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Tell the EPA to save billions of fish


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In the 40th anniversary year of the Clean Water Act, the Environmental Protection Agency has the chance to make good on its responsibility to stop the slaughter of fish at industrial facilities like Indian Point nuclear power plant, which alone kills 1.2 billion fish and other Hudson River lifeforms every year.

We need you to send a strong message to the EPA before July 12. Tell the EPA to require the use of the closed-cycle cooling, the best technology available, to stop fish kills at industrial facilities, and stop caving to industry pressure.

Since its inception in 1966, Riverkeeper has fought to stop power plants and other industries from killing fish in cooling water intakes. Closed-cycle cooling technology has been available for decades to reduce water use and environmental impacts by upwards of 95% but facilities like Indian Point have fought us all the way to the Supreme Court to avoid the cost of doing the right thing.

Reacting to that 2009 Supreme Court ruling, the EPA has been slowly drafting rules that would govern the use of surface waters for industrial cooling, the technology used to limit environmental impacts and the cost-benefit calculations that will govern the technology choices (known as 316(b) for that section of the Clean Water Act).

Since proposing a weak rule in April 2011, the EPA collected more data, and is seeking public comment on its new findings. Most importantly, EPA conducted a sophisticated economic survey to gauge the value the American public places on ecosystem protection. While this comes as no surprise to Riverkeeper, EPA’s survey demonstrated that the economic benefits of protecting fish from cooling water intake structures far exceeds the costs. In light of those new findings, and Riverkeeper’s own analyses showing that that a tough rule won’t affect electrical reliability and would create jobs, EPA should require closed-cycle cooling nationwide.

An additional concern is unwarranted flexibility in the rule: EPA’s notice uses some form of the word “flexible” 13 times in 10 pages. That much “flexibility” opens loopholes that industry can exploit to save money at the expense of our environment.

Tell the EPA to require closed-cycle cooling and eliminate the excessive “flexibility” for industry in order to protect our fish.

Comment on the EPA’s Notice of Data Availability (NODA) for the implementation of Clean Water Act, Chapter 316(b).

Identify your comments by Docket No. EPA–HQ–OW–2008–0667 in the subject line, and submit them by email to to [email protected] by the July 12 deadline.

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