RE: Working Draft EPA's NPDES Pesticides General Permit

George Robinson to: Jack Faulk 01/22/2010 05:33 PM

Cc: "Bob Hays", "Bob Spencer", "Rod Gabehart", "Gary Bahr", "Sherman 

Takatori", "Fred Rios"

Jack,

Attached are Idaho's comments regarding the draft PGP (the cc list are all

ISDA employees that were requested to review and comment on the draft). I

hope that the meetings in Dallas proved very useful and beneficial.

George Robinson

Idaho State Dept of Agriculture

-----Original Message-----

From: Faulk.Jack@epamail.epa.gov [mailto:Faulk.Jack@epamail.epa.gov] 

Sent: Wednesday, January 13, 2010 4:48 PM

Subject: Working Draft EPA's NPDES Pesticides General Permit

All,

Attached is a copy of EPA's current working draft NPDES Pesticides General

Permit (PGP) for your review and comment. First, we ask that you not

share this draft, either electronically or in paper form, with others.

This permit, by nature of the discharge, is not a typical NPDES permit and,

as you know, we are working through some challenging issues.

Until we feel comfortable with our approach, we'd prefer not to have to

discuss the details of our working drafts with entities outside of our

co-regulator family. We hope to receive that input from you directly!

We will be public noticing the draft permit around the end of April 2010 at

which point anybody and everybody, including states, will have an

opportunity to review and comment on that version of the permit. We do not

have a copy of the permit fact sheet to share with you. The permit writing

has been quite a dynamic process and trying to keep up with a fact sheet

has not been so successful. We hope, although cannot guarantee, to be able

to share a copy of a draft fact sheet with you at some point before

issuance of the permit. Thanks for your understanding.

Tomorrow, January 14, from 1-3 pm eastern time, we will be discussing this

permit on a free webcast, to prepare folks for reviewing the permit and for

participating in our two-day face-to-face meeting in Dallas On January

20-21. If you have not yet done so, you can register to participate in the

webcast (must be done in advance) at

http://event.on24.com/r.htm?e=183080&s=1&k=17604CA8BF94523AA10DE0009E2B2EFF

. You can register for the meeting in Dallas at

http://www.tetratech-ffx.com/npdes_pesticides/.

We would like your comments on this working draft but ask that you submit

those comments electronically no later than close of business Monday,

January 25, 2010. Please send those comments to me at faulk.jack@epa.gov.

We plan to read and consider all comments we receive from you by that time.

We will also be documenting the discussion in Dallas and considering those

comments as well.

One additional item to consider. This permit includes several comments

asking for your specific input on certain permit language. If you have
limited time for which to review the permit, we would ask that you at least

take a look at those few comments and provide your thoughts on those.

Thanks for your patience and understanding and enjoy your reading.

(See attached file: PGP working draft 011310 pm.doc)

Jack

Water Permits Division

US Environmental Protection Agency

EPA East (4203M)

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Telephone (202) 564-0768

Fax (202) 564-6431