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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?

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