Summary Report of Tribal Consultation

for the Proposed Rule:
Water Quality Standards
Regulatory Revisions
to Protect Tribal Reserved Rights

U.S. Environmental Protection Agency

October 2021


-------
Jilts

Introduction	3

Consultation and Coordination	3

Information Sharing and Engagement	4

Individual Consultation and Coordination Meetings	4

Written Comments	5

Themes Emerging from Consultation Meetings and Comment Letters	6

Appendix A: Notification of Consultation and Coordination Letter Sent to Tribes on June 11, 2021.... 11

2


-------
Introduction

This consultation report was prepared to support EPA's proposed rule Water Quality Standards
Regulatory Revisions to Protect Tribal Reserved Rights.

EPA initiated a 90-day pre-proposal tribal consultation and coordination period by sending a
"Notification of Consultation and Coordination" letter on June 11, 2021, to all 574 federally
recognized tribes as of that date. The consultation period began on June 15, 2021 and ended on
September 13, 2021. EPA conducted the consultation and coordination process in accordance
with the EPA Policy on Consultation and Coordination with Indian Tribes
(https://www.epa.gov/tribal/epa-policv-consultation-and-coordination-indian-tribes).

In addition to two national tribal listening sessions held in July and August 2021, EPA
presented at 20 meetings of tribal staff and leadership, held seven staff-level
coordination/engagement meetings, and held seven leader-to-leader meetings. EPA continued
outreach and engagement with tribes at national and regional tribal meetings after the end of the
consultation period. EPA considered all pre-proposal tribal input received as it developed the
proposed rule.

This report summarizes the consultation and outreach conducted with tribes prior to
development of a proposed rule as well as comments provided by participants at tribal meetings
and the written comments received during the pre-proposal tribal consultation period. The
summary is intended to provide a description of the wide range of comments received from
tribes and tribal organizations as part of this consultation process.

sultation and Coordination

On June 11, 2021, EPA sent a Tribal Consultation Notification letter inviting tribal officials to
participate in consultation and coordination events and provide comments to EPA. The letter
(Appendix A) was sent to all 574 federally recognized tribes as of that date. EPA also notified
tribes of the consultation via the Tribal Consultation Opportunities Tracking System on the
EPA Tribal Portal (http://tcots.epa.eov). The letter invited tribal leaders and designated
consultation representatives to participate in the tribal consultation and coordination process.

EPA consulted with tribes to gain an understanding of tribal views on a potential rulemaking to
revise the federal water quality standards regulation to explain how tribal reserved rights to
aquatic and aquatic-dependent resources must be protected when states and EPA are
establishing and revising water quality standards and to solicit their comments on potential
provisions of a proposed rule. Due to the ongoing pandemic, EPA participated in all meetings
virtually.

The consultation period ended on September 13, 2021, though EPA continued outreach with
tribes as well as consultation with individual tribes after the close of the consultation period. In
addition, EPA continued to accept both individual requests for consultation and tribal
consultation comment letters after the close of the consultation period.

3


-------
Information Sharing and Engagement

EPA engaged tribes at 20 meetings of tribal consortia and regional tribal operations
committees (RTOC) and held two national listening sessions for tribal representatives.
Table 1 below lists the title and date of each information sharing meeting EPA
participated in.

Table I: Information Sharing and Tribal Engagement Meetings

Date

July 12, 2021
July 13, 2021
July 13, 2021
July 14, 2021
July 14, 2021
July 15, 2021
July 19, 2021
July 21, 2021
July 22, 2021

August 4, 2021
August 4, 2021
August 11, 2021
August 11, 2021

August 23, 2021

August 24, 2021
August 26, 2021
September 10, 2021
September 22, 2021
September 27, 2021

Event

Region 2 Tribal Nations Listening Session

Region 6 Regional Tribal Operations Committee (RTOC) Meeting
Washington Coordinated Tribal Water Quality Program/NWIFC
Region 5 RTOC Meeting

National Tribal Water Council - EPA Monthly Call

Region 10 RTOC Meeting

First National Listening Session for Tribes

Region 7 RTOC Meeting

Region 9 RTOC Meeting

Region 4 RTOC Meeting

EPA National Tribal Caucus

Region 1 RTOC Meeting

National Tribal Water Council

Second National Listening Session for Tribes

Follow Up Call with Region 9 Tribal Caucus/RTOC

Region 8 RTOC Meeting

Great Lakes Indian Fish and Wildlife Commission

EPA Tribal Wetlands Workshop

National Tribal Caucus-Office of Water 1-on-l

November 17, 2021 Oregon Tribal Environmental Forum

EPA provided the same background information at each meeting via powerpoint presentation
except the September 27 National Tribal Caucus Office of Water 1-on-l, where background
was summarized verbally. Representative copies of the presentations are available in the docket
for this proposed rule.

