| Public Process Description
In late February, 2005, the City of Spokane, Spokane County and
several other public and private entities with Spokane River
discharge permits (the Petitioners) reached agreement with the
Washington State Department of Ecology to tentatively withdraw their
Petition for Rule Making concerning Draft TMDL limits. Ecology agreed
to suspend issuance of TMDL limits. Together, using information
assembled for the Draft TMDL and a Use Attainability Analysis (UAA)
prepared by the Petitions, the Petitioners and Ecology are working
on a TMDL Implementation Plan for the Spokane River. This collaboration
allows productive discussion about the Draft TMDL and the UAA
in the context of planned future actions and the expected resulting
improvements in river quality. The discussion is called the
Spokane River TMDL Collaboration.
Issuance of TMDL limits has specific
public involvement requirements which both the Petitioners and
Ecology intend to meet. That process is now temporarily “on hold” as
the Petitioners and Ecology work on a proposed Implementation Plan.
Several issues will come into question as this is done, understandings
about data may change, and the Draft TMDL may need to be revised.
If TMDL changes are recommended, those will be subject to the same
public scrutiny and opportunities for input that have been used
in developing the Draft TMDL. In particular, the TMDL Advisory Committee
will need to review any modifications proposed for the Draft TMDL
and the TMDL process will need to be completed. No part of the
TMDL process is being or will be skipped.
Similarly, there are established
processes for developing a Use Attainability Analysis and submitting
a Petition for Rule Making to adjust water quality standards for
a specific water body. Those processes were followed by the Petitioners
and they withdrew their petition as the deadline for an Ecology
response approached. The petition was withdrawn without prejudice
concerning its being filed again. All processes associated with issuance
of a TMDL and a Petition for Rule Making are simply “on hold” while
a proposed Implementation Plan is under discussion.
Both Ecology
and the Petitioners are very committed to open discussions during
the “on hold” period as a proposed Implementation
Plan is being considered. The discussions will be occurring in
two types of venues. The first, known as the Full Group, involves
representatives of all Petitioners, the United States Environ-mental
Protection Agency, the Idaho Department of Environmental Quality,
the Washington Department of Ecology and others. This venue will
also serve as the focal point for “government to government” level
discussions with tribes. All Full Group meetings are publicized
and open to public attendance. Every meeting will include opportunities
for public comment. The Full Group is where collective determinations
are reached.
A second venue for conversation about the proposed
Implementation Plan and related issues is in Workgroups. Several
Workgroups will be functioning simultaneously to delve into
the meaning and significance of data, develop improved understandings,
answer specific questions, and prepare answers and recommendations
for the Full Group.
Meetings of the Wastewater Flows and Loadings,
Technology, Reuse and Conservation, and Non-Point Source Workgroups
will be publicized in advance. The public will have opportunity
to observe as a Workgroup deals with topics. In the interest of efficiency,
there will not be any public comment at these Workgroup meetings.
Meeting notes will be kept and made available to the public at
the web site described below. If members of the public have concerns
or suggestions about the Workgroups, those should be e-mailed to
the attention of the Steering Workgroup (address available on the
web site) where they will be considered at the earliest opportunity
and responses prepared.
The Steering Workgroup is responsible for
keeping the discussion process moving effectively and efficiently.
The Steering Workgroup, led by facilitator Bill Ross of Ross and
Associates, will convene frequently, often by conference call.
Notes will be kept of all Steering Workgroup meetings and made available
on the web site. The Steering Workgroup is responsible for making
sure discussions move forward. Substantive Petitioner/Ecology determinations
may only be made in the Full Group in open session.
The address
for the Spokane River Collaboration web site is http://client-ross.com/spokane-river/.
Everyone,
including the public, Petitioners and Ecology, should consider
this web site the primary source for information about Spokane
River Collaboration discussions. One part of this site is devoted
to Full Group and Workgroup meeting schedules and locations. Another
holds meeting notes, and other timely information. There is also
a Library with links to relevant documents available for download.
The Spokane River Collaboration site is intended to provide source-controlled
information officially offered by the Petitioners, Ecology or both.
It provides contacts for anyone wishing to offer comment about
the process or substantive issues under consideration. The site
is not set up as a “blog” or “chat room” for
general use. All material on the site must be approved by the facilitator.
Posting can only occur through Bill Ross and Ryan Orth of Ross
and Associates (ryan.orth@ross-assoc.com).
In summary:
- Should changes in the Draft TMDL result from the current
effort, those changes will be subject to the same level of public
review and comment used in developing the Draft. The TMDL Advisory
Committee will review any changes and the public process will
be completed.
- Determinations concerning the Petitioner/Ecology
discussions will only be made by the Full Group
- All meetings
of the Full Group will be publicized, open for public observation,
and include opportunity(s) for public input
- Workgroup meetings,
while publicized and open for public observation, will not include
opportunities for public comment
- Workgroup sessions will be documented
with meeting notes that will be timely posted on the web site
- The public may provide comment about Workgroups via the Steering
Workgroup e-mail address available at the web site
- The Spokane
River Collaboration web site is (http://client-ross.com/spokane-river).
All material posted is sent to the facilitator and approved and
posted by him. The web site is the primary information source
for the public, Petitioners and the Department of Ecology
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