Take Action: Water Quality Standards

Designated Uses Action Checklist

1) Develop the list of existing uses in your watershed.

2) Get a copy of your water quality standards. Go to EPA’s water quality standards website at www.epa.gov/wqsdatabase/.

3) Identify which designated uses your water quality agency has included in the state-wide standards. Compare them to your list of uses.

4) Determine which uses have been designated specifically for the rivers, lakes, streams, wetlands and estuaries in your watershed.

5) Identify any waters whose existing uses may not be adequately protected by the uses that have been designated.

6) Provide your water quality agency with information (pictures, newspaper articles, personal letters, notes from your interviews with river users, etc.) to demonstrate the full range of existing uses for each waterbody.

7) Identify any waters without recreation or aquatic life designated uses. Ask for a “use attainability analysis” (scientific evaluation) for each.

8) Watch for proposals to remove uses or “downgrade” waterbodies. Insist on “use attainability analyses” and defend against removal of any uses that are existing.

9) Support or initiate the designation of any additional uses necessary.

Water Quality Criteria Action Checklist

1) Compile a list of characteristics that need to be monitored and managed to fully protect uses in your watershed.

2) Get a copy of your water quality standards. Most states have them available online, but you can also use EPA’s website at www.epa.gov/wqsdatabase/.

3) Review the general narrative criteria that apply across the state.

4) Review the numeric criteria developed to protect existing and designated uses in your watershed. Is the state missing important criteria that you identified? What else should be measured, monitored and controlled through permits?

5) Determine which water quality parameters are particularly important in your watershed.

6) Identify how protection differs between designated uses.How does the temperature criterion change from “cold water fishery” to “warm water fishery?” How does the bacteria criterion change from swimming to boating?

7) Build a team of technical advisors consisting of biologists, chemists, hydrologists, toxicologists, etc.

8) Make a list of state-wide and watershed specific criteria that may not be strong enough to protect the uses in your area; develop your case for improving these criteria.

9) Make your case during the Triennial Review or in a petition process.

10) Make sure that any caveats or regionally specific characteristics stated in EPA criteria guidance documents are fully considered when criteria are established, permits are written and watershed restoration plans (TMDLs) are developed.

11) Insist that permits and watershed restoration plans (TMDLs) in your watershed are based on the appropriate criteria.

Antidegradation Action Checklist

1) Use River Network's state-by-state antidegradation database to find your state's antidegradation policy and implementation procedure.

2) Compare your agency’s policy to the federal policy. Note any sections that are less protective than the federal policy as well as any that seem unclear or incomplete.

3) If your state has implementation procedures, review them carefully. Do they seem adequate to turn policy into everyday action? If implementation procedures have not been developed, insist that the state agency do so. Use the federal regulations (40CFR131.12(a)) to make your point.

4) Ask officials with your agency whether and how the policy is applied to permitting decisions (e.g., NPDES, 404, 401) in your watershed. Ask for recent examples. Is there documentation of the review? Insist on it.

5) Document any instances when you believe the policy should have been applied but it wasn’t. Put your concerns about the adequacy of the policy or its implementation in writing and discuss them with officials at your water quality agency and the regional office of the EPA.

6) When new permits are proposed or old ones renewed, get involved to make sure the antidegradation procedures are fully and faithfully followed. The antidegradation policy applies beyond permits to “activities,” but it is easier to evaluate the process through NPDES permits and 401 certification of federal permits.

7) If improvements in the state’s policy and procedures are needed, work with other public interest groups to secure them through the Triennial Review or a petition.