Rulemaking - PCB Variances on the Spokane River, Chapter 173-201A WAC - Informal Comment Period

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Comment From: Environmental Protection Agenc...

7/29/20 @ 5:00 PM
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Comment From: Donna Borden Rhodes

7/25/20 @ 1:17 PM
The goal should be to decrease PCBs in the river, not to allow for companies to avoid pollution abatement and continue to harm the river and the living creatures that depend on it for sustenance. No variances and decrease PCBs for the benefit of al...↓
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Comment From: Sierra Club - Upper Columbia R... (John Osborn)

7/25/20 @ 11:56 AM
We are resubmitting our attached letter dated July 9, 2019, "Spokane River TMDL variance process - EIS scoping comments" as comment for the WDOE's preliminary draft rule language and preliminary draft supporting documents: Preliminary Draft Rule Lang...↓

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Comment From: Spokane Riverkeeper (Jerry White, Jr)

7/25/20 @ 11:20 AM
Please find the Spokane Riverkeeper comments on the informal, preliminary draft rulemaking for Spokane River PCB Variances attached/uploaded. We have also uploaded several other documents for the Record. JW
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Comment From: Chastity Kolb

7/25/20 @ 9:43 AM
I am a resident of Spokane, WA, and a member of the Spokane Riverkeeper. I ask that the Washington Department of Ecology continue to protect the health and wellbeing of the members of this community and communities downstream by denying the applicat...↓
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Comment From: Gonzaga University Legal Servi... (Rick Eichstaedt)

7/24/20 @ 8:06 AM
Please find the attached comments and attachments submitted on behalf of Gonzaga University Legal Services, Environmental Law and Land Use Clinic.
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Comment From: Spokane County Environmental S... (Kevin Cooke)

7/24/20 @ 7:36 AM
See attached letter.
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Comment From: Kaiser Aluminum Washington LLC

7/24/20 @ 7:15 AM
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Comment From: Kaiser Aluminum Washington LLC

7/24/20 @ 7:13 AM
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Comment From: Prakash Bhuta

7/24/20 @ 6:33 AM
Dear Sir/Madam
I respectfully write at your decision to let PCB released in small proportion in the Spokane river. Your decision is misguided,dangerous to our health and asinine. I hope you will reconsider and drop this plan.
Thank you.

Prakash Bhuta
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Comment From: The Lands Council (Mike Petersen)

7/24/20 @ 6:02 AM
Please see our attached file - TLC Variance letter
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Comment From: City of Post Falls (Craig Borrenpohl)

7/23/20 @ 12:47 PM
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Comment From: Robert Loomis

7/23/20 @ 3:41 AM
Ladies/Gentlemen: I write with respect to the proposed PCB variance(s) relative to the Spokane River. Though I am not formally trained as an organic chemist I do have considerable experience in the fields of chemistry and toxicology. In my view th...↓
Sincerely,
Bob & Pat Loomis
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Comment From: Patty Gates

7/23/20 @ 2:15 AM
My comments are regarding Rulemaking - PCB Variances on the Spokane River, Chapter 173-201A WAC -
I stand firmly against the issuance of a variance to polluters into the Spokane River. By its very nature a variance goes against the current laws enacte...↓
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Comment From: K Green

7/23/20 @ 1:30 AM
I remember when the Spokane River was terribly dirty and toxic. There is no reason that we should go backwards on the progress that has been made, particularly with something as unhealthy and stealthy as PCB levels. I think even considering a varianc...↓
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Comment From: Jane Long

7/23/20 @ 12:53 AM
I am opposed to this variance for pollution in the Spokane River. I recently moved here and love the river. It's the heart of the city! It needs to be free of pollutants for all to enjoy. Thank you.
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Comment From: Linda Carroll

7/23/20 @ 12:27 AM
As the daughter of a Rogers High School (Spokane) chemistry teacher I am strongly opposed to the proposal to allow toxic pollutants to increase by as much as five times the upper limit allowed by the clean water plan designed to protect the health of...↓
It is the solemn obligation of the Washington State Department of Ecology to withdraw this sell-out to industry and turn to safeguarding our natural surroundings, which deeply affect our health beginning with our drinking water.
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Comment From: Kathleen Callum

7/22/20 @ 11:31 PM
Please, no PCB variances on the Spokane River or any other waterway. Clean Water is a big deal to us and the environment.
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Comment From: Anonymous Anonymous

7/22/20 @ 7:03 PM
Please protect our rivers... do not allow plastic to remain in our water.

