Clean Water Challenges Abound for Industry

Water Quality Standards (WQS) are the foundation for water quality pollution control under the Clean Water Act.

By Roberta Savage

Water Quality Standards (WQS) are the foundation for water quality pollution control under the Clean Water Act. States in particular continue to struggle with current federal policies for re-designating uses in a water body. Criteria development is also a complicated area with science not always working succinctly with policy. Further, many states have raised concerns about the National Criteria Documents (see: www.epa.gov/waterscience/criteria/wqcriteria.html) and recent Endangered Species Act consultation challenges. States depend on these documents to develop standards and legal vulnerabilities could undermine current and future efforts.

Water quality monitoring is essential to define water resource conditions, identify problems, design water quality management strategies, evaluate program effectiveness, and identify and characterize trends. Of the billions spent on clean water programs, only a fraction was for monitoring. After three decades, 53% of rivers and streams assessed can be characterized as “good” while 39% “impaired.” But these numbers represent only 19% of U.S. river and stream miles. For the other 81%, the picture remains obscured.

Over the past 15 years, the NPDES universe (see: www.epa.gov/npdes/) has quadrupled, vastly outpacing federal resources allocated and leaving it for states to fill the ever-widening resource gap. The nature of new “point sources” is very different from traditional industrial sources. They’re smaller, more numerous and widely distributed, and less amenable to traditional end-of pipe controls. Compound this with recent court decisions limiting and/or complicating use of the “general permit,” and it becomes increasingly evident the program must evolve, receive an enormous influx of resources or risk falling under its own weight.

Total Maximum Daily Loads (TMDLs) are essentially pollution budgets for specific river segments of a water body. The USEPA and states are scheduled to develop as many as 40,000 TMDLs over the next 15 years. This process is scientifically, legally and politically challenging and, in some cases, implementation could take a decade or more before water quality improvements are achieved.

States continue to deal with problems of failing infrastructure and the lack of resources to adequately maintain existing and future needs. Although the State Revolving Fund (SRF) programs has capitalized over $50 billion dollars in loan funds, the recent decline in federal contributions raises real concerns about its continuing growth in metropolitan areas.

States, industrial sources, and local and federal governments have worked diligently to improve water quality. The next generation of water quality problems are significantly different from those states have historically faced. These relate primarily to wet weather events from point and nonpoint sources (e.g., runoff from forests, rangelands, farm lands and urban areas). A prescriptive top-down approach will not be effective, and increasingly these water quality problems must be resolved at the watershed level.

Success requires creative use of the Clean Water Act and other legislation, including the Farm Bill, Transportation Act, Endangered Species Act and an array of state and local authorities. This entails renewed emphasis on getting better information for decision-making, increased public involvement and stewardship, and continued use of adaptive management. IWW

About the Author: Roberta (Robbi) Savage is executive director of Association of State and Interstate Water Pollution Control Administrators (www.asiwpca.org) the national, professional organization of state and interstate water quality program officials responsible for implementing the Clean Water Act. She’s also the president of America’s Clean Water Foundation, and creator of World Water Monitoring Day). For regulatory news, search www.industrialww.com - keywords: “EPA Action”.

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