1

MEMORANDUM

TO: Public Record for the NPDES Electronic Reporting Rule

EPA Docket Number EPA-HQ-OECA-2009-0274 (www.regulations.gov)

FROM: Carey A. Johnston, P.E.

USEPA/OECA/OC

ph: (202) 566 1014

johnston.carey@epa.gov

DATE: 13 November 2014

SUBJECT: Notes from State Technical Workgroup Meeting (10 July 2014) [DCN 0181]

Overview 

This was the sixteenth meeting for the EPA-state technical workgroup, which is 

discussing key issues related to the proposed NPDES Electronic Reporting Rule (eRule). These 

discussions are informing the forthcoming supplemental Federal Register notice and they will 

continue beyond the publication of the supplemental notice to help EPA address state 

comments. EPA participants will include the OECA eRule Team as well as representatives from 

EPA’s Office of Water and Office of Environmental Information. Technical workgroup members 

are listed below in Tables 1 and 2. The agenda for this meeting is also provided below. EPA is 

summarizing the notes from these discussions for the docket in order to provide transparency 

on EPA’s outreach during the rulemaking process. The OECA eRule team will also be available 

for any other stakeholder group that would like to discuss the eRule.

Meeting Notes

EPA (Mr. Carey Johnston) started the meeting by reminding state participants that in 

addition to raising questions during the technical workgroup meetings, states can email their 

questions on the proposed rule (including the data elements) to EPA. Questions on all aspects 

of the proposed rule can be sent to Mr. Johnston. Mr. Johnston then asked teleconference 

participants to focus on the pretreatment data elements. This was the second discussion on the 

pretreatment data elements as the group was not able to fully review all the pretreatment data 

elements in first discussion on June 29th (see DCN 0141). The source of these data elements 

includes NPDES permit applications and Notices of Intent (NOI) (see 30 July 2013; 78 FR 46096-

46098), State or EPA pretreatment inspections or audits (Page 46102-46103), and POTW 

Pretreatment Program Annual Report and SIU Periodic Compliance Reports in Municipalities 

without an Approved Pretreatment Program (Page 46111). 

Mr. Johnston started the technical discussion by reading the name of each data element 

along with the corresponding data description and regulatory or policy citation. After reading 
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about five to ten elements at a time, Mr. Johnston asked for input from the technical 

workgroup. Below are some questions and comments from the technical workgroup. The first 

set of data elements discussed were the data elements that relate to the Annual POTW 

Pretreatment Program report (Page 46108-46111).

 For the SNC Published in Newspaper Flag data element, Michigan DEQ suggested that EPA 

drop the requirement that SNC be published in a newspaper. Ms. Beth Graves (ECOS) also 

suggested that EPA doesn’t need to specify ‘Newspaper’ in the data element. 

 Michigan DEQ also noted that they have non-Federal POTW programs that they call ‘miniprograms.’ They allow these mini-programs to implement the pretreatment program 

through oversight of industrial users and enforcement of Federal pretreatment standards.

 Texas noted that after a permit is re-issued the POTW needs to evaluate if any local limits 

need to be updated. Virginia DEQ noted that if a POTW is in compliance and nothing has 

changed then their agency doesn’t make the POTW evaluate its local limits. New Jersey DEP 

state they it is a permit requirement in New Jersey permits that POTWs re-assess their local 

limits

 Tennessee, Michigan, and South Dakota noted that they require influent and effluent 

sampling at the POTW and to compare these data against the last technical evaluation. They 

also have the POTWs review their Industrial User (IU) list to see if there are any changes 

from the last review. 

 Michigan DEQ and Kansas suggested that EPA drop the data element requirements for 

Removal Credits as so few POTWs have this authority. EPA estimates that approximately 4 

of the roughly 1,600 POTW Pretreatment Programs have this authority. 

 Michigan DEQ suggested that EPA add ‘current’ to the Industrial User Control Mechanism 

Flag data element so that it reads as, “whether the Industrial User has a current Control 

Mechanism.”

 Several states (MO, KS, TX, OK, and AR) ask EPA to make clear that the POTW Pretreatment 

Program Annual Report data elements apply the current reporting period. For example, 

they suggested that EPA add ‘in the reporting period’ in the description of these data 

elements to make clear that the reported data is for that reporting period.

 Texas suggested that the data related to flow be simplified.

