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<br />ANPRM Comments <br />December 8, 1998 <br />Page 8 <br /> <br />. <br /> <br />4. III.C. Other Criteria Issues -- Arid West Water Quality: <br /> <br />Over the past decade or so, many issues have been raised regarding whether the <br />unique conditions present in streams in the arid West warrant a modified approach <br />to adopting water quality standards for such streams. For example, it has been <br />suggested by many that ephemeral and effluent-dependent streams present unique <br />circumstances that make application of national ambient water quality criteria <br />inappropriate. In addition, note that although EPA defines "biological integrity" to <br />be based on the "natural habitat of a region", returning to a natural condition is no <br />longer a realistic option for many western streams. <br /> <br />Congress has funded an Arid West Water Quality Research Project (AWWQRP) <br />that is currently looking at scientific and technical issues associated with water <br />quality standards for western waters. In order to achieve an appropriate resolution <br />of these issues, it is important for EPA to also engage in a dialogue on the policy <br />aspects of water quality standards for western streams, in parallel to the scientific <br />research efforts of AWWQRP. Unless and until there is a resolution of the issues <br />regarding the need for unique water quality standards for western waters, the <br />,debate surrounding these issues will continue to be a distraction that contributes . <br />confusion and discontent to western water quality management efforts. <br /> <br />Please note that although this comment is offered under the "Criteria" heading, it <br />also applies to issues regarding the assignment of appropriate use designations to <br />westem waters. <br /> <br />Antidegradation <br /> <br />1. III.D.2. General Description of Antidegradation, and III.D.3. "Tier 1": <br /> <br />EPA's current three-tier antidegradation system ought to be simplified to a two-tier <br />system. The current "Tier 1" is confusing and redundant with the requirement for <br />use-based designations, since the first rule of the use-based water quality <br />designation system is that all existing uses must be protected. Use designation <br />requirements can be applied to provide the same protection as EPA discusses <br />separately as "Tier 1" of its antidegradation requirements. . Antidegradation policy <br />would be more understandable if it were focussed on a two-tier system (current Tier <br />2 and Tier 3) that applies where appropriate to provide protection over and above <br />the use-based water quality standards designations. <br /> <br />. <br />