From my backlog of e-mail, here is an idea for a new initiative. DEP is required to do a review of water quality standards every three years. In preparation for that, they solicited public comments last fall (available at:
Among the environmental groups, Appalachian Mountain Advocates recommended a standard for conductivity, John and Petra Wood recommended standards for conductivity, sulfates ad TDS, and Duane Nichols recommended a TDS standard.
Not surprisingly, First Energy wants to weaken the arsenic standard.
And AEP wants to limit the Category A (Public water supply) implementation, as well as restrict uses of the Stream Condition index (benthic insects), rescind the selenium Acute criterion, and weaken standards for mercury, beryllium, iron and aluminum (the aluminum and beryllium changes happened in the Legislature this year).
Although we missed the deadline for initial comments, it would be a good step for us to support a WQS for TDS or conductivity as an extra tool for Marcellus activities, and adding a sulfate standard would be useful for coal-related impacts, as this is the dominant toxicant in TDS, and needs a stand-alone standard.
Whaddya tink?
Jim Kotcon
P.S. Please keep the message form the "mole" below to ourselves.
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Here are some comments from a mole in the water office.
What I'm hearing is that it would be good for the environmentalists to request that DEP develop a sulfate criteria, that the Legislature needs to be lobbied to pass the TDS standard, and that they should be keeping up with what DEP's watershed assessment branch is doing with the fish IBI. Both our water quality standards group, Kevin Coyne and Watershed Assessment Branch, John Wirts are willing to meet with them to help them understand what DEP is doing. That used to happen but the enviros have not requested a meeting for a long time. They should try to meet with the staffers vs the politicos to get the best info. There is alot of room for intereference and influence on the fish IBI so it would be best not to let industry get the upper hand.
As far as the specifics below, it all looks good. DEP staff feels pretty confident about the fecal coliform/e coli switch and don't see much of a threat there, but welcome the comments. It is suggested that Michael Becher, Appalachian Mt. Advocates is knowledgeable on the Category A issue listed here, but this group is probably aware of that.