172 



state Water Resources Cfxitroi Board July 15, 1993 



HR31 



The current Ocean Plan triennial review focuses on 22 high priority issues. Among 

 these are severai reiatedto contamination by pathogenic organisms: (1) further 

 examination of the adequacy of three bacterial indicator groups (total coliform, fecal 

 coliform and enterococcus) for protection of water-contact recreation; (2) extension 

 of existing boundaries of the water-contact zone; and (3) determination if stricter 

 standards are needed to protect human health in shellfish harvesting waters. 



The State Water Resources Control Board welcomes this opportunity to provide 

 testimony on HR 31. We applaud the efforts of Congressmembers Hughes, Saxton, 

 Gallo, Payne, Pallone, Roukema and Hochbrueckner in proposing legislation to 

 improve the quality of this nation's coastal recreation waters while making more 

 directly accountable those charged with protecting this fragile resource. While there 

 have been extensive studies relating to chemical pollution over past years, 

 microbiological issues have been somewhat neglected nationally. Congressional 

 Interest in microbiological issues as reflected in HR 31 should be supported. 



CONCERNS Wrm HR 31 



A Nationwide Standard 



While we agree with the intent of HR 31, we must voice our concern at the proposed 

 language recommending that nationwide water quality criteria for pathogens in 

 coastal recreation waters be created. First, HR 31 states that EPA must adopt 

 "water quality criteria for pathogens in coastal recreation waters". California does 

 not have criteria or standards for pathogens per se, but for indicator organisms 

 (total coliform, fecal coliform, and enterococcus). Another concern is based on the 

 fact that physical conditions on the west coast are very different from east and Gulf 

 Coast waters. For example, temperature, depth, and salinity regimes differ. What 

 may be protective of east coast waters may not be useful on the west coast. The 

 choice of a nationwide indicator organism for water contact bacterial standards 

 brings debate. 



-2- 



