The proposed fee increases are out of step with the Construction General Permit and MS4 permit issuance. The Department should propose and then implement fee increases at the time of permit issuance. 

The proposed increases, if implemented, will require municipalities to update ordinances that were just revised as part of the ESC and SWM consolidation effort less than 18 months ago. Additional ordinance revisions to incorporate the newly proposed fee schedule mid-permit cycle will be a hardship to local municipal staff. 

The fee increases should not be evaluated at the current time and should be implemented as part of the next permit issuance.