Document ZnQbDMdw00J25MjVMEqe5RmNV

To: From: Sent: Subject: Jackson, RyanQackson.ryan@epa.gov] Green Guy Media Wed 9/13/2017 2:02:17 PM u Green Guy Media Newsletter u Chattahoochee Riverkeeper Climate Change Conference 17cv1906 Sierra Club v. EPA ED_O01523_00000352-00001 17cv1906 Sierra Club v. EPA ED_001523_00000352-00002 To: Jackson, Ryan[jackson.ryan@epa.gov] From: Brittingham, Charles II (WAS-CAS) Sent: Fri 9/8/2017 2:00:05 AM Subject: Fwd: Hurricane response Coleman Ltr 9.1.17 PDF.pdf 1.htm FYI -- Bech Bruun from the Texas Water Development Board is meeting with Lee Forsgren on Monday the 11th at 3:45pm to talk about the contents of the attached letter. IF you or Administrator Pruitt can pop into the meeting for a quick hello, I'm sure Bech ("Beck") and Governor Abbott would appreciate it. TWRB is a state agency and prohibited from hiring a lobbyist, but I've worked with Bech before and know his brother Dane very well. Assisting as a friend and not a hired gun. Thanks for considering, bud. Miss you, so I wouldn't mind seeing you as well. Charles 202-412-3106 Sent from my iPhone Begin forwarded message: From: Bech Bruun <Bech.Bruun@twdb.texas.gov> Date: September 7, 2017 at 9:33:08 PM EDT To: "CBrittiiigham@cassidy.com" <CBrittingham@cassidy.com> Subject: Fwd: Hurricane response The attached letter describes what we'll be discussing w/ EPA on Monday at 3:45 p.m. Thx! Bech Sent from my iPhone Begin forwarded message: From: Jeff Walker <Jeff.Walker@twdb.texas.gov> Date: September 1, 2017 at 2:28:25 PM CDT To: "Coleman.sam@Epa.gov" <Coleman.sam@Epa.gov> Cc: "fergusoii.lincoln@epa.gov" <ferguson.lincoln@epa.gov>, "wagner.keniieth@epa.gov" <wagner.kemieth@epa.gov>, "sawyers.aiidrew@epa.gov" <sawyers.andrew@epa.gov>, "Shapiro, Mike (Sliapiro.Mike@epa.gov)" <Shapiro.Mike@epa.gov>, "hosch.claudia@epa.gov" 17cv1906 Sierra Club v. EPA ED_O01523_00000354-00001 <hosch.claudia@epa.gov>, Bech Bruun <Bech.Bruun@twdb.texas.gov>, ''grevatt.pete^epa.gov'1 <grevatt.peter@epa.gov>, "forsgren.lee@epa.gov'1 <fors gren.lee@epa.gov> Subject: Hurricane response Administrator Coleman, I enjoyed meeting with you yesterday though it was a bit chaotic. Attached is a letter with more detail and information related to what we briefly discussed. If you have any questions, please let me know. Jeff Walker Executive Administrator Texas Water Development Board (512) 463-7848 This message contains information which may be confidential and privileged. Unless you are the intended recipient (or authorized to receive this message for the intended recipient), you may not use, copy, disseminate or disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender by reply e-mail, and delete the message. Thank you very much. 17cv1906 Sierra Club v. EPA ED_001523_00000354-00002 September 1. 201 " Development Board PO Box 13231, 1700 M Conqmss Ave Auean I-, 7871 ` ,031 i'Hone mmum.7847. f-.o (5K0 5 Mt. Samuel Coleman. I'.lv . ... . . Acting Regional Administrator R.S. km ironmcnlal Protection .Agency. Region b 1-145 Ross Avenue Suite 12(Ht Dallas. I exas 75202-2733 ' 1 )car Administrator ( olcmmi: A. . It was good to talk with you yesterday, men though it was not under the best of circumstances. A> was mentioned, you participated in a meeting on August 30 m ( orpus Christi. IX with Imvironmcntal Protection Agency (IiPA) Administrator Pniill in regards to the catastrophic disaster in our great state caused by Hurricane Harves1. I also understand that (`hairman Bech Bruun was m attendance and discussed the efforts of the Texas Water I Jcwlopmcnl Boaid ( 1WI )B) to assist entities impacted by the events. i'hairman Bruun currently has a tncetinp. scheduled w ith < ffice of Water personnel at I-PA I Icadquartcis on September 1 I. The meeting is with Andrew Sawyers. I rector of Wastewater Management and other invitees including l.cc l-'orsgren. Based on Administrator Pruitt's expressed interest in Corpus Christi, he may also be interested in attending. yf Hie pin pose ol the meeting is to discuss how the State Rewiring C undo (SRI ) can best he used to address immediate recovery and future resiliency efforts. Wc feel that there are two primary needs in Texas al this time: utilization of the SRI funds as expeditious budge financing to jumpstart the nwwr. process and addressing stormwater infrastructure for the future. Wc believe that the SRP funds can provide a critical linancmg biidge between the immediate need for cilies to restore thcii water and wastewater