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Comment From: John Public

7/22/20 @ 6:11 PM
We need less pollution not more.
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Comment From: Madonna Luers

7/22/20 @ 3:26 PM
Please no variances on PCB levels in the Spokane River! We can't roll back all the work so far to keep our river clean and we don't want to pass this task on to the next generation. Develop a plan using daily maximum loading limits and stick with it!...↓
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Comment From: Mark Beattie

7/22/20 @ 2:32 PM
There can be no ethical reason to allow a variance on PCB pollution in the Spokane river. The arguments in favor boil down to improving someone's financial bottom line at the expense of water quality, aquatic life and recreation opportunities for nea...↓
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Comment From: Jesse Retan

7/22/20 @ 11:52 AM
Rolling back variances for PCB limits is a horrible idea. I am an avid river enthusiast that is on the river fly fishing, hiking or biking and floating easily 200 days of the year. The river has flourished with increases of regulations over the past ...↓
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Comment From: Jennifer Brock Olson

7/22/20 @ 10:56 AM
I am saddened that we are even entertaining the idea of variances. New laws with strict rules about what could be dumped into our rivers were established some time ago. Our planet is in crisis and the fact that you are even discussing variances is a ...↓
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Comment From: MaryLou Lewis

7/22/20 @ 10:28 AM
I believe that we should continue keeping the Spokane River and its tributaries free from chemicals and other pollutants including human waste. Clean water is a necessity for humans and other animals. We should never question if the water is safe f...↓
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Comment From: Elizabeth Schneider

7/22/20 @ 9:27 AM
I oppose any variance for PCB discharge into the Spokane River. Variances are bad for the river, bad for the public and bad for the country. Instead the Department of Ecology should prepare a real plan for a maximum daily load that will strictly bu...↓
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Comment From: Aruna Bhuta

7/22/20 @ 9:10 AM
There has never been variance for toxins like PCBS in our nation. The higher PCB levels will affect most vulnerable-pregnant moms, indigenous and immigrant communities. Variance are bad for our river, public and our nation.
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Comment From: Lori Feagan

7/22/20 @ 9:07 AM
Variances are bad for our river, bad for our economy, bad for the public and bad for our nation. This is not 1960, it's 2020 and we understand the value of clean water and the health risks of loosening protections. There are negative impacts to local...↓
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Comment From: Barbara Brock

7/22/20 @ 8:43 AM
PLEASE do not go backwards...we only have ONE Spokane River and must keep this as pristine as possible for the next few generations. Adopt a legacy, think of the future, NOT just a simple fix for today and shortcuts to increase pollution. Thank you f...↓
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Comment From: Kim Harmson

7/22/20 @ 8:12 AM
To Whom it May Concern,

There have never been variances for toxic PCBs approved in our entire nation - and for good reason. PCBs have been proven to be toxic to people and planet. TOXIC.

Why then, would the Department of Ecology even consider a varianc...↓

The risks are highly detrimental - and even possibly deadly: to the general public and Spokane visitors who delights in recreating on the river, the people who rely on dietary sustenance from our river (vulnerable populations of indigenous, immigrant, pregnant mothers and young children's developing brains and bodies), the abundance of wildlife in and on our river and to the indigenous peoples of our river.

We can do better and we must. We must move forward with the implementation of a maximum daily load that will limit the toxins being dumped into our river. Let us continue to move forward as a city of growth and courageous intentionality which implements rigorous standards as we plan for the future. It is our responsibility to our children, to future generations and to the planet.

