On Friday, Riverkeeper submitted comments to EPA Region 10 urging EPA to consider higher fish consumption rate numbers for Idaho as to be more protective of current recreational and subsistance users.
In short, the more fish a state or a people eat, the better water quality standards that state is going to adopt. You might recall last year when Oregon made news by setting the highest fish consumption rate in the U.S. and what a victory for human health and water quality that was. Well both Washington and Idaho are in the midst of the same process, processes Riverkeeper is paying close attention to. For the purpose of this blog post and this particular comment letter we sent, we’ll be talking about Idaho.
At the end of the day, it comes down to human health. Riverkeeper is committed to not only ensuring clean water, but healthy communities. And with a low fish consumption rate, the latter becomes quite difficult.
Consider this quote from Columbia Riverkeeper staff attorney Lauren Goldberg in a blog post she wrote about Washington’s fish consumption rates:
“While many of us have the luxury of shifting our diets away from—or completely foregoing—otherwise healthy, often abundant, locally caught fish because of toxic contamination, this isn’t a solution. Low income families, immigrants with traditions deeply rooted in catching fish for the dinner table, and tribes who have fished the Northwest’s great rivers since time immemorial are disproportionately impacted by our society’s failure keep dangerous toxic pollutants out of our rivers and fish.”
In Idaho, EPA is considering a fish consumption rate of 17.5 gpd grams/day in areas not supporting salmon and steelhead (the Spokane River). In our letter to EPA Region 10, we point out that 17.5 is far too low, considering that in 2007, the Agency for Toxic Substances and Disease Registry calculate a fish consumption rate of 42 grams/day for recreational anglers on The Spokane River. But probably stronger is the case made for subsistance fishing. Subsistance uses on the Spokane River are much higher. The Spokane Tribe’s current fish consumption rates reflect a local subsistance rate much greater than the 17.5 grams/day being considered by EPA. The Tribe’s current rate is set at more than 80 grams/day and is proposed to be increased to more than 800 grams/day.
In fact, even EPA’s own guidance calls for the use of a much higher default rate of subsistance users – 142.4 grams per day.
This might all look like nitpicking on grams per day, but the number is important in that it helps dictate water quality standards. Water quality standards are the basis for protecting and regulating the quality of surface waters in the United States. The standards implement portions of the federal Clean Water Act by specifying the designated and potential uses, such as fishing, swimming and drinking water, of waterbodies in the state.
This is something we’ll no doubt be very active on in the coming months and year, both in Idaho and Washington. If you’d like more information or to find out how you can get involved in this, feel free to leave a comment or email me at bart at cforjustice dot org.
