September 24, 2004

Mr. Dave Rountry
Department of Ecology
Southwest Regional Office
P.O. Box 47775
Olympia, WA 98504-7775

Dear Mr. Rountry,

The Chehalis Basin Partnership today agreed to endorse the Detailed Implementation Plan that will guide implementation of actions needed to achieve the water quality protections identified in existing TMDLs approved for the Chehalis Basin. The Partnership directed me to express to you our appreciation for your efforts to ensure that the Detailed Implementation Plan reflects as accurately as possible how existing local programs can contribute to the desired outcome. Your work with the Partnership's Water Quality Committee and your willingness to make revisions to the Detailed Implementation Plan are appreciated and we commend you for your commitment to local involvement.

We recognize the benefits of the completed Detailed Implementation Plan and significance of local review and endorsement. This plan clearly describes the things that need to be accomplished locally to protect water quality. It clearly identifies what role state and local government and other local organizations can play in protecting local water resources. It can be used by these organizations to support requests for funding so that they have the resources to implement their plan elements.

In endorsing this Detailed Implementation Plan however, the Partnership also must recognize the reservations expressed by some of our members. It has been EPA's stated policy that if nonpoint sources of pollution that contribute to water quality impairment are not controlled, additional reductions will be made to NPDES permit limits for point sources. Because of this federal policy that ultimately holds point sources accountable for all sources of pollution, we feel it is important that adequate resources be made available to organizations responsible for implementing portions of the Detailed Implementation Plan and that enough time be provided for the plan to show results. There are also reservations that continual changes to the state Water Quality Standards will prevent us from ever actually achieving them no matter how much time, effort and money is spent. It must be understood that these types of concerns make it difficult for local government and citizens to reach agreement on how to support TMDLs.

It should also be clearly understood that the Chehalis Basin Partnership is endorsing THIS version of the Detailed Implementation Plan for Chehalis Basin TMDLs. If substantive revisions are made to this Detailed Implementation Plan as a result of new TMDLs, or changes to existing, TMDLs the Partnership can not be said to endorse those changes until it has had time to review them.

Finally, we hope that the process used to develop this Detailed Implementation Plan for Chehalis Basin TMDLs establishes a statewide standard for local participation in development and implementation of TMDLs.

The Partnership expects to continue serving as a focal point for coordinating implementation of local elements of the Detailed Implementation Plan. We also expect to continue to advocate for cost-effective protection of water quality, and will support efforts to obtain financial support so local governments and organizations can implement their commitments to water quality protection strategies that they described in the Detailed Implementation Plan.

Sincerely,

Bob Sphar
Chairman

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