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NWF Alert on Great Waters Program

Please note: Visit this document on the Great Lakes Natural Resource
Center web site for interesting links.  


          In early July, the U.S. EPA will seek public
     comments on whether additional measures are
     necessary to protect America's largest waters from
     air pollution, such as dioxin, mercury and PCBs. 
     The public will then have 30 days to comment on
     the EPA's "Adequacy Determination."


                   May 20, 1997

Dear Conservationist Activist:

     Many of America's major waterways are contaminated by
chemicals that fall from the sky.  The most deadly chemicals, such as
dioxin, PCBs, mercury, and DDT, are linked to infertility problems,
weakened immune systems and behavioral disorders in humans and
wildlife.  Some of these chemicals can also cause cancer if they
reach high levels in the body.  The major sources of these pollutants
are incinerators, coal fired power plants, and tailpipes of autos and

     Some of the waterways that are most important to many of
you are also the most threatened.  Once in the water, many of these
pollutants move up the food chain where they concentrate in fish and
humans at dangerously unsafe levels.   According to the U. S.
Environmental Protection Agency (EPA), air pollution is responsible

    * 90% of the mercury pollution in Lake Superior, making some
     fish unsafe to eat; 

    * more than half of the PCBs in Lakes Michigan, Superior and
     Huron -- the U.S. Public Health Service has concluded that
     these chemicals are a threat to people who eat Great Lakes
     fish, especially women and their children; and,

     * as much as 40% of the nitrogen pollution in the Chesapeake
     Bay, adding to nutrient levels that deplete waters of vital life
     giving oxygen.   
            Although, this information is at least three years old, new
information is expected to reaffirm air pollution as a major source of
water pollution.  One conclusion is clear: if you want to protect the
waters you care about most, stronger air protection measures are

Great Waters Program: a new tool to control air and water

     In 1990, Congress added a provision to the Clean Air Act
calling for the Great Waters Program.  Great Waters are defined as
the Great Lakes, Lake Champlain, Chesapeake Bay, and other
coastal waters.  This program tells the EPA to study the link between
air pollution and water quality in our Great Waters, and then to
determine whether existing emission standards and other control
measures are adequate to protect public and environmental health --
this is called an adequacy determination.  If the Agency determines
that current controls are not adequate, then the EPA must take
additional measures. 

     The Great Waters Program will be an effective tool to fight
both water and air pollution.  Because much of this air pollution
originates outside of the several Great Waters basins,  it is very likely
that any new measures must be implemented nationally.

NWF forces EPA to implement Great Waters Program

     Unfortunately, the EPA has fallen far behind in implementing
this new tool to control air pollution and improve water quality.  In
July, 1996, NWF, the Sierra Club and the Chesapeake Bay
Foundation sued the U.S. EPA for its failure to implement the Great
Waters Program.  Last week the Agency agreed to submit its report
to Congress and seek public comment on a proposed adequacy
determination in early July.  The public will have 30 days to comment
on the EPA's draft adequacy determination, and by March 15, 1998,
the Agency must sign and forward its final adequacy determination to

     This report will be the basis for the EPA's adequacy
determination as to whether additional protection measures are
needed.  In the report, EPA must assess:

1.   the sources and contributions of air pollution to the Great
     Waters, and their effects on environmental and public health;  
 2.   air pollution contributions to violations of the Safe Drinking
     Water Act, water quality standards under the Clean Water
     Act, or the objectives of the Great Lakes Water Quality
     Agreement; and, 

3.   any revisions to current protection measures necessary to
     assure environmental and human health protection under the
     Clean Air Act and other applicable federal laws.

     This schedule gives us precious little time -- 30 days -- to
review such a detailed report.  That is why we wanted to give you an
advanced notice because we know July is a busy time for many of

Here's what we can do

     NWF staff will analyze the report, prepare draft comments,
and send them to you on July 9 for your use.  Your comments can be
as simple as a letter from your organization or you can submit more
extensive comments.  Please feel free to incorporate any or all parts
of NWF's comments in preparing you own statement.

     Your comments are critical. The EPA has dragged its feet on
this program because it expect strong opposition from industry and
Congress.  Without your pressure, EPA will once again take the path
of least resistance.  The Agency will only begin to develop new
measures to reduce air pollution, if they conclude they are necessary.

     We will keep you informed about the contents of the report as
soon as it becomes available.  If you have any questions, please call
Rick Spencer at NWF's National Office, or Anita Kraemer at NWF's
Great Lakes Natural Resources Center.   Rick's telephone number is
(202) 797-6635; his E-mail address is spencer@nwf.org.  Anita's
telephone number is  (313) 769-3351; her E-mail address is

Thank you for help on this matter.


   Norman L.  Dean            
   Senior Vice President for Conservation Programs

P.S.  If you want to get a copy of the report you can contact:

John Ackermann
Office of Air Quality Planning and Standards,  MD-15
Research Triangle Park, NC 27711 
(919) 541-5687

If you would like a copy during the comment period, please tell Mr.
Ackermann so he can put you on the expedited mailing list.  He
would also like to know if you would like to get the report through the
world wide web