W-98-31-III TMDL Comments Clerk Water Docket (MC-4101)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, DC 20460

RE: Opposition to Delay of Effective Date and Efforts to Weaken New TMDL Regulations

I oppose any delay of the effective date of the July 2000 Total Maximum Daily Load (TMDL) regulations and I oppose any effort to weaken these regulations. To delay or weaken the proposed TMDL regulations will be a major environmental and public health setback for the American people.

Delaying the effective date of the July 2000 regulations is the first step toward weakening the entire TMDL program to appease industry interests. The TMDL program today provides our best hope for cleaning up more than 20,000 polluted waterbodies across the nation. These waterbodies are listed as polluted because they do not meet the most basic goal of the Clean Water Act - safe waters for human recreation and wildlife. Any steps to weaken the TMDL program are actions that will condemn current and future generations to dirty water and unsanitary conditions. Here in Oklahoma, over 63% of rivers and streams, and over 44% of lakes, are too polluted to meet water quality standards to protect aquatic life. We can't afford any more delays.

Some states need to be forced to speed up TMDL development and implementation. In Oklahoma, we need more stringent TMDL requirements to prevent our waters from being wrongly taken off 303d lists, to ensure all impaired streams are put on the list and to force real progress in getting some meaningful TMDLs developed. Factory farms and corporate agriculture are the biggest polluters in this state. Entities like Tyson Foods, Farm Bureau and others are constantly pushing to remove streams from the impaired list and questioning the basis of listing decisions. Federal regulations are necessary to insure proper actions are taken by state agencies which are subject to much political pressure not to impose any requirements on agricultural sources of pollution.

In Oklahoma, there has been little progress in cleaning up our streams and lakes - they grow more polluted by uncontrolled nutrients, agricultural runoff and physical damage and dams with each passing day. Too many of our most precious streams and lakes are polluted and in need of TMDLs - for example, the Illinois River, the Mountain Fork , Lake Eucha and Lake Tenkiller. The lack of nutrient criteria and TMDLs is ruining water supplies of our major metropolitan areas, hurting recreation and damaging fish and wildlife uses. We are afraid to let our children swim anymore.

Reopening the TMDL regulations in order to weaken this critical Clean Water Act program will make matters worse for American citizens across the country living with polluted waters. Cleaning up the country's polluted lakes, rivers, streams and coasts is what the Clean Water Act requires and what the American public wants. It is time to move forward.

I urge you to reconsider your decision to reopen the TMDL regulations, and ask that EPA not delay or weaken the Clean Water Act's program for cleaning up the nation's polluted waters.

Sincerely,