Hello Fellow Conservationist,

 You may have recently received a news item from one of the listserves you
participate in entitled: "Water Quality Standards Notice of Intended Action:
 Stream Use Designation Revisions", and you may have wondered what this is
really all about.  It is critical that you understand what is going on and
take action.  Please go to the website: http://iowa.sierraclub.org and read
the section about the Stream Uses Outreach Project.  Most importantly, you
will be able to download a testimony form to make official comments about
the uses you make of these streams.

 Those of you who work with DNR know that the agency is schizophrenic.  On
the one hand there are hundreds of dedicated conservationists working to
protect and improve water quality in the state and whose efforts are well
received by their constituents... the general public.  But there also is a
group with the task of issuing permits allowing pollution.  This group is
under constant pressure from the wastewater community, including municipal,
industrial, and agricultural "stakeholders", to find ways to allow more
pollution.  The rule-making action occurring now would reduce or remove the
aquatic life and recreational protections we just achieved for these streams
two years ago.

 We all know that water quality problems continue to plague Iowa.  Many of
our rivers and streams still do not meet the Clean Water Act goals of
"fishable and swimmable".  We need your help NOW to identify rivers and
streams where "fishable and swimmable" uses do exist or could be attained,
so those uses can be protected.
 In the context of the 1972 federal Clean Water Act, "fishable" refers to
the protection of all aquatic life, large or small, abundant or rare. Where
there is aquatic life, water quality standards used to craft state-issued
pollution permits for cities and industries must protect for the growth and
reproduction of that aquatic life.  "Swimmable" refers to the safe enjoyment
of all recreational activities in and on the water, whether it be swimming
and kayaking at times of high flow, or children splashing and making mud
pies in the shallows at times of lower flow.  Where there is human contact
with the water, water quality standards must protect us and our children
from the risk of bacterial infection.

 *There are many reasons for requiring clean water in our rivers, lakes, and
streams, but there are no reasons for allowing dirty water.  Only excuses.*

 Exactly ten years ago, EPA informed Iowa DNR of serious deficiencies in our
water quality standards.  To put it bluntly, Iowa's standards simply did not
provide adequate protection.  In fact, Iowa's standards only protected
aquatic life in 17% of our river and stream miles, and recreational
activities were only protected in 3%.  We now have an opportunity, with your
help, to take a giant step forward.

 Two years ago Iowa's Environmental Protection Commission finally adopted
the federally required "presumption of quality" for all of our rivers and
streams.  Unfortunately, the Iowa legislature immediately stepped in to
prohibit the issuance of pollution permits using these higher standards
until all streams receiving pollution were formally assessed to determine
whether aquatic life and recreational uses existed or were attainable.  This
Use Attainability Analysis (UAA) downgrade process is only allowed by the
federal Clean Water Act where it can be shown those uses do not exist, have
never occurred since 1975, and cannot be attained through the use of
reasonable stream improvement and pollution prevention measures.  Other
states have used this process sparingly and have generally set the
investigative and information threshold necessary to remove these
protections very high.  In Iowa, we are doing just the reverse.

 Because of the legislated requirement to quickly assess more than a
thousand streams, DNR has been unable to thoroughly investigate present and
past uses, particularly recreational uses.  We are at risk of losing the
aquatic life and recreational protections afforded just two years ago unless
we present evidence that those uses exist now, or have existed in the past.
 As a concerned conservationist in your area, you are in a unique position
to comment upon activities occurring in your local rivers and streams.

 In October, DNR began formal rule-making to downgrade the recreational
and/or aquatic life protections for 279 stream segments as part of phase one
of the UAA process.  Many more downgrades will follow in phases two and
three.

 *The Iowa chapter of the Sierra Club will fight for aquatic and
recreational protections for your rivers and streams.  But we need you to
tell DNR the truth about how people use them.*

 Fortunately, all we need to do to protect the streams in your county is
simply tell DNR the truth about the activities and uses that exist.  Do
people fish the streams? Do some people eat the fish they catch?  At times
of higher flows do people canoe, kayak or float the streams in a manner that
might cause them to accidentally ingest water?  Do teenagers "tramp" along
the streams, possibly swimming or dunking each other?  At times of lower
flows, do parents allow their children to splash and play in the water?
 Where do these activities occur, and can you prove it?  We need your help
getting the answers to these simple questions.

 At the website: http://iowa.sierraclub.org you will find a state map
showing all of the streams that DNR is proposing to downgrade in phase one.
 You will also find links to individual county maps.  Streams shown in blue
will maintain an A1 recreational designation, providing a high level of
protection.  A few segments shown in yellow will be designated A3, which
also provides a high level of protection.  The problem lies with all of the
streams shown in red (state map) or olive green (county maps).  Those will
be designated A2, which does not protect for activities where people
intentionally get wet and might ingest water.   You will notice that even
major rivers hundreds of miles long, like the West Nishnabotna, Middle
Nodaway, Middle River, Boyer River, Soldier River, Floyd River, a segment of
the Wapsipinicon, Buffalo Creek, the North Fork of the Maquoketa, the North
English and English Rivers, and many more will lose primary contact
recreational protection.  In all, 279 river and stream segments will lose
protection in just this phase of the UAA process.  DNR is saying that they
have no evidence that anyone has ever recreated in these rivers and streams
since 1975 in a manner that would pose a significant risk of ingesting
water.  Therefore recreational protection will be reduced in order to allow
cities and industries to continue discharging unnecessary pollution.

 Similarly, streams labeled B(WW2) on the map will have their aquatic life
protections lowered to a designation that does not fully protect for
bio-accumulative toxins that could have long term consequences for people
eating the fish.

 *The legislatively mandated UAA process is not about protecting water
quality; it's about managing a permit program to allow more pollution.*

 The period allowed for public comments about DNR's stream downgrade
proposals will close on December 11.  Please use the template at out website
to describe the uses you know are occurring in your rivers and streams.
 Please augment this with as much detail and as many attachments as you feel
necessary to prove these uses exist.

 From another Iowan for Clean Water, thank you for your help.

Steve Veysey, Conservation Co-chair
Iowa Chapter of the Sierra Club

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