D3.1 Chapter 3 Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Larry Schaffner, Thurston County
3.1
"Since this is already covered in Chapter 1, is it necessary here too?
Alternatively, you might consider removing that section from Chapter 1
and covered the applicable in each of the chapters."
Included applicable MS4 Permit requirements in Chapter 3 for readers
who do not read every chapter of the guidance manual and to prevent
readers from have to flip back to Chapter 1 to review requirements.
Added reference to Appendix 1-A.
Amy B. Waterman, Ecology
3.1
"Called "high priority areas" in Phase I"
Received email from Ecology on 10/8/2024 with direction to use "priority
areas".
Abbey Stockwell, Ecology
3.6
"consider including this list here"
Reorganized chapter structure so Section 3.6 appears before Section 3.5.
Added text to Section 3.2.1 explaining areas of concern are not required
by the MS4 Permits.
Amy B. Waterman, Ecology
3.2
"We used the language "meet any of the following criteria" to make it
clear this wasn't an "and" in the sense that areas had to meet both of
these criteria."
Revised text to "Priority areas, as described by the MS4 Permits, include
curbed municipal streets that discharge to MS4 outfalls meeting any of
the following criteria: high-traffic roadways such as arterials or
collectors; and streets serving commercial or industrial land uses."
Larry Schaffner, Thurston County
3.4
"I suggest separating out data recommendations for assessing curbed
municipal streets discharging to outfalls that meet the high traffic streets
and streets serving commercial or industrial land use area criteria. This
would constitute the minimum to meet Permit expectations.
Presenting other data considerations would come into play should the
jurisdiction op to fold in additional criteria in setting priorities. Perhaps
these could be introduced in the “Other Considerations for Selecting
Priority Areas for Street Sweeping” section."
Separated the data recommendations into two lists: one for meeting MS4
Permit requirements and the other for additional considerations/areas of
concern.
Larry Schaffner, Thurston County
3.4
"If in compliance with the Permit, jurisdictions should have mapped the
associated drainage areas for tributary conveyances to all known outfalls
with a 24-inch nominal diameter or larger, or an equivalent cross-
sectional area for non-pipe systems. "
This is a new requirement for the EWA Permit. Propose no change.
Larry Schaffner, Thurston County
3.4
"This would be data associated with an additional consideration."
Receiving water data is necessary for MS4 Permit requirements. Propose
no change.
Larry Schaffner, Thurston County
3.4
"These would data associated with additional considerations."
Included data under additional considerations list.
Larry Schaffner, Thurston County
3.4
"Note: At least one know error exists in a figure in this guidance
document. I believe it has been brought to Ecology’s attention."
Noted. Thank you.
Abbey Stockwell, Ecology
3.4
"Be clear that this info is associated with the additional considerations
listed above "areas of concern" which may be beyond permit
requirements for priority areas"
Separated the data recommendations into two lists: one for meeting MS4
Permit requirements and the other for additional considerations/areas of
concern.
Amy B. Waterman, Ecology
3.4
"Seems like it would be helpful to note permit-required data."
Added "(Required by MS4 Permits)" to the mapping items required by the
Phase I and the EWA and WWA Phase II Permits.
Amy B. Waterman, Ecology
3.4
"Note that this mapping guidance will be updated."
Noted. Thank you.
Larry Schaffner, Thurston County
3.5
"Suggest using this subsection for the content appearing Section 3.6 –
Other Considerations for Selecting Priority Areas for Street Sweeping. "
Reorganized chapter structure so Section 3.6 appears before Section 3.5.
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D3.1 Chapter 3 Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Larry Schaffner, Thurston County
3.6
"As suggested above, I suggest moving this in the spot currently occupied
by subsection 3.5.4 as a means to improve the organization flow of the
information and process presented."
Reorganized chapter structure so Section 3.6 appears before Section 3.5.
Amy B. Waterman, Ecology
3.6.5
"Commercial land uses already covered in earlier section."
Deleted Central Business Districts section.
Larry Schaffner, Thurston County
3.3.1
"To improve readability, rather than integrating references into
parentheticals, consider using an endnote approach instead."
