Some more considerations for water quality classifications.

[vern]

Got this today:

Pennsylvania Bulletin

Information included at this site has been derived directly from the Pennsylvania Code, the Commonwealth's official publication of rules and regulations and from the Pennsylvania Bulletin, the Commonwealth's official gazette for information and rulemaking

www.pacodeandbulletin.gov

 

[vern]

Personal take on this: It most likely means that the Class A and Wild Trout classifications are being sought to be downgraded to a less protective class.
Not much time to provide documentable qualifications for maintaining their protective status.

IMO Field inspections and techniques for determining long term stream health are too restricted and insufficient.

Extreme weather effects can easily alter suitable substrate and channel composition to maintain preexisting random sampling values.

For what it's worth, feel that total flow from origin through total length should be recorded and tested categorically and regularly - not just at 10-year intervals - to determine the health and actual productivity of a stream for long term classification.

Streams and sections are dynamic.

Personal outlook is cynical. Could it be that intentions for redesignations are for permitting industrial uses? Maybe decline the status to accommodate pipeline crossings or flow extractions for consumption?

(Boy. Am I a downer!)

Thank God there is a nice 530-mile increase in Class A proposed!

 

[troutbert]

Personal take on this: It most likely means that the Class A and Wild Trout classifications are being sought to be downgraded to a less protective class.

I think it's more likely that they are considering upgrading to a more protective class (High Quality Coldwater Stream), as described here:

https://files.dep.state.pa.us/PublicParticipation/Public%20Participation%20Center/PubPartCenterPortalFiles/Environmental%20Quality%20Board/2024/Sept_10_2024/04b_7-583_ClassA4_Streams_Report.pdf

 

[Mike]

My take is completely different. I suspect that DEP is reviewing the existing Chapter 93 Water Quality Standards designation for each stream now that it has been been determined by the PFBC that the subject streams either are Class A or are streams that support natural reproduction of trout, but aren’t Class A. These streams may be presently improperly classified in Chapt 93, such as being WWF (warmwater fishery), TSF (trout stocked fishery), or perhaps even CWF (coldwater fishery). Some may not be classified in Chapt 93. Typically, entire lengths or else smaller segments of the WWFs and the TSFs would be upgraded to CWF for the wild trout streams and HQCWF for the Class A’s. Occasionally, a DEP eval of the macroinvertebrate diversity and quality results in a Class A receiving an EV designation instead of the HQ designation. EV is the most protective; HQ is the next most protective from water quality and use perspectives. Downgrades have been uncommon in my experience.

 

[lycoflyfisher]

Vern, I think you may be being too cynical. This public notice is likely the precurser to the other notice you are referencing.

Pa Fish and Boat Commission designates trout streams. DEP manages and designates the Chp 93 designations pertaining to water quality. There is some interaction and relationship between PFBC trout stream designations and the CHP 93 designations, but they are still independent.

When PFBC identifies new wild trout streams or class a trout streams they review the Chp 93 designation. Generally wild trout streams are provided CWF designation and the Class A trout stream designation is a biological qualifier to be considered for Chp 93 High quality designation. This provides for more stringent/ effective e&s and stormwater controls for construction and lower pollutant limits for point source discharges. This is a very brief summary.

So if the PFBC identifies streams may be eligible for Chp 93 upgrades, they will recommend upgrades to DEP or request a review. The public notice you shared is the first step by DEP to start the evaluation process. They are making a public call from any entity (academic, state agencies, county conservation districts, non profits, etc) that may have data for their review. DEP will review data and likely collect new water chemistry data and potentially evaluate macroinvertebrate populations. Then they will make a determination on the Chp 93 designstion review.

The notice you refer to as an increase of 530 class a miles documents upgrades to chp 93 designations, mainly to HQ-CWF as a result of PFBCs Class a designation and subsequent recommended Chp 93 upgrade to DEP.

 

[vern]

I am indeed a bit, perhaps more than a bit, cynical! LOL 😂

(Truthfully, though, it is influenced somewhat from years of being exposed to backroom negotiations of elected and party leadership and special interests.)