EXH2110033718

Tom: Youare correct(Item# 13) thatthereshouldbenoquestionaboutthe retrofittingof existingstormwaterouffallsthat are partof industrialactivitybasins.What needsto bedevelopedintheNPDES permitis a compliancescheduleon how andwhenthisretrofittingwilloccur. am becomingas frustratedas you,Tom, inthewaywe are continuingto talkpasteachotheroverhowstormwater dischargesachievecompliancewithWQ Standards(Items#11 & 12). Again,theWQ approachto achievecomplianceis bya step-wiseanddeliberativeapproach("adaptivemanagement"forlackof a betterterm)of applyingcurrenttechnology BMPs,monitoringtheeffectivenessof thoseBMPsandthendeterminingadditionalmeasures(i.e. additionalsource control,developmentof innovativeBMPs)shouldmonitoringindicatethatstormwaterdischargesare adverselyimpacting beneficialusesof the receivingwater. I knowthatyouwantto employthe401 Certificationto requireinstantaneousand strictcategoricalcompliancewiththe numericWQ standardsforstormwaterdischarges.I don'tsee howthatis possible. Ican'tmakethat happenwiththe NPDES Permit. That beingthe case,and if thatis howyouindeedwantto conditionthe 401 Certification,I see noalternativebutto denya 401 certificationfor anyprojectwithexistingstormwaterdischarges. --mOriginalMessage From: Luster, Tom Sent: Friday,May 14, 1999 3:27 PM To: Hellwig,Raymond;Ehlers,Paula;Stockdale,Erik;Fitzpatrick,Kevin;Bolender,Wendy Subject: RE: Updated401 PermitMatrix Hi Ray and all -- Gosh, comments from Tom Luster!!! Yes, who'd of guessed it... First, an editorial comment, provided at the risk of sounding like a broken record... I think part of my role in 401 is to provide applicants with clear understanding of what's expected for project approval. For some reason, I apparently am not making myself clear enough -- we've told the Port many times what was needed to meet the regulations and the level of information we expected, and they have often either come back with something that falls far short of our requirements, or as in the current situation, have asked us to lessen what we're requiring (e.g., reconsider whether NW Ponds are waters of the state, whether flow augmentation is necessary, etc.). I think we are all in agreement that there are many ways to get to a complete mitigation package, The Port has made great strides on some of the issues…

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PSCAA Advisory Council Meeting Agenda
Add to CalendarMWednesday Mar 11, 9:00am - 11:35am
1904 3rd Avenue, Suite 105, Seattle, WA 98101
Call to order – Roll Call – Quorum Established – Land Acknowledgement We would like to acknowledge that our Agency operates in four present-day counties, which are the traditional lands of the Coast Salish people, past and present. This acknowledgement does not take the place of authentic relationships with indigenous communities in our jurisdiction and [...]