NW Arkansas Council Submittal ocr 1 |
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100 W. Center, SlIttc 300
Fayt"nevillr:, AH 72 iOJ
I -1795822100 479 582 1919
Mr. Phillip Moershel
Water Quality Standards Section
Oklahoma Water Resources Board
3800 N. Classen Boulevard
Oklahoma City, Oklahoma 73118
Dear Mr. Moershel,
JUly 29, 2011
The Northwest Arkansas Council is a non-profit group of key regional business
and civic leaders. Representatives from area small businesses, institutions of higher
education, area Chambers of Commerce and the region's largest employers are active
members of the Council. Our primary goal is to ensure that Northwest Arkansas
remains a vibrant and attractive community for businesses, residents, families and
retirees for decades to come.
Northwest Arkansas has a direct and sUbstantial interest in the ongoing review of
the Scenic Rivers phosphorus standard by the Oklahoma Water Resources Board. A
clean environment and healthy streams are important to Northwest Arkansas. The
Council supports environmental regulations that are scientifically based, reasonable and
necessary to protect and preserve natural resources. However, we oppose regulations
that are unreasonable, lack a legitimate scientific basis or are more restrictive than
necessary to protect and preserve natural resources.
We are pleased that Oklahoma has started the process of re-evaluating the
Scenic Rivers Phosphorus standard. As you know, Oklahoma'S 2002 mandate that
phosphorus concentrations of 0.037 mg/L be met at the Arkansas/Oklahoma state line
by July 1, 2012 in each of the six designated scenic rivers has been a source of much
controversy and many strained relationships between the two states over the past
decade. Despite the consensus view that this standard was unsound, unreasonable
and unattainable, Arkansas agreed in the Statement of Joint Principles and Actions not
to challenge the standard through litigation for ten years and to instead devote
substantial resources to lowering phosphorus levels to the extent practicable provided
that Oklahoma would "re-evaluate" 0.037 mg/L before 2012 "based upon the best
scientific information available and with the full and timely participation of Arkansas
officials."
Northwest Arkansas has spent hundreds of millions of dollars on phosphorus
removal projects and water quality protection since 2003 in an effort to forge a positive
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