Abstract

In 1987, the Colorado Water Quality Control Commission conducted a triennial review of the water quality standards. The Denver Water Board petitioned the commission to revise standards for cadmium, lead, and silver in a segment of the South Platte River. After hearings, the commission changed the silver standard from 0.0001 to 0.0002 mg/L. The standard was based on mean only, rather than on ambient water quality (the statistical methodology of the mean plus a standard deviation (X + S). The commission had concluded that X + S may be underprotective because of the extreme variability of the available data base. The ruling was challenged, and the trial court reversed the new rule.

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