D3.4 Chapter 8 Comment Responses
Commenter,
Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment Addressed
Larry Schaffner
8.1
See my comment for Section 4.7 regarding whether this type of content should be
integrated in that chapter or reside in this one.
The effectiveness is addressed in Chapter 4, and cost considerations addressed
in this chapter. Added a sentence directing reader to Chapter 4 for other
considerations about effectiveness.
Yes
Larry Schaffner
8.3
The decision on whether to go in-house, contracting out, or a hybrid would seem
to play a significant role on how one goes about these calculations.
These equations are intended to be used for calculating in-house sweeping
costs. Added a sentence to clarify.
Yes
Sarah Zehner, ECY
8.4
The Water Quality Combined Program has guidelines that are updated each year,
so requirements for funding are ever changing. Since we don't think this
document is going to be updated every year with the new guideline requirements,
we would prefer to just list the types of funding that may be available and give the
link to our webpage for more details. I am the planner for SFAP and would be
grateful if you would run this section by me when finalizing language.
Significantly reduced the section, added a comment at the beginning of the
section noting that grant requirements can change and included weblinks to the
sites Sara Ponte provided in the followingcomment.
Yes
Sarah Ponte, ECY
8.4
WQP website: Water quality combined – Washington State Department of
Ecology
Stormwater funding requirements website that provides resources to grant/loan
recipients: Stormwater Funding Requirements – Washington State Department of
Added weblinks at the beginning of the section.
Yes
Amy Waterman,
ECY
8.4
ECY requires that that the applicant first applies for an Enhanced Maintenance
Plan grant to document and quantify their current sweeping and maintenance
practices. The plan is used to determine eligibility for future grants. The only part
that is grant eligible is the part that is an increase over the existing program. If
applicants are not meeting Permit requirements now and they need funds to do
so, then those costs could be eligible.
Significantly reduced the section per Ecology staff suggestion.
Yes
Shelby Giltner
8.4
[referencing Amy's comment on 8.4] Funding for the EMP and street sweeping
equipment can be requested in the same application.
Significantly reduced the section per Ecology staff suggestion.
Yes
Amy Waterman,
8.4
a Project Manager from the region and one from a different region.
Significantly reduced the section per Ecology staff suggestion.
Yes
Amy Waterman,
ECY
8.4
SFAP applications are also reviewed by a Financial Manager and an Engineer.
Significantly reduced the section per Ecology staff suggestion.
Yes
Sarah Zehner, ECY
8.4
This is not a true statement. For SFAP, it only matters that there is an
enhancement to your current program.
Significantly reduced the section per Ecology staff suggestion.
Yes
Sarah Ponte, ECY
8.4
As Sarah Zehner mentioned, the WQC Guidelines are changed yearly, and the
number of funding sources may also change in the future. I suggest removing
"seven" from this document if this manual is not going to be updated yearly.
Significantly reduced the section per Ecology staff suggestion.
Yes
Cleo Neculae, ECY
8.4
Please clarify. Should this be "SFAP grant staff"?
Significantly reduced the section per Ecology staff suggestion.
Yes
Abbey Stockwell,
ECY
8.4
This information may be best left to the grants program, as it could change in the
future. For document durability, it may be better to list the sources of funding
than to provide this level of detail on the grant application review process
Significantly reduced the section per Ecology staff suggestion.
Yes
Shelby Giltner
8.4
[in response to Abbey's comment on 8.4] I agree. The Funding Guidelines and
processes are constantly being updated.
Significantly reduced the section per Ecology staff suggestion.
Yes
Amy Waterman,
ECY
8.4
Not always true. The minimum point requirements varies with total funding and
number of applicants.
This should be left out.
Significantly reduced the section per Ecology staff suggestion.
Yes
Page 1
D3.4 Chapter 8 Comment Responses
Commenter,
Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment Addressed
Kitty Weisman, ECY 8.4
This paragraph isn't quite accurate. We recommend referring readers to the
current grant cycle funding guidelines. Each SFAP application is reviewed for
eligibility, scored, and ranked by Ecology staff according to current funding cycle
guidelines. Ecology distributes funding to the highest-scoring projects above a
funding limit set by the Washington State Legislature for that biennium in a
combination of grants and loans depending on the project type and willingness of
the applicant to receive loan funds.
Significantly reduced the section per Ecology staff suggestion.
Yes
Abbey Stockwell,
ECY
8.4
Capacity grants are available as long as ECY received funding from the legislature
each biennium
Significantly reduced the section per Ecology staff suggestion.
Yes
Sarah Zehner, ECY
8.4
Please discuss this section with Jessica Schwing and Kyle Graunke.
