EIS scoping for WAC 173-201A Rulemaking for Variances on the Spokane River

Submitted By

112 Results

Search Type

Sort:

Sort Results By

Comment From: Spokane Riverkeeper and Puget ... (Jerry White)

7/11/19 @ 11:59 AM

Spokane Riverkeeper comments on EIS scoping for WAC 173-201A Rulemaking for Variances on the Spokane River have been uploaded.

Attachments:

Download

Comment From: melvin Oleson

7/11/19 @ 9:24 AM

Rulemaking to amend Chapter 173-201A WAC, Water Quality Standards for Surface Waters of the State of Washington- variance for Spokane River; DEIS I am responding to the Request for Comments on the above CR-101 proposal for Variance for the Spokane...↓ River. As I understand this request it is to address the Draft Environmental Impact Statement rather than the specifics of the Variance process. To that end will attempt to address the larger concerns with variances in general and the Spokane River in specific. Preamble: I am very familiar with the water body in question from my days at University of Idaho, where in 1971-1972 I conducted preliminary work on my masters in Ecology (biological) on the Coeur D'Alene river in the Silver Valley. In taking biological samples and water quality samples (heavy metals) from the Silver Valley mining district I became acutely aware of the impact of toxic materials on the biological ecosystem. My control bodies in these studies were the St Mary's river in northern Idaho and the Spokane River (where it crosses the Idaho/Washington State boundary). At that time we did not have the ability to monitor for bioaccumulating organics such as PCB. However, it was noted that the discharges from the Silver Valley were thought to impact the Spokane river when compared to expected results from the comparable St. Mary's river. Since that time, I have worked in the water quality field from 28 years and have obtained professional certification as Certified Professional in Industrial Stormwater Management and Certified Professional in Stormwater Quality. I have retired and no longer have a specific association with any organization or cause. I provide these comments as a knowledgeable concerned citizen who has kept an eye on the Spokane River process out of concern for that wonderful river and the known adverse impact of decades of negative anthropomorphic activities. Comments: Variances are essentially a last ditch stand to find a way to resolve an intractable problem for both the environment and dischargers- in this case the historic discharges of PCBs. The problem has three major components: 1) As with many of these bio accumulative organics the impacts are far reaching. As noted recently the southern Orca population is believed to have high levels of PCBs that may reduce survival of calves. 2) It is also quite reasonable to associate "cause" to a wide range of contributors from industry, municipalities, military, agriculture and utilities. The specific characteristics of PCBs in electrical field made them very useful in transformers as well as a range of other products such as paints. 3) the very long half-life of the PCBs results in a long-lasting reservoir of these materials from past use. This is further complicated with the reported production of these materials, news reports as recent as two years ago, in developing countries for use in many applications. The overall goal of the proposed variance rule being considered in this rule is; "write a permit meeting legal requirement and are relevant to other waterbodies in the state" (Spokane Permit tools workshop 2). This is truly then a Statewide issue as the resulting permit conditions developed for the Spokane River are intended to be (broadly) applied to the entire State. Since it is well known from the work done on the Human Health Standards that PCBs are expected to be found in nearly every water body in the state this rule has substantial environmental, economic and social impact. Evaluating the proposals discussed in multiple (well thought out and informative) presentations by Ecology staff the conclusion I reach is that this needs to be a state-wide variance program addressing water quality in the waterbodies- not, as promoted by Ecology, a discharge effluent-based variance program. This conclusion is based on the following considerations: 1) The sources of PCBs are statewide and affect many, if not most, waterbodies in the state. Thus, a common unified approach is needed to provide relief to multiple types of permittees, including, but not limited to, municipal waste treatment plants, industrial process water dischargers, stormwater discharges from both industry and municipalities, and non-municipal government discharges (i.e.: hatcheries). Establishing a statewide unified approach can also have influence on contributors such as military bases, tribal authorities, Federal agencies. Without a unified approach each entity will undergo the same repetitive efforts to establish the necessary criteria for receiving a variance associate with the permit. This is an inefficient use of state, business, municipal and Federal resources. 2) Use Attainability Analysis (UAA) is the logical alternative to the use of variances, except- they will never qualify in a Washington State waterbody. An excellent presentation at the Spokane River Permit Tool workshop (August 8th, 2018) clearly laid out the requirements to obtain a UAA. The first and irrevocable requirement is that a UAA can only be used "To remove uses designated to a waterbody in the state water quality standards that are neither existing nor attainable." A quick review of the relevant WAC's (173-201A-600 and -602) in effect establish an existing designated use for fishery, agriculture, stock watering or human health on every waterbody in the state and thus, since PCBs affect living organisms, it would preclude using a UAA. 3) Measuring PCB concentrations is very difficult to the levels established as the current approved EPA qualitative method does not monitor to these low levels and the method being used to monitor to these levels is not EPA approved and thus is not a legitimate indicator of the concentration. Conversations with knowledgeable persons over the last couple years suggest EPA is not likely to approve the method with lower detection levels. If we can't measure it successfully at the prescribed levels, then there is little opportunity to determine if a discharge has meet these levels. Worse yet, if a permittee has an exceedance that is measurable, then they have no way to demonstrate they are back in compliance as the more sensitive method is not "credible" without EPA approval. 4) The sources of PCBs to the states waterbodies has not been removed, and probably never will be. During the human health rule revision process, it was noted from a study done in Oregon by a reputable source that the body burden of Salmon returning to native streams was far above the allowable water quality standard. As these fish were destined to die in their native spawning areas (or hatcheries) then the PCB they contained would be introduced into the waterbody. Notice, I did not say reintroduced as when salmon leave the native fresh waters, they are a relatively small fish compared to the returning spawning fish and have little total body burden. The majority of the PCB body burden these returning fish have is picked up in the ocean environment where there is a large sink of PCB's that have been contributed over the years by discharges from around the northern Pacific (and may still be occurring from some sources). The practices of some agencies to take hatchery carcass from spawned out fish and reintroduce them to the native streams, while attempting to restore native food balances, also reintroduces PCB's into these waters. Another report discusses how the remains of these, and other, fish are recycled into fish food for use at hatcheries. This of course puts an initial body burden into the released fish and, in the food web, may contribute to the transfer of PCBs to the Southern Orca population. 