# COLUMBIA RIVER INTER-TRIBAL FISH COMMISS ION 700 N E M ultn omah Str e et, S ui t e 12 00 Por t lan d , O regon 9 72 32

September 19 , 2014 Gina McCarthy, EPA Administrator USEPA Headqumiers William Jefferson Clinton Building 1200 Penn sy lvania Avenue, N.W. Mail Code: 1101A Washington, DC 20460 RE : F e deral Promulgation of Wa s hington State Water Quality Standards Dear Administrator McCmihy: (503) 238

- 0667 F (5 03) 2 35 -4228

www . c ritfc. o r g

On behalf of the Columbia River Inter- Tribal Fi sh Commission' s (CRITFC) member tribes

- the Confederate d Tribes of the Umatilla Indian Reservation, the Confederated Tribes of the Warm Springs Re s ervation of Oregon , the Confederated Tribes and Bands ofthe Yakama Nation, and the Ne z Perce Tribe- I been directed to express our concern over the continued delay in Washington State to r evise its inadequate water quality standards. As stewards of the Co lumbi a River, CRITFC supports the im plementation of regulations and programs that improve water quality to a level sufficient to protect our watershed from the harmful impacts of waterborne pollutants. CRITFC strongly endorses the position of Region 10 Administrator Dennis McLerran who recognize s that more stringent water qua lity standards are necessm·y than those currently proposed in Washington State to meet C lean Water Act requirements to protect the environment and the health of all peopl e living in the region. With their muc h higher fish consumption rate , our tribal members are subjected to far greater hazards from contaminants in our water than the genera l public. Whi le the human health criteria recently proposed by Governor Jn s lee recommends a higher fi s h con sumption rate for Wa s hington State, the cancer risk level would actually increa s e from 1 in 1 , 000 , 000 to 10 in 1, 000 , 000. The Governor ' s proposal puts tribal members at a heightened risk of expo s ure to unsafe bioaccumulative toxic chemica ls and does not safeguard the unique cultural , economic, and sub s istence relationship of our tribes to treaty guaranteed fishery resourc es . CRITFC sug g e s ts that EPA adhere to the recomm endations contained in the National E nvironmenta l Justice Advisory Counci l report "Fish Consumption and Environmental Ju s tice, November 2002" which calls for EPA to improve the quality of aquatic ecosystem s and protect the health of fish consuming peop l e. The recommendations include takin g stronger steps to prevent and reduce the r e lease of persi stent , bioaccumulative toxics into the nation' s aquatic re s ourc es by making full u s e of the authority of fed e ral environmental laws and the tru st re spon s ibility ofthe A ge nc y . Federa l promu lgati on of water qua lity standards in Washington State i s a n e x ample of how

Puttin g fi sh b ack in th e rive r s andp rotecti n

g th e wate r s h eds wh er e fis h l i veGina McCarthy, September 19 ,2014 Page 2 of2

EPA's authority cou ld be better asserted. To this end, CRITFC respectfully requests that EPA move ahead with federal promulgation of water quality standards in Washington State without further delay. CRITFC and EPA have built a lon g - standing relationship based upon a shared vi s ion of clean water for all people who inhabit the Columbia River Basin. We commend the actions that Administrator McLerran has taken in pushing for strong standards in Oregon and in delivering this message to other states in the region as well. If you would like to further discuss how our organization can work with EPA on this issue, please contact me or Dianne Barton at 503-238-0667. Sincerely,

Carlos Smith Chainnan Cc : Dennis McLerran, EPA Region I 0 Administrator Lisa Fe ldt , Act in g Deputy Administrator Ken Kopocis, Acting Assistant Administrator for Office of Water