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RESPONSE TO WRITTEN TESTIMONY AT EUGENE CITY COUNCIL PUBLIC HEARING ON THE MWMC WASTEWATER FACILITIES PLAN AND SDC METHODOLOGY Digestion Expansion/Class A Capability, First Full Paragraph Top of Page 7 All of the projects in the 20-year project list are required either to meet specific regulatory and/or capacity requirements, involve implementation of adopted policies by the MWMC as recommended to them by Citizen's Advisory Committees, were specifically directed by the MWMC for worker and community protection (i.e., conversion of the disinfection system), or some combination of the above. The $13.8 million Digestion Expansion/Class A Capability project is an example of a project that meets multiple criteria as it contains both a component to meet specific capacity needs and a component to address a long-term policy goal of the Commission to achieve a higher level of biosolids quality (the Environmental Protection Agency's Class A criteria). As documented on page 8-12 of Section 8 of the 2004 MWMC Facilities Plan: "This project provides additional digestion capacity (approximately one third of the cost) and would convert MWMC to a Class A biosolids program (remaining two thirds of the cost) which would provide additional enhanced capability to address higher community performance standards. The allocation is split one third/two thirds between Capacity and Performance." By spending the $9.2 million (two thirds of $13.8 million), MWMC will receive the benefit of achieving a higher quality biosolids product that will give them more flexibility in terms of ultimate disposal/reuse options, and which reduces operational costs associated with administering the biosolids management program. Also, because of the higher level of performance being provided by the Class A process, MWMC is able to avoid spending $6 million on a fifth biosolids storage lagoon at the remote Biosolids Management Facility (BMF). Therefore, the net additional incremental cost of going to Class A is $3.2 million ($9.2 million minus $6 million). Finally, if MWMC chose not to convert digestion to Class A and instead opted to construct the fifth biosolids storage lagoon, the SDC rate would increase because the lagoon would be allocated to "Capacity" instead of "Performance." Referring to the 'General' column of Table C-3: Capacity Summary of MWMC Biosolids Facilities of the SDC Methodology, 100 percent of the lagoon project would be allocated to growth while only 31.8 percent of the Class A portion of the Digestion Expansion/Class A Capability project would be allocated to growth. If MWMC does not implement Class A: 100 percent of $6 million = $6 million If MWMC does implement Class A: 31.8 percent of $9.2 million = $2.9 million This example illustrates a core feature of the 2004 Facilities Plan to existing and future users. Because of the approach to enhance existing facilities that address multiple issues instead of constructing new facilities, this Plan saves MWMC money, thereby keeping sewer rates and SDCs well below the State averages. Finally, with regards to digestion technology assessment as recommended in the 2004 Facilities Plan, digestion technology advancements are a work-in-progress and will continue to evolve as additional research and development occurs. Detailed design of a Digestion Expansion/Class A Capability project is not scheduled to commence until 2011 or in 7 years. It would not be prudent to lock MWMC to a certain technology approach at this time. C:\DOCUMENTS AND SETTINGS\CEEXELF~LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK3B~AIS HBALE~rERSFROMCH2 FINAL DRAFT 061804.DOC 5