Summary: comments chapter 4 street sweeping manual
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Shelby Giltner, ECY
Ch. 4 Title
Suggestion for the title: Establishing and Implementing Street Sweeping Programs.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Paul Marrinan
Ch. 4 Title
I think it’s a good idea to rename this section either to what you propose in your
email or: elements of a sweeping a program.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Madison Bristol, ECY
Ch. 4 Title
ECY REVIEWERS – Review due 12/20/2024. Please utilize COMMENTS and not
TRACKED CHANGES. This helps with document reconciliation. Thank you.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Larry Schaffner
Ch. 4 Title
Suggested renaming is in recognition that this chapter may also be useful for
jurisdictions with existing programs. The renaming suggestion is inspired by the
language in the last sentence of Section 4.2.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Paul Marrinan
Ch.4 – Title
I think it’s a good idea to rename this section either to what you propose in your
email or: elements of a sweeping a program.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Jackie Cladwell, Vancouver
Chp. 4 Title
The chapter title is currently “Establishing Street Sweeping Programs,†however,
some of the chapter contents may be useful for jurisdictions with existing programs.
Does it make sense to rename the chapter to something like, “Street Sweeping
Program Components� Do you have any other suggestions? We prefer the second
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
David Jackson, Marysville
Chp. 4 Title
Suggested chapter title: Elements of a Street Sweeping Program†to match verbiage
in the Stormwater Management Manual?
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Amy B. Waterman, ECY
4.1
and maintaining
added
Yes
Abbey Stockwell, ECY
4.1
Should it be clear that the purpose of this guidance is a sweeping program for water
quality/stormwater management? – which can be combined with other sweeping
benefits/purposes and public services (aesthetics of an area, air quality, etc.)
Added to 2nd sentence in first paragraph.
Yes
Traci Pearson, ECY
4.1
[Regarding "waste disposal" in the middle of the paragraph.] If you haven't already, I
suggest checking in with Ecology's Hazardous Waste and Solid Waste Programs
about their waste management and disposal regulations related to street/sweeping
Comment noted. Comment will be moved to chapter 7
Disposing of Street Sweeping Waste.
Yes
Larry Schaffner
4.2
General comment: Given this is a guidance manual, consider whether the
references at the end of the chapter are sufficient. While citations may serve a
specific value in some instances, their frequent use throughout the document might
seem out of place (and can present a distraction) in the context of this guidance
Per TAC discussion, references will be left as is.
Yes
Jessica Schwing, ECY
4.2
[Following end of 2nd sentence]. consider adding in the additional steps in the
program- proper storage and disposal of this waste. We see many "programs" that
fail to account for these steps resulting in a re-release/re distribution of pollutants.
This also results an extreme under-estimation of the cost to implement a sweeping
Added a few words about storage and disposal along with
a reference to chp 7 for more details.
Yes
David Mora, ECY
4.2
[Following end of 3rd sentence]. might clarify : with high efficiency sweepers
Added "when high efficiency sweepers are utilized."
Yes
Xavier Gilbert, ECY
4.2
[Regarding sentence that ends in "…reduce clogging of stormwater infrastructure,
allowing for less frequent maintenance."] Just because less sediment is reaching
the BMP does not mean you can maintain it less. Water is still reaching the BMP
which causes wear and tear and warrants routine maintenance.
Attempting to run a street sweeper in the hopes of cutting corners in other
maintenance areas will do more harm than good.
Revised sentence to provide clarification that sweeping
has the potential to reduce the amount of maintenance
needed and the BMP lifecycle.
Yes
Jessica Schwing, ECY
4.2
[Regarding sentence that ends in "…allowing for less frequent maintenance."] Has
"less frequent maintenance" been demonstrated?
Revised sentence to provide clarification that sweeping
has the potential to reduce the amount of maintenance
Yes
Page 1
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Paul Marrinan
4.3
Add permitting to this list and to the bullet points below. We are required to
maintain a health department permit and test the waste prior to disposal to ensure
that it is not hazardous.
