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Birch Bay NPDES Permit Comments

NWEA Birch Bay NPDES Permit Comments July 14, 2020

Although nitrogen and phosphorus end up in Puget Sound and its tributaries from diverse sources, such as stormwater and agricultural lands, the Washington Department of Ecology
(Ecology) has concluded that municipal and industrial discharges are the primary source of anthropogenic nutrient inputs into the Sound. Thus, a critical component of Washington’s effort
to attain and maintain water quality standards in Puget Sound must be to impose limits, under the Clean Water Act (CWA), on the amounts of nitrogen and phosphorus that sewage treatment
facilities may discharge into rivers and the Sound. Although, as demonstrated in the fact sheet that accompanies this draft NPDES permit, Ecology appears to believe that it can suspend the
requirements of the CWA and the federal and state regulations that govern the issuance of NPDES permits on various grounds, that approach is contrary to law, as explained in the
comments below. Ecology is prohibited from issuing NPDES permits that allow dischargers to cause or contribute to violations of water quality standards including the violations that have
been measured, those that have been predicted to exist by Ecology models, those that are threatened to develop as nutrient pollution increases, and those that in combination with other
factors and parameters—such as lowered flows and higher temperatures—create increasingly more widespread and deleterious effects on water quality and the beneficial uses that depend
upon high quality waters.

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