Revised Tentative Order R9-2009-0002; NPDES CAS0108740 Orange County Municipal Storm Water Permit Reissuance

Abstract

Thank you for providing Rancho Mission Viejo (RMV) with the opportunity to review and comment on the referenced Revised Tentative Order. We have previously submitted comments on this tentative order. Staff has been most helpful in addressing our comments and we are pleased to see that our request to have the Regional Board consider how the protection of water quality at the watershed scale can provide equal or greater benefits than the protection of water quality at a site-specific scale has resulted in the inclusion oflanguage in support of this concept- see Section F.l.c (8). In recent discussions with staff regarding inclusion ofthe language "and acceptable to the Regional Board " staff indicated that the lack of certainty regarding what watershed and/or subwatershed planning principles would be used prompted the inclusion of this language. In our prior correspondence on the tentative order RMV included an attachment which summarized the Watershed Planning Principles and approaches taken by RMV to implement these principles during development of our water quality management plans. This attachment is included in this comments letter also. In addition, RMV has previously provided the Regional Board with the sub-basin planning principles for each of the subbasins located on our property as part ofthe document titled Watershed and Sub-Basin Planning Principles (February 2003). We respectfully request that the language "and acceptable to the Regional Board " be deleted from the tentative order for the following reasons: (1) The Regional Board already knows what planning principles we will be and are using in our planning to protect water quality; an