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COST RECOVERY METHODS 
As can be seen, the annual cost of a POTW Pretreatment Program can 
amount to a substantial sum of money. At this point in time, there appears 
to be some ambiguity on what EPA regulations may or may not permit as 
a cost recovery system. A strong case can be made, however, for several 
different cost recovery methods, depending upon the characteristics of 
the POTW's users and its user charge system. The POTW should be able 
to utilize whatever system is equitable and publicly acceptable. The 
following possible POTW Pretreatment Cost Recovery Methods are offered 
for consideration. 
Charge All Users 
This is the simplest method of cost recovery, particularly if an 
ad valorem tax user charge system is utilized. Cost accounting and records 
keeping are greatly simplified. 
A broad justification can be made that all users of the system benefit 
from an effective POTW Pretreatment Program. Assuming that no extensive 
additional sampling or enforcement is required against any particular 
industry, broad equity can be claimed. If, however, problems develop 
with some industries which require extensive monitoring and enforcement, 
then inequities will result. 
Charge All Industrial Users 
A stronger case can be made that only industry should pay for a POTW 
Pretreatment Program. The question then must be asked should industry 
as stipulated in the SIC Codes included in the Federal Regulations bear 
the burden or only those with industrial discharge. 
Charging only industry under an ad valorem tax system is more complicated 
since some type of industrial special charge would be required. Under 
a water use based user charge system, the charge-back system would be 
greatly simplified. As in the "Charge All Users" scenario, inequities 
result if some industry requires special monitoring or enforcement. 
Charge Significant Industrial Users 
Under this system, only those industries which actually have discharges 
would be charged. The break-point is obviously controlled by the final 
turn that the Federal Regulations take in terms of industries and pollu- 
tants to be covered. The "significant'' break-point should track with 
that ultimately defined by U.S. EPA. 
Again, this system presents more complexity to an ad valorem system 
since some type of special charge would be needed. A water consumption 
based or sewer discharge based user charge system should be able to readily 
accommodate such a cost recovery system. 
Charge Base Cost to All Users with Incremental Cost to Problem Industrial 
Users 
This system of cost recovery has the merits of the "Charge All Users" 
scenario in terms of ease of administration under an ad valorem system, 
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