Presentation is loading. Please wait.

Presentation is loading. Please wait.

Designated Uses - Can they be changed?

Similar presentations


Presentation on theme: "Designated Uses - Can they be changed?"— Presentation transcript:

1 Designated Uses - Can they be changed?
Designated Uses - Can they be changed? WQSA: Module 3 - Designated Uses

2 Module Outline What are they? Why are they important?
Module Outline What are they? Why are they important? What is the statutory and regulatory basis for them? What are some examples of designated uses? What are my options for changing them? What are existing uses? What is a use attainability analysis? This module provides information on a variety of topics related to uses. What do the CWA and regulations say about designated uses Some examples How can a designated use be revised And what is the difference between designated uses and existing uses. WQSA: Module 3 - Designated Uses

3 Designated Uses: Definition (see 40 CFR 131.3(f))
Designated Uses: Definition (see 40 CFR 131.3(f)) Regulatory: Those uses specified in state or tribal water quality standards regulations for each water body or segment, whether or not they are being attained. Plain language: A concise statement of management objectives and expectations for each of the individual surface waters under state/tribal jurisdiction. Designated uses serve to tell the public how the state plans to manage these waters and provides a collective goal they intend to strive for. The designated use and the criteria necessary to protect it establish the foundation for all other Clean Water Act (CWA) requirements, such as NPDES permitting, monitoring and assessment, and Total Maximum Daily Loads. One point to note is that some states use different terms when referring to designated uses. For example, some states call designated uses “beneficial uses”. The requirements are still the same regardless of the term used. WQSA: Module 3 - Designated Uses

4 Why are Designated Uses Important? (1)
Why are Designated Uses Important? (1) Getting water quality standards right is critical to achieving CWA goals and restoring water quality Getting WQS right starts with getting designated uses right WQSA: Module 3 - Designated Uses

5 Why are Designated Uses Important? (2)
Why are Designated Uses Important? (2) Establish water quality goals for a specific water body Determine criteria needed to protect use Criteria are the regulatory basis for management actions like attainment decisions, Total Maximum Daily Loads, and NPDES permit limits A “designated use” reflects a water quality goal. It is important to note that it is acceptable for the current water quality conditions to not be meeting the designated use. The concept of designated use recognizes that it might take quite some time before various environmental controls can be put in place to achieve the necessary levels of water quality. “Criteria” are elements of state/tribal water quality standards, expressed as either levels of individual pollutants, water quality characteristics, or descriptions of conditions that, if met, will generally protect designated uses. Different designated uses may require different criteria. For example, a coldwater fishery designated use requires a cooler temperature criterion than a warmwater fishery. The dissolved oxygen requirements may also be different for these two uses. WQSA: Module 3 - Designated Uses

6 Where Does the CWA Talk About Uses? (1)
Where Does the CWA Talk About Uses? (1) CWA 101(a)(2)sets a national goal that, wherever attainable, water quality provides for the protection and propagation of fish, shellfish and wildlife, and recreation in and on the water Includes protection of aquatic life for human consumption The CWA section 101(a)(2) goal is often referred to as the “Fishable/swimmable, where attainable” goal. However, this is a misnomer as it is incorrectly human centric. While the term implies the goal is to allow humans to fish and swim safely in the nation’s waters, the CWA’s true objective is to restore and maintain the chemical, physical, and biological integrity of the nation’s waters. In other words, we protect waters so that fish and animals can safely use the waters as well as humans. The CWA gives states and authorized tribes the primary responsiblity for determining the appropriate uses for their waterbodies and adopting these uses into WQS. EPA has an oversight role to ensure state/tribal WQS are consistent with the goals of the CWA. As mentioned earlier, designated uses are goals that may not be currently attained. Therefore, designated uses cannot be set only to reflect the currently attained conditions without an analysis of what might be attainable in the future. WQSA: Module 3 - Designated Uses

7 Where Does the CWA Talk About Uses?(2)
Where Does the CWA Talk About Uses?(2) CWA 303 (c)(2)(a): water quality standards shall serve the purposes of the [Act] and consider the use and value for public water supplies, propagation of fish and wildlife, recreational, agricultural, industrial and other purposes, and…navigation (italics added) While the interim objective of the CWA is to attain the uses described in section 101(a)(2), the CWA also clearly states that when designating uses, one must also consider the use and value of a waterbody for uses other than those listed. Such uses include public water supplies, agricultural and industrial uses as well as navigation. WQSA: Module 3 - Designated Uses