Staff from EPA's Office of Water, Office of International and Tribal Affairs, and the respective
EPA Regional offices participated in these meetings.

Individual Consultation and Coordination Meetings

A total of 18 tribes requested individual consultation or staff-level coordination. Table 2 below
lists the staff-level coordination meetings that EPA held, and Table 3 below lists the leader-to-
leader meetings that EPA held.

4


-------
In two instances, EPA was unable to schedule consultation meetings where the tribe did not
follow up after multiple outreach attempts.

Table 2: Skiff-Level Engagement Meetings
Date	Tribe

August 12, 2021 Swinomish Indian Tribal Community

August 25, 2021 Little Traverse Bay Bands of Odawa Indians

September 1, 2021 Confederated Salish and Kootenai Tribes of the Flathead Nation

September 1, 2021 Leech Lake Band of Ojibwe

September 10, 2021 Listening Session for Tribes Located in EPA Region 5
September 20, 2021 Little River Band of Ottawa Indians
October 25, 2021 Squaxin Island Tribe

Table 3: Leader-to-Leader Meetings

Date

August 10, 2021
September 9, 2021
September 15, 2021
September 16, 2021
September 16, 2021
September 21, 2021

September 28, 2021

Tribal Nation

Lac du Flambeau Band of Lake Superior Chippewa
Houlton Band of Maliseet Indians
Makah Tribe

Pokagon Band of Potawatomi Indians
Summit Lake Paiute Tribe

Chickaloon Native Village, including staff from Eklutna
Native Village, and Seldovia Village Tribe
Nez Perce Tribe

EPA provided the same background information at each meeting via powerpoint presentation.
Representative copies of the presentations are available in the docket for this proposed rule.

Staff from EPA's Office of Water, Office of International and Tribal Affairs, and the respective
EPA Regional offices participated in these meetings. Staff from the Office of General Counsel
also participated in some leader-to-leader meetings.

Following each leader-to-leader meeting EPA sent tribal leadership a follow up letter thanking
the tribe for consulting with EPA and summarizing the tribe's comments during the discussion.

Written Comments

EPA received pre-proposal comment letters from the following tribes and tribal organizations:

•	Choctaw Nation of Oklahoma

•	Columbia River Inter-Tribal Fish Commission

•	Confederated Salish and Kootenai Tribes of the Flathead Nation

•	Confederated Tribes of the Umatilla Indian Reservation

•	Fond du Lac Band of Lake Superior Chippewa

•	Great Lakes Indian Fish and Wildlife Commission

5


-------
•	Houlton Band of Maliseet Indians

•	Lac du Flambeau Band of Lake Superior Chippewa Indians

•	Leech Lake Band of Ojibwe

•	Little River Band of Ottawa Indians

•	Little Traverse Bay Bands of Odawa Indians

•	Makah Tribe

•	Mille Lacs Band of Ojibwe

•	National Tribal Water Council

•	Nez Perce Tribe

•	Onondaga Nation

•	Penobscot Nation

•	Red Cliff Band of Lake Superior Chippewa Indians

•	Seneca Nation

•	Snoqualmie Tribe

•	Yakama Nation

All letters submitted are available in the docket for this rulemaking at Docket ID No. EPA-
HQ-OW-2021-0971.

1 liKniies Emerging from Consultation Meetings and Commem II '-iters

This section summarizes the key themes of comments received through the tribal
consultation process, including feedback provided by tribes during information sharing and
engagement, staff-level coordination and leader-to-leader consultation meetings as well as
written feedback provided in comment letters. Nearly all commenters were supportive of
the potential rule in concept. EPA considered all pre-proposal tribal input in developing the
proposed rule.

