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CCR2010012-Opposing NR151 COMMON COUNCIL - CITY OF MUSKEGO RESOLUTION #012-2010 RESOLUTION REQUESTING REVISION TO THE PROPOSED SPENDING CAP FORMULA FOR SOLID POLLUTANT DISCHARGE BY MUNICIPAL WPDES PERMITEES WHEREAS, Wisconsin Administrative Code (WAC) Section NR 151.13(2)(b)2 requires municipalities possessing Wisconsin Pollutant Discharge Elimination System (WPDES) permits to implement a 40% reduction in total suspended solids (TSS) in runoff that enters waters of the state (as compared to no controls), by March 10, 2013, to the Maximum Extent Practicable (MEP); and WHEREAS, a problem exists by the use of the subjective term Maximum Extent Practicable. In the WAC, the term MEP was intended to provide a form of relief for municipalities whom the Wisconsin Department of Natural Resources (WDNR) would believe have reasonably attempted to satisfy the TSS 40% reduction standard but could not. Although municipalities appreciate the intent of this form of relief, municipalities are also afraid of the range of subjective interpretations and applications of the term MEP; and WHEREAS, the City has preliminarily achieved a reduction of 32.9% TSS in Year 2008, leaving and additional 7.1% of removal necessary; and WHEREAS, the Wisconsin Natural Resources Board is proposing the following language be inserted as a rule change that will define MEP, “The implementation of best management practices required by this section does not result in an annual expenditure greater than 0.37 dollars per thousand dollars of reported equalized value for the municipality. For purposes of this calculation, a 20 year amortization of debt service is associated with capital cost expenditures.”; and WHEREAS, according to the 2009 Equalized Values of the City of Muskego, Muskego has an Aggregate Full Value of $2,695,603,324.22; and therefore, applying a proposed annual spending cap formula of $0.37 per $1,000 of equalized value, the City's annual spending cap would be approximately $997,373.23; and WHEREAS, the City’s 2009 projected budget expenditures is $13,182,379.00, which when utilizing the proposed annual spending cap formula of $0.37 per $1,000 of equalized value, shows the City potentially spending 7.6% of its entire budget on TSS removal; and WHEREAS, the City of Muskego fully intends on complying with State laws, spending 7.6% of the City’s entire budget on TSS removal is not economically feasible; and NOW, THEREFORE, BE IT RESOLVED That the Common Council of the City of Muskego, upon the recommendation of the Finance Committee, does hereby request that the Wisconsin Natural Resources Board remove this portion of the MEP provision from the current proposed revisions to NR 151. Reso. #012-2010 Page 2 th DATED THIS 9 DAY of FEBRUARY , 2010 SPONSORED BY: FINANCE COMMITTEE Ald. Noah Fiedler Ald. Tracy Snead Ald. Keith Werner This is to certify that this is a true and accurate copy of Resolution #012-2010 which was adopted by the Common Council of the City of Muskego. _____________________________ Janice Moyer, Clerk-Treasurer