8 What Does the Act Mean by “use” ?
What Does the Act Mean by “use” ? A function of, or activity in, a water that is supported by a level of water quality A 101(a)(2) use means a level fo water quality that protects aquatic life and wildlife, consumption of aquatic organisms by humans, and primary contact recreation. EPA publishes recommended criteria intended to protect the 101(a)(2) uses. In evaluating whether a state or tribe’s use designation is intended to fully protect the 101(a)(2) goal uses, EPA may consider whether the state or tribal criteria associated with the adopted use are designed to provide an equivalent level of protection as EPA’s recommended criteria. It is important to remember that the intent of the WQS program is not to protect water quality for the sake of water quality. We protect water quality for the purposes of supporting particular uses of that waterbody and maintaining the water quality that has supported particular uses in the past. WQSA: Module 3 - Designated Uses

9 The WQS Regulation 40 CFR 131.10(j); 40 CFR 131.10(k)
The regulation effectively establishes a “rebuttable presumption” that CWA 101 (a)(2) uses are attainable Regulations require appropriate documentation to show such uses are not attainable (i.e. Use Attainability Analysis or UAA) States and Tribes have the primary role in establishing uses and in weighing evidence regarding their attainability WQSA: Module 3 - Designated Uses

10 Categories of Designated Uses
Categories of Designated Uses Protection and Propagation of fish, shellfish and wildlife Recreation in and on the water Public Water Supply Agricultural Industrial Navigation Other Purposes WQSA: Module 3 - Designated Uses

11 Other Designated Uses Ceremonial Uses Shellfish Harvesting Areas
Other Designated Uses Ceremonial Uses Shellfish Harvesting Areas Wildlife Protection Endangered Species Protection Drinking Water Source Protection Hydroelectric Power WQSA: Module 3 - Designated Uses

12 Expectations for Designated Uses (1)
Expectations for Designated Uses (1) Be Specified in State and Tribal WQS Regulations (40 CFR (a)) Consider all uses identified in CWA 101(a) and 303(c) (40 CFR (a)) WQSA: Module 3 - Designated Uses

13 Expectations for Designated Uses (2) 40 CFR 131.10(d)
Expectations for Designated Uses (2) 40 CFR (d) Do not provide for waste transport or assimilation 40 CFR (a) Provide for the attainment and maintenance of the water quality standards of downstream waters 40 CFR (b) WQSA: Module 3 - Designated Uses

14 Expectations for Designated Uses (3)
Expectations for Designated Uses (3) Protect uses that can be achieved, at a minimum, by the imposition of: Technology based effluent limits on point sources and Cost effective and reasonable best management practices on non point sources 40 CFR (d) Established through a public process. 40 CFR (e) WQSA: Module 3 - Designated Uses

15 What is a Use Refinement?
What is a Use Refinement? States may refine their designated uses to reflect more specific goals and what is attainable. Use refinement – broad term relating to any activity to review and revise the designated uses. Subcategorization – refining by subdividing into smaller more similar categories similarities in natural conditions (e.g. water body type) anthropogenic disturbance history, resulting biological condition, and potential to recover. WQSA: Module 3 - Designated Uses

16 Why are Refinements to Designated Uses Important ?
Why are Refinements to Designated Uses Important ? Describe the expected condition more accurately. waterbody type / ecoregion human caused conditions that cannot be remedied Provide clear articulation of management objectives and expectations Facilitate adoption of more effective criteria and thus appropriate endpoints for permits and TMDLs Capture incremental improvements over time WQSA: Module 3 - Designated Uses

17 To Refine Designated Uses, States/Tribes May…
To Refine Designated Uses, States/Tribes May… Adopt seasonal uses 40 CFR (f) AND/OR Adopt sub-categories of a use 40 CFR (c) appropriate criteria may be set to reflect the “varying needs” of such uses when adopting subcategories with less stringent criteria, a UAA is required WQSA: Module 3 - Designated Uses

18 Sub-Categories of Uses (1): CWA 101(a)
Sub-Categories of Uses (1): CWA 101(a) Protection and propagation of fish, shellfish and wildlife: Simple Coldwater fishery/Warmwater fishery 40 CFR (c) Complex Ecologically defined uses in Ohio and Maine WQSA: Module 3 - Designated Uses

