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Commission as a part of the CDH, id. § - 201(1)(a). The Commission's duties include, <br />inter alia, classifying the State's waters, promulgating water quality standards, <br />promulgating permit regulations, and acting as an appellate body to review all <br />determinations by the division [Division of Administration, CDH, id. § -103(4)] dealing <br />with surface water discharge permits or portions thereof, id. § -202. For reasons not <br />clear to us, the Mid - Continent discharge permits were issued by the Water Quality <br />Control Division CDH. <br />PERMITS COMPARISON <br />In addition to the overlap of statutory authority between MLRD and WQCD, <br />the similarity of enforcement design is clear after comparing the substance of the <br />permits each issued to Mid - Continent. <br />Although the language in the Mid - Continent MLRD permit lacks some <br />precision, there is no doubt that the MLRD permit describes what WQCD denominates <br />as the Outfall No. 016 series of three ponds (see illustrative sketch map, Brief Exhibit- <br />)). The rationale accompanying the 1984 MLRD permit revision discusses the Outfall <br />No. 016 ponds as follows, MCR Ex. 4 -D p. 17, Record 00334 -00400 (dated August, <br />1984): <br />zs See MCR Ex. 5 -A (1982 WQCD permit), covering letter p. 2, signed by Jeb Love, <br />Section Chief, Permits Section, Water Quality Control Division; MCR Ex. 5 -B (1983 permit <br />amendment), covering letter, signed by Gary G. Broetzman, Director, Water Quality Control <br />Division; MCR Ex. 5 -C (1984 permit amendment), covering letter, signed by Gary G. <br />Broetzman, Director, Water Quality Control Division; MCR Ex. 5 -D (1986 permit amendment), <br />covering letter, signed by Gary G. Broetzman, Director, Water Quality Control Division; MCR <br />Ex. 5 -E (1987 permit amendment), covering letter, signed by Paul Ferraro, Director, Water <br />Quality Control Division; and MCR Ex. 5 -F (1988 permit), covering letter, signed by Paul <br />Ferraro, Director, Water Quality Control Division. <br />Mid - Continent Answer Brief <br />- 29 - Appeal No. 93 CA 297 <br />