 With respect to the Control Authority Resources data element, Texas suggested that it 

might be difficult for POTW Pretreatment Programs to provide a dollar amount on their 

annual budget. The commenter suggested that EPA re-word this data element to capture 

EPA’s intent, which is to have the pretreatment program state whether the pretreatment 
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program has sufficient resources (e.g., budget, full-time equivalent labor) to fully implement 

its pretreatment program.

 Texas also suggested that EPA clarify that the reduced reporting data element applies to 

Middle Tier CIUs. 

After the meeting EPA received comments from the Kansas Department of Health & 

Environment and Washington State Department of Ecology. They are presented in Attachments

1 and 2 respectively.
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State Technical Workgroup Meeting – NPDES Electronic Reporting Rule

10 July 2014

Agenda

1pm Introduction/Roll Call 

1:10 Discussion of pretreatment data elements 

2:00 End of Call

Quick Reminder

 The technical workgroup is not a formal decision-making body. The workgroup is expected 

to develop, research, and evaluate options for consideration by EPA and state senior 

management.

 There are no formal quorum rules for the workgroup. Scheduled teleconferences will 

proceed with whichever workgroup members call in to participate.

 There will be no formal voting or consensus of the workgroup. Instead, the workgroup is 

expected to try to develop recommendations reflecting their various perspectives, not 

achieve consensus.

 Summaries of the workgroup’s discussions will be prepared for and reviewed by the 

workgroup, for presentation to EPA senior management and other states and the 

rulemaking record. The discussions summaries will outline the major elements of the 

discussions, areas of agreement and any dissenting views.
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Table 1: State Technical Workgroup Members

Main Contact State or 

Organization Main Contact Email

State/Org. 

Present? 

(Yes/No)

Sean Rolland ACWA srolland@acwa-us.org Yes

Karen Lechner AK karen.lechner@alaska.gov Yes

Christy Monk

AL

cvm@adem.state.al.us

Eric Cleckler ecleckler@adem.state.al.us No

Glenda Dean gld@adem.state.al.us

Teresa Marks

AR

marks@adeq.state.ar.us

Yes

Pat Goff goff@adeq.state.ar.us

Mo Shafii shafii@adeq.state.ar.us

Karen Bassett bassett@adeq.state.ar.us

David Ramsey ramsey@adeq.state.ar.us

Ellen Carpenter carpenter@adeq.state.ar.us

Wendy LeStarge

AZ

lestarge.wendy@azdeq.gov

Robin Belley belley.robin@azdeq.gov No

David Lelsz lelsz.david@azdeq.gov;

Andy Putnam

CO

andrew.putnam@state.co.us

goff@adeq.state.ar.us Yes

Elisa Willard elisa.willard@state.co.us

Bob Zimmerman DE robert.zimmerman@state.de.us

stephanie.bower@state.de.us No

Beth Graves ECOS bgraves@ecos.org Yes

Chris Klena

FL

chris.m.klena@dep.state.fl.us

Yes

Jessica Kleinfelter jessica.kleinfelter@dep.state.fl.us

Edward Smith edward.c.smith@dep.state.fl.us

Frances Carpenter frances.carpenter@dnr.state.ga.us

Frances Carpenter GA frances.carpenter@dnr.state.ga.us No

Tom Easterly

IN

teasterl@idem.in.gov

ckoontz@idem.in.gov

Yes Jeremy Chenevert jcheneve@idem.in.gov

Mark Stanifer mstanife@idem.in.gov

Courtney Cswercko IA courtney.cswercko@dnr.iowa.gov Yes

Ed Dillingham

KS

edillingham@kdheks.gov

Steve Caspers scaspers@kdheks.gov Yes

Shelly Shores-Miller sshoresm@kdheks.gov

Shawn Hokanson KY shawn.hokanson@ky.gov No

Grace Scott

MI

scottg@michigan.gov

Yes Carla Davidson davidsonc@michigan.gov
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Main Contact State or 

Organization Main Contact Email

State/Org. 

Present? 

