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