Comments on the Draft Puget Sound General Permit

We agree with Ecology that “current individual permits do not address this [nitrogen] pollutant,” Preliminary Draft at 7, but we do not agree with Ecology that it can force facilities to apply for this coverage, id. at 6 (“must submit”). Under what legal authority does Ecology believe that it can force an application for coverage under this permit, particularly given that all of the facilities in question already have NPDES permits?

NWEA Comments n Ashland Permit Oct 2021

Despite the length of time, it has taken the Oregon Department of Environmental Quality (“DEQ”) to issue this proposed permit—the current permit has been expired for 13 years, as it was issued on May 27, 2004 and expired on December 31, 2008—it does not appear to reflect much careful thought on the part of DEQ and it fails to meet multiple legal requirements.

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