(Yes/No)

Ruth Wallace

MO

ruth.wallace@dnr.mo.gov

Walter Fett walter.fett@dnr.mo.gov Yes

Christopher Miller epermitting@dnr.mo.gov

Tamara Dahl

MN

tamara.dahl@state.mn.us

Yes Paul Scheirer paul.scheirer@state.mn.us

John Murphy NEIWPCC jmurphy@neiwpcc.org No

Jason Lonardo

NJ

jason.lonardo@dep.state.nj.us

Yes Julio Collazo julio.collazo@dep.state.nj.us

Robert Wither

NY

rewither@gw.dec.state.ny.us

Yes Joseph DiMura jxdimura@gw.dec.state.ny.us

Shellie Chard-McClary

OK

shellie.chard-mcclary@deq.ok.gov

Roy Walker roy.walker@deq.ok.gov Yes

David Pruitt david.pruitt@deq.ok.gov

Jim Billings OR billings.jim@deq.state.or.us Yes

Sean Furjanic PA sefurjanic@pa.gov No

Kent Woodmansey

SD

kent.woodmansey@state.sd.us

Tim Flor tim.flor@state.sd.us Yes

Albert Spangler albert.spangler@state.sd.us

Lawrence Bunting

TN

lawrence.bunting@TN.gov 

Yes Yatasha Moore yatasha.moore@tn.gov 

Kim Wilson

TX

kim.wilson@tceq.texas.gov

Yes Rebecca Villalba rebecca.villalba@tceq.texas.gov

Lynley Doyen lynley.doyen@tceq.texas.gov

Kimberly Shepard kimberly.shepard@tceq.texas.gov

Jeff Studenka UT jstudenka@utah.gov No

Jerome Brooks

VA

jerome.brooks@deq.virginia.gov

Deborah Debiasi Deborah.DeBiasi@deq.virginia.gov Yes

Phani Eturu phani.eturu@deq.virginia.gov

Stephen Bernath

WA

sber461@ecy.wa.gov

Dave Knight dakn461@ecy.wa.gov Yes

Nancy Kmet nkme461@ecy.wa.gov
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Table 2: EPA Technical Workgroup Members

Name EPA Office Email Present? 

(Yes/No)

Lisa Lund OECA/OC/IO lund.lisa@epa.gov No

John Dombrowski OECA/OC/ETDD dombrowski.john@epa.gov No

Andy Hudock OECA/OC/ETDD hudock.andrew@epa.gov No

Rochele Kadish OECA/OC/ETDD kadish.rochele@epa.gov No

Carey Johnston OECA/OC/ETDD johnston.carey@epa.gov Yes

David Sprague OECA/OC/ETDD sprague.david@epa.gov Yes

Emery Harriston OECA/OC/ETDD harriston.emery@epa.gov Yes

Rhonda Golder OECA/OC/ETDD golder.rhonda@epa.gov Yes

Jackie Clark OW/OWM/WPD clark.jackie@epa.gov Yes

Roy Chaudet OEI/OIC/IESD chaudet.roy@epa.gov No

Chuck Freeman OEI/OIC/IESD freeman.charles@epa.gov No

Aditi Prabhu OGC/WLO prabhu.aditi@epa.gov No

David Apanian Region 4 apanian.david@epa.gov Yes

Jan Pickrel OW/OWM/WPD pickrel.jan@epa.gov Yes

Glynis Hill OP/ORPM/PRAD hill.glynis@epa.gov No
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Attachment 1 – Comments from Kansas Department of Health & Environment

From: Steve Caspers [mailto:scaspers@kdheks.gov] 

Sent: Friday, July 11, 2014 11:58 AM

To: Johnston, Carey

Cc: Sean Rolland (srolland@acwa-us.org); Pickrel, Jan <Pickrel.Jan@epa.gov>; Pickrel, Jan 

<Pickrel.Jan@epa.gov>; Dave Knight (dakn461@ECY.WA.GOV); Grace Scott (scottg@michigan.gov); 

Rebecca Villalba (rebecca.villalba@tceq.texas.gov); Kirsch, Susan (skirsch@acwa-us.org)

Subject: Electronic Reporting - Pretreatment data - comments - Part 2

Carey, as per your request, below are written comments regarding our conference call yesterday, for 

your consideration. Note: Some of these comments may not have come directly from me, but are 

included if we endorse them. Hopefully other States will provide their input as well.

(1) SNC with pretreatment schedule flag: Suggest the word “enforceable” be added so the wording 

is “enforceable pretreatment schedules”. This needed since not all pretreatment schedules are 

enforceable, unless they are placed in an administrative order, permit or other enforceable 

document.