1. Concerns about water pollution and importance of clean water to protect tribal
reserved resources and lifeways

Many commenters stated that clean water is essential to tribal lifeways, including sustenance
fishing, commercial fishing, and cultural uses, and stressed the need for clean water to exercise
their reserved rights to their lifeways.

•	Several commenters stated that the risk to human health from consumption of
contaminated fish is a key concern of tribal governments and many individual tribal
members.

•	Some tribes stated their commitment to protecting water quality for current and future
generations.

•	Tribes mentioned wild rice, salmon, and other marine and freshwater fish as resources
central to their lifeways.

•	Some commenters noted that pollution has compromised tribes' ability to live their
lifeways as understood by their ancestors, including noting that fish consumption
advisories signify a violation of tribal reserved rights.

6


-------
•	Some tribes emphasized the need to protect waters adjacent to and connected with
waters where reserved rights apply.

•	Some commenters requested that EPA consider cumulative impacts of both point
and nonpoint sources of pollution to migratory species that move through the
territorial waters of different states and countries.

•	Some commenters stated that the federal trust responsibility requires EPA to
protect tribal reserved rights when it promulgates or approves WQS.

•	Some commenters noted that nutrient pollution is a key obstacle to exercising their
reserved rights

•	One commenter noted the importance of water quantity, which affects parameters
such as dissolved oxygen and temperature, which are key for juvenile fish in small
freshwater streams.

2.	Request for clarification about the mechanisms for updating state WQS to comply

with the new regulatory requirements

Many tribes and tribal organizations asked questions about the mechanisms for states to come
into compliance with the new regulatory requirements.

•	Some commenters asked how the new regulatory requirements would be integrated into
state triennial water quality standard reviews.

•	Some commenters expressed frustration with a lack of response to tribal concerns
and protection of tribal interests in their state's WQS revision process.

•	Some commenters asked what recourse tribes would have if states fail to update their
WQS in a timely manner to comply with the new regulatory requirements.

•	One tribe requested that the rule include mechanisms for tribes to petition the agency on
these issues.

•	Some tribes asked how WQS variances and other WQS policies would be affected by
the rule.

•	Some commenters expressed disagreement with the Clean Water Act construct
providing states primacy in establishing WQS for their own waters. Some
commenters disagreed with EPA's previous case-specific conclusions that the state
had WQS jurisdiction in waters of their reservations and trust lands.

3.	The need for WQS to reflect unsuppressed exercise of tribal reserved rights

Several commenters stated that the proposed regulation should protect the intended or
traditional uses of a water body, including historical fish consumption rates, which may not be
the same as current tribal uses of that water body due to factors including fish contamination
and tribal citizens' awareness of that contamination; water pollution generally; reduced or
altered fish populations in accessible water bodies; improper application of fishing restrictions
to tribal fishers; and access issues.

4.	Clarification about how the extent of reserved rights will be determined

Several written commenters and meeting participants asked how the extent of tribal reserved
rights will be determined and who would be responsible for making such determinations.

7


-------
•	One commenter recommended that EPA should clarify that protections for
subsistence fishing, traditional gathering, and other cultural uses apply whether or
not a tribe has articulated specific water quality standards applicable to its current
territory or has been authorized to implement its own CWA program.

•	Several commenters noted the need for meaningful consultation with affected tribal
reserved right holders on the scope and definition of their reserved rights.

•	Some commenters noted that EPA cannot delegate its trust responsibility to consult with
tribes and protect tribal reserved rights to states, noting that tribes' government-to-
government relationship is with the federal government rather than states.

•	Some commenters requested clarification about how EPA will minimize litigation risk
that could impact reserved rights.

•	Some commenters requested clarification about how EPA will ensure the regulation is
flexible enough to accommodate different treaties and other relevant sources of law.

•	Some commenters asked whether EPA would consult the Department of Interior for
such determinations.

•	One commenter requested that in framing the proposed regulation, EPA should
clarify that reserved rights are derived from the tribes' sovereign status and were
preserved, not created, by the underlying treaties.

•	Some commenters recommended that EPA ensure that permits for activities upstream of
waters where tribal reserved rights apply protect those rights.

