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Monitoring Section

Monitoring Section. Satisfy federal law & BayKeeper’s prevailing petition - include type, intervals & frequency to yield sufficient data Level playing field - current permits all different Increase comparability of data - better over-all interpretation of data; more powerful data

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Monitoring Section

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  1. Monitoring Section • Satisfy federal law & BayKeeper’s prevailing petition - include type, intervals & frequency to yield sufficient data • Level playing field - current permits all different • Increase comparability of data - better over-all interpretation of data; more powerful data - SB 1070: Board must post water quality monitoring results • Capture economies of scale - option to do all monitoring on regional basis

  2. Comment: Cost “MRP proposes a very expensive monitoring and assessment program” • Comparable to one Program’s current monitoring, with additional TMDL monitoring • Provide option for cost-sharing efficiency

  3. Comment: Prioritize / Use BASMAA Draft Permit BASMAA Draft similar except: • Follow-up not required when “basic” monitoring detects problems • Long-term monitoring done by Board • No monitoring projects • TMDL monitoring in TMDL section • Watershed assessments in separate section

  4. Comment from NRDC The monitoring program must allow each permittee, the RWQCB, and the public to determine whether each permittee is causing / contributing to a violation of an applicable water quality standard. It does not appear that the proposed program would meet this goal and requirement.

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