Water Quality: EPA Should Improve Guidance and Support to Help	 
States Develop Standards That Better Target Cleanup Efforts	 
(19-JUN-03, GAO-03-881T).					 
                                                                 
Water quality standards comprise designated uses and water	 
quality criteria. These standards are critical in making	 
accurate, scientifically based determinations about which of the 
nation's waters are most in need of cleanup. GAO examined the	 
extent to which (1) states are changing designated uses when	 
necessary, (2) EPA is assisting states toward that end, (3) EPA  
is updating the "criteria documents" states use to develop the	 
pollutant limits needed to measure whether designated uses are	 
being attained, and (4) EPA is assisting states in establishing  
criteria that can be compared with reasonably obtainable	 
monitoring data.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-881T					        
    ACCNO:   A07269						        
  TITLE:     Water Quality: EPA Should Improve Guidance and Support to
Help States Develop Standards That Better Target Cleanup Efforts 
     DATE:   06/19/2003 
  SUBJECT:   Environmental monitoring				 
	     Standards evaluation				 
	     Water pollution control				 
	     Water quality					 
	     EPA Total Maximum Daily Loads Program		 

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GAO-03-881T

Testimony Before the Subcommittee on Water Resources and Environment,
Committee on Transportation and Infrastructure, House of Representatives

United States General Accounting Office

GAO For Release on Delivery Expected at 10: 00 a. m. EDT Thursday, June
19, 2003 WATER QUALITY

EPA Should Improve Guidance and Support to Help States Develop Standards
That Better Target Cleanup Efforts

Statement of John B. Stephenson, Director Natural Resources and
Environment

GAO- 03- 881T

The extent to which states are changing designated uses varies
considerably. Individual states made anywhere from no use changes to over
1,000 use changes during the 5- year period, from 1997 through 2001.
Regardless of the number of use changes states made, nearly all states
report that some water bodies within their states currently need changes
to their designated uses. To do so, many states said they need additional
EPA assistance to clarify the circumstances in which use changes are
acceptable to EPA and the evidence needed to support those changes.

While EPA has developed and published criteria for a wide range of
pollutants, the agency has not updated its criteria documents to include
sedimentation and other key pollutants that are causing approximately 50
percent of water quality impairments nationwide. In addition to needing
new criteria documents, states need assistance from EPA in establishing
criteria so that they can be compared with reasonably obtainable
monitoring data. Changing either designated uses or criteria is considered
a standards

modification. Twenty- two states reported that an improvement in the
process for changing designated uses would result in different water
bodies being slated for cleanup; 22 states also reported that an
improvement in the process for modifying criteria would have that effect.
Collectively, 30 states would have different water bodies slated for
cleanup with an improvement in the process of modifying standards.

States Reporting That Different Water Bodies Would Be Slated for Cleanup
if the Process of Changing Standards Were Improved

Water quality standards comprise designated uses and water quality
criteria. These standards are

critical in making accurate, scientifically based determinations about
which of the nation*s waters are most in need of cleanup. GAO examined the
extent to which (1) states are changing designated uses when necessary,
(2) EPA is

assisting states toward that end, (3) EPA is updating the *criteria
documents* states use to develop the pollutant limits needed to

measure whether designated uses are being attained, and (4) EPA is
assisting states in establishing

criteria that can be compared with reasonably obtainable monitoring data.
GAO recommended in its January 2003 report that the Administrator, EPA (1)
provide additional

guidance regarding use changes, (2) follow through on plans to assess the
feasibility of establishing a clearinghouse of approved use

changes, (3) set a time frame specifically for the development of sediment
criteria, (4) develop

alternative, scientifically defensible monitoring strategies that states
can use to determine if water bodies are meeting their water quality
criteria, and (5) develop guidance and a training strategy to help EPA
regional staff in determining the scientific defensibility of proposed
criteria modifications. EPA agreed with

GAO*s recommendations and plans to take steps to address them.

www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 881T. To view the full product,
including the scope and methodology, click on the link above. For more
information, contact John B. Stephenson at (202) 512- 3841 or stephensonj@
gao. gov. Highlights of GAO- 03- 881T, a report to the

Subcommittee on Water Resources and Environment, Committee on
Transportation and Infrastructure, House of Representatives

June 19, 2003

WATER QUALITY

EPA Should Improve Guidance and Support to Help States Develop Standards
That Better Target Cleanup Efforts

Page 1 GAO- 03- 881T Water Quality Mr. Chairman and Members of the
Subcommittee: Thank you for the opportunity to discuss our work assessing
the

Environmental Protection Agency*s (EPA) and states* actions under the
Clean Water Act to improve water quality standards. Water quality
standards are critical in making accurate, scientifically based
determinations about which waters are most in need of attention. Without
accurate standards, our nation runs the risk of wasting valuable resources
by *overprotecting* some waters or facing unacceptable environmental
consequences by *underprotecting* others.