5) Washington State has never issued a variance for an individual entity. Thus, in searching for a variance issuance in similar states I have found two. One is for the wastewater treatment plants in the Silver Valley in Idaho in which the plant was dealing with the highly contaminated water from the run-off from the mining slag piles. This would not be a natural background situation as the mining activity was anything but natural. It might qualify as an intake credit under WAC 173-201A-460 a feature that could be incorporated into the variance discussion. The second variance I found was in Montana for nutrients. This was a statewide variance designed to address increasing pollution form nitrogen and phosphorous. It applies statewide and has a range of provisions that each point source dischargers needs to comply with. As there are so few comparable examples of how to develop a variance in the Pacific Northwest it suggests that the process is open to extensive interpretation and many nuances in policy and practice. 6) In the presentation on Nov 5th 2018 the seven requirements for variance considerations were described. Of these two (3and 6) were of particular interest in the situation specific to Spokane: One of the following seven conditions from the Federal Regulations must be used for this part of the submittal. I have appended observations to each of these points. (1) Naturally occurring pollution concentrations prevent the attainment of the use; or | observation, As noted in 4) above there is a naturally occurring source of the pollution in play in the movement of oceanic PCBs into the freshwater system by salmon and some other fish. While this may seem a stretch to the rule consider that even if Washington state was able to totally end discharges of PCB's they would still be renewed annually in those waterbodies hosting salmon populations. As we struggle to provide better access to habitat for salmon by removing barriers (such as culverts) we only increase the spread of PCBs in the state's waters. Another consideration is the possibility of air deposition across the state. NOAA studies in the 2000 demonstrated that extensive amounts of mercury were being deposited in Washington state from airborne discharges from SE Asia resulting in warm water fishery advisories. I have not found any studies on this form of PCB air deposition, however; it does seem feasible and is another (anthropomorphic) natural (air) source of PCBs that would thwart our best efforts to reduce steam levels. (2) Natural, ephemeral, intermittent, or low flow conditions or water levels prevent the attainment of the use, unless these conditions may be compensated for by the discharge of sufficient volume of effluent discharges without violating State water conservation requirements to enable uses to be met; or : |no observation (3) Human caused conditions or sources of pollution prevent the attainment of the use and cannot be remedied or would cause more environmental damage to correct than to leave in place; or A demonstration that attaining the water quality standard is not feasible for the requested duration of the variance based on 40 C.F.R. 131.14. |observation As noted in above discussions the possibility of actually meeting the current water quality standards for PCB's is highly unlikely when fighting against the background of redeposition, very long half-life and multiple sources. This is not to say we should give up and do nothing. Rather, it enforces the concept that we need a statewide unified approach to providing everyone a variance for PCB's (and maybe some other bioaccumulatives). The approach should address source control from all sources, such as stormwater, process water, POTWs, agricultural discharges. It should also include actions to promote the end of production and use of PCBs around the North Pacific Ocean to diminish the amount of PCBs that are returned by anadromous fish. The current approach to address the problems for Spokane is inadequate in addressing the state wide PCB issues that endanger our beloved Orcas and human health. (4) Dams, diversions, or other types of hydrologic modifications preclude the attainment of the use, and it is not feasible to restore the water body to its original condition or to operate such modification in a way that would result in the attainment of the use; or |observation the accumulation of sediments in reservoirs, lakes and ponds may be a source of removable PCB's. The tendency of PCB's to cling to particulates makes this an interesting consideration in removal and sequestration. Yes, it includes the dreaded dredging; yet, what better use of dredging than to remove an intractable pollutant like PCB's? Capping may be an option in some situations. (5) Physical conditions related to the natural features of the water body, such as lack of proper substrate, cover, flow; depth, pools, riffles, and the like, unrelated to water quality, preclude attainment of aquatic life protection uses; or |no observation (6) Controls more stringent than those required by § 301 (b) and 306 of the Act would result in substantial and widespread economic and social hardship. |observation an interesting paradox in that the point of a variance is to ensure that a permittee continually seeks out the most effective method to remove PCB's. Yet, there is no criteria for what constitutes "substantial widespread economic and social hardship". For example, what if a POTW for a major municipality discovers that it needs to add yet another level of treatment to address the "improved" methods for removing PCBs. The question then becomes how much additional can they charge the supported community and businesses to make this improvement? $10, $50, $100, $500 per month or some equally substantial amount per 100 cfs of use? The state needs to come up with a unified way to make this decision under the umbrella of a unified state-wide variance process/ permit. (7) Actions necessary to facilitate lake, wetland, or stream restoration through dam removal or other significant reconfiguration activities preclude attainment of the designated use and criterion while the actions are being implemented. |observation see 4) above. 7) One additional comment on the need to create a statewide variance for PCB's with uniform standards. Climate Change: As someone who has worked in the field for many years, I am very aware of the energy requirements that are associated with advance treatment systems. The more we press for removal of extremely small amounts of PCBs the more energy it will require. Systems such as stormwater discharges may no longer be able to go to directly to receiving water and will need treatments systems, the construction and operation of which, will require significant amounts of energy. While we can hope it will be renewable energy, but; that may be as much a dream as the ability to remove most of the PCBs from our northwest streams. Summary: The intention to move forward with the development of a variance system is a good and necessary policy and practice action. The difference between what is proposed and what is needed that the variance program needs to be developed on a statewide basis PRIOR to its being applied to any specific instance. Only in this way can an effective, efficient and enforceable set of rules be developed that give hope of addressing the PCB (and similar pollutant) problem. I urge Ecology to withdraw (or modify) this CR101 to make it a statewide rulemaking. As stated earlier from the Spokane permit tool workshop 2: the goal is to: write a permit meeting legal requirement and are relevant to other waterbodies in the state Sincerely Melvin W. Oleson CPISM/CPSWQ PS: my great appreciation to the Ecology staff who have helped me understand (in part) the complex aspects of the variance rule. The team in Spokane at the workshops and the headquarters staff (especially Ms. Niemi) have be invaluable and very patient.

