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Lincoln C. Loehr

Paralegal

206-***-**** Direct

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Environmental & Natural Resources

Lincoln C. Loehr

ExperienceLincoln Loehr is a paralegal who serves as environmental compliance analyst for the Environment, Land Use and Natural Resources group. He provides support to clients and environmental attorneys on matters of discharge permitting, total maximum daily loads, stormwater management, environmental cleanups and regulatory and standards development. Lincoln has worked on wastewater discharge permitting issues in Washington, Alaska, Idaho and Oregon and has served on advisory committees to the Washington State Department of Ecology on matters of rule-making and policy development.

Since 1987, Lincoln has provided review and comments on rule revisions regarding Washington's water quality standards, and since 1992, he has provided review and comments on rule revisions regarding Alaska's water quality standards. Lincoln has also influenced the mixing zone considerations in EPA's technical guidance and in Washington's and Alaska's water quality standards. He maintains a broad network of municipal, industrial, technical consultant, scientific and agency contacts throughout the country, which helps with early identification of matters that may affect environmental regulatory issues. Representative WorkNPDES Permitting IssuesWorked on reviews, comments, modifications and appeals of NPDES permit conditions for municipal discharges in Washington, Idaho and Alaska. Worked on reviews, comments, modifications and appeals of NPDES permit conditions for industrial clients in Washington and Alaska.Worked on behalf of the cruise ship industry to review and comment on a federal general permit for vessel discharges and a general permit for cruise ship discharges in Alaska.Prepared complete draft permits and fact sheets for two industrial facilities. Routinely reviews other NPDES permits and fact sheets in Washington, Alaska and Idaho.Standards Development IssuesWorked on behalf of various municipal and industrial clients on regulatory developments pertaining to surface water quality standards, mixing zone regulations, temperature standards, ground water quality standards, biomonitoring, sediment management standards, cleanup standards and associated implementation guidance. Reviewed and commented on the Guidance for Implementing Whole Effluent Toxicity prepared by EPA Regions IX and X.Reviewed and commented on the Tribal Water Quality Standards Template prepared by EPA Region X and on several tribal proposed standards or revisions.Petitioned the State Department of Ecology to revise Washington's water quality standards for dissolved oxygen and arsenic.Assisted Alaska and Idaho in changing arsenic standards. 303(d) Listings of Contaminated Waterbodies Since 1994, has worked on behalf of several cities, an aluminum smelter, a pulp and paper company and a timber firm in preparing comments regarding proposed 303(d) listings.TMDL DevelopmentsReviewed and commented on modeling and waste load allocation proposals and draft permits for the Snohomish River Estuary TMDL for dissolved oxygen.Reviewed and commented on a TMDL and its implementation plan for bacteria in an urban stream.Favorably resolved metals TMDL issues for the Spokane River for all the municipal and industrial point sources in Idaho and Washington.Worked on review of the state agency-developed TMDL and the discharger-developed Use Attainability Analysis and site-specific standards, all pertaining to dissolved oxygen concerns for the Spokane River.Commented on a TMDL for metals on the South Fork of the Coeur d'Alene River.Commented on permit conditions implementing a TMDL for numerous parameters and subsequent work on appeal of permit conditions for an Idaho municipality.Reviewed and commented on a TMDL that sought reductions in nutrients in order to attain pH water quality standards.For a small shipyard in Bellingham, Washington, reviewed a TMDL for a cleanup of contaminated sediments.Mixing ZonesConvinced EPA technical staff to include mixing zone allowances in federal guidance that were based on realistic durations of exposure of aquatic organisms in receiving waters.Involved with development of mixing zone regulatory language for Washington and Alaska.Assisted municipal and industrial dischargers in Washington, Alaska and Idaho on mixing zone issues.Reviewed how 46 states regulate and implement mixing zones. Professional Honors & ActivitiesMember, first Alaska Cruise Ship Wastewater Discharges Science Advisory Panel. The panel presented its final report and findings to the Governor of Alaska in 2002. Served as principal author on an article in the Marine Pollution Bulletin (2006) discussing the panel's work and conclusions. Appointed in 2009 to a second Alaska Cruise ship Wastewater Discharges Science Advisory Penal to evaluate treatment technologies.Presentations"An Assessment of Alaska Cruise Ship Wastewater Discharges by the First Cruise Ship Science Advisory Panel in 2002," Alaska Resource Development Council meeting, Juneau, 2010"Using a Simple Dilution Model to Estimate Wastewater Contaminant Concentrations Behind Moving Passenger Vessels," Oceans 2003 Conference, San Diego, 2003"Comparison of States' Approaches for Mixing Zones," Rocky Mountain States Chapter of the Water Environmental Federation, Jackson, Wyoming, 1999"Understanding Hardness in a TMDL for Metals Leads to a Counterintuitive Solution," Pacific Northwest Water Pollution Control Association Conference, Portland, 1998"Municipal Waste Discharge Policies in Washington State and Recent Discharge Issues Between the State and British Columbia," International Association of Water Quality Biennial Conference, Vancouver, British Columbia, Canada, 1998"Mixing Zones: The Need to Consider the Underlying Assumptions in the Various Water Quality Standards," EPA Multi-Regional Meeting on Water Quality Standards and Criteria, Denver, Colorado, 1996Civic ActivitiesMember, Snohomish County Marine Resources Committee Member, Kiwanis Club of ShorelinePublications"The Significance of Dilution in Evaluating Possible Impacts of Wastewater Discharges from Large Cruise Ships," Marine Pollution Bulletin, 2006"Using a Simple Dilution Model to Estimate Wastewater Contaminant Concentrations Behind Moving Passenger Vessels," proceedings of the Oceans 2003 Conference, 2003"The Impact of Cruise Ship Wastewater Discharges on Alaska Water," report by Science Advisory Panel & Alaska Department of Environmental Conservation Commercial Passenger Vessel Environmental Compliance Program, 2002"Municipal Waste Discharge Policies in Washington State and Recent Discharge Issues Between the State and British Columbia," Water Science Technology, 1998"Arsenic Human Health Surface Water Quality Standards: A Snapshot of State Standards, Summer 1996," SETAC News, 1996"An Opportunity to Correct the Marine Water Quality Criteria for Copper," Water Environment & Technology, 1995"Duration of Exposure, Its Role in Assessing Toxicity of Effluents, and the Need to Recognize the Benefits Inherent in Well-Sited and Well-Designed Outfalls," proceedings of the Seventeenth Annual Aquatic Toxicity Workshop, Vancouver, British Columbia, 1991EducationUniversity of Washington, M.S., Public Administration, 1977 University of Washington, B.S., Oceanography and Geology, 1969

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