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Intertwined: Fish Consumption and Water Quality Standards

[1]The Oregon Department of Environmental Quality (DEQ) has scheduled a series of public workshops in February [2] regarding raising the state’s water quality standards. DEQ proposes to make Oregon’s water quality standards among the toughest in the country. The reason? DEQ argues that the more fish you eat, the more you are exposed to the cumulative effects of toxins in water, and therefore the higher the standard should be for those toxins.

DEQ proposes an unjustifiably high “safe” assumption of 175 grams of fish consumed per person per day, equivalent to eating 23 fish meals a month. This is ten times EPA’s national fish consumption standard of just 17.5 g/day. In 2008, a DEQ committee reviewed the economic impacts [3] on relevant industries if this higher fish consumption standard were adopted. The committee concluded that technology isn’t currently available, or else the costs are so prohibitively high, that meeting the new standard would not be feasible. Yet, DEQ continues to insist on an over-inflated fish consumption rate to justify a significant increase in water quality standards.

When the Clean Water Act was passed in 1972, pollutants were measured in parts per thousand. We now measure pollutants in parts per trillion. Government agencies must recognize there are diminishing health benefits and economic returns to the continued tightening of environmental regulations. DEQ’s proposed water quality standards are an example of unrealistic premises being used to pursue diminishing returns at exorbitant costs.


Karla Kay Edwards [4] is Rural Policy Analyst [5] at Cascade Policy Institute [6]. She has held positions of leadership in numerous organizations focusing on agricultural and rural industries and issues, including the Fresno (California) Farm Bureau, Washington Cattlemen’s Association and the Oregon Department of Agriculture.

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