Significantly reduced the section per Ecology staff suggestion.
Yes
Abbey Stockwell,
ECY
8.4
This might be better left to the grants website than included here
Significantly reduced the section per Ecology staff suggestion.
Yes
Amy Waterman,
ECY
8.4
Tacoma's Rate Structure Report would be useful reference; can be found here:
https://www.wastormwatercenter.org/permit-assistance/municipal/gross-
grants/
Significantly reduced the section per Ecology staff suggestion.
Yes
Larry Schaffner
8.4
Found this to be an awkward read and wasn’t clear on its intent.
Significantly reduced section.
Yes
Larry Schaffner
8.4
Suggest deleting this detail as it goes beyond the scope of the manual. It kept, it
should be rewritten in the context of funding sweeping programs.
Deleted.
Yes
Sarah Zehner, ECY
8.4
Clean Water State Revolving Loan Funds can also be used to purchase sweepers.
SRF funds don't require an EMP and can be used to replace a sweeper without
enhancement to the program.
Significantly reduced the section per Ecology staff suggestion.
Yes
Kitty Weisman, ECY 8.4
Consider adding a sentence or two directing smaller, rural jurisdictions to free
technical assistance for rate structure analyses and grant application
assistance. Rural Community Assistance Corporation (RCAC) and Small
Communities Initiative (SCI) both provide free assistance to such communities.
Significantly reduced the section per Ecology staff suggestion.
Yes
Amy Waterman,
ECY
8.5
If you can get some costs from any WA jurisdictions, that would be helpful. It
would be great to take an example sweeping program that contracts out
sweeping and compare it to a similar program that does in house.
We requested more cost data and provided what we received. We also included
a calculator to convert costs from other years to the current year based on
inflation.
Yes
Shelby Giltner
8.5
[referencing Amy's comment on 8.5] I agree the cost to run these programs will
vary significantly nationally. Providing WA examples will give a better estimate on
the cost per square mile.
We requested more cost data and provided what we received. We also included
a calculator to convert costs from other years to the current year based on
inflation.
Yes
Zackary Holt
8.5
Many jurisdiction do a hybrid version of this where they do certain areas and
contract out a portion of work for others.
Added reference to a hybrid model.
Yes
Larry Schaffner
8.5
See my comment for Section 4.7 regarding whether this content should be
integrated in Chapter 4 or reside in this one.
Given much of this chapter’s focus involves around the use of the Calculator,
integrating this section into Section 4.7 could make more sense.
The effectiveness is addressed in Chapter 4, and cost considerations addressed
in this chapter. Added a sentence directing reader to Chapter 4 for other
considerations about effectiveness.
Yes
Rachel Yonemura,
ECY
8.5
what about effectiveness? Ch 4.7 notes better sweeping quality when done in-
house. This section seems to have some inconsistencies with section 4.7
The effectiveness is addressed in Chapter 4, and cost considerations addressed
in this chapter. Added a sentence directing reader to Chapter 4 for other
considerations about effectiveness.
Yes
Page 2
D3.4 Chapter 8 Comment Responses
Commenter,
Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment Addressed
Jackie Caldwell,
Vancouver
8.5
[Regarding: Does your jurisdiction, or has your jurisdiction ever contracted out
street sweeping services? If so, do you have cost data you can share? What
are/were the pros and cons of contracting out street sweeping services vs in-
house street sweeping services?] We have not contracted out sweeping services
for our public roadways. At times, Facilities has contracted sweeping of certain
City-owned parking lots. VPD West is an example I’m aware of.
Comment Noted
Yes
Sarah Ponte, ECY
8.6
Consider referencing our program website where current guidelines are posted:
Water quality combined – Washington State Department of Ecology
Included links to the stormwater funding requirements and water quality
combined funding program.
Yes
Amy Waterman,
ECY
8.2.1
Specific water quality concerns (TMDL's, proximity to salmon habitat) should be
on list.
Added "water quality concerns such as TMDLs or proximity to salmon habitats" to
list of items that may influence street sweeping program goals and needs.
Yes
Zackary Holt
8.2.1
It is a good idea to talk with union reps internally as well to make sure no contract
violations might occur, especially with OT and shift (night work) considerations.
Added "union worker contracts" to list of staff items to consider in 4.2.2
Yes
Sarah Zehner, ECY
8.2.1
Water quality/pollutant concerns?
Added "water quality concerns such as TMDLs or proximity to salmon habitats" to
list of items that may influence street sweeping program goals and needs.
Yes
Amy Waterman,
8.2.1 – Table 8-1
8-1?