This is correct, added reference to applicable health
department permits; will elaborate more on this in Chapter
Yes
Larry Schaffner
4.3
General thought to consider: Subsections in 4.3 includes language such as “See
Chapter/Section X for further discussion on Yâ€. This makes me wonder how to
efficiently present information (or where best to present it) without being
We will revisit this after the entire manual has been pulled
together and if needed make adjustments in the draft
compiled manual. This may include removing some
Yes
Abbey Stockwell, ECY
4.3
[Regarding second sentence] . I am not sure this is a "but" statement. Recommend:
Jurisdictions with a Phase I or Phase II MS4 Permit are required to conduct street
sweeping. Other considerations such as safety or maintenance concerns and public
perception may also factor into goals.
Changed "but" to "and"
Yes
Abbey Stockwell, ECY
4.3
[End of second to last sentence in first paragraph] . and permit requirements?
added
Yes
Brent Dhoore
4.3.1
This can also include local Health Department permit requirements for handling and
storage which include ongoing permit compliance admin.
added
Yes
Amy B. Waterman, ECY
4.3.1
if they are planning to purchase their own sweeping equipment.
Added a few words about deciding whether or not to
purchase a sweeper.
Yes
Larry Schaffner
4.3.1
In addition, coordinating externally could come into play with effected businesses
and special events.
added
Yes
Zackary Holt
4.3.1
Could we consider something less procedural than an SOP? In my experience,
operators tend to disregard these unless they are super simplified, such as flip
books that are 1-2 pages tops? Or maybe a combination of the two?
Added separate bullet for corollary instructions.
Yes
David Mora, ECY
4.3.1
[Regarding Sweeping locations and routes and Sweeping schedule bullets] . I would
consider the how to of routes and scheduling, waste disposal, and tracking as part
of your SOP
Yes, these aspects will likely be included in SOPs, but we
wanted to call out these items as their own specific
considerations. Designing street sweeping routes will be
included in Chapter 5 – Optimizing Street Sweeping
Practices. Scheduling is discussed later in this chapter.
Waste disposal is discussed in Chapter 7 – Disposing of
Street Waste. Tracking is included in Chapter 6 – Data
Collection and Reporting.
Yes
Xavier Gilbert, ECY
4.3.1
[Regarding Sweeping locations and routes and Sweeping schedule bullets]. What
does this mean? Do they know WHY they are sweeping this area? Do they know what
pollutants are of concerns in each area?
The process behind selecting areas to sweep is explained
in Chapter 3 – Selecting Priority Areas. Pollutants of
concern are discussed in Chapter 2 – Street Sweeping
Yes
Sarah Ponte, ECY
4.3.1
[Regarding Equipment selection and maintenance protocol bullet]. Consider
including/taking into consideration maintenance costs in the budget allocation
This is addressed in chapter 8.
Yes
Rachel Yonemura, ECY
4.3.1
[Regarding Equipment selection and maintenance protocol bullet]. it might be good
to make a quick note about making a plan for if/when a sweeper is down. sometimes
sweepers can be down for a long period of time, but sweeping still needs to be done.
Added consideration and examples of contingency plans
for equipment downtime to Section 4.6.2.
Yes
Jessica Schwing, ECY
4.3.1
[Regarding Waste disposal process bullet]. What about storage and
calculating/estimating your storage needs? Almost all the other factors hinge on
knowing how much material you have to physically move around, store, dump etc.
This will be addressed in chapter 7.
Yes
Xavier Gilbert, ECY
4.3.1
[Regarding Data collection and documentation bullet]. This is a great way to figure
out where your hot spots are and adjust your sweeping intervals accordingly.
Agree. Data collection for use in identifying areas to street
sweep, including hot spots, is included in Chapter 3 –
Yes
Abbey Stockwell, ECY
4.3.2
[Regarding first sentence of the section] . Consider adding GIS staff to this list for
route mapping, updates, route optimization and analysis
Added GIS staff to list.
