High Rock Lake Chl a DD 12.07.22

1

Decision Document of the United States Environmental Protection Agency
Determination Under Section 303(c) of the Clean Water Act Review of North Carolina’s
Site-Specific Chlorophyll a Criterion for High Rock Lake

North Carolina transmitted the revisions to its water quality standards (WQS) to the U.S. Environmental
Protection Agency by letter dated October 21, 2022, and it was received by EPA on October 25, 2022.
As described more fully below, the EPA has reviewed and is approving the revisions pursuant to section
303(c) of the Clean Water Act (CWA or Act). Regarding consultation activities for section 7 of the
Endangered Species Act (ESA), the EPA Region 4 concluded that the revisions addressed by today’s
action would, depending on the species, have no effect or may affect, but not likely to adversely affect
the corresponding threatened or endangered species. A letter reflecting that conclusion was sent to the
U.S. Fish and Wildlife Services Asheville Ecological Services Field Office on October 26, 2022 and
concurrence was received on November 17, 2022.

Part I - Overview of State and Federal Information

Background

Consistent with North Carolina’s 2014 Nutrient Criteria Development Plan (NCDP), and subsequent
revisions, a scientific advisory council (SAC) was convened to develop numeric nutrient criteria for
High Rock Lake (HRL). The SAC met multiple times over the years to discuss and develop numeric
nutrient criteria that would protect the applicable designated uses of HRL (Water Supply V or IV and
Class B). To summarize the analysis and decision points that took place during the course of the SAC
meetings, including the conclusions reached by the group at a two-day meeting in December 2018, the
group provided a recommendation document, A Chlorophyll a Criterion for High Rock Lake, dated May
26, 2020, (SAC TSD) to the North Carolina Department of Environmental Quality (NCDEQ or
Department) Division of Water Resources (DWR). The state then continued the criterion development
effort, through coordination with the Criteria Implementation Committee (CIC) and ongoing internal
DWR conversations. As a result of the SAC and North Carolina’s subsequent work, the state has now
proposed and adopted a site-specific chlorophyll a (chl a) criterion for HRL at 15A NCAC 02B
.0211(4)(a). An additional document, Overview of High Rock Lake (HRL) Chlorophyll a Site-Specific
Standard, Version 2, Updated 7/1/2022 (DWR TSD), was created by the state to provide further
information and transparency in how the final chl a criterion was developed in consideration of the
SAC’s recommendations to ultimately derive a scientifically defensible criterion protective of the
applicable designated uses for HRL.

Clean Water Act Requirements

Under section 303(c) of the CWA and federal implementing regulations at 40 C.F.R. Part 131, states and
authorized tribes have the primary responsibility for reviewing, establishing, and revising WQS, which
consist of the designated uses of a waterbody or waterbody segment, the water quality criteria necessary
to protect those designated uses, and an antidegradation policy. The regulations at 40 C.F.R. sections
131.10, 131.11, and 131.12 provide the minimum expectations for designated uses, water quality
criteria, and antidegradation, respectively.

Each state or tribe must follow its own legal procedures for adopting WQS. 40 C.F.R. section 131.6(e).
The state or tribe must submit certification by the appropriate legal authority within the state or tribe that
the WQS were duly adopted pursuant to state or tribal law. Id.
2

Section 303(c) of the CWA also requires states and tribes to submit new or revised WQS to the EPA for
review. The EPA is required to review these changes to ensure revisions to WQS are consistent with the
CWA. When the EPA approves a state or tribal WQS, it becomes the applicable WQS for purposes of
the CWA. 40 C.F.R. section l31.21(c)(2).

Endangered Species Act Requirements

Section 7(a)(2) of the ESA requires federal agencies, in consultation with the U.S. Fish and Wildlife
Service (USFWS) and/or the National Marine Fisheries Service (NMFS), to ensure that their actions are
not likely to jeopardize the continued existence of federally listed species or result in the destruction or
adverse modification of designated critical habitat of such species. Regarding consultation activities for
section 7 of the ESA, the EPA Region 4 concluded that the revisions addressed by today’s action would
have no effect for those species not present in the action area, and for the aquatic-dependent species in
the action area, the revision may affect, but not likely to adversely affect those species. A letter
reflecting that conclusion was sent to the USFWS Asheville Ecological Services Field Office on October
26, 2022 and concurrence was received on November 17, 2022.