•	Some commenters asked how EPA intends this rule to apply to tribes without rights
under federal law and/or recommended that EPA provide equivalent protection to
resources used by all tribes regardless of existing legal recognition of those rights, based
on their inherent sovereignty, recognizing that tribes have fished, hunted and gathered
in and around waters since time immemorial, and that rights that were never ceded are
retained.

5. Clarification about how the level of water quality necessary to protect tribal reserved

rights will be determined

Many commenters requested clarification about how the level of water quality necessary to
protect tribal reserved rights will be determined, who will be responsible for such
determinations, and what will happen in the event of disagreement between the relevant state(s)
and tribe(s).

•	Some commenters sought clarification about what minimum threshold or bar would
be set in the revised regulation for protection of tribal reserved rights.

•	Some commenters recommended specific thresholds to protect tribal reserved
resources, including that for the purpose of establishing human health criteria, the
cancer risk level be no less than 10"6 and tribes be treated as the target population;
that EPA establish a fish consumption rate floor of 175 g/day for waters in ceded
territories in the Pacific Northwest; that state designated uses must protect tribal
reserved rights; and that EPA should prioritize designation of Tier 3 waters.

•	Some commenters requested that EPA update its 2000 Methodology for Deriving
Ambient Water Quality Criteria for the Protection of Human Health to reflect the

8


-------
above recommendations for calculation of human health criteria for waters covered
by tribal reserved fishing rights.

•	Some commenters expressed concern that the option to establish designated uses to
protect tribal reserved resources could be implemented with an inadequate standard
of protection.

•	Some commenters requested that traditional ecological knowledge be included as a
type of data to consider under this regulation.

•	Several commenters sought clarification about how EPA would reconcile differences of
opinion about the level of water quality necessary to protect reserved rights where
multiple tribes hold reserved rights in the same geographic area, in some cases covering
multiple states, if there is disagreement about the necessary level of protection. For
example, there may be differing fish consumption rates in different parts of a state or
between different tribes whose ceded territories or usual and accustomed areas overlap.

o Some commenters raised concerns that this could result in a patchwork of
different levels of protection for the same reserved resources across different
states.

o Some tribal representatives suggested that in such situations EPA should, in
consultation with affected tribes and impacted states, implement consistent
WQS across all jurisdictions.

•	Several commenters recommended that EPA specify in regulation that the level of
CWA protection can be defined by available data or data that can be acquired
through typical monitoring or relevant environmental information systems (i.e.,
GIS, LiDAR).

•	One commenter recommended that instead of insisting that states "adopt"
designated uses that reflect treaty-protected use rights or rights created by federal
law or executive action, EPA should require states to recognize these rights as pre-
existing designated uses which were created outside the CWA.

•	Several commenters recommended that EPA should provide technical and funding
support for any additional studies or data collection needed to determine the water
quality standards necessary to protect tribal reserved rights.

6.	Clarification about how this rule will impact water rights

Several tribes with water rights requested clarification about how this rule would impact
adjudicated water rights and/or urged EPA to ensure this change to the WQS regulations would
protect flow sufficient to effectuate tribal reserved rights to aquatic and aquatic-dependent
resources.

7.	Clarification about implementation

Several commenters requested information about how the new regulation would be
implemented in other CWA programs such as National Pollutant Discharge Elimination System
(NPDES) permits and Section 401 certifications, as well as how it would lead to cleaning up
existing pollution problems.

•	Some commenters requested that EPA revise its interpretation of the 401 certification
regulations to allow tribes to object to or condition permits that would impair their

9


-------
reserved rights in both reservation waters and ceded territories, even when those rights
were not protected by existing WQS.

•	Some tribes recommended that EPA should consult with the potentially affected tribe(s)
as to any impact a permitted activity might have on the tribe's reserved rights.

•	Some tribes requested that EPA address states' failure to implement existing WQS in
other CWA programs.

•	One commenter recommended that EPA institute a process by which tribes can
nominate high quality waters in areas where retained rights are held, modeled on
the framework of the Tribal Forest Protection Act of 2004.

•	One commenter recommended that EPA should require states to develop long-term
plans in collaboration or in close consultation with affected Native Nations to bring
affected water bodies into (or closer to) compliance.