Revised citation style to IEEE (in-text citations, numbered in square
brackets, which refer to the full citation listed in the references at the end
of the chapter).
Amy B. Waterman, Ecology
3.3.1.1
"We considered using AADT or ADT (actually went out with in Draft), but
got push back on availability."
We are providing this guidance as one resource Permittees can use to
identify high-traffic roadways if the data is available.
Amy B. Waterman, Ecology
3.3.1.1
"We found, in looking into this, that many municipalities have their own
classifications and definitions, which is why we left it open to how
Permittee's define. In addition to WSDOT, which is mentioned later in this
chapter, Seattle's classification may be a local example to share."
Added City of Seattle's street classifications as an example of detailed
street classifications.
Larry Schaffner, Thurston County
3.3.1.2
"Should this be “adjacent land use”? “Connecting land use”?"
Revised text to "connecting land use".
Larry Schaffner, Thurston County
3.3.1.2
"Are their also studies available that collected samples to evaluate runoff
from adjacent land uses?"
Yes, this information is available and will be incorporated into Chapter 2.
Added a reference to Chapter 2 in this section.
Larry Schaffner, Thurston County
3.3.1.2
"Does the literature report anything regarding bacteria?"
Added sources of bacteria to Table 3-2.
Abbey Stockwell, Ecology
3.3.1.2
"the permit doesn't require residential areas – unless they are associated
with high traffic streets"
Section 3.3 describes information we found in available literature, which
includes information about sweeping residential streets. This section
does not relate to Permit requirements. Permittees may consider
sweeping some residential streets, such as tree-lined streets, as part of
the their program, going above and beyond Permit requirements.
Amy B. Waterman, Ecology
3.3.1.2
"Seems like Ecology's S8 Data Characterization Study (2015) is a useful
reference here as well:
https://apps.ecology.wa.gov/publications/SummaryPages/1503001.html
Thank you for providing this resource. We plan to incorporate this
resource into Chapter 2.
Larry Schaffner, Thurston County
3.3.1.3
"Suggest integrating this subsection’s content into Section 3.6."
This section describes information found during the literature search, so
it belongs in this section. Reorganized chapter structure so Section 6.3
appears after applicable Permit requirements and before Section 3.5.
Amy B. Waterman, Ecology
3.3.1.3
"Address how this would fit with Permit required priority areas."
Section 3.3 describes information we found in available literature
regarding street sweeping. This section does not directly relate to Permit
requirements. Some Permittees may choose to include other areas of
concern as part of their street sweeping program to meet specific
jurisdictional needs/goals.
Larry Schaffner, Thurston County
3.5.1
"Is this in reference to the March 31, 2028 deadline to map MS4 tributary
basins to outfalls with a 24” nominal diameter or larger, or an equivalent
cross-sectional area for no-pipe systems that have SW treatment and
flow control BMPs/facilities owned or operated by the Permittee
[S4.b.iii.]? If so, should this matter since the Permit already requires
ongoing mapping of their associated drainage areas [i.e. S4.C.4.a.v.(b)]?
In other words, doesn’t MS4 tributary basins = associated drainage areas
This is a new requirement for the EWA Permit. Revised text to specify EWA
Permit.
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D3.1 Chapter 3 Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Larry Schaffner, Thurston County
3.5.1
"Impervious surface cover???"
Revised text to "impervious surface cover".
Abbey Stockwell, Ecology
3.5.1
"it is unclear which mapping requirement is being referred to here.
consider striking"
Revised text to “Mapping tributary conveyances to outfalls…”. This
section was also revised to indicate this is only a new mapping
requirement in the EWA Permit.
Amy B. Waterman, Ecology
3.5.1
"? list of or link to?"
Revised text to “with resources provided at the end of this section.”
Abbey Stockwell, Ecology
3.5.1
"recommend removing reference to "point of compliance" in figure – this
is not a term used with the muni permit"
We hope to replace this figure with an example map from a Permittee.
Larry Schaffner, Thurston County
3.5.2
"The link goes to an FHWA document."
