Preliminary Determination to Develop a Puget Sound Nutrients General Permit

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Comment From: City of Bremerton (Tom Knuckey)

10/21/19 @ 4:00 PM

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Comment From: Cindy Hansen

10/21/19 @ 1:59 PM

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Comment From: Marine Resources Advisory Coun... (Martha Kongsgaard)

10/21/19 @ 11:05 AM

See attached letter for comments from the Marine Resources Advisory Council. Thank you for the opportunity to provide comment.

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Comment From: Puget Sound Partnership (Laura Blackmore)

10/21/19 @ 10:47 AM

Comments attached.

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Comment From: Joint Utilities Response Lette... (Teresa Peterson)

10/21/19 @ 9:05 AM

Please see the attached file.

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Comment From: Mindy Roberts, Washington Envi... (Mindy Roberts)

10/21/19 @ 8:36 AM

Please see attached comment letter from Washington Environmental Council, Nisqually Indian Tribe, Zero Waste Washington, Seattle Audubon, Salmon-Safe, Deschutes Estuary Restoration Team, Olympia Environmental Council, Surfrider Foundation, and RE Sou...↓

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Comment From: City of Everett - LCB (Mark Sadler )

10/21/19 @ 8:15 AM

Please see the uploaded PDF.

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Comment From: City of Tacoma (Teresa Peterson)

10/21/19 @ 8:09 AM

Please see the attached letter from the City of Tacoma.

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Comment From: Northwest Indian Fisheries Com... (Alice Johnstone)

10/21/19 @ 8:07 AM

Good afternoon, Attached is a letter to Maia Hoffman, Washington Department of Ecology, Water Quality Permit Coordinator, from NWIFC Executive Director Justin Parker, regarding NWIFC Comment Letter on Ecology's Preliminary Determination - Puget So...↓

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Comment From: Lakehaven Water and Sewer Dist... (John Bowman)

10/21/19 @ 8:05 AM

See attached letter.

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Comment From: Judi Gladstone