Government to Government Consultation 

The EPA recognizes its unique legal relationship with Tribal Governments as set forth in the United
States Constitution, treaties, statutes, executive orders, and court decisions. Government-wide and the
EPA-specific policies call for regular and meaningful consultation with Indian Tribal Governments
when developing policies and regulatory decisions on matters affecting their communities and resources.
Due to the nature of the revisions, the EPA determined that Tribal resources would not be impacted by
this action and therefore concluded that tribal consultation was not necessary.

Summary of EPA Approval Actions

North Carolina’s provisions are shown in detail in Part II. The EPA approves the revisions to add a site-
specific chl a criterion for HRL.

Part II - EPA’s Analysis

The revisions addressed in this document were discussed in a virtual public hearing held on October 28,
2021 and approved for adoption by the North Carolina Environmental Management Commission on July
14, 2022. The revisions became effective on September 1, 2022. Twelve comments were received
generally expressing support with suggestions related to a lack of a proposed assessment methodology
and the proposed text’s variation from the original SAC recommendations. The NCDEQ’s responses to
the comments are further documented in its report of proceedings (ROP).

In a letter written to Regional Administrator Daniel Blackman, Mr. Richard Rogers, Director for the
Division of Water Resources for the NCDEQ, submitted the revisions as new and revised WQS for
review by the EPA pursuant to section 303(c) of the CWA. The letter and supporting documentation
were received electronically on October 25, 2022. In an October 20, 2022, letter, North Carolina’s
Senior Deputy Attorney General certified that the WQS revisions were duly adopted pursuant to North
Carolina law.

3

The revisions to 15A NCAC 02B .0211(4) are as follows:
(4) Chlorophyll a (corrected): except as specified in Sub-Item (a) of this Item, not greater than 40
ug/l for lakes, reservoirs, and other waters subject to growths of macroscopic or microscopic
vegetation not designated as trout waters, and not greater than 15 ug/l for lakes, reservoirs, and
other waters subject to growths of macroscopic or microscopic vegetation designated as trout
waters (not applicable to lakes or reservoirs less than 10 acres in surface area). The Commission
or its designee may prohibit or limit any discharge of waste into surface waters if the surface
waters experience or the discharge would result in growths of microscopic or macroscopic
vegetation such that the standards established pursuant to this Rule would be violated or the
intended best usage of the waters would be impaired;

(a) Site specific High Rock Lake Reservoir [Index Numbers 12-(108.5), 12-(114), 12-117-(1),
12 117-(3), 12-118.5, and the uppermost portion of 12-(124.5) to the dam of High Rock
Lake] Chlorophyll a (corrected): not greater than one exceedance of a growing season
geometric mean of 35 ug/L in the photic zone within a three-year period.
(b) For the purpose of Sub-Item (a) of this Item:
(i ) The growing season is April 1 through October 31;
(ii) Samples shall be collected in a minimum of five different months within each
growing season with a minimum of two growing season geometric means collected in a
three-year period;
(iii) The photic zone shall be defined as the surface down to twice the Secchi depth;
(iv) Samples shall be collected as a composite sample of the photic zone; and
(v) Samples that do not satisfy the requirements in Sub-Item (iv) of this Sub-Item shall be
excluded from the calculation of the geometric mean.

15A NCAC 02B .0211(4) has been modified to reflect the adoption of a site-specific criterion for chl a
that will replace the previously applicable “not greater than 40 µg/l” chl a criterion that applied to HRL,
a reservoir. As summarized in the DWR TSD, the newly adopted site-specific criterion was based on a
multiyear evaluation process and “reflects a combination of the SAC’s recommendations to DWR, CIC
input, and the expertise of DWR staff.” The criterion is comprised of a duration component (growing
season as a geometric mean), magnitude component (geometric mean of 35 µg/L), and a frequency
component (expressed as frequency of not-to-exceed more than once in three years). Each of these three
components and additional sampling and location details are discussed in more detail below.

