EXH1269050909

PCHBPollution Control Hearings Board of the State of Washington

August 3, 2001 i3E=T 3F ECC, LC,.Gv Ann Kenny, Senior Pm'mJt Specialist , Washington Dcpanm=nt of Ecology Northwest Regional Office 3190 - 160th Avmu¢ $outhcasl Bellevue, WA 9800g-$452 Dear Ms. Kenny; King County is pleased to have this opporttmiW to work with the Department of Ecology (Ecology) by making its technical review capacity and knowledge of local =ormwater conditions available to assistin reviewing the Port of S=_e's Low Flow Impact Analy$ia - Low Flow Impact Offset Facilily Proposal (July 2001). This analysis of low flow impacts, and the propos=d facilities for offsetting identified Isnpacts, constimto a substantial proposal to provide mitigation for natural resource m_pscts which goes well beyond the basic requirements of the King County Surface Water Design Manual. Since this proposal goes beyond the requirements of the Design Manual, reviewers did not have the be=¢fit of clem"per/orJ_anc¢standards/or low flow mitigation efforts against which to measure the proposals. The enclosure provide= gcmer41comments on the low flow study, as well as specific comments on the analysis and proposed facilities grouped by drainage basin. To assist Ecology, substantial commentary hm bcen included to hclp clarify the reviewm-s' undersmading of the tccZuzicalissues and the logic contributing to specific comments, Reviewers did find several inconsistencies and gaps m data, primarily in the report documentation, that we reconmaend correcting in the final proposal's preparation. While most of these appear to be minor errors attributable to the mul_ple itcratsons and edits that the documenthasgonethrough, several of them have thc potential toaffect facilitydesign andplan effectiveness beyond…
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