10/21/19 @ 7:30 AM

Thank you for the opportunity to comment on the Department of Ecology (Ecology) proposed nutrient discharge general permit for wastewater treatment plants (WWTPs) that discharge to Puget Sound. The Washington Association of Sewer and Water Distri...↓cts (WASWD) represents local public water and wastewater districts throughout the state. Our members are dedicated to providing safe drinking water, and wastewater collection and treatment that protects local environments. Of these members, thirteen have WWTPs that discharge directly to Puget Sound. These members collectively represent about 25% of agencies, as identified by Ecology, that would be affected by the development of this proposed General Permit. WASWD member districts are committed to clean water for their communities, making significant investments to provide cost-effective services in a way that best utilizes limited funding. To that end, further investments to protect Puget Sound need to be focused on those efforts with the greatest potential to improve water quality. A general permit could be a tool for achieving that if it produces water quality outcomes commensurate with the cost of any regulatory requirements. We appreciate Ecology's efforts to address dissolved oxygen impairment in Puget Sound, including the development of the Salish Sea Model and the Forum conducted for stakeholders to provide input on that modeling and potential management solutions. In considering the potential use and impact of a general permit for nutrients, WASWD members have three overarching concerns discussed in this letter: optimizing benefits regionally with innovative approaches that will support affordable rates for customers; utilizing robust scientific modeling to identify cost-effective solutions; and engaging stakeholders to inform permit provisions. WASWD has also co-signed a letter along with other wastewater treatment agencies in the region that identifies additional detailed concerns our members support. Affordability Adding nutrient removal to wastewater treatment facilities will be extremely expensive, not just in initial cost, but for operations, maintenance, upgrades and training of personnel. Higher costs, such as increased electrical usage which contributes to a larger carbon footprint, have been indicated by WWTPs reporting at the Puget Sound Nutrient Forum (PSNF) meetings. In addition, not all WWTPs have equal ability to implement nutrient removal. A General Permit framework can take this into account by focusing reductions based on a watershed and/or regional Puget Sound basis to accommodate creative and flexible solutions such as trading, bubble permits and offsets. Meeting water quality goals for watershed areas or Puget Sound as a whole will allow the biggest benefit for dollars spent and make it more affordable for customers. Science-based Decisions Having solid science-based decisions backing permit provisions is essential for making the case to ratepayers that the associated rate increases will produce water quality results that make the rate increase worthwhile. In one of the PSNF meetings, Ecology brought in representatives from 3 areas using nutrient general permitsLong Island Sound, Chesapeake Bay and San Francisco Estuary. These presentations indicated that reductions in nutrients were occurring under these permits. What it did not demonstrate, for the most part, was how these reductions were making a clear ecological and environmental difference in those regions. The modeling done by Ecology focuses on nutrient reduction making a small change in dissolved oxygen levels. The effects this will have on salmon and orcas is not clear, however, and certainly not demonstrated. Measurable science-based outcomes are needed to be able to make permit adjustments as more information is obtained, to demonstrate that actions taken are having the desired effect on the ecosystem, and to demonstrate to the public that higher wastewater bills for customers are providing the best value to Puget Sound water quality. Further, science-based decisions must be supported by modeling of the complete system, including non-point pollution and upstream conditions that play a significant role in nutrient enrichment. Especially since Ecology has already stated that nutrient reductions at WWTPs will not solve the problem alone, information from the watersheds needs to be utilized in determining the most cost-effective solution to the problem. Stakeholder Engagement In developing and implementing permits, stakeholder engagement is crucial in getting adequate information and input on permit issues. Individual WWTP permits involve significant discussion between utility staff and Ecology to determine improvements and direction over the typical five-year term of NPDES permits. A general permit for nutrients will need this approach as well, especially when it comes to innovation. Ecology would need to coordinate closely with wastewater stakeholders during the development of any draft and final general permit requirements. Regional collaboration among Puget Sound point source dischargers, along with other stakeholders in the region including other governmental agencies, academic sciences, environmental groups and business leaders should be explored. The Bay Area Clean Water Agencies (BACWA) and/or the San Francisco Estuary Partnership may be good models for Puget Sound to provide a way for hearing directly from stakeholders and having well-informed Puget Sound nutrient reduction assessment, planning and implementation. WASWD members want wastewater ratepayers to have confidence that public investments driven by a General Permit can demonstrate a direct connection commensurate with tangible improvements to the health of Puget Sound. Science-based measurable outcomes, and approaches that lead to cost-effective solutions, can make a General Permit a useful tool in addressing nutrient discharges. Thank you again for the opportunity to comment on the "Preliminary Determination to Develop a New General Permit." Judi Gladstone Executive Director WASWD

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Comment From: Jamestown S'Klallam Tribe (Robert Knapp)

10/21/19 @ 7:11 AM

Jamestown S'Klallam Tribe Please find the attached comment letter regarding the general permit approach to nutrient pollution in Puget Sound.

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Comment From: Surfrider Foundation (Gus Gates)

10/21/19 @ 7:00 AM

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Comment From: Working Group on Seafood and E... (Brad Warren)

10/21/19 @ 6:01 AM

Thank you for proposing this important step to reduce nitrogen loading, hypoxia, and acidification in Puget Sound. On behalf of the Working Group on Seafood and Energy, I'm pleased to submit the attached comment letter in support of the proposed Gene...↓

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Comment From: Coalition for Clean Water (Donald Seeberger)

10/21/19 @ 6:00 AM

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Comment From: City of Langley (Randi Perry)

10/21/19 @ 5:00 AM

Subject: Ecology's Preliminary Determination to Develop a Puget Sound Nutrients General Permit The City of Langley is not in favor of a General Permit to control nutrients in discharges from domestic wastewater treatment plants WWTP. Each WWTP di...↓

