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with the added advantage of making problem dischargers pay the cost for 
extensive monitoring or enforcement activities. 
Under this system, great care would have to be taken in establishing 
the threshold level of POTW activity which results in an industry being 
labeled "problem." Further, extreme care in cost accounting would be 
necessary to be certain that charges levied can be substantiated in court, 
if necessary. 
This system should be capable of ready administration under either 
a water consumption base or sewage flow use charge system. 
Charge Base Cost to All Industrial Users with Incremental Cost to "Problem" 
Industrial Users 
On the surface, this system appears to provide for maximum equity 
since only industry pays and "problem" industries pay for additional work 
generated on their behalf. As in the previous scenario, care must be 
taken in defining the "threshold" after which an industry is labeled a 
problem. Close cost accounting is also necessary. 
For a water consumption based or sewage flow based user charge system, 
administration should be accomplished with little difficulty. For an 
‘ad valorem system, additional administration and billing would be required. 
Other Combinations 
After reviewing the above, it is apparent that other combinations 
can come to mind based on the particular POTW's circumstances. The above 
are offered not as the "only" methods, but rather to stimulate thought 
on other alternatives. 
CONCLUSION 
While POTW Pretreatment Program development costs are significant, 
their grant eligibility makes them more palatable to municipal agencies. 
Development costs, however, are quickly dwarfed by annual operating costs 
which municipal agencies must bear without the benefit of Federal largesse. 
As with inflation and other demands for public dollars, these costs will 
become more difficult to justify, let alone obtain, with the result being 
that the maintenance of high quality POTW pretreatment programs may be 
More difficult to achieve. This will be particularly the case where en- 
vironmental benefits are not readily apparent and the economic impact 
on local industry is severe. 
POTW Pretreatment Programs will require a substantial amount of hard- 
ware and trained personnel. The amount of sophisticated laboratory hardware 
Tequired by POTWs will depend on the extent to which they will have to 
Perform priority pollutant analyses. The number of significant industries, 
the extent of industrial self-monitoring, and the number of enforcement 
actions will greatly impact both the hardware and personnel categories 
and hence operating costs of POTW Pretreatment Programs. Legal costs 
Nay also be substantial. 
Several methods of funding a POTW Pretreatment Program are possible. 
The exact method should be determined by the statutes governing the POTW 
since institutional methods vary widely across the country. 
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