Sincerely,
Kim Harmson
704 East 23rd Ave
Spokane, WA 99203
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Comment From: Deborah Maher

7/22/20 @ 7:59 AM
Please do NOT support PBC variances to protect our river and our health!
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Comment From: David Egly

7/22/20 @ 6:51 AM
I beg you NOT to grant variances for PCBs on the Spokane River. As our environment becomes more fragile due to human use and climate change, we must hold polluters accountable and work together to protect all of our natural resources. Don't start a n...↓
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Comment From: William Brown

7/22/20 @ 5:49 AM
My guess is that the only justification for tolerating dumping PCB's in the river is some sort of financial hardship being appealed to by the polluters. At a minimum, I would want these polluters to fund an independent study looking at the economics ...↓
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Comment From: Hal Rumsey

7/22/20 @ 5:45 AM
Please think long and hard about the future before you decide on variances to increase the amount of pollutants in our river. Those who create and release toxic chemicals into our environment should be prepared to pay the full cost of prevention and ...↓
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Comment From: Jeffrey Ellingson

7/22/20 @ 5:32 AM
There can be no excuse, no reason, for allowing PCB-tainted discharges into the Spokane River system. We are continuing to improve the water quality in the River, and it is imperative that we not allow pollution levels to backslide. The River is vita...↓
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Comment From: Tom Sahlberg

7/22/20 @ 5:20 AM
Re: This, from the Spokane Riverkeeper Jerry White in the 7/22 Spokesman Review - "If successful, the variance effectively asks us to wait for another generation for the promise of clean water and edible fish to come true." PLEASE DO NOT SEEK, SUPPO...↓
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Comment From: Ray and Paula Dirks

7/22/20 @ 5:19 AM
Please fight variances to the Clean Water Act of 1972, which brought many of our nation's waterways back from the brink. We must not let a variance give a pass to pollute our beautiful treasure— the Spokane River. We need to demand that regula...↓
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Comment From: Spokane City Council

7/22/20 @ 4:45 AM
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Comment From: Gordon Larson

7/22/20 @ 4:44 AM
I am writing the environmental regulators that they must discontinue seeking variances as a solution for PCB pollutants in the Spokane River, and instead seek creative solutions that hasten to solve the problem, with definite limits to the loads allo...↓
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Comment From: Paul Lindholdt

7/22/20 @ 4:40 AM
Prepare a total maximum daily load that will limit PCB toxicity in the Spokane River.
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Comment From: Lynaia Liptak

7/22/20 @ 3:34 AM
I oppose variances to the laws that keep our river clean.

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Comment From: Jesse Korb

7/22/20 @ 3:05 AM
As a local angler & resident of Spokane, I contend that variances are bad for our River. As a citizen of the inland northwest, I would love to see our continued efforts in our clean cool water that we can pass down to generations proudly. Thanks!
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Comment From: Doug Lindvall

7/22/20 @ 3:05 AM
Cathy MR wants to do away with hard-earned protections for the air we breath, and the water we drink, in lockstep with our deluded president. Their donors insist on it.

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Comment From: Mary Sullivan

7/22/20 @ 2:32 AM
I am strongly opposed to a variance for PCB levels in the Spokane River. If a variance is issued, human nature is such that nothing will be done until the end of this 20 year window. If no variance is granted this problem will be tackled now. Now ...↓
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Comment From: debbie Anonymous

7/22/20 @ 1:02 AM
Please, no variances. Keep our river clean and healthy. Do not add rules to help circumvent the limits to pollutants. We need a rule that will mandate limits on PCB toxins being dumped into our river.
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Comment From: Leeanna WhisperingHorse

7/21/20 @ 11:41 PM
This PCB Variance is bad for the Spokane river. We as 'the most intelligent' species should know this. Haven't we done enough damage already? We need to think outside the box to create less toxic environments, not going backwards and trying to get aw...↓
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Comment From: Spokane Tribe of Indians Depar...

