U.S. EPA, Region 10

1200 Sixth Avenue, Suite 155

Seattle, WA 98101


Dear Misha Vakoc, 



Situated in the Seattle metropolitan area, Naval Base Kitsap’s Municipal Separate Storm Sewer Systems (MS4s) discharge into several waterways within the Puget Sound.  Many of these waterways hold recreational value and some of them support salmonid and endangered Killer Whale populations. A stormwater permit is crucial to regulating the volume of pollutants and bacteria entering these waterways. 



  1. One of the federal requirements of the Clean Water Act is to require controls necessary to reduce pollutants in municipal stormwater discharges.  Effective management practices would be: 1) bioswales and bioretention ponds placed downhill from large impervious areas and roadways and 2) rain gardens constructed adjacent residential areas.  The construction of community rain gardens could be a particularly effective way to garner community/volunteer engagement. Could these management practices be considered Early Action Projects (EAPs) referenced on the permit fact sheet?  


  1. Page 2 the schedule of submissions include specific project plans and testing plans. Since the specific details will be submitted at a later date, this prevents the public from commenting on specific details. That appears to defeat the public noticing and commenting process and appears to be a piecemealing approach. Please explain how the public noticing requirements are being met with that approach. Shouldn't the final plans also be presented for public review and commenting? Alternatively, can you provide notice and solicit comments to a list of stakeholders who might have input into the final plans?


  1. Page 6 section 3.1 first sentence states that "it is presumed that the permittee is not causing or contributing to an exceedance above the State of Washington's water quality standards." That is a presumption that should not be made without a baseline study. For example, since the presumption covers groundwater in addition to stormwater, how can the presumption be made that all groundwater quality criteria have been met when such things as spills, underground storage tanks, areas of concern are included in the presumption? Therefore, please require a baseline study to be prepared which adequately supports the stated presumption. 


  1. On page 29 of the fact sheet, it is stated that the Navy has not yet chosen which of two compliance monitoring strategy options it would use for monitoring stormwater.  The EPA suggests option 2 (in negotiable terms), Stormwater Action Management (SAM) largely because it is the approach used throughout the Puget Sound region so it would be the more consistent option.  The Navy has addressed uncertainty regarding funding needed to commit to this option so the other approach would be that they determine their own method of compliance monitoring. It is advisable that if the Navy is unable to commit to SAM, then perhaps they would do well to use the framework of SAM as a reference for compliance monitoring, so as to remain as consistent as possible with monitoring practices throughout the region. 


Please direct all responses to these comments to the following email address: This email address is being protected from spambots. You need JavaScript enabled to view it.    




Matthew Coughlin (Associate in Maryland)

Environmental Reviewer 

Environmental Review Inc.

1792 Rogers AvenueSan Jose, California  95112