EPA Response: Thank you for this suggestion. We will make this change to Appendix A so that the data 

element reads as, “SNC with Pretreatment Enforceable Compliance Schedule Flag .”

(2) Date of most recent adoption of technically based local limits and date of most recent technical 

evaluation of local limits: As noted on the phone, it appears these two data names and data 

descriptions were accidently switched. It is also not clear what is meant by the words “the date 

the CA evaluated the need for local limits”. States have varied frequencies on how often they 

require head-works analysis to be performed and it also varies how extensive these reevaluations are. In Kansas, local limits are required to be re-calculated when one of six criteria 

are met. (loss or gain of IUs, significant upgrade of a WWTP, change in WQ standards, a change 

in the city’s NPDES limits, the 503 sludge limits change or if pass through or interference occurs). 

It is not necessarily based on whether the city’s NPDES permit is expiring or not. Maybe it would 

be more clear to ask for two items. One, the date the local limits were “last recalculated” and 

second, the date the last local limits “were adopted”. These dates would be more clear, 

meaningful and easier to track.

EPA Response: Thank you for this suggestion. We will make the suggested change to these two data 

elements. EPA solicits comment on the following revisions to two data elements. EPA notes that if the 

Control Authority does not do an evaluation or adoption of local limits within a reporting period then 

these data elements can be left blank in that annual report. 

Local Limits Adoption Date: This is the most recent date on which the Control Authority has adopted 

new local limits within the reporting period. The date must be provided in YYYY-MM-DD format where 

YYYY is the year, MM is the month, and DD is the day.

Local Limits Evaluation Date: This is the most recent date on which the Control Authority evaluated the 

need for local limits within the reporting period. The date must be provided in YYYY-MM-DD format 

where YYYY is the year, MM is the month, and DD is the day.
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(3) POTW discharge contamination indicator: It was suggested that this item be separated into two 

elements. One, problems related to upset and bypass and the second, those problems related to 

interference and pass through.

EPA Response: Thank you for this suggestion. EPA is using two data elements to track any issues at the 

POTW with one data element focusing on the discharge (POTW Discharge Contamination Indicator) and 

the other focusing on the biosolids management (POTW Biosolids Contamination Indicator). The first 

data element identifies “whether there have been any problems (e.g., pass-through or interference) 

with the receiving POTW’s effluent discharge within the reporting period.” The commenter’s suggestion 

does not seem workable as the term ‘interference’ includes events such as ‘upsets’ and ‘bypass.’ EPA is 

soliciting comment on retaining the two data elements and not trying to split the POTW Discharge 

Contamination Indicator into two separate data elements.

(4) Removal credits: Since there are only a handful of programs in the nation with removal credits, 

it is suggested only the minimum amount of information that needs to be reported to OMB by 

EPA be requested and eliminate all of the other elements.

EPA Response: Thank you for this suggestion. We will delete the data elements related to removal 

credits from Appendix A.

(5) Industrial user city: EPA indicated on the phone that it would not create a problem if the name 

of the city the IU was located in, was not the same name of the approved program the IU was 

located in. It was also pointed out that an IU could even be located in a different State than the 

approved program was located in, if the IU was near a state border.

EPA Response: Thank you for this comment. The tracking of locational data for Industrial Users is 

independent of the corresponding pretreatment program locational data. The commenter’s scenario 

(different cities or states for an Industrial User and its pretreatment program) will not be a problem with 

EPA’s electronic data collection tools or ICIS-NPDES.

(6) IU control mechanism: It was suggested the words “active” be added to indicate that only 

control mechanisms that were active need to be reported, not the number of “expired or 

inactive” control mechanisms. 

EPA Response: Thank you for this suggestion. We will make the suggested change to these two data 

elements in Appendix A.

(7) Number of IU sampling events: Not sure why this information is even being requested and why 

it would be important to know. The term “sampling events” could also be interpreted 

differently. For example, do “all” of the parameters mentioned in a permit need to be analyzed 

to be considered a “sampling event”? What if only a portion of the parameters were sampled, 

due to a non-compliance event?

EPA Response: Thank you for this comment. The tracking of IU sampling events, those performed by the 

IU and those performed by the Control Authority, provides important information on the adequacy and 

robustness of the pretreatment program. These data will help the Approval Authority improve their
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oversight of the Control Authority. EPA will provided additional clarity in the Appendix A data elements 

regarding the sampling events that must be counted and reported on the annual report.

