The proposed rule revisions are estimated to yield $38,700 in annual savings through reduced enforcement, permitting, and technical consultation workloads.
Because regulatory efficiencies cannot always be precisely measured in advance, the following cost savings reflect conservative estimates based on available workload data.
1. Prevented Level 2 (L2) Violations: $32,000 annually. Issuing a L2 Violation requires significant staff resources, due to field work, data review, team meetings, communications with the PWS, and administrative costs for preparing the letter. Each L2 costs DDW an estimated $3,200.
Assuming the new rule prevents 10% of these incidents, staff time savings are estimated at $32,000 per year.
2. Prevented Boil Orders: $1,400 annually. Preparing and issuing a Boil Order incurs approximately $1,400 in staff administrative and technical assistance costs per order. Preventing one Boil Order per year, which is a 10% reduction, yields an annual savings of $1,400.
3. Streamlined Permitting Process: $2,000 annually. Standardized submittal requirements reduce staff review time for approximately 35 chlorinator projects per year, saving an initial $2,000 annually. As the total number of installed chlorinators grows each year, DDW staff time savings will increase over time.
4. Reduced Technical Assistance: $3,300 annually. Eliminating regulatory ambiguities reduces the back-and-forth communication required between DDW staff, PWS, and engineering consultants regarding compliance and disinfection remedies, saving an estimated $3,300 in staff time each year.
