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<br />. ". <br /> <br />in fact, this is the seco~d ANPRM for the Water Quality Standards program that EPA has <br />released. Given the volume of comments EP A expects to receive on the ANPRM and the <br />workload that EPA's Office of Water currently faces due to other matters, TV does not believe <br />that there is any cause for worry regarding timing. Moreover, ifEP A proceeds as it typically <br />does, it would be highly unlikely for the agency to propose new requirements on all of the issues <br />which the ANPRM raises at once; more likely would be a staged approach with the Agency <br />proposing new rules on individual pieces of the ANPRM over time, (This approach would also <br />be consistent with the schedule EP A itself issued this summer regarding its agenda for new water <br />quality criteria regulations.) <br /> <br />, b. flexibility. Traditionally, a call for "flexibility to address site-specific circumstances" is a call <br />for less environmental protection. From the many other statements in the Board's proposed <br />comments that indicate a hostility towards additional regulatory protection for human health and <br />the environment, TV must assume that that's what this language means here. TV urges the <br />Board not to adopt this stance. <br /> <br />c, new need. In addition, TV must point out that clean water is not a "new need" in Colorado or <br />the nation. The Clean Water Act is over a quarter century old. As stated at the beginning of this <br />document, while there has been substantial progress as a result of the Act, there is much left to be <br />done. It is 'simply inappropriate to call proposed refinements and additions to EPA's clean water <br />programs 'new needs' as if they had just been identified. It is instead the case that EPA is search <br />for new strategies to meet the demonstrably unmet goals of a 26-year-old statute. <br /> <br />For all of these reasons, TV recommends that the Board strike this sentence in its entirety. <br /> <br />TV appreciates the Board's consideration of these proposed changes, <br /> <br />4 <br />