Your comments are needed on the Draft Impaired Waters List to help clean up Iowa's most polluted water bodies. This Action Alert provides resources to help you submit comments. ******** Comments due this Friday October 18, 2002 ********** The Iowa Department of Natural Resources (DNR) is preparing the Impaired Waters List as directed under the Clean Water Act, Section 303(d). The Impaired Waters List identifies water bodies in Iowa suffering from pollution, and begins the clean up process known as TMDL (Total Maximum Daily Load). Significant federal, state, and local resources are deployed according to the priorities established by the list. This clean up process is one of Iowa's most important tools for protecting and improving water quality. The Council wants the Impaired Waters List-the first step in this process-to be comprehensive and complete. Public comments to the DNR are vital in helping ensure the Impaired Waters List addresses all of Iowa's most serious water quality problems. To help you provide comments the Council has several resources available. -- Below is a sample comment letter. Feel free to use it all or in part. -- Susan Heathcote, the Council's Research Director, is available to help you prepare your comments and to answer any questions you might have. She can be reached at (515) 244-1194 or <[log in to unmask]>. ******************************************** SAMPLE LETTER October 18, 2002 Chris Van Gorp Iowa Department of Natural Resources Wallace State Office Building 502 East 9th Street Des Moines, IA 50309 Dear Mr. Van Gorp: I would like to provide the following comments on Iowa's proposed 2002 Section 303(d) list of impaired waters. The Impaired Waters List is the first step in one of Iowa's most important tools for protecting and improving water quality in the state. No other program offers the potential resources for water quality improvements, nor provides the kind of coordination of federal, state, and local resources necessary to address water quality problems in Iowa. Therefore, it is vitally important that Iowa's Impaired Waters List be as comprehensive and complete as possible. The 2002 Impaired Waters List is neither complete nor comprehensive at this point, due in large part to the data limitations imposed by the State Legislature in 2000 in the so called "credible data law." These restrictions on data used to create the Impaired Waters List are not in compliance with federal listing requirements. To correct this situation, and ensure Iowa is able to accurately address our priority water quality problems, I recommend the following: 1. Do not remove water bodies included on the 1998 Impaired Waters List simply because they fail to meet Iowa's restrictive "credible data" requirements. This includes at least 49 different impairments on 38 water bodies in the state. 2. Wetlands especially suffer from this restrictive data requirement. The 44 wetlands proposed for "delisting" should be included on the 2002 list. Because Iowa has failed to establish monitoring criteria for wetlands, the DNR should rely on "best professional judgement" to ensure we protect and improve our vital wetlands. 3. The 2002 Impaired Waters List should reflect all the data that is available to the DNR as required by the Clean Water Act and regardless of the restrictive requirements of Iowa Law. This would include: -- The Iowa Lakes Survey conducted by Iowa State University. This comprehensive study provides some of the best information available on the condition of 132 Iowa Lakes. -- Water bodies with repeated fish kills. Such water bodies must be considered biologically impaired. The DNR maintains data on such water bodies, and this information should be consulted as the DNR prepares Iowa's Impaired Waters List. -- Water bodies with combined sewer overflow impairments. Iowa currently has 15 municipal facilities with combined sewer overflow (CSO) permits that allow discharge of raw sewage into our rivers following rainfall. These river segments affected by CSOs should be listed. -- Drinking water sources with pesticide contamination. All surface drinking water sources should be listed where monitoring indicates pesticides are present at levels exceeding one-half the maximum contaminant level (MCL) or health advisory level (HAL) in the finished drinking water. In addition, water bodies should be listed where individual raw water samples exceed the MCL or HAL level on a regular basis. Iowa's future depends on clean water, clean air, and clean soil. The DNR is one of the most important mechanisms for protecting our natural resources. It is my hope that the DNR takes the opportunity presented by the 2002 Impaired Waters List seriously, and seeks to create a list that is comprehensive and complete. Thank you for the opportunity to provide these comments. Sincerely, (Your name/organization) Erin E. Jordahl Director, Iowa Chapter Sierra Club 3839 Merle Hay Road, Suite 280 Des Moines, IA 50310 515-277-8868 [log in to unmask] [log in to unmask]