December 15, 2020
Colorado Dredge and Fill: CMA elected to draft comments in response to the White Paper authored by the Water Quality Control Division outlining issues needing to be developed if Colorado were to adopt a dredge and fill permitting program in response to changes made to the Waters of the United States made by the Trump Administration. CMA’s “red-line” comments made to the White Paper’s Google drive document can be found here: White Paper – Google Document. CMA also provided an overview of its more detailed comments which can be found here: CMA Policy Comments.
The committee discussed a recent letter signed by CMA and other regulated entities expressing concern about the Water Quality Control Division’s new Rule Applicability to Water Quality Control Division Permit-Type Actions under the Colorado Administrative Procedures Act which essentially says that permitees renewing water quality permits will be subject to an ever-changing set of water quality standards while a permit is renewed. CMA wishes to thank Rhonda Sandquist of Brownstein Hyatt Farber and Schreck for preparing the letter and collaborating with CMA and its members to express objections to this draft policy.
The committee briefly discussed the current status of potential updates to WQCC Regulation 31 and a stakeholder discussion of the WQCD’s proposed Chemical Agent requirements.