October 12, 2014
Dear Mr. Frederick:
Backcountry Hunters and Anglers has recently become aware of your decision to lower water quality protection standards regulating the amount of E.coli bacteria permitted in Wyoming surface waters. As we understand it, your August 20, 2014, decision to revise water quality standards pertaining to recreational use would result in a significant increase in levels of E.coli allowed in waters used by our members for primary contact recreation. Because of the potential impact to our members’ use and enjoyment of the state’s surface waters, and because we did not receive notice of the proposed revision, we respectfully request that you rescind your August 20, 2104, decision and re-open the comment period to allow potentially affected users an opportunity to review and comment on the revisions.
Wyoming Backcountry Hunters & Anglers is dedicated to speaking-up for the clean, wild waters that the fish, wildlife, and people of Wyoming depend on. Our members use Wyoming’s surface waters for fishing, hunting, and for a variety of other uses. As our organization’s name suggests, our members are dedicated to pursuing their activities in backcounty areas, far from roads and trailheads. When we venture into the backcountry, circumstances dictate that we must rely exclusively on naturally occurring surface waters, including creeks, springs and even seeps, for our survival. We use available water sources for cooking and camp chores, for quenching our thirst, for washing and rinsing off, and a variety of other essential uses, many of which create a potential for ingestion of water. In arid parts of the state, good quality surface water takes on even greater importance, as useable sources can be extremely rare and difficult to find.
It is our understanding that the Clean Water Act requires states to protect the quality of water needed to maintain existing uses. The uses of water by our members mentioned above are not hypothetical or imaginary; we fill our water bottles from streams and springs, we douse our heads to cool off; we brush our teeth with this water. The list of uses goes on-and-on. The change to a lower water quality standard that allows greater concentrations of E.coli bacteria in the water would threaten our recreation uses.
In conclusion, your August 20, 2014, decision to downgrade over 75% of the state’s surface waters to secondary contact recreation appears based on erroneous information and belief that low-flow streams are not used for primary contact information. I hope our letter helps you appreciate that this is certainly not the case in much of the state.
I hope that we may hear back from you soon regarding our concerns.
Southern Rockies Coordinator
Backcountry Hunters & Anglers
Cc: Wyoming DEQ Director
U.S. EPA Region 8 Administrator