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available of the risks incurred by surfers riding their 

 surfboards, or parsons wading or swimming near wastewater ocean 

 outfalls, points of urban or storm water runoff or marinas with 

 sewage holding tanks. 



While we are concerned about the increasing number of federally 

 mandated standards imposed on the states, we can appreciate the 

 need for having consistent minimum health standards among various 

 states. Coastal currents, as we know, do not recognize state, or 

 even national, boundaries. Our current frustrations with the 

 wastewater problems that affect our southern border are a good 

 example of that. We do not believe that federal criteria for 

 coastal recreational waters would present any significant 

 problems for California. We recommend, however, that when 

 establishing these standards attention be paid to the regional 

 differences in the physical and chemical conditions of different 

 coastal waters. Conditions such as temperature, depth and 

 salinity can vary significantly between West Coast and East Coast 

 or Gulf Coast waters. Therefore, standards that are developed 

 based on East Coast conditions may not provide adequate 

 protection in West Coast waters . 



We are concerned, however, over the impact of federally mandated 

 monitoring requirements. Our concerns relate to flexibility and 

 overall costs. Given the numerous variables associated with 

 bacterial monitoring in ocean waters which necessitate custom 

 designed monitoring programs to be effective, it is difficult to 

 envision a monitoring program designed at the federal level that 



