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File #: Pres 22-27    Version: 1 Name: Suncor Water Quality - Permit comment letter
Type: Presentation Status: Agenda Ready
File created: 1/10/2022 In control: City Council
On agenda: 1/24/2022 Final action:
Title: Suncor Water Quality Permit Comment Letter
Attachments: 1. Council Communication, 2. Suncor Letter - Draft, 3. Suncor Permit Outline, 4. Suncor Permit Review
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Suncor Water Quality Permit Comment Letter

Summary & Background
The State of Colorado issues permits for two water quality laws, the Federal Clean Water Act and the Colorado Water Control Act. Any facility that discharges wastewater or pollutants to surface waters must obtain a water quality discharge permit from the State, sometimes referred to as a discharge permit. These permits last for five years but can be continued until they can be renewed. The permit is an enforceable mechanism that limits the amount of used water from a facility, including treated groundwater, and stormwater.

As it relates to Suncor, the water quality discharge permit regulates the water that Suncor can put into Sand Creek. It also places conditions of many types on Suncor including those related to monitoring, spill prevention, maintenance failures and transparency.

Suncor had two separate permits issued in 2012. One permit pertained to wastewater and one to stormwater discharges. This current renewal process combines the two permits into one and enacts stricter regulations. It will incorporate new water quality standards, policies, and lessons learned.

The Colorado Department of Public Health and Environment (CDPHE) is asking the public to comment on the draft permit and has established a public comment period that will allow written comments to be submitted until February 10, 2022.

The City is working with our Environmental Consultants, Lotus Sustainability and Engineering and Pinyon Environmental, to draft a letter to CDPHE commenting on the draft permit. The letter will lobby for new and stricter requirements in the permit to protect Sand Creek and downstream waters and will advocate for the health of the residents of Commerce City.

The comment letter will summarize the differences between the existing and draft permits and will provide comments on the changes. Special note will be given to the impact discharges from the facility, and what effect they...

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