systems and the delivery of federal disaster aid, to which thev arc eligible, hut may be protracted in its ddiwiy. It the SRI ImuK can be used as bridge financing to enable the systems to get to the business of restoring service without hindering their tutnrc ability to access or receive then full amount of disaster lundim:. the local, state, and national economy benefit. Additionally, as you know, the Water Resources Development Act of 2010 expanded the chgubilitics of the (.'lean Water SRI; to include projects that manage, reduce, treat or recapture stormwater (Section 603 (c)(2)). While there are generally direct and ancillary water quality benefits, the Act does not require a water quality benefit I or the projects. Hie TWI )B currently has 1 $-17 million (`lean Water SRI-' application from the City of Houston for stormwater infrastructure that we anticipate the Board considering for funding in < ctobcr. Wc know there is additional need and anticipate future applications from the Harris County area as well as other areas of the state. Continued support of these project eligibilities will greatly strengthen the state and enhance the utilization of the Clean Water SRI;. . . A" i h'o' -'ifi To piovido leadership, information, education, and '-upper fur Dlannir-q (maroa1 .rostan-w and r .'re.n > far tiw tor,s<-.-r,.i*rn in 1 respon'.ttjle ................... development of water for Texas f'i i'c W m.'.'-i Bech Bruun. Chairman | Kaihleen Jackson Board Member | Peter Lake, Board Member Jeff Walker. Executive Administrator ............................................................................... 17cv1906 Sierra Club v. EPA ED_001523_00000356-00001 Administrator Coleman September 1, 2017 Page 2 Finally, as the state agency responsible for the administration of the Drinking and Clean Water State Revolving Funds, the TWDB stands ready to assist our communities in the recovery and rebuild/restoration process. I think you will agree with us that funding for recovery efforts should be delivered expeditiously to those in need and should not hinder their ability to deliver clean drinking water and to protect the water quality of our streams, lakes and bays. Additionally, we should be preparing for future events of this type and building resiliency into our systems. To deliver SRF funding promptly, we have reviewed current federal codes and state rules governing the State Revolving Funds and propose the following: As mentioned above, allow interim financing for communities to begin rebuilding/reconstruction of infrastructure until federal disaster funding is obtained at which time, the interim loan will be reimbursed from the federal disaster aid without reduction in aid eligibility. Bypassing the Intended Use Plan process relating to submittal of a Project Information Form, public comment period and invitation process. The state proposes to outline information required of all political subdivisions and posting on our website. Expedite the Environmental Review process for the Clean Water SRF. For Categorical Exclusions (CE), modify the current prohibition on issuing CE's if the project will provide capacity to serve a population 30% greater than the existing population. We propose for emergency projects, setting the limit to growth not exceeding 30% of the design population. 40 CFR 6.204(a)(l)(ii) Approval to allow entities impacted by the disaster to modify the scope of their currently ranked projects to specifically address replace/rehab of their systems without loss of points or reranking Allow all SRF funds to provide the match requirements for federally funded projects, such as Federal Emergency Management Agency or the U.S. Army Corps of Engineers. Expansion of the public interest de minimus waiver of the American Iron and Steel requirements to expand beyond the 5% allowance. Allow a general public interest waiver for Texas emergency projects similar to the waiver that was granted to the state of Washington on October 5, 2015. We believe that these allowances and procedural changes will assist communities in rebounding and continue contributing to a robust economy without jeopardizing the SRFs, the disaster recovery process, or the environment. If you have any questions or comments, please do not hesitate to contact me. Chairman Bruun is looking forward to the meeting on September 11 and hopes to see the Administrator there as well. Executive Administrator 17cv1906 Sierra Club v. EPA ED_001523_00000356-00002