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Comment From: Surfrider Foundation Washingto... (Gus Gates)

10/21/19 @ 3:23 AM

See attached letter from Surfrider Foundation Washington Chapters

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Comment From: Surfrider Foundation Washingto... (Gus Gates)

10/21/19 @ 3:14 AM

See attached letter from Surfrider Foundation Washington Chapters

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Comment From: Sue Joerger

10/21/19 @ 3:06 AM

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Comment From: Joseph Grogan

10/21/19 @ 2:31 AM

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Comment From: Abby Barnes

10/21/19 @ 2:23 AM

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Comment From: Jim Voetberg

10/21/19 @ 12:51 AM

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Comment From: Olympic Environmental Council (Darlene Schanfald)

10/20/19 @ 10:59 AM

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Comment From: Alyssa Barton

10/18/19 @ 9:24 AM

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Comment From: King County Department of Natu... (Christie True)

10/18/19 @ 8:16 AM

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Comment From: Lake Stevens Sewer District (Caitlin Hubbard)

10/18/19 @ 4:07 AM

Water Quality Permit Coordinator Northwest Regional Office Washington State Department of Ecology 3190 160th Avenue SE Bellevue, WA 98008-5452 Regarding: Whether a general permit is the appropriate tool to control and reduce nutrients in disch...↓arges from WWTP's to Puget Sound. Dear Ecology: The answer to the above question is no, a general permit is not the appropriate tool to control and reduce nutrients in discharges from WWTP's to Puget Sound. A general permit would not take into account a WWTP's receiving water, present or future capacity to remove nutrients, or the ability of its ratepayers to bear the burden of cost. This last point is perhaps the most poignant: a blanket general permit such as this would adversely affect the poorest and most vulnerable members of our population, as those communities would be held to the same standard as wealthier ones, without consideration of how the ratepayers would cover the cost. Wealthy communities will have an easier time either buying their way out of these limits or purchasing, installing and maintaining the technology needed to achieve nutrient reductions. The Lake Stevens Sewer District believes it would be more important to invest in efforts to quantify non-point source, agricultural, and Victorian inputs of nutrients into Puget Sound before requiring the expenditure of billions of dollars. While WWTP's may appear to be low hanging fruit, that fruit is small and withered compared to other yet-to-be quantified inputs of nutrient sources to Puget Sound. If this must happen immediately, we ask that a means of funding be included in order to protect those ratepayers in the most vulnerable portions of society. Because the receiving waters of the Lake Stevens Sewer District have not been sampled in a long time, and this comment period encouraged submitting data about receiving waters, LSSD sampled Ebey Slough upstream and downstream of its outfall. Sampling was conducted 150' north and south of the outfall via grab sample from a boat. Because Ebey Slough is a marine estuary with flow direction dependent on the tide, sampling occurred while the tide was coming in (flowing north) and when the tide was flowing out (flowing south). The mixing zone for this outfall is 215' in length, and sampling was conducted outside of this zone. During the first sampling, the downstream sample was 0.01 mg/L lower in Total Inorganic Nitrogen (TIN) than the upstream sample. When the tides changed, again the downstream sample was 0.01 mg/L lower than the upstream sample. Supplemental information for this sampling event is included in the following pages. We are dedicated to protecting and enhancing water resources in Puget Sound, and are hoping for a collaborative approach that gets most impact per dollar spent. Thank you for your consideration, Caitlin Hubbard, Lake Stevens Sewer District

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Comment From: City of Oak Harbor (City of Oak Harobor )

10/17/19 @ 7:26 AM

City of Oak Harbor comments in attached file. File includes transmittal letter and Resolution.