Duration

A growing season duration was selected for the HRL site-specific chl a criterion, characterized as the
months of April 1 through October 31 in provision 15A NCAC 02B .0211(4)(b)(i), and described as a
growing season geometric mean in the main paragraph of (4)(a). A growing season time period is
frequently used by states developing chl a criteria, as it accounts for when conditions are expected to be
conducive for algal growth, and algal growth can be measured as chl a concentrations in water. The
incorporation of a growing season geometric mean, defined as April 1 through October 31 in sub-
item(b)(i), reflects the fact that these months are the most common times that chl a can be monitored,
which makes the conclusions from the data most representative of the data used in the development
efforts for the revised criterion. These months are also when chl a also tends to be elevated, and
consequently it is an appropriate time period to assess the lake and determine whether or not the
designated uses are being met relative to chl a expression. The SAC and DWR were both in agreement
with the selection of this seasonal duration component. Section 4.2.1 of the SAC TSD provides further
4

detail regarding the SAC’s analysis to support the development of a growing season duration
component, and its defined length of April through October.

Water quality studies to assess nutrient-driven enhanced productivity in natural and man-made
systems have shown that both short-term acute impacts (fish kills, algal toxins, etc.) and long-
term enhanced productivity, with potential shifts in the species assemblage present, can occur in
different systems (e.g. USEPA, 2000). The development of the temporal component for a site
specific chl a criterion should consider how the key designated uses [for HRL] may be impacted
on an acute and chronic basis. In general, acute effects can be associated with algal toxins or
with depletion of dissolved oxygen due to the decay of large algal blooms. For High Rock Lake,
the algal assemblage during the growing season often has a high proportion of cells contributed
by species of cyanobacteria (see Section 3.2.4). A limited number of measurements to date
indicate that algal toxins are present but at a relatively low concentration (see Section 3.2.5). As
discussed in Chapter 3, it is important to note that these observations are mainly limited to
biweekly measurements of dissolved toxins during the summer of 2016. The sample resolution
may not be representative of peak bloom conditions when toxin concentrations (both dissolved
and intracellular) tend to reach their maxima nor can any conclusions be drawn in regard to year
to year variability. The abundance of algae during the growing season is typically high, and
periods of depleted dissolved oxygen in deeper waters of the reservoir have been reported when
bottom waters become isolated from surface waters due to thermal stratification (see Section
3.2.1). It is unclear, however, as to the extent that elevated levels of nutrient-driven productivity
contribute to dissolved oxygen depletion compared to the thermal isolation of bottom waters
during warm season conditions. Due to a lack of clear nutrient-driven acute effects in High Rock
Lake, the SAC chose to focus criterion development efforts on longer-term measures of the
reservoir’s trophic state.

The potential long-term or chronic effects of nutrient-driven enhancement of primary production
would be evaluated with a seasonal geometric mean (geomean). The objective of the criterion
would be to assess the central tendency of chl a concentrations over time for stations included in
each assessment unit. The use of a geomean for the proposed criterion is due to the geomean
being the best measure of central tendency for log-normally distributed parameters such as chl a
(USEPA, 2010). It is proposed that the geomean be calculated with data collected during the
growing season (April-October), as an indication of overall algal production and representative
of the time of maximum productivity in High Rock Lake, since chl a concentrations in High
Rock Lake are typically higher during the growing season than in other months of the year (see
Section 3.2.4). Utilizing data from the growing season is appropriate to assess reservoir trophic
status and the general potential for algal-related effects. Overall, the reduction of the long-term
central tendency for chl a would also reduce the frequency of elevated chl a values over time.

With regard to the designated uses for HRL, the designated uses include either Water Supply V (WS-V)
Class B waters or WS-IV Class B waters. The WS designations protect water as water supplies in
moderately to highly developed watersheds and Class B requires protection of primary and secondary
recreation, fishing, aquatic life including propagation and survival, and wildlife. Section 4.1 of the SAC
TSD further examined how these designated uses were considered in light of potential impacts from
nutrient-driven enhanced primary production. Based on available scientific literature and site-specific
information from HRL, the final chl a criterion, relying on a duration articulated as a growing season
geometric mean, ensures that all designated uses for HRL will be met. This is discussed in more detail in
the magnitude section below.
5

Magnitude

A geometric mean of 35 µg/L was selected as the level, or magnitude, which would be protective of
HRL’s designated uses. This level was selected based on evaluation of (1) the range of chl a magnitude
values available in scientific literature; (2) other states’ chl a criteria adoptions for lakes and reservoirs
located in the Southeast; and (3) HRL station by station analysis completed as part of the SAC’s TSD
and noted in Table 1 of the DWR TSD. The SAC’s magnitude analysis relative to designated uses and
the consideration of station analysis is further described below.