No attachments

Comment From: Kalispel Tribe (Ken Merrill)

7/11/19 @ 6:48 AM

Attachments:

Download

Comment From: Spokane Falls Trout Unlimited (Hilary Hart)

7/11/19 @ 6:45 AM

Attachments:

Download

Comment From: The Lands Council (Mike Petersen)

7/11/19 @ 6:18 AM

Please see the attached file for The Lands Council comments. Thank you, Mike Petersen

Attachments:

Download

Comment From: Jennifer Brock Olson

7/11/19 @ 4:57 AM

Ecology must consider how a variance will impact the ability to meet the Spokane Tribe's Water Quality Standards (for poly chlorinated biphenyls or PCBs). Ecology cannot take action that will cause or contribute to a violation of the Tribe's standard...↓

No attachments

Comment From: Kaiser Aluminum

7/11/19 @ 3:35 AM

Attachments:

Download

Comment From: B.J. Kieffer

7/11/19 @ 2:55 AM

Attachments:

Download

Comment From: Michael Reid

7/10/19 @ 5:00 PM

No attachments

Comment From: Megan Martens Haworth

7/10/19 @ 5:00 PM

No attachments

Comment From: Maya Newman

7/10/19 @ 6:33 AM

Implementing variances without a clearly defined time-frame of when the discharger will meet the original standard is extremely risky. Effectively, dischargers will be able to set their own standards based on their economic motivations and not the h...↓

No attachments

Comment From: Anna Belinski

7/10/19 @ 5:52 AM

An EIS need include: - a thorough assessment of how PCB variances will affect the Spokane Tribe PCS water quality standard downstream from Spokane and the legal and environmental issues of that. - an exploration of how this would negatively influen...↓

No attachments

Comment From: Center for Environmental Law &... (Trish Rolfe)

7/09/19 @ 8:04 AM

Attachments:

Download

Comment From: Justin Belker

7/07/19 @ 5:00 PM

No attachments

Comment From: Hilary Ohm

7/07/19 @ 6:54 AM

Please clean up the PCBs in the Spokane River. The costs to fish, wildlife and people are too great. Thank you.

