Letter to the editor
Angela Neville's March 1999 editorial piece, "Chez EPA's new menu," arched my eyebrows with the thought, "Oh, really?". My reaction was to the proposed action by the U.S. Environmental Protection Agency (EPA) regarding administrative procedures coordinating the Clean Water Act and the Endangered Species Act between the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (FWS).
The phrase she used (in referring to EPA), "its traditional command and control approach," had a familiar ring, as I recalled my recent review of Section VI - National Level Activities to Ensure Protection of Species: A. - National Rulemaking of the Draft Memorandum of Agreement between EPA, FWS and NMFS Regarding Enhanced Coordination under the Clean Water Act and the Endangered Species Act.
One need read no further than the first two lines: "EPA will propose amendments to its national water quality standards regulations (40 CFR Part 131) to include provisions to ensure the protection of endangered and threatened species ..." or further along: "EPA will propose to require that water quality not likely jeopardize the continued existence of endangered or threatened species or result in the destruction or adverse modification of designed critical habitat."
Perhaps Gwen Whitt at EPA's Office of Cooperative Environmental Management ought to speak with J. Charles Fox at EPA. Or should it be the other way around? There shouldn't be any wonder about my cynicism about a federal agency purporting to "help" us via their new "menu." Rather than cuisine, maybe I'm whiffing the "aroma" of something else.
Roy G. Metzgar
Water Quality Scientist, City of Everett
Everett, Wash.
This article originally appeared in the 06/01/1999 issue of Environmental Protection.
About the Author
Gerald F. Connell, ChE is a consultant, retired after 30 years with Capital Controls Group, Severn Trent Service Inc., Colmar, Pa. Mr. Connell is author of "The Chlorination/Chloramination Handbook," published by the American Water Works, and a forthcoming "Chlorination/Dechlorination Handbook" to be published by WEF.