Section 4.3 of the SAC TSD provides further detail regarding the SAC’s analysis to support the
development of a 35 µg/L magnitude from a range of protective values, including the scientific
judgments made. In another lake, 35 µg/L or other higher values noted in the examples, may not be
protective enough, but as further described below, the conclusion to use 35 µg/L in this case was tied
very specifically to the discussions around the existing data and information known about HRL.

The magnitude component of the chl a criterion is more challenging to derive than for
constituents that display a simple dose-response relationship with designated uses. In some
settings, development of precise, quantitative relationships between chl a and indicators of
designated use impairment may be possible, and a magnitude could be selected to limit identified
response indicators from exceeding specific thresholds. However, the SAC’s comprehensive
examination of relationships between chl a and potential indicators in High Rock Lake (see
Section 3) did not identify dose-response relationships upon which a chl a criterion could be
based. In fact, High Rock Lake exhibits a combination of favorable indicators and indicators of
potential concern. With the understanding that scientific judgment would be required, the SAC
adopted the following general approach for deriving a site-specific chl a criterion magnitude for
High Rock Lake:

1. An extensive review of literature was conducted to define the ranges of chl a
concentration in natural and man-made systems that have been interpreted to be
protective of designated uses potentially impacted by a high abundance of algae (see
Section 2). This review culminated in the decisions made by the SAC at its December
2018 meeting.3 [1]
2. The current conditions of High Rock Lake were evaluated, with an emphasis on
current chl a levels, on relationships between chl a and indicator parameters, and on
evidence for algal-related impacts to designated uses (see Section 3).
3. The results of steps 1 and 2 were synthesized to develop chl a concentration range that
was deemed to support designated uses in water bodies similar to High Rock Lake. At the
December 2018 SAC meeting, a chl a criterion magnitude was selected from this
range.4[2]
4. A Monte Carlo analysis was performed to confirm that attainment of the recommended
criterion would protect the reservoir’s fishery and result in a low rate of exceedance of
the upper end of the acceptable chl a range.

1 Footnote 3 in the SAC TSD states: “The summary of the group’s basis states that the ‘literature supports recreation, aquatic
life and drinking waters uses are achieved when chla is 20-40 μg/L.’”
2 Footnote 4 in the SAC TSD states: “The magnitude summary states ‘35 μg/L to support average chl a levels throughout
High Rock Lake of 20-25 μg/L, derived from 25-40 μg/L range for warmwater reservoirs.’ The 35 μg/L was ‘near the upper
end of the range selected due to mostly favorable use indicators.’”
6

The results of steps 3 (range derivation) and 4 (Monte Carlo analysis) are provided in the
following subsections along with the specification of the SAC recommended criterion
magnitude.

Section 4.3.1 of the SAC TSD expanded on the results of step 3, range derivation, and Section 4.3.2
summarized how the final magnitude of 35 µg/l was selected.

….Based on the literature review (see Section 2; Figure 4.1), a chl a value of 25 μg/L would be
protective of the water supply and primary recreation uses, assuming the associated presence of
cyanobacteria is not linked to algal toxin levels that can pose a risk to animal and human health
(Chapter 3), and since observation of surface algal scums have generally been absent at High
Rock Lake (see Chapter 3 for details).

The upper end of the chl a range to support aquatic life is based on reservoir research
documenting abundant apex predators, prey species, and zooplankton at average chl a
concentrations of 35-40 μg/L (Allen et al., 1998; Bayne et al., 1994)….(Section 4.3.1)

The SAC recommends a criterion magnitude of 35 ug/L, from the derived range of 25-40 μg/L,
expressed as a seasonal geomean. In developing the recommendation, the SAC considered
proposals as low as 25 μg/L and as high as 40 μg/L. Ultimately, the criterion magnitude was set
in the upper half of the potential range in acknowledgement of the favorable indicators of use
attainment in High Rock Lake, such as a thriving fishery and low algal toxin levels observed in
summer of 2016. The maximum value was not selected based on site-specific fisheries
information presented to the SAC indicating abundant benthic species, possible overall decreased
fish species diversity, and decreased catch rate of striped bass compared with other North
Carolina Piedmont reservoirs. Implementation of the proposed criterion of 35 μg/L in High
Rock Lake would require a reduction in the level of chl a in the reservoir from the existing
condition (see Figure 4.1). Total productivity of the fishery would be expected to decrease,
which may increase diversity and shift species abundance toward pelagic species. (Section 4.3.2)

As noted earlier, the DWR TSD highlights that the magnitude selection considered the station by station
assessment, noting it as “consistent with methodology used to develop the 35 µg/L geometric mean.”
Section 4.4.2.1 of the SAC TSD provides the following details regarding individual station analysis
completed by the SAC.