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Comment From: Cassandra Moore, Senior Planne... (Cassandra Moore)

10/17/19 @ 4:56 AM

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Comment From: Celina Abercrombie

10/17/19 @ 2:24 AM

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Comment From: Alderwood Water and Wastewater... (Larry Jones)

10/16/19 @ 4:00 PM

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Comment From: Donald Monahan

10/13/19 @ 4:00 PM

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Comment From: City of Edmonds (Pamela Randolph)

10/10/19 @ 3:35 AM

October 10, 2019 Water Quality Permit Coordinator Northwest Regional Office State of Washington Department of Ecology 3190 160th Avenue SE Bellevue, WA 98008-5452 Subject: Ecology's Preliminary Determination to Develop a Puget Sound Nutrient...↓s General Permit The City of Edmonds respectfully submits the following comments and questions regarding the use of a General Permit to control nutrients in discharges from domestic wastewater treatment plants to the Puget Sound as presented by the Department of Ecology (DOE) during the August 7, 2019 forum. Prior to sharing our comments and questions on the use of a General Permit, we will outline our concerns with the current approach. We have heard that the driver for this expedited approach is the threat of legal action from a third party. The General Permit approach appears to be somewhat reactionary and based upon a "willingness to pay" criteria instead of continuing with Ecology's previous thoughtful and scientifically-based approach which is based on accepted water quality modelling impacts. While the threat of legal action is real and becoming more prevalent in our society, a third party litigant will not be held accountable for the unintended consequences that may result. Making a precipitous change in direction based on threatened or filed legal action seems like a misguided approach to improving the health of the Puget Sound and does not guarantee a cleaner Puget Sound. We encourage DOE to continue with their original approach, i.e. using a calibrated water quality model, to set discharge limits based on the size and location of the discharge and the resulting nutrient loadings. Please do not let the threat of legal action push you into an expedient regulatory response that may result in unintended consequences but will surely result in far greater costs. Without understanding the specifics of how a General Permit would be utilized, it is difficult to comment on the approach in a qualified and comprehensive manner. Under the right conditions, the City might support a General Permit; however the manner in which it is applied and integrated with the current Individual Permit should be clearly presented by the DOE. We believe that the Individual Permit is the best approach to control the impact that a facility has on the receiving body of water. The Individual Permit is already in place, it is clearly understood, it is facility focused, and evaluates the mixing zone and discharge loads. Using the Individual Permit would not create future conflicts with requirements that may be contained in a General Permit and its requirements are clear and concise. The DOE needs to explain precisely how a General Permit would improve upon the Individual Permit approach and how the two permits would be integrated. A general permit can't possibly account for differences in discharge location, different currents, different nutrient concentrations, and other characteristics that vary from plant to plant. Using a General Permit would mean maintaining yet another layer of permitting requirements. A new permit must be managed, meaning it will require additional paperwork and a lengthy application process. This level of effort requires additional resources both within the agency affected and within the DOE. There will no doubt be additional fees established to fund the DOE level of effort. These funds would best be used to reduce or contain nutrients or achieve other water quality or habitat goals. We do understand that a potential benefit of using a General Permit could be that agencies might work together in order to develop nutrient sharing models or processes to "share the load." We are aware that this approach may have been utilized in other areas of the country, however we do not have confidence this approach will be successful in the Puget Sound area. There is a concern that the larger agencies, with available staff, will dominate the conversation and the outcome. We believe that a sharing model or trading scheme may border on overreach in an effort to extend this massively expensive program to all facilities through a General Permit when the largest six contributors to nutrient enrichment are located close to where the problems are and where controls would have the biggest impact. If these six facilities are primarily responsible for the dissolved oxygen depletion