BOARD00585

• Board Meeting Date: 11/23/1998
• Description: Federal "Clean Water Action Plan" and EPA's Advance Notice of Proposed Rule Making - Status Report
• Board Meetings - Doc Type: Memo

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Trout Unlimited's proposed chanl!es to the draft 11/18/98 CWCB letter to EPA rel!ardinl!
the Al!encv's ANPRM on the Water Ouality Standards Rel!ulation

1. "However, it does not provide the basis to conclude that so many aspects of the
implementation effort require such extensive overhauL"

TV recognizes that the CWCB does not have direct responsibility for protecting water quality in
the state of Colorado. Thus, the CWCB probably does not receive as a matter of course the
extensive information made available by EP A, the state water quality agencies and others,
applicable both in Colorado and for the nation, regarding unaddressed water quality problems.
While there is no question that the Clean Water Act has been a success in cleaning up the
majority of the major municipal and industrial point sources of pollution, and in upgrading
wastewater treatment plants throughout the nation, much is left to be done before the nation's
waters achieve the goals of the Clean Water Act set in 1972, Today, the vast majority of the
nation's waterways that remain polluted are polluted by non-point sources of pollution and other
activities (some involving discharges of pollutants and some not) which are not currently
regulated, In the context of the progress that the nation has made to date towards meeting the
goals of the Clean Water Act, the ANPRM would be better characterized as the beginning ofa
national debate on how to fill in the gaps, e.g., by adopting new types of criteria, and how to
tighten existing programs, so as to be able to make additional progress.

For these reasons, TV objects to the above sentence and recommends that the Board strike this
sentence in its entirety.

2, "That justification has not been demonstrated and the CWCB questions whether such need
exists."

EPA, state water quality agencies and many other governmental and non-governmental
organizations in this country have reams of data regarding the pollution of the nation's water
quality that have yet to be addressed with existing law. If the CWCB were interested in
obtaining such information, TV would be happy to assist the Board in that effort However, this
statement in the CWCB's comments does not reflect data that are easily obtainable, For this
reason, TV recommends that The Board strike this sentence in its entirety. In the alternative, TV
proposes the following substitution:

It would be useful for EP A to make available a list of references for the studies and other
sources of information that describe the needs these proposed changes and additions to
the WQS program would address.

3. "Without strong evidence that agricultural activities are causing significant barriers to the
successful implementation of the CW A and an evaluation of the potential economic impact

Trout Unlimited: America's Leading Coldwater Fisheries Conservation Organization
CQlorado Office. 1900 13th Street, suite 10 t, Boulder, CO 80302. Phone [phone] . Fax [phone]