No attachments

Comment From: Jane & Sam Joseph

7/04/19 @ 5:00 PM

No attachments

Comment From: Ian Moxley

7/04/19 @ 5:00 PM

No attachments

Comment From: Michelle Guilford

7/04/19 @ 5:00 PM

No attachments

Comment From: M. Haworth

7/04/19 @ 5:00 PM

No attachments

Comment From: Tristina Ropp

7/04/19 @ 5:00 PM

No attachments

Comment From: Emily Kratzer

7/04/19 @ 5:00 PM

No attachments

Comment From: Erma McKoy

7/04/19 @ 5:00 PM

No attachments

Comment From: Diana Stewart

7/04/19 @ 9:03 AM

It's a resounding NO from me regarding any weakening of water quality regulations in any way. It's our responsibility to our kids and grandkids (as well as to our area's wildlife) to be their voice, and to make progressively greater inroads as quick...↓

No attachments

Comment From: Sandra Coon

7/04/19 @ 12:53 AM

Please do not reduce water quality standards by implementing a "varrience" that will allow more pollution into the Spokane River. PCB'S are bad for humans and wildlife, this is not news. Keeping our limited fresh water recourse clean is one of the jo...↓

No attachments

Comment From: Analisa Lee

7/02/19 @ 11:44 AM

I adamantly oppose weakening the allowable PCB limits in the Spokane River. The adverse impacts of increasing allowable limits are far reaching and serious. PCBs are in human breast milk, in every one of our bodies, in our brains, in everything, and...↓

No attachments

Comment From: Kim Harmson

7/02/19 @ 7:50 AM

Dear Ms. Braley, I am writing today to comment on the WDOE Environmental Impact statement on the scoping process for proposed pollution discharger variances on the Spokane River. I would like to express my extreme opposition to the adoption of...↓ these pollution discharger variances by the WDOE. Such variances would allow industrial and municipal dischargers to determine and propose their own pollution limits and this is entirely unacceptable. Instead of these proposed discharger variances, which would leave dischargers unaccountable, it important to have dischargers accountable to the public. Thus i am requesting WDOE implement the conventional clean up plan called the Total Maximum Daily Load or TMDL. This kind of plan would require loading limits and timelines that would require dischargers to ratchet down their pollution and allow the public to be informed. The WDOE's Environmental Impact Statement on discharger variances must do the following things: 1. Ecology must consider how a variance will impact the ability to meet the Spokane Tribe's Water Quality Standards (for poly chlorinated biphenyls or PCBs). Ecology cannot take action that will cause or contribute to a violation of the Tribe's standards. 2. Ecology must explain how a variance will comply with the Federal Court order to develop a clean-up plan called a Total Maximum Daily Load (TMDL) for PCBs. 3. Ecology must address issues of environmental justice -- who is eating fish and how will they be impacted by a decision to weaken the water quality standard for PCBs? Will the variance disproportionately impact Native Americans or other fishing and minority communities? 4. Ecology must assess all technological options to address PCBs. 5. Ecology must assess impacts of PCBs on the entire food web. 6. Ecology must fully assess the effectiveness of issuing pollution permits with compliance schedules to meet the EPA/WA water quality standard. 7. Ecology must assess the social and economic costs of continued toxic pollution shouldered by the community in the form of lost and degraded uses. For example, who does not use the river any longer because of polluted fish and what is that costing us? Thank you for your time, Sincerely, Kim Harmson 1

No attachments

Comment From: Austin Zimmerman & Van Densmore

7/01/19 @ 5:00 PM

No attachments

Comment From: Jack Armstrong

7/01/19 @ 1:41 PM

Hello, I am a Spokane citizen who is very concerned about the water quality of the Spokane River and it's impact on the potential future of our city. If we want to continue to grow Spokane and attract bright, young minds, natural resources such as...↓

No attachments

Comment From: Michael Cochran

7/01/19 @ 8:44 AM

I feel it is highly important today not to deviate from the existing goals toward the cleanest water quality and the lowest possible PCB's for the Spokane River. The existing goals must be maintained for the protection of the Native Redband Rainbow ...↓

No attachments

Comment From: Mary and Brian Jokela

7/01/19 @ 5:39 AM

Ecology must consider how a variance will impact the ability to meet the Spokane Tribe's Water Quality Standards (for poly chlorinated biphenyls or PCBs), with no action that will cause or contribute to a violation of the Tribe's standards. ...↓

No attachments

Comment From: George Morrison

7/01/19 @ 3:19 AM

I strongly urge The WDOE to not allow the polluters of the Spokane, or any other river within the State, any rule variance until there is a complete and public review of the process. The proposed rule change must consider the following: Ecology mu...↓

No attachments

Comment From: Elizabeth Nedeff

7/01/19 @ 2:06 AM

Please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quality in the Spokane River. (1) What are the impacts of de-listing redband trout as a designated use of the Spokane River, thus degr...↓

No attachments

Comment From: Michele Moxley

6/30/19 @ 5:00 PM

No attachments

Comment From: Aileen Palid & John Browning

6/30/19 @ 5:00 PM

No attachments

Comment From: Sarah Calvin

6/30/19 @ 5:00 PM

No attachments

Comment From: Sarah Calvin

6/30/19 @ 5:00 PM

No attachments

Comment From: Denise Attwood & James Conner

6/30/19 @ 5:00 PM

No attachments

Comment From: Blake Koehn

6/30/19 @ 2:00 PM

No attachments

Comment From: Jean Carman

6/30/19 @ 9:58 AM

Please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quality in the Spokane River. I find it incredibly disconcerting and morally reprehensible that while our state is filing suit again th...↓