in South Puget Sound (based on modelling), it seems that is where this program should start. If controlling nutrients at those facilities does not result in an adequate amount of improvement then phase 2 of this program could be initiated with additional participants. Otherwise you end up with all of the little, remote facilities helping the larger facilities (with many more ratepayers) pay for the problem they have arguably created. Specific comments and questions are: • Please clarify "capping the load". Will smaller plants not at full capacity and are in an urban growth setting be limited in order to allow larger plants, typically in the more populated areas, to realize future growth? • Some trading schemes, such as the Chicago Carbon Exchange have not proven effective in achieving their goals. Other schemes, such as the Long Island Sound model, demonstrate that it may be possible for nutrient trading to occur however without the benefit of water quality improvement in the targeted area. Would a credit from the north Puget Sound carry the same weight as a credit from the south Puget Sound? Would a nutrient trading scheme be applied only to load limits? Any scheme that is developed that does not target the water quality of the South Sound would likely not be supported. It is questionable whether a nutrient trading scheme would be beneficial even if one were to be developed. • Will the General Permit contain all limits associated with nitrogen or would be additional nitrogen limits imposed (i.e., concentration limits for nitrate) to the Individual Permits? • This effort is referred to as a "Nutrients Limit" implementation. Is it limited to Nitrogen only or are you also planning on addressing phosphorus at some point. If not why is it referred to as a nutrients limit and not a nitrogen limit? • The General Permit announcement indicated additional data could be requested and submitted by the affected treatment plants during the comment period but does not give any examples of the type of data Ecology might find useful. What sort of data would be useful to this process? How will the data be used and shared? If additional data is needed, we question the wisdom/value of moving forward so quickly with the implementation of a General Permit. • Can the two-tiered implementation concept, which was shared during the last forum, be accomplished by using Individual Permits? • A previous version of the Puget Sound Oxygen model described a "line in the sound". This line represented a delineation between flows and mixing zones between the South Sound and the Northern Sound. Will this delineation between North and South be further studied? If not, why not? • It is not clear how a General Permit for WWTP's will provide an ability to approach the larger watershed management needs? As outlined in the DOE presentations, the challenge appears to be greater than the WWTP loads alone. • If a General Permit is utilized, would any compliance schedules for meeting nutrient limits be contained in the General Permit or would they be included in Individual Permits? • Is the DOE considering both Load limits and concentration limits? • Would ammonia limits (particularly as it pertains to concentration limits for acute and chronic toxicity) remain in the Individual Permits or would they be within the General Permit? • DOE has indicated that in response to the NWEA petition nutrient loads will be capped for WWTPs. Will these caps set the initial allocation for nutrient loads under the General Permit based on rated facility capacities or will new permitted loads be established? • If existing facilities were already achieving nutrient limits, would they still need to apply under the General Permit? If yes, arguably the effect would be to solely share the cost of the new program. • WWTPs are permitted based on BOD and TSS removal. Would the General Permit require re-rating of existing facilities with regard to nitrogen removal? If so, what happens to a facility that is at 50% of capacity vs. a plant at 80% capacity? The City of Edmonds does not support the use of a General Permit at this time. There are too many unknowns which must be clarified prior to supporting the use of General Permit. We suggest a series of meetings be held so that the Ecology can fully explain the benefits, risks, and cost implications of using a General Permit. We ask for time to form a coalition, develop a structure in which to work, establish rules of engagement, and establish clear goals and criteria to address nutrient removal as a community. A coalition approach may prove beneficial in order to develop partnerships and advice to both legal and environmental concerns that have impact on our communities and the Puget Sound. While we all take pride in our mission and commitment to protect the Puget Sound there must be scientific evidence, a level playing field, and an impact-based approach established that focusses the effort on the area of concern.