19 Sub-Categories of Uses (2): CWA 101(a)
Sub-Categories of Uses (2): CWA 101(a) Recreation in and on the water Primary Contact Recreation Seasonal Primary Contact Recreation MN: Primary Contact Recreation May 1 – Oct 1 Secondary Contact Recreation (after UAA) WQSA: Module 3 - Designated Uses

20 Refining Uses With More Specific Subcategories (1)
Refining Uses With More Specific Subcategories (1) Classification based on natural differences in expected condition: Lakes and Streams Ecoregions Classification based on intensity of use Low Frequency Swimming Area WQSA: Module 3 - Designated Uses

21 Refining Uses With More Specific Subcategories (2)
Refining Uses With More Specific Subcategories (2) Different expectations because of human caused conditions Urban Spillway Advantage: Better describe use allowing tailored criteria for more specific levels of protection WQSA: Module 3 - Designated Uses

22 Boundaries on Refining Designated Uses
Boundaries on Refining Designated Uses May not remove an existing use Must be supported by a use attainability analysis under conditions specified in 40 CFR (j). Must reflect the highest attainable use. WQSA: Module 3 - Designated Uses

23 Existing Uses: Definition
Existing Uses: Definition Regulatory: Those uses actually attained in a waterbody on or after November 28, 1975, whether or not they are included in the water quality standards (40 CFR (e)) Plain Language: Defines an absolute “floor” or minimum use and necessary level of water quality WQSA: Module 3 - Designated Uses

24 What is an Existing use (1)?
What is an Existing use (1)? Actually attained The use and the water quality necessary to support the use Regulations require protection of uses, not specific water quality parameters Existing uses are not generally adopted into state/tribal law nor is it required State and tribes are not bound to describe existing uses in the same way their WQS articulate designated use. States and tribes can articulate existing uses more specifically than designated use to reflect the degree of use that has actually been attained. WQSA: Module 3 - Designated Uses

25 What is an Existing use ? (2)
What is an Existing use ? (2) Not intended to apply where the state or tribe wishes to remove a use if the removal would result in improving the condition of a waterbody (e.g. adding a more stringent use or a use more reflective of the expected condition). WQSA: Module 3 - Designated Uses

26 How Do I Determine an Existing Use?
How Do I Determine an Existing Use? Made on a site-specific basis Consider the quantity, quality, and reliability of different types of available data Determine the extent to which water quality since 1975 has supported an actual use occurring in the water States/tribes have flexibility to determine existing uses where: Use has not occurred, but water quality is sufficient to support it; or Data are inconclusive or lacking There is a lack of data WQSA: Module 3 - Designated Uses

27 What is the difference between Existing uses and Designated uses?
What is the difference between Existing uses and Designated uses? The existing use identifies a minimum use and level of water quality that must be maintained to protect uses that have already been attained A designated use, on the other hand, expresses the state/tribal objectives (i.e., the highest attainable uses) for a waterbody. designated use may or may not have actually been attained in the waterbody WQSA: Module 3 - Designated Uses

28 Beneficial Uses: California Perspective

29 Water Quality Standards: Beneficial Use Component

30 Beneficial Uses = Designated Uses
Those uses specified in State or Tribal water quality standards rules for each waterbody or waterbody segment, whether or not those uses are being attained CFR 131.3(e) Goals or “desired” uses of a waterbody Existing use – a use that was actually attained in a waterbody on or after November 28, 1975* “Actually attained” = 1) Use has occurred or 2) Water quality has been sufficient to support use Not just current/present use – includes some historical uses, too *Date of original water quality standards regulation

31 Federal & State Terminology
Federal & State Terminology Federal Parlance CA State Parlance Beneficial Uses Designated Uses Existing or Intermittent Uses Existing Uses Potential Uses Existing uses (even if not designated) must be protected. FEDERAL DESIGNATED USES = CA STATE BENEFICIAL USES WQSA: Module 3 - Designated Uses

32 CA Potential Uses May be existing, but no documentation of use
May be a “goal” use – i.e., one that is not existing Past use (occurring before November 28, 1975) Desired use Plans to put water to such future use; Conditions make such future use likely; Statewide policy (Sources of Drinking Water Policy); Designation by Regional Board as goal use; Public desire to put water to such use.

