----- Original Message -----
Sent: Friday, December 28, 2007 10:32
AM
Subject: Re: Sierra Club's Mike Carberry
interview on DNR stream controversy KGAN-TV Wed 12/26
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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