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capital needs, given that the design life of the water pollution control facility would be reached in 2004. When that analysis was completed, and reviewed by MWMC as part of its ordinary budget process for FY2002-03, the capital needs were estimated at about $105 million, including the $36 million that remained from the prior planning efforts. Although this was not a formal planning effort that resulted in a comprehensive plan which the Commission would forward to the governing bodies for consideration, the magnitude of the need prompted the Commission to institute a comprehensive planning process. That process ultimately resulted in the MWMC 2004 Facilities Plan, which has been submitted by MWMC to the governing bodies. The MWMC 2004 Facilities Plan includes all of the project components contemplated by this $105 million in projected capital spending. In addition, it deals with issues which have arisen since the three previous efforts were completed. Most notably, this includes the impact of the 2002 NPDES discharge permit by DEQ, which adds additional limitations on discharges and maintains other limits, despite the growth (both current and anticipated) in the population served by the system. The impact of these changes drives the need for additional capital spending, including revisions to several of the project components contemplated by the earlier plans. This planning effort involved evaluation of a wide range of technologies and facility improvement options that could be implemented to provide maximum discharge permit compliance and capacity through 2025. Four final, viable alternatives were identified, ranging in cost from $144 million to $233 million (in 2004 dollars). The MWMC has approved a plan that will implement $144- $160 million, depending on ultimate approvals sought from DEQ. These rough cost estimates are reflected in the project cost estimates found in Table 16a. The Home Builders do support some of the proposed amendments though it has been their objections that have generated the most interest among the respective planning commissions. Other than the preceding comments regarding the two general areas of concern expressed by the Home Builders, this memorandum will direct your attention to Attachments 2 & 4, which include the written testimony submitted by the Home Builders on April 20, 2004 and on May 7, 2004, and the staff response. Without putting too fine a point on it, the staff does not share the opinions of the Home Builders with respect to what should or should not be included as part of the PFSP and Metro Plan regarding the collection and treatment of sanitary sewage, or with respect to the requirements of applicable state law regarding land use planning and the provision of urban services. Conclusion Based on the requirements of Oregon Administrative Rules, the policies of the Metro Plan, and the requirements of each jurisdiction's codes regulating Metro Plan amendments, the proposed amendments to the Metro Plan text and Public Facilities and Services Plan text, maps and tables, are consistent with applicable state law and the local criteria of approval. This conclusion is supported by the evidence in the record developed by the joint planning commissions and the general findings in Attachment 7. Attachments Attachment 1 - Planning Commission staff report, findings and proposed amendments Attachment 2 - Public Hearing Testimony and Staff Response Attachment 3 - Table of Contents of Joint Planning Commission Record Attachment 4 - Public Testimony Submitted After Hearing Close and Staff Response Attachment 5 - Oregon Administrative Rule Chapter 660 Division 11 Public Facilities Planning Attachment 6 - Ordinances Amending the Metro Plan and PFSP Attachment 7 - Findings