Over the last three years, the Idaho Department of Environmental Quality has been undergoing the process of updating Idaho’s human health water quality criteria (WQC) for the protection of human health. DEQ’s previous attempts to update WQC were disapproved by the Environmental Protection Agency (EPA), as the proposed standards were deemed inadequately protective. Additionally, the EPA disapproved DEQ’s proposed fish consumption rate (FCR) of 17.5 grams/day because DEQ failed to consider local and regional fish consumption information, which suggests that some in the Idaho general population consume much more than 17.5 grams of fish per day and thus would not be protected by Idaho’s standard. For context, FCRs are used at the federal and state level for developing WQC. An FCR tells citizens how much fish per day is safe to eat from a jurisdiction’s waters.
To help inform the state on fish consumption patterns, the Nez Perce Tribe and Shoshone-Bannock Tribes, with EPA support, undertook a comprehensive tribal fish consumption survey in 2014-2015. Simultaneously, DEQ initiated a fish consumption survey of the Idaho general population. While significantly less than preindustrialization consumption rates, survey findings concluded that at the upper end the Shoshone-Bannock Tribes consume 427.1 grams/day of fish. Using a more rigorous survey methodology developed by the National Cancer Institute, the Nez Perce Tribe consumes 233.9 grams/day of fish at the upper end.
Rather than calculating the FCR of the general population in the same manner as the tribal survey, which is supported by the EPA and who will have final approval over Idaho’s WQC, IDEQ choose to discount all anadromous species (e.g. salmon), except for steelhead, and market-bought fish. Upon providing IDEQ the tribal survey data and results, the agency, without approval from the tribes or EPA, engaged in a back-of-the-envelope exercise whereby they removed all anadromous species except steelhead, and all market-bought fish from the tribal survey results.
DEQ has also repeatedly ignored requests from the tribes to factor suppressed consumption into their updated FCR as it wouldn’t be fair to dischargers (i.e., polluters). It is a recognized fact that tribes eat far less fish than historically (suppressed consumption) due to limiting factors including dams and other impediments, depleted or extirpated fish runs, fish consumption advisories and water quality/quantity.
The end result is that DEQ is proposing to develop WQC based on a mean FCR of 16.1 grams/day or about the amount of fish that fits on a cracker. Our neighbor to the west, Oregon, implemented a 175 grams/day FCR in 2011, which is equal to a six-ounce fish meal/day. Washington is currently undergoing the same process as Idaho and a 175 grams/day FCR has also been proposed there.
Water and fish are sacred resources to the tribes of Idaho. DEQ’s proposed FCR is an affront to their health and way of life. But the impact of DEQ’s proposal extends beyond the tribes to all citizens of Idaho and downstream residents in Oregon and Washington where Idaho’s impaired waters will flow. Anachronistic WQC are not what Idahoans deserve and will lead to increased impairment of the state’s water and health of its citizens.
To date the FCR/WQC process has been dominated by the usual mix of agriculture, business, and industry. But between Oct. 7 and Nov. 6 Idahoans will have the opportunity to provide oral and written comment to DEQ letting them know that water quality and human health are more important than profits. Please consider attending the public hearing on Oct. 27 at IDEQ in Boise or one of its satellite offices or submitting written comments. Relevant information can be found at deq.idaho.gov/58-0102-1201.
Scott Hauser is the environmental program director for the Upper Snake River Tribes Foundation in Boise.