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Letter to Susie L. Smith June 23, 2004 Page 5 compensation and make the hard decisions related to issues such as System Development Charges. Such allegations don't even warrant a response. 5. Mr. Stamp frequently cites court decisions and other authorities related to Oregon's land use law. The legislature specifically provided in the System Development Charge statute that the "establishment, modification or implementation of a system development charge, or a plan or list...or any modification of a plan or list is not a land use decision." See ORS 223.314. Oregon land use laws are irrelevant. B. Allocation of Wet Weather Flow Costs. Mr. Stamp's comments in this section reflect incorrect assumptions and a lack of understanding of how infiltration and inflow (I/I) have been addressed in the local and regional collection systems. While the existing wastewater collection system does allow a much greater percentage of the total wet weather flow to enter the system, some I/I unavoidably enters the collection system in newly developing areas. That amount of I/I increases over time. Existing customers pay for the costs to reduce I/I through the local wastewater portion of rates charged by Eugene and Springfield. These investments have no relationship to the MWMC System Development Charge calculations. The I/I that occurs and increases over time must be addressed and accounted for by planning and constructing adequate peak flow capacity at the treatment plant. New developments connecting to the facilities are responsible only for a share of the peak flow capacity that is attributable to the I/I contribution of their development over time. It is a much smaller share than that borne by existing system users. While the Iii generated may be a small amount immediately after construction, the design life of a pipeline can be 50 years or greater, and the wet weather flows received by the treatment plan must be estimated to meet the demands of future conditions. Therefore, future facilities are sized to meet estimated peak flows after subtracting out the projected I/I removal achieved through the local system maintenance and rehabilitation programs. Nationwide experience over the last 25 years has shown that I/I cannot be considered simply a collection system deficiency resolved through ongoing collection system repair and rehabilitation. That is why wastewater treatment plants must be designed with capacities to handle a projected peak flow. The MWMC Wet Weather Flow Management Plan, completed in 2001, determined the most cost-effective combination of I/I work in the collection system and treatment capacity at the regional wastewater facilities. To estimate the amount of I/I from future developments, MWMC analyzed the FI contribution from selected, existing developments that were constructed within the last 20 years using construction techniques and materials similar to those used today. That analysis and the experience of other agencies resulted in the establishment of the I/I contribution amount from future developments. C. Allocation of Quality Improvement Cost. Mr. Stamp states that growth should only be assessed for the portion of the cost of meeting new and more stringent regulating requirements. He does not state, but implies, that is not what is happening. In fact it is. The cost