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choices as to how the outcomes are met and, therefore, the cost of implementation. Some <br /> of these choices include timing of construction activities (dry versus wet season), <br /> management measures to be used, maintenance of facilities, and response to violations. <br /> MEP, and therefore cost, will only become an issue if the measures undertaken by the <br /> property owner are not successful in meeting the outcomes and the City's efforts to have . <br /> these measures improved aze challenged by the property owner (on the basis of MEP). <br /> By definition, Maximum Extent Practicable means a higher than average effort. On <br /> an extremely sensitive site, in poor weather conditions, cost to protect the water quality will <br /> be higher than for the same use on a nonsensitive site during dryer conditions. A <br /> developer/owner could implement low cost practices and stay well below the MEP, or they <br /> could elect not to consider these factors and potentially spend up to the MEP. <br /> The proposed MEP cost factor contained in the Administrative Rule was based on <br /> estimated costs for implementing erosion control efforts fora 6,000 square foot single-family <br /> residence. The estimates ranged between $960 to $2700, or 16 to 45 cents per square foot <br /> of the lot assuming the entire lot azea is disturbed. The estimates were calculated by city <br /> staff and members of the Home Builders Association. For a lazger subdivision (14 acres), <br /> cost estimates were $6,500 or one cent per square foot. Costs aze expected to be on the <br /> higher side for pazcels located in sensitive areas and for construction activities occurring <br /> during the wet-weather season. Given these estimates aze based on typical conditions, the <br /> $0.50 per square foot factor of disturbed lot area appeazs reasonable given it represents a <br /> maximum level of effort. <br /> Since the program will be reviewed at the end of the first yeaz of implementation, <br /> the MEP cost amount will stay at $0.50 per squaze foot of disturbed area. As the program <br /> is implemented and more cost data is obtained it may be appropriate to consider adjustments <br /> of the MEP definition at that time. Therefore, there is no need to adjust the rule at this time. <br /> Comment 2: The cost for preparing the construction site management plan should <br /> be included as a cost for determining Maximum Extent Practicable. <br /> Finding: Cost to prepaze construction site management plans aze allowed under <br /> 6.645-D2.2. Therefore, there is no need to adjust the rule. <br /> Comment 3: Delays in getting a building permit should be included as a cost for <br /> determining Maximum Extent Practicable. <br /> Finding: The erosion program will be adequately staffed to meet the administrative <br /> needs of the program. Currently, delays in building permit issuance occur for a variety of <br /> reasons of which none are related to the erosion program. The MEP provision is directly <br /> related to the effort in preventing and/or minimizing negative water quality impacts from <br /> construction activities to the stormwater system. However, there is no direct relationship in <br /> <br /> Erosion Prevention Administrative Rule R-6.645 - 2 <br /> <br />