<think>.pdf

On March 17, 2009, the writer objects to the NCRWQCB staff's recommendation to list Lake Shastina as impaired for mercury. The listing is based on a single day's 2000 fish tissue sampling by CDF&G using three different testing methodologies at one of four labs, data nearly nine years old. The writer states the testing methodology is questionable and results could change significantly due to environmental factors like forest fires or water chemistry shifts. Listing would mandate an undefined future TMDL for methylmercury (MMHg) without peer-reviewed protocols for monitoring water chemistry, making it a bookkeeping exercise imposing undefined obligations. The writer notes MMHg bioaccumulates up the food chain but health risks from natural exposure are mixed across studies (Faroe Islands showing neurological issues, New Zealand showing subtle effects, Seychelles showing none), and man-made exposures are rare and severe. The California OEHHA's efforts to label tuna with MMHg warnings were rejected by a court in January 2009, and their risk model relies heavily on statistical models rather than epidemiological data. The writer concludes Lake Shastina's situation differs fundamentally from the Trinity River, which has a confirmed mercury mine source, and characterizes the recommendation as regulatory harassment stemming from unfounded environmentalist allegations previously proven false.