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permit non -local sites. While small volumes make the increased costs of landfilling or sending to a regional facility more manageable, these small facilities will face similar issues of not having reasonable options available if Classt land application is no longer feasible. ❑ Lower impact alternatives were not implemented? Describe the alternatives and the basis for not implementing them. A phosphorus -based rate for land application (based on site-specific criteria) results in a significant reduction in the quantity of biosolids that can be applied per acre. DEP is not aware of a feasible alternative to this reduced application rate. Reducing the application rate would require approximately 4-10 times the amount of acreage to land apply the current amount of biosolids. This would be costly to all parties involved, and it is likely that most biosolids currently, land applied would shift to Class AA. Shifting to Class AA is extremely difficult in rural areas where small wastewater treatment facilities; biosolids treatment facilities, and septage management facilities do not have the benefit of economies of scale. Therefore, the likely alternative would be to landfill the biosolids, which would require dewatering and a willing landfill to dispose of the solids. These increased operational costs will result in substantial costs, especially if the biosolids or septage must be transported long distances for disposal. Ultimately, ratepayers and home owners will bear the additional costs. Even if additional land for land application is obtained, other provisions related to continued land application will increase costs. These include but are not limited to: increased biosolids monitoring, ground water monitoring, and surface water monitoring. H. Any additional information that the agency determines may be useful. ❑ None. ® Additional. Although a few innovative technologies have been proposed as an alternative to biosolids land application, there is at best very limited evidence that these could successfully serve as alternative management options. Also, the costs for these innovative technologies appear to be at higher than current costs of Class AA technologies. I. A description of any good faith written proposal for a lower cost regulatory alternative to the proposed rule which substantially accomplishes the objectives of the law being implemented and either a statement adopting the alternative or a statement of the reasons rejecting the alternative in favor of the proposed rule. 149