Water quality standards comprise two key components* designated uses and
water quality criteria. States are responsible under the Clean Water Act
both for determining uses and for setting criteria. Both actions require
EPA approval.

Designated uses identify the purposes for which a given body of water is
intended to serve, such as drinking water, contact recreation (e. g.,
swimming), and aquatic life support (e. g., fishing). Water quality
criteria are used to determine whether a water body is achieving its
designated uses by specifying pollutant limits, such as the maximum
allowable concentration of a pollutant, or an important physical or
biological characteristic that must be met (for example, an allowable
temperature range). To develop criteria, states rely heavily on EPA-
developed *criteria documents.* These documents contain the technical data
that help states

adopt pollutant levels that, if not met, may preclude a water body from
supporting its designated uses. States may adopt these criteria as
recommended by EPA, adapt them to meet state needs, or develop their own
criteria using other scientifically defensible methods.

The Clean Water Act also requires that states periodically review their
standards and revise them as needed. Before any revisions can take effect,
however, a state must submit them to its EPA regional office for approval.
Periodic review and revision of water quality standards is important
because the standards serve as the foundation of several water quality
programs, such as the Total Maximum Daily Load (TMDL) program. Under this
key program, waters that do not achieve water quality standards are listed
as impaired and then targeted for cleanup. According to EPA, over 20,000
bodies of water throughout the United States are impaired by one or more
pollutants.

In recent years, questions have been raised as to whether current water
quality standards are accurate and, therefore, whether the right waters
are

Page 2 GAO- 03- 881T Water Quality being targeted for cleanup. My
testimony will discuss our January 2003 report on this subject, which was
prepared at this Subcommittee*s

request. 1 As requested, we examined the extent to which (1) states are
changing designated uses when necessary, (2) EPA is assisting states
toward that end, (3) EPA is updating the criteria documents states use to
develop the pollutant limits needed to measure whether designated uses are
being attained, and (4) EPA is assisting states in establishing criteria

that can be compared with reasonably obtainable monitoring data. To
respond to the request, we conducted a Web- based survey of the 50 states
and the District of Columbia. We also interviewed officials from the 10
EPA regional offices and conducted site visits to Kansas, Montana, and
Ohio. We also met with, and obtained information from, officials from
EPA*s headquarters and the Association of State and Interstate Water
Pollution Control Administrators. Finally, we interviewed representatives
of various interest groups, such as Earthjustice and the American Farm
Bureau Federation.

In summary, Mr. Chairman, we found the following:  The extent to which
states are changing designated uses varies

considerably. Individual states made anywhere from no changes to over
1,000 changes during the 5- year period, from 1997 through 2001.
Regardless of the number of use changes states have made to date, however,
nearly all states reported that they have water bodies within their states
that currently need changes to their designated uses. According to the
states, they have not made needed designated use changes because of a
number of barriers, including inadequate monitoring data and resistance
from interest groups and affected parties. Importantly, another key reason
has been uncertainty over the circumstances in which use changes are
acceptable to EPA and the evidence needed to support those changes.

 Many states said they need additional assistance from EPA to make
accurate and defensible decisions on what some believe will be a much
larger number of designated use changes in coming years. Specifically,
they cited a need for additional EPA guidance to clarify both the
circumstances under which use changes are acceptable and the type of

1 U. S. General Accounting Office, Water Quality: Improved EPA Guidance
and Support Can Help States Develop Standards That Better Target Cleanup
Efforts, GAO- 03- 308 (Washington, D. C.: Jan. 30, 2003).

Page 3 GAO- 03- 881T Water Quality evidence needed to support those
changes. EPA headquarters officials acknowledge this need and have formed
a national working group to

develop additional guidance on designated use changes. Such guidance would
also (1) help clarify to EPA regional officials what state- proposed
changes are acceptable and (2) promote more consistent review and approval
policies across EPA*s 10 regional offices.