Yes
Page 2
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Xavier Gilbert, ECY
4.3.2
[Regarding Mechanic bullet]. If you are running an in-house street sweeping
program, this is a key piece of the puzzle to keep things running smoothly.
Comment noted.
Yes
Zackary Holt
4.3.2
[Regarding Crew Leader bullet] . Responsible for data collection as well?
Added "may also be responsible for data collection".
Yes
Abbey Stockwell, ECY
4.3.3
Delete “highâ€, can match PH II language as below
left as is for consistency with other manual sections.
Yes
Larry Schaffner
4.3.3
Seems redundant with the previous sentence.
Sentence deleted.
Yes
Zackary Holt
4.3.3
[Regarding Selbig & Bannerman 2007 citation] . Local? If not, in which area was the
Added study location and climate. Moved section to
Yes
Larry Schaffner
4.3.3
May be less relevant in western WA (at the lower elevations) given the relatively mild Added a sentence about seasonal sweeping for WWA.
Yes
Larry Schaffner
4.3.3
In drawing conclusions, suggest considering the climatic conditions where these
studies took place.
Added and moved section to Section 2.2.3 Removal
Efficiency.
Yes
Larry Schaffner
4.3.3 Table 4-1
Does the study describe what “hot spot areas†entail? If so, suggest adding that
description in a footnote to this table.
Added definition for hotspots. Moved section to Section
2.2.3 Removal Efficiency.
Yes
David Mora, ECY
4.3.3 Table 4-1
[Regarding Arterials info] . Perhaps optimal if your objective is to keep other BMPS
working. If optimal is getting anywhere near the efficiencies hoped for to curb 6PPD-
Waiting to hear back from Ecology regarding a source for
this.
Larry Schaffner
4.3.3
Great information in this section
Comment noted.
Yes
Jessica Schwing, ECY
4.3.3
[Regarding sentence in paragraph before table 4-1] Research studies also provide
recommendations for street sweeping frequency]. to address specific pollutants or
environmental conditions.
Added "to address water quality." Moved section to
Section 2.2.3 Removal Efficiency.
Yes
Larry Schaffner
4.3.3
I understand how this could be the case on arterials, but residential areas too?
In residential areas, street parking maybe will be greater –
Yes
Zackary Holt
4.3.3
In my experience, planning for and implementing no parking sign placement can be
a significant lift (site dependent, neighborhood design, etc.) with notification
requirements, parking alternatives, etc. Is this discussed later?
Addressed in Section 4.8.5 and Section 8.2.4.4
Yes
Amy B. Waterman, ECY
4.3.3
Any more recent ones? Also this section does not address PNW specific situation,
with most of rainfall in the fall and winter. This was a major consideration in Permit
requirements to sweep before the onset of these rain events.
We did not find more recent studies, but we did find a
resource relevant to WWA climate. Added a sentence
about seasonal sweeping for WWA. Moved section to
Section 2.2.3 Removal Efficiency.
Yes
Larry Schaffner
4.3.3 – Figure 4-1
Did the study involve similar climatic conditions as found in eastern and/or western WAdded context of study location and climate. Moved
section to Section 2.2.3 Removal Efficiency.
Yes
David Jackson, Marysville
4.3.4
[RE: Have any jurisdictions scheduled street sweeping around needle drop? If so,
can you provide what time of year is best for different species of conifers?]Our sweeping is based on high traffiic areas and annual coverage.
Comment Noted.
Yes
Larry Schaffner
4.3.4
Is this intended to imply utilizing an in-house mechanic? If not, is seems redundant
with utilizing a private contractor.
Revised sentence to provide clarification.
Yes
Larry Schaffner
4.3.4
The relevance of this portion of the sentence isn’t clear to me.
Deleted portion of sentence.