33 Application of Beneficial Uses in CA: “Waters of the State”
In CA, beneficial uses apply to “waters of the state”, which means any surface water or groundwater, including saline waters, within the boundaries of the state. Broader application than federal designated uses, includes groundwater and some isolated surface waters “Waters of the U.S.” does not include groundwater and “isolated, intrastate and nonnavigable waters”

34 Application of Beneficial Uses in CA (cont.)
Specific waterbodies / groundwater basins Entire hydrographic unit Tributary rule - The beneficial uses of any specifically identified water body generally apply to all its tributaries Similar rule for groundwater

35 Statutory Use Categories
Federal Clean Water Act §§ 101(a)(2), 303(c)(2)(a) …it is the national goal that wherever attainable, an interim goal of water quality which provides for the protection and propagation of fish, shellfish, and wildlife and provides for recreation in and on the water be achieved …; …Such standards shall be such as to protect the public health or welfare, enhance the quality of water … taking into consideration their use and value for public water supplies, propagation of fish and wildlife, recreational purposes, and agricultural, industrial, and other purposes, and also taking into consideration their use and value for navigation. Cal. Water C. §13050 “Beneficial uses” of the waters of the state that may be protected against quality degradation include, but are not limited to, domestic, municipal, agricultural and industrial supply; power generation; recreation; aesthetic enjoyment; navigation; and preservation and enhancement of fish, wildlife, and other aquatic resources or preserves.

36 Federal CWA Categories Cal. Water C. Categories
Federal CWA Categories Cal. Water C. Categories CA Basin Plan Categories Propagation of fish, shellfish & wildlife Preservation and enhancement of fish, wildlife, and other aquatic resources or preserves WARM, LWRM, COLD, SAL, EST, MAR, WILD, BIOL, ASBS, RARE, MIGR, SPWN Recreation in & on the water Recreation; aesthetic enjoyment REC-1, Limited REC-1, REC-2, COMM, SHELL Public water supplies Domestic and municipal supply MUN* Agricultural use Agricultural supply AGR* Industrial use Industrial supply IND*, PRO* Navigation NAV Other purposes Power generation; other beneficial uses GWR, FRSH, POW, AQUA, WET, FLD, WQE, CUL, FISH Generally the uses of groundwater include municipal and domestic supply (MUN), Agricultural supply, industrial supply, and process water. WQSA: Module 3 - Designated Uses

37 Protection of Beneficial Uses
Protection of Beneficial Uses Generally, Existing and Potential Uses are protected with the same water quality standards “Rebuttable presumption” that fishable – swimmable uses are attainable Most surface waters are designated with REC & aquatic life beneficial uses Existing uses – whether designated or not – must be protected Fish consumption protected under REC-1, COMM & SHELL WQSA: Module 3 - Designated Uses

38 Revising Beneficial Uses
23 standardized beneficial use categories developed in mid-1990s New beneficial use categories, or subcategories, may be added by individual Water Boards Wetland: WET, FLD, WQE Cultural: CUL Subsistence fishing: FISH Limited Warmwater habitat: LWRM Limited contact recreation: LREC-1

39 Revising Beneficial Uses
Requires Basin Plan Amendment Create new use category or subcategory Demonstrate necessity of new beneficial use definition Designate waterbodies with beneficial use Demonstrate that use “exists” or has the potential to occur in the water body De-designate or downgrade use UAA and 40 CFR (g) factors Requires adoption by RB & approval by SB, OAL, and EPA [for surface water only]

40 De-designating Beneficial Uses
May not remove an existing use [40 CFR ] If use is not existing For surface water, follow federal regulations at 40 CFR (g) For groundwater, no explicit requirements Demonstrate that use is not a “past, present or probable use” For MUN use, demonstrate that an exception is met [Statewide Sources of Drinking Water Policy (SB Res )] Consider antidegradation Triennial Review of waterbodies not designated as fishable/swimmable

41 California UAAs (cont.)
REC Natural intermittent or low flow conditions Hydromodifications Other considerations: access, recreational facilities, location & safety SHELL Natural physical features unrelated to WQ

42 California UAAs (cont.)
MUN Naturally occurring pollutant concentrations Natural intermittent or low flow conditions Others Aquatic Life Uses Hydromodifications