 As required, EPA has developed and published criteria for a wide range
of pollutants. However, EPA has not developed criteria for sedimentation
(e. g., sand and silt accumulation) and is currently developing the
complex criteria needed for nutrients (e. g., phosphorus from fertilizers
and nitrogen from animal waste). According to EPA data, sedimentation and
nutrients are key pollutants responsible for a relatively large share of
the nation*s impaired waters. Hence, it is not surprising that states
responding to our survey rank these two pollutants as their highest
priorities for criteria development.

 Even when EPA has developed criteria documents, some states have
reported difficulty in using the documents to establish criteria in such a
way that the criteria can be easily compared with reasonably obtainable
monitoring data. As a related matter, states also expressed difficulty in
modifying the criteria they already have in place, when necessary, to
reflect new data or changing ecological conditions. While most states
cited resource constraints as a barrier that affects their ability to make
criteria modifications, more than half of the states also cited EPA*s
approval process* noting, for example, insufficient assistance from their
respective EPA regional offices in helping them understand the data
necessary to

justify a criteria modification. The difficulty states have had in
developing accurate water quality standards has important implications for
their efforts to correctly identify which of their waters are impaired. If
they cannot use their standards to

accurately target their impaired waters, they risk focusing their limited
resources on cleaning up the wrong water bodies and/ or exposing their
citizens to health and environmental risks. Thirty states reported in
response to our survey that if EPA improved the process of modifying
standards through changes to designated uses and/ or criteria, they would
identify different waters for TMDL development. Significantly, this total
does not reflect the effects on lists of impaired waters of new criteria
for sedimentation and other pollutants being developed by EPA and the
states. These criteria are also likely to affect which waters states list
as impaired.

Page 4 GAO- 03- 881T Water Quality Designated uses are the purposes that a
state*s waters are intended to serve. Some waters, for example, serve as a
drinking water source, while

others are designated to serve as a source of recreation (swimming or
boating) and/ or to support aquatic life. The state must also develop
water quality criteria, which specify pollutant limits that determine
whether a water body*s designated use is achieved. These water quality
criteria can be expressed, for example, as the maximum allowable
concentration of a given pollutant such as iron, or as an important
physical or biological characteristic that must be met, such as an
allowable temperature range. To develop water quality criteria, states
rely heavily on EPA- developed

*criteria documents.* These documents contain the technical data that
allow states to develop the necessary pollutant limits. EPA is responsible
for developing and revising criteria documents in a manner that reflects
the latest scientific knowledge. States may adopt these criteria as
recommended by EPA, adapt them to meet state needs, or develop criteria
using other scientifically defensible methods.

States are also required to periodically review both their waters*
designated uses and associated criteria, and make changes as appropriate.
Before those changes can take effect, the state must submit them to EPA

and obtain approval for them. EPA is required to review and approve or
disapprove standards changes proposed by a state within 60 to 90 days.

Figure 1 illustrates how states use water quality standards to make key
decisions on which waters should be targeted for cleanup. States generally
determine if a water body*s designated use is achieved by comparing

monitoring data with applicable state water quality criteria. If the water
body fails to meet the applicable standards, the state is required to list
that water as *impaired*; calculate a pollution budget under EPA*s Total
Maximum Daily Load program that specifies how compliance with the standard
can be achieved; and then eventually implement a cleanup plan. Thus, as
noted in 2001 by the National Academy of Sciences* National Research
Council, 2 water quality standards are the foundation on which the entire
TMDL program rests: if the standards are flawed, all subsequent steps in
the TMDL process will be affected.

2 National Research Council, Assessing the TMDL Approach to Water Quality
Management

(Wash., D. C.: 2001) Background

Page 5 GAO- 03- 881T Water Quality Figure 1: Water Quality Standards as
the Basis for Cleanup Decisions

Page 6 GAO- 03- 881T Water Quality We asked the states to report the total
number of designated use changes they adopted from 1997 through 2001.
While some states made no use

changes, others made over 1,000 changes. At the same time, nearly all
states told us that designated use changes are needed. Twenty- eight
states reported that between 1 to 20 percent of their water bodies need
use changes; 11 states reported that between 21 and 50 percent of their
water bodies need use changes; and 5 states reported that over 50 percent
of their water bodies need use changes.

These percentages suggest that future use changes may dwarf the few
thousand made between 1997 and 2001. For example, Missouri*s response
noted that while the state did not make any use changes from 1997 through
2001, approximately 25 percent of the state*s water bodies need changes to
their recreational designated uses and more changes might be needed for
other use categories as well. Similarly, Oregon*s response noted that
while the state made no use changes from 1997 through 2001, the state
needs designated use changes in over 90 percent of its basins.

