To add to Steve's comments, the DNR must also be stopped from arguing that 
downgrading streams from A1 to A2 still gives them more protection than they had 
two years ago, before the new water quality standards. Of course they are! 
Before the new standards, 83% of the streams in Iowa had absolutely no 
protection. So anything is obviously more than nothing. That does not mean that A2 
designation complies with the requirements of the Clean Water Act. 
 
Wally Taylor
 
In a message dated 12/28/2007 10:32:25 AM Central Standard Time, 
[log in to unmask] writes:

Hello Mike,
 
Good job on the TV interview.  Here's what people need to keep in mind 
though.  The A1 designation does not just encompass swimming.  The DNR's constant 
use of "swimming" in all of their press is a false premise they deliberately 
perpetrate in order to make their actions seem reasonable.  A1 has three 
determinatives 1) prolonged contact with the water, 2) risk of ingesting water, and 3) 
ingestion in quantities that could cause harm.  Swimming is not a 
determinative, it is just an example of one type of activity the rule is supposed to 
protect.  
 
My comeback to the DNR spin is that kids splashing and playing in the water 
need protection too.  We must always challenge their false premise as part of 
our response.
 
DNR will also say that the A2 designation being given most of these streams 
will effectively protect for A1 activities as well, since disinfection is "all 
or nothing" from an engineering standpoint.  They fail to mention that the 
scientific basis for protecting for A2 (incidental contact) activities is being 
challenged nationally by the wastewater industry, and EPA may remove their 
guidance that states protect A2 designated streams.  Even now it is not an EPA 
requirement.  If that happens, states that define "primary contact" activities 
inclusively will still protect for most activities in most streams.  States, 
like Iowa, that are trying to define "primary contact" activities very narrowly 
will NOT be protective of most activities in most streams.  Based upon DNR 
statements to the wastewater folks, the half-life for implementing these new 
standards into permits will be ten years or more.  There is a great risk that 
disinfection will never be implemented for streams designated A2.  That's why we 
have to fight to keep as many streams as possible designated A1.  

Keep up the fight.
 
Steve






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