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developmenY'.10 Each permittee will provide the rationale for its selected benchmark ' <br />development approach. ! <br />Lastly, DEQ requested that permittees submit TMDL Benchmarks irr response to the Willamette <br />TMDLs as part of their upcoming permit renewal applications." This will primarily impact Salem <br />and Eugene, who have not developed benchmarks in response to previous TMDLs. <br />Anticipated Permit Language <br />DEQ will clarify the expectations for TMDL benchmarks in the next round of permits to promote <br />consistency in future submittals and ease of program evaluation. <br />Public Process and Timeline foc Permit Renewal <br />The first topic of discussion with the ACWA permit renewal group was centered on the language <br />in the current permits that requires municipalities to take public comment on their SWMPs before <br />they submit them as part of the permit renewal application in August, 2008. The current permit <br />language is arguably confusing. After discussing the issue with permittees and DOJ counsel, we <br />proposed the following basic steps: <br />1. Revised SWMPs are submitted to DEQ in August2008, after public comment. <br />2. Permit negotiations take place. <br />3. Permittees are given 30 days to make any requi~ed or elective SWMP revisions. <br />4. The SWMP and permit go out for public comment. <br />5. The SWMP becomes effective when the permit is issued.. <br />6. Subsequent updates to the SWMP would be part of adaptive management. <br />~i ~ <br />Issues around the public process and timeline for permit renewal were successfully addressed { , <br />with the permittees and we have a good plan for moving forward. `'"` <br />Anticipated Permit Language <br />DEQ will clarify this requirement in the "Permit Renewal Application Requirements" section of <br />next round of permits. Permittees will not be required to conduct a public process.on revised <br />SWMPs for the next,permit renewal (2014). Rather, a single public process will be conducted for <br />the next permit and associated SWMPs at the time of permit issuance. The next round of <br />permits will include a general requirement for the permittees to adopt a public participation <br />process that provides opportunities for the public to participate in the development, <br />implementation and adaptive management of the SWMP. . <br />lo "ACWA Benchmark Response - Oct 07" <br />"The renewal application request letter was sent on 1/11/08. <br />F <br />Y ~ <br />8 <br />