SUBJECT: REQUEST BY THE CITY OF PLYMOUTH (SCG NO. 642-010) TO APPROVE THE USE OF AN INCOME SURVEY.
DISCUSSION: The City of Plymouth (City) proposes to retrofit their existing effluent storage pond at an estimated cost of $350,000. The project is contained on the adopted Small Communities Grant (SCG) Project Priority List and is eligible for grant funding.
The City has requested that the Division of Clean Water Programs (DCWP) use a Median Household Income (MHI) survey approved by the United States Department of Agriculture, Rural Development (USDA-RD) in lieu of the updated 1996 MHI figures based on MHI data from the 1990 Census.
The Small Community Grant (SCG) Priority List indicates that the City's 1996 MHI based on U.S. Census data is $31,220. The income survey approved by USDA-RD on August 21, 1997 yields a 1996 MHI estimate of $24,000. Changing the MHI to $24,000 would increase the City's SCG from $185,790 to $285,842 (an increase of $100,052) based on an estimated project cost of $350,000.
The DCWP denied the City's request by letter dated August 8, 1997 based on Section II. Definitions of the SCG Policy. Section II. provides for the use of an income survey for communities which are not a city, town, or census designated place. The City appealed the DCWP decision by letter dated August 25, 1997 and asserts that it cannot pursue assistance from the SCG Program without receiving a larger grant.
The rationale for the restrictions in the SCG Policy on income surveys for determining the level of grant assistance was to treat applicants on a consistent basis to the maximum extent possible, provided the boundaries of the city, town, or census designated place coincide with the wastewater service area, and to reduce the number of applicants wanting to increase their SCG amount. In the City's case, the sewer boundaries and the census boundaries are the same, and therefore, the SCG Policy does not provide for use of an income survey for determining MHI.
Approval of the City's request may result in additional communities seeking to conduct income surveys to increase their SCG funding. If this occurs, fewer SCG projects would receive funding. For these reasons, the DCWP proposes that the SWRCB deny the City's request to use an income survey. Copies of correspondence on this issue are contained in Exhibit A.
POLICY ISSUE: Should the SWRCB approve the use of the income survey submitted by the City?
RWQCB IMPACT: None.
FISCAL IMPACT: Approval of this item would increase the grant funding to the City by an estimated $100,052.
STAFF RECOMMENDATION: That the SWRCB deny the request by the City of Plymouth to use an income Survey.
(Attachment not available electronically but can be obtained by calling Eric Torguson at
September 29, 1997 DRAFT
1. The State Water Resources Control Board adopted the Policy for Implementing the Small Communities Grant Program on April 30, 1997;
2. The City of Plymouth (City) conducted a Median Household Income (MHI) survey approved by the United States Department of Agriculture, Rural Development, which shows a 1996 MHI of $24,000.
3. Section II. Definitions of the Policy for Implementing the Small Communities Grant Program limits the use of income surveys for cities, towns, and census designated places;
4. The City's sewage service area boundaries correspond to the census tract boundaries;
5. The City requests that the State Water Resources Control Board allow it to use an income survey in lieu of the current census based MHI estimate;
6. The City asserts that they will be unable to pursue a Small Community Grant without additional grant assistance; and
7. Granting the City's request would set a precedent allowing other communities on the Small Community Grant Priority List to propose alternatives to lower their MHI level to achieve a higher level of grant assistance and deplete the limited funds faster than anticipated.
THEREFORE BE IT RESOLVED THAT:
The State Water Resources Control Board denies the City's request to use the income survey.
The undersigned, Administrative Assistant to the Board, does hereby certify that the foregoing is a full, true, and correct copy of a resolution duly and regularly adopted at a meeting of the State Water Resources Control Board held on October 23, 1997.
Administrative Assistant to the Board