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Conservation districts assist DEQ with stream classification

by Wyoming Livestock Roundup

Worland – “It has always been a challenge for semi-arid states across the West to determine how they designate what types of recreational activities our waters can support,” stated Wyoming Association of Conservation Districts Executive Director Bobbie Frank at WESTI Ag Days in Worland on Feb. 19.

“We protect our waters for primary and secondary contact,” she said. “The E. coli standard means that the higher the use, the less E. coli should be in the water. It’s a risk management stamp.”

Frank went on to say that the standard is not a guarantee for anyone’s health or safety.

“It does not guarantee that if a water body meets the standard that someone won’t get sick. All it says is that if there is a higher level of emersion activities where someone might ingest the water, there is a higher chance of getting sick if there is E. coli in the water,” she commented. 

Accurate classification

Wyoming Department of Environmental Quality’s (DEQ) Water Quality Division Administrator made a final determination regarding designated use changes for primary and secondary classification of contact recreation for streams in Wyoming.

Without the DEQ changes, the standard of the Environmental Protection Agency (EPA) is to designate all waters under primary use, unless proven otherwise.

“There is what is called a ‘rebuttable presumption’ that everything is fishable and swimmable under the Clean Water Act until we demonstrate it’s not,” Frank explained.

To demonstrate that it’s not, an attainability analysis must be completed, illustrating that someone went to the site and collected information to find out if the area can support the indicated uses.

“If that first designation is not right, then all other decisions are going to be wrong. We are going to imply the wrong standard, and we are probably going to invest resources inaccurately,” she said.

New model

DEQ realized that processing countless attainability analyses to correct designations throughout Wyoming would become a very difficult, expensive process, so they designed a categorical process using geographic information system (GIS) data and a set of criteria to develop a better system of recreational use classification.

Factors such as location, stream flow levels and designated contact use were built into the model to help designate streams.

“In our conversations with DEQ, we thought it was a great idea,” Frank noted.

However, there was some concern from the conservation districts about how DEQ would ground-truth the model, or verify its accuracy, especially with limited staff.

“Conservation districts started working on getting correct information to make sure that water bodies are classified to their true capability to serve for primary or secondary contact recreation,” Frank commented. “We know we want to make sure this is a defensible, science-based approach.”

Site data

Eight hundred randomly selected sites were distributed amongst the districts and employees collected data over four months.

“I have pictures of conservation districts folks who had to lease horses and horse trailers to go up into the wilderness in Teton County. They were all over,” she commented.

Review of the site inspections revealed that the DEQ model is about 75 percent accurate, a significant improvement over the EPA’s standard designation system.

“Assuming everything is primary means about 25 percent of our waters are probably classified correctly and 75 percent are classified incorrectly. Under the model, we’ve flipped that,” she explained, adding that conservation districts efforts saved taxpayer time and money.

EPA approval

DEQ submitted the model to the EPA for consideration, but Frank remarked, “The environmental community out-cried that they were not included in the process, despite the fact that there were several public notices and opportunities to comment.”

A formal public meeting was hosted by DEQ to discuss the model this past fall, and comments were collected.

“We are waiting for DEQ to finish their response to comments from the hearing last fall. They are going to resubmit it to EPA for approval, and we are going to back them up 100 percent on it,” she continued.

Although she admitted that the model isn’t perfect, its accuracy is much better than the current EPA standard, and she trusts that the groundwork from the districts has provided scientific and defensible data to back up stream recreational use designations.

Further verification

The process for individual site verification will also still be available if EPA accepts the model. Therefore, if an individual disagrees with a certain classification, they can still go through the attainability analysis process.

“Folks may go to the DEQ website, pull up their place to look at the water bodies and say that it’s wrong. We can still do a site-specific analysis, and there is a process to submit that information,” she said.

An interactive map can be found on the DEQ website and specific bodies of water can be selected to determine both their classification and the listed reasons for the designated classification. Further information about how water bodies are classified can also be found at the site.

Natasha Wheeler is editor of the Wyoming Livestock Roundup and can be contacted at

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