Many states explained their current need to make designated use changes by
noting, among other things, that many of the original use decisions they
made during the 1970s were not based on accurate data. For example, Utah*s
response noted that because of concerns that grant funds would be withheld
if designated uses were not assigned quickly, state water quality and
wildlife officials set designated uses over a 4- to 5- day period using
*best professional judgment.* As states have collected more data in
ensuing years, the new data have provided compelling evidence that their
uses are either under- or over- protective.

In addition to changing designated uses for individual waters to reflect
the new data, some states are seeking to develop more subcategories of
designated uses to make them more precise and reflective of their waters*
actual uses. For example, a state may wish to create designated use
subcategories that distinguish between cold and warm water fisheries, as
opposed to a single, more general fishery use. Developing these
subcategories of uses has the potential to result in more protective uses
in some cases, and less protective uses in others. States* Practices in

Changing Designated Uses Vary Widely

Page 7 GAO- 03- 881T Water Quality According to responses to our survey, a
key reason state officials have not made more of the needed designated use
changes is the uncertainty many

of them face over the circumstances in which use changes are acceptable to
EPA and the evidence needed to support these changes. EPA regulations
specify that in order to remove a designated use, states must provide a
reason as to why a use change is needed and demonstrate to EPA that the
current designated use is unattainable. To do this, states are required to
conduct a use attainability analysis (UAA). A UAA is a structured,
scientific assessment of the factors affecting the attainment of the use,
which may include physical, chemical, biological, and economic factors.
The results of a state*s analysis must be included in its submittal for a
use change to EPA. States that want to increase the stringency of a
designated use are not required to conduct a UAA.

UAAs vary considerably in their scope and complexity and in the time and
cost required to complete them. They can range from 15- minute evaluations
that are recorded on a single worksheet to more complex analyses that
might require years to complete. A Virginia water quality official
explained, for example, that some of the state*s UAAs are simple exercises
using available data, while others require more detailed analysis
involving site visits, monitoring, and laboratory work. In their responses
to our survey, states reported that the UAAs they conducted in the past 5
years have cost them anywhere from $100 to $300,000.

In 1994, EPA published guidance regarding use changes that specifies the
reasons states may remove a designated use. Nonetheless, our survey shows
that many states are still uncertain about when to conduct UAAs, or about
the type or amount of data they need to provide to EPA to justify their
proposed use changes. Forty- three percent of states reported that they
need additional clarifying UAA guidance. Among them, Oregon*s response
explained that water quality officials need guidance on whether a UAA is
required to add subcategories of use for particular fish species.
Virginia*s response indicated that the state needs guidance on what
reasons can justify recreational use changes, noting further that state
water quality officials would like to see examples of UAAs conducted in
other states. Louisiana*s response similarly called for specific guidance
on what type of and how much data are required for UAAs in order for EPA
to

approve a designated use change with less protective criteria. EPA
headquarters and regional officials acknowledge that states are uncertain
about how to change their designated uses and believe better guidance
would serve to alleviate some of the confusion. Of particular note,
officials from 9 of EPA*s 10 regional offices told us that states need EPA
Assistance and

Guidance Needed to Help States Make Defensible Designated Use Changes

Page 8 GAO- 03- 881T Water Quality better guidance on when designated use
changes are appropriate and the data needed to justify a use change.
Chicago regional officials, for

example, explained that the states in their region need clarification on
when recreational use changes are appropriate and the data needed to
support recreational use changes.

In this connection, an official from the San Francisco regional office
suggested that headquarters develop a national clearinghouse of approved
use changes to provide examples for states and regions of what is

considered sufficient justification for a use change. A 2002 EPA draft
strategy also recognized that this type of clearinghouse would be useful
to the states. The strategy calls on EPA*s Office of Science and
Technology to conduct a feasibility study to identify ways to provide a
cost- effective

clearinghouse. According to EPA, the agency plans to conduct the
feasibility study in 2004. EPA headquarters officials have also formed a
national working group to

address the need for guidance. According to the officials, the group plans
to develop outreach and support materials addressing nine areas of concern
for recreational uses that states have identified as problematic. In
addition, the group plans to develop a Web page that includes examples of
approved recreational use changes by the end of 2004. The national work
groups* efforts may also help address another concern cited by many
states* a lack of consistency among EPA*s regional offices on how they
evaluate proposals by their states to change designated uses.