•	Several commenters recommended that EPA allow for tribal co-management of
water resources on federal lands where tribes reserve rights.

8.	How would this rule apply to a specific tribe or situation?

Several tribes requested clarification about how this rule would apply to their specific situation.

•	Several tribes asserted in written comments that they have reserved rights to aquatic and
aquatic-dependent resources in areas where states have WQS jurisdiction, including in
portions of the Great Lakes, Maine, Idaho, New York, Minnesota, Michigan,

Wisconsin, Montana, Oregon, Idaho, Washington, Wyoming and Alaska.

9.	Comments related to the process for developing the rule

EPA received several comments related to the process for developing the proposed and final

rules.

•	Some participants suggested that EPA co-draft the rule with tribes, noting the value that
tribes can provide in such a process. Several commenters and meeting participants
wanted to review rule language as it was being developed or requested pre-proposal
discussion of possible regulatory text.

•	Some commenters expressed a lack of trust in EPA and the U.S. government
generally to have their best interests at heart or fully understand their needs.

•	Some commenters expressed frustration with the number of initiatives on which
EPA is simultaneously requesting their input.

•	Some commenters requested that EPA provide an opportunity for further government-
to-government consultation prior to publication of a proposed rule in the Federal
Register for public comment.

•	One commenter requested that pre-proposal feedback from states be made
accessible to tribes prior to, or no later than the time of, publication of the proposed
rule in the Federal Register.

•	Some commenters recommended that EPA provide guidance to the states on
identifying and protecting tribal reserved rights to aquatic and aquatic-dependent
resources.

•	One commenter recommended that EPA initiate three-way conversations between the
tribe, EPA and the state on these regulatory revisions.

10


-------
>1 .| -endix A: Notification		 .nsultation and Coordination Letter Sent i • 11 ill»• on June

1

11


-------
*t0,x

UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF WATER

Re: Notification of Consultation and Coordination on Potential Revisions to the Federal Water
Quality Standards Regulations to Protect Tribal Reserved Rights

Dear Honorable Leader,

The U.S. Environmental Protection Agency (EPA) is initiating consultation and coordination with
federally recognized Indian tribes to inform potential revisions to the federal Clean Water Act (CWA)
water quality standard (WQS) regulations. Many tribes, through treaties and equivalent agreements
with the U.S. government, hold reserved rights to aquatic or aquatic-dependent resources in waters
outside the boundaries of federal Indian reservations, or in areas otherwise subject to state and federal
jurisdiction. EPA's Office of Water is considering pursuing a change to the federal WQS regulations at 40
CFR Part 131 to explicitly and sustainably protect tribal reserved rights in state waters, consistent with
existing legal obligations.

This action is separate from and complementary to EPA's concurrent action to establish baseline WQS
under the CWA for waters on Indian reservations that currently do not have EPA-approved WQS in
place. EPA is initiating a concurrent 90-day tribal consultation period for that complementary action.

This consultation and coordination process will be conducted in accordance with the EPA Policy on
Consultation and Coordination with Indian Tribes (https://www.epa.gov/tribal/epa-policv-consultation-
and-coordination-indian-tribes). EPA invites you and/or your designated consultation representative(s)
to participate in this process. The 90-day consultation period begins on June 15, 2021 and ends on
September 13, 2021. EPA will continue to consider comments received after the close of the
consultation period to the extent possible as EPA moves forward with decision-making. Pending the
input that EPA receives during the tribal consultation period, EPA anticipates proposing this rule in early
2022. This will provide an additional opportunity for tribes to comment during the public comment
period on the proposal.

EPA will hold a listening session via webinar for tribal leaders and staff on July 19, 2021 from 3:00-5:00
pm (EDT). You can register for the webinar here. While listening sessions do not constitute individual
tribal-EPA government-to-government consultation, it is hoped the sessions will provide further
information to tribes to make an informed decision about whether to request an individual consultation.

EPA plans to hold a second listening session via webinar towards the end of the consultation period. EPA


-------
plans to announce the date and time of the second webinar in early August and anticipates scheduling
the webinar to occur in late August or early September. Updates on the second webinar will be posted
to: https://www.epa.gov/wqs-tech/protecting-tribal-reserved-rights-in-WQS.