No attachments

Comment From: Carolina Hood

6/29/19 @ 3:44 PM

Comments: Please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quality in the Spokane River. (1) What are the impacts of de-listing redband trout as a designated use of the Spokane River...↓

No attachments

Comment From: Sheryl Krohne

6/29/19 @ 12:24 AM

Consider the pollution to the fish and the water that people kayak and stand in to fish. We use this river and ingest the water even if we don't actually drink it. When we fall in kayaking or tubing, we drink some water. I don't want to drink PCBs an...↓

No attachments

Comment From: Wayne Attwood

6/28/19 @ 7:45 AM

Please e advised that I oppose any weakening of the established regulations. Great progress has been made in cleaning up the Spokane River, and any step back from the existing rules would be a step in the wrong direction. Allowing those polluters t...↓

No attachments

Comment From: James Cronin

6/28/19 @ 6:36 AM

No attachments

Comment From: William Golding

6/28/19 @ 5:44 AM

I am appalled by Washington State Department of Ecology's efforts to weaken water quality requirements and efforts to avoid cleaning up pollution in the Spokane River. This is a direct violation of treaty agreements between the United States and a mu...↓ltitude of Indigenous Nations within present day Washington State. These sovereign nations have reserved rights to access healthy fish throughout the Spokane River and the subsequent Colombia River watershed, in exchange for access to the lands of present-day Washington State. Allowing for avoiding clean up of this polluted waterway violates these treaty rights. This violation, if allowed will carry on a history of violating treaty rights, and is unacceptable. As a resident of Washington State, I am gravely disturbed by these efforts and strongly oppose any efforts to avoid cleaning up degraded water quality across the state. Please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quality in the Spokane River. (1) What are the impacts of de-listing redband trout as a designated use of the Spokane River, thus degrading and possibly destroying the redband fishery? (2) What are the social, economic and ecological impacts of not reducing PCB concentrations in the Spokane River, particularly when summertime flows fall to dangerously low levels due to overpumping and climate change? (3) Explain why letting polluters off the hook for cleaning up PCB contamination is more important/valuable than public and ecological use of the Spokane River. (4) Explain why, after more than 40 years of knowing about the public health dangers posed by PCBs, the state has never required Spokane River polluters to control the PCB pollution coming out of their pipes, thereby failing to meet the Clean Water Act goals of a fishable, swimmable river. (5) Explain why the State of Washington is suing EPA for rolling back standards for PCB pollution elsewhere in Washington, while at the same time proposing to roll back PCB standards for the Spokane River? (6) Please make the polluters' applications for variance available to the public before asking for scoping comments, and extend the deadline for scoping comments, to allow the public adequate time to fully understand the issues before being asked to comment. Thank you for this opportunity to comment on the scoping process to adopt a variance for lowering water quality – a move that threatens the ecological health of the Spokane River. Please keep me informed about further developments related to this proposal.

No attachments

Comment From: Kim Engel

6/27/19 @ 10:28 PM

We, as a community, have worked very hard to make sure our River is clean and taken care of. The City has just spent millions of dollars to try to mitigate the pollution from storm run-off. It seems that this will definitely be a step backwards in ou...↓

No attachments

Comment From: Denise Attwood

6/27/19 @ 10:38 AM

To: Susan Braley Washington State Department of Ecology June 27,2019 PO Box 47600 Olympia, WA 98504-7600 RE: EIS scoping for WAC 173-201A Rulemaking for Variances on the Spokane River Dear Ms. Braley, We are writing to...↓day to comment on the WDOE Environmental Impact statement on the scoping process for proposed pollution discharger variances on the Spokane River. We would like to express our extreme opposition to the adoption of these pollution discharger variances by the WDOE. Such variances would allow industrial and municipal dischargers to determine and propose their own pollution limits and this is entirely unacceptable. Instead of these proposed discharger variances, which would leave dischargers unaccountable, it important to have dischargers accountable to the public. Thus we are requesting WDOE implement the conventional clean up plan called the Total Maximum Daily Load or TMDL. This kind of plan would require loading limits and timelines that would require dischargers to ratchet down their pollution and allow the public to be informed. The WDOE's Environmental Impact Statement on discharger variances must do the following things: 1. Ecology must consider how a variance will impact the ability to meet the Spokane Tribe's Water Quality Standards (for poly chlorinated biphenyls or PCBs). Ecology cannot take action that will cause or contribute to a violation of the Tribe's standards. 2. Ecology must explain how a variance will comply with the Federal Court order to develop a clean-up plan called a Total Maximum Daily Load (TMDL) for PCBs. 3. Ecology must address issues of environmental justice -- who is eating fish and how will they be impacted by a decision to weaken the water quality standard for PCBs? Will the variance disproportionately impact Native Americans or other fishing and minority communities? 4. Ecology must assess all technological options to address PCBs. 5. Ecology must assess impacts of PCBs on the entire food web. 6. Ecology must fully assess the effectiveness of issuing pollution permits with compliance schedules to meet the EPA/WA water quality standard. 7. Ecology must assess the social and economic costs of continued toxic pollution shouldered by the community in the form of lost and degraded uses. For example, who does not use the river any longer because of polluted fish and what is that costing us? Thank you for your time, Denise Attwood & James R. Conner 13212 South Austin Road Spokane, WA 99224

