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| Home > Issues & Actions: UAAs |
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You Can Help Keep Your Stream Safe for Recreation!
Submit Information on Your Stream by August 31, 2008
The Missouri Department of Natural Resources (DNR) has made its recommendations for which streams will have protections against bacteria removed -- that is, which of Missouri's streams will be left unsafe for swimming and other recreational use.
Before final decisions are made on these streams by the state Clean Water Commission (CWC) this fall, however, you will have the opportunity to give them information about how your stream is used by you and others. If anyone has used these streams, at any time since 1975, in ways that could expose them to bacteria, the streams must be made safe for swimming and other recreation -- regardless of DNR's recommendations.
Please check these lists of streams DNR is recommending to lose protections and streams it is recommending keep protections. If streams you know are on either list, you can use this Recreational Use Comment Form to tell the state how you have used them.
While it's critical that the state hear from you about streams most in danger of losing protections, it's also important to tell them about your use of streams on which they're currently considering keeping protections. Without evidence of recreational use, the state can decide to remove protections on any of these streams. But your information about recreational use can keep them clean and safe forever.
Why is the State Trying to Make Some of Missouri's Streams Unsafe to Swim and Play In?
Until 2005, only relatively few streams in Missouri met the Clean Water Act's goal of being "swimmable" -- a goal of making all the nation's streams and lakes safe for swimming by 1983. In 2005, the state was finally forced to protect all of Missouri's classified streams from bacterial pollution through the settlement of a lawsuit brought by the Missouri Coalition for the Environment. But since then, the state has been trying to remove protections, stream by stream, that make water recreation safe.
What is bacterial pollution?
It's the bacteria -- fecal coliform, E. coli, and many others -- that exists in human sewage. When sewage wastewater is disinfected, that bacteria is killed before the treated wastewater is discharged to streams and lakes. When that wastewater is not disinfected, bacteria released to streams and lakes poses a significant health hazard, leaving those who swim and play in those waters susceptible to typhoid fever, hepatitis, dysentery, gastroenteritis, ear infections, and other illnesses.
Why is the state trying to remove protection from bacterial pollution?
The state's Department of Natural Resources (DNR) issues permits to thousands of wastewater treatment facilities, run by cities, towns, industries, private subdivisions, mobile home parks, service stations, etc., that allows them to discharge treated wastewater to streams and lakes. Upgrading those facilities to disinfect their wastewater costs money -- though still only a small part of the overall cost of their operations. But DNR listens closely to facility operators -- more so than to the public -- and it's looking for ways to not cost them money.
What is the state doing?
To remove bacteria protections and allow wastewater treatment facilities to escape the costs of disinfection, the state has to remove from each stream the "designated use" of "whole body contact recreation" (any activity that might get you totally wet -- like swimming, kayaking, water skiing, jet skiing, snorkeling, or rigorous playing). Once "whole body contact recreation" (WBCR) is determined something that isn't and can't be done in a stream, the protections (in this case, disinfection) provided by the designated use can be removed. To do this, a "study" called a Use Attainability Analysis (UAA) is done on the stream where the state is looking to remove the WBCR use designation and the requirement for disinfection.
So what's wrong with doing UAAs?
DNR is doing UAAs on every stream where there is a discharge, as the facilities' permits come up for renewal. Since 2005, DNR has done or contracted for over 700 UAAs -- at taxpayer expense! Remember, though, that the federal Clean Water Act goal is for all streams to be protected for swimming. Removing WBCR use (or the possibility of swimming) should be a very rare action, not something done routinely.
UAAs are supposed to be very rigorous studies, with the burden of proof on those that would remove WBCR use. Instead, DNR has made UAAs as easy (and cheap for wastewater facilities) as possible, and most have been done very sloppily, not even meeting the low standards DNR has set for UAAs. In some cases, they have even been done on the wrong stream -- and still the state approved removing the WBCR use.
The state is deciding to remove bacterial protections almost solely on the basis of how deep the stream is. If the stream doesn't have pools at least a meter (about 3 feet) deep or if it doesn't average at least 0.5 meter (about 1 1/2 feet) deep, measuring from stream edge to edge, the state doesn't figure people can get totally wet in it. Any child, splashing and playing in a stream 6 inches deep and getting water in their mouth, nose, ears, and cuts, would certainly prove them very wrong. Shouldn't Missouri's streams be safe for kids to play in?
DNR doesn't require that UAAs include information about whether and how people actually use the stream. But the Clean Water Act says that existing uses of a stream -- even those that have occurred only once since 1975 -- must be protected. If people have swum or played in the stream since 1975, the stream and the people who use it are supposed to be protected. Shouldn't the state show concern for its citizens and the law by insisting that local residents be asked if they swim and play in a stream before bacterial protections are removed?
What can I do?
See if streams you use are on the list of those where removal of bacterial protection is recommended or those where recommendations are to retain protection.
If a stream you use is on either list, send in to DNR this short Recreational Use Comment Form (Word document). If you can show that people have used the stream in ways that can get them totally wet at any time since November 28, 1975, the state must protect it for recreational use and require disinfection of wastewater. Including a map (hand-drawn or copied) showing exactly where you use the stream will help DNR make sure they protect that portion of the stream. Please also send an email to us at dsherburne@moenviron.org telling us what stream you've sent in information on.
Pass the word to anyone you know who uses and cares about Missouri streams! Tell them to visit the Missouri Coalition for the Environment UAA webpage (www.moenviron.org/UAA.asp).
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