March 15, 2022
FEDERAL ISSUES
WOTUS
Regional Roundtables were announced:
https://www.epa.gov/wotus/public-outreach-and-stakeholder-engagement-activities
CMA Consideration of Sackett Amicus Curiae Brief—to be decided by CMA Board—CMA considering implications of a ruling that would put the State of Colorado into a position of pursing state dredge and fill legislation again.
Discussion of inclusion of ground water into WOTUS
Aluminum:
NMA comments submitted: NMA Aluminum Comments, and GEI Aluminum TSD Technical Memo
CMA is developing a project to enhance our participation in the Water Quality Forum aluminum workgroup by assessing the spatial distribution of publicly available data compared to current aluminum standards and the 2018 EPA 304(a) criteria.
STATE ISSUES
Permit Issues Workgroup
https://drive.google.com/drive/folders/1LF7vUp9wMwNmF_7aZ9-yWoyekopxfkXl
Implicit NILs Workgroup
https://drive.google.com/drive/folders/1hx4QwqpibKcs9xwakcGZfdux0fU1p8Cd
CMA Comments – Stated that document is guidance is not regulation, two-year lookback, some allowance for case specific situations, requirement to use lab sheets for verified data, suggested using DRMS data. Waiting for final memo, doesn’t appear that it has been completed by March 30, 2022.
Data where we have a long history of non-detects. Methods continue to develop.
AD Alternatives Analysis – Meeting in March
https://drive.google.com/drive/folders/1n4_pwgXZg8tbeZbx4OKoh-utiufhlpCH
Chemical Evaluations
Chemical Evaluations and Discharge Permits – New Division website, supplier form, how chemical suppliers can feel comfortable providing information. Still questions remaining. Any further need for meeting with Division?
Lab Issues – WET Testing
https://docs.google.com/document/d/1iDUaAthFIKE_HcvzQDefbdXVSTYJE98LdIoKdRPnkVM/edit
Small group discussion – April 7 Permits Topic Group – Should we prepare?
Discussion of application of chemical evaluation requirements for compliance purposes. Status of administratively continued permits and chemical evaluations.
State Issues
Temperature Workgroup – Cannot currently access website.
What issues do we want to discuss with Water Quality Control Division? Beginning of April pre-meeting?
Temperature
Stormwater
RP Analysis – Need to better describe – why have to monitor for substance not used?
Chantell will be checking in with Megan Wilson, City of Boulder – update on Temperature
Poppy: Metal mining and possibly coal stormwater permit? Poppy will send the request for information.
Legislative Items – Dianna Orf
Dredge and Fill – No legislative bill.
Potential Anti-Degradation Bill – Benavidez – Bill was introduced.
CDPHE request for increased appropriation – Driven by Environmental Justice program
PFAS – Bill has been introduced, need to watch for increased monitoring and permitting conditions.