43 Emerging Beneficial Use Issues in CA
REC Uses REC-1 Use in engineered channels REC-1 Use & impacts from natural sources of bacteria Wetland Beneficial Uses Beneficial uses (WET, FLD, WQE) Statewide effort – new beneficial use definitions & corresponding WQOs Subsistence Fishing New beneficial use (Region 1) Available survey instruments to document use Shellfish Beneficial Use – commercial, recreational, bait Survey of use (2008) Tiered Aquatic Life Uses (“TALU”)

44 Introduction to Criteria
Introduction to Criteria What exactly is meant by the term “Criteria” (Water Quality Objectives in CA) What do the WQS regulations require for state adopted criteria? For what types of criteria has EPA developed recommendations? Other Questions: What are the roles of the various offices? OW, OST, SHPD, HECD ? What are Laws, What are Regulations, What is Guidance?, Policy? What are the objectives and major provisions of CWA? What is the purpose of Water Quality Standards and the Standards Program? What is EPA’s role in Implementing WQS ? What are we going to cover in this Water Quality Standards Academy? What are Waters of the US? How have water pollution control laws changed over the years? WQSA: Module 3 - Designated Uses

45 Water Quality Criteria (40 CFR 131.3)
Water Quality Criteria (40 CFR 131.3) Discussed in Sections 304(a) and 303(c) of the Act A concentration, level or narrative statement Represent a level of water quality that supports a particular use When criteria are met, water quality will protect the designated use The second component of the Water Quality Standards program is water quality criteria. Water quality criteria are limits on a particular pollutant or limits on a condition of a waterbody designed to protect and support a designated use. States and Indian Tribes adopt water quality criteria as part of their water quality standards. States/Tribes can consider which criteria are needed to protect the designated use and then incorporate these criteria into their water quality standards. Section of the Water Quality Standards Regulation covers water quality criteria. Water quality standards include criteria, defined as either numeric limits or narrative statements, that establish the levels of a pollutant that, if met, will allow the use to be attained. Criteria are scientifically-based and must be set to protect the designated uses fully. EPA produces water quality criteria recommendations under section 304(a) of the Act. These criteria are used as the basis for State water quality standards. However, the regulation allows the States to develop their own criteria or site-specific criteria modifications to EPA's recommendations. The 304(a) criteria are scientific recommendations and are not Federal standards. Water quality criteria include aquatic life criteria, human health criteria, biological criteria, and nutrient criteria. Water quality criteria have no force of law until they have been incorporated into State and Tribal water quality standards and approved by EPA. A discussion of each type of water quality criteria will be presented during this training course. We'll also spend some time discussing site-specific criteria that are developed to reflect site-specific or local environmental conditions. Under section 304(a) of the Act, EPA has also developed recommendations for water quality parameters, such as dissolved oxygen, pH, temperature, etc. Water quality criteria are elements of State water quality standards, expressed as constituent concentrations, levels or narrative statements, representing a water quality that supports a particular designated use. When criteria are met, water quality will generally protect the designated use (40 CFR 131.3). These limits, or criteria, are intended to protect and support a designated use. When appropriate criteria are selected for a particular waterbody, and when water quality in that waterbody meets all the criteria, the designated use should be protected. We discussed designated uses in Module 3. They include public water supplies, propagation of fish and wildlife, navigation, and other uses. WQSA: Module 3 - Designated Uses

46 Water Quality Criteria 1 Word – 2 Meanings
Water Quality Criteria 1 Word – 2 Meanings Scientifically defensible guidance developed and published by EPA per CWA § 304(a) Basis for Federal promulgation when necessary Adopted part of State/Tribal WQS Section 303(c) One frequent question regarding incorporation of 304(a) water quality criteria for pollutants that EPA periodically develops or updates (e.g., EPA’s 2001 updated aquatic life water quality criterion document for cadmium) into State/Tribal water quality standards. - When EPA releases new or updated 304(a) criteria guidance, States generally have about 5 years to adopt numerical criteria ‘as protective as’ this recommended criteria value where they are necessary to protect the designated use. - The reason a lag time is allowed is to give States time to consider incorporating new or revised criteria into their WQS early in the triennial review process. - For example, if a State is at the start of its triennial review process, say within the first year of the three year process, it is likely that they have sufficient time to incorporate a new or revised numerical criteria ‘as protective as’ EPA’s recommended criteria value into that triennial review three year process. After the first year, it is likely that the State held a hearing on its proposed new or revised WQS, and it may be difficult/cumbersome to add new changes to the WQS and stay within the three year clock. In these situations, EPA generally allows States to finish that triennial review process without incorporating EPA’s new or revised criteria into the WQS, and incorporate the new or revised criteria value in the next triennial review cycle. - the reasoning for this five year period is further described in EPA’s 2000 “Revisions to the Methodology for Deriving Ambient Water Quality Criteria for the Protection of Human Health” published on EPA’s website: WQSA: Module 3 - Designated Uses

