NACWA submitted comments on April 24 to EPA’s recent Public Review Draft of Field-Based Methods for Developing Aquatic Life Criteria for Specific Conductivity.
The comments recognize that salinity, as measured by specific conductivity, can play an important role in overall water quality. However, NACWA does not support the proposed Draft Field-Based Methods as a mechanism for establishing water quality criteria to protect aquatic life. The Draft Field-Based Methods takes a serious deviation from traditional and standard science-based toxicological analysis in determining the toxic concentration thresholds for aquatic macroinvertebrates exposed to certain chemicals or pollutants and should not be used where there may be compliance implications.
Further, NACWA’s comments address how the clean water community will be disproportionately impacted if EPA determines its Draft Field-Based Methods are an appropriate means of establishing water quality criteria.
If members have any questions or comments, please contact Emily Remmel at 202/533-1839.