for A/Cs from 15 hp to 30 hp and 500,000 BTU, up to 1,000,000 BTU
$55.45 for A/Cs over 30 hp and 1,000,000 BTU, up to 1,750,000,000 BTU
$92.65 for A/Cs over 50 hp and over 1,750,000,000 BTU
Plumbing Permit Fee: (based on value of plumbing work)
$20.00 for permit issuance
$15.00 per building sewer connection
sf = square foot; hp=horsepower; HVAC = heating, ventilation, and air conditioning.
a. Amery, WI, Code Title 15 Building Code. Section 15-1-16 continues to reference Ordinance 2-2010 for building permit fees.
Sources: Ashtabula County, Ohio, No date; Borough of Middletown, Pennsylvania, No date; City of Amery, 2010 and 2020; City of Bay City, 2018; City of Bloomington, 2018; City of Chadron, 2009; City of Dunnellon, 2018; City of Hollister, 2015; City of Sealy, Texas, 2016; City of Sonora, California, 2015; City of Tampa, 2018; City of West Columbia, 2018; City of Westfield, Indiana, 2018; Clark County, Washington, 2020; County of Spotsylvania, 2019; Lupo, 2020; Mecklenburg County Government, 2019; Rice County, Minnesota, 2020; West Baton Rouge Parish (Port Allen), Louisiana, 2019.
Exhibit A-2 shows the combined building permit and related construction fees for each jurisdiction. The fees are based on the GAC building footprints and costs shown in Exhibit 2.
Exhibit A-2. Total of Building Permit and Related Costs for GAC Processes
by Jurisdiction and System Design Flow in mgd (2018$)
Jurisdiction
0.03
0.124
0.305
0.74
2.152
7.365
22.61
75.07
Tampa, FL
                                     2,666
                                     2,666
                                     2,666
                                     2,666
                                     2,846
                                     3,494
                                     4,395
                                     6,460
Westfield, IN
                                      610
                                      642
                                      666
                                      718
                                     1,198
                                     1,918
                                     3,498
                                     7,828
Sealy, TX
                                      133
                                      190
                                      255
                                      573
                                     1,657
                                     2,882
                                     4,933
                                     9,773
Lake Charles, LA
                                      80
                                      105
                                      134
                                      348
                                      863
                                     1,484
                                     2,814
                                     5,746
City of Bloomington, IL
                                      361
                                      584
                                      756
                                     1,313
                                     3,084
                                     4,714
                                     8,301
                                    15,986
Spotsylvania County, VA
                                      810
                                      870
                                     1,075
                                     1,075
                                     1,698
                                     2,956
                                     5,367
                                    11,881
Charlotte, NC
                                      60
                                      145
                                      218
                                      704
                                     1,758
                                     3,167
                                     6,273
                                     9,746
West Columbia, SC
                                      100
                                      113
                                      135
                                      284
                                      869
                                     1,521
                                     2,525
                                     4,693
Port Allen, LA
                                      117
                                      119
                                      141
                                      282
                                      743
                                     1,303
                                     2,362
                                     4,817
Rice County, MN
                                      83
                                      181
                                      265
                                      735
                                     1,940
                                     3,462
                                     6,383
                                    10,740
Clark County (Brush Prairie), WA
                                      619
                                      629
                                     1,141
                                     2,096
                                     4,351
                                     7,139
                                    12,475
                                    22,022
Bay City, MI
                                      313
                                      474
                                      612
                                     1,372
                                     1,372
                                     6,987
                                    13,521
                                    25,839
Jefferson (Ashtabula County), OH
                                      396
                                      407
                                      416
                                      434
                                      977
                                     1,396
                                     2,316
                                     4,834
Middletown Borough, PA
                                      279
                                      369
                                      454
                                      887
                                     3,553
                                     6,951
                                    15,315
                                    36,081
Amery, WI
                                      250
                                      250
                                      250
                                      478
                                     1,758
                                     3,606
                                     7,395
                                    15,590
Dunnellon, FL
                                      295