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The “(lbs/day)” numbers listed above will be used as the target pounds to determine each NPDES permit holder’s Delta. An NPDES permit holder’s Delta is the actual pounds of phosphorus discharged per day minus the target pounds. NPDES permit limits will be based on a seasonal average with appropriate daily, weekly, and monthly limits that recognize the uncertainties and start-up complexities of new treatment technology. The 2017 phosphorus targets are goals during the first ten years of the MIP. These phosphorus targets will not be binding during the first ten years so as to allow assessment of the beneficial impact on DO from all MIP-related technology improvements and phosphorus reduction actions initiated during this time, and to allow V21 4 measurement of the actual Delta reduction by the dischargers based on experience. By the end of the 20th year, NPDES permit holders are required to be in compliance with the phosphorus WLA in the right hand column of the chart above. Once an NPDES permit holder demonstrates reliable ability to continually meet its target, either by treatment technology or technology combined with actions to eliminate the Delta, that permit holder will have met its responsibilities for meeting waste load allocations as expressed in either the MIP or the TMDL. Aggressive efforts, initiated as quickly as possible, to reach the targets during the first ten year period of the MIP are required. These efforts will include both phosphorous removing treatment technology upgrades and a suite of other phosphorus reducing actions from the list of “target pursuit actions” described below. Some aggressive programs to meet phosphorus targets may be conducted jointly by several dischargers. These efforts need to result in assignment of reduced pounds of phosphorus to individual dischargers because dischargers must meet individual targets. A trading program of dischargers’ demonstrated surplus phosphorus may be implemented consistent with EPA guidelines pending Ecology’s verification of any surplus phosphorus offset pounds. As part of the implementation of the MIP, each National Pollution Discharge Elimination System permit holder in Washington State covered by the Spokane River Dissolved Oxygen TMDL will, in accord with the section titled “Schedule of Activities,” prepare a technology selection protocol and an Engineering Report with construction schedule for the treatment technology improvements the permit holder intends to install. The permit holder will also prepare a Delta elimination plan with a schedule of target pursuit actions (see details below) that, in combination with the technology improvements, provide reasonable assurance the April-October phosphorus target will be achieved in the first 10 years of the MIP. The ways these targets and associated requirements will be reflected in each NPDES permit is explained in the section below titled “NPDES Permit Cycle.”