No attachments

Comment From: Rana Bonnice

6/27/19 @ 5:50 AM

It is appalling that after more than 40 years of knowing about the public health dangers posed by PCBs, the state has never required Spokane River polluters to control the PCB pollution coming out of their pipes, thereby failing to meet the Clean Wat...↓

No attachments

Comment From: Claudia Dubuque

6/27/19 @ 4:27 AM

Regarding EIS scoping for WAC 173-201A Rule making for Variances on the Spokane River, please do not lower water quality standards. Please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quali...↓

No attachments

Comment From: Morton Alexander

6/27/19 @ 4:20 AM

Just because the EPA is setting the pace of de-regulation on environmental standard, Washington's very lax Department of Ecology shouldn't follow suit. Please be truly conservative of the health of the Spokane River, and don't weaken the already ina...↓

No attachments

Comment From: Maia Ostrom

6/27/19 @ 1:55 AM

No attachments

Comment From: Patty Gates

6/27/19 @ 1:41 AM

Regarding scoping discharger variances: 1. Ecology must consider how a variance will impact the ability to meet the Spokane Tribe's Water Quality Standards (for poly chlorinated biphenyls or PCBs). Ecology cannot take action that will cause or co...↓

No attachments

Comment From: Chad Evans

6/27/19 @ 1:41 AM

No attachments

Comment From: Cheryn Zimmer

6/27/19 @ 1:40 AM

Protect water quality around our state with a universal standard.

No attachments

Comment From: Joe Ginsburg

6/26/19 @ 2:44 PM

Please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quality in the Spokane River. (1) What are the impacts of de-listing Redband trout as a designated use of the Spokane River, thus degr...↓

No attachments

Comment From: Michael Lampi

6/26/19 @ 1:53 PM

No attachments

Comment From: Kevin Gallagher

6/26/19 @ 1:32 PM

After more than 40 years of knowing about the public health dangers posed by PCBs, why has the Washington Department of Ecology never required Spokane River polluters to control the PCB pollution coming out of their pipes, thereby failing to meet the...↓

No attachments

Comment From: Paul Franzmann

6/26/19 @ 1:23 PM

A variance -some kind of local exception- is wrong on too many counts: -It looks political; make this equal across the board -No one should need to worry over the quality of tap water -'Slippery slope' ... once variations are made, another a...↓

No attachments

Comment From: john alder

6/26/19 @ 1:12 PM

will you pleaseeeeeeeee! stop polluting my river i want drink bath and clean with that water

No attachments

Comment From: Javier Madrigal Jr.

6/26/19 @ 1:06 PM

PCBs are dangerous. Limiting PCB exposures for wildlife and humans is important to our health and our children's health because of risks that include birth defects and cancers. A "water quality variance" will weaken water quality standards. This...↓

No attachments

Comment From: Nicole Larson

6/26/19 @ 8:58 AM

No attachments

Comment From: Cynthia Flora

6/26/19 @ 8:40 AM

These variances are akin to putting the fox in charge of the hen house, something we as Americans have had to swallow over and over during the past few years. And the charade is to continue for twenty years no less! If you think it would be okay...↓ to let Ecology agree that polluters can decide what level of pollution THEY think is acceptable...that is bizarre. WDOE must be allowed enough time to mount a vigorous, complete examination of the effects of this proposed action, otherwise WDOE will be abdicating their responsibilities to protect the health and future ecological well-being of the Spokane River and by extension enjoyment thereof by of the citizens of the state. You would impair our relationship with the Spokane Tribe and knowingly diminish their resources as well. Citizens must be allowed reasonable time to comment. Why this is all scrunched into three weeks in the summer when you have had a year to come up with this pretense of regulation? This is typical modus operandi when an organization is trying to ignore the wishes of the electorate. I agree with the well crafted thoughtful requests of people commenting before me based on forward thinking science rather than a desire to return to blind polluting of waters that belong to all citizens of our state. (1) What are the impacts of de-listing redband trout as a designated use of the Spokane River, thus degrading and possibly destroying the redband fishery? (2) What are the social, economic and ecological impacts of not reducing PCB concentrations in the Spokane River, particularly when summertime flows fall to dangerously low levels due to over pumping and climate change? (3) Explain why letting polluters off the hook for cleaning up PCB contamination is more important/valuable than public and ecological use of the Spokane River. (4) Explain why, after more than 40 years of knowing about the public health dangers posed by PCBs, the state has never required Spokane River polluters to control the PCB pollution coming out of their pipes, thereby failing to meet the Clean Water Act goals of a fishable, swimmable river. (5) Explain why the State of Washington is suing EPA for rolling back standards for PCB pollution elsewhere in Washington, while at the same time proposing to roll back PCB standards for the Spokane River (these countervailing decisions make NO sense) ? (6) Please make the polluters' applications for variance available to the public before asking for scoping comments, and extend the deadline for scoping comments, to allow the public adequate time AT MINIMUM 60 days to fully understand the issues before being asked to comment. Please keep me updated on this issue.