7/21/20 @ 8:00 AM
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Comment From: James Tuck

7/21/20 @ 3:34 AM
I am making a formal comment on the variances that the WDOE is considering for the Spokane River. It is WDOE job to hold polluters responsible and to adhere to the Clean Water Act of 1972. Polluters need to be held accountable and therefore industr...↓

Sincerely,

James E. Tuck
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Comment From: Lauren Davis

7/20/20 @ 12:39 PM
Washington state residents have showed strong support for clean water and air. I am one of the citizens of Washington that support continued efforts to mandate the Total Maximum Daily Load of PCB's be limited. We have worked hard to clean up the ri...↓

Variances are bad for the river, for the fish and other life in the river, for the people, for the state. Please hold industry accountable for their accumulated waste.

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Comment From: Charlie Martin

7/20/20 @ 2:22 AM
Our river is fed by our aquifer and also feeds our aquifer, one of the purest sources of drinking water in the world. These companies have plenty of money to clean up their wastewater or have it processed by our water reclamation facilities.
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Comment From: James Cronin

7/18/20 @ 3:37 PM
The Draft Environmental Impact Statement does not explore the impacts of stalling the timelines to meet state pollution standards.
The draft Environmental Impact Statement needs to address a "no discharge" alternative - explore the impacts of getting ...↓
More actions are needed to reduce and remove PCB toxins from waste water needs to be inside the "Pollution Minimization Plans". These PMPs are a part of the variance applications. Many of the current plans are vague or do not go far enough.
Increase the reporting and accountability inside the variances. Every discharger should be mandated to finding and reporting-on the latest, developing technology to destroy toxics in their pollution discharge
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Comment From: Denise Attwood

7/18/20 @ 6:37 AM
To Washington State Department of Ecology,
I kindly request that you do not grant any variances to industries who are dumping PCBs into the Spokane River.
If variances are allowed, 5 major polluters, will be exempted from meeting the lawful state stand...↓

The Spokane River is a recovering river ecosystem that still has a long way to go before becoming the clean and pristine system that it needs to be for it to survive. If we allow 5 regional dischargers a 20-year pass to dump as much as 140 times the legal limit for pollution into the Spokane River then the health of the river ecosystem and those that engage with it will decline. This is not the intent of the DOE's mission to "Protect, preserve, and enhance the environment for current and future generations".
The variances in question will also enable those dischargers to avoid federal pollution limits which protect the health of local residents and the health of our fish and those animals and humans that rely on them. The variances also ignore the purpose of the Clean Water Act by letting polluters propose how many toxins they would like to dump into the Spokane River.
Granted it is difficult to come up with the technology to limit the PCBs but then again it is difficult to restore a healthy river ecosystem that has been heavily damaged by past pollution. In the end the state will have to pay the cost if more PCBs are dumped into the river. Eventually taxpayer dollars will be needed to clean up the pollution or to provide healthcare for those who become sick due to the toxins. Better to let the polluters figure out how to deal with the costs of their own waste rather than making the state have to clean up after them.
Please do not allow for variances.
Thank you for your time.
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Comment From: Anna Belinski

7/18/20 @ 4:24 AM
Variances should NOT be granted to these river polluters. This is just another way of pushing back dealing with the issue of an over-polluted Spokane River and giving leeway to powerful toxic industry. PLEASE put the Spokane tribe, people of Spokane,...↓
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Comment From: Alex Richardson

7/17/20 @ 10:51 PM
I don't support any variances that allow more pollutants into our river. The river is not even clean enough to eat from without the variances, and I think our biggest goal as the Spokane community should be to restore the water quality to a pristine ...↓
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Comment From: Jeffrey Ridlington

7/17/20 @ 11:20 AM
It is important to protect our rivers and water system in Spokane. There should not be any variances permitted to pollution.
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Comment From: Debbie Stempf

7/17/20 @ 5:02 AM
Do NOT allow increases in the variances accepted in our river! Protect our childrens' children's water and do not allow increased PCBs into our river system!
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Comment From: Anne Tenold

7/17/20 @ 3:49 AM
Please provide a cleanup plan that holds all polluters responsible - a Total Maximum Daily Load. Please put polluters on 10-year compliance schedules to clean their pollution up. Please protect our river!