Yes
Zackary Holt
4.3.4
Debris that has accumulated on the vehicle? Roadside debris or CB debris such as
leaves, etc.? Or is this referring to the process of sweeping?
Refers to cleaning debris out of sweepers after each
sweeping event. Change to “vehicle cleaning†to clarify.
Yes
Larry Schaffner
4.3.4
Does this refer to leaks on the pavement or reducing the likelihood of leaks from the
sweeper?
Added "from the sweeper".
Yes
Zackary Holt
4.3.5
Does this include decanting processes? It sounds like only solids are addressed.
WWA has a lot of juicy street waste that in many instances requires some form of
Revised section to address TAC comments which includes
reference to decanting. More details are provided in chp 7.
Yes
Paul Marrinan
4.3.5
Maybe include potential permitting language in the disposal section instead of
creating a distinct section.
Revised section to address TAC comments.
Yes
Page 3
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Amy B. Waterman, ECY
4.3.5
I know there will be more detail on Chapter 7, but this section should acknowledge
the fact that there are liquid and solid wastes from street cleaning. The MS4 Permits
(Appendix 6) have requirements for street waste liquids, which is Ecology's
jurisdiction. Street waste solid disposal is permitted by the County Health
Revised section to address TAC comments which includes
reference to decanting and county health department
permits.
Yes
Abbey Stockwell, ECY
4.3.6
[Regarding 3rd sentence in the first paragraph]. Should this include a discussion on
technology for sweepers that can do some of this documentation?
Add more text with reference to Chapter 6 which includes
details on using sweeper technology for documentation.
Yes
Amy B. Waterman, ECY
4.3.6
[Regarding Bullet: Other documentation requirements: Street sweeping training
performed and staff trained] . including training to prevent or minimize impacts to
water quality.
Section modified and the bullet commented on is not
longer in this section. Comment moved to chapter 6.
Yes
Abbey Stockwell, ECY
4.3.6
Some items in the…
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Shelby Giltner, ECY
Ch. 4 Title
Suggestion for the title: Establishing and Implementing Street Sweeping Programs.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Paul Marrinan
Ch. 4 Title
I think it’s a good idea to rename this section either to what you propose in your
email or: elements of a sweeping a program.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Madison Bristol, ECY
Ch. 4 Title
ECY REVIEWERS – Review due 12/20/2024. Please utilize COMMENTS and not
TRACKED CHANGES. This helps with document reconciliation. Thank you.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Larry Schaffner
Ch. 4 Title
Suggested renaming is in recognition that this chapter may also be useful for
jurisdictions with existing programs. The renaming suggestion is inspired by the
language in the last sentence of Section 4.2.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Paul Marrinan
Ch.4 – Title
I think it’s a good idea to rename this section either to what you propose in your
email or: elements of a sweeping a program.
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Jackie Cladwell, Vancouver
Chp. 4 Title
The chapter title is currently “Establishing Street Sweeping Programs,†however,
some of the chapter contents may be useful for jurisdictions with existing programs.
Does it make sense to rename the chapter to something like, “Street Sweeping
Program Components� Do you have any other suggestions? We prefer the second
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
David Jackson, Marysville
Chp. 4 Title
Suggested chapter title: Elements of a Street Sweeping Program†to match verbiage
in the Stormwater Management Manual?
Retitled to “Street Sweeping Program Components†per
TAC meeting.
Yes
Amy B. Waterman, ECY
4.1
and maintaining
added
Yes
Abbey Stockwell, ECY
4.1
Should it be clear that the purpose of this guidance is a sweeping program for water
quality/stormwater management? – which can be combined with other sweeping
benefits/purposes and public services (aesthetics of an area, air quality, etc.)
Added to 2nd sentence in first paragraph.
