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. ~ <br />Additional Question for I,egal Revaewers: <br />In the first draft of this memo that was prepared, industrial pernuts were included under <br />the major issues section. The language was as follaws but also included the highlighted <br />question as to whether the lariguage should remain given information pravided in the <br />PER. <br />Industria~ Permits <br />For thosc jurisdictions that do not have an MOA with DEQ to act as an agent for <br />the industrial NPDES pennits, we are un~lear vf the role of these jurisdictions as <br />outlined in the permit. The required role of the permittee without an MOA is <br />duplicative with DEQ's responsibility for aversight and implementation of this <br />industrial permitting progam. Is it DEQ's intent that it is the permittee's <br />responsibility tv identify the businesses which should have permits and DEQ will <br />then issue the pernuts? In addifiion, how is the pennittee e~ected to determine <br />whether an industrial or commerciat area is contributing a substantial pvllutant <br />loading and how is a substantial pollutant loading defined? These clarificadons <br />would be important to make prior to wider distribution of this permit. <br />The pernuttees answers to the question as to whether to include this section in the memo <br />or not was pretty evenly split between jurisdietions. So, I'm including it here to get your <br />feedback. The City of Portland feedback was as follows: <br />'THE INCLUDED TEXT CLEARLY SAY$ `..DEVELOP CONTROLS ... IN'THEIR <br />SWMP'. TO ME, THIS COULD MEAN A PERMITTEE MAY INCLUDE A TASK IN <br />TI~IR SWMP RELATED TO COORDINATIl~TCs OR OBTAINING INFORMATION <br />FROM DEQ ON PERMITTED INDUSTRIES. 1T IS A BIG LEAP FROM THIS TO <br />THE PROVI5IONS INCLUDED 'IN TI~ DRAFT PERMIT. SO, I SAY LEAVE IT IN <br />A5 AN ISSUE ~E WANT CLARIFICATION ON. TI-~RE I5 ANOTI-~R ISSUE AS <br />C: Dounumts and Set~c Tcea De~top Mmw to DE(1 foa Legal Rnvinar.da: 7:33 AM 0916 ON . L"'c~f'. 5 <br />