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It is possible that a small private PWS will hire an engineering firm to help them with compliance with these rules,
but the majority of these systems will be able to comply without third party assistance. EGLE will be placing
considerable emphasis on providing compliance assistance to PWSs.
24. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without
adversely affecting competition in the marketplace.
Since the rules apply equally to all small private PWSs, there will not be an uneven distribution of burden between
them. It is likely that some costs will be passed along to ratepayers who are using the drinking water supply.
25. Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets lesser
standards for compliance by small businesses.
None – there will be equal oversight for all impacted by the rules.
26. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small
businesses.
Exempting small business or setting lesser standards would ignore the public health risk created by these chemicals
and create two classes of drinking water customers in the state, those protected from PFAS exposure at a level
determined to be protective by science, and second class customers exposed at a higher level. This would be
unacceptable from a public health and environmental justice perspective.
27. Describe whether and how the agency has involved small businesses in the development of the proposed rules.
Several small businesses and/or those serving small private water supplies were involved in the stakeholder process.
These include the Michigan Manufactured Housing Association and the Michigan Rural Water Association.
A. If small businesses were involved in the development of the rules, please identify the business(es).
No specific small businesses were involved in development of the rules.
28. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.
The businesses that will be most affected by these rules will be those with their own water supply. This includes
approximately 650 CWSs. More than half of these are manufactured housing communities, and many of the rest are
condominiums, apartment buildings, and other residential units. It also includes approximately 1,000 non-transient
noncommunity water supplies – industries, small businesses, etc. – that are not hooked up to municipal water.
The compliance costs for all PWSs as presented in item #13 would apply to this group as follows. For annual
monitoring this group of 1,650 water supplies would spend approximately $4 million (1,650 supplies taking 4
samples per year at a cost of $600 per sample. Of the 22 water systems identified in statewide testing to be
exceeding the proposed MCLs, 9 can be classified as businesses (not a school or a church). Using the methodology
in item 13, these supplies pump an average of 20,000 gallons per day. With an estimated cost of treatment of $46
per gallon it is estimated that these supplies will spend $920,000 to install treatment with an anticipated annual
maintenance cost of $7,000.
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the
proposed rules.
Those directly affected include owners of private water systems, laboratories, engineering firms, companies that
supply and install treatment, and companies that provide water system operations services.
B. What additional costs will be imposed on businesses and other groups as a result of these proposed rules (i.e.
new equipment, supplies, labor, accounting, or recordkeeping)? Please identify the types and number of businesses
and groups. Be sure to quantify how each entity will be affected.
Businesses that operate their own water supplies will be required to comply with the new rules. They will be
required to sample their finished drinking water for PFAS ($300 per sample if the business collects themselves or
$600 per sample if they hire a contractor to take the sample) and find alternate water or install treatment if their water
exceeds the proposed MCLs. Sampling costs are estimated at $4 million annually. Installation of treatment is
estimated to be a one-time cost of $920,000 with annual maintenance costs of $7,000. Reporting cost increases are
negligible as these supplies are already required to report monthly operations and testing – this rule would add one
more item 4 times a year.
29. Estimate the actual statewide compliance costs of the proposed rules on individuals (regulated individuals or
the public). Include the costs of education, training, application fees, examination fees, license fees, new
equipment, supplies, labor, accounting, or recordkeeping.
MCL 24.245(3)