Yes
Traci Pearson, ECY
4.1
[Regarding "waste disposal" in the middle of the paragraph.] If you haven't already, I
suggest checking in with Ecology's Hazardous Waste and Solid Waste Programs
about their waste management and disposal regulations related to street/sweeping
Comment noted. Comment will be moved to chapter 7
Disposing of Street Sweeping Waste.
Yes
Larry Schaffner
4.2
General comment: Given this is a guidance manual, consider whether the
references at the end of the chapter are sufficient. While citations may serve a
specific value in some instances, their frequent use throughout the document might
seem out of place (and can present a distraction) in the context of this guidance
Per TAC discussion, references will be left as is.
Yes
Jessica Schwing, ECY
4.2
[Following end of 2nd sentence]. consider adding in the additional steps in the
program- proper storage and disposal of this waste. We see many "programs" that
fail to account for these steps resulting in a re-release/re distribution of pollutants.
This also results an extreme under-estimation of the cost to implement a sweeping
Added a few words about storage and disposal along with
a reference to chp 7 for more details.
Yes
David Mora, ECY
4.2
[Following end of 3rd sentence]. might clarify : with high efficiency sweepers
Added "when high efficiency sweepers are utilized."
Yes
Xavier Gilbert, ECY
4.2
[Regarding sentence that ends in "…reduce clogging of stormwater infrastructure,
allowing for less frequent maintenance."] Just because less sediment is reaching
the BMP does not mean you can maintain it less. Water is still reaching the BMP
which causes wear and tear and warrants routine maintenance.
Attempting to run a street sweeper in the hopes of cutting corners in other
maintenance areas will do more harm than good.
Revised sentence to provide clarification that sweeping
has the potential to reduce the amount of maintenance
needed and the BMP lifecycle.
Yes
Jessica Schwing, ECY
4.2
[Regarding sentence that ends in "…allowing for less frequent maintenance."] Has
"less frequent maintenance" been demonstrated?
Revised sentence to provide clarification that sweeping
has the potential to reduce the amount of maintenance
Yes
Page 1
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Paul Marrinan
4.3
Add permitting to this list and to the bullet points below. We are required to
maintain a health department permit and test the waste prior to disposal to ensure
that it is not hazardous.
This is correct, added reference to applicable health
department permits; will elaborate more on this in Chapter
Yes
Larry Schaffner
4.3
General thought to consider: Subsections in 4.3 includes language such as “See
Chapter/Section X for further discussion on Yâ€. This makes me wonder how to
efficiently present information (or where best to present it) without being
We will revisit this after the entire manual has been pulled
together and if needed make adjustments in the draft
compiled manual. This may include removing some
Yes
Abbey Stockwell, ECY
4.3
[Regarding second sentence] . I am not sure this is a "but" statement. Recommend:
Jurisdictions with a Phase I or Phase II MS4 Permit are required to conduct street
sweeping. Other considerations such as safety or maintenance concerns and public
perception may also factor into goals.
Changed "but" to "and"
Yes
Abbey Stockwell, ECY
4.3
[End of second to last sentence in first paragraph] . and permit requirements?
added
Yes
Brent Dhoore
4.3.1
This can also include local Health Department permit requirements for handling and
storage which include ongoing permit compliance admin.
added
Yes
Amy B. Waterman, ECY
4.3.1
if they are planning to purchase their own sweeping equipment.
Added a few words about deciding whether or not to
purchase a sweeper.
Yes
Larry Schaffner
4.3.1
In addition, coordinating externally could come into play with effected businesses
and special events.
added
Yes
Zackary Holt
4.3.1
Could we consider something less procedural than an SOP? In my experience,
operators tend to disregard these unless they are super simplified, such as flip
books that are 1-2 pages tops? Or maybe a combination of the two?
Added separate bullet for corollary instructions.
Yes
David Mora, ECY
4.3.1
[Regarding Sweeping locations and routes and Sweeping schedule bullets] . I would
consider the how to of routes and scheduling, waste disposal, and tracking as part
of your SOP
Yes, these aspects will likely be included in SOPs, but we
wanted to call out these items as their own specific
considerations. Designing street sweeping routes will be
included in Chapter 5 – Optimizing Street Sweeping
Practices. Scheduling is discussed later in this chapter.
