November 15, 2002
John Palmer
EPA Region 10
1200 6th Avenue
Seattle, WA 98101
RE: Second Draft of Regional Water Temperature Guidance for Public Review Dear Mr. Palmer:
This letter is respectfully submitted on behalf of the Chehalis Basin Partnership (Partnership), the local planning unit established under Watershed Planning Act (Chapter 90.82 RCW). A portion of the Partnership's work includes addressing water quality standards, which will be a component of our watershed management plan that is scheduled for adoption by October 2003. Several members of the Partnership attended the public meeting hosted by EPA and the Department of Ecology on November 7, 2002. Please be advised that other members of the Partnership reserve the right to submit comments further articulating their respective issues.
The second draft guidance document appears to focus more on long term mechanisms to achieve the proposed guidance and to prevent further degradation. This appears to be a positive change. However, several of our Point Source Discharge entities expressed concern that the proposed guidance might make them targets for discrimination. In the Upper Chehalis, too many cities have fallen victim to compliance orders to improve, or construct new, wastewater treatment facilities on the heels of completing similar improvements to the facilities.
The proposed guidance incorporates a unique flexibility that the past guidance lacked. The current proposal seems to recognize that scientific techniques and approaches toward habitat enhancement and water quality are constantly evolving. This is evident in Section VI Approaches to Address Situations Where EPA's Recommended Numeric Criteria are Inappropriate or Unachievable. The Partnership appreciates that EPA is considering three approaches to address the situations where the systems cannot meet the guidance. Situation 2 (Section VI.2) would have greatly benefited several TMDLs in our area because it would have allowed impacts that were not human induced to be considered when determining the TMDL targets.
We hope that any modifications to the guidance that may occur during this comment period reflect the positive changes that occurred after the first draft.
Respectfully submitted,
Robert Spahr, City of Chehalis Mayor
Chehalis Basin Partnership Chair
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