(8) IU process flow rate: The current data description asks for “process” flow but it appeared the 

intent was to gauge the impact of the IU, on the POTW. Therefore, it may be more appropriate 

to request the “total” flow of the IU. 

EPA Response: Thank you for this suggestion. We will simply the tracking of IU flow rate in Appendix A.

(9) Control Authority budget resources: It appears the current data description requests the budget 

amount in dollars. This information will be very difficult to derive, since most programs do not 

have a line item budget. To better meet the intent of the regulations, it is suggested the data 

description be replaced with the following language or similar. “Does the POTW have adequate 

resources to properly implement and administer their pretreatment program?” This would be a 

“yes” or “no” answer.

EPA Response: Thank you for this suggestion. We will make the suggested change to the data element. 

EPA solicits comment on the following revision to this data element.

Control Authority Resources: A unique code/description that identifies whether the pretreatment 

program has sufficient resources (e.g., budget, full-time equivalent labor) to fully implement its 

pretreatment program.

Overall comments;

(1) For items that will require a “yes or no” reply, it would be more clear to mention that in the 

data description. 

EPA Response: Thank you for this suggestion. We added text in the data descriptions in Appendix A to 

provide more clarity on the data format.

(2) There are inconsistencies when the data name refers to “Industrial Users” but the data 

description only specifies “Significant Industrial Users”. SIUs are only a subset of IUs.

EPA Response: Thank you for this comment. We added text in the data descriptions in Appendix A to 

provide more clarity. EPA is soliciting comment on any additional text that can provide more clarity. 

(3) The words “in the previous 12 months” is used often and can be interpreted differently on 

when the 12 months actually begin. Furthermore, not all programs use the calendar year 

that would better define the time period. Suggest the words “reporting period” be used in 

the data description, since this timeframe is clearly defined in control mechanisms. The 

down side is you will not be comparing all data for exactly the same time period, because 

varying report periods are utilized. However, you already have this problem with the current 

verbiage, because the 12 month time periods are not going to be the same either.

EPA Response: Thank you for this suggestion. We used the term, ‘in the reporting period,’ in the 

Appendix A data elements to provide clarity on what actions and data should be reported in each annual 

report. 
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We appreciate the opportunity to provide comments and look forward to working with EPA on making 

these changes a reality.

Steve Caspers, Pretreatment Specialist

Bureau of Water

Industrial Programs Section

Kansas Department of Health & Environment

E-Mail address:SCaspers@kdheks.gov

785.296.5551

Fax 785.296.0086
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Attachment 2 – Washington State Department of Ecology

From: Knight, David J. (SWRO) (ECY) [mailto:dakn461@ECY.WA.GOV] 

Sent: Tuesday, July 15, 2014 2:46 PM

To: Johnston, Carey

Cc: Pickrel, Jan <Pickrel.Jan@epa.gov>; Grace Scott (scottg@michigan.gov); Rebecca Villalba 

(rebecca.villalba@tceq.texas.gov); Steve Caspers <scaspers@kdheks.gov>; Kmet, Nancy (ECY) 

<nkme461@ECY.WA.GOV>

Subject: RE: Electronic Reporting - Pretreatment data - comments - Part 2

Carey, the electronic reporting rule (ERR) determines how data is collected and reported, and thus will 

have a significant bearing on program implementation. Accordingly, I would like to make a few finer 

points I think are important to capture on this that haven’t been brought to light.

Please consider changing Table 1 (data sources) of the FR notice NPDES Data Group #7 from 

“Pretreatment Control Authorities” to “POTWs that are Pretreatment Control Authorities”. Annual 

pretreatment reports are only required of POTWs administering pretreatment programs, not of States 

and EPA when they act as the Pretreatment Control Authority. The referenced primary citation 

403.12(i)) specifically only applies to delegated POTWs. States assuming a POTW’s responsibilities are 

required (by 40 CFR 403.10(e)) to carry out the provisions of 403.8(f), but are not required to submit 

annual reports per 403.12(i). EPA has already developed a separate area (section 21 – “Reports outside 

Delegated Pretreatment Programs” with data items 284-294) to capture the reporting needed on SIUs 

where States and EPA regions that act as control authorities. Reporting requirements of states with 

respect to SIUs they permit (including middle tier CIUs, and NSCIUs) should be compiled there.