Waste disposal is discussed in Chapter 7 – Disposing of
Street Waste. Tracking is included in Chapter 6 – Data
Collection and Reporting.
Yes
Xavier Gilbert, ECY
4.3.1
[Regarding Sweeping locations and routes and Sweeping schedule bullets]. What
does this mean? Do they know WHY they are sweeping this area? Do they know what
pollutants are of concerns in each area?
The process behind selecting areas to sweep is explained
in Chapter 3 – Selecting Priority Areas. Pollutants of
concern are discussed in Chapter 2 – Street Sweeping
Yes
Sarah Ponte, ECY
4.3.1
[Regarding Equipment selection and maintenance protocol bullet]. Consider
including/taking into consideration maintenance costs in the budget allocation
This is addressed in chapter 8.
Yes
Rachel Yonemura, ECY
4.3.1
[Regarding Equipment selection and maintenance protocol bullet]. it might be good
to make a quick note about making a plan for if/when a sweeper is down. sometimes
sweepers can be down for a long period of time, but sweeping still needs to be done.
Added consideration and examples of contingency plans
for equipment downtime to Section 4.6.2.
Yes
Jessica Schwing, ECY
4.3.1
[Regarding Waste disposal process bullet]. What about storage and
calculating/estimating your storage needs? Almost all the other factors hinge on
knowing how much material you have to physically move around, store, dump etc.
This will be addressed in chapter 7.
Yes
Xavier Gilbert, ECY
4.3.1
[Regarding Data collection and documentation bullet]. This is a great way to figure
out where your hot spots are and adjust your sweeping intervals accordingly.
Agree. Data collection for use in identifying areas to street
sweep, including hot spots, is included in Chapter 3 –
Yes
Abbey Stockwell, ECY
4.3.2
[Regarding first sentence of the section] . Consider adding GIS staff to this list for
route mapping, updates, route optimization and analysis
Added GIS staff to list.
Yes
Page 2
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Xavier Gilbert, ECY
4.3.2
[Regarding Mechanic bullet]. If you are running an in-house street sweeping
program, this is a key piece of the puzzle to keep things running smoothly.
Comment noted.
Yes
Zackary Holt
4.3.2
[Regarding Crew Leader bullet] . Responsible for data collection as well?
Added "may also be responsible for data collection".
Yes
Abbey Stockwell, ECY
4.3.3
Delete “highâ€, can match PH II language as below
left as is for consistency with other manual sections.
Yes
Larry Schaffner
4.3.3
Seems redundant with the previous sentence.
Sentence deleted.
Yes
Zackary Holt
4.3.3
[Regarding Selbig & Bannerman 2007 citation] . Local? If not, in which area was the
Added study location and climate. Moved section to
Yes
Larry Schaffner
4.3.3
May be less relevant in western WA (at the lower elevations) given the relatively mild Added a sentence about seasonal sweeping for WWA.
Yes
Larry Schaffner
4.3.3
In drawing conclusions, suggest considering the climatic conditions where these
studies took place.
Added and moved section to Section 2.2.3 Removal
Efficiency.
Yes
Larry Schaffner
4.3.3 Table 4-1
Does the study describe what “hot spot areas†entail? If so, suggest adding that
description in a footnote to this table.
Added definition for hotspots. Moved section to Section
2.2.3 Removal Efficiency.
Yes
David Mora, ECY
4.3.3 Table 4-1
[Regarding Arterials info] . Perhaps optimal if your objective is to keep other BMPS
working. If optimal is getting anywhere near the efficiencies hoped for to curb 6PPD-
Waiting to hear back from Ecology regarding a source for
this.
Larry Schaffner
4.3.3
Great information in this section
Comment noted.
