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Eastern Washington Early Comments Workgroup

Introduction

The Eastern Washington Early Comment Workgroup, also called the EWA Workgroup, provides a transparent process for Eastern Washington stormwater stakeholders to identify, discuss, and develop suggested revisions to the Eastern Washington Phase II Municipal Stormwater General Permit.

The workgroup is open to:

  • Municipalities
  • State agencies
  • Non-governmental organizations
  • Private sector entities
  • Other stormwater stakeholders in Eastern Washington

The workgroup will cooperatively develop suggested revisions to the Phase II permit. These suggestions will be submitted to the Washington State Department of Ecology as early comments during the 2029 Phase II permit reissuance process.

The EWA Workgroup will begin meeting in July 2026. Suggested permit revisions are expected to be submitted to Ecology as early comments by February 1, 2027.

Ground Rules

  • Aim to achieve consensus among Members.
  • If consensus cannot be reached, include a range of perspectives.
  • Maintain a collaborative and transparent process.

Workgroup Process 

Flowchart showing the EWA Workgroup early comment development process: members brainstorm comment topics, volunteers lead topic subgroups, volunteers join subgroup teams, and subgroups develop draft permit comments.
Figure 1. EWA Workgroup process for developing permit revision suggestions.

The early comment process begins with workgroup members creating a comprehensive list of proposed comment topics related to specific permit conditions.

Workgroup members may volunteer to lead Topic Groups. Each Topic Group will develop suggested permit revisions for a selected topic.

Suggested revisions developed by Topic Groups will be:

  1. Reviewed by the full EWA Workgroup.
  2. Revised, if needed.
  3. Finalized through a consensus-based process.
  4. Submitted to Ecology as early comments on the draft 2029 Phase II permit.

Roles Within the Workgroup 

The EWA Workgroup includes four main roles:

  • Members
  • Leads
  • Participants
  • Coordinators

Members 

Members attend workgroup meetings, propose comment topics, and review draft suggested revisions as they are developed.

Members may volunteer to serve as Topic Group Leads or Participants, but they are not required to do so.

Members will be identified in the early comments submitted to Ecology.

Leads 

Leads are Members who volunteer to coordinate and guide a Topic Group as it develops suggested revisions for a specific comment topic.

Participants

Participants are Members who volunteer to contribute to a Topic Group and help develop suggested revisions for a specific comment topic. 

Coordinators 

Coordinators are Washington Stormwater Center staff who support the EWA Workgroup by:

  • Coordinating meetings
  • Communicating information to Members
  • Serving as a liaison between Ecology and the EWA Workgroup

Topic Groups 

The EWA Workgroup may divide into Topic Groups to develop suggested permit revisions for specific comment topics.

Each Topic Group includes:

  • One or more Leads
  • Participants who choose to contribute to that topic

Topic Groups are formed when a Member volunteers to lead a proposed topic. Participants then self-assign to Topic Groups based on their interest and expertise.

Topic Groups meet independently on a schedule agreed to by the Lead and Participants.

Template Requirements

Topic Groups will use the Early Comment Document Template when preparing suggested revisions.

Topic Groups will incorporate feedback from Members and prepare final documents using the template.

Download the 2026 Topic Group Template (DOCX)

Diagram showing the EWA Workgroup structure. The Ad Hoc Workgroup consists of multiple topic-based subgroups. Each subgroup includes one Lead and several Members who work together to develop permit revision suggestions for a specific topic.
Figure 2. EWA Workgroup organizational structure. The full workgroup is organized into topic-based subgroups. Each subgroup is led by a volunteer Lead and includes Members who collaborate to develop suggested revisions for specific permit topics.

Role Tasks 

Member Tasks 

Members will:

  • Help create a comprehensive list of suggested comment topics, including relevant permit section citations.
  • Review suggested revisions developed by Topic Groups.
  • Provide input on draft suggested revisions, when appropriate.
  • Approve suggested revisions for submission as early comments, when appropriate.

Topic Group Lead and Participant Tasks 

Topic Group Leads and Participants will:

  • Review the technical or policy conditions of the relevant permit section.
  • Develop meaningful suggested revisions for the Phase II permit.
  • Aim to develop suggestions that are likely to achieve consensus among workgroup Members.
  • Provide regular status updates to the full workgroup.
  • Communicate the intent and approach of the early comment documents being developed.
  • Consider feedback from workgroup Members and incorporate it into draft documents, when applicable.
  • Prepare final early comment documents using the workgroup template.
  • Provide final documents to the Coordinator.

Coordinator Tasks 

Coordinators will:

  • Schedule EWA Workgroup meetings.
  • Develop meeting agendas.
  • Take meeting notes.
  • Share meeting summaries with workgroup Members, as needed.
  • Help workgroup Members understand Ecology’s early comment process.
  • Communicate relevant discussions with Ecology, as appropriate.
  • Poll workgroup Members when there is dissent to document the range of perspectives.
  • Document Member consensus on final early comment documents.
  • Compile, without editing, the final early comment documents into a single body of work.

Schedule 

The EWA Workgroup and Topic Groups will meet regularly so Members stay informed about the development of suggested revisions.

EWA Workgroup Schedule 

The EWA Workgroup will meet monthly to receive progress updates from each Topic Group and provide feedback, as needed.

An EWA Workgroup contact will submit the compiled suggestions to Ecology as a single body of work by February 1, 2027.

EWA Workgroup Meeting Schedule 

Date Meeting Type
June 29, 2026 Plenary Meeting
July 9, 2026 Topic Group Meeting
August 12, 2026 Progress Update Meeting
September 9, 2026 Progress Update Meeting
October 14, 2026 Progress Update Meeting
November 11, 2026 Progress Update Meeting
November 25, 2026 Early Comment Review Meeting
December 9, 2026 Early Comment Review Meeting
January 13, 2027 Finalize Early Comments
February 1, 2027 Submit Early Comments to Ecology

Topic Group Schedule 

Topic Groups will meet on schedules determined by each group.

Topic Group suggestions should be available to the EWA Workgroup by December 2026.

Visual timeline illustrating the EWA Workgroup schedule and major milestones from June 2026 through February 2027. Detailed meeting dates and milestones are provided in the schedule table above.

Previous Early Comments 

In 2022, twenty-seven government entities and one non-governmental organization participated in the Eastern Washington Ad Hoc Workgroup. The workgroup developed six suggested permit revisions for the 2024 Phase II permit reissuance.

The suggested revisions were submitted to Ecology as early comments.

View the 2024 Phase II early comments

2024 Phase II Permit Early Comment Topics 

The 2024 early comments addressed the following topics:

  • Conditions to perform effectiveness studies
  • Redundancies between Phase II Municipal and Construction Stormwater Permits
  • Education and outreach requirements
  • Required procedure implementation
  • Scope of coverage for MS4 and UIC programs
  • Implementation of a business inspection program

Workgroup Contacts 

Trey George 

City of Spokane
[email protected]

Cory Olson 

City of Spokane Valley
[email protected]

Laurie Larson-Pugh 

Washington Stormwater Center
[email protected]

For information about EWA Workgroup meetings, please contact Laurie Larson-Pugh.


Department of Ecology 

The EWA Workgroup acknowledges that:

  1. Permit revision suggestions submitted to Ecology as early comments are advisory and do not supersede any Ecology process.
  2. Ecology is the legally responsible entity for revising and reissuing the Phase II permit.
  3. Regulatory processes must be followed during permit reissuance, including the submission of early comments.