47 Water Quality Criteria Requirements (40 CFR 131.11)
Water Quality Criteria Requirements (40 CFR ) States/Tribes Must adopt criteria that protect the designated use: Based on a sound, scientific rationale Sufficient parameters to protect the designated use Must support the most sensitive use (for waters with multiple use designations) WQSA: Module 3 - Designated Uses

48 Water Quality Criteria: Forms (40 CFR 131.11b)
Water Quality Criteria: Forms (40 CFR b) States and Tribes should adopt numeric criteria based on: 304(a) guidance 304(a) guidance modified to reflect site specific conditions Other scientifically defensible methods States/Tribes should adopt narrative criteria: Where numeric criteria cannot be established Or to supplement numeric criteria WQSA: Module 3 - Designated Uses

49 Special Criteria Requirements for CWA 307(a) “Priority Pollutants”
Special Criteria Requirements for CWA 307(a) “Priority Pollutants” 1987 CWA Amendment - CWA Section 303(c)(2)(B) For 307(a) Pollutants Where EPA Has Published 304(a) Guidance – States Shall Adopt Numeric Criteria Where Discharge/Presence Can Reasonably be Expected to Interfere with Designated Uses States Must Identify How They Intend to Regulate Point Sources of Priority Pollutants if They Use Narrative Criteria EPA Promulgation WQSA: Module 3 - Designated Uses

50 CWC Section 13241 establish such water quality objectives that will ensure the reasonable protection of beneficial uses considering: Past, present, and probable future beneficial uses of water. Environmental characteristics of the hydrographic unit including the quality of water available Water quality conditions that could reasonably be achieved through the coordinated control of all factors Economic considerations. The need for developing housing. The need to develop and use recycled water

51 NUMERIC CRITERION EXAMPLE
NUMERIC CRITERION EXAMPLE For the protection of Human Health from the Toxic Effects of Copper, the Concentration of Copper in Water Should not Exceed the Recommended Criterion Level of 1300 μg/L. WQSA: Module 3 - Designated Uses

52 NARRATIVE CRITERION EXAMPLE
NARRATIVE CRITERION EXAMPLE Toxicity All waters shall be maintained free of toxic substances in concentrations that produce detrimental physiological responses in human, plant, animal, or aquatic life. This objective applies regardless of whether the toxicity is caused by a single substance or the interactive effect of multiple substances WQSA: Module 3 - Designated Uses

53 TYPES OF WATER QUALITY CRITERIA
TYPES OF WATER QUALITY CRITERIA Human Health Criteria Bacteriological Criteria Aquatic Life Criteria Sediment Quality Assessments Biological Criteria Nutrient Criteria Others WQSA: Module 3 - Designated Uses

54 Study Question 1 A designated use must apply to an entire waterbody.
Study Question 1 A designated use must apply to an entire waterbody. True False WQSA: Module 3 - Designated Uses

55 Study Question 2 Which of the following cannot be a State/Tribal designated use? a. navigation b. boating c. propagation of fish d. waste transport e. drinking water f. swimming WQSA: Module 3 - Designated Uses

56 Study Question 3 What is the minimum designated use(s) expected by the Water Quality Standards regulations? a. Fishing b. propagation of fish, shellfish, wildlife and recreation in and on the water c. drinking water d. navigation e. agriculture WQSA: Module 3 - Designated Uses

57 Study Question 4 A use must be attained before the State or Tribe can designate it for a particular waterbody. True False WQSA: Module 3 - Designated Uses

58 Study Question 5 Recreation is often divided into what two subcategories? a. primary contact/secondary contact b. fishing/swimming c. boating/wading d. summer/winter WQSA: Module 3 - Designated Uses


Download ppt "Designated Uses - Can they be changed?"

Similar presentations


Ads by Google