195 



Without these structural remedies the only short terro 

 relief fron non-point source pollution will follow from 

 "Best Management Practices" (BMP's) as outlined in section 

 319 of the CWA. BMP's are Presently not working because 

 they rely on voluntary compliance and because local agencies 

 have no standards with which to define NPDES stora drain 

 permit levels. There will be no such standard until 

 Congress invests in additional research to deteratine what 

 the spectrum of pollutants commonly are in stem drain 

 runoff. 



Our experience with the present syste» of self 

 wonitoring in water quality testing to insure compliance 

 with NPDES permit levels, is that this system allows 

 polluters to select testing schedules for which discharges 

 are miniiaal . only a systaia of remote monitoring by a 

 dispassionate third party can eliminate tuis Kind of 

 aliasing. Fuirtheraore , most testing is done in the 

 neighborhood of off shores outfalls, where people are not 

 swimming. Insufficient water quality monitoring resources 

 are directed towards shore stations at popular beaches. 

 Since surf zone pollution is due to episodic non-point source 

 runoff events, the likelihood of infrequent shore testing 

 providing adequate warning to bathers is remote. in 

 addition, there needs to be a uniform archival format for 

 reporting water test results so that screening for 

 violations can b« automated by computer. Under the present 

 non-'uniform reporting arrangements, thousands of violations 

 lie unnoticed in EX>A files. A good example of this was 

 brought to light by the Surfrider Foundation litigation 

 against 2 pulp mills for over 40,000 previously unnoticed 

 violations of the CWA. 



Finally, section 404 of the CWA needs to be 

 strengthened to protect our existing wetlands. These are 

 Natures natural urban runoff treatment systems. In fact 

 Congress should give consideration to wetlands restoration 

 as Q remedial approacih to the urban runoff problem. 



sinoerely, 



Scott A. J^nxins, PhD 

 Environmental Director 



o 



73-065 0-93 (204) 



