McFarland Cascade Holding Permit

October 22, 2025

We agree that all sources of mercury should be required to institute Mercury Minimization Plans (“MMP”) as is required in Schedule D Condition 8. We ddisagree that DEQ can issue a permit without a water quality-based effluent limit (“WQBEL”) for mercury. First, while NWEA does not believe that the Willamette Mercury TMDL is an actual TMDL, DEQ did submit it to EPA for approval and EPA did approve it as a TMDL. Therefore, this permit must conform to the assumptions and requirements of the approved TMDL.