EXH2113033728

leadonthis. Ill be gladto continueto coordinateif appropriate,butthestormwaterexpertiseisobviously moreinMelodie'sshopthanmine. Feel freeto sendcommentsontheattachedsummaryto me, and I'll discusswithMelodiehowto handlefromhere. Thanks AR 033728 ECYO0000453 Exhibit-2113. -- WATER QUALITY PROGRAM Relationship between Clean Water Act Sections 401 and 402 Background: Permitting activities by both the SEA and WQP programs on several large, complex projects have identified a difference in the way the two programs are currently interpreting and applying the requirements of Clean Water Act Sections 401 and 402, and the State's Surface Water Quality Standards (WAC 173-201A). The primary focus of this difference has been on the adequacy of stormwater treatment requirements contained in NPDES stormwater permits issued under section 402 and those specified in the stormwater BMP manual. SEA program staffhave suggested that the relationship between 401 and 402 is hierarchical: that a higher burden of proof is required prior to certifying under section 40,1that a project meets water quality standards. WQP management believes these sections are complementary, not hierarchical, and should be harmonized, not duplicative. A secondary issue is the use of 401 certifications to establish additional requirements beyond those identified in the stormwater BMP manual for sites that are not covered under the 402 stormwater permits. _ Analysis: 401 staff have suggested that the inability of the 402 stormwater permits to ensure compliance with the Water Quality Standards (WQS) necessitates the identification and imposition of additionial controls prior to the issuance of a 401certification. Of particular concern to 401 staff are the limitations of the stormwater BMP manual that is referenced…

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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 [...]