WVEC Action Alert

October 11 , 2005

Below:

Water Quality Standards - Triennial Review for 2007 - Comment Suggestions

Stop Congress and the Bush administration from seriously degrading organic standards


Water Quality Standards - Triennial Review for 2007
Comment Suggestions  

The WV Department of Environmental Protection (DEP) has solicited public comment as it begins the federally required triennial review of its Water Quality Standards.   This is the first important opportunity to participate in reviewing the standards that protect the state's waters.   And, this is the first time review has been conducted within DEP since rulemaking authority was transferred from the Environmental Quality Board (EQB).   To ensure healthy water in West Virginia, public participation is important in this process.  

We urge our members to submit comments to WV-DEP, DWWM, Triennial Review Comment, 601 57 th St., SE, Charleston, WV 25304, or gjshaffer@wvdep.org.   Comments should be postmarked no later than October 14, 2005 .

Here are summary talking points related to a few parameters that deserve attention in the upcoming triennial review.  

  • Bacteria.   Bacteria contamination is one of the most prevalent problems in WV waters and presents a serious health risk.

A properly implemented E.coli criterion will better protect citizens from water borne disease.   DEP should carefully transition from fecal coliform to an E.coli criterion over a five-year period.   In the interim, streams already listed as impaired for bacteria based upon fecal coliform data should not be removed from the 303(d) list for clean-up.

  • Mercury.   Mercury laden fish present human health risks for which West Virginians have been inadequately protected by water quality standards .

DEP should revise its mercury criteria to be at least as protective as federal guidance.   The state's water quality standard criterion for mercury, measured in fish tissue, is less stringent than current federal recommendations and should be revised to protect human and aquatic health.

  • Selenium.   Selenium is a threat to aquatic life and is a particular concern in West Virginia.   Protective criterion should be retained.

Although the U.S. Environmental Protection Agency (EPA) has proposed new criterion for selenium, the proposed changes are flawed and do not meet EPA's intention of providing protection to more aquatic life.   The proposed changes would allow selenium to bio-accumulate to toxic levels in aquatic species.   DEP should retain the state's current aquatic life criterion.

  • Turbidity.   West Virginia waters are heavily impacted by sediment run-off.   A strong 'clean sediment' criterion is critical to the health of our rivers.

EPA has extensively investigated criteria related to clean sediment.   DEP should review EPA guidance and establish criterion to minimize biological impairment from sediment in West Virginia's waters.

  • Trout Stream List.   Healthy trout habitat is an indicator of healthy water.   West Virginia has a long list of healthy trout streams to be proud of and to protect.

To provide adequate protection under the state's water quality standards to all the state's trout streams, DEP should begin the process to add those streams originally identified by West Virginia's Division of Natural Resources (DNR) as Tier 2.5 trout waters to the standard's Appendix B-2 for trout waters.   A complete list is important in order that our water quality standards abide the Clean Water Act requirement to protect streams designated as trout waters.

  • Pollutant Parameters & EPA Standards.   There are approximately 70 pollutants for which EPA has new or more protective criteria than WV. DEP should adopt EPA criteria for those of importance to WV.

DEP should review the list of pollutants and identify those that occur, have occurred in the past, or are likely to occur in West Virginia.   Once identified, criteria at least as protective as EPA guidance should be adopted.

When submitting comments to DEP please emphasize the importance of healthy rivers and streams, and the interest of the public in participating in DEP's role promulgating the rules that protect our waters. For many years, water quality rulemaking under the management of EQB has been an open process encouraging public participation.   DEP can now set the stage for an equally open process.

Return to Index


Stop Congress and the Bush administration from seriously degrading organic standards

The Organic Consumers Association (OCA) needs your immediate help to stop Congress and the Bush administration from seriously degrading organic standards. After 35 years of hard work, the U.S. organic community has built up a multi-billion dollar alternative to industrial agriculture, based upon strict organic standards and organic community control over modification to these standards.

Now, large corporations such as Kraft & Dean Foods--aided and abetted by the U.S. Department of Agriculture (USDA), are moving to lower organic standards by allowing a Bush appointee to create a list of synthetic ingredients that would be allowed organic production. Even worse these proposed regulatory changes will reduce future public discussion and input and take away the National Organic Standards Board's (NOSB) traditional lead jurisdiction in setting standards. What this means, in blunt terms. is that USDA bureaucrats and industry lobbyists, not consumers, will now have more control over what can go into organic foods and products.

Next week, acting in haste and near-total secrecy, the U.S. Senate will vote on a "rider" to the 2006 Agriculture Appropriations Bill that will reduce control over organic standards from the National Standards Board and put this control in the hands of federal bureaucrats in the USDA (remember the USDA proposal in 1997-98 that said that genetic engineering, toxic sludge, and food irradiation would be OK on organic farms, or USDA suggestions in 2004 that heretofore banned pesticides, hormones, tainted feeds, and animal drugs would be OK?).

For the past week in Washington, OCA has been urging members of the Senate not to reopen and subvert the federal statute that governs U.S. Organic standards (the Organic Food Production Act - OFPA), but rather to let the organic community and the National Organic Standards resolve our differences over issues like synthetics and animal feed internally, and then proceed to a open public comment period. Unfortunately most Senators seem to be listening to industry lobbyists more closely than to us. We need to raise our voices.

In the past, grassroots mobilization and mass pressure by organic consumers have been able to stop the USDA and Congress from degrading organic standards. This time Washington insiders tell us that the "fix is is already in." So we must take decisive action now. We need you to call your U.S. Senators today. We need you to sign the following petition and send it to everyone you know. We also desperately need funds to head off this attack in the weeks and months to come. Thank you for your support. Together we will take back citizen control over organic standards and preserve organic integrity.

Take action here:

http://www.democracyinaction.org/oca/campaign.jsp?campaign_KEY=1242

"You must be the change you wish to see in the world." - Mahatma Gandhi

Return to Index