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upper Al system) that are predicted by the model for the larger contributing area under existing <br />(2006) conditions, and exacerbated by future development. <br />Topic; Pollutant Estimates <br />Pollutant load estimates are not based upon basin - specific water quality data. Question <br />use of TSS as an indicator. Question assumption regarding contribution of runoff from <br />decommissioned UICs. [SC -101, [RR -111 <br />Although there is limited data on water quality in the Basin, the pollutant load estimates point to <br />the need to address expected increases in pollutants from added impervious surfaces, and provide <br />a means by which pollutant estimates can be compared between basins and contrasted between <br />existing and future build -out conditions. Estimating pollutant loads helps in identifying locations <br />for water quality capital projects. For example, RRSC -2, Water Quality Facilities for High <br />Source Areas, includes specific high pollutant source locations for water quality retrofit facilities. <br />The pollutant load estimates also support the implementation of Stormwater Development <br />Standards and support continuation of the other complimentary best management practices <br />conducted in the City and County's stormwater programs. Estimating pollutant loads from <br />runoff being surfaced by decommissioning drywells supports the strategy for decommissioning <br />drywells via rain gardens or pipe connections with pre- treatment, so as not to adversely affect <br />downstream surface water quality. <br />With regards to the use of total suspended solids (TSS) as an indicator of pollutant, TSS was <br />used in the basin plans as a surrogate for the suite of pollutants typically associated with <br />stormwater (specifically, sediment, nutrients, heavy metals). This is a common approach, <br />utilized by other large municipalities in the state of Oregon. The TSS amounts are <br />approximations based upon pollutant loading data used by the Phase I municipalities in Oregon. <br />Estimates assume no water quality BMPs for future development. Estimates assume all <br />runoff from decommissioned drywells will be transferred untreated to surface waters. <br />[RR -101, [SC -111 <br />Agree. The pollutant load estimates are based upon pollutant loading concentrations used by <br />Phase I municipalities in Oregon, and the comment is correct in that the loadings assume no <br />water quality BMPs. The pollutant load estimates were generated for illustrative and <br />comparative purposes (e.g. identifying high pollutant source areas within a basin, comparing <br />basin loads), and staff thought it important to use the same approach as for the other stormwater <br />basins completed in 2002. <br />The City is collaborating with other Phase I municipalities and professionals across the country <br />to compile and utilize effectiveness data for stormwater management facilities so as to better <br />estimate pollutant loadings from urban areas utilizing these facilities. <br />RR -SC Stormwater Basin Plan Comments Pg.16 of 17 <br />