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6 

 less specific criteria that may better represent the actual 

 situation with regard to our present knowledge. 



While NOAA generally believes that the monitoring provisions of 

 H.R. 31 are reasonable, we remain concerned that the bill not 

 mandate new and expensive monitoring requirements on financially 

 strapped states and local governments which may be unnecessary. 

 H.R. 31 appears to provide some flexibility by calling for the 

 establishment of minimum requirements and by allowing the 

 Administrator of EPA to exempt certain coastal recreational 

 waters from the requirements. 



NOAA believes that the bill's requirements for development of 

 uniform methods of testing and monitoring beach environmental 

 quality should be a part of the comprehensive water quality 

 assessment and monitoring program which EPA and NOAA are directed 

 to develop pursuant to the recently enacted National Coastal 

 Monitoring Act (NCMA) , Title V of the NOAA Authorization Act of 

 1992. The NCMA specifically directs that EPA and NOAA should 

 establish monitoring guidelines and protocols to survey water 

 quality in coastal and Great Lakes waters. Thus, the requirement 

 in H.R. 31 for development and issuance of beach water quality 

 monitoring methods is already mandated by the NCMA, and we 

 believe should be developed in coordination with this larger 

 monitoring program. 



