Multnomah County NPDES Phase permit fee potential increase

From: Roy IWAI

Sent: Thu Nov 16 15:41:18 2017

To: SVETKOVICH Christine; Ian CANNON; MARTIN Michele

Subject: Multnomah County NPDES Phase permit fee potential increase - MS4 Draft Fee Concept

Importance: Normal

Attachments: MS4 Permit Fee Workgroup-Draft Concept (1).pdf; Multco.NPDES.2017.AnnualReport.Binder.pdf;

Christine -

I'd like to discuss with you the new Draft Concept for Multnomah County's NPDES Phase I permit, as shared by the MS4 Permit Fee Workgroup. I understand the need for the fee increase, and am supportive of having consistently funded DEQ staff to coordinate the NPDES program. The Draft Concept makes logical sense overall, but I'm afraid it doesn't account for anomalous situations like that for Multnomah County. The County's situation is unique, however, and I'd like to share why this is:

Multnomah County's NPDES phase I permit area is unlike any other Phase I community.

* Our permit area covers only five Willamette River Bridges, 28 miles of urban roadway within Troutdale, Wood Village, and Fairview, a few small urban pockets within the urban services area of City of Portland's land use and road maintenance authority, and one pocket neighborhood adjacent to Fairview. The overall population within these areas is likely a few hundred people.

* Until 2010, the County was a co-permittee on two separate NPDES permits: City of Portland and City of Gresham. Given the difficulty by DEQ to evaluate our program in total as it was split under two permits, and given the work for the County to submit reports under two permits, Multnomah County was pulled out of both permits and given it's own Phase I permit. While we have Phase I status, our permit area is not reflective of the guidance to establish Phase I permit.

* Multnomah County is a jurisdiction that does not have a stormwater utility fee (as our permit area is almost entirely within other cities). The increase in stormwater fees in the draft fee concept doesn't accurately reflect the nature of the Multnomah County jurisdiction. In fact, our program is smaller than any Phase II jurisdictions and Phase I co-permittee, as a result of the size of our permit area.

A few questions for discussion:

* Has DEQ MS4 Permit Fee work group considered the unique permit area of Multnomah County?

* What opportunities are there for Multnomah County to share in details the nature of our NPDES program with DEQ?

* What alternatives might exist to contribute in a fair manner?

* I've attached our most recent NPDES Annual Report for reference and details.

I appreciate your help, and look forward to working closely with DEQ on this issue.

Thank you - Roy

Roy Iwai | (503) 988-0195 | Water Quality Program | Multnomah County Transportation Division | Twitter