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Comment From: Anonymous Anonymous

7/17/20 @ 3:25 AM
Please do not permit these variances. There is no reason to allow the further pollution of the Spokane River to assuage large, successful companies in their search for higher profits. It has taken years to get the River back towards it's current leve...↓
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Comment From: Bill Codd

7/17/20 @ 12:26 AM
As a concerned citizen of Spokane, I an strongly encouraging you to rule in favor of the health of the Spokane River. Don't allow variances on toxic pcb's entering the river. Those standards were set for good reason.
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Comment From: Nancy Schaub

7/16/20 @ 11:33 PM
Please do not grant these variances to polluters. Polluting the Spokane River is an egregious violation of the rights of all nature: humans, animals, all life.
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Comment From: Emily Davis

7/16/20 @ 10:44 PM
Hello Department of Ecology,
As a citizen of Spokane I do not accept or support any toxic pollution variances in the Spokane River. Dischargers need to be held to tight pollution standards in order to maintain the health of the Spokane River. A lawful...↓
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Comment From: Ben Rall

7/16/20 @ 9:59 PM
The proposed variances would:
Allow four regional dischargers a 20-year pass to dump as much as five times the legal limit for pollution into your river. One pollution discharger has applied for a 10 year variance.
Enable those dischargers to avoid est...↓
Ignore the purpose of the Clean Water Act by letting polluters propose how many toxins they would like to dump into your river.
Ignore the intention of the Clean Water Act to eliminate all water pollution by 1987.
Do ask the WDOE for a clean up plan that holds all polluters responsible - a "Total Maximum Daily (pollution) Load". This kind of plan will pin pollution dischargers to pollution limits for the entire river.
Do ask WDOE to put polluters on 10 year compliance schedules to clean their pollution up.

Specifically, the review of the documents reveals issues that Ecology needs to address:

The Draft Environmental Impact Statement does not explore the impacts of stalling the timelines to meet state pollution standards.
The draft Environmental Impact Statement needs to address a "no discharge" alternative - explore the impacts of getting all pollution out of the Spokane River.
More actions are needed to reduce and remove PCB toxins from waste water needs to be inside the "Pollution Minimization Plans". These PMPs are a part of the variance applications. Many of the current plans are vague or do not go far enough.
Increase the reporting and accountability inside the variances. Every discharger should be mandated to finding and reporting-on the latest, developing technology to destroy toxics in their pollution discharge.
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Comment From: Christopher Carter

7/16/20 @ 5:56 PM
Please safeguard the future health of the Spokane River and all other state habitats; that is your job. I actually worked for the WCC for two years, which is an offshoot of WA DOE. After serving on the Spokane WCC crew and working to restore damaged ...↓
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Comment From: Debbie Novak

7/16/20 @ 3:56 PM
I want the WDOE to not grant any variances that allow for any further polluting of our Spokane River or any water ways. We were expected to have the River cleaned up by 1987. Looks like we missed that date! I expect the WDOE to stand true to the p...↓
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Comment From: Gwen Ammon

7/16/20 @ 2:48 PM
The Spokane River has been cared for with regular clean ups since it went through a large toxicology cleanse many years ago. Currently it offers a clean source for the surrounding wildlife as well as a cool place for my small child and I to spend hot...↓
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Comment From: Sarah Iannelli

7/16/20 @ 2:17 PM
I don't think there is any safe limit for PCBs and toxins to be released into our rivers. We should be trying to minimize their concentration rather than loosening limits on how much of this toxic pollution can be released into our environment. I do ...↓
Please include a clean-up plan that holds all polluters responsible, for example, a plan that includes a "Total Maximum Daily (pollution) Load". This kind of plan will pin pollution dischargers to pollution limits for the entire river. Polluters should also be put on 10 year compliance schedules to clean their pollution up.
The Draft Environmental Impact Statement does not explore the impacts of stalling the timelines to meet state pollution standards. Please look into this in more detail.
The Draft Environmental Impact Statement needs to address a "no discharge" alternative that explores the impacts of getting all pollution out of the Spokane River.
More actions are needed to reduce and remove PCB toxins from waste water; this needs to be included in the "Pollution Minimization Plans".
There needs to be an increase in the reporting and accountability inside the variances. Every discharger should be mandated to finding and reporting on technology that could be used to destroy/breakdown toxins in their pollution discharge.