Dash missing from the copy of document, but intended to be here. Updated.
Yes
Larry Schaffner
8.2.2
Wouldn’t this be rolled into the FTEs needed to achieve program goals as well as
the ongoing costa associated with the street sweeping program?
Rearranged bullets to consolidate main topics.
Yes
Larry Schaffner
8.2.2
I found this sentence confusing. Does the proposed edit help clarify it’s intent?
The proposed edit is appropriate here. Changes accepted. Tense updated for
sentence to make sense based on proposed change.
Yes
Jessica Schwing,
ECY
8.2.2
What about materials storage? Fuel? Usually loads get dumped somewhere,
tested to see if they are contaminated, and then either hauled off or taken to a
disposal site. all of this costs space time, money and staff. Suggest spending
some time with TAC Members to get real world examples of how much space
they have vs. how much they need, how long things sit before they have to take
sweepings somewhere, how they protect piles from wind and water erosion, and
Material storage and fuel are included in the list in Table 8.1, with a detailed
breakdown in the subsequent subsections. Chp 7 also have more details about
waste storage.
Yes
Jessica Schwing,
ECY
8.2.2
Seems odd that this gets its own bullet. Typically you would include that in bullet
Combined in bullet 1 with wages.
Yes
Jessica Schwing,
ECY
8.2.2
Do you mean expected program growth and inflationary costs? A program need
to coordinate with city planners and see the additional roads/traffic/development
planned and account for that growth.
This is not what was meant, rather the costs that will incur consistently over the
program. Clarified startup versus ongoing costs and added a bullet for program
growth and inflationary cost. Moved growth projections to process for calculating
costs.
Yes
Jessica Schwing,
ECY
8.2.2
current equipment age and life expectancy
This comment was acknowledged and addressed in Section 8.2.3.4
Yes
Jessica Schwing,
ECY
8.2.2
almost all of these are also associated with an on-going cost
Footnote added to clarify.
Yes
Xavier Gilbert, ECY
8.2.2
Please keep in mind that if you want to do the repairs/maintenance in house, you
will need a CERTIFIED mechanic, which will come at a costly rate. If you want to
outsource this work, it is very expensive, and difficult to get in with shops, so you
will likely need a second piece of equipment to run as a backup, raising overall
costs of everything.
Added mechanics to the example staff types.
Yes
Page 3
D3.4 Chapter 8 Comment Responses
Commenter,
Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment Addressed
Zackary Holt
8.2.2.1
Performance evaluation, inspections, etc. as well.
Added "inspecting and evaluating contractor work" to list of responsibilities
Yes
Larry Schaffner
8.2.2.1
However, wouldn’t recouping those costs be reflected in the cost for contracting
those services?
Revised section to clarify.
Yes
Xavier Gilbert, ECY
8.2.2.1
Cross training can be a very slipper slope. Where are you pulling these 4
employees from, to run the sweeping services? How can you be sure that running
the street sweeper is more beneficial to water quality, than normal stormwater
Comment noted. This is a very common practice by jurisdictions especially small
jurisdictions. For example, during the winter staff may run the snow plow and
then the sweeper during other seasons.
Yes
Scott Johnston
8.2.3
[Regarding additional bullet added: Vehicle tracking: (we use Zonar to track
vehicle, and it tells us when brushes are operating and when it is not.) Would fit
under Documentation and Reporting] . This will help with requirements in
Chapter 4.
Moved comment to chapter 6, Data collection.
Yes
Amy Waterman,
ECY
8.2.3.2
OR developing RFP, hiring contractor, and managing contract.
Added
Yes
Larry Schaffner
8.2.3.2
Please clarify what is meant by this
Updated to "Updates to sweeping schedule" to clarify
Yes
Brent Dhoore
8.2.3.3
Fuel use cost?
Added "fuel cost" to list.
Yes
Abbey Stockwell,
ECY
8.2.3.3
Should this also include life cycle costs of sweepers? If a city/county owns a
decant facility any costs associated with O&M for potential increases in street
Added "life-cycle costs" to Section 8.2.3.3 and "operations and maintenance of
decant facilities" to Section 8.2.3.8.
Yes
Zackary Holt
8.2.3.3
I would say something different than maintained. Mechanics don’t like operators
trying to “fix’ equipment or provide maintenance outside of their normal pre-trip
inspections and preparation. Perhaps ‘properly operated, with service conducted
by qualified staff members’?
Revised text.
Yes
Zackary Holt
8.2.3.3
Fleet services usually covers most of these bullets for all vehicles and equipment
at most jurisdictions. I might consider removing ‘operations’ from this section, as
it appears to…