Some states* water quality officials noted in particular that the data
needed to justify a use change varies among EPA regions. For example,
Rhode Island*s response asserted that the state*s EPA regional office
(Boston) requires a much greater burden of proof than EPA guidance
suggests or than other regional offices require. The response said that
EPA guidance on UAAs should be more uniformly applied by all EPA regional
offices. Several EPA regional officials acknowledged the inconsistency and
cited an absence of national guidance as the primary cause.

EPA headquarters officials concurred that regional offices often require
different types and amounts of data to justify a use change and noted that
inconsistency among EPA regional offices* approaches has been a
longstanding concern. The officials explained that EPA is trying to reduce
inconsistencies while maintaining the flexibility needed to meet
regionspecific conditions by holding regular work group meetings and
conference calls between the regional offices and headquarters.

Page 9 GAO- 03- 881T Water Quality While EPA has developed and published
criteria documents for a wide range of pollutants, approximately 50
percent of water quality impairments

nationwide concern pollutants for which there are no national numeric
water quality criteria. Because water quality criteria are the measures by
which states determine if designated uses are being attained, they play a
role as important as designated uses in states* decisions regarding the
identification and cleanup of impaired waters. If nationally recommended
criteria do not exist for key pollutants, or if states have difficulty
using or modifying existing criteria, states may not be able to accurately
identify water bodies that are not attaining designated uses.

Sedimentation is a key pollutant for which numeric water quality criteria
need to be developed. In addition, nutrient criteria are currently being
developed, and pathogen criteria need to be revised. Together, according
to our analysis of EPA data, sediments, nutrients, and pathogens are
responsible for about 40 percent of impairments nationwide. (See fig. 2.)
Not surprisingly, many states responding to our survey indicated that
these pollutants are among those for which numeric criteria are most
needed. 3 3 Specifically, when asked to identify the top three such
pollutants, the pollutants most

frequently cited were nutrients, followed by sediment and pathogens. EPA
Has Not Developed and

Updated Key Criteria Documents

Page 10 GAO- 03- 881T Water Quality Figure 2: Percent of Impairments
Nationwide Caused by Various Pollutants

Recognizing the growing importance of pathogens in accounting for the
nation*s impaired waters, EPA developed numeric criteria for pathogens in
1986* although states are having difficulty using these criteria and are

awaiting additional EPA guidance. EPA is also currently working with
states to develop nutrient criteria and has entered into a research phase
for sedimentation. EPA explained that the delay in developing and
publishing key criteria has been due to various factors, such as the
complexity of the criteria and the need for careful scientific analysis,
and an essentially flat budget accompanied by a sharply increased
workload. EPA also explained that for several decades, the agency and the
states focused more on point source discharges of pollution, which can be

Page 11 GAO- 03- 881T Water Quality regulated easily through permits, than
on nonpoint sources, which are more difficult to regulate. 4 Even when EPA
has developed criteria recommendations, states reported

that the criteria cannot always be used because water quality officials
sometimes cannot perform the kind of monitoring that the criteria
documents specify, particularly in terms of frequency and duration. Our
survey asked states about the extent to which they have been able to
establish criteria that can be compared with reasonably obtainable
monitoring data. About one- third reported that they were able to do so to
a *minor* extent or less, about one- third to a *moderate* extent, and
about one- third to a *great* extent. Mississippi*s response noted, for
example, that the state has adopted criteria specifying that samples must
be collected on 4 consecutive days. The state noted, however, that its
monitoring and assessment resources are simply insufficient to monitor at
that frequency. Mississippi is not alone: a 2001 report by the National
Research Council found that there is often a *fundamental discrepancy
between the criteria used to determine whether a water body is achieving
its designated use and the frequency with which water quality data are

collected.* To address this discrepancy, regional EPA officials have
suggested that EPA work with the states to develop alternative methods for
determining if water bodies are meeting their criteria, such as a random
sampling approach to identify and set priorities for impaired waters.

If a state believes that it can improve its criteria, it has the option of
modifying them* with EPA*s approval. In fact, states are required to
review and modify their criteria periodically. A state might modify a
criterion, for example, if new information becomes available that better
reflects local variations in pollutant chemistry and corresponding
biological effects.

