EXH0551023701

PCHBPollution Control Hearings Board of the State of Washington

Sent: Thursday, March 11, 1999 8:46 AM To: Manning,Sandra; Luster,Tom; Holliday, Keith; Vining,Rick: Randall, Loree'; 'Eliz.Phinney' Cc: Heltwig,Raymond:Ehlers, Paula Subject: FW: Anotherviewpointon stormwater Hi: rm resending the e-mail below since rm not sure it made it to you due to lest Friday's e-mail failure at HQ. I also want to share the results of a meeting that Ray and I had Tuesday with our region's water quality program regarding this issue. Ray and I met with John Glynn (Section Supervisor) and Kevin Fitzpatrick a unit supervisor for NPDES stormwater permitting and arrived at the following understandings and points of clarification: 1. Ray emphasized that SEA program management is aware of the issues/concerns and is working to develop a consistent approach to 401 and stormwater issues. 2. John concurred with Kevin's opinion (see below) that it is very difficult to apply water quality standards to discharges that are not coming from a point source to a discharge such as stormwater. He too believes that efforts to strictly apply the numeric criteria of the water quality standards is very difficult and it would be impossible to guarantee that the standards would be met. This could place Ecology in the position of not being able to issue any 401 certifications for projects that involve storrnwater discharges. ' We discussed our concern that it is difficult to define exactly what we mean when we say a project must meet water quality standards when stormwater is concerned. The adaptive management strategy that " Kevin describes…
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