LETTER: MT BHA Opposes Narrative Water Standards by MTDEQ

February 8th, 2022

To Montana Department of Environmental Quality:

Montana BHA on behalf of our 3,000+ dues-paying members continue to oppose the requested implementation of SB 358 via the amendment of ARM 17.30.1304.

While SB 358 directs the department to amend the administrative rules to delete references to numeric nutrient standards, we implore the department to find creative ways to incorporate unambiguous quantitative measurements back in.

Climate change is already warming our waters, making nutrient pollution caused by excess nitrogen and phosphorus in the air and water a large and growing threat to aquatic health by leading to harmful algal blooms. Significant increases in algae harm not just water quality, but important wildlife habitats and food resources. Large growths of algae, as seen recently in many of Montana’s rivers and streams, can severely reduce or eliminate oxygen in the water, leading to illnesses or death of large numbers of fish. We should be working to remedy these concerns rather than making them worse.

By removing quantitative standards, we find ourselves moving in the wrong direction, going back in time and abandoning the best science and tools we have at our disposal. Adopting nutrient standards that are void of quantitative measurements - while we may call these 'narrative' standards - they simply don't tell the whole story of our water health. From a state that generates $7.1 billion from outdoor recreation alone, we expect better. Thank you for the opportunity to voice our concerns.

Scott Mylnechuk –

Missoula Valley Leader of Montana Backcountry Hunters & Anglers