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Comment From: Anonymous Anonymous

7/16/20 @ 1:46 PM
Common sense says PCB's or any other damaging pollutants don't belong in the Spokane River at all. Nature is a gift and should be respected and passed on for generations after us. Not only for us humans, but also to protect wildlife and natural habi...↓
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Comment From: StaffReady (Nancy Janzen)

7/16/20 @ 1:11 PM
As the CEO of StaffReady, I care deeply about the river running through the city where we headquarter our company. I'm in opposition to any rollbacks or variance allowances that would increase in anyway pollution load on our river.

I want our region t...↓

We have made great strides as a country in moving to protect and manage our natural resources as opposed to short-term loopholes focused on quick profit.

Thank you for your consideration,
Nancy Janzen
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Comment From: Michael Van Dyke

7/16/20 @ 12:29 PM
Hello,

I am a pediatrician in Spokane WA and I'm commenting on the proposed rulemaking changes to amend chaper 173 201A. I want to let you know that improving the health of our Spokane River is vital to our children's health. Clean water, free of p...↓
Some suggestions:
Consider a Total Maximum Daily (pollution) Load. This can restrict pollution dischargers to pollution limits for the entire river.
Consider using and sticking to 10 year compliance schedules to force polluters to clean their pollution up.
Ensure PMP's are not vague and that specifics when added are followed up on.
Finally, increase the reporting and accountability inside the variances. Every discharger should be mandated to finding and reporting-on the latest, developing technology to destroy toxics in their pollution discharge.

Thank you for all your hard work for our wonderful Spokane River and the people of Washington State.

Sincerely,

Michael Van Dyke DO
319-333-8326
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Comment From: Imaginary Trout LLC

7/16/20 @ 12:02 PM
The Draft Environmental Impact Statement does not explore the impacts of stalling the timelines to meet state pollution standards.

The draft Environmental Impact Statement needs to address a "no discharge" alternative - explore the impacts of getting ...↓

More actions are needed to reduce and remove PCB toxins from wastewater needs to be inside the "Pollution Minimization Plans". These PMPs are a part of the variance applications. Many of the current plans are vague or do not go far enough.

Increase the reporting and accountability inside the variances. Every discharger should be mandated to finding and reporting on the latest, developing technology to destroy toxins in their pollution discharge.
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Comment From: Joshua Abel

7/16/20 @ 11:59 AM
The Draft Environmental Impact Statement does not explore the impacts of stalling the timelines to meet state pollution standards.

The draft Environmental Impact Statement needs to address a "no discharge" alternative - explore the impacts of getting ...↓

More actions are needed to reduce and remove PCB toxins from waste water needs to be inside the "Pollution Minimization Plans". These PMPs are a part of the variance applications. Many of the current plans are vague or do not go far enough.

Increase the reporting and accountability inside the variances. Every discharger should be mandated to finding and reporting-on the latest, developing technology to destroy toxics in their pollution discharge.
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Comment From: Sheri Lattimore

7/16/20 @ 11:15 AM
No one, no entity should be allowed to dump poisons into our river. The river is a community resource for fishing and other recreation as well as the home to a variety of wildlife. The river and its silent power is enjoyed by everyone in our area. ...↓
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Comment From: Sheri Lattimore

7/16/20 @ 11:13 AM
No one, no entity should be allowed to dump poisons into our river. The river is a community resource for fishing and other recreation as well as the home to a variety of wildlife. The river and its silent power is enjoyed by everyone in our area. ...↓
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Comment From: Spokane Falls Trout Unlimited (Board of Directors)

7/16/20 @ 11:09 AM
The Draft Environmental Impact Statement does not explore the impacts of stalling the timelines to meet state pollution standards.