Revised text to "FHWA".
Christian Nilsen, GeoSyntec
3.1
"Suggest a brief statement on why this step is important. Something brief,
like 'to target areas with the greatest potential for improvement
permittees should identify priority areas for sweeping.""
Added "This information can assist Permittees with targeting areas with
the greatest potential for water quality improvement."
Larry Schaffner, Thurston County
3.5.3
"Are there any Permittees that don’t have a zoning maps?"
Most jurisdictions probably have zoning maps, but we would like to
provide resources in case they may be useful.
Larry Schaffner, Thurston County
3.5.4
"As mentioned above, I suggest renaming this subsection and using this
spot for the information presented in Section 3.6."
Reorganized chapter structure so Section 3.6 appears before Section 3.5.
Larry Schaffner, Thurston County
3.5.4
"A reasonable interpretation would be that the Permit’s two criteria in
S5.4.e.i. (of the WWA Phase II permit) define the baseline for this
expectation. Anything else would be additional considerations."
Deleted the first two sentences of the original paragraph.
Larry Schaffner, Thurston County
3.5.4
"As mentioned above, it would be helpful to integrated Section 3.3.1.3
content into Section 3.6."
Reorganized chapter structure so Section 3.6 appears before Section 3.5.
Zack Holt, Bremerton WA
3.5.4
"On page 3-9 section 3.5.4. consider including the National Wetland
Inventory maps and the IPaC wildlife planning maps from USFWS, the
WDFW PHS dataset, WDFW’s fish passage inventory maps, Ecology’s
Washington State Coastal Atlas, Local jurisdiction zoning maps (for
commercial areas, etc.) and DNR’s NHD database for critical areas
information, environmentally sensitive areas and waterbodies."
Added the suggested resources to Section 3.5.4.
Abbey Stockwell, Ecology
3.5.4
"To clarify, this does not mean we expect Permittees to identify other
areas than what is required for priority areas. This section should be clear
that these are other areas for consideration – not required by permit."
Deleted the first two sentences of the original paragraph.
Amy B. Waterman, Ecology
3.5.4
"Again, this is not in the permit priority area designation."
Yes, areas of concern have been described as optional.
Page 3
D3.1 Chapter 3 Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Larry Schaffner, Thurston County
3.5.3
"Our senior land use planner suggests a couple of methods.
Method 1 uses zoning and future land use designations. The caveat
being, not all the parcels may be currently developed and used of
commercial or industrial land uses, and there may be industrial of
commercial land uses elsewhere not captured by this approach.
Method 2 uses the assessor’s most recent parcel data. The caveat being,
while this reflects current use of the property, it doesn’t capture areas
zoned for commercial or industrial uses into the future."
Added, "Municipalities may also use assessor parcel data to identify
zoning. Since zoning can change, it is recommended that the jurisdictions
consult with their planning department to identify if and where future
zoning and land use designation changes may occur."
Larry Schaffner, Thurston County
3.6.1
"Could also consider tree-lined streets as its own category."
Revised "these areas" to "tree-lined" streets.
Christian Nilsen, GeoSyntec
3.6.3
"If including areas where construction activity is important, there should
be some mention of the construction general permit. Outline
requirements of construction permittees vs municipal permittees. "
No revisions made as the construction general permit is outside the
scope of this manual.
Larry Schaffner, Thurston County
3.5.5
"Might be more helpful to depict this using the relevant GIS coverages
described above."
We will work on updating this figure for the draft manual either with a
jurisdiction's figure or one we create.
Larry Schaffner, Thurston County
3.6.6
"Is doesn’t seem like the correct section reference?"
Revised to Section 3.3.1.3.
Shelly Basketfield, SPU
overall
"please revise pine needles with conifer needles."
Revised all instances of "pine needles" to "conifer needles".
Don McQuilliams, Bellevue WA
overall
"Good morning Laurie, I have review chapters 1 and 3 and both are well
done. I didn’t have any specific comments or changes that jumped out at
me at first review. Seems pretty straight forward."
Thank you for your review.
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