CR_15-085 Expression of limits, whole effluent toxicity, TMDL development and implementation, and other aspects of the WPDES permitting program

Clearinghouse Rule 15-085 , Natural Resources Board Order WT-11-12

Final Regulatory Flexibility Analysis

Of the 126 WPDES permit holders that are believed to be economically and fiscally impacted by the proposed rule revision, 43 dischargers are believed to be small businesses. The potentially impacted businesses include food processors, cheese makers, and other small businesses like metal finishing plants and manufacturers. WET laboratories are typically small business and would likely be positively impacted by the revisions. Using the same methods previously described, it is estimated that small cheese makers may incur a fiscal impact of $83,000-$109,000, the impact to food processors may range from $51,000-$65,500, and other small businesses may incur a cost between $24,000-$35,000 . This rule does not specify monitoring frequencies or TRE requirements. Therefore, TRE thresholds and monitoring frequencies were assumed for each permittee. Additional guidance will be developed to help clarify what appropriate monitoring frequencies may be, and when a TRE study should be considered. These decisions will be made on a case-by-case basis to ensure adequate environmental protection and reasonable reporting requirements.