No attachments

Comment From: Joan Broeckling

6/26/19 @ 8:19 AM

To whom it may concern: I would like to request an extended scoping period for the EIS impacting discharge variances for the Spokane River. The health of our river is at stake. The urgent need to protect the health of our waterways supercedes any ...↓

No attachments

Comment From: Paul Lindholdt

6/26/19 @ 8:11 AM

Carefully consider how a variance will impact the Spokane Tribe's Water Quality Standards for PCBs.. Ecology must take no action that will cause or contribute to a violation of the Tribe's standards.

No attachments

Comment From: Dawn Spickler

6/26/19 @ 7:38 AM

Ecology must consider how a variance will impact the ability to meet the Spokane Tribe's Water Quality Standards (for poly chlorinated biphenyls or PCBs). Ecology must explain how a variance will comply with the Federal Court order to develop a clean...↓

No attachments

Comment From: Bo Bricklemyer

6/26/19 @ 7:20 AM

After being informed by my local Sierra Club of your intention to modify CWA rules, I ask you to please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quality in the Spokane River. Answers to ...↓

No attachments

Comment From: Aaron Banks

6/26/19 @ 6:54 AM

A three-week comment period is NOT sufficient for local citizens to become knowledgeable or engaged in the process being proposed. The comment period must be expanded to a minimum of 60 days, as the summer vacation months will limit public engagemen...↓

No attachments

Comment From: Michelle Stepp

6/26/19 @ 6:35 AM

No attachments

Comment From: Dave Peeler

6/26/19 @ 6:16 AM

No attachments

Comment From: Laura Delmas

6/26/19 @ 6:05 AM

No attachments

Comment From: JJ Anonymous

6/26/19 @ 5:55 AM

At this time, we cannot lower our environmental standards...we already have a federal government corruptly forcing that on us, every day. The State of Washington must therefore be extremely conscious and careful to EXPAND protections, rather than lo...↓

No attachments

Comment From: Terri Dumala

6/26/19 @ 5:33 AM

No attachments

Comment From: Virginia Bell

6/26/19 @ 5:30 AM

I attended Gonzaga U. from 1974-79 and know that the Spokane River is a vital resource of fresh water for the region. Please enlist the particular strengths of academic institutions, governments and corporations to create economic and social incentiv...↓

No attachments

Comment From: Anne Tenold

6/26/19 @ 5:18 AM

No attachments

Comment From: Susan Lindsey

6/26/19 @ 4:58 AM

I am very concerned about this Scoping proposal. The Spokane River is important to our community and we need to maintain strict environmental standards to keep the river and the riparian area around it healthy. How will this variance impact the a...↓

No attachments

Comment From: Debbie Stempf

6/26/19 @ 4:58 AM

Ecology must consider how a variance will impact the ability to meet the Spokane Tribe's Water Quality Standards for PCB's. Ecology must explain how a variance will comply with the Federal court order to develop a clean-up plan called a Total Maxi...↓

No attachments

Comment From: Jordan Leach

6/26/19 @ 4:54 AM

No attachments

Comment From: Roger Rouleau

6/24/19 @ 7:02 AM

Hello, I worked in the commercial diving industry for over 30 years witnessing the changes made to protect water quality. My work included installation and maintenance on sewage outfalls, pipe line discharges from pulp and paper plants and other ...↓

No attachments

Comment From: Trenton Miller

6/23/19 @ 7:36 AM

Please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quality in the Spokane River. What are the impacts of de-listing redband trout as a designated use of the Spokane River, thus degrading...↓

No attachments

Comment From: Michael Van Dyke

6/22/19 @ 11:22 PM

Please extend the comment period by 45 more days to ensure the public has time to properly assess and comment.