Yes
Jessica Schwing, ECY
4.3.3
[Regarding sentence in paragraph before table 4-1] Research studies also provide
recommendations for street sweeping frequency]. to address specific pollutants or
environmental conditions.
Added "to address water quality." Moved section to
Section 2.2.3 Removal Efficiency.
Yes
Larry Schaffner
4.3.3
I understand how this could be the case on arterials, but residential areas too?
In residential areas, street parking maybe will be greater –
Yes
Zackary Holt
4.3.3
In my experience, planning for and implementing no parking sign placement can be
a significant lift (site dependent, neighborhood design, etc.) with notification
requirements, parking alternatives, etc. Is this discussed later?
Addressed in Section 4.8.5 and Section 8.2.4.4
Yes
Amy B. Waterman, ECY
4.3.3
Any more recent ones? Also this section does not address PNW specific situation,
with most of rainfall in the fall and winter. This was a major consideration in Permit
requirements to sweep before the onset of these rain events.
We did not find more recent studies, but we did find a
resource relevant to WWA climate. Added a sentence
about seasonal sweeping for WWA. Moved section to
Section 2.2.3 Removal Efficiency.
Yes
Larry Schaffner
4.3.3 – Figure 4-1
Did the study involve similar climatic conditions as found in eastern and/or western WAdded context of study location and climate. Moved
section to Section 2.2.3 Removal Efficiency.
Yes
David Jackson, Marysville
4.3.4
[RE: Have any jurisdictions scheduled street sweeping around needle drop? If so,
can you provide what time of year is best for different species of conifers?]Our sweeping is based on high traffiic areas and annual coverage.
Comment Noted.
Yes
Larry Schaffner
4.3.4
Is this intended to imply utilizing an in-house mechanic? If not, is seems redundant
with utilizing a private contractor.
Revised sentence to provide clarification.
Yes
Larry Schaffner
4.3.4
The relevance of this portion of the sentence isn’t clear to me.
Deleted portion of sentence.
Yes
Zackary Holt
4.3.4
Debris that has accumulated on the vehicle? Roadside debris or CB debris such as
leaves, etc.? Or is this referring to the process of sweeping?
Refers to cleaning debris out of sweepers after each
sweeping event. Change to “vehicle cleaning†to clarify.
Yes
Larry Schaffner
4.3.4
Does this refer to leaks on the pavement or reducing the likelihood of leaks from the
sweeper?
Added "from the sweeper".
Yes
Zackary Holt
4.3.5
Does this include decanting processes? It sounds like only solids are addressed.
WWA has a lot of juicy street waste that in many instances requires some form of
Revised section to address TAC comments which includes
reference to decanting. More details are provided in chp 7.
Yes
Paul Marrinan
4.3.5
Maybe include potential permitting language in the disposal section instead of
creating a distinct section.
Revised section to address TAC comments.
Yes
Page 3
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Amy B. Waterman, ECY
4.3.5
I know there will be more detail on Chapter 7, but this section should acknowledge
the fact that there are liquid and solid wastes from street cleaning. The MS4 Permits
(Appendix 6) have requirements for street waste liquids, which is Ecology's
jurisdiction. Street waste solid disposal is permitted by the County Health
Revised section to address TAC comments which includes
reference to decanting and county health department
permits.
Yes
Abbey Stockwell, ECY
4.3.6
[Regarding 3rd sentence in the first paragraph]. Should this include a discussion on
technology for sweepers that can do some of this documentation?
Add more text with reference to Chapter 6 which includes
details on using sweeper technology for documentation.
Yes
Amy B. Waterman, ECY
4.3.6
[Regarding Bullet: Other documentation requirements: Street sweeping training
performed and staff trained] . including training to prevent or minimize impacts to
water quality.
Section modified and the bullet commented on is not
longer in this section. Comment moved to chapter 6.
Yes
Abbey Stockwell, ECY
4.3.6
Some items in the…
