DEQ/EPA/CTUIR WATER QUALITY STANDARDS PROJECT:

NON-NPDES DISCUSSIONS

Facilitator’s Chart Notes as Quick Reminders from 2/4/10 Meeting

Timeline Changes:

May 15 to SOS (for June public comment)

DEQ will need to have draft rules completed by April 15

Additional Meetings:

•  Discussion of mixed media suggestions (Chris, Nina, Dave K, Peter, Allison, Dave W, Jim P, Ellen H)

•  2/16: Toxics reduction strategy stakeholder group

•  Non-NPDES issues (mid-March, first week of April)

“Recommendations”

•  Need to be specific with recommendation

•  In facilitator report – need to clarify where there is group consensus and where there is not. If not, clarify who does not agree and why not

•  Requires members to be clear re: “This is a recommendation”

•  Let facilitator know (e.g. via email and in meetings)

State pre-treatment program task force

•  Small group needed for additional ideas (Dave K, Nina, Peter)

•  DEQ needs help with rule language

•  Crosses over to NPDES rule work

Prescriptive TMDLs

•  Process to define safe harbor BMP – clarify

•  Connection/follow-up with landowner re: compliance – clarify

•  Data needs to set TMDL – needs clarification

•  Based on target, not land use

•  TMDLs are lengthy process, so while good concept, not a fast fix for reducing toxics

•  How does this apply to existing TMDLs?

“Directed” Toxics Reduction Strategy

•  In definition: include other agencies (not just DEQ)

•  Where might incentives fit? (Clarify)

•  Link policy three more clearly in strategy directives

•  Caution re: timing of reviews in absence of adequate funding

•  What is meant by source – at what point? Definitions

Anti-degradation Approach

•  Needs to be teamed with other approaches – consider it the cap of cap and trade

•  NPS is handling anti-degradation via TMDL (remember this please!)

•  What’s baseline? Needs clarity

•  Tier 1/Tier 2 issues

•  Other states do have language that could be used in Oregon (see memo)

•  Do rule change NOW (not later)

Sediment Approach

•  Need updated information from ODF re: burned forests

•  Consider pesticide label in TMDL discussions

•  Careful of impacts rule may have on potentials for other environmental improvements (e.g., road crossings)

•  Problem statement and gap analysis needed

•  Beyond evaluation and investigation: what is the direction for action?