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Published on Tuesday, September 3, 2013

Human health water quality standards (Fish consumption rate)

The ongoing discussions about increasing water quality standards based on human health and an increased fish consumption rate are of keen interest to cities. These discussions could potentially result in very significant changes to the way wastewater and stormwater are managed in communities around the state.

AWC continues to participate in the policy forums and delegates table discussions that the Department of Ecology has been convening. These forums are an opportunity for the various parties to discuss the sometimes very technical regulatory decisions that the Department will be making and share their perspectives as the Department designs these standards. Our main message remains that cities are supportive of clean water and safe fish from those waters. We are not opposed to adjustments to the formula to more accurately reflect the fish consumption patterns of our neighbors who eat a lot of fish. What we want to see out of this process is a standard that can be met where cities across the state will not find themselves out of compliance or facing uncertainty about permit renewals. We need to see implementation tools that will be successful, stable, and not open jurisdictions across the state to legal liability for standards that are not achievable by existing technology.

In addition to these forums with the Department of Ecology, cities have a direct voice with Governor Inslee who has appointed Bellingham Mayor Kelli Linville to join an advisory committee to help inform the Governor on these issues. We appreciate Mayor Linville's willingness to provide this critical service for cities around the state.

Delegates’ table meetings are scheduled in September and November, with a full draft rule expected this winter (early 2014).

Key issues that we'll be looking at when the rule comes out include:

  • Treatment of salmon and other fish that get either a portion or none of their toxic load from Washington waters.
  • Treatment of PCBs and mercury that Ecology has indicated will get special treatment because they are very difficult to address.
  • Implementation tools and their effectiveness and stability.
  • Relative Source Contribution (on the table is to make these water quality standards even more strict to account for toxics coming from unregulated sources).

We will continue to keep you updated on the progress of this effort, and if you have any questions or want any more detail, please contact Carl Schroeder.