Adoption of New Bacterial Standards for Recreational Waters: Science and Process at the State Level

The adoption of new water quality standards involves not only science, but administrative processes as well. This applies to revisions to existing standards as well. A case in point is EPA's long-standing recommendation that bacterial standards for recreational waters be based on either E. coli or enterococcus in freshwater, and on enterococcus in marine waters. While this recommendation is based on the best science available, only a limited number of regulatory agencies have embraced it formally. The reasons for this lack of response range from the inertia of tradition to concerns about the potential negative impacts on long-standing, expensive and complicated wastewater infrastructure projects that have goals based on existing criteria. Anticipating and addressing these concerns are a necessary part of the foundation for adopting any new standards and avoiding unintended consequences.