EPA invites interested tribal governments to request individual government-to-government consultation
with EPA by contacting:

Jennifer Brundage at Brundage.Jennifer@epa.gov/(202) 566-1265 or
Karen Gude at Gude.Karen@epa.gov/(202) 564-0831.

In order to provide time to schedule consultations prior to the close of the consultation period, please
provide such requests by August 23, 2021. Given that this is a national consultation including all tribes
and the United States is recovering from the pandemic, we anticipate that most if not all consultations
will need to be conducted virtually.

Enclosed is a consultation and coordination plan that provides additional background and detail about
the proposal that EPA is considering and the process that EPA intends to follow, including information
on how you can provide input on this potential action. This information is also available in EPA's Tribal
Consultation Opportunities Tracking System (TCOTS) at https://tcots.epa.gov.

Please contact our official EPA representative for this consultation and coordination process, Jennifer
Brundage (Brundage.Jenniferffiepa.gov) at (202) 566-1265, if you have any questions or would like to
request alternate arrangements to the process outlined in the consultation and coordination plan. We
look forward to hearing from you.

Sincerely,

Deborah G. Nagle, Director
Office of Science and Technology

cc: Tribal Environmental Directors and Natural Resource Directors
EPA Regional Indian Coordinators

Enclosure

2


-------
Consultation and Coordination Plan for Potential Revisions to the Federal Water Quality Standards

Regulations to Protect Tribal Reserved Rights

Overview

EPA is examining how it could revise the federal water quality standards (WQS) regulations to explain how
applicable tribal reserved rights are to be considered when states or EPA are establishing and revising WQS.

The proposed regulatory revisions would be relevant to situations where tribes have reserved rights to aquatic
or aquatic-dependent resources in waters where states have jurisdiction to establish WQS. This is separate from
and complementary to EPA's concurrent action to establish baseline WQS under the Clean Water Act (CWA) for
waters on Indian reservations that currently do not have EPA-approved WQS in place. EPA is initiating a
concurrent 90-day tribal consultation period for that complementary action.

Background information on the initiative

In 2016, after consultation and coordination with tribes, EPA concluded that WQS must comply with both the
CWA and any applicable tribal reserved rights. For example, in Washington and Maine, EPA concluded that the
states' human health criteria must be set at levels that would make fish safe to eat in subsistence/sustenance
quantities in waters where reserved rights to fish for subsistence/sustenance exist. In both Washington and
Maine, EPA disapproved the state's WQS and promulgated federal WQS that reflected the Agency's conclusion
regarding protection of tribal reserved rights.

EPA's actions in Maine and Washington were both state-specific actions where EPA's reserved rights rationale
was set forth in preamble language, rather than in regulation. The agency took a different position on this issue
in subsequent years, which has resulted in uncertainty with respect to how states and EPA must reconcile
existing legal obligations.

In his January 26, 2021 memorandum, Tribal Consultation and Strengthening Nation-to-Nation Relationships,
President Biden committed to fulfilling federal trust and treaty responsibilities to tribal nations. Building from
that commitment, EPA is renewing its emphasis on protecting tribal reserved rights to water resources and is
interested in restoring the 2016 paradigm of harmonizing WQS with tribal reserved rights in a transparent and
sustainable way. In that spirit, EPA is now considering amending the nationally-applicable federal WQS
regulations to explain how WQS actions must be harmonized with applicable tribal reserved rights where those
rights to a particular resource exist and are implicated.

EPA is considering proposing the following concepts in its amendments to the WQS regulations at 40 CFR Part
131:

•	The requirement that states and EPA must not impair tribal reserved rights when establishing, revising,
and evaluating WQS.

•	The requirement that if reserved rights exist in the geographic area where a given set of WQS will apply,
and the rights are related to a certain level of CWA protection that can be defined by available data,
upholding those rights requires providing that level of CWA protection.

•	Requirements outlining that the scope/definition of these reserved rights and their protection must be
informed by consultation with the affected tribe(s).

•	Providing options for regulatory approaches that states and EPA can use to ensure tribal reserved rights
are protected:

o Designated uses that explicitly incorporate protection of resources covered by tribal reserved
rights.