The draft Environmental Impact Statement needs to address a "no discharge" alternative - explore the impacts of getting ...↓

More actions are needed to reduce and remove PCB toxins from waste water needs to be inside the "Pollution Minimization Plans". These PMPs are a part of the variance applications. Many of the current plans are vague or do not go far enough.

Increase the reporting and accountability inside the variances. Every discharger should be mandated to finding and reporting-on the latest, developing technology to destroy toxics in their pollution discharge.
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Comment From: Christopher Lawrence

7/16/20 @ 10:41 AM
The implementation of thee new rules are against everything we have fought for to combat water pollution!
Ecology needs to address:
-The Draft Environmental Impact Statement does not explore the impacts of stalling the timelines to meet state pollution...↓
-The draft Environmental Impact Statement needs to address a "no discharge" alternative - explore the impacts of getting all pollution out of the Spokane River.
-More actions are needed to reduce and remove PCB toxins from waste water needs to be inside the "Pollution Minimization Plans". These PMPs are a part of the variance applications. -Many of the current plans are vague or do not go far enough.
-Increase the reporting and accountability inside the variances. Every discharger should be mandated to finding and reporting-on the latest, developing technology to destroy toxics in their pollution discharge.

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Comment From: Anonymous Anonymous

7/16/20 @ 10:39 AM
Please do not allow variances - it is important that Spokane moves forward in maintaining the beauty of our rivers and ecology.
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Comment From: Dale Arnold

6/28/20 @ 8:06 AM
PCB's have been investigated for many decades and Allowable concentrations have been developed based on impacts to Health, Microorganisms and the Environment.
These Chemicals are Carcinogenic and in Lower Concentrations have been found to effect Repro...↓
The Current PCB standard is not protective. The proposed standard is one that does approach the protective level of the Environment. In light of the presence of PCB's in so many of the Products that are commercially available one must do what ever is reasonable to introduce controls when and where they can be most effective. Which is why I support the 7 parts per quadrillion standard the Ecology proposed.

As for the Dischargers to the Spokane Rivers request for a Variance This is something that should not be approved.

There are other ways to deal with discharges that do not meet standard. There are ways that a temporary waiver of the standard can be granted while the entity studies, reviews and designs a system to meet the standard. There are yearly extensions to the current permits that can allow the discharger to conduct business while all the while design and build facilities to me the standard.

Today there is NO discharger on the River who has completed their tertiary upgrades to meet the Phosphorus Standard. Without this initial Treatment how can Ecology and the Discharger evaluate additional PCB treatment needed?

I would suggest that ONLY After completion of the Tertiary treatment Facilities of a Discharger that an Evaluation of the effectiveness of that unit to remove PCBs be initiated.

Today it is too premature to allow a variance of a discharge BEFORE the effectiveness of Treatment for that discharge.

PCB's are such a problem in the Environment we must require Everyone who impacts It to do their fair share of cleanup.

The Users of the River are also the Rate Payers and the Consumers who pay for PCB removal. I'm sure that as users of the Spokane River they are supportive of additional cost to remove these pollutants when ever practical.

My Knowledge of the City of Spokane Facility is that it was undersized in it's design. It assumed during wet weather events the discharge of Settled Stormwater and Final Filter Effluent can be blended to meet the Total Phosphorus Standard. This short sightedness never considered the increase treatment capabilities of a larger Facility to also reduce PCB discharges during wet weather/high flow events.

Evaluation of this Facility Discharge needs to be done BEFORE issuing and variance to current water quality standards.

Performing a Due Diligence Study of the Dischargers Facilities needs to take place Before issuing a Variances. And, All those impacted From Tribes and Users of the River to the Rate Payers funding improvements be identified.

The true cost and Impact must be evaluated

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Comment From: Dawn Spickler

6/26/20 @ 4:39 AM
As far as I know PCB's are a known carcinogen. Why would we pollute the Spokane River with such chemicals? Is business more important than human health?

As a resident of Spokane, Washington I am strongly against dumping carcinogens into our river.
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