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<br />Agenda Item 11, September 21-22,1998, Board Meeting <br />Page 2 <br /> <br />. States will continue to require flexibility, as well as technical and financial assistance, in <br />meeting national water quality objectives and cannot maintain existing programs while <br />participating in the wide array of proposals included in the ANPRM; and <br /> <br />. Many ofEPA's suggestions raise questions that the CWCB is not presently prepared to <br />evaluate, and will require time and information; these include: <br /> <br />. changes in the antidegradation policy and the use attainability analysis, <br /> <br />. the potential refinement of the "existing use" and "designated use" concepts, <br /> <br />. the potential new guidance on "use removal criteria" and mixing zone <br />determinations , <br /> <br />. the refmement or development of many new criteria for toxicity, sediment quality, <br />human and wildlife health, microbial and nutrient levels, etc., and <br /> <br />. the suggested "independent application" policy) <br /> <br />I would appreciate your guidance, first, on the question of whether to send comments <br />and, second, on the content desired in such a letter. <br /> <br />. <br /> <br />. <br /> <br />Attachments <br /> <br />L:/boardmemlnov98f20 EPA CleanWaterActionPlan BdMem Nov98 <br /> <br />. <br />