3


-------
o Criteria that protect tribal reserved rights in waters where those rights apply,
o Assignment of Tier 3 antidegradation protection (i.e., requirement to maintain and protect
current and future improved water quality) in waters where tribal reserved rights apply and
where current water quality is sufficient to protect those rights.

EPA is interested in your feedback on these specific concepts to ensure that we take all relevant considerations
into account in this effort. EPA also anticipates soliciting pre-proposal feedback from states, since the rule will
have implications for how states establish and revise WQS.

Potential benefits of this rulemaking

The goals of revising the federal WQS regulation are:

•	Provide sustainable protection of tribal reserved rights.

•	Provide clarity and transparency about how states and EPA must protect tribal reserved rights when
establishing and revising WQS.

Opportunities for tribes to participate

The consultation period on this proposal will remain open for 90 days and will include two listening sessions via
webinar.

EPA will hold a listening session via webinar for tribal leaders and staff on July 19, 2021 from 3:00-5:00 pm
(EDT). You can register for the first webinar here. EPA plans to hold a second listening session via webinar
towards the end of the consultation period. EPA plans to announce the date and time of the second webinar in
early August and anticipates scheduling the webinar to occur in late August or early September. The final date
and time along with registration information will be 1) posted on EPA's website for this rulemaking, and 2)
shared with those who register for the first webinar on July 19.

The webinars will provide tribes and tribal leaders an opportunity to ask questions, learn more about this
consultation opportunity and the potential revisions, and share their views.

Tribes may submit written comments to Jennifer Brundage at Brundage.jennifer@epa.gov.

Tribes may access this letter and related consultation information in EPA's Tribal Consultation
Opportunities Tracking System (TCOTS) located at https://tcots.epa.gov.

EPA's goal is to provide sufficient information for tribal leaders and their designated consultation
representative(s) to make an informed decision about the desire to continue with government-to-
government consultation and to understand how to provide informed input. At any point during the
consultation period EPA invites tribal nations to request government-to-government consultation with EPA.
Tribes may request consultation for this potential rulemaking as well as the concurrent tribal baseline
rulemaking at the same time. EPA looks forward to working with federally recognized tribes to better
understand their needs and answer questions related to the potential revisions to the federal WQS
regulation.

The information that you provide during the consultation period will help inform our forthcoming rule
proposal. Whether or not you participate in this consultation and coordination process, you will still have the
opportunity to provide input on the forthcoming proposed rule, which we anticipate will be available for
public comment in early 2022. The proposed rule will be published in the Federal Register, accessible at

4


-------
regulations.gov, and available on EPA's website here.

Tribal Consultation and Coordination Process and Timeline

Date/Time

Event

Contact Information

June 15, 2021

Initiation of the 90-day tribal
consultation period. Consultation
notification letters are emailed to
tribal leaders.

EPA Contact: Jennifer Brundage
(202)566-1265
(Brundage.Jennifer(3epa.gov)

July 19, 2021
3:00-5:00 PM (EDT)

Webinar #1 for Tribal
Leaders and Staff:

Proposed Water Quality
Standards Regulatory Revisions
to Protect Tribal Reserved Rights

EPA Contact: Jennifer Brundage
(202)566-1265
(Brundage.Jennifer@epa.gov)

To register, please visit EPA's
website for this rulemaking
(https://www.epa.gov/was-
tech/protecting-tribal-reserved-
rights-in-WQS).

Date and Time TBD
Anticipated late
August or early
September

Webinar #2 for Tribal Leaders and
Staff (same content as Webinar
#1):

Proposed Water Quality
Standards Regulatory Revisions
to Protect Tribal Reserved Rights

EPA Contact: Jennifer Brundage

(202)566-1265

(Brundage.Jennifer(3epa.gov)

Final date and time along with registration

information will be 1) posted on EPA's website for

this rulemaking at https://www.epa.gov/wqs-

tech/protecting-tribal-reserved-rights-in-WQS, and

2) shared with those who register for the first

webinar on July 19.

September 13, 2021

Close of formal tribal
consultation and coordination
period.

Any written comments must be received by this
date. Please send comments via e-mail to Jennifer
Brundage Brundage.iennifer@epa.gov.

5


-------