In response to our survey, 43 states reported that it is *somewhat* to
*very* difficult to modify criteria. Not surprisingly, a vast majority of
states reported that a lack of resources (including data, funding, and
expertise) complicates this task. Nevada*s response, for example,
explained that, like

4 Point source discharges include discrete discharges from individual
facilities, such as factories and wastewater treatment plants. Nonpoint
sources of pollution are diffuse sources that include a variety of land-
based activities, such as timber harvesting, agriculture, and urban
development. States Need EPA

Assistance to Establish Criteria That Can Be Compared to Reasonably
Obtainable

Monitoring Data

Page 12 GAO- 03- 881T Water Quality many states, it typically relies on
EPA*s recommended criteria because of limited experience in developing
criteria as well as limited resources; in

many instances, developing site- specific criteria would better reflect
unique conditions, allowing for better protection of designated uses.
Significantly, however, more than half of the states reported that EPA*s
approval process serves as a barrier when they try to modify their
criteria. In this connection, respondents also noted that EPA*s regional
offices are

inconsistent in the type and amount of data they deem sufficient to
justify a criteria change. Some regional officials told us that this
inconsistency is explained, in part, by staff turnover in the regional
offices. Likewise, a

2000 EPA report found that less tenured staff in some regional offices
often lack the technical experience and skill to work with the states in
determining the *scientific feasibility* of state- proposed criteria
modifications. Our report concluded that additional headquarters guidance
and training of its regional water quality standards staff would help
facilitate meritorious criteria modifications while protecting against
modifications that would result in environmental harm.

Because designated uses and criteria constitute states* water quality
standards, a change in either is considered a standards modification. We
first asked the states whether an improvement in the process of changing
designated uses would result in different water bodies being slated for

cleanup within their states, and 22 states reported affirmatively. We then
asked the states whether an improvement in the process of modifying
criteria would result in different water bodies being slated for cleanup
within their states, and 22 states reported affirmatively. As figure 3
shows,

when we superimposed the states* responses to obtain the cumulative effect
of improving either designated uses or the process of criteria
modification, a total of 30 states indicated that an improvement in the
process of modifying standards (whether a change in their designated uses,
their criteria, or both) would result in different water bodies being
slated for cleanup. Improvements to

Designated Uses and Criteria Could Have a Large and Cumulative Impact on
Impaired Waters Lists

Page 13 GAO- 03- 881T Water Quality Figure 3: States Reporting That
Different Water Bodies Would Be Slated for Cleanup if Improvements Were
Made to the Process of Changing Standards

Importantly, the 30- state total does not reflect the impacts that would
result from EPA*s publication (and states* subsequent adoption) of new
criteria for sedimentation and other pollutants, nor does it reflect
states* ongoing adoption of nutrient criteria. As these criteria are
issued in coming years, states will adopt numeric criteria for these key
pollutants, which, in turn, will likely affect which waters the states
target for cleanup.

To help ensure that both designated uses and water quality criteria serve
as a valid basis for decisions on which of the nation*s waters should be
targeted for cleanup, we recommended that the Administrator of EPA take
several actions to strengthen the water quality standards program. To
improve designated uses, we recommended that EPA (1) develop additional
guidance on designated use changes to better clarify for the states and
regional offices when a use change is appropriate, what data are

Page 14 GAO- 03- 881T Water Quality needed to justify the change, and how
to establish subcategories of uses and (2) follow through on its plans to
assess the feasibility of establishing

a clearinghouse of approved designated use changes by 2004. To improve
water quality criteria, we recommended that EPA (1) set a time frame for
developing and publishing nationally recommended sedimentation criteria,
(2) develop alternative, scientifically defensible monitoring strategies
that states can use to determine if water bodies are meeting their water
quality

criteria, and (3) develop guidance and a training strategy that will help
EPA regional staff determine the scientific defensibility of proposed
criteria modifications.

According to officials with EPA*s Water Quality Standards Program, the
agency agrees with our recommendations, has taken some steps to address
them, and is planning additional action. They note that, thus far, EPA
staff have already met with a large number of states to identify
difficulties the states face when attempting to modify their designated
uses. The officials also noted that, among other things, they plan to
release support materials to the states regarding designated use changes;
develop a Web page that provides examples of approved use changes; and
develop a strategy for developing sedimentation criteria by the end of
2003.

Mr. Chairman, this completes my prepared statement. I would be happy to
respond to any questions you or other members of the Subcommittee may have
at this time.

For further information, please contact John B. Stephenson at (202) 512-
3841. Individuals making key contributions to this testimony included
Steve Elstein and Barbara Patterson. Other contributors included Leah
DeWolf, Laura Gatz, Emmy Rhine, Katheryn Summers, and Michelle K.
Treistman. Contact and

Acknowledgments

(360359)

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Contact: Web site: www. gao. gov/ fraudnet/ fraudnet. htm E- mail:
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U. S. General Accounting Office, 441 G Street NW, Room 7149 Washington, D.
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