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• The Policy for Tmplementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries in California(aka the State Implementation Policy, or"SIP") • The California Toxics Rule (CTR) • Applicable Regional Water Quality Control Board (RWQCB) Basin Plan Water Quality Objectives(WQOs) The concentration of copper needed to effectively control algae and other aquatic vegetation typically exceeds SIP water yuality criteria. On a short term or seasonal basis, the Permittee may treat waterbodies and or discharge treated water into receiving water and as a result exceed SIP water quality criteria for copper. Although the SIP prohibits discharge of copper in excess of applicable water quality criteria into receiving wat�rs, Section 5.3 of the SIP allows for short term or seasonal exceptions from meeting water quality criteria if determined to be necessary to implement control measures either for resource or pest management conducted by public entities. Such exceptions may also be grar�ted for draining water supply reservoirs, canals, and pipelines for maintenance, for draining municipal storm water conveyances for cleaning or maintenance, or for draining water treatment facilities for cleaning or maintenance. The Permittee has concluded that it meets one or more of the criteria for gaining a Section 5.3 SIP exception. Permittees who elect to use a SIP exception to gain permit coverage must satisfactorily complete several steps, including preparation and submission of a California Environmental Quality Act (CEQA) document which when completed and submitted to the SWRCB, will be referenced in a revised Permit. Once listed in the revised Permit, the Permittee may discharge copper to receiving waters in excess of water criteria on a short term or seasonal basis. The SWRCB staff has indicated once all application documents are submitted, they will post the Permittee's SIP exception request for a 30 day public notice and draft a resolution that would add the Redwood Shores Lagoon to the permit's exception list. Once these steps are completed, SWRCB staff will schedule a request for permit reopening on a SWRCB meeting agenda. During the meeting,the SWRCB will be asked to adopt and revise the permit, and have the RCPW added to the list of SIP exception holders. To achieve compliance with the new permit and allow for applications of aquatic herbicides and algaecides to be made during the 2015 vegetation growth season, Consultant shall complete the following tasks: Task 1: Ag�ncy Pre-consultatfdn and Consultation: As necessary, Consultaht will communicate with the SWRCB and/or RWQCB staff as well as responsible and trustee agenc�es to discuss and present details of the proposed RCPW CEQA document prior to submittal. Task 2: RCPW Pre-consultation and Consultation: CLPs Team will meet with RCPW staff to gather further details of the aquatic vegetation management program (CLI currently has some of the information required below). At a minimum, the following data and documentation would be required: ATTY/AGRZ025.015/CLEAN LAKES INC. REV:01-27-15 MLG Page 30 of 14