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Comment From: Northwest Environmental Advoca... (Nina Bell)

10/09/19 @ 6:12 AM

Please see comment letter uploaded.

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Comment From: Washington Water Service (Roy Stanton)

10/08/19 @ 4:00 PM

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Comment From: The Freshwater Trust (Joe Whitworth)

10/08/19 @ 3:45 AM

Please see attached comments.

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Comment From: Victoria Hansen

10/08/19 @ 3:22 AM

The PSNGP is Extinct!! DOE must move heaven and Earth to stop all nutrients from Entering Puget Sound! NO MORE DILUTION! After Last Summer's sewage spills and overflows, Puget Sound is over saturated and declining to the point of tipping.

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Comment From: Jonathan Kercher

10/07/19 @ 3:50 AM

As a wastewater treatment plant operator of over ten years, I can honestly say the time for a general permit is long past. The current target of 15 years to completion is unacceptable. Many plants are in disrepair and need rebuilding today. This comp...↓

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Comment From: LOTT Clean Water Alliance (Lisa Dennis-Perez)

9/23/19 @ 2:29 AM

Please see the attached file

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Comment From: Robert Vadas, Jr.

9/20/19 @ 3:51 AM

Because general permits have helped reduce estuarine eutrophication in northeastern-USA states, such additional, efficient management would likely benefit Puget Sound, especially if it achieves a total cap on nutrient releases. This is crucial, given...↓

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Comment From: Olympia Urban Waters League (Harry Branch)

9/19/19 @ 8:08 AM

Urban stream burial increases nitrogen transport. It's about structure, how physical parameters impact chemical and biological parameters. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4505844/

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Comment From: CRAIG DOBERSTEIN

9/09/19 @ 3:47 AM

I support Ecology's plans and efforts to develop a Puget Sound Nutrients General Permit. While regulations in general are not always popular, I believe water quality protection is too important of an issue to treat passively, and too easy for public ...↓

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Comment From: Helen Zenon

9/05/19 @ 4:00 PM

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Comment From: Brian Richardson

9/05/19 @ 12:41 AM

I have been employed as a wastewater operator since 1983, in that time I have seen other states and countries surpass Washington in treatment methods that would protect our waterways and as a result protect the wildlife that resides there. Europe and...↓ China have advanced their treatment technologies well beyond most areas of the United States yet engineers and managers in our state are hesitant to embrace these many proven technologies. Ecology is on the right track with process optimization as many facilities are not doing all they can within their own design. Process optimization should be the first step and mandatory for all facilities regardless of size and include the requirement of hiring a process control specialist to ensure any changes are appropriate and effective. The Federal Clean Water act of the 70s was a huge step in water quality improvement in the US, however its time for a new and improved Clean Water Act to meet todays technology and take the next step to close in on 100% treatment with direct reuse. Washington can be a leader in this endeavor with its own Clean Water Act Legislation. Nutrient and Pharmaceutical removal from WWTP is critical to keeping our water ways clean. Another large component that is actually far worse than wastewater discharge is storm water run off, bioassay testing of storm water shows a much higher and faster mortality of study specimen's such as fat head minnows. A wholesale change in the treatment of storm water needs to take place along with restoration of shoreline habitat that will assist in the natural cleaning of our waterways. On a more broader scale the state needs to take a hard look at industry and consider the environmental impacts in decisions to allow large industry with the potential to pollute into our state. The current public comment provisions to allow public participation is not well advertised and is often inconvenient for the majority of the public to attend. Likely the only reason I received this public notification is because of my participation in watching the nutrient forum workshops. A system should be set up such as a well advertised public website where people can go to provide public comment for any proposals related to the protection of the environment. The website could be broadcast on local news networks and also commercials and social media. Todays generation will participate if its in a format they can access via a smartphone or tablet. In summary I would like to say that we have kicked the can down the road far enough and its time take the lead. When traveling people always ask where your from and when I tell them Washington their first comment is its so beautiful there and their right, but there's an ugliness under the surface that we can't ignore anymore, the fish and the orca's are calling our bluff!!!