…Compared with other approaches, the use of individual stations increases the
homogeneity of water within an AU, which is an important characteristic of AUs as
recommended by USEPA (2005). The single station approach also avoids averaging that can
mask temporal and/or spatial changes in chl a concentration. Accordingly, an individual-station
approach will generally be more sensitive to detecting chl a related changes that occur at specific
locations within the reservoir. The individual station approach will also be better able to detect
chl a related problems that result from changes in the spatial distribution of nutrient loading to
the lake from loading hot spots or changing development patterns in the watershed.

Because the highest-chlorophyll station would tend to control a reservoir TMDL, an individual
station approach for delineating AUs will generally require higher levels of nutrient reduction
than approaches that would average the chl a goal over larger segments. To this extent, the
individual station approach is more environmentally conservative with respect to potential
7

harmful effects of excess algae (e.g., toxins, bloom events, etc.). An estimate from the Monte
Carlo analysis is that applying the criterion using individual stations for AU specification rather
than the limnological AU specification will decrease the prevalence of chl a values above 40
μg/L from 11.7% to 0.7% (Table 4.3)….

These excerpts from the SAC TSD highlight the conclusions supporting the final selection of a 35 µg/L
from within the range of 25-40 µg/L that reflected much of the SAC’s discussion over the years.
Although the final value appears higher than criteria in other nearby states, the Department’s proposal to
base assessment units on areas associated with each sampling station with each station-based assessment
unit required to meet the criterion – combined with the spatial heterogeneity in chl a values typically
observed across these stations – suggests that the majority of the lake would have chl a levels below 35
µg/L if the sampling station with the highest chl a value was meeting the 35 µg/L criterion. In other
words, the end result is that some portions of the lake will reflect values lower than the magnitude of 35
µg/L when all portions of the lake are at a level no greater than the adopted criterion. Furthermore,
recognizing that the lake is generally exceeding the adopted criterion based on current, historical
information at this time, weight was given to the fact that low algal toxin levels observed in summer of
2016 suggest that the lake supported the public water supply and primary contact recreation uses in 2016
when chl a levels were higher than 35 µg/L. However, given the limited algal toxin data, it is also
possible that additional information in the future could result in a different conclusion. Finally, although
scientific evidence is inconclusive to estimate the degree to which aquatic species diversity and
abundance would shift upon implementation of the 35 µg/L criterion, based on EPA’s evaluation of the
available information, the anticipated balance between the productivity and diversity of the fish
community at the 35 µg/L magnitude is expected to support the full aquatic life use for this reservoir
aquatic life community.

In addition to the above spatial analysis considerations, the SAC TSD also discusses the effects of the
adoption of the site-specific criterion on the designated uses in HRL. Page 51 of the SAC TSD
highlights that the “risk of a potential modest reduction in fisheries production [is] an acceptable
tradeoff for the reduction in risks associated with the current high level of phytoplankton biomass (e.g.
potential for cyanobacterial blooms and toxin production).” And although there are no potable water
intakes directly associated with HRL, the SAC TSD indicates the downstream water supply use
associated with the lake downstream from HRL (and includes a downstream intake for the Town of
Denton) continues to be met. The analysis completed by the SAC also concluded on page 53 that
“although water clarity was dominated by suspended sediment in much of the reservoir, chl a reduction
from ~70 to ~40 ug/L could cause modest increases (0.1 – 0.3 m) in Secchi depth in parts of the
reservoirs in some years or hydrologic conditions.”

In the supporting documentation, the SAC and DWR were able to document their considerations with
regard to designated use protection endpoints, the improved water quality associated with future
reductions to meet the site-specific criterion, and the consideration of applying the criterion to individual
stations to better detect changes in the HRL system. As a result, the adoption of a 35 µg/L magnitude
represents a scientifically defensible conclusion based on the available literature information and
considerations of the site-specific information within HRL.

