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~"~ - • ; `Assigr~ed waste load allocatior~s will be achieved through the implementation of best management practices identifted in tke S~YMP that target TMI~L-related pollretants " This language could be in#erpreted to imply that TMDL waste load allocations will be achieved by the end of permit term. We don't think this is DEQ's intent as in Schedule B(3)(h) it states that the permit renewa.l application package should include the follvwing: "Are evalaration of the progres~ towards mee#ing arry czpplicable TMDL poll::tarret load red:~ction benChmarks " As we have always understood, the intent of the requirements (which is confirmed in the Permit Evaluation Report) is that permittees eval~tate pragress towards their propa-sed benchmarks at the end of the pemut cycle, not that WLAs are necessarily achieved. Depending upon DEQ's iutent, this language in Schedule D could present a significant issue for the permittees and in our minds is a fatal flaw which would be confusing and riiisleading to the public. In ~Schedule D92}(b) of the draft permi~ the langua,ge states the following (underlines added for emphasis): `progress towards meeting the ?~I~L ber~chmrrrks must be identiified in the SWAi1P. . " This requirement is addressed in Schedule B. l.b.iv and from the municipality's perspective, the benchmark analysis is part of the permit renewal process, but does not ap}~ear within the SWMP itself. Th~ PER clarifies that the expectation is "to assess the overadl e,~'fectiveness of the SWMP in makireg pro,gress taward achievireg the WLA " but we believe the specif c language in the permit needs further refinement. Maintenance The permittees agree with DEQ on the goal of the requirement (Section A(3)(g)) which is to ensure the long-term ~erforrnance of starmwater quality facilities. However, some of the language in-this section should be reflected in the individual jurisdictions SWNtPs and not in the pernut itseif. For example, for municipaliries with hundre~is or thousands of existing water quality facilities, these requirements are not appropriate and wauld require resource im~acts that far exceed the "maximum eactent practicable" standard_ In addition, it is not clear in the draft pernut template whether the mapping requirement applies to existing and/or new facilities. Lastly, not all jurisdictions have authority as required under the permit to "operate and maintain pr~blie stre~#s, roads ared highways ". What is Appropriate to Include in the SWMP as ~p,posed to the Fermit The draft pernut has some new and very prescriptive standards with respect to performance w~ich .are in can#lict vvith the maximum extent practicable standard. In particular, thresholds and performance standards for wa~er quality design standards (80% C: Dw.~~fa nnd Settiaga Tces Desktop M~oto DHQ fac Ir.~al Revisw.da: 733 AM 0916 0% Page 3