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Kentucky Resources Council, PO Box 1070, Frankfort, KY 40602 Phone [502] 875-2428

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PO Box 1070, Frankfort, KY 40602  Phone 502.875.2428, Fax 502.875.2845

KRC Comments On Revised Solid Waste Permit Fees  Posted: July 1, 2009

June 30, 2009

George Gilbert, P.E.
Division of Waste Management
200 Fair Oaks Lane, 2nd Floor
Frankfort, KY 40601
George.Gilbert@ky.gov

RE: Proposed Regulation 401 KAR 47:090

Dear Mr. Gilbert:

The following comments are submitted on behalf of the Kentucky Resources Council, Inc. after a review of the proposed amendments to 401 KAR 47:090:

While the Council supports the increase in fees contemplated by the proposed changes to 401 KAR 47:090, the Council strongly urges the Division to consider further increasing the fees so that the Division may recover 100% of the costs associated with these programs.

Currently, the permit fees for the solid waste program bring in only $200,000 per year, while the program costs approximately $1.6 million to administer. At a time of serious budget shortfall in state government and with the Department revenue already cut by almost $5 million dollars in fiscal year 2009, fees must be raised to cover the costs of running the solid waste program so that the Department is able to provide the services it is mandated to deliver under Kentucky law and so that taxpayers are not subsidizing the costs of this pollution prevention program.

The Council further recommends that the Department seek to effect a change in KRS 224.10-100(20), which currently prevents the Department from charging application fees to publicly owned facilities. Such an exemption passes the costs of processing these permit applications and enforcing permits to the taxpayers instead of the customers of the
facility, which creates unfair competition in the solid waste industry and penalizes customers who recycle more because they are indirectly being required to subsidize the permit processing fees for these facilities even though they are using the services less than other customers.

Thank you for your consideration of these comments.

Sincerely,

Liz Edmondson
Staff Attorney
Kentucky Resources Council, Inc.
P.O. Box 1070
Frankfort, KY 40602
Liz.d.Edmondson@gmail.com

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