COLUMBIA RIVER INTER-TRIBAL FISH COMMISSION 

700 NE Multnomah Street, Suite 1200 

Portland, Oregon 97232 

September 19, 2014 

Gina McCarthy, EPA Administrator 

USEP A Headqumiers 

William Jefferson Clinton Building 

1200 Pennsylvania Avenue, N.W. 

Mail Code: 1101A 

Washington, DC 20460 

RE: Federal Promulgation of Washington State Water Quality Standards 

Dear Administrator McCmihy: 

(503) 238-0667 

F (503) 235-4228 

www.critfc.org 

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

Confederated Tribes of the Umatilla Indian Reservation, the Confederated Tribes of the Warm 

Springs Reservation of Oregon, the Confederated Tribes and Bands ofthe Yakama Nation, and the 

Nez Perce Tribe- I been directed to express our concern over the continued delay in Washington 

State to revise its inadequate water quality standards. As stewards of the Columbia River, CRITFC 

supports the implementation 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 recognizes that 

more stringent water quality standards are necessm·y than those currently proposed in Washington 

State to meet Clean Water Act requirements to protect the environment and the health of all people 

living in the region. 

With their much higher fish consumption rate, our tribal members are subjected to far greater 

hazards from contaminants in our water than the general public. While the human health criteria 

recently proposed by Governor Jnslee recommends a higher fish consumption rate for Washington 

State, the cancer risk level would actually increase from 1 in 1,000,000 to 10 in 1 ,000,000. The 

Governor's proposal puts tribal members at a heightened risk of exposure to unsafe bioaccumulative 

toxic chemicals and does not safeguard the unique cultural, economic, and subsistence relationship 

of our tribes to treaty guaranteed fishery resources. 

CRITFC suggests that EPA adhere to the recommendations contained in the National 

Environmental Justice Advisory Council report "Fish Consumption and Environmental Justice, 

November 2002" which calls for EPA to improve the quality of aquatic ecosystems and protect the 

health of fish consuming people. The recommendations include taking stronger steps to prevent and 

reduce the release of persistent, bioaccumulative toxics into the nation's aquatic resources by 

making full use of the authority of federal environmental laws and the trust responsibility ofthe 

Agency. Federal promulgation of water quality standards in Washington State is an example of how 

Putting fish back in the rivers and protecting the watersheds where fish live 
Gina McCarthy, September 19,2014 

Page 2 of2 

EPA's authority could 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 long-standing relationship based upon a shared vision 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 Feldt, Acting Deputy Administrator 

Ken Kopocis, Acting Assistant Administrator for Office of Water