EPA Response: Thank you for this comment. We added text in Table 1 to provide more clarity that these 

annual reports are to be submitted by POTWs and not states that are acting as the Control Authority. In 

particular, we added ‘POTW’ to the title of this report so that it now reads as: POTW Pretreatment 

Program Annual Report.

For data relating to POTW Annual Reports (section 25), eight of the data items list the data sources as 

both ‘7’ (Pretreatment Control Authorities) and ‘8’ (SIUs outside of delegated POTW pretreatment 

programs). Please consider removing the ‘8’ for these basic data fields which identify the User and their 

flows. For SIU’s permitted by the State or EPA, they duplicate information which States and EPA would 

enter in sections 1 (basic facility information) & 2 (basic permit information) for their Permittees. It 

would be better if information on SIU’s outside of delegated POTW programs not already addressed by 

Sections 1 and 2 was consolidated in section 21 “Reports Outside Pretreatment Programs” (data items 

284-294).

EPA Response: Thank you for this comment. EPA has simplified the collection of facility and flow data in 

Appendix A. We are soliciting comments on these revisions. 

Please consider removing the reference to PCI’s and Audits in the title of Section 13. The title now 

reads: “Pretreatment Information on Permit Applications, Notices of Intent, (or Pretreatment 

Compliance Audit or Inspection)...”. However, a different section (#20 - Compliance Monitoring Activity 

– Pretreatment Inspections and Audits) already addresses information needed to be compiled from PCI’s 

and Audits. It would be unmanageable to attempt to collect and enter all data listed in section 13 

(including a number of data items on each SIU) as part of a PCI or Audit. EPA should compile in section 
13

20 all data which EPA expects to be tabulated from a PCI or Audit (except perhaps basic inspection data 

such as inspector, date, etc.).

EPA Response: Thank you for this comment. We have made the suggested change to Appendix A.

With respect to Steve Casper’s comments, I would add two things:

With respect to comment (7) below, I presume that EPA’s reason for ERR data fields relating to POTW 

sampling and inspection activities is to ensure that the POTW has fulfilled their legal obligation to 

inspect each SIU at least once annually and annually perform oversight monitoring for each SIU for all 

pollutants for which the SIU has permit limits. If this is the case, the data field descriptions might make 

this a bit clearer by asking this more directly.

EPA Response: Thank you for this comment. We have made changes to Appendix A. See response to 

comment #7 above.

With respect to overall comment (2) below, I would add that the pretreatment rules have not been as 

clear they might about POTW obligations with respect to IU’s which are not SIU’s, and the ERR could 

help foster consistency in the degree of reporting of these “other IU’s”. My understanding is that 

information relating to an IU that is not an SIU is only required to be reported when the IU meets 

applicable SNC criteria. But EPA’s definition of ‘SIU’ allows (at 40CFR403.3(v)(3)) a CA to determine that 

an IU meeting the SIU criteria is not an SIU. And while this provision requires the action be consistent 

with 403.8(f)(6), that doesn’t stipulate how such determinations need to be documented, and listing of

such Users isn’t specifically reinforced in annual reporting 403.12(i)(1). 

Because 403.8(f)(6) is primarily focused on an initial list, and 403.12(i)(1) is focused on updates to prior 

lists, there may be any number of high flow and/or high strength industries which have at some point 

been delisted and are no longer permitted, tracked, or reported on in any manner. Because the rules 

don’t require specific documentation be kept or for the POTW to periodically revisit such de-listings, 

there is an unaddressed potential for inconsistent application of this provision. To address this, I believe 

it would be appropriate and consistent with 403.8(f)(6) and 403.12(i) to specifically require POTWs 

annually provide an updated list of their IU’s which includes all SIU’s and all IU’s which otherwise meet 

the criteria for being an SIU (at 403.3(v)(1)), but have been delisted, and give the reason for the 

delisting.

EPA Response: Thank you for this comment. We have made changes to Appendix A so that POTWs can 

update their list of IUs through the annual report.

Dave Knight

David J. Knight P.E. 

Environmental Engineer 

Southwest Regional Office, Water Quality Program 

Washington State Department of Ecology 

PO Box 47775, Olympia WA 98504-7775 

Phone (360) 407-6277 

Email - david.j.knight@ecy.wa.gov