On DEQ’s water well test fees

This is in regard to my letter last week and the follow up news articles in the papers regarding DEQ’s proposed testing of water wells. At the time I wrote my last letter it was not exactly clear what DEQ’s proposed costs were and I made some statements that implied that DEQ was over charging for the testing fee ($10,000). Now

DEQ has revealed that the cost is $2,700 for each of the 4 sets of tests.

This comes to $10,800 total for the testing. In this case, DEQ would actually be subsidizing the testing by $800 for each well. If this is the actual cost it appears very high and DEQ need’s to re-evaluate alternative methods to accomplish the testing.

The impact on the business community is significant especially when it is applied on top of DEQ’s fees for Water Quality Certificates (WQC). This is another recently imposed fee on some water well operators. Anybody that discharges Reverse Osmosis concentrate (as many of these well owners do) now must get an EPA permit, which also requires a WQC.

EPA charges nothing for their permit –DEQ charges $5,000 for the WQC. The EPA permit is extremely detailed and comprehensive whereas the DEQ WQC only requires a brief letter and response from DEQ. How is it that EPA doesn’t charge for their detailed permit that they develop yet DEQ charges ridiculous sum of $5,000 on a regulation that they piggy back on? It does not appear that DEQ can justify the $5,000 fee for the WQC.

This point of contention was brought up during the public comment period when DEQ first issued the WQC regulations a couple of years ago. However, they totally ignored the comments from the public, the professional engineering community and environmental consultants. I am concerned that they may do the same with the new water well testing requirements. Unfortunately, this double charge is being imposed upon the local business community at the worst time. In some cases the impact is huge.

For instance, some businesses have 4 water wells and maybe 2 discharge points for their RO concentrate. In this case, the total fee imposed for the well testing and WQC would be $50,000. Another business we know of has 10 water wells–their cost would be $10,000 excluding other testing requirements, cost of hiring consultants, and in-house costs.

DEQ needs to establish a more affordable, cost effective way to protect our island’s public water supplies so that businesses (and CUC) are not unfairly burdened. Believe me, we know the importance of this program. I don’t want my kids growing up exposed to cancerous substances from our public water supplies.

But, I also know that this can be done for far less money and much more efficiently than DEQ is proposing. What needs to happen is for DEQ to include the private sector in developing and implementing this program. However, given the government’s track record, they will just plow forward with blindfolds on and with little or no consideration for public comments or opinion.

Lastly, I would think that private wells would not be needed if the government entity charged with providing water (CUC) was capable of doing so. This should be taken into consideration, as it is not a luxury to have water wells, but a matter of necessity.

Sincerely,

Efrain F. Camacho,P.E.

President, EFC Engineers and Architects