The Spokane River Regional Toxics Task Force (SRRTTF) is in the process of updating its Memorandum of Agreement (MOA). This update occurs in part due to new parties signing on to the SRRTTF MOA in the near future, but also due to suggested changes (identified by Task Force members and advisors) that address evolving needs. The process by which the MOA will be revised was discussed at the October 22nd, 2014 Task Force meeting and is as follows:
- Initial comment period: all comments and suggested changes to the “Track Changes” version of the MOA that is posted below, to be sent to Chris Page of the Ruckelshaus Center (firstname.lastname@example.org) no later than 10 am on November 17th, 2014
- MOA Work Group formation: one (or, if necessary, two) representative(s) to serve on an MOA Work Group will be identified by each of the following: Idaho NPDES permittees, Washington NPDES permittees, NGO’s/Environmental Groups, EPA, Ecology, IDEQ, Health Agencies, Tribes by (or at) the November 17th Task Force meeting
- The MOA Work Group will incorporate changes to the MOA and bring to the full Task Force for approval. (Dates TBD.)
- Revised MOA signatory review period. New signatories will run the MOA through their legal departments and decision makers and send any needed changes back to the full Task Force for consideration. This may require another work effort by the MOA Work Group before the document is finalized and acceptable to all parties for signing. (Dates TBD.)
– SRRTTF-MOA_EPA_City-Spokane_Spokane-Co _Riverkeeper comments November 2014
– SRRTTF-MOA_Track Changes Version- May 2014
Letters to Tribes
– Chairman Boyd 11.14.14
– Chairman Allan 11.14.14
– Chairman Peone 11.14.14
– Chairman Nenema 11.14.14
As EPA draws nearer to finalizing the NPDES permits for the Idaho dischargers, the SRRTTF has indicated it will work to agree on any changes to its Memorandum of Agreement (MOA) needed to reflect the addition of EPA and the Idaho parties to the Task Force. The SRRTTF may also wish to edit the wording or adjust content of the MOA, e.g. to update it chronologically or revise its protocols.
In 2013, EPA reviewed the January 2012 signed MOA and provided comments to the SRRTTF via the Department of Ecology. The SRRTTF asked (at its January 2014 meeting) that the MOA with EPA’s requested edits be distributed for Task Force member consideration. After legal review by Task Force entities, the MOA (with EPA’s comments) was distributed to SRRTTF members for additional suggested edits. This was done considerably in advance of the finalization of the Idaho discharger permits in order to identify potential issues or conflicts that might need additional conversations to reconcile, and to allow time for that process to unfold. A representative from the Idaho discharger community has indicated that they would like to wait until after the Idaho permits are finalized to provide comments on the MOA.
At the April, 2014 SRRTTF meeting it was requested that the MOA with EPA’s comments and suggested edits from two Task Force member entities (City of Spokane and Spokane County) be distributed, along with this memo explaining the process. The MOA below shows comments from those three parties as of May 2014, and awaits the finalization of the Idaho permits and subsequent consideration by the full Task Force including prospective member entities.
– SRRTTF MOA with EPA, City of Spokane, and Spokane County Comments May 2014
Task Force members, prospective member entities (including Idaho parties), and active participants are invited to submit their any comments and requested edits or adjustments to the current Memorandum of Agreement (MOA) to the Ruckelshaus Center by April 9 at 5pm.
– SRRTTF MOA for Comments (word doc)
On December 14, 2011, EPA submitted comments to the Memorandum of Agreement.
These were received after the MOA was finalized and not incorporated into the document.
EPA will be reviewing these comments for relevancy and sending an updated version for discussion at the January 22, 2014 Task Force meeting.
Many of the comments will be revised because they are no longer relevant.
Conditions 10 and 11 on page 2 of 20 of the MOA will be relevant:
SRRTTF MOA DRAFT dated 11-09-2011 Annotated
EPA Comments on Spokane MOA
Spokane River Regional Task Force
Administrative Work Group Meeting
Date: August 8, 2012
Time: 10:00 a.m. to 12:00 pm
Location: Washington Department of Ecology
N. 4601 Monroe St.
Spokane, WA 99205
Click here for a map.
SRRTTF Administrative Work Group Meeting Notes
SRRTTF Administrative Work Group Meeting Draft Agenda
Comments Received from Kaiser Aluminum
Form of Electronic Notice Consent
Conflict of Interest Policy
Comments Received from Spokane County:
Microsoft Office Outlook – Memo Style-20120807163433
Comments Received from Ecology and WA Department of Health:
Microsoft Office Outlook – Memo Style-20120807151702
Agreement signed by participating Spokane River Regional Toxics Task Force members.
Spokane River Regional Toxics Task Force Final Memorandum of Agreement