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Kentucky Resources Council, PO Box 1070, Frankfort, KY 40602 Phone [502] 875-2428

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PO Box 1070, Frankfort, KY 40602  Phone 502.875.2428, Fax 502.875.2845

Increased Ambient Monitoring Recommended In Comments On TMDL For Bayou de Chien  Posted: July 6, 2006
July 6, 2006

David W. Morgan, Director
Division of Water


Dear David:

KRC has reviewed, and endorses and incorporates by reference the comments submitted to the Division of Water by the Kentucky Waterways Alliance regarding the proposed Draft TMDL for Fecal Coliform for Bayou de Chien, Central and Cooley Creeks.

In addition to those comments, KRC recommends that the watershed plan for Bayou de Chien include ambient sampling stations above and below the proposed locations of each proposed KNDP hog operation in any tributaries of Bayou de Chien and in the mainstem itself (including the proposed operations in the Cane Creek and Mudd Creek watersheds). Such ambient sampling will help detect any contribution from those operations to the background ambient levels of pathogens, and will assure that the baseline conditions are not worsened as the watershed plan is developed. Particularly in Cane Creek, which the draft TMDL notes is habitat for the protected relict darter species, the proposed subwatershed monitoring should begin prior to commencement of the proposed hog operations in order to establish background loadings above and below the proposed operations.

KRC also notes that, to the extent that the sampling identifies agricultural operations as a source for localized or watershed level impairment, the Kentucky Statewide Agricultural Water Quality Plan imposes requirements on agricultural operations within the watershed that should be triggered by the Division of Water's findings, and that the sufficiency of those plans should be reviewed in order to mitigate the contribution of such operations to the ambient levels of pathogens.

Thanks in advance for your consideration of these comments.

Cordially,
Tom FitzGerald
Director

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