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Comment From: Steve Deem

8/30/19 @ 4:05 AM

I strongly support setting nutrient limits for Puget Sound discharges including nitrogen and phosphorous. We (the communities living around Puget Sound) can be better stewards of this water body. The LOTT wastewater treatment plants have already show...↓

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Comment From: Hal Michael

8/23/19 @ 11:56 PM

I am curious as to why an permit is necessary. The issues of nutrients should be addressed in the discharge specific permits already in existence. For example, the General Permit for fish hatcheries, which I worked on and with for years, could have e...↓

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Comment From: Anonymous Anonymous

8/22/19 @ 2:04 AM

I don't feel a general permit is the way to go. There are numerous different types of treatment, terrain, collection systems, etc.. A general permit requiring all discharges be held under the same restrictions and guidelines just would not work. I fe...↓

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Comment From: Sabine Doenninghaus

8/21/19 @ 9:07 AM

Dear Madam or Sir, regarding the proposed Puget Sound Nutrients General Permit, I would like to draw your attention to the deteriorating water quality of Puget Sound I have witnessed personally. As a public observer and citizen of the region, I ur...↓ge you to support the implementation of a permit. In 2011, I started to swim and snorkel in Puget Sound on a regular basis, i.e. at least twice a week year round. I have monitored two sites in South Puget Sound since then, and I have personally witnessed the disappearance of not only several species of seastars since 2013, but also crabs and squid overall. Regarding the disappearance of seastars, I would like to draw your attention to the so-called seastar-wasting-disease or "event" (see the multitude of academic and other articles on the following website: https://marine.ucsc.edu/data-products/sea-star-wasting/articles.html). Within only 8 years, I have seen intertidal areas that were full of life in 2011 (a lot of different kinds of crabs, seastars, fish, squid/squid eggs) to almost barren underwater landscape (with few exceptions, for instance leather stars (Dermasterias imbricata)). I have no doubt that this change is directly related to human population growth and activities in the Puget Sound region affecting not only the water quality but also the structural habitat of various sealife (not the mention the orcas, seals and sealions). If we do not stop polluting Puget Sound, I am sure there will be no sealife left within a few years to a decade from now because the human population in the region is growing very quickly, and the majority of the population does not care about what is under water unless it is fish for food or the occasional orca for "sightseeing" and excitement. Businesses and also private people need to stop polluting Puget Sound and drastically reduce the emission of nutrients into the water that destroy the natural habitat of animals (and ultimately humans). People and businesses need to be made more aware of the fact that everything that enters the waters of Puget Sound has an impact on all of the lifeforms in it and around it. The implementation of a strict permit system with rigorous controls and rules is a very good idea to help save the Salish Sea. If we, the inhabitants of the Puget Sound area, want to protect our Sea and the living creatures in it, we need to act NOW. In times of overall climate crisis and plastic pollution of the Pacific and other oceans, we cannot afford to rest and idle. In order to prevent a further deterioration of the water quality of the Salish Sea, I urge you to support the implementation of a nutrient permit and strict rules regarding waste water in the area. Thank you for your time and attention. Sincerely, Sabine Doenninghaus, PhD RN

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Comment From: Anonymous Anonymous

8/21/19 @ 7:48 AM

WWTPs are so complicated they require individual permits. If a solution includes infrastructure upgrades and reviewing engineering reports, doesn't that require an engineer to review? The noted alternative of adding monitoring to existing individual ...↓