Frequency

The provision provides that HRL’s chl a concentration is “not greater than one exceedance of a growing
season geometric mean…within a three year period.” To acknowledge year to year variability in chl a
8

concentrations, the state plans to collect data from at least two growing seasons. For assessment
certainty, the DWR TSD clarifies that a minimum dataset of two seasonal geometric means is needed.
Table 1 in the DWR TSD further explains their expectations in making assessment decisions as
“[acknowledging] year-to-year variability in chlorophyll a concentrations and the need for more than
one year of data before making decisions.” Because the criterion allows for one excursion in a three-year
period, the presence of either two or three excursions in a three year period would demonstrate that the
criterion was not being met and therefore impaired.

The state’s indication that a minimum dataset of two seasonal geometric means within a three-year
period is required for decisions is a moot point in the case of High Rock Lake as the modeling indicates
reductions will be needed to meet the site-specific criterion that has been adopted. The EPA’s approval
of a “not greater than 1 in 3” frequency will ensure the designated uses for HRL are protected by not
allowing multiple excursions above the adopted growing season geometric mean. Future assessment
methodologies for HRL or any waterbody which consider sufficiency and/or reliability of information
should be consistent with the CWA-effective WQS, section 303(d) of the Act, and related guidance.

Sampling and Location Details

The site-specific chl a provision details of sub-item (b)(ii) through (v) state that samples be collected in
a minimum of five different months during the growing season with a minimum of two growing season
geometric means collected, that those samples be based on samples collected in the photic zone and as a
composite sample, and a definition of photic zone, defined as “the surface down to twice the Secchi
depth.” Additionally, sub-item (v) includes specificity on how to address data that does not satisfy sub-
item (iv). Provisions (b)(ii) and (b)(v) are related to data sufficiency requirements and do not establish or
revise the magnitude, duration or frequency of the revised criterion. Therefore, the EPA has concluded
that (b)(ii) and (b)(v) do not constitute new or revised water quality standards subject to CWA section
303(c) review.

However, since provisions (b)(iii) and (b)(iv) provide specificity and definition related to the expectation
of the use of the photic zone for sampling, the EPA concluded these two provisions further define the
desired condition and therefore, constitute new or revised water quality standards and are subject to
CWA section 303(c) review. Just as it was appropriate to define a growing season time period when
conditions are expected to be conducive for algal growth, measuring chl a concentrations in the water
column, specifically the photic zone, moving forward ensures the data most representative of the data
used in the development efforts for the revised criterion continues to be used. As a result, these two
provisions represent a reasonable consideration for the HRL chl a criterion.

The adopted provision also specifies the location to which the site-specific chl a criterion for HRL will
apply as part of the introductory text in (4)(a). The index numbers provided correspond to the defined
extent of HRL in the NCDP and already appear as part of the Department’s classification system for
these waters. The segments incorporate the mainstem of the lake and its tributaries identified as part of
HRL. Defining the precise location to where the site-specific criterion applies will ensure the criterion is
correctly applied and therefore is an important component of this site-specific criterion adoption. In the
DWR TSD, the state discusses an existing narrative statement at 15A NCAC 02B .0211(2), which states
“The conditions of waters shall be such that waters are suitable for all best uses specified in this Rule.
Sources of water pollution that preclude any of these uses on either a short-term or long-term basis shall
be deemed to violate a water quality standard.” DWR explains that this narrative statement will protect
9

any shallow waters, isolated coves, seasons, or instances not covered by the, site-specific, seasonal
geomean criterion for HRL.

Conclusion

After reviewing the SAC TSD and DWR TSD, the EPA concludes that the site-specific chl a criterion
reflects a scientifically defensible numeric nutrient criterion for HRL and will protect for the reservoir’s
designated uses. The site-specific chl a provision is therefore consistent with section 303(c) of the Act
and 40 C.F.R. Part 131, including section 131.11(b)(1)(iii), which allows adoption of water quality
criteria by states based on other scientifically defensible methods.

Part III - EPA’s Conclusions

Based on the reasons outlined above, it is our conclusion that the requirements of the CWA and 40
C.F.R. Part 131 have been met and the revisions are therefore approved.

_____________________ ___________________________
Date Denisse D. Diaz, Acting Director
Water Division