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<br />STATE OF COLORADO <br /> <br />. <br /> <br />"-';i !.vi, _', _ _. ,"'v <br />Patti Shwayder, Executive Director <br /> <br />WATER QUALITY CONTROL COMMISSION <br />http://www.cdphe.state.co.us <br /> <br />4300 Cherry Creek Drive South <br />Denver, Colorado 80246-1530 <br />Phone (3031 692.3469 <br /> <br /> <br />Colorado Deparonent <br />of Public Health <br />and Environment <br /> <br />December _' 1998 <br /> <br />W-98-01 <br />WQS-ANPRM Comment Clerk <br />Water Docket <br />MC 4101 <br />U.S. Environmental Protection Agency <br />401 M Street, S.W. <br />Washington, D.C. 20460 <br /> <br />PREUMlNARY DRAf1l <br />NO do. DATE/:j;~Jff <br /> <br />Dear EPA Colleagues: <br /> <br />. <br /> <br />On behalf of the Colorado Water Quality Control Commission, I offer the following <br />comments in response to EPA's Water Quality Standards Regulation Advance Notice of <br />Proposed Rulemaking. <br /> <br />General Comments <br /> <br />1. The current water quality standards system is basically working and there is no <br />need for a major overhaul of EPA's Water Quality Standards Regulation. In narrow <br />circumstances, adding clarifications to the current regulation regarding existing <br />requirements may be appropriate. However, the adoption at this time of substantial <br />new or more restrictive federal mandates regarding water quality standards would <br />not be a constructive way to foster additional progress regarding water quality <br />protection. Instead, EPA's focus should be on generating informal guidance and <br />scientific information that provide additional tools for states in implementing their <br />primary responsibility under the Clean Water Act for developing and maintaining <br />water quality standards. Many of the new tools being explored by EPA may be <br />useful in site-specific or watershed-specific applications, but should not be <br />mandated as across-the-board requirements. <br /> <br />2. <br /> <br />Where EPA does add clarification to existing requirements, it should limit its focus <br />to cstabli31;iFlg ~p.~lli@:QQ.t the broad goals and objectives of the program elements <br />in question, while leaving substantial flexibility to states in determining how best to <br />achieve those goals and objectives. Currently different states apply the individual <br />elements of a water quality standards program in many different ways. What <br />matters is not whether each individual element is applied in an identical fashion, but <br />whether a comparable overall level of water quality protection is achieved by the <br /> <br />. <br />