No attachments

Comment From: Louise Zovanyi

6/22/19 @ 6:57 AM

No attachments

Comment From: Helen Curtis

6/22/19 @ 2:27 AM

The following questions and requests for explanations reflect my thoughts on dealing with PCBs in the Spokane River: (1) What are the impacts of de-listing redband trout as a designated use of the Spokane River, thus degrading and possibly dest...↓

No attachments

Comment From: Linda Carroll

6/22/19 @ 12:06 AM

As a Spokane voter, property owner, and tax payer, as well as the daughter of a Rogers High School chemistry teacher who learned from an early age the damage that pollution does to our health and our environment, I submit the following comments for E...↓

No attachments

Comment From: Elizabeth Williams

6/21/19 @ 2:26 PM

Please accept the following as my comments for Ecology's scoping process for adopting a variance to lower water quality in the Spokane River. I live just a mile from the Little Spokane River which feeds into the Spokane River. On my way to and fro...↓

No attachments

Comment From: Levi Hanson

6/21/19 @ 11:44 AM

Regarding the EIS for PCBs in the Spokane River. We have a unique opportunity to uphold water quality standards in the Spokane River and not fall prey to efforts by the Trump administration to lessen standards. We've made progress and are working tow...↓

No attachments

Comment From: Patty Gates

6/19/19 @ 11:04 AM

1. I am deeply disappointed in the direction that the Dept. of Ecology is taking regarding the amendment of the water quality standards for surface waters in our state. A three week comment period is NOT long enough to understand this variance proces...↓

No attachments

Comment From: Ellen Ziegler

6/19/19 @ 1:11 AM

1. A three week comment period is NOT long enough to understand this variance process and its risks to my river – please add at least 45 days to the comment period. 2. Give me, a member of the public and local resident, a chance to comment...↓

No attachments

Comment From: Carol Reynolds

6/18/19 @ 1:01 AM

We as stewards of the earth have to protect our water at all costs. I ask that: - An extension should be given to the comment process. 3 weeks is not enough time for the public to hear about it and respond to the dangers that more pollution in the ...↓

No attachments

Comment From: Mary Jokela

6/16/19 @ 8:52 AM

An inadequate public comment period exists to process/understand this variance process and its risks to our Spokane River. Increase it by 45 days. Citizens deserve the opportunity to comment in person at a publicly held hearing. Arrange public h...↓

No attachments

Comment From: FOGH (Friends of Grays Harbor) (Arthur Grunbaum)

6/16/19 @ 12:53 AM

Thank you for this opportunity to comment. FOGH (Friends of Grays Harbor) is a broad-based 100% volunteer tax-exempt 501(c)(3) citizens group made up of crabbers, fishers, oyster growers and caring citizens. The mission of FOGH is to foster and...↓

No attachments

Comment From: Responsible Growth * NE Washin... (Phyllis J. Kardos)

6/15/19 @ 3:26 PM

Responsible Growth * NE Washington is against this rule-making and the variances because it will likely let the major dischargers off the hook from reducing their pollution contributions. This is only now getting out to the public and it certainly ne...↓

No attachments

Comment From: Marian Frobe

6/15/19 @ 8:04 AM

I know it's going to be difficult for some polluters to meet the deadline for getting PCBs out of our river, but I don't believe we should be granting variances without a longer public comment period. We don't know what these variances entail and the...↓

No attachments

Comment From: stephanie smith

6/15/19 @ 2:23 AM

Please extend the public comment period to three months. Three weeks isn't enough time. I would also like to see a chance to comment in person at a public hearing in the evening so working people like me can go. Please make the variance applications ...↓

No attachments

Comment From: The Lands Council (Mike Petersen)

6/14/19 @ 6:05 AM

Dear Ecology, The Lands Council is a member of the Spokane River Regional Toxics Task Force, and has been working on reducing PCB's to the river and educating the public about PCB's for over a decade. We request that the comment period be extended...↓

No attachments

Comment From: Anne Tenold

6/14/19 @ 4:01 AM

1. A three week comment period is NOT long enough to understand this variance process and its risks to my river – add 45 days to the comment period. 2. Give us, the public, a chance to comment in person at a publicly held hearing. 3. Pl...↓

No attachments

Comment From: nancy Schaub

6/14/19 @ 3:13 AM

No attachments

Comment From: Bart Rayniak

6/14/19 @ 2:41 AM

No attachments

Comment From: James Tuck

6/14/19 @ 12:31 AM

I strongly urge the DOE to extend the comment period for water quality variances. A 3 week comment period is too short and it needs to be extended by adding at least an additional 45 days. In addition the public should be given a chance to speak in...↓

No attachments

Comment From: Jack Armstrong

6/13/19 @ 11:45 PM

Hello, I am a citizen of Spokane who has lived here my entire life. I've had a few short stints of time in other cities in different states, and one thing I've realized through my travels and life in other cities is that great natural resources su...↓

No attachments

Comment From: Susan Amstadter

6/13/19 @ 3:31 PM

I support the Urgent Alert issued by the Spokane Riverkeeper organization because the risks associated with proposed variances are too great and reiterate their request and ask that: The three week comment period on the variance policy be extended...↓

No attachments

Comment From: Stanley Mrzygod

6/13/19 @ 2:22 PM

I am opposed to the proposed variance notice reduction to a 3 week notification. PCBs are extremely damaging to the environment as human health. Once in the river they persist for extremely long periods. A public hearing and time to carefully study t...↓

No attachments

[ Previous Page / Next Page ]