Public Comment Responsiveness Summary Hawaii’s 2002 Clean Water Act Section 303(d) Waterbody List Hawaii State Department of Health (DOH) November 20, 2002 General Comments:: Several commenters expressed concern that the State’s proposed listing methodology is arbitrary or inconsistent with regulatory requirements. Specifically, several comments challenged the use of: •= Minimum sample sizes; •= Minimum percentage exceedance rates to determine impairment; and •= Quality assurance/quality control procedures to ensure that data are reliable and representative of receiving water conditions. EPA assessment and listing guidance documents specifically recommend that states develop listing methodologies based on accepted scientific principles that result in defensible listing decisions (see EPA, 1997, EPA, 2001, and EPA, 2002). EPA endorses the use of rigorous QA/QC procedures, including definition of minimum sample sizes needed to assess waters, as part of state assessment methodologies (see EPA, 1997 and EPA, 2002). With respect to minimum sample sizes, DOH had to balance the desire for statistical rigor in the assessment process (which would have entailed setting higher minimum sample sizes) with the requirement to assess waters for which limited data were available. It is reasonable for the DOH to set minimum sample sizes by exercising professional judgment with respect to these competing goals. EPA also endorses the application of ...
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