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consistency and intem, confirm a continued process for discussion, and schedule <br />additional focused meetings. ~ <br />o Within a period of up to 60 days, conduct 3 or 4 bi-weekly meetings between <br />permittees and DEQ before the permit template g~s out for informal public <br />review. These meetings would include walking through the specific permit <br />language with DEQ, identifying aur issues and proposing alternatives or making <br />recommendations to resolve those issues. "Stakeholder" discussions between <br />DEQ and other interested parties would follow the petmittee/DEQ drafting <br />process. <br />Issues of Great~est Concern <br />This section of the memo outlines aur issues of geatest concern with the draft permit. <br />Given the short time frame to address these issues, this memo does not propose <br />alternatives or make recommendations. However, it provides our reasoning for why we <br />tliink it would be detrimental to release the permit for public revie~w prior to further <br />clarifications. The ma.jor issues include: <br />• Hydromodification assessments/retrofit assessments/water quantity controls, <br />• TMDL related permit language, ' <br />• Maintenance requirements, and <br />~ The prescriptive natiue of specific requirements. <br />Hydromodification/retrofits/water quantit,y control: <br />We want to further understand the intent of these requirements as a whole. What are the <br />desired outcomes of the assessments? Because the requirements are not clear, we are <br />inferring that DEQ is expecting that the permittees conduet very extensive and expensive <br />studies. We would qusstion the valve of such studies whe~ we essentially lrnov~ what the <br />outcomes will be in terms of addressing solely one source ofthe impacts.(i.e., <br />stormwater) to receiving streams. If we better understand DEQ's expectations, we may <br />be able to describe how we would (or already are) implementing BMPs to achieve the <br />same goals. ff expensive studies are being requested, we t}unk it would be more effect"ive <br />from a water quality standpoint to apply resources to BMP implementation for ex le, <br />retrofits and lvw impact development) as vupased to more studi ~ _ ,_,z , r 4~ <br />_• In general DEQ has not <br />discussed these assessment-related requirements with us and they represent significant <br />potenrial changes to the permittees stormwater programs with financial and policy <br />implications. We would like to discuss these new requirements, their intent and their <br />practical implications prior to wider distribution of the draft pemut. _ <br />TNIDL Iangua~e <br />In Schedule D(2}(a) of the draf~ permit, the language states the following (uncierlining has <br />been added for emphasis): <br />c: ~e aoa s~ rr~ ~aa~ ae~,o w ns~ r~ ~x~w.ax ~:~ wu o9 tcon Page 2 <br />