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8 



adjustments to reflect health effects and monitoring data developed since the 1986 

 criteria. To date only eight States, the District of Columbia, and several territories 

 and native american tribes have adopted the 1986 criteria. 



We applaud the bill's efforts (section 3(b)(2)] to ensure State adoption of 

 EPA criteria published under section 304(a)(9) of the Clean Water Act, however we 

 offer a modification. We believe the States should adopt EPA's published criteria 

 within a fixed time, such as three years, after EPA publishes updated guidance. If 

 a State fails to adopt the criteria within three years, EPA's criteria should become 

 applicable water quality standards, without further promulgation by EPA. We 

 believe adoption of criteria in this way will be the most cost effective and 

 expeditious route to ensure adequate protection of coastal recreational waters. 



Coastal Beach Water Quality Monitoring 



EPA agrees with the need for consistent monitoring practices as indicated in 

 H.R. 31. State and local governments should have adequate, consistent 

 monitoring practices. However, experience has shown us that there has been 

 resistance to the transition from the old criteria and monitoring methods. 

 Discussions with State and local governments indicate they may be reluctant to 

 invest in new equipment and training in order to use procedures with which they 

 are unfamiliar. 



Nonetheless, we will continue to encourage the State and local governments 

 to change to improved monitoring methods and criteria. We believe these improved 



