Peter Nielsen, Clark Fork Coalition 



• We don't know what level of algae growth is acceptable 

 in the Clark Fork, but we do know that what is out there 

 is excessive. There are DO violations, and algal growth 

 is obnoxious. The growth of algae must not impair 

 beneficial uses. 



• There has been strong support in the community in the 

 last few years for efforts to limit nutrients in the 

 Clark Fork (i.e., the pulp mill, WWTP, phosphate ban). 

 There is a widespread belief that the Clark Fork is 

 "grungy" . 



• There is no detail in the report regarding rooted plants 

 (Eurasian milfoil) in the Fend Oreille River. The report 

 should identify the plant, discuss the rapid rate of 

 growth and spread, and discuss the perceived threat that 

 it will invade the Clark Fork system. 



Response: The text has been modified on page 3-91 and on 

 pages 5-13 and 5-14. 



• The issue of nondegradation standards should be explained 

 more thoroughly in the report. There is a difference of 

 opinion as to what constitutes compliance with 

 nondegradation rules. 



Response: The Water Quality Bureau is responsible for 

 interpreting and enforcing nondegradation rules on a case- 

 by-case basis subject to concurrence by the Board of 

 Health. It is not the purpose of this report to interpret 

 the rules. 



• Nutrients should be regarded as deleterious substances 

 as defined under the rules. Nutrient loading should be 

 limited to the amount actually discharged in 1982 (when 

 the rules were adopted) , rather than the design capacity. 

 If the WQB had allowed increased loading up to the design 

 capacity of the Missoula WWTP, it would have been almost a 

 doubling over 1982 actual discharge. Nutrient loading to 

 the Clark Fork and Lake Pend Oreille cannot be limited if 

 certain sources are allowed to double. 



• The action plan should recommend limiting total nutrient 

 loading from all sources. It should recognize that some 

 control of nonpoint sources and some additional control of 

 MPDES permits may also be necessary. 



Response: The recommendation has been modified 

 (page 5-16) . 



A-8 



