ASDWA recently finished development of its PFAS CoSTS (PCoSTS) model, an adaptation of the Cost of State Transactions Study (CoSTS) developed for the Revisions to the Lead and Copper Rule (LCRR). PCoSTS estimates the additional burden for primacy agencies associated with the recent proposed PFAS regulation.
PCoSTS estimates the primacy agency staff time required for the first year of rule implementation, which includes one-time activities such as regulatory start-up and review and approval of water system treatment plans, will be 1,039,750 hours. At the state and local hourly government employee rate of $57.60 based on the U.S. Bureau of Labor Statistics, the first year of implementation will cost primacy agencies $59,889,624.
PCoSTS also estimates the primacy agency staff time that will be required in subsequent years for annual regulatory activities, such as reporting, compliance, and technical assistance. Following the first year of implementation, ASDWA estimates the proposed rule will require 325,850 hours of staff time at a cost of $18,768,960 annually. Combining the cost of the first year of implementation with four subsequent years of annual rule requirements (for a total of 2,343,150 staff hours), ASDWA’s model estimates that the proposed NPDWR will increase primacy agency staff hours by roughly 469,000 hours annually in its first five years of implementation, translating to an annual cost of approximately $27M.