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<br />Agenda Item 11, September 21-22,1998, Board Meeting <br />Page 4 <br /> <br />. <br /> <br />c. Independent Application <br /> <br />Independent application policy refers to tools or monitoring data used to assess the extent to <br />which water quality attains the ecological integrity of an aquatic system. This policy is <br />interpreted only in the context of protection of aquatic life and not in the context of protection <br />of human health or wildlife. The EPA recommends that state arid tribes adopt water quality <br />criteria that would support aquatic life, and use chemical-specific, toxicity, or biological <br />criteria for water quality monitoring. <br /> <br />Discussion and-Recommendation <br /> <br />On September 1, 1998, staff from the CWCB, Division of Water Resources, Division of <br />Wildlife, Department of Natural Resources, and the Water Quality Control Division and <br />Commission (WQCD & WQCC) met to review potential impact of the EPA's plans on <br />Colorado. The group decision was to suggest that the WQCC take the lead in formulating <br />comments to the EP A on behalf of the State of Colorado. All other interested state agencies <br />would of course be invited to share their concerns and suggestions with the WQCC. However, it . <br />is not clear that the WQCC wants that responsibility, especially since comments for ANPRM are <br />due by next January. <br /> <br />. <br /> <br />. <br />_ Our knowledge of the EPA's plans is limited at this time, as these plans are at their initial stages <br />of development. Although it would be difficult to disagree with the goals of the Clean Water <br />Action Plan, we are not convinced that the current system is indeed in need of so much <br />improvement. Therefore, unless the Board advises us otherwise, we have organized a Water <br />Quality Team within our staff and plan to keep track of the EPA's effort more closely. Through <br />this team effort, we plan to propose comments on the EPA plans for your review. We also plan <br />to continue our coordination with the State Engineer and the WQCD and to participate in an <br />upcoming WQCC workshop on October 14 to discuss plans for responding to EPA's plans. <br /> <br />Attachments <br /> <br />. <br />