Every three years the Kentucky Department of Water (KDOW) produces a detailed review of its Water Quality Standards (WQS) in what is called the Triennial Review. The Triennial Review WQS become an overarching guide for protecting our creeks, streams, rivers and lakes. There will be a public comment hearing where citizens and organizations are invited to voice their opinions and critique changes to the WQS. The meeting will be held at 6p, July 23 in Frankfort at the Energy and Environment Cabinet, Training Room B, 300 Sower Boulevard. We invite you to join us there and show your support for keeping our state’s waterways healthy and safe for recreation.
KWA has notified the KDOW that we will be there to offer our thoughts on proposed amendments. Some of which we liked, and some of which we think need improvement.
We also encourage you to weigh in on the amendments. To do so, you can send an email to: water @ky.gov. Below is a pre-written letter with comments that reflect our objections to the WQS changes. We encourage you to personalize the message by adding that you are a paddler, fisherman, swimmer or boater who is concerned about how these changes could impact your recreation. (Please add your name and address at the bottom.) Then copy and paste the message into an email and send it to the link above.
As always, we ask that your additional comments be respectful in tone and content.
If you would like more detail about the changes, you can download and read the KDOW amendments here.
Division of Water
300 Sower Blvd., 3NW 36WK
Frankfort, KY, 40601
ATTN: Carole Catalfo, Esq.
Internal Policy Analyst, RPPS
SENT VIA ELECTRONIC MAIL to firstname.lastname@example.org
RE: Comments on the 2019 Triennial Review
Dear Ms. Catalfo and Director Goodmann,
As a Kentucky resident, I care deeply about our waterways. I submit these comments on the proposed changes to Kentucky’s water quality standards.
The Division has proposed to allow Primary and/or Secondary Recreation Uses to be suspended or removed in certain instances. I strongly object to allowing Combined Sewer Overflow Control Plans and financial capacity analyses to substitute for the Economic Guidance EPA developed specifically to assess the suspension or removal of uses of our waterways. The Combined Sewer information was never intended to be a justification to suspend or remove recreational uses.
I also object to allowing the removal or suspension of recreational uses for up to 5 years. The Clean Water Act requires the Division to evaluate the justification of these decisions every 3 years.
Kentucky’s waters have a rich and diverse mussel and fish population and controlling the discharge of ammonia is critical for the protection of our mussel beds. In 2013, EPA issued new criteria for ammonia to protect mussels and 6 years later, it is time for Kentucky to adopt these national criteria.
I am also concerned about harmful algae blooms in our waterways and request that after more than a decade of research the Division propose new limits on nitrogen and phosphorus pollution to control nutrients in our waters.
I support the addition to fifty-seven new Outstanding State Resource Water and twenty-nine Exceptional waters. Likewise, I support the proposed changes to clarify that the Division can establish more stringent water criteria to protect an Outstanding State Resource Water.
Thank you for the opportunity to comment.