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Comment From: Victoria Hasn

8/21/19 @ 7:17 AM

Hey Ecology! It's no 1980's...RCO 90-48-260. No more point source Waste Discharge or pollution discharge electric mination permits! ITS Still Up To Yoz! Please save Puget Sound for our grand children. You need to move FAST! Move Heaven and Ear...↓th and stop all effluent, raw sewage and stormwater run off from reaching Elliott Bay, Duwamish, Green! Lake Union ....U have to do it NOW! Victoria P HANSEN 620 Hudson Pl Port Townsend, Wa 98368 206-396-1957. Cell or text Please take a serious look . HOW CAN Ecology AWARD the dangerous system that has repeatedly failed to protect Puget Sound and All the people who live here! Last month 4 million gallons of raw sewage entered Puget Sound .... Hottest temperatures of the earth recorded With deadly Consequences to our fragile marine ecosystem... And now we mourn the death of three more Orcas....feeling so sad and have give up. Biologist warns it's 'past the time' to act for Southern resident killer whales – KING TV There's no hope....the damage just keeps on!!! So I ask you, read through the media clips and do something about it!!! The blog, awards, emails are all bullshit when the world is at risk!!! Tori Hansen 620 Hudson Pl Port Townsend, Wa 98368. 206-396-1957 Read On! Sewage Overflow 10 Times Higher Than Previous Estimates SEATTLE (AP) — THE Washington Department of Ecology says the amount of sewage overflow that forced a Seattle beach to close is 10 times more than original estimates. Re: Wastewater Treatment AWARDS❓❓❓❓❔❓ . We posted this news release celebrating the outstanding performance of these facilities around Washington. Some of the facilities have received an award since we started handing them out — 24 years! Image.jpeg Department of Ecology News Release - July 19, 2019 Incidents in the past 24 hours leading to beach closures in Puget Sound West Point Wastewater Treatment Plant SEATTLE – The Washington Department of Ecology is investigating sewage treatment failures at King County's two largest sewage treatment plants. and on.... 4.5 million gallons of sewage spill into the Puget Sound by KOMO News Staff Friday, July 19th 2019 and on.... 3 million gallons of untreated sewage spill into Puget Sound, state officials investigating and on.... Take a Closer Look at Puget Sound Pollution Every year millions of gallons of raw sewage and untreated runoff pour into Puget Sound. Each sewage spill is the result of equipment failure or malfunction at a wastewater treatment plantcausing high volumes of raw untreated sewage to enter Puget Sound. In addition, Unexpected and untreated, stormwater runoff pushes petroleum, oil and heavy metals pollutants into Puget Sound. Image_1.jpeg By Associated Press, Wire Service Content June 28, 2019, at 4:57 p.m. Sewage Overflow 10 Times Higher Than Previous Estimates SEATTLE (AP) — THE Washington Department of Ecology says the amount of sewage overflow that forced a Seattle beach to close is 10 times more than original estimates. KCPQ-TV reports officials said earlier this week that 16,000 gallons had spilled into Puget Sound at Golden Gardens Park. Officials said Friday that additional samples now show about 165,000 gallons of sewage overflow. 4.5 million gallons of sewage spill into the Puget Sound by KOMO News Staff Friday, July 19th 2019 130,000 gallons of sewage spill into Puget Sound after power outage A sign on the banks of Seattle's Lake Union warning that sewage spills into the lake during heavy rainfall. (Dyer Oxley, MyNorthwest) A windstorm that struck Shoreline caused massive quantities of wastewater to overflow into Puget Sound on Friday, Dec. 14. RELATED: Seattle sewage plant having trouble keeping up with population The windstorm caused a power outage at King County's Richmond Beach Pump Station. That caused 130,000 gallons of sewage to overflow into Puget Sound. Power was out at the pump station for approximately two hours. There were no ill effects in water quality found following the overflow. Victoria Hansen Sent from my iPhone On Aug 7, 2019, at 4:12 PM, Galleher, Stacy (ECY) wrote: There are more than 300 wastewater treatment plants and about a third of them have met every single standard and deadline for the whole year. Ecology recognizes these facilities through our award program. We posted this news release celebrating the outstanding performance of these facilities around Washington. Some of the facilities have received an award since we started handing them out — 24 years! You can also visit our blog for more information about the awardees. Ecology logo Visit us on the web and follow our news and social media. Subscribe or Unsubscribe

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Comment From: Roy Light

8/21/19 @ 7:14 AM

I am assuming that a new general permit would require permit coordination, permit fees and additional administration. It seems more logical to simply add this to the NPDES permits as they come up for renewal to reduce the financial burden on the rate...↓

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Comment From: Heather Matthies

8/21/19 @ 3:09 AM

Great idea and I fully support.

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