Long Term Strategy for WQ Standards

1. Long Term Strategy for WQ Standards • Ecology believes the Triennial Review as traditionally conducted isn’t working well. • We want to have a public discussion about the WQS issues the department chooses to invest in. • Ecology is considering a new approach to selecting WQS issues for the agency to work on.

2. The Traditional TR Approach • Ecology picks topics for WQS revision and tries to complete them as part of a Triennial Review. • This results in people not understanding why we haven’t picked their issues for rule revision. • Sets up the expectation that we’ll complete the entire rule revision within a three year period. • It’s nearly impossible for us to meaningfully involve the public and change a regulation in only 3 years.

3. A New Approach to Triennial Reviews • TR workshops will be held every three years • But they would not be used to discuss proposed rule changes. • They would be to have an open public discussion on: • What Ecology is working on now (topics and status); • Emerging EPA and legislative demands; and • To involve the public in prioritizing issues for rule change as well as for training and guidance.

4. A New Approach - Continued • Public processes for specific topics would be set based on complexity and relative priority. • Allows timely completion of the TR requirement; • Allows better public discussion on WQS issues; • Discrete issues would not be tied to larger ones. • Example: A UAA fine tuning designated uses for a single water body would not need to wait until statewide rules revising toxics etc. have made it through.

5. A Method for Prioritizing Issues • As part of the new approach, Ecology is developing a method to assess the relative priority of issues. • Each potential issue would be evaluated against a set of factors, and given a numeric score. • The scores would not be used exclusively to determine what Ecology will work on: • Help Ecology select and prioritize its work; • Make the decision process more transparent; • Enhance the quality of public involvement.

6. Issues Would be Evaluated In Categories Such As: Ranked from 1(low) to 5(high) • Environmental Benefits • Site level benefit (how important when applied?) • Geographic extent (only a few streams?) • Opportunity for control (link to regulated actions?) • Administrative Benefits • Technical ease (is the data available?) • Stakeholder support (will it be widely challenged?) • Compliance Benefits • Reduces compliance costs (is it less expensive to comply?) • Reduces complexity (less work to implement?) • Geographic extent of benefit (most dischargers benefit?) • Level of Federal Support (is mandated or a completed criteria?) • Is Rulemaking Necessary? (or is guidance appropriate?)

7. Ecology Wants Your Feedback • Is this idea worth pursuing further ? • What do you think about holding non-rulemaking workshops to involve the public? • Do you like including guidance and training? • Is it good to put issues on separate timelines? • Are there specific